CIVIL DISTRICT COURT FOR THE PARISH OF STATE or LOUISIANA 13 ?an, NO.: {His 5? CHOICE FOUNDATION A. A LAW INDUSTRIES, LLC, ET AL. FILED: DEPUTY CLERK OF COURT PETITION FOR DAMAGES Plaintiffs, Choice Foundation (?Choice?) and Orleans Parish School Board aver the folloWing in support of their Petition for Damages. OVERVIEW 1; Choice operates Lafayette Academy Charter School (?Lafayette Academy?) in New Orleans, Louisiana, which is currently controlled by OPSB. Up until the 2018?2019 school year, Lafayette Academy Was located at 2727 Carrollton Ave, New Orleans, LA 70118 (the ?Carrollton Campus?). The Federal Emergency Management Agency funded a master plan to repair or rebuild schools in Orleans Parish, which included repairs in two phases of construction at the Carrollton Campus in 2016 and 2017. At the time of construction, Lafayette Academy was controlled by the Louisiana Department of Education Recovery School District RSD contracted with Jacobs Project Management Consortium acobs/CSRS?) for Jacobs to act as the program and construction manager for the construction projects at Lafayette Academy. RSD contracted with Tuna Construction, LLC, and Tuna contracted with V.E. Keeler Associates, LLC to remove asbestos-containing ?oor tiles from four classrooms on the third ?oor of the Carrollton Campus in March 2016 (the ?Phase 1 Work?). The negligence of RSD, Jacobs, Tuna, and Keeler led to de?ciencies as outlined by the Louisiana Departmentof Environmental Quality in a July 31, 2017 report. Notably, that report was (not given to Choice until nearlya year after that date, Choice and OPSB were the subject of negative media attention. Many parents and students were upset that they were not noti?ed of the report earlier, which Choice understands led to some students switching to other schools. acobs?s mismanagement cOntinued during the second phase of construction at Lafayette Academy. During the 2017-2018 school year, RSD contracted with a different contractor, Law Industries, LLC, who subcontracted with Advanced Environmental Consulting, Inc. to perform various additional improvements at the Carrollton Campus, which included asbestos removal and replacement of the concrete ?oor ?ll system on the ?rst and second floors (the ?Phase 2 Work?) Jacobs again served as the construction manager of the project on behalf of RSD pursuant to a contract. There were major issues with the phase 2 work that forced Lafayette Academy to relocate campus. Choice and OPSB have suffered damages as result of Defendants? actions. PARTIES 2. Plaintiff, Choice, is a non?pro?t corporation organized in the State of Louisiana that is based in New Orleans, Louisiana. Choice Operates Lafayette Academy and also operates Esperanza Charter School at 4407 S. Carrollton Ave, New Orleans, LA 70119. 3. Plaintiff, a politiCal subdivision of the State of Louisiana, capable of suing, and is the current owner of the Carrollton Campus. 4. Defendant, Jacobs, is a partnership consisting of Jacobs Project Management, Inc, a Delaware corporation, and CSRS, Inc, a Louisiana Corporation, that served as the manager of the work performed at the Carrollton Campus. Jacobs? program and construction management services for the Lafayette Academy project were provided as a part of its overall contract with the RSD for the management of the $1.8 billion New Orleans school building master plan funded by FEMA. Thus, pursuant to a contract with the RSD, Jacobs served as the representative on the Phase I and Phase 2 projects at Lafayette Academy 5. Defendant, Tuna, is a Louisiana limited liability company doing business in New Orleans, Louisiana. Tuna is a general contractor that RSD contracted with to perform the Phase 1 Work, which was for various improvements, including, but not limited to, replacing windows, at the Carrollton Campus during the 2016?2017 school year. -2- 6. Defendant, V.E. Keeler Associates, LLC is a Louisiana limited liability company doing business in New Orleans, Louisiana that was the asbestos removal contractor hired by Tuna to perform the Phase 2 Work of removing asbestos?containing floor tiles from four classrooms on the third ?oor of the Carrollton Campus in March 2016. 7. Defendant, Law, is a Louisiana limited liability company doing business in New Orleans, Louisiana. Law was the general contractor that performed and/or hired subcontractor, ABC, to perform Phase 2 remodeling and asbestos removal work at the Carrollton Campus in May and June 2018 that Jacobs administered. 8. Defendant, ABC, is a Louisiana corporation doing business in New Orleans, Louisiana, and was the subcontractor who performed the Phase 2 Work at the Carrollton Campus. 9. Defendant, N-Y Associates, Inc. is a Louisiana corporation doing business in New Orleans, Louisiana and served as the architect for Phase 1 and Phase 2 Work performed at the Carrollton Campus. 10. Defendant, Colony Insurance Company, is an insurance company authorized to do business in Louisiana and issued an insurance policy or policies to Law that provide coverage for Choice?s and damages. 1 1. Defendant, Travelers Indemnity Company (?Travelers Indemnity?), is an insurance company authorized to do business in Louisiana and issued an insurance policy or policies to Tuna that provide coverage for Choice?s and damages. 12. Defendant, Travelers Property Casualty Company of America (?Travelers Property?), is an insurance company authorized to do business in Louisiana and issued an insurance policy or policies to Trina that provide coverage for Choice?s and damages. 13. Defendant, Insurance Company? is a placeholder defendant for any other insurance companies who issued an insurance policy or policies to Law that provide coverage for Choice?s and damages. 14; Defendant, Insurance Company? is a placeholder defendant for any insuranCe companies who issued an insurance policy or policies to ABC that provide coverage for Choice?s and damages. 1 5. Defendant, Insurance Company? is a placeholder defendant for any insurance companies who issued an insurance policy or policies to that provide coverage for Choice?s and damages. 1 6. Defendant, KL Insurance Company? is a placeholder defendant for any insurance companies who issued an insurance policy or policies to Jacobs that provide coverage for Choice?s and damages. 1'7. Defendant, Insurance Company? is a placeholder defendant for any insurance companies who issued an insurance policy or policies to Tuna that provide coverage for Choice?s and damages. 18. Defendant, Insurance Company? is a placeholder defendant for any insurance companies who issued an insurance policy or policies to Keeler that provide coverage for Choice?s and damages. 19. Jacobs, Tuna, Keeler, Law, AEC, Colony, Travelers Indemnity, Travelers Property, and the placeholder insurance companies may be. collectively referred to as ?Defendants? throughout the Petition. VENUE AND JURISDICTION 20. Pursuant to Louisiana Code of Civil Procedure articles 42, 73, 74, 76, and/or 76.1, venue is proper in Orleans Parish because, among other things, the wrongful conduct occurred in Orleans Parish, and Choice?s and damages were sustained here. 21. Jurisdiction is proper in this Court pursuant to Article V, ?l6 of the Louisiana Constitution, and jurisdiction is vested in this Court pursuant to Louisiana Code of Civil Procedure articles 2 and/or 6. 22. Choice and OPSB assert that the faults, acts, opinions, and/or negligence of the Defendants with respect to the construction at the Carrollton Campus caused and/ or contributed to the damages suffered by Choice and OPSB. 23. Choice is a charter school management organization established in 2004 to provide hi gh? quality public education to students in New Orleans. Choice currently serves approximately 1,800 students from pre?kindergarten through eighth grade, almost all of whom are economically disadvantaged. Choice has long been one of the leading charter management organizations in New Orleans and its schools have always maintained their commitment to providing all children with access to a high-quality, well-rounded education. 24. Choice Foundation entered into a lease with RSD. RSD was responsible? for providing a school campus to Choice Foundation to operate Lafayette Academy, and RSD selected the Carrollton Campus as the site for Lafayette Academy. Thereafter, the Carrollton Campus transitioned to OPSB, but pursuant to La. R.S. RSD maintained control of the OPSB buildings and managed the entire renovation process. 25. The Carrollton Campus, like many schools and buildings in New Orleans, contains asbestos, which is naturally occurring in the environment. Asbestos has a risk of being harmful, -5- . however, if the proper precautions are not taken and there is exposure for prolonged periods of time. Here, the Defendants knew or should have known of proper precautions but failed to adhere to them. 26. During the 2016-2017 school year, the RSD contracted with Tuna Construction, LLC to perform the Phase 1 Work for various improvements, including, but not limited to, replacing Windows, at the Carrollton Campus. Jacobs, through a contract with the RSD, served as the construction manager on the project; 27. During construction, Tuna and its subcontractors failed to submit necessary reports. 28. Tuna contracted with V. Keeler to remove asbestos-containing ?oor tiles from four- classrooms on the third ?oor of the Carrollton Campus. In March 2016, V. Keeler began that construction. 29. During that construction, Choice received complaints from faculty regarding smells and sounds that disrupted teaching and caused concern for their health. 30. Choice later learned that on March 22, 2017, Louisiana Department of Environmental Quality visited the Carrollton Campus and observed multiple violations, which were outlined in an LDEQ Asbestos Demolition/Renovation Compliance Inspection Report. These violations were attributable to V. Keeler?s negligence. Speci?cally, LDEQ found the following areas of concern: AREAS LAC 33:13.5 351.F.3.h Nu demoli?na nr'vreass'atian as?vity Iliad RACM nr shalt he conducted at regniaied by this Salasac?na unless at Ieast sue ??estas shaman-at mined in acesrdaace wish Sahsee?sa ofthis Semen rs physicaiw prawns. An super-?aw was as: nanny present at the time sf Inspection The ?acting? was found to he: with. faisi?ad paperwork. LAC EMILE I515.I.a.ii. ?ischarge no visIbIs missians is the sniside air tram calies?an, mixing, wetting, and handIing speratiaas, or last: ?re meiheds speci?ed try Sahaec?aa 0 sf this Ssc?an In dean emissiaas strumming particulsts ashasfss araIcrial before they .mape In, or are rams In, the snaf?e air. Bani prints were visihie an the floor 1116 two csntainment mas. Children wars Walking- the halIs hams the two containment areas. LAC The RMEM and any shall be adequately was, and esnralnsd In Isak-?ght, dear magma: wrapping. The mapped ?ooring auctions 'We ant Wet. MC 33: 1. After wetting, ssal all asbcsIM?mniaining waste maIarial in Sank? ?ght chair, transparent containers hangs) while wet; as, for maieriais that wit! ?t Int-e Withaus additions! breaking, put ma?erials' Isis leak-?ght. char, transparent warning, ensuring Ihai Ills ACWM is swur?y wrapped and raided. OnIy smne asbestns sustaining wast-c materials were Wat The Iar'gs sanctions were not wet or leak? ?ghI. LAC ?35121?? asbestes-sapntaiaing Waste ?:31ch in he Imusp??ed ill? the faci??y siIe, labs! or wrapped hasten-Isis with ?le slams attire waste generatsr and the Incatina at which ?re waste was generated. Generator iabefs observed on bags of maIsrial as smart? were not. legibis. Large sectisns sf ACM that had bean rammed had no genera?or IaheI at A In?ow-up Iaspcc?nn s13 3f2?a'i2m mvssE-sd that genemtnr labels stiII were not lasing Used on every bag and rammed as rsquimd 3 1 . Neither Choice nor OPSB a copy of the LDEQ report dated July 31, 2017 that outlined these Violations at the time the report was issUcd. Rather, Choice and OPSB were not advised of the issues or report until late June 2018?almost a year after the date of report. On the other hand, RSD and Jacobs were well aware ofthc report and ?ndings at the time it was issued. 32. Abatement work had to stop while Tuna, V. chler, and addressed the Violations. V. chler was allowed to continue its work on evenings and weekends. Ultimately, V. Kcelcr completed the asbestos-removal from third ?oor classrooms. LDEQ eventually certi?ed that the problems were ?xed and that there was no safety risk to students. 4 33. When the LDEQ report. was released to Choice and the public over a year later, however, many Lafayette Academy parents were concerned with the ?ndings. Thereafter, Choice and OPSB received negative media attention and-sonic students decided they would not return to Lafayette Academy. 34. The failure of Jacobs, Tuna, and Keeler to properly oversee, manage, coordinate, and/or complete the project in a safe and compliant manner led to Choice?s and damages. 35. During the 2017?2018 school year, RSD contracted with a different contractor, Law, to perform the Phase 2 Work of various additional improvements at the Carrollton Campus, which included asbestos removal and replacement of the concrete ?oor ?ll system on the ?rst and second ?oors. Law contracted with ABC. Jacobs again served as the construction manager of the project on behalf of RSD pursuant to a contract, and again served as the architect for the Phase 2 project. 36. In late May 2018, Law and ABC were approved to proceed with removing the asbestos? containing tile on the ?rst and second ?oors of the Carrollton Campus, and this Phase 2 work began after the 2017-2018 school year ended. 37. Jacobs and Associates were responsible was overseeing the work and ensuring it was being properly done, and Law and ABC were likewise responsible for conducting the Phase 2 Work properly; 38. On June?6, 2018, Jacobs and discovered substantial asbestos contamination due to Law and mistakes and noti?ed RSD. Thereafter, Jacobs and/or RSD noti?ed LDEQ. 39. 2? 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The contamination and un?nished renovations forced Lafayette Academy out of its historical campus on Carrollton Avenue. The campus still requires remediation before it is suitable for use as a school. 43. The problems related to asbestos-removal work prompted a series of conversations among Choice, OPSB, and others regarding the problems and rami?cations they could haVe on the school year. 44. By letter dated July 13, 2018, the RSD provided the below information and noti?ed Choice that it would be required to relocate Lafayette Academy students to a separate facility for Fall 2018: During summer of 2618, ?rst and second fioor renovation and abatement work com merited. This Work did not start untii after school dismiss-ed in May of 2918, and no school-chiiciren were on the premises at any time during the rendvation period. Due to the contractor?s deviation from tire design and hazardous materiais abatementfcontaiomeat specifications, as observed by representatives, the Architect of Record issued a stop-Work Order to the Contractor on tune 15, 201.8. "ihe R59 instrected LDEQ be advised of the situation, and engaged that Separtment in the discussion of corrective action. The exterior site Was cleaned shortly thereafter; and LDEQ inspectors we re kept acorised of, and the scope and performance of this work. Exterior cleaner; is complete, and sit required ciea?ra'nce testing of the exterior was performed. Due to the contractor?s breaches referenced above, the RED issued a Notice of Contractor {Defaoit and intent to terminate the Construction Contract on .i'uiy 6, 2818. the contractor?s actions have made timely compietion of the remainder of this refurbishmentfabatement project impossible, and it must continue into the iali months. For this reason, and reason, the schooi must reiocate for the 2648 session. 45. Choice learned that Lafayette?s first, second, and third ?oors contain unsafe asbestos levels and would require remediation. Because Law was terminated, the scope of work had to be rebid, causing further delay. 46. As a result, Choice was forced to relocate Lafayette Academy for the 2018?2019 and 2019? 2020 school years. 47. OPSB identi?ed an alternate location on Kerlerec Street and extensive renovation work with contractors working around the clock had to be performed to ensure school started on August -11- 27, 2018, which was nearly 20 days after school would have started at the Carrollton Campus had there been no negligence by the Defendants. 48. Although Choice and OPSB worked?tirelessly to prepare the Kerlerec Campus for 2018- 2019 school year, it came at great ?nancial and human cost. 49. In addition, the Kerlerec Campus was not what many students and parents expected when enrolling their children at Lafayette Academy and the location was not as convenient, which may have affected enrollment, which cannot be calculated at this point. 50. Also, now that the Carrollton Campus cannot be used for the 2019?2020 school year and Lafayette must remain at the Kerlerec campus, OPSB must update other sites for projects that Were originally set to be at the Kerlerec campus, which has caused OPSB to expend additional monetary resources and sustain additional damages as a result of Defendants? negligence. CLAIMS AGAINST DEF ENDANTS 51. Choice and OPSB repeat and re?aver the allegations set forth in paragraphs 1 50 as if copied herein. 52. Due to the negligence of the Defendants, the work had to cease, and the Carrollton Campus?s ?rst and second ?oors contain unsafe asbestos levels and will require remediation. 53. I Jacobs owed a duty to Choice and OPSB to oversee and administer the Phase 1 and Phase 2 projects according to the standard of care of similar professionals in the industry, which included timely, safely, and correctly completing the project for which it was responsible, which Jacobs did not do. 54. Jacobs was negligent, causing damage to Choice and OPSB by, including, but not limited to, failing to follow generally accepted construction management practices in overseeing the project at the Carrollton Campus, failing to properly oversee the design and construction work, -12- failing to competently act as representative on the project, causing and/or contributing to delays, failing to adhere to standards for a reasonably prudent manager in the Orleans Parish area. 55. Tuna owed a duty to Choice and OPSB to perform its role as the general contractor for the Phase 1 Work according to the standard of care of similar professionals in the industry, which Tuna did not do. 56. Tuna was negligent, causing damage to Choice and OPSB by, including, but not limited to, failing to follow generally accepted construction practices and by negligently performing renovations/work, by failing to properly oversee and undertake the construction of its work, by causing and] or contributing to delays, and by failing to adhere to standards for a reasonably prudent contractor in the Orleans Parish area. ?57. V. Keeler owed a duty to Choice and OPSB to perform its role as the asbestos removal contractor for the Phase 2 Work according to the standard of care of similar professionals in the industry, which V. Keeler did not do. 58. V. Keeler was negligent, causing damage to Choice and OPSB by, including, but not limited to, failing to follow generally accepted construction practices and by negligently performing renovations/work, by failing to properly oversee and undertake the construction of its work, by causing and/or contributing to delays, and by failing to adhere to standards for a reasonably prudent contractor in the Orleans Parish area. i 59. Law owed a duty to Choice and OPSB to perform its role as the general contractor for the Phase 1 Work according to the standard of care of similar professionals in the industry, which Law did not do- 60. Law was negligent, causing damage to Choice and OPSB by, including, but not limited to, failing to follow generally accepted construction practices and by negligently performing renovations/work, by'failing to properly oversee and undertake the construction of its work, by -13- causing and! or contributing to delays, and by failing to adhere to standards for a reasonably prudent contractor in the Orleans Parish area. 61. ABC dwed a duty to Choice and OPSB to perform its role as the asbestos removal. contractor for the Phase 2 Work according to the standard of care of similar professiOnals in the industry, which ABC did not do. 62. ABC was negligent, causing damage to Choice and OPSB by, including, but not limited to, . failing to follow generally accepted construction practices and by negligently performing renovations/work, by failing to properly oversee and undertake the construction of its work, by causing and/ or contributing to delays,- and by failin to adhere to standards for a reasonably prudent contractor in the Orleans Parish area. 63. owed a duty to Choice and OPSB to perform its role as the architect for the Phase 1 and Phase 2 Work according to the standard of care of similar professionals in the industry, which N-Y did not do. 64. Associates was negligent, causing damage to Choice and OP SB by, including, but not limited to, failing to follow generally accepted architecture and/0r engineering practices at the Carrollton Campus, failing to properly oversee the design and construction work, failing to competently act as representatives on the project, causing and/or contributing to delays, failing to adhere to standards for a reasonably prudent architect and/ or engineer in the Orleans Parish area. 65. Defendants are jointly liable to Choice and OPSB for their damages pursuant to Louisiana Civil Code article 2324. CLAIMS AGAINST INSURERS UNDER LOUISIANA DIRECT ACTION STATUTE 66. Choice and OPSB repeat and re?ayer the allegations set forth in paragraphs 1 65 as if copied herein. -14- 67. Colony, Travelers Indemnity and Travelers Property, ABC, DEF, GHI, JKL, MNO, and PQR insurance companies (collectively, the ?lnsurers?) are insurance companies who were at pertinent times the commercial general liability and/or excess and/or profesSioual liability insurance carriers for defendants in this lawsuit. 68. Pursuant to Louisiana Revised Statutes 22:655 the Insurers are solidarily liable with its respective insureds to Choice Foundation and OPSB to the limits of the policies for their insured?s acts and/or omissions that caused damage to Choice Foundation and OPSB. DAMAGES 69. Choice and OPSB repeat and re?aver the allegations set forth in paragraphs 1- 68 as if copied herein. 70. Due to the failure of Defendants to complete the scheduled renovation projects in a safe and timely manner at the Carrollton Campus, Choice has incurred and is continuing to incur damages. 71. Choice stored furniture and equipment of signi?cant value including, but not limited to, Choice?s computer servers on the floors which were contaminated and must be replaced. Moreover, the play yard and additional items, including those in the large metal storage units in which Choice stored items from the ?rst ?oor, were contaminated. Thus far, Choice authorized an expenditure of at least $1.3 million to replace centaminated furniture and equipment. 72. In addition to loss of furniture, equipment, and other items, the Carrollton Campus could not be used for the 2018-2019 school year. Moreover, the Carrollton Campus cannot be used for the 2019-2020 school year either, which has caused ?lrther damages. -15- 73. Choice was required to relocate Lafayette Academy for the 2018-2019 school year (and for the 2019-2020 school year) at great cost and inconvenience to Choice and disruption to the Lafayette faculty, students, and families. 74. Many parents have expressed their frustration to Choice and the media regarding the relocation and how the situation was handled, which in turn has harmed Choice. 75. Choice has incurred additional damages, including, but not limited to, damages caused by the disruption of operations and relocation of operations to another campus. Thus, Choice has a claim for extra expenses. 76. Choice?s claims for lost pro?ts will not be known until the loss of students can be calculated for the 2018?2019 school year or even until next year when Choice determines how many students it lost due to the relocation. The loss of a student in one year subsequently affects the lost pro?ts for the remaining years that student would have attended Lafayette Academy but for the actions of the Defendants. 77. In addition, Choice has lost faculty that affects the operations of the school. 78. Choice has incurred damages through no fault of its own, and it has incurred expenses in preparing for the new school year, which has been delayed due to the Defendants? actions, at a replacement facility. 79. Accordingly, Choice seeks all damages resulting from the Defendants? actions, including, but not limited to, the amounts paid to replace furniture, equipment, claserOr?n materials, and I other items that were contaminated and to be replaced; (2) extra expenses it incurred to relocated the Carrollton Campus to the Kerlerec Campus; and (3) lost pro?ts to be calculated. ~16- DAMAGES 80. Choice and OPSB repeats and re-avers the allegations set forth in paragraphs 1 79 as if copied herein. I 81. Due to the faiIUre of Defendants to complete a scheduled renovation project in a safe and timely manner at the Carrollton Campus, OPSB has also incurred and is continuing to incur damages. 82. To date, been forced to spend approximately $5,000,000.00 dollars to relocate schools and programminglas a result of Defendants? negligence, which rendered the Carrollton Campus unusable when OPSB needed that location for school operations. Because Lafayette Academy will remain on the Kerlerec Campus until 2020, OPSB must perform renovations at another facility to accommodate programming that Was slated to be in the Kerlerec Carnpus next year. 83. Accordingly, OPSB seeks all damages resulting from the Defendants? actions, including, but not limited to, (1) any and all costs associated with relocating Choice to the Kerlerec. facility and (2) any and all costs associated with relocating other programming that was slated to occupy the Kerlerec facility during the 2019-2020 school year. REQUEST FOR JURY Choice and OPSB request a trial by jury. PRAYER FOR RELIEF Choice and OPSB respect?illy pray that this Petition for Damages be deemed good and sufficient and that, after due proceedings are conducted, judgment be rendered in their favor and against Defendants, Tuna, V. Keeler, Law, AEC, Jacobs, Colony Insurance Company, Travelers Indemnity Company, Travelers Preperty Casualty Company of America, ABC Insurance Company, DEF Insurance Company, GHI Insurance Company, JKL Insurance Company, MNO Insurance Company and PQR Insurance Company, who are jointly liable to -17_ Choice and OPSB, awarding all legal and equitable relief to which Choice and OPSB are entitled, including, but not limited to, (1) damages sustained by Choice, including, but not limited to, (2) damages sustained by OPSB, including, but not limited to, any and all costs associated With relocating schools and programs as a result of Defendants? negligence; (3) Pre?judgment and post?judgment interest on the total award rendered by this. Court; (4) Attorneys? fees, penalties, and all other damages available under Louisiana Revised Statutes 22:1982 and 22:1973 against the insurance company defendants. (5) All other general and equitable relief this Court deemsproper. Dated: May 10, 2019 A Respectfully submitted, JAME GARNER, #19589 RYAN O. LUMINAIS, #30605 AMANDA R. SCHENCK, #30706 SHER GARNER CAHILL RICHTER KLEIN HILBERT, LLC 909 Poydras Street, 28th Floor New Orleans, LA 70112 Phone: (504) 299?2100 Fax: (504) 299?2300 COUNSEL FOR CHOICE FOUNDATION AND WILLIAMS, #28809 FISHNIAN HAYGOOD, L.L.P. 201 St. Charles Avenue Suite 4600 . New Orleans, LA 70170-4600 504.586.5252 COUNSEL FOR ORLEANS PARISH SCHOOL BOARD ?18- PLEASE SERVE: Law Industries, LLC Through its registered agent: Byron Jerome Law 7547 Town South Ave. Baton Rouge, LA 70808 Advanced Environmental Consulting, Inc. Through its registered agent: Glenn L. Johnson or Kim Johnson 685 Rodney Dr. Baton Rouge, LA 70808 Tuna Constructi0n, LLC Through its registered agent: Jonathan S. Forester 201 St. Charles Ave. Suite 3300 New Orleans, LA 70170 V.E. Keeler Associates, LLC Through its registered agent: Roy J. Rodney, Jr., Esq. 620 N. Carrollton Ave. New Orleans, LA 70119 Associates Through its registered agent: Michael F. Nieoladis 2750 Lake Villa Dr. Metairie, LA 70002 Jacobs Project Management Company/CSRS Consortium Through the registered agent for its partner, CSRS, 1110. Domaine Rutledge 6767 Perkins Road Suite 200 Baton Rouge, LA 70808 Colony Insurance Company Through its registered agent: Louisiana Secretary of State 8585 Archives Ave. Baton Rouge, LA 70809 Travelers Indemnity Company Through its registered agent: Louisiana Secretary of State 8585 Archives Ave. Baton Rouge, LA 70809 Travelers Property Casualty Company of America Through its registered agent: Louisiana Secretary of State 85 85 Archives Ave- Baton Rouge, LA 70809 -19-