FILED DALLAS COUNTY 3/10/2017 3:38:52 PM FELICIA PITRE DISTRICT CLERK 4 CT-CERT-MAIL DC-17-02998 CAUSE NO. __________________________ SUZANNE CALLAWAY-DAVIS Plaintiff v. AMAZON.COM LLC, OLADAYA ANIPOLE, INPAX SHIPPING SOLUTIONS INC., AND INSS, LLC § § § § § § § § § § Freeney Anita IN THE DISTRICT COURT DALLAS COUNTY, TEXAS F-116TH ______ JUDICIAL DISTRICT Defendants ______________________________________________________________________________ PLAINTIFF SUZANNE CALLAWAY-DAVIS’ ORIGINAL PETITION TO THE HONORABLE JUDGE OF SAID COURT: COMES NOW, Suzanne Callaway-Davis, (hereinafter referred to as “Plaintiff”), complaining of Amazon.com LLC, Mr. Oldaya Anipole, Inpax Shipping Solutions Inc., and INSS, LLC (hereinafter referred to as “Defendants”) and for cause of action would respectfully show unto this Honorable Court and Jury as follows: DISCOVERY CONTROL PLAN 1. Plaintiff intends for discovery to be conducted under Level 2 of Texas Rule of Civil Procedure 190.3 and affirmatively pleads that this suit is not governed by the expedited-actions process of Texas Rule of Civil Procedure 169 because Plaintiff seeks monetary relief of over $100,000.00. PARTIES 2. Plaintiff is an individual residing in Dallas County, Texas. _____________________________________________________________________________________________ Plaintiff Suzanne Callaway-Davis’ Original Petition Page 1 3. Amazon.com LLC is a foreign company engaging in the business of electronic commerce in the State of Texas. Defendant may be served with process by serving its registered agent of service, Corporation Service Company, located at the following address: 211 E. 7th Street, Suite 620, Austin, Texas 78701. 4. Inpax Shipping Solutions Inc. is a foreign transport company engaging in the business of shipping and transportation in the State of Texas. Defendant may be served with process at its principal office location: 2444 Forest Park Rd, Atlanta, Georgia 30315. 5. INSS, LLC is a foreign transport company engaging in the business of shipping and transportation in the State of Texas. Defendant may be served with process at its principal office location: 2444 Forest Park Rd Se, Atlanta, Georgia 30315. 6. Oldaya Anipole is a Texas resident and employee of INSS, LLC engaging in the business of shipping and transporting packages in the State of Texas. Defendant may be served with process by serving him at his place of residence: 425 Bernard Street, Denton, Texas 76207. JURISDICTION 7. The Court has jurisdiction over this cause of action because the amount in controversy is within the jurisdictional limits of the Court. 8. The Court has jurisdiction over Defendant Amazon.com LLC because it is a foreign company that engages in the business of electronic commerce in the State of Texas and Plaintiff’s causes of action arise out of Defendant’s business activities in the State of Texas. Specifically, Defendant Amazon.com LLC ships and transports items in Texas and has “purposefully availed” itself of the privilege of conducting activities in Texas. Kelly v. General Interior Constr., Inc., 301 S.W.3d 653, 660-61 (Tex. 2010). _____________________________________________________________________________________________ Plaintiff Suzanne Callaway-Davis’ Original Petition Page 2 9. The Court has jurisdiction over Defendant Oldaya Anipole because he is a resident of Texas and an individual engaging in the business of transporting and shipping items in the State of Texas and Plaintiff’s causes of action arise out of Defendant INSS, LLC’s business activities in the State of Texas. Specifically, Defendant Anipole, an employee of Defendant INSS, LLC, drove the Amazon truck over Plaintiff’s mailboxes and into her house, causing significant damage. Defendant Anipole has “purposefully availed” itself of the privilege of conducting activities in Texas. Kelly v. General Interior Constr., Inc., 301 S.W.3d 653, 660-61 (Tex. 2010). 10. The Court has jurisdiction over Defendant Inpax Shipping Solutions Inc. because itis a foreign transport company that engages in the business of shipping and transporting items in the State of Texas and Plaintiff’s causes of action arise out of Defendant Inpax Shipping Solutions’ business activities in the State of Texas and has “purposefully availed” itself of the privilege of conducting activities in Texas. Kelly v. General Interior Constr., Inc., 301 S.W.3d 653, 660-61 (Tex. 2010). 11. The Court has jurisdiction over Defendant INSS, LLC because it is a foreign transport company that engages in the business of shipping and transporting items in the State of Texas and Plaintiff’s causes of action arise out of Defendant INSS, LLC’s business activities in the State of Texas. Specifically, INSS, LLC employed Defendant Anipole and has “purposefully availed” itself of the privilege of conducting activities in Texas. Kelly v. General Interior Constr., Inc., 301 S.W.3d 653, 660-61 (Tex. 2010). VENUE 12. Venue is proper in Dallas County, Texas, because the Property is situated in Dallas County, Texas. TEX. CIV. PRAC. & REM. CODE § 15.032. _____________________________________________________________________________________________ Plaintiff Suzanne Callaway-Davis’ Original Petition Page 3 FACTS 13. At 5:09 pm, Plaintiff’s neighbors called the Dallas Police who arrived at the scene at 5:11 pm and generated a report. [Exhibit A]. 14. At approximately 5:15 pm on the evening of June 19, 2016, Plaintiff’s neighbor, Ms. Harrison, called Plaintiff. Plaintiff’s neighbor informed her that Defendant Anipole was making a delivery for Defendants Amazon.com LLC, Inpax Shipping Solutions Inc., and INSS, LLC to Plaintiff’s neighbor’s home. Allegedly after making the delivery, Defendant Anipole accelerated the delivery truck, jumping the curb of the cul-de-sac, crashed into Plaintiff’s and her neighbor’s brick mailboxes, and continued driving straight into Plaintiff’s home, specifically Plaintiff’s dining room window of the property located at: 12544 Renoir Lane, Dallas, Texas 76230 (“the Property”). 15. Defendant Anipole further attempted to flee the scene but was stopped by Plaintiff’s neighbor. The Property sustained severe structural damage to the interior and exterior of the home, foundation, dining room window, exterior brick, inside wall near the window, shrubbery, outdoor lighting and sprinkler systems. 16. Plaintiff was further informed that Defendant Anipole was in an accident the previous week. 17. On June 20, 2016, Plaintiff contacted the Dallas Police to secure a copy of the report with Case ID: 148435-2016, which was unavailable until June 28, 2016. The police report indicated that at 5:05 pm on June 19, 2016, a white 2016 Nissan van with license plate number: GNY7112 driven by Defendant Anipole, with driver’s license number: 40237878 collided into two brick mailboxes and continued into the front left of a house located at 12544 Renoir Lane. The report states that the unit applied the accelerator _____________________________________________________________________________________________ Plaintiff Suzanne Callaway-Davis’ Original Petition Page 4 pedal, driving over the curb, colliding with two brick mailboxes, and continued into the front left of Plaintiff’s home. 18. On the same day, Plaintiff turned off her television and heard rushing water. Plaintiff walked through her home and observed water flooding through her dining room via the missing window from the outdoor sprinkler system. Plaintiff immediately attempted to turn off the sprinkler system, but irreparable damage had already been sustained by the water from the sprinkler system entering into the home. 19. On June 21, 2016, Plaintiff began making phone calls to contractors in the area in order to mitigate the damage. However, Plaintiff was told that due to the July 4th holiday, most of the contractors would take anywhere from a few days to a few weeks to get a quote. 20. On July 1, 2016, Plaintiff had Carl Dill Services inspect the sprinkler system. In order to mitigate any further damage to the Property, Plaintiff temporarily placed an adapter on the spout. Similarly, Plaintiff had someone inspect the window to determine what should be done regarding the severe damage to the window and frame. 21. On July 3, 2016, Plaintiff had Hamilton Interior Finishes, LLC inspect the house. Plaintiff was informed that there was extensive interior and exterior damage. Hamilton Interior Finishes, LLC suggested Plaintiff may need to retain a structural engineer to inspect the foundation. 22. On July 11, 2016, Richard Lowrey, a claims adjuster for Brezina Claim Associates, Inc. arrived to inspect the Property with Mr. Hamilton and Jay Hamm, a structural engineer. Mr. Hamilton and Mr. Hamm advised Plaintiff that she would likely need to replace everything damaged portion of the Proeprty. _____________________________________________________________________________________________ Plaintiff Suzanne Callaway-Davis’ Original Petition Page 5 23. Brezina Claim Associates inspected the property for insurer, Am-Trust North America, as Defendant Inpax Shipping Solutions Inc. is the insured. Mr. Lowrey estimated the replacement cost value of the property to be $8,410.02, less non-recoverable depreciation in the amount of $528.32, for net claim in the amount of $7,881.70. This amount is insufficient to restore the Property to its pre-loss condition and is an intentional attempt to underpay Plaintiff for her loss. Further, Plaintiff has never received an engineering report or any indication as to the findings and recommendations of Mr. Hamilton and Mr. Hamm. 24. On July 14, 2016, Plaintiff contacted Brick Doctor in order to get a quote for the damage to the brick mailbox as well as the brick exterior of her home. The Property was inspected on July 27, 2016. Brick Doctor estimated the damage to the mailbox to be $1,650.00. The proposal included re-building the mailbox to the same design and replacing the broken brick with material of like kind and quality. With respect to the house, Brick Doctor estimated the damage to the brick to be $2,108.00. The proposal included removing all brick from the windowsill and re-doing the foundation and replacing the broken brick with material of like kind and quality. 25. Defendants failure to provide an adequate settlement of Plaintiff’s severe Property damage forced Plaintiff to retain the legal services of McClenny Moseley & Associates, PLLC on September 14, 2016. 26. On September 26, 2016, Plaintiff retained Becker Engineering to inspect the Property and provide an engineering opinion. [Exhibit B]. Gregory Becker with Becker Engineering observed new cracks and separations in the brick veneer and junction of the frieze board. Although some areas outside the dining room were previously repaired, the vehicle collision showed a re-opening as well as a cracked foundation. The dining room window was destroyed and the glazing was separated from the frame. The window frame _____________________________________________________________________________________________ Plaintiff Suzanne Callaway-Davis’ Original Petition Page 6 was bowed, cracked, and separated. Mr. Becker observed that new cracks and separations were observed in the interior, consistent with the deflection of vibrations due to the impact of the vehicle, causing stress cracks and fractures. Mr. Becker also observed that the hardwood floor shows evidence of cupping due to the sprinkler water. 27. Mr. Becker stated that assuming the Amazon truck was 3,200 pounds and traveling at a speed of 30 miles per hour, the approximate force of impact would be 96,800 foot-pounds. It was observed that the collision with the brick mailboxes had little effect on the speed of the vehicle colliding into Plaintiff’s home. 28. Mr. Becker recommended the re-building of the mailbox as well as repairing or replacing the outdoor sprinkler and lighting systems. Mr. Becker recommended replacing the exterior brick veneer and repairing the separated frieze board. Mr. Becker also recommended replacing the damaged window and frames. Further, Mr. Becker recommended the removal and replacement of the interior hardwood flooring as well as the interior sheetrock and trim. 29. Plaintiff was also forced to retain the services of a professional estimate writer to properly scope and evaluate the Property. On or around October 28, 2016, Plaintiff’s professional estimate writer inspected the Property and estimated the damages to be in the amount of $140,848.35. [Exhibit C]. 30. With regard to the exterior, Plaintiff’s professional estimate writer estimated for the removal and replacement of the brick mailbox as well as installing and removing a house wrap to secure the air/moisture barrier. Plaintiff’s professional estimate writer also estimated for the removal and replacement of the brick veneer of the chimney, as well as removing and replacing the chimney cap and _____________________________________________________________________________________________ Plaintiff Suzanne Callaway-Davis’ Original Petition Page 7 case cover. For the second chimney, Plaintiff’s professional estimate writer estimated for the removal and replacement of chimney flashing, ½-inch sheathing, brick veneer, a chimney cap, and a flue cap. 31. With respect to the left elevation, Plaintiff’s professional estimate writer estimated for the removal and replacement of the brick veneer. Similarly, for the rear and right elevations, Plaintiff’s public adjuster estimated for the removal and replacement of the brick veneer and door jamb and trim, as well as associated costs for resetting the wooden fence and air condenser unit. 32. Plaintiff’s professional estimate writer also estimated for the removal and replacement of 1-inch by 4-inch trim board to replace the freeze board on the exterior perimeter, as well as sealing and painting costs. Additionally, Plaintiff’s professional estimate writer estimated for the removal and replacement of the brick to replace the brick fence with material of like kind and quality. 33. With respect to the interior, Plaintiff’s professional estimate writer estimated for the pack-out, pack-in costs associated with the content, including fine art storage, a variety of storage boxes, furniture blankets, and bubble wrap. 34. With respect to the dining room, Plaintiff’s professional estimate writer estimated for the removal and replacement of the wooden window, including removing and replacing the window sill, batt insulation, ½-inch drywall, shutters, and interior door. The professional estimate writer also estimated for texturing the drywall, as well as sealing and painting the walls and window sill. The professional estimate writer also estimated for the removal and replacement of the oak flooring, sanding, staining, and finishing the wood floor. _____________________________________________________________________________________________ Plaintiff Suzanne Callaway-Davis’ Original Petition Page 8 35. With respect to the foyer/entry, kitchen, living room, family room, laundry room, bedrooms, laundry room and garage, Plaintiff’s professional estimate writer estimated for the removal and replacement of drywall, texturing the drywall, painting the ceiling and walls, and painting the crown molding, among other things. 36. Defendant Anipole acted as an authorized agent of Defendants Inpax Shipping Solutions Inc. and INSS, LLC. Defendant Anipole acted within the course and scope of his authority as an employee of Defendants Inpax Shipping Solutions Inc. and INSS, LLC. 37. Similarly, Defendants Inpax Shipping Solutions Inc. and INSS, LLC acted as agents of Defendant Amazon.com LLC. Defendant Amazon.com LLC is vicariously liable for the actions of Defendants Inpax Shipping Solutions Inc, INSS, LLC and Anipole. 38. As a result of Defendant Anipole’s act, including driving Defendant Amazon.com LLC’s delivery truck in the course of Defendants Inpax Shipping Solutions Inc. and INSS, LLC’s scope of employment into Plaintiff’s Property, Plaintiff was forced to retain the professional services of McClenny Moseley & Associates, PLLC, who is representing Plaintiff with respect to these causes of action. CAUSES OF ACTION: NEGLIGENCE 39. Plaintiff hereby incorporates by reference all facts and circumstances set forth under the foregoing paragraphs. 40. Defendant Amazon.com LLC is vicariously liable for the actions of Defendants Inpax Shipping Solutions Inc. and INSS, LLC because Defendant Amazon.com LLC employs Defendants Inpax Shipping Solutions Inc. and INSS, LLC to conduct its business. Similarly, Defendant Amazon.com LLC is vicariously liable _____________________________________________________________________________________________ Plaintiff Suzanne Callaway-Davis’ Original Petition Page 9 for the actions of Defendant Anipole, because Defendant Anipole is an employee of Defendants Inpax Shipping Solutions Inc. and INSS, LLC. See St. Joseph Hosp. v. Wolff, 94 S.W.3d 513, 540 (Tex. 2002) (plurality) ("The common law has long recognized that liability for one person's fault may be imputed to another who is himself entirely without fault solely because of the relationship between them."). 41. “There are three essential elements in a common law negligence claim (1) a legal duty owed by one person to another, (2) a breach of that duty; and (3) damage proximately caused by the breach. See Werner v. Colwell, 909 S.W. 2d 866, 869 (Tex. 1995); Pinkerton’s v. Manriquez, 964 S.W. 2d 39, 44 (Tex. App.— Houston [14th Dist.] 1997, pet. denied). 42. Defendant Anipole owed Plaintiff a general duty of reasonable care because operators of commercial vehicles should have a commercial driver’s license and operate vehicles in a safe manner. 43. Defendant Anipole breached this duty by misapplying the acceleration pedal instead of the brake pedal plowing through Plaintiff’s mailbox and continuing through her dining room. 44. As a result of Defendant Anipole’s action, Plaintiff sustained severe Property damages. 45. Further, as a result of Defendant Anipole’s negligent actions, Defendants Inpax Shipping Solutions Inc., INSS, LLC, and Amazon.com LLC are liable to Plaintiff for the damages sustained to her Property, as Defendant Anipole was acting within the scope and course of his employment with Defendants Inpax Shipping Solutions Inc. and INSS, LLC. Defendants Inpax Shipping Solutions Inc. and INSS, LLC acted within the scope and course of their employment with Defendant Amazon.com LLC. _____________________________________________________________________________________________ Plaintiff Suzanne Callaway-Davis’ Original Petition Page 10 GROSS NEGLIGENCE 46. Plaintiff hereby incorporates by reference all facts and circumstances set forth under the foregoing paragraphs. 47. Gross negligence means an act or omission: (A) which when viewed objectively from the standpoint of the actor at the time of its occurrence involves an extreme degree of risk, considering the probability and magnitude of the potential harm to others; and (B) of which the actor has actual, subjective awareness of the risk involved, but nevertheless proceeds with conscious indifference to the rights, safety, or welfare of others. TEX. CIV. PRAC. & REM. CODE § 41.001, .003(a). 48. Viewing Defendant Anipole’s actions objectively, accelerating an Amazon delivery vehicle over the curb, through a brick mailbox, and into the dining room of a house involves extreme risk and has the potential to cause severe and substantial harm to others. Had Plaintiff been in the dining room, there would have been a high likelihood of serious bodily injury or death. Further, instead of applying the brakes, Defendant Anipole accelerated, driving over the curb, through the brick mailboxes, and into Plaintiff’s home. Had Plaintiff been home at the time, or sitting in her dining room, she would have sustained severe injuries due to Defendant Anipole’s actions. Instead of applying the brakes, Defendant Anipole wrongfully and unjustifiably accelerated the Amazon vehicle. 49. All Defendants are liable for gross negligence as Defendant Anipole was acting within the scope and course of his employment with Defendants Inpax Shipping Solutions Inc. and INSS, LLC. Defendants Inpax Shipping Solutions Inc. and INSS, LLC acted within the scope and course of their employment with Defendant Amazon.com LLC. _____________________________________________________________________________________________ Plaintiff Suzanne Callaway-Davis’ Original Petition Page 11 NEGLIGENT HIRING 50. Plaintiff hereby incorporates by reference all facts and circumstances set forth under the foregoing paragraphs. 51. “An employer owes a duty to its other employees and the general public to ascertain the qualifications and competence of the employees it hires, especially where the occupation at issue could cause hazard to others or requires skilled or experienced persons.” Phillips v. Super Servs. Holdings, LLC, 189 F. Supp. 3d 640, 648 (S.D. Tex. May 26, 2016) (citing Morris v. JTM Materials, Inc., 78 S.W.3d 28, 49 (Tex.App.—Fort Worth 2002, no pet.)). An employer is liable for negligent hiring if it hires an incompetent or unfit employee whom it knows, or by the exercise of reasonable care should have known, was incompetent or unfit, creating an unreasonable risk of harm to others. Id. 52. At all relevant times, Defendant Anipole was an agent or employee of Defendant INSS, LLC. 53. At all relevant times, Defendants Inpax Shipping Solutions Inc. and INSS, LLC were agents or employees of Defendant Amazon.com LLC. 54. Defendants Inpax Shipping Solutions Inc. and INSS, LLC are liable for negligent hiring because they hired an incompetent and unfit employee who was in an accident one week prior to the incident on June 19, 2016. Defendants Inpax Shipping Solutions Inc. and INSS, LLC failed to investigate properly into Defendant Anipole’s past accident history. Had Defendants Inpax Shipping Solutions Inc. and INSS, LLC investigated properly and exercised due care in hiring Defendant Anipole, they would have known that Defendant Anipole was unfit for the position of operating the vehicle. _____________________________________________________________________________________________ Plaintiff Suzanne Callaway-Davis’ Original Petition Page 12 55. Defendant Amazon.com LLC is liable for negligent hiring because its employees, Defendants Inpax Shipping Solutions Inc. and INSS, LLC hired an incompetent and unfit employee who was in an accident one week prior to the incident on June 19, 2016. Defendant Amazon.com LLC failed to investigate properly into Defendants Inpax Shipping Solutions Inc. and INSS, LLC hiring procedures. Had Defendant Amazon.com LLC investigated properly and exercised due care in hiring Defendants Inpax Shipping Solutions Inc. and INSS, LLC it would have known that Defendant Anipole was unfit for the position of operating the vehicle. NEGLIGENT ENTRUSTMENT 56. Plaintiff hereby incorporates by reference all facts and circumstances set forth under the foregoing paragraphs. 57. In order to prevail on a negligent entrustment action, Plaintiff must show: “(1) the defendant entrusted the vehicle to the driver; (2) that person was an unlicensed, incompetent, or reckless driver; (3) at the time of the entrustment, the defendant knew or should have known that the driver was an unlicensed, incompetent, or reckless driver; (4) the driver was negligent on the occasion in question; and (5) the driver’s negligence proximately caused the accident.” Goodyear Tire & Rubber Co. v. Mayes, 236 S.W.3d 754, 758 (Tex.2007). 58. At all relevant times, Defendant Anipole was an agent or employee of Defendants Inpax Shipping Solutions Inc. and INSS, LLC. 59. At all relevant times, Defendants Inpax Shipping Solutions Inc. and INSS, LLC were agents or employees of Defendant Amazon.com LLC. _____________________________________________________________________________________________ Plaintiff Suzanne Callaway-Davis’ Original Petition Page 13 60. Defendants Inpax Shipping Solutions Inc. and INSS, LLC are liable for negligent entrustment because they entrusted the Amazon vehicle to Defendant Anipole. As stated previously, Defendant Anipole was incompetent or reckless as he drove over the curb, through Plaintiff’s mailbox, and into Plaintiff’s Property. Defendants Inpax Shipping Solutions Inc. and INSS, LLC should have known Defendant Anipole was incompetent or reckless if they had looked into Defendant Anipole’s prior accident history. As stated previously, Defendant Anipole was negligent as he owed a duty of reasonable care to Plaintiff, breached that duty, and caused substantial Property damages. 61. Defendant Amazon.com LLC is liable for negligent entrustment because it entrusted the Amazon vehicle to Defendants Inpax Shipping Solutions Inc. and INSS, LLC which employed an incompetent or reckless driver, Defendant Anipole, whom Defendants Inpax Shipping Solutions Inc. and INSS, LLC knew or should have known was incompetent or reckless. Further, as stated previously, Defendant Anipole was negligent as he owed a duty of reasonable care to Plaintiff, breached that duty, and caused substantial Property damages. DAMAGES 62. Plaintiff will show that all of the aforementioned acts, taken together or singularly, constitute the producing causes of the damages sustained by Plaintiff. 63. A plaintiff may recover exemplary damages only if she proves by clear and convincing evidence that the harm with respect to which the claimant seeks recovery of exemplary damages results from (1) fraud; (2) malice; or (3) gross negligence. TEX. CIV. PRAC. & REM. CODE § 41.003(a). The exemplary damages may not exceed an amount equal to the greater of 1) (A) two times the amount of economic damages; plus (B) _____________________________________________________________________________________________ Plaintiff Suzanne Callaway-Davis’ Original Petition Page 14 an amount equal to any noneconomic damages found by the jury, not to exceed $750,000; or 2) $200,000. § 41.008(b). 64. Defendant’s acts have been the producing and/or proximate cause of damage to Plaintiff, and Plaintiff seeks an amount in excess of the minimum jurisdictional limits of this Court. 65. More specifically, Plaintiff seeks monetary relief, including damages of any kind, penalties, costs, expenses, pre-judgment interest, and attorney’s fees in excess of $1,000,000.00. ATTORNEY’S FEES 66. For the prosecution and collection of this claim, Plaintiff has been compelled to engage the services of the law firm whose name is subscribed to this pleading. Therefore, Plaintiff is entitled to recover from Defendants an additional sum to compensate Plaintiff for the reasonable and necessary services of Plaintiff’s attorneys in the preparation and trial of this action, including any appeals to the Court of Appeals and/or the Supreme Court of Texas pursuant to TEX. CIV. PRAC. & REM. CODE §§ 38.001-.005. JURY DEMAND 67. Plaintiff demands a jury trial, consisting of citizens residing in Dallas County, Texas, and tenders the appropriate fee with this Original Petition. CONCLUSION 68. Plaintiff prays that judgment be entered against Defendant Amazon.com LLC, Oladaya Anipole, Inpax Shipping Solutions Inc., and INSS, LLC and that Plaintiff be awarded all of her actual damages, consequential damages, prejudgment interest, additional statutory damages, post judgment interest, reasonable and necessary attorney’s fees, court costs and for all such other relief, general or specific, in law or in equity, whether pled or un-pled within this Original Petition. _____________________________________________________________________________________________ Plaintiff Suzanne Callaway-Davis’ Original Petition Page 15 PRAYER WHEREFORE, PREMISES CONSIDERED, Plaintiff prays she be awarded all such relief to which she is due as a result of the acts of Defendants Amazoncom LLC, Oladaya Anipole, Inpax Shipping Solutions Inc., and INSS, LLC, and for all such other relief to which Plaintiff may be justly and rightfully entitled. In addition, Plaintiff requests the award of attorney?s fees for the trial and any appeal of this lawsuit, for all costs of Court on her behalf expended, for pre- judgment and post?j udgment interest as allowed by law, and for any other and further relief, either at law or in equity, to which Plaintiff may show the herself to be justly entitled. RESPECTFULLY SUBMITTED, Ny?fo??zf?? ASEOC james M. Clenny State Bar No. 24091857 J. Zachary Ivloseley State Bar No. 24092863 Kelley A. Seid State Bar No. 24102480 411 N. Sam Houston Parkway 13., Suite 200 Houston, Texas 77060 Principal Of?ce No. 713?334?6121 Facsimile: 713-322?5953 ATTORNEYS FOR PLAINTIFF Cal/amy?Drwir? Oz?gi/m/ Petition Page 16 EXHIBIT Dal/ax Polite Repon? Cam ID: 748435-2076 MCCLENNY I MOSELEY 8. ASSOCIATES Da11as Paiice Records Section 1400 S. Lamar DaHasi 15 ?5215 {214; 611?3345 104011 Annette an 318 J0n28?16 Get 0 Externa1 Pub 1 necwdent USN 6.00 Cash 6.00 Subteta1 8.00 Payment 6?00 Law Enfrroernent and Use ONLY FATAL. CNN scHo'OL BUS lj RAILROAD MAB SUPPLEMENT QCTIVE CHOOL ZONE Lotei Loni 15164719 . 1 urn. m. Units i 1 Pi?enel I I 1 crash '0 /2016291672 Texas Peace Of?cer's Crash Report (Form (ZR-3 111l2015) Mail to: Texas Department of Transportation. Crash Data and Analysis, P-0. Box 149349, Austin TX ?8714. Questions? Call WEE-7457 m- Refer to Attached Code Sheel for Numbered Fields '=These ?elds are required on all additional sheets submitted for this crash additional vehicles, occu pants, injured, etc). Page 1 of 2 'Crash Date 'Crash Time Cage Loc (24HRMM148435?2016 'County 'City Outside Name DALLAS Name DALLAS CityLin-iit lnyour opinion.le result In atlnast BYE: . e. . La?lude Longitude ROAD ON WHICH CRASH OCCURRED aa '1 Rdwy. 'Hwy. 2 Rdwy. Block 3 Street Street 4 Sheet 2 Sys. LR Num. Pan 1 Num?12500 Pre?x Name RENOIR 50117): 1- 3 Crash Occurred on a Private Drive or Toll Road! Speed Const. Yes Workers Yes Street Roadi'Private Propertnyad-cing Lot Toll Lane Limit 30 Zone No Present El No Best. 5 INTERSECTING OR IF CRASH NOTATJNTERSECTION, NEARESTINTERSECTING ROAD OR REFERENCE MARKER l3 . At Yes 1 Rdwy, Hwy. 2. Rdwy. Block 3 Street Street 4 Street Int. N0 Sys. LR Num, Part 1 Num. 5900 Pre?x Name HOWARD Suffix Distance from Int. FT 3 i:iir. from Int. Reference Street RRX or Ref. Marker 60 Ml or Ref. Marker Marker Desc. NumUnit 5 Unit Parked Hit and LP LP Numl Base. 1 Vehicle nun smear}; Numm-Irllz GINIBLOL3I3I4I1 Veh. e. Vein. Veh. Veh. 7 Body 23:; 32233?ng In In Year Color WHI Make NISSAN MOGBI NV Style VN NarrativeifchECKEd} a DUID mum 9 DL 10 CDL 11 DL DOB Type 1 Slate TX Num. 40237378 Class End. 96 Rest Address (Street. C?ylsmeJiPi 425 BERNARD s-r BENTON, TX 7620'; . ?a an .5 . Name: Last. First. Middle Enter Driveror Primary Person forthis Unit on ?rst line ?51 irr? p: -E TE.- 5 a a 3 i?az w?23min: N6 3 1 1 ANIPOLE, OLADAYO Not Applicable - Alcohol and Hi Drug Results are oniy reported for DriverfPrimary Person for 5 each Unit. Owner OwnerlLassee Imam" ?amaamd'e? INSS, LLC, 90 BOX 16290 ATLANTA, GA 30321 Proorof 13 Yes Expired 26 Fin. Fin. Resp, Fin, Reap. [[Exempt Resp-Type2 Nama wesco INS. C0- Numl WPP141294600 Fin. Resp. 2? Vehicle 1 1 27 Vehicle Vehicle Phone Num. (212) 220-7120 Damage Re?ll-I91 Damage Ram-.ENC Towad Towed By To Unit 5 Unit Parked Hitand VIN est: Ice un State Vein, 6. Van. Veh. Ven. 7 Body POL "fer EMS 0? Emergeri [Ex lalnlo Year I I I I Color Make ??91 5MB 3 DUID DUJD DUID 9 or. 10 CDL 11 DL 1303 Type State Num. Class End. RestAddress (Street. City. State. ZIP) In . E?Name: Last. FirstIMiddle 33EnterDriveror Primary Personforthis Unit on?rstline ?Eazr?hwo, :2 B?a?x??m Ea: as ?3 NotApplicable~Akohoiand u? Drug Results are only reported I: for Driven?Primary Person for 3 each Unit. [1 Owner OwnerlLessee Lessee Name 8. Address Proofof E: Expired 25 Fm. Fin, Resp, Fin. Resp. FID- Resp. No Exempi Resp. Type Name Num. Fl?- R6511 27 Vehicle 27 Vehicle Vehicle Phone Num. Damage Ra?ng1 Damage [mammal-'1 ENG Towed Towed By To Law Enforcement and TXDOT Use ONLY- 0353 13001" Page of 3 Form ?19015) 143435-2016 Crasth 15164719.1/2016291672 unit PmDatuafDealh TimeofDeath Mum. Num. Take" 7" TakeIa}: Em Charge CitatiordRaferonoa Num. In In. ?3 2: Damaged Property Other Than Vehicles Ownal?s Name Owners Address '5 EHOUSE BRICK MAILBOX DAVIS, SUZANNE 12544 RENOIR LN DALLAS, TX 75230 MAILBOX GRAFFY, GEORGE 12548 RENOIR LN DALLAS, TX 75230 a Unit 10,001+ TRANSPORTING [Was 28 mm. EQCam'er Carrier Num. El LBS. HAZARDOUS MATERIAL 9" CAPACITY 03311299" [31% Opor. ID Type ED Num. Carrier?s Carriers 30 Van. Can). Name Primary Addr. Type 31Bus HazMat [:l?a?es 32 HazMa: HazMat 32 HazMat :4on3: 33 Cargo Type [jovwn I I I I I Rename [[No Class Num. ID Numl I I I Class Num. Num. I II I i I Trade? Unit 34 m. cm Dlsabling Trams? Unit 347m. CMVDisabling [:IYes Num. I I I Type Damage? Num. I I I I I Type Damage? Sequence Ovaenta 358qu 35 Seq.2 355qu 35 Seq.4 3E Contributing Factors [Investigators Opinion) 37 Vehicie Defects {Investigators Opinion] Environmental and Roadway Conditions :33 Unlt# Contributing MayHaveConlzib. Contnbutlng MayHavo Contnb?#:93er Light Entering Roadway Roadway Surface Traf?c '63 1 99 Good. Good. Roads Type Alignment Conomon Control 32$ 1 1 4 1 96 lmea?gator?s Narrative Opinion of What Happened Field Diaqram . Not to Scale {Attach Additional Sheen if Necessary] Unit #1 was attempting to parallel park facing south against the east curb of 12500 Renoir Lane in the cul-de?sac. Unit #1 driver misapplied the accelerator pedal instead of the brake pedal and Unit #1 drove forward over the east curb in a Southeasterly direction. Unit #1 collided front distributed to two brick mailboxes and continued traveling Unit #1 than collided front left to a house at 12544 Renoir LaneTima Noti?ed How Trme Arrived Ropon Date (24HRMMInvest. .Yes Investigator ID Comp. Name{Pnnlaed}HARRIS, Hum. 7026 nu ORI - . ServicePOLICE DEPARMNT RegionIDAl OI 9' I I jihad? Wears! omens . Texas Peace Of?cer's Crash Report - Code Sheet Numbered Fields on the Refer to the Numbered Lists on this Code Sheet. Each list includes the codes that may be entered on the form and the description of each code. Page 1 of2 Law Enforcement and Use ONLY. Form 1i?1i2015 1. Roadway System 2. Roadway Part 3. Street Prefix, 4. Street Suf?x IH Interstate TL Toll Road 1 Maini?Proper Lane Direction from Int. RD Road LOOP L009 5 US US Highway N- Alternate 2 Servicel'Frontage Road or Ref Marker ST Street EXPY 5] SH 2 State Highway SP 3 3 EntranceiOn Ramp North OR Drive CT 3 PM Farm to Market CR County Road 4 Exithff Ramp NE Northeast AVE 2 Avenue Circle 4: RR Ranch Road - PR Park Road 5 ConnectorlF-?lyover 2 East BLVD Boulevard PL Place 3 RM Ranch to Market PV 2 Private Road 98 Other (Explain in Narrative) SE Southeast PKWY Parkway PARK Park El Business Interstate RC Recreational Road 8 South LN Lane CV COVE 9 so Business US LR Local RoadiStreel sw Southwest FWY Freeway as Business State (Street. Road. Ave" West HWY Highway BF Business PM Blvd.. Pl.. Trl., Beach. Alley. NW Northwest WAY Way a Si. State Loop Boat Ramp, etc.) TRL Trail 5. Unit 6. Vehicle Color 7. Body Style 8. Driver 9. Driver License 10. Commercial Driver Description BGE Beige PNK Pink P2 Passenger Car. PC Cari LicenseilD Class License Endorsements 1 Motor Vehicle BLK BIBCK PLE Purple Truck . Type A Class A Hazardous Materials 2 Train BLU Blue RED Red P4 Passenger Car. PM Pellce 1 2 Driver License AM Class A and Tank Vehicles 3 3R2 Bronze Sliver 4-1300r 2 Commercial Class Passengers 4 Pedestrian BR0 3 Brown TAN PK Pickup TL Trailer, Diner Llc. BM Class and School Bus 5 Motorized CAM Camou?age TEA Teal (green) AM Ambulance Trailer. or 3 Occupational a Class Doublei'Triple Trailer Conveyance CPR Conner TRQ TWUOISE BU Bus TR Two? 4 a is Card CM Class and Tank Vehicle with 6 TowediTrailer GLD Gold (blue) SB Yellow School BUS TT TNCK Tractor 5 Unlicensed Class HazMat 7 Non-Contact GRY Gray White FE Farm Equipment VN Van 98 Other 5 Unlicensed 5 Unlicensed ea 2 Other son a Green YEL Yellow FT Fire Thick 99 Unknown 98 Otherrotit oi as None {Explain in MAR Maroon 98 Other MC Elect?? V8999 State as Otherlotii or State Narrative; MUL Multicolored (Explain in sv Sport Utility 98 Other (Explain 99 2 Unknown 99 Unknown ONG Orange Narrative) Vehicle in Narrative) 99 Unknown 99 Unknown P11 Bus not to exceed 26.000 GVWR PE 2 2' Passenger CMVs restrict to Class only Pt 3 LOFS or over in veh equip wiairbrakes PM 2 Operation Class exempt veh authorized P15 Operation Class A exempt veh authorized P?i8 if CMV. school buses interstate Pi? if CMV, government vehicles interstate P18 only trans personal prop interstate P19 2 if CMV. trans corpsei?sickiinjured interstate P20 if CMV, privately trans passengers interstate ?l if CMV. ?rei'rescue interstate P22 if CMV. intro-city zone drivers interstate P23 li CMV. custom?harvesting interstate P24 it CMV. transporting beesr?hives interstate P25 if CMV. use in oili?water well P26 if CMV. for operation of mobile crane P27 l-iME expiration date P28 FRSI COL valid to P29 2 FRSI COL - MlvliDDiY?r or exempt veh P30 FRSI CDL Mil/liDDi?YY MMIDDIYY or exempt A veh P31 a Class only - no taxii?busi?emergency veh Outside rearview mirror or hearing aid Automatic transmission Applicable prosthetic device Medical variance documentation required Power steering Vehicle not to exceed Class Valid TX vision or limb waiver required Applicable vehicle devices P1 For Class TRC 545.424 until P2 TolFron?l P3 TolFrom work P4 ToiFrom school P5 ToiFrom workischool or a LOFS 21 or over P9 Toh?rom work or LOFS 21 or over P7 Toh?rom school or LOFS 21 or over P8 With telescopic lens P9 LOFS 21 or over bus only P10 LOFS 21 or over school bus only 13. Seat Position 1 Front Left 2 Front Center 11. Driver License Restrictions A With corrective lenses LOFS 21 or over Daytime only 0 Not to exceed 45 MPH No expressway driving Must hold valid leamer lie to TRC 545.424 applies until MMIDDIYY Vehicle not to exceed 26.000 GVWR I MC not to exceed 250 CC Licensed MC operator 21 or over in sight Moped 2 Vehicle without airbrakes CDL intrastate only Ignition interlock required OcciEssent. need CMV?see court order LOFS 21 or over vehicle above Class LOFS 21 or over vehicle above Class 12. Person Type 1 Driver 2 PassengeriOccupant 10 Cargo Area 11 Outside Vehicle 3 3 Front Right 13 Other in Vehicle P32 Other 4 Pedestrian 4 Second Seat Left 14 Passenger in Bus 5 2 Unlicensed 5 Driver of Type Vehicle 5 2 Second Seat Center 15 Pedestrian. 96 None 6 Passenger/Occupant on 6 Second Seat Right or Conveyance 98 Otheri?Out Of State VEHICLE, DRIVER, AND PERSONS Type Vehicle 7 Third Seat Left 98 Other {Explain in 99 Unknown 98 Other {Explain in Narrative) 8 Third Seat Center Narrative}I 99 Unknown 9 Third Seat Right 99 7? 14. injury Severity 15. Ethnicity 16. Sex Ejected 18. Restraint Used 19. Airbag A lncapacitating Injury White I ?l Male 1 No 1 Shoulder and Lap Belt 7 Child Booster Seat 1 Not Deployed Non-lncapacltating Black 2 Female 2 Yes 2 Shoulder Belt Only 95 NUDE 2 Deployed, Front injury Hispanic 99 Unknown 3 Yes. Partial 3 Lap Belt Only 97 Applicable 3 Deployed, Side 2 Possible Injury A Asian 97 Not Applicable 4 2 Child Seat. Facing Forward 98 Other (Explain in 4 Deployed. Rear 2 Killed i Amer, indianlAlaskan Native 99 Unknown 5 Child Seat. Facing Rear Narrative) 5 Deployed. Multiple Not injured 98 Other 6 Child Seat. Unknown 99 Unknown 97 Not Applicable 99 Unknown 99 Unknown 99 Unknown 20. Helmet Use 21. Solicitation 22- Alcohol Specimen Type" 27. Vehicle Damage Rating 1 Not Worn Solicit 1 Breath in most cases. enter in the format 2 Worn. Damaged No Solicit 2 Blood where 3 Worn. Not Damaged . 3 Urine XX is the Direction of Force 4 Worn. Unk. Damage 4 Refused ABC is the Damage Description 2? or 3?letter 9? Not Applicable 96 None code). and is the Damage Severity (0-7). 99 Unknown if Worn 98 Other (Explain in Narrative} an 23. Drug Specimen 25. Drug Category 26. Financial 1? Spef'al 059895 use: IF Type 2 CNS Depressants Responsibility Type 32:; hurried. girOLdut: n? 2 Blood 3 one Stimulants 1 Liability Insurance Policy to 53:1? Dene; ?e ?3 CO 5 3 Urine 4 Hallucinogens 2 Proof oi Liability Insurance vx?o ur?jemr? dime u? 4 Refused 6 Narcotic Analgesics 3 Insurance Binder MC 1 ?9 99 0 moped. scooter. etc. 96 ?one 7 [?haiants 4 Bond 98- Other {Explain in 8 Cannabis 5 2 Certi?cate of Deposit with pp we a rm rac or, Narrative} 10 Dissociative Anesthetics Comptroller too 11 Multiple Drugs (Exolain in 6 Certi?cate of De coil with 24. Drug Test Narrative) County Judge 1 Positive 97? Applicable 7 Certi?cate of Self?Insurance 2 Negative as Other Drugs (Explain in '97 3 Not Applicable Narrative} 99 Unknown 99 Unknown in?ux Wm??f #1erth Texas Peace Officer's Crash Report - Code Sheet Numbered Fields on the CR-3 Refer to the Numbered Lists on this Code Sheet. Each list includes the codes that may be entered on the form and the description of each code. Page 2 of 2 Law Enforcement and Use ONLY. Form 1i1i2015 COMMERCIAL MOTOR VEHICLE 28. Vehicle Operation 1 Interstate Commerce 1 US DOT 2 intrastate Commerce 2 3 Not in Commerce 3 4 Government 96 None 5 Personal 29. Carrier ID Type 98 Other [Explain in Narrative) 30. Vehicle Type 1 Passenger Car 2 Light Truck 3 Bus (9?15) 4 Bus {315) 7 Truck Trailer 8 Truck Tractor (Bobtail) 9 Tracton'Semi Trailer 10 Tracton?Double-Trailer 11 Trailer 5 Single Unit Truck 2 Axles 6 Tires 6 Single Unit Truck 3 or More Axles 98 Other (Explain in Narrative) 99 Unknown Heavy Truck 31. Bus Type 32. Hazardous Material Class Number 0 2 Not a Bus 1 Explosives 1 School 2 Gases (Public or Private) 3 Flammable Liquids 2 Transit 4 Flammable Solids 3 intercity 5 Oxidizers and Organic Peroxides 4 Charter 6 Toxic Materials and infectious Substances 5 Other 7' Radioactive Materials 6 Shuttle 8 Corrosive Materials 9 Not Reported! 9 Miscellaneous Dangerous Goods Unknown . 33. Cargo Body Style 1 Bus (9-15) 8 Auto Transporter 2 Bus (315) 9 Garbage Refuse 3 Van/Enclosed Box 10 2 Grain Chips Gravel 4 Cargo Tank 11 Pole 5 Flatbed 13 interrnodal 6 Dump 14 Logging 7 Concrete Mixer 15 2 Vehicle Towing Another Vehicle 97 Not Applicable 98 Other (Explain in Narrative) 34. Trailer Type 1 Full Trailer 2 Semi~Traiier 3 Pole Trailer 35. Sequence of Events 1 Non-Collision: Ran Off Road 2 Non?Collision: Jackknife 3 Non-Collision: Overturn Rollover 4 Non-Collision: Downhill Runaway 5 Non-Collision: Cargo Loss Or Shift 6 Non-Collision: Explosion Or Fire 7 Non-Collision: Separation of Units 8 Non?Collision: Cross Mediaanenteriine 9 NonvColiision: Equipment Failure 10 Non-Collision: Other 11 Non-Collision: Unknown 12 CollisiOn involving Pedestrian 13 Collision involving Motor Vehicle in Transport 14 Collision involving Parked Motor Vehicle 15 Collision Involving Train 16 Collision involving Pedaicycle 17 Collision involving Animal 18 Collision involving Fixed Object 19 Collision With Work Zone Maintenance Equipment 20 Collision With Other Movable Object 21 Collision With Unknown Movable Object 98 Other (Explain in Narrative) FACTORS AND 36. Factors and Conditions 1 Animal on Road - Domestic 2 Animal on Road - Wild 3 Backed without Safety 4 Changed Lane when Unsafe 33 Failed to Yield ROW Open intersection 34 Failed to Yield Private Drive 35 Failed to Yield ROW - Stop Sign 36 2 Failed to Yield ROW To Pedestrian 56 Parked without Lights 5? 2 Passed in No Passing Lane 58 2 Passed on Right Shoulder 59 Pedestrian FTYROW to Vehicle 14 Disabled in Traf?c Lane 37 Failed to Yield ROW Turning Left 38 Failed to Yield ROW Turn on Red 60 Unsafe Speed 15 Disregard Stop and Go Signal 16 Disregard Stop Sign or Light 1? Disregard Turn Marks at Intersection 18 Disregard Warning Sign at Construction 19 Distraction in Vehicle 20 Driver inattention 21 Drove Without Headlights 22 Failed to Control Speed 23 3 Failed to Drive in Single Lane 24 Failed to Give Half of Roadway 25 Failed to Heed Warning Sign 26 2 Failed to Pass to Left Safely 2? ,Failed to Pass to Right Safely 28 Failed to Signal or Gave Wrong Signal 29 Failed to Stop at Proper Place 30 Failed to Stop for School Bus 31 2 Failed to Stop for Train 32 Failed to Yield ROW Emergency Vehicle 39 Failed to Yield ROW Yield Sign 40 2 Fatigued or Asleep 41 Faulty Evasive Action 42 2 Fire in Vehicle 43 Fleeing or Evading Police 44 Followed Too Closely 45 Had Been Drinking 46 Handicapped Driver {Explain in Narrative) 4? lli {Explain in Narrative) 48 impaired Visibility {Explain in Narrative) 49 Improper Startfrom Parked Position 50 Load Not Secured 51 Opened Door into Traf?c Lane 52 Oversized Vehicle or Load 53 Overtake and Pass Insuf?cient Clearance 54 Parked and Failed to Set Brakes 55 Parked in Traf?c Lane 61 Speeding {Over Limit) 82 Taking Medication {Explain in Narrative} 63 Turned improperly Cut Comer on Left 64 Turned improperly Wide Right 85 Turned improperly Wrong Lane 66 Turned when Unsafe 6? Under influence Alcohol 68 2 Under in?uence Drug 69 Wrong Side Approach or intersection 70 Wrong Side Not Passing 71 Wrong Way One Way Road 73 Road Rage ?4 Device Use - Talking 75 Device Use Texting 76 Device Use - Other 77 Device Use - Unknown 98 Other (Explain in Narrative) 37. Vehicle Defects 5 Defective or No Headlamps 6 Defective or No Stop Lamps 7 Defective or No Tail Lamps 8 Defective or No Turn Signal Lamps 9 Defective or No Trailer Brakes 10 Defective or No Vehicle Brakes 11 Defective Steering Mechanism 12 Defective or Slick Tires 13 Defective Trailer Hitch 98 Other (Explain in Narrative) 38. Weather Condition 1 Clear 2 Cloudy 3 3 Rain 4' SieetlHaii 5 2 Snow 6 Fog 7 7- Blowing 8 2 Severe Crosswinds 98 Other (Explain in Narrative) 99 Unknown 39. Light Condition 1 Daylight 2 Dark. Not Lighted 3 Dark, Lighted 4 Dark, Unknown Lighting 5 Dawn 6 Dusk 98 Other (Explain in Narrative) 99 Unknown 40. Entering Roads 2 Three Entering Roads - 3 Three Entering Roads 4 Four Entering Roads 5 Five Entering Roads 6 Six Entering Roads 7 Traf?c Circle 8 Cloverleaf 97 Not Applicable 98 Other (Explain in Narrative) 41. Roadway Type 42. Roadway Alignment 43. Surface Condition 44. Traffic Control 1 Two?Way. Not Divided 1 Straight. Level 1 Dry 2 inoperative (Explain in Narrative) 2 Two~Way, Divided, Unprotected 2 Straight. Grade 2 Wet 3 Of?cer Median 3 Straight. Hillcrest 3 Standing Water 4 Flagman 3 Two-Way. Divided. Protected 4 Curve, Level 4 Snow 5 2 Signal Light Median 5 Curve, Grade 5 Slush 6 Flashing Red Light 4 One-Way 8 Curve) Hillcrest 6 ice 7 Flashing Yellow Light Other (Explain in Narrative) 98 Other (Explain in Narrative) 7 Sand, Mud. Dirt 8 Stop Sign 99 Unknown 98 Other (Explain in Narrative) 9 Yield Sign 99 Unknown 10 Warning Sign 11 Center StripelDivider 12 No Passing Zone 13 2 RR GateiSignal 15 Crosswalk 16 Bike Lane 17 Marked Lanes 18 Signal Light With Red Light Running Camera 96 None 98 Other (Explain in Narrative) EXHIBIT Bet/?67? E?gmem?g Repon? MCCLENNY I MOSELEY 8. ASSOCIATES EXHIBIT Suzdme Profem'om/ Eyiimm?e Writer? Eytmm?e MCCLENNY I MOSELEY 8. ASSOCIATES 1 Professional Public Adjusters, LLC Tony Sherriff 3379 Howard Rd Waxahachie Texas 75165 Insured: Property: CALLAWAY-DAVIS_SUZANNE12544 12544 Renoir Lane Dallas 75230 Home: (214) 392-1387 Claim Rep.: Business: Tony Sherriff 3379 Howard Rd Waxahachie , TX 75165 Business: E-mail: (817) 602-7422 tonysherriff46@gmail.com Estimator: Business: Tony Sherriff 3379 Howard Rd Waxahachie , TX 75165 Business: E-mail: (817) 602-7422 tonysherriff46@gmail.com Claim Number: Date of Loss: Date Inspected: Price List: Estimate: Policy Number: 10/28/2016 TXDF8X_OCT16 Restoration/Service/Remodel CALLAWAY_ Date Received: Date Entered: Type of Loss: 10/29/2016 5:58 PM 2 Professional Public Adjusters, LLC Tony Sherriff 3379 Howard Rd Waxahachie Texas 75165 CALLAWAY_ General DESCRIPTION QTY 1. Taxes, insurance, permits & fees (Bid Item) RESET REMOVE REPLACE TAX O&P TOTAL 0.00 1,000.00 0.00 200.00 1,200.00 4.00 EA 566.89 0.00 0.00 453.52 2,721.08 250.00 SF 0.00 1.00 2.06 50.42 302.48 38.50 0.00 0.00 1,232.00 7,392.00 0.00 225.03 0.00 45.00 270.03 1.00 EA This will include insurance for contents manipulation 26. Dumpster load - Approx. 40 yards, 7-8 tons of debris 50. window protection - plastic and tape - 10 mil Line item changed to window protection to prevent damage during exterior brick replacement 207. General Demolition - per hour 160.00 HR General labor to remove demolished bricks to dumpsters 4 men 1 week 238. Electrical - Labor Minimum 1.00 EA TO DO AN ELECTRICAL SURVEY OF THE HOUSE SYSTEM AND DELINIATE REPAIRS. A SUPLEMENTAL ESTIMATE MAY BE NEEDED 239. Alternate Living Expences 42.00 DA 0.00 500.00 1,732.50 0.00 22,732.50 Line item changed as no other to cover ALE. Allowance for 6 weeks (42 days) of alternate living expenses while the house is repaired. It will not be livable during this time. Totals: General 1,734.56 1,980.94 34,618.09 Exterior Front Elevation DESCRIPTION QTY RESET REMOVE REPLACE TAX O&P TOTAL 2a. Remove Brick - structural (Giant brick), 4" 655.00 SF 1.62 0.00 0.00 212.22 1,273.32 2b. Brick - structural (Giant brick), 4" 655.00 SF 0.00 7.54 236.14 1,034.96 6,209.80 To rebuild brick mail box structure damaged in accident 224a. Remove House wrap (air/moisture barrier) 656.00 SF 0.03 0.00 0.00 3.94 23.62 224b. House wrap (air/moisture barrier) 656.00 SF 0.00 0.27 8.12 37.04 222.28 196a. Remove Mailboxes commercial/group - keyed 2.00 EA 2.40 0.00 0.00 0.96 5.76 196b. Mailboxes - commercial/group keyed 2.00 EA 0.00 119.20 19.00 51.48 308.88 263.26 1,340.60 8,043.66 Totals: Front Elevation CALLAWAY_ 11/3/2016 Page: 2 3 Professional Public Adjusters, LLC Tony Sherriff 3379 Howard Rd Waxahachie Texas 75165 chimney Height: 8' 173.33 190.42 1.90 21.67 1' 11" 9" 1' 6" 9' 7" 8' 11" chimney DESCRIPTION QTY Living Room 27a. Remove Brick veneer SF Walls SF Walls & Ceiling SY Flooring LF Ceil. Perimeter RESET REMOVE REPLACE TAX O&P TOTAL 1.75 0.00 0.00 72.46 434.71 0.00 8.01 61.48 343.92 2,063.47 19.25 0.00 0.00 3.86 23.11 371.84 6.84 75.72 454.40 207.00 SF 27b. Brick veneer 207.00 17.09 SF Ceiling 17.09 SF Floor 21.67 LF Floor Perimeter Foyer/Entry SF 28a. Remove Chimney flashing - large (32" x 60") 1.00 EA 28b. Chimney flashing - large (32" x 60") 1.00 EA 30a. Remove Fireplace - chimney cap concrete 1.00 EA 28.89 0.00 0.00 5.78 34.67 30b. Fireplace - chimney cap concrete 1.00 EA 0.00 143.67 1.89 29.12 174.68 32a. Remove Fireplace - chimney chase cover - sheetmetal 1.00 EA 14.43 0.00 0.00 2.88 17.31 32b. Fireplace - chimney chase cover sheetmetal 1.00 EA 354.39 15.86 74.06 444.31 86.07 607.80 3,646.66 REPLACE TAX O&P TOTAL Dining Room 0.00 Family dining room Toilet 1 0.00 Closet 1 Totals: chimney Chimney 2 Chimney 1 (A1) QTY RESET DESCRIPTION REMOVE Kitchen 202a. Remove Chimney flashing large (32" x 60") - copper 1.00 EA 19.25 0.00 0.00 3.86 23.11 202b. Chimney flashing - large (32" x 60") - copper 1.00 EA 0.00 751.63 38.17 157.96 947.76 203a. Remove Sheathing - plywood 1/2" CDX 192.00 SF 0.43 0.00 0.00 16.52 99.08 203b. Sheathing - plywood - 1/2" CDX 192.00 SF 0.00 1.40 10.14 55.78 334.72 Family Room Up For roof protection during chimney rebuild Laundry Room 236.00 SF Stairs1.75 0.00 0.00 82.60 495.60 200b. Brick veneer 236.00 SF 0.00 8.01 70.09 392.10 2,352.55 EA 28.89 0.00 0.00 5.78 34.67 1.00 EA 0.00 143.67 1.89 29.12 174.68 204a. Remove Fireplace - chimney cap - concrete 204b. Fireplace - chimney cap concrete CALLAWAY_ Hallway 1.00 Up 200a. Remove Brick veneer 11/3/2016 Chimney2 (A1) Bedroom 1 Garage Page: 3 4 Professional Public Adjusters, LLC Tony Sherriff 3379 Howard Rd Waxahachie Texas 75165 CONTINUED - Chimney 2 DESCRIPTION QTY RESET REMOVE REPLACE TAX O&P TOTAL 205a. Remove Flue cap - oversized 1.00 EA 14.43 0.00 0.00 2.88 17.31 205b. Flue cap - oversized 1.00 EA 0.00 214.45 15.82 46.06 276.33 136.11 792.66 4,755.81 Totals: Chimney 2 Left Elevation DESCRIPTION QTY RESET REMOVE REPLACE TAX O&P TOTAL 5a. Remove Brick veneer 675.00 SF 1.75 0.00 0.00 236.26 1,417.51 5b. Brick veneer 675.00 SF 0.00 8.01 200.48 1,121.46 6,728.69 23a. Remove House wrap (air/moisture barrier) 675.00 SF 0.03 0.00 0.00 4.06 24.31 23b. House wrap (air/moisture barrier) 675.00 SF 0.00 0.27 8.35 38.14 228.74 208.83 1,399.92 8,399.25 Totals: Left Elevation Rear Elevation DESCRIPTION QTY 225. Wood fence 5' - 6' high - Detach & reset - per 8' section RESET 1.00 EA REMOVE REPLACE TAX O&P TOTAL 0.00 69.11 0.18 13.86 83.15 To disconnect and replace 6ft high wood fence from structure to replace brick siding. 33a. Remove Brick veneer 439.00 SF 1.75 0.00 0.00 153.66 921.91 33b. Brick veneer 439.00 SF 0.00 8.01 130.38 729.36 4,376.13 34a. Remove House wrap (air/moisture barrier) 439.00 SF 0.03 0.00 0.00 2.64 15.81 34b. House wrap (air/moisture barrier) 439.00 SF 0.00 0.27 5.43 24.78 148.74 35a. Remove Jamb and trim for overhead door unit LF 0.75 0.00 0.00 0.00 0.00 35b. Jamb and trim for overhead door unit LF 0.00 5.32 0.00 0.00 0.00 37. Detach & Reset Overhead door & hardware - 18' x 7' 1.00 EA 0.00 0.00 0.00 52.36 314.15 135.99 976.66 5,859.89 Totals: Rear Elevation 261.79 Right Elevation CALLAWAY_ 11/3/2016 Page: 4 5 Professional Public Adjusters, LLC Tony Sherriff 3379 Howard Rd Waxahachie Texas 75165 CONTINUED - Right Elevation DESCRIPTION QTY RESET REMOVE REPLACE TAX O&P TOTAL 42. Central air - condenser unit Detach & reset 1.00 EA 0.00 494.68 0.00 98.94 593.62 43. Wood fence 5' - 6' high - Detach & reset - per 8' section 2.00 EA 0.00 69.11 0.35 27.72 166.29 To disconnect and replace 6ft high wood fence from structure to replace brick siding.. 2 locations 198a. Remove Brick veneer 1,267.36 SF 1.75 0.00 0.00 443.58 2,661.46 198b. Brick veneer 1,267.36 SF 0.00 8.01 376.41 2,105.60 12,633.56 199a. Remove House wrap (air/moisture barrier) 1,267.36 SF 0.03 0.00 0.00 7.60 45.62 199b. House wrap (air/moisture barrier) 1,267.36 SF 0.00 0.27 15.68 71.58 429.45 226. Swimming Pool - Labor Minimum 0.00 248.75 0.00 49.76 298.51 392.44 2,804.78 16,828.51 1,222.70 7,922.42 47,533.78 1.00 EA to detach and reset pool equipment as needed for brick replacement Totals: Right Elevation Total: Exterior 2' 2' 2" 2" 7'' 8"11' 6" 11' 6" 1' 6" 6" 1' 1' 1' 8" 8" 4' 8' 4" 4' 8' 4" 14' 4" 15' 5' 5' 3" 3" 2' 2' Main Level 9' 8" 9' 6' 7' 4" 4" 1' 3" 6' 1" 1" 7' 7" 10' 1" 9' 5" 9' 2' 4" 4" 10'4"7' 7' 3" 11" 2' 8' 8" 4" 7' 23' 10" 2" 23' 35' 2" 2" 35' 9' 9' Dwelling footprint 3,077.25 6,416.25 371.00 384.66 74' 75' 9" 5" 2'7 2' 2' 2' 4' 8" 8" 4' 8' 11" 11" 8' 15' 14' 3" 7" 13' 13' 1" 1" Dwelling footprint 21' 21' 7" 7" Height: 8' SF Walls SF Walls & Ceiling SY Flooring LF Ceil. Perimeter 3,339.00 SF Ceiling 3,339.00 SF Floor 384.66 LF Floor Perimeter 25' 25' 3" 3" 6' 6" 6"11' 6' 6' 6' 4" 4" 11' 8" DESCRIPTION QTY RESET REMOVE REPLACE TAX O&P TOTAL 221a. Remove Trim board - 1" x 4" installed (pine) 384.66 LF 0.31 0.00 0.00 23.84 143.08 221b. Trim board - 1" x 4" - installed (pine) 384.66 LF 0.00 2.71 43.16 217.12 1,302.71 To replace the freeze board on exterior perimeter 222. Seal & paint trim - two coats 384.66 LF 0.00 0.95 3.17 73.72 442.32 229. Mask the surface area per square foot - plastic and tape - 4 mil 112.00 SF 0.00 0.17 0.46 3.90 23.40 120.00 SF 1.62 0.00 0.00 38.88 233.28 To mask the overhead door 230a. Remove Brick - structural (Giant brick), 4" CALLAWAY_ 11/3/2016 Page: 5 6 Professional Public Adjusters, LLC Tony Sherriff 3379 Howard Rd Waxahachie Texas 75165 CONTINUED - Dwelling footprint DESCRIPTION QTY REMOVE REPLACE TAX O&P TOTAL 0.00 7.54 43.26 189.62 1,137.68 Totals: Dwelling footprint 90.05 547.08 3,282.47 Total: Main Level 90.05 547.08 3,282.47 230b. Brick - structural (Giant brick), 4" RESET 120.00 SF TO REPLACE BRICK FENCE TO MATCH BUILDING AT FRON RIGHT interior Contents DESCRIPTION REMOVE REPLACE TAX O&P TOTAL 128.00 EA 0.00 42.97 0.00 1,100.04 6,600.20 32.00 HR 0.00 43.40 137.50 277.76 1,804.06 1.00 EA 0.00 2,000.00 0.00 400.00 2,400.00 96. Provide box, packing paper & tape medium size 15.00 EA 0.00 3.21 8.75 10.36 67.26 97. Provide box, packing paper & tape large size 15.00 EA 0.00 4.15 11.48 13.42 87.15 98. Evaluate pack & inventory bric-abrac - per Med box 15.00 EA 0.00 11.14 20.54 34.14 221.78 99. Evaluate pack & inventory bric-abrac - per Lg box 15.00 EA 0.00 14.17 26.36 43.48 282.39 101. Evaluate pack & inventory bric-abrac - per Sml box 25.00 EA 0.00 9.03 27.32 46.06 299.13 102. Provide picture-frame box, packing paper & tape 25.00 EA 0.00 4.92 23.03 26.58 172.61 300.00 LF 0.00 0.19 10.81 12.34 80.15 1.00 EA 0.00 14.24 2.69 3.08 20.01 40.00 EA 0.00 10.91 82.76 94.48 613.64 4.00 EA 0.00 163.59 64.78 130.88 850.02 92. Contents - move out then reset 105. Contents Evaluation and/or Supervisor/Admin - per hour 95. Fine art - storage and insurance 103. Bubble Wrap - Add-on cost for fragile items 104. Provide TV box, packing paper & tape 106. Provide furniture heavyweight blanket/pad 208. Moving van (24' - 27') and equipment - per day QTY RESET To move house contents to off site storage and return. Due to dwelling being in Home owners Assn it is not possible to use on site storage containers 209. Off site storage allowance 1.00 MO 0.00 500.00 41.25 108.26 649.51 2,300.88 14,147.91 For off site storage due to dwelling being in Home owners Assn it is not possible to use on site storage containers Totals: Contents CALLAWAY_ 457.27 11/3/2016 Page: 6 7 Professional Public Adjusters, LLC Tony Sherriff 3379 Howard Rd Waxahachie Texas 75165 2' 8' 10" Dining Room 10' 5' 4" Family dining room Dining Room 15' 6" 6' 2" Foyer/Entry 4' 10" 3' 1' 7" 2' 2" 4' 6" 2' 2" 15' 5' 4" 2' 1" 3' 3' 6" 1' 9" 3' 8" 5' 2' 2' 6" 4' 2" 1' 10" Height: 8' 445.22 692.81 27.51 55.65 Toilet 1 Missing Wall SF Walls SF Walls & Ceiling SY Flooring LF Ceil. Perimeter 8' 10 3/16" X 8' 247.59 SF Ceiling 247.59 SF Floor 55.65 LF Floor Perimeter Opens into FAMILY_DININ Closet 1 DESCRIPTION 55. Carpenter - General Framer - per hour Kitchen Chimney 1 (A1) QTY 32.00 HR RESET REMOVE REPLACE TAX O&P TOTAL 0.00 65.94 0.00 422.02 2,532.10 TO REPAIR AND REFRAME WALL AND CEILING DAMAGE AT SITE OF CRASH Family Room 56a. Remove Wood window - picture (fixed), 12-23 sf 2.00 EA 26.08 0.00 0.00 10.44 62.60 56b. Wood window - picture (fixed), 12-23 sf Stairs 2.00 EA 0.00 483.89 70.49 207.66 1,245.93 193a. Remove Window sill 6.00 LF 0.54 0.00 0.00 0.64 3.88 193b. Window sill 6.00 LF 0.00 2.26 0.39 2.80 16.75 45.00 SF 0.00 5.86 21.76 57.10 342.56 58a. Remove Batt insulation - 4" - R11unfaced batt 117.00 SF 0.18 0.00 0.00 4.22 25.28 58b. Batt insulation - 4" - R11unfaced batt 117.00 SF 0.00 0.48 2.70 11.78 70.64 59a. Remove 1/2" drywall - hung, taped, floated, ready for paint 124.00 SF 0.32 0.00 0.00 7.94 47.62 59b. 1/2" drywall - hung, taped, floated, ready for paint 124.00 SF 0.00 1.88 4.40 47.50 285.02 81. Texture drywall - smooth / skim coat 692.81 SF 0.00 1.04 4.57 145.02 870.11 Up Laundry Room Up Hallway 57. Add Garage on for impact resistant laminated glass Closet 2 Ceiling has machine texture. This needs to be floated to a smooth finish before re-textureing to ensure a consistant finish throughout. A patch will always show up as a patch. 61. Texture drywall - machine 692.81 SF 0.00 0.38 1.71 53.00 317.98 63. Seal the walls and ceiling w/latex based stain blocker - one coat 692.81 SF 0.00 0.44 4.00 61.76 370.60 64. Paint the walls and ceiling - two coats 692.81 SF 0.00 0.66 10.86 93.64 561.75 234. Paint crown molding - two coats 55.65 LF 0.00 0.99 0.50 11.12 66.71 194. Seal & paint window sill 12.00 LF 0.00 1.72 0.22 4.16 25.02 85a. Remove Oak flooring - select grade - no finish 247.59 SF 1.81 0.00 0.00 89.62 537.76 85b. Oak flooring - select grade - no finish 247.59 SF 0.00 7.59 98.25 395.50 2,372.96 CALLAWAY_ 11/3/2016 Page: 7 8 Professional Public Adjusters, LLC Tony Sherriff 3379 Howard Rd Waxahachie Texas 75165 CONTINUED - Dining Room DESCRIPTION QTY RESET REMOVE REPLACE TAX O&P TOTAL 223a. Add for glued down application over concrete substrate 247.59 SF 1.16 0.00 0.00 57.44 344.64 223b. Add for glued down application over concrete substrate 247.59 SF 0.00 1.03 17.98 54.60 327.60 87. Sand, stain, and finish wood floor 247.59 SF 0.00 3.73 17.77 188.26 1,129.54 88. Add for dustless floor sanding 247.59 SF 0.00 1.00 0.00 49.52 297.11 89. Additional coats of finish (per coat) 495.18 SF 0.00 0.86 8.58 86.90 521.33 65. Detach & Reset Baseboard - 3 1/4" MDF w/profile 55.65 LF 0.00 0.00 0.09 21.40 128.34 66. Paint baseboard - two coats 55.65 LF 0.00 0.96 0.50 10.78 64.70 231a. Remove Shutters - wood louvered or paneled - Large 2.00 EA 4.82 0.00 0.00 1.92 11.56 231b. Shutters - wood - louvered or paneled - Large 2.00 EA 0.00 323.25 43.23 137.94 827.67 232a. Remove Interior door - birch stain grade jamb & casing 1.00 EA 14.43 0.00 0.00 2.88 17.31 232b. Interior door - birch - stain grade jamb & casing 1.00 EA 0.00 196.26 12.85 41.84 250.95 34.00 LF 0.00 0.96 0.31 6.58 39.53 321.16 2,285.98 13,715.55 233. Paint casing - two coats 1.92 Totals: Dining Room Foyer/Entry 3' 4" 3' 8" Foyer/Entry 6' 11" Height: 8' 305.89 397.44 10.17 38.24 3' 11" 4' 1" 6' 2" 3' 6' 2' 11" 3' 3" 5' 3" 5' 3" 1' 4" 8" 7' 7" SF Walls SF Walls & Ceiling SY Flooring LF Ceil. Perimeter 91.56 SF Ceiling 91.56 SF Floor 38.24 LF Floor Perimeter 6' 7" Dining Room Missing Wall 5' 11 13/16" X 8' Opens into LIVING_ROOM Missing Wall 7' 7" X 8' Opens into FAMILY_DININ DESCRIPTION QTY RESET REMOVE REPLACE TAX O&P TOTAL 91.56 SF 0.00 0.29 0.30 5.38 32.23 70. Mask more than the floor Closet 1 perimeter per square foot - plastic and tape - 4 mil 344.12 SF 0.00 0.17 1.42 11.98 71.90 71. Texture drywall - smooth / skim coat 397.44 SF 0.00 1.04 2.62 83.18 499.14 Family dining room 69. Floor protection - heavy paper and Toilet 1 tape Chimney 1 (A1) Kitchen CALLAWAY_ 11/3/2016 Family Room Up Laundry Room Page: 8 9 Professional Public Adjusters, LLC Tony Sherriff 3379 Howard Rd Waxahachie Texas 75165 CONTINUED - Foyer/Entry DESCRIPTION QTY RESET REMOVE REPLACE TAX O&P TOTAL Ceiling has machine texture. This needs to be floated to a smooth finish before re-textureing to ensure a consistant finish throughout. A patch will always show up as a patch. 72. Texture drywall - machine 397.44 SF 0.00 0.38 0.98 30.40 182.41 73. Seal the walls and ceiling w/latex based stain blocker - one coat 397.44 SF 0.00 0.44 2.30 35.44 212.61 74. Paint the walls and ceiling - two coats 397.44 SF 0.00 0.66 6.23 53.70 322.24 75. Mask and cover light fixture 5.00 EA 0.00 9.41 0.26 9.48 56.79 76. Detach & Reset Heat/AC register Mechanically attached 1.00 EA 12.24 0.00 0.00 0.00 2.44 14.68 77. Detach & Reset Crown molding - 5 1/4" 38.24 LF 2.58 0.00 0.00 0.06 19.76 118.48 78. Paint crown molding - two coats 38.24 LF 0.00 0.99 0.35 7.66 45.87 195a. Remove 1/2" drywall - hung, taped, floated, ready for paint 64.00 SF 0.32 0.00 0.00 4.10 24.58 195b. 1/2" drywall - hung, taped, floated, ready for paint 64.00 SF 0.00 1.88 2.27 24.52 147.11 16.79 288.04 1,728.04 To replace drywall on dividing wall at foyer that is knocked 1 inch out of vertical Totals: Foyer/Entry 7' 5" 8' 6" 6' Living Room 2' 1" 18' 5" 2' 1" 9' 10" 16' 4" Height: 8' 653.63 1,073.41 46.64 Dining Room 81.70 Foyer/Entry 1' 5" 12' 5" 7' 9" 2' 5" 4' 6" 2' 6" 3' 3' 2' 2" 2' 9" 8' 1" 12' 9" 16' 8" 18' 9" 4' 2" 4' 2" 7' 1" 7' 9" Living Room 7' 1" 8' 6" chimney 8' 11" 9' 7" 11' 7" 11' 5" 5' 8" 7" 9" 5' 10" Family dining room Missing Wall Toilet 1 DESCRIPTION Closet 1 9. Floor protection - heavy paper and tape Chimney 1 (A1) 419.77 SF 18. Texture drywall - smooth / skim coat 5' 11 13/16" X 8' QTY Kitchen 1,073.41 SF SF Walls SF Walls & Ceiling SY Flooring LF Ceil. Perimeter RESET 419.77 SF Ceiling 419.77 SF Floor 81.70 LF Floor Perimeter Opens into FOYER_ENTRY REMOVE REPLACE TAX O&P TOTAL 0.00 0.29 1.39 24.62 147.74 0.00 1.04 7.08 224.70 1,348.13 Family Room Ceiling has machine texture. This needs to be floated to a smooth finish before re-textureing to ensure a consistant finish throughout. A patch will always show up as a patch. Up Laundry Room Stairs 1,073.41 SF 0.00 0.44 6.20 95.70 574.20 12. Paint the walls and ceiling - two coats Chimney2 (A1) 1,073.41 SF 0.00 0.66 16.83 145.06 870.34 Continuous paintBedroom from1 foyer CALLAWAY_ Up 67. Seal the walls and ceiling w/latex based stain blocker - one coat Hallway Garage 11/3/2016 Bathroom 1 Closet 1 Toilet 1 Closet 2 Page: 9 10 Professional Public Adjusters, LLC Tony Sherriff 3379 Howard Rd Waxahachie Texas 75165 CONTINUED - Living Room chimney DESCRIPTION QTY 8. Texture drywall - machine Living Room Foyer/Entry 237. Paint crown molding - two coats RESET REMOVE REPLACE TAX O&P TOTAL 1,073.41 SF 0.00 0.38 2.66 82.12 492.68 81.70 LF 0.00 0.99 0.74 16.32 97.94 34.90 588.52 3,531.03 Dining Room Totals: Living Room Family dining room Toilet 1 Closet 1 Family Room 4' 1" 3' 3' 11" 7' 4" 13' 3" 10' Chimney 1 (A1) 11' 3" 5' 2" 13' 1" 12' 11" 5' 6" 10' 7" 10' 9" 2' 4" Up Laundry Room Height: 8' 514.56 922.40 45.32 71.78 Missing Wall - Goes to Floor Missing Wall Garage Missing Wall DESCRIPTION Closet 1 407.84 SF Ceiling 407.84 SF Floor 63.50 LF Floor Perimeter Stairs Chimney2 (A1) Bedroom 1 SF Walls SF Walls & Ceiling SY Flooring LF Ceil. Perimeter Up 8' 1" 13' 8" 4' 4" 3' 2' 6" 13' 6" Family Room 4' 11" Hallway9" Kitchen 3' 4" 13' 5" 7' 6" 19' 3" Bathroom 1 4' 11" X 6' 8" Opens into HALLWAY 3' 4 3/8" X 8' Opens into STAIRS 11' 2 5/8" X 8' Opens into KITCHEN QTY RESET REMOVE REPLACE TAX O&P TOTAL Closet 2 108. Floor protection - heavy paper and tape 407.84 SF 0.00 0.29 1.35 23.94 143.56 109. Mask more than the floor perimeter per square foot - plastic and tape - 4 mil 571.51 SF 0.00 0.17 2.36 19.92 119.44 Toilet 1 192. Detach & Reset Ceiling fan & light - High grade 1.00 EA 157.84 0.00 0.00 0.00 31.56 189.40 115. Detach & Reset Heat/AC register Mechanically attached 1.00 EA 12.24 0.00 0.00 0.00 2.44 14.68 114. Mask and cover light fixture 4.00 EA 0.00 9.41 0.21 7.56 45.41 922.40 SF 0.00 1.04 6.09 193.08 1,158.47 110. Texture drywall - smooth / skim coat Ceiling has machine texture. This needs to be floated to a smooth finish before re-textureing to ensure a consistant finish throughout. A patch will always show up as a patch. 111. Texture drywall - machine 922.40 SF 0.00 0.38 2.28 70.56 423.35 112. Seal the walls and ceiling w/latex based stain blocker - one coat 922.40 SF 0.00 0.44 5.33 82.24 493.43 113. Paint the walls and ceiling - two coats 922.40 SF 0.00 0.66 14.46 124.66 747.90 0.00 0.00 0.12 37.06 222.37 0.00 0.99 0.65 14.36 86.07 Paint is continuous from adjoining rooms 116. Detach & Reset Crown molding 5 1/4" 71.78 LF 117. Paint crown molding - two coats 71.78 LF CALLAWAY_ 2.58 11/3/2016 Page: 10 11 Professional Public Adjusters, LLC Tony Sherriff 3379 Howard Rd Waxahachie Texas 75165 CONTINUED - Family Room mney DESCRIPTION QTY REMOVE REPLACE Totals: Family Room Room TAX O&P TOTAL 32.85 607.38 3,644.08 Foyer/Entry Dining Room Kitchen 5' 4" Closet4'1 2" 7' 10" 11' 3" Chimney 1 (A1) Family Room 27' 2" 27' 6" 9' 11" 10' 3" 2' 6" 1' 10" Family dining room Toilet 1 Kitchen Height: 8' 505.76 775.66 29.99 63.22 7" 4' 1" 2' 2" 3' 5" Laundry Room Up Stairs SF Walls SF Walls & Ceiling SY Flooring LF Ceil. Perimeter 269.91 SF Ceiling 269.91 SF Floor 63.22 LF Floor Perimeter 5' 4" X 8' Opens into FAMILY_DININ Missing Wall 11' 2 5/8" X 8' Opens into FAMILY_ROOM Up Missing Wall Hallway himney2 (A1) edroom 1 Garage DESCRIPTION REMOVE REPLACE TAX O&P TOTAL 269.91 SF 0.00 0.29 0.89 15.84 95.00 Mask more than the floor perimeter per square foot - plastic and tape - 4 mil 568.98 SF 0.00 0.17 2.35 19.82 118.90 121. Texture drywall - smooth / skim coat 775.66 SF 0.00 1.04 5.12 162.36 974.17 119. Floor protection - heavy paper and tape Bathroom 1 Closet 2 120. oilet 1 RESET QTY RESET Ceiling has machine texture. This needs to be floated to a smooth finish before re-textureing to ensure a consistant finish throughout. A patch will always show up as a patch. 122. Texture drywall - machine 775.66 SF 0.00 0.38 1.92 59.34 356.01 123. Seal the walls and ceiling w/latex based stain blocker - one coat 775.66 SF 0.00 0.44 4.48 69.16 414.93 124. Paint the walls and ceiling - two coats 775.66 SF 0.00 0.66 12.16 104.82 628.92 0.00 9.41 0.42 15.14 90.84 Note ceiling is continuous from family room and foyer 125. Mask and cover light fixture 8.00 EA 126. Detach & Reset Heat/AC register Mechanically attached 2.00 EA 12.24 0.00 0.00 0.00 4.90 29.38 63.22 LF 2.58 0.00 0.00 0.10 32.64 195.85 127. Detach & Reset Crown molding 5 1/4" Crown moulding is separated in the kitchen from the ceiling due to accident impact 128. Paint crown molding - two coats 63.22 LF 0.00 0.99 0.57 12.64 75.80 140a. Remove 1/2" drywall - hung, taped, floated, ready for paint 64.00 SF 0.32 0.00 0.00 4.10 24.58 140b. 1/2" drywall - hung, taped, floated, ready for paint 64.00 SF 0.00 1.88 2.27 24.52 147.11 141a. Remove Wallpaper 144.00 SF 0.70 0.00 0.00 20.16 120.96 141b. Wallpaper 144.00 SF 0.00 2.05 12.12 61.46 368.78 CALLAWAY_ 11/3/2016 Page: 11 12 Tony Sherriff 3379 Howard Rd Waxahachie Texas 75165 Dining Room CONTINUED - Kitchen DESCRIPTION QTY REMOVE REPLACE TAX O&P TOTAL 144.00 SF 0.00 0.47 0.00 13.54 81.22 Closet 1 Remove Wallpaper border 145a. Premium grade 20.00 LF 0.59 0.00 0.00 2.36 14.16 145b. Wallpaper border - Premium grade 20.00 LF 0.00 3.62 4.19 15.32 91.91 46.59 638.12 3,828.52 Toilet 1 144. Prep wall for wallpaper RESET Totals: Kitchen Kitchen 7" 2' 6" Laundry Room 4' 1" Up Laundry Room 9' 2" 5" 8' 10" ning room Professional Public Adjusters, LLC Up Stairs 7' 7' 2" DESCRIPTION 253.83 315.89 6.89 31.73 SF Walls SF Walls & Ceiling SY Flooring LF Ceil. Perimeter REPLACE TAX O&P TOTAL 62.05 SF 0.00 0.29 0.20 3.64 21.83 131. Mask more than the floor perimeter per square foot - plastic and tape - 4 mil 285.56 SF 0.00 0.17 1.18 9.96 59.69 132. Texture drywall - smooth / skim coat 315.89 SF 0.00 1.04 2.08 66.12 396.73 Garage RESET 62.05 SF Ceiling 62.05 SF Floor 31.73 LF Floor Perimeter REMOVE 130. Floor protection - heavy paper and tape QTY Height: 8' Ceiling has machine texture. This needs to be floated to a smooth finish before re-textureing to ensure a consistant finish throughout. A patch will always show up as a patch. 133. Texture drywall - machine 315.89 SF 0.00 0.38 0.78 24.16 144.98 134. Seal the walls and ceiling w/latex based stain blocker - one coat 315.89 SF 0.00 0.44 1.82 28.16 168.97 135. Paint the walls and ceiling - two coats 315.89 SF 0.00 0.66 4.95 42.70 256.14 0.00 9.41 0.10 3.78 22.70 Note ceiling is continuous from family room and foyer 136. Mask and cover light fixture 2.00 EA 137. Detach & Reset Heat/AC register Mechanically attached 1.00 EA 12.24 0.00 0.00 0.00 2.44 14.68 138. Detach & Reset Crown molding 5 1/4" 31.73 LF 2.58 0.00 0.00 0.05 16.40 98.31 139. Paint crown molding - two coats 31.73 LF 0.00 0.99 0.29 6.34 38.04 11.45 203.70 1,222.07 Totals: Laundry Room CALLAWAY_ 11/3/2016 Page: 12 13 Dining Room Family dining room Toilet 1 Professional Public Adjusters, LLC Closet 1 Tony Sherriff 3379 Howard Rd Chimney 1 (A1) Waxahachie Texas 75165 Kitchen Family Room Up Laundry Room Bedroom 1 14' 9" 14' 5" Stairs Up 15' 4" 8' 9" 18' 10" 3' 10" Hallway 2' 6" 2' 2' 3' 2" 3' 3' 2' 8" 2' 10" 1' 4" 8' 11" 3' 4" 18' 6"Chimney2 (A1) 6' 3" 15' 6" Bedroom 1 9' 9" 16' 11" 7' 1" 4' 6" 5' 2' 2' 14' 10" 14' 11" 6' 7" Garage 4' 6" 4' 10" 6' 11" Closet 1 Bathroom 1 DESCRIPTION Closet 2 Toilet 1 Height: 8' 686.11 1,096.47 45.60 85.76 QTY 156. Floor protection - heavy paper and tape 410.36 SF 190. Detach & Reset Ceiling fan & light - High grade 1.00 EA SF Walls SF Walls & Ceiling SY Flooring LF Ceil. Perimeter RESET 157.84 410.36 SF Ceiling 410.36 SF Floor 85.76 LF Floor Perimeter REMOVE REPLACE TAX O&P TOTAL 0.00 0.29 1.35 24.08 144.43 0.00 0.00 0.00 31.56 189.40 157. Mask more than the floor perimeter per square foot - plastic and tape - 4 mil 771.87 SF 0.00 0.17 3.18 26.88 161.28 158. Texture drywall - smooth / skim coat 1,096.47 SF 0.00 1.04 7.24 229.50 1,377.07 Ceiling has machine texture. This needs to be floated to a smooth finish before re-textureing to ensure a consistant finish throughout. A patch will always show up as a patch. 159. Texture drywall - machine 1,096.47 SF 0.00 0.38 2.71 83.88 503.25 160. Seal the walls and ceiling w/latex based stain blocker - one coat 1,096.47 SF 0.00 0.44 6.33 97.76 586.54 161. Paint the walls and ceiling - two coats 1,096.47 SF 0.00 0.66 17.19 148.18 889.04 0.00 9.41 0.42 15.14 90.84 Note ceiling is continuous from family room and foyer 162. Mask and cover light fixture 8.00 EA 163. Detach & Reset Heat/AC register Mechanically attached 2.00 EA 12.24 0.00 0.00 0.00 4.90 29.38 85.76 LF 2.58 0.00 0.00 0.14 44.28 265.68 85.76 LF 0.00 0.99 0.78 17.14 102.82 187a. Remove Mirror - 1/4" plate glass 198.00 SF 0.22 0.00 0.00 8.72 52.28 187b. Mirror - 1/4" plate glass 198.00 SF 0.00 11.44 128.39 478.70 2,872.21 167.73 1,210.72 7,264.22 164. Detach & Reset Crown molding 5 1/4" Crown is separating from the wall and ceiling from the accident impact 165. Paint crown molding - two coats Totals: Bedroom 1 CALLAWAY_ 11/3/2016 Page: 13 14 Dining Room Family dining room Toilet 1 Professional Public Adjusters, LLC Closet 1 Tony Sherriff 3379 Howard Rd Kitchen Waxahachie Texas 75165 Chimney 1 (A1) Family Room Up Laundry Room 14' 5" 3' 9" droom 1 Bathroom 1 Garage 18' 8" himney2 (A1) 7' 4' 2" 18' Garage Height: 8' 759.99 1,323.03 62.56 95.00 23' 1" 1' 1" 2' 6" Up 17' 7" 24' 9" Hallway 22' 9" Stairs SF Walls SF Walls & Ceiling SY Flooring LF Ceil. Perimeter 563.04 SF Ceiling 563.04 SF Floor 95.00 LF Floor Perimeter 2' 8" 2' 10" Closet 2 DESCRIPTION QTY RESET REMOVE REPLACE TAX O&P TOTAL 563.04 SF 0.00 0.29 1.86 33.04 198.18 1,323.03 SF 0.00 1.04 8.73 276.94 1,661.62 oilet 1 166. Floor protection - heavy paper and tape 168. Texture drywall - smooth / skim coat Ceiling has machine texture. This needs to be floated to a smooth finish before re-textureing to ensure a consistant finish throughout. A patch will always show up as a patch. 169. Texture drywall - machine 1,323.03 SF 0.00 0.38 3.27 101.22 607.24 170. Seal the walls and ceiling w/latex based stain blocker - one coat 1,323.03 SF 0.00 0.44 7.64 117.94 707.71 171. Paint the walls and ceiling - two coats 1,323.03 SF 0.00 0.66 20.74 178.78 1,072.72 0.00 9.41 0.10 3.78 22.70 42.34 711.70 4,270.17 1,131.08 8,835.04 53,351.59 Note ceiling is continuous from family room and foyer 172. Mask and cover light fixture 2.00 EA Totals: Garage Total: interior 2nd floor Bedroom 2 16' 6" 2' 6" 16' 2' 5" Bedroom 2 1' 2' 6" 2' 3" 11' 11' 6" closet 3 closet 4 2' 6" 4' 5" 2' 6" 3' 6" 11" closet 4' 1" 5 1' Height: 8' 431.99 607.99 19.55 54.00 SF Walls SF Walls & Ceiling SY Flooring LF Ceil. Perimeter 175.99 SF Ceiling 175.99 SF Floor 54.00 LF Floor Perimeter Stairway Bathroom Toilet 3 DESCRIPTION QTY RESET REMOVE REPLACE TAX O&P TOTAL 210. Floor protection - heavy paper Up and tape 175.99 SF 0.00 0.29 0.58 10.32 61.94 Officedrywall closet 219a. Remove 1/2" - hung, taped, ready for texture 32.00 SF 0.32 0.00 0.00 2.04 12.28 219b. 1/2" drywall - hung, taped, ready for texture 32.00 SF 0.00 1.64 1.11 10.72 64.31 Office CALLAWAY_ 11/3/2016 Page: 14 15 Professional Public Adjusters, LLC Tony Sherriff 3379 Howard Rd Waxahachie Texas 75165 CONTINUED - Bedroom 2 DESCRIPTION QTY 211. Texture drywall - smooth / skim coat RESET 175.99 SF REMOVE REPLACE TAX O&P TOTAL 0.00 1.04 1.16 36.84 221.03 Ceiling has machine texture. This needs to be floated to a smooth finish before re-textureing to ensure a consistant finish throughout. A patch will always show up as a patch. 212. Texture drywall - machine 175.99 SF 0.00 0.38 0.44 13.46 80.78 213. Seal the ceiling w/latex based stain blocker - one coat 175.99 SF 0.00 0.44 1.02 15.68 94.14 214. Paint the walls and ceiling - two coats 607.99 SF 0.00 0.66 9.53 82.16 492.96 0.00 9.41 0.26 9.48 56.79 Note ceiling is continuous from family room and foyer 215. Mask and cover light fixture 5.00 EA 216. Detach & Reset Heat/AC register Mechanically attached 1.00 EA 12.24 0.00 0.00 0.00 2.44 14.68 217. Detach & Reset Crown molding 5 1/4" 54.00 LF 2.58 0.00 0.00 0.09 27.88 167.29 218. Paint crown molding - two coats 54.00 LF 0.00 0.99 0.49 10.80 64.75 14.68 221.82 1,330.95 Totals: Bedroom 2 closet 3 closet 3 Bedroom 2 closet 4 Bedroom 2 3' 6" 3" 2' 2" 1' 2" 2' 6" closet 5 8" 2' 6" 10" 10" 6" closet 5 3' SF Walls SF Walls & Ceiling SY Flooring LF Ceil. Perimeter 52.20 SF Ceiling 52.20 SF Floor 25.94 LF Floor Perimeter Up Stairway Toilet 3 7' 7" 4' 6" 4' 8" Bathroom Height: 8' 207.51 259.71 5.80 25.94 closet 4 Stairway Toilet 3 Stairway Office Subroom: Stairs2 (1) Office closet 2' 4" 5' 6" 5' 8" 2' 8" 3' Up 114.14 130.64 3.50 11.17 Height: 12' 6" SF Walls SF Walls & Ceiling SY Flooring LF Ceil. Perimeter 16.50 SF Ceiling 31.50 SF Floor 13.99 LF Floor Perimeter Office Office closet Missing Wall 3' X 12' 6" Opens into LANDING Missing Wall 3' X 12' 6" Opens into STAIRWAY DESCRIPTION 176. Floor protection - heavy paper and tape CALLAWAY_ QTY 83.70 SF RESET REMOVE REPLACE TAX O&P TOTAL 0.00 0.29 0.28 4.92 29.47 11/3/2016 Page: 15 16 Professional Public Adjusters, LLC Tony Sherriff 3379 Howard Rd Waxahachie Texas 75165 CONTINUED - Stairway DESCRIPTION 178. Texture drywall - smooth / skim coat QTY RESET REMOVE REPLACE TAX O&P TOTAL 0.00 1.04 0.45 14.40 86.30 68.70 SF Ceiling has machine texture. This needs to be floated to a smooth finish before re-textureing to ensure a consistant finish throughout. A patch will always show up as a patch. 179. Texture drywall - machine 68.70 SF 0.00 0.38 0.17 5.26 31.54 180. Seal the ceiling w/latex based stain blocker - one coat 68.70 SF 0.00 0.44 0.40 6.12 36.75 390.36 SF 0.00 0.66 6.12 52.74 316.50 0.00 9.41 0.26 9.48 56.79 181. Paint the walls and ceiling - two coats Note ceiling is continuous from family room and foyer 182. Mask and cover light fixture 5.00 EA 183. Detach & Reset Heat/AC register Mechanically attached 1.00 EA 12.24 0.00 0.00 0.00 2.44 14.68 184. Detach & Reset Crown molding 5 1/4" 37.11 LF 2.58 0.00 0.00 0.06 19.16 114.96 185. Paint crown molding - two coats 37.11 LF 0.00 0.99 0.34 7.40 44.48 Totals: Stairway 8.08 121.92 731.47 Total: 2nd floor 22.76 343.74 2,062.42 4,201.15 19,629.22 140,848.35 Line Item Totals: CALLAWAY_ Grand Total Areas: 12,056.14 SF Walls 7,143.73 SF Floor 0.00 SF Long Wall 7,143.73 Floor Area 7,806.21 Exterior Wall Area 0.00 Surface Area 0.00 Total Ridge Length CALLAWAY_ 7,098.30 SF Ceiling 793.75 SY Flooring 0.00 SF Short Wall 19,154.44 SF Walls and Ceiling 1,497.17 LF Floor Perimeter 1,500.54 LF Ceil. Perimeter 7,497.00 Total Area 867.36 Exterior Perimeter of Walls 11,299.10 Interior Wall Area 0.00 Number of Squares 0.00 Total Hip Length 0.00 Total Perimeter Length 11/3/2016 Page: 16 17 Professional Public Adjusters, LLC Tony Sherriff 3379 Howard Rd Waxahachie Texas 75165 Summary for Dwelling Line Item Total Material Sales Tax Cleaning Mtl Tax Storage Rental Tax 117,017.98 3,743.88 73.21 41.25 Subtotal Overhead Profit Cleaning Sales Tax 120,876.32 9,814.61 9,814.61 342.81 Replacement Cost Value Net Claim $140,848.35 $140,848.35 Tony Sherriff CALLAWAY_ 11/3/2016 Page: 17 18 7' 4" 7' 4" 4' 4' 7' 8" 7' 2' 2' 10' 1" 9' 5" 2' 4" 2' 4" 8' 4" 7' 8" 14' 4" 15' 23' 2" 23' 10" 7' 3" 7' 11" 2' 2" 10' 2' 2' 5' 3" 9' 4" 5' 3" 1' 3" 7" 8' 4" 8' 4" 1' 8" 1' 8" 9' 11' 6" 11' 6" 6' 1" 9' 8" 1' 6" 6' 1" 1' 6" Main Level 9' 75' 5" 74' 9" 35' 2" 35' 2" 9' Dwelling footprint 14' 7" 15' 3" 21' 7" 21' 7" 4' 8" 4' 8" 25' 3" 8' 11" 8' 11" 13' 1" 13' 1" 25' 3" 6' 4" 11' 11' 8" 2' 2' 6' 6" 6' 6" 6' 4" Main Level CALLAWAY_ 11/3/2016 Page: 18 19 5' 3" 10' 9' 4" 7' 5" 4' 2" 3' 7' 10" 3' 7" 6' 6"1 (A1) Chimney 27' 2" 19' 3" 11' 3" Kitchen Family Room 5' 2" 3' 4" 5' 6" 12' 10" 7' 8' 10" 59' 9" 9' 11" 3' 3' 3' 2' 8" 1 Closet 9' 5' 2" 10' 3" 7' 3" 9' 11" Toilet 1 20' 5" 15' 6" 15' 6' 2" 8' 10" 14' 4" 15' 15' 4" 5' 4" Family dining room 9' 35' 3" 2' 2' 2" 4' 1" 3' 8" 2' 2" 9' 11" Foyer/Entry 8' 4" 7' 7" 7' 8" Dining Room 5' 4" 8' 6" 6' 4' 2" 4' 2" 7' 1" 23' 2" 23' 10" 5' 3" 1' 4" 9' 3" Living Room 2' 1" 2' 1" 7' 9" 7' 5" 7' 1" 11' 7" 11' 5" 5' 8" 8' 6" 9' 7" chimney 8' 11" 5' 10" 1' 11" 1' 6" interior Up Laundry Room 3' 11" 24' 9" 14' 5" 21' 6" Stairs Up 24' 9" 7' Hallway Garage 9' 1" 7' 10" 8' 13' 8' 3" 4' 11" 4' 7" 1 Toilet 2' 9" 5" 7' 3" 6' 11" 23' 9" Bathroom 1 Closet 1 6' 7" 10' 8" 5' 22' 9" 3' 9" 6' 7" 6' 3" 24' 11" Closet 2 2' 2' 2" 4' 6" 4' 1" Bedroom 1 8' 7" 8' 11" 14' 11" 6' 28' 6" 2' 7" Chimney2 (A1) 7' 3" interior CALLAWAY_ 11/3/2016 Page: 19 20 2nd floor 20' 8" 3' 8" 4' 11" 16' 5' 9" 11' Bedroom 2 11' 8" 11' 6" closet 3 closet 4 4' 1" 7' 2' 7" 4' 3" 3' 4' 6" Bathroom 7' 5" closet 5 4' Stairway 6' Up 9' 10" Office 10' 2" Office closet 3' 4" 4' 3' 10" 12' 10" 1' 8" 9' 2" 21' 1" 2' 8" 12' 8" 3' 16' 11" 4' 16' 7" 2' 3 Toilet 10' 8" 13' 4" 2nd floor CALLAWAY_ 11/3/2016 Page: 20 1 Professional Public Adjusters, LLC Tony Sherriff 3379 Howard Rd Waxahachie Texas 75165 1 1-ADDRESS Date Taken: 8/14/2012 Taken By: ROBERT SMITH 2 2-FRONT Date Taken: 8/14/2012 Taken By: Tony Sherriff CALLAWAY_ 11/1/2016 Page: 1 2 Professional Public Adjusters, LLC Tony Sherriff 3379 Howard Rd Waxahachie Texas 75165 3 3-2 CRUSHED MAIL BOXES Date Taken: 8/14/2012 Taken By: Tony Sherriff 4 4-CRUSHED MAIL BOXES Date Taken: 8/14/2012 Taken By: Tony Sherriff CALLAWAY_ 11/1/2016 Page: 2 3 Professional Public Adjusters, LLC Tony Sherriff 3379 Howard Rd Waxahachie Texas 75165 5 5-GARDEN AT CRASH SITE Date Taken: 8/14/2012 Taken By: Tony Sherriff 6 6-IMPACT SITE FRONT LET OF BUILDING Date Taken: 8/14/2012 Taken By: Tony Sherriff CALLAWAY_ 11/1/2016 Page: 3 4 Professional Public Adjusters, LLC Tony Sherriff 3379 Howard Rd Waxahachie Texas 75165 7 7-IMPACT SITE /front entry Date Taken: 8/14/2012 Taken By: Tony Sherriff 8 8-BOARDED UP DOUBLE WINDOWS IMPACT SITE Date Taken: 8/14/2012 Taken By: Tony Sherriff CALLAWAY_ 11/1/2016 Page: 4 5 Professional Public Adjusters, LLC Tony Sherriff 3379 Howard Rd Waxahachie Texas 75165 9 9-BRICK SIDING FROM IMPACT Date Taken: 8/14/2012 Taken By: Tony Sherriff 10 10-GARDEN WITH SPRINKLER HEAD AT CRASH SITE Date Taken: 8/14/2012 Taken By: Tony Sherriff CALLAWAY_ 11/1/2016 Page: 5 6 Professional Public Adjusters, LLC Tony Sherriff 3379 Howard Rd Waxahachie Texas 75165 11 11-CRACKS AT BRICK SIDING Date Taken: 8/14/2012 Taken By: Tony Sherriff 12 12-BRICK CRACKS AT INPACT SITE Date Taken: 8/14/2012 Taken By: Tony Sherriff CALLAWAY_ 11/1/2016 Page: 6 7 Professional Public Adjusters, LLC Tony Sherriff 3379 Howard Rd Waxahachie Texas 75165 13 13-CHIMNEY FRONT RIGHT Date Taken: 8/14/2012 Taken By: Tony Sherriff 14 15-HOA SIGN AT REAR Date Taken: 8/14/2012 Taken By: Tony Sherriff CALLAWAY_ 11/1/2016 Page: 7 8 Professional Public Adjusters, LLC Tony Sherriff 3379 Howard Rd Waxahachie Texas 75165 15 16-RIGHT SIDE FROM REAR Date Taken: 8/14/2012 Taken By: Tony Sherriff 16 17-RIGHT SIDE . LIVING ROOM ENTRY AT LEFT Date Taken: 8/14/2012 Taken By: Tony Sherriff CALLAWAY_ 11/1/2016 Page: 8 9 Professional Public Adjusters, LLC Tony Sherriff 3379 Howard Rd Waxahachie Texas 75165 17 18-RIGHT SIDE AT POOL Date Taken: 8/14/2012 Taken By: Tony Sherriff 18 19-RIGHT SIDE LOOKING TO REAR Date Taken: 8/14/2012 Taken By: Tony Sherriff CALLAWAY_ 11/1/2016 Page: 9 10 Professional Public Adjusters, LLC Tony Sherriff 3379 Howard Rd Waxahachie Texas 75165 19 20-RIGHT SIDE LOOKING TO REAR Date Taken: 8/14/2012 Taken By: Tony Sherriff 20 21-LEFT REAR CORNER Date Taken: 8/14/2012 Taken By: Tony Sherriff CALLAWAY_ 11/1/2016 Page: 10 11 Professional Public Adjusters, LLC Tony Sherriff 3379 Howard Rd Waxahachie Texas 75165 21 22-POOL EQUIPMENT RIGHT REAR CORNER Date Taken: 8/14/2012 Taken By: Tony Sherriff 22 23-REAR BRICK SIDING Date Taken: 8/14/2012 Taken By: Tony Sherriff CALLAWAY_ 11/1/2016 Page: 11 12 Professional Public Adjusters, LLC Tony Sherriff 3379 Howard Rd Waxahachie Texas 75165 23 24-CRACKS IN BRICK WORK LEFT SIDE Date Taken: 8/14/2012 Taken By: Tony Sherriff 24 25-CRACKS INTHE BRICK CRACKING AT LEFT SIDE Date Taken: 8/14/2012 Taken By: Tony Sherriff CALLAWAY_ 11/1/2016 Page: 12 13 Professional Public Adjusters, LLC Tony Sherriff 3379 Howard Rd Waxahachie Texas 75165 25 26-CRACKS INTHE BRICK WORK LEFT SIDE Date Taken: 8/14/2012 Taken By: Tony Sherriff 26 28-DINING ROOM BROKEN WINDOWS AT CRASH SITE Date Taken: 8/14/2012 Taken By: Tony Sherriff CALLAWAY_ 11/1/2016 Page: 13 14 Professional Public Adjusters, LLC Tony Sherriff 3379 Howard Rd Waxahachie Texas 75165 27 29-WINDOW SHUTTERS AT CRASH SITE Date Taken: 8/14/2012 Taken By: Tony Sherriff 28 30-BROKEN WINDOW SILL AT CRASH SITE Date Taken: 8/14/2012 Taken By: Tony Sherriff CALLAWAY_ 11/1/2016 Page: 14 15 Professional Public Adjusters, LLC Tony Sherriff 3379 Howard Rd Waxahachie Texas 75165 29 31-DINING ROOM OVER VIEW SHOWING DAMAGED WALL Date Taken: 8/14/2012 Taken By: Tony Sherriff 30 32-DINING ROOM OV Date Taken: 8/14/2012 Taken By: Tony Sherriff CALLAWAY_ 11/1/2016 Page: 15 16 Professional Public Adjusters, LLC Tony Sherriff 3379 Howard Rd Waxahachie Texas 75165 31 33-DINING ROOM OV LOOKING TO FRONT DOOR Date Taken: 8/14/2012 Taken By: Tony Sherriff 32 34-SEPARATING BASE BD IN DINING ROOM FROM IMPAC Date Taken: 8/14/2012 Taken By: Tony Sherriff CALLAWAY_ 11/1/2016 Page: 16 17 Professional Public Adjusters, LLC Tony Sherriff 3379 Howard Rd Waxahachie Texas 75165 33 35-CEILING CRACKS FROM IMPACT Date Taken: 8/14/2012 Taken By: Tony Sherriff 34 36-WALL CRACKS FROM IMPACT DINING ROOM Date Taken: 8/14/2012 Taken By: Tony Sherriff CALLAWAY_ 11/1/2016 Page: 17 18 Professional Public Adjusters, LLC Tony Sherriff 3379 Howard Rd Waxahachie Texas 75165 35 37-DINING ROOM TO KITCHEN DOOR Date Taken: 8/14/2012 Taken By: Tony Sherriff 36 38-DOOR CASING SEPARATED FROM IMPACT DINING Date Taken: 8/14/2012 Taken By: Tony Sherriff CALLAWAY_ 11/1/2016 Page: 18 19 Professional Public Adjusters, LLC Tony Sherriff 3379 Howard Rd Waxahachie Texas 75165 37 40-KITCHEN OVER VIEW Date Taken: 8/14/2012 Taken By: Tony Sherriff 38 41-KIT5TCHEN LOOKING TO DINING ROOM Date Taken: 8/14/2012 Taken By: Tony Sherriff CALLAWAY_ 11/1/2016 Page: 19 20 Professional Public Adjusters, LLC Tony Sherriff 3379 Howard Rd Waxahachie Texas 75165 39 42-CEILING CRACKS AND CROWN SEPARATION Date Taken: 8/14/2012 Taken By: Tony Sherriff 40 43-KITCHEN CROWN AND WALL PAPER Date Taken: 8/14/2012 Taken By: Tony Sherriff CALLAWAY_ 11/1/2016 Page: 20 21 Professional Public Adjusters, LLC Tony Sherriff 3379 Howard Rd Waxahachie Texas 75165 41 44-DRYWALL CRACKS AT KITCHEN/DINING DOOR Date Taken: 8/14/2012 Taken By: Tony Sherriff 42 45-SEPARATED DOOR CASING TO DINING ROOM Date Taken: 8/14/2012 Taken By: Tony Sherriff CALLAWAY_ 11/1/2016 Page: 21 22 Professional Public Adjusters, LLC Tony Sherriff 3379 Howard Rd Waxahachie Texas 75165 43 46-CEILAING CRACK AT KITCHEN SKYLIGHT Date Taken: 8/14/2012 Taken By: Tony Sherriff 44 47-DRYWALL CRACKS AT KITCHEN Date Taken: 8/14/2012 Taken By: Tony Sherriff CALLAWAY_ 11/1/2016 Page: 22 23 Professional Public Adjusters, LLC Tony Sherriff 3379 Howard Rd Waxahachie Texas 75165 45 49-LAUNDRY OVER VIEW Date Taken: 8/14/2012 Taken By: Tony Sherriff 46 50-LAUNDRY CROWN Date Taken: 8/14/2012 Taken By: Tony Sherriff CALLAWAY_ 11/1/2016 Page: 23 24 Professional Public Adjusters, LLC Tony Sherriff 3379 Howard Rd Waxahachie Texas 75165 47 51-DRYWALL CRACK AT LAUNDRY DOOR Date Taken: 8/14/2012 Taken By: Tony Sherriff 48 52-LAUNDRY WALL AND CROWN Date Taken: 8/14/2012 Taken By: Tony Sherriff CALLAWAY_ 11/1/2016 Page: 24 25 Professional Public Adjusters, LLC Tony Sherriff 3379 Howard Rd Waxahachie Texas 75165 49 53-CRACKED DRYWALL IN LAUNDRY Date Taken: 8/14/2012 Taken By: Tony Sherriff 50 54-BASE SEPARATION Date Taken: 8/14/2012 Taken By: Tony Sherriff CALLAWAY_ 11/1/2016 Page: 25 26 Professional Public Adjusters, LLC Tony Sherriff 3379 Howard Rd Waxahachie Texas 75165 51 56-ENTRY FOYERLOOKING TO DINING ROOM Date Taken: 8/14/2012 Taken By: Tony Sherriff 52 57-FOYER WINDOWS Date Taken: 8/14/2012 Taken By: Tony Sherriff CALLAWAY_ 11/1/2016 Page: 26 27 Professional Public Adjusters, LLC Tony Sherriff 3379 Howard Rd Waxahachie Texas 75165 53 58-FOYER CEILING Date Taken: 8/14/2012 Taken By: Tony Sherriff 54 59-FOYER WALL CRACKS Date Taken: 8/14/2012 Taken By: Tony Sherriff CALLAWAY_ 11/1/2016 Page: 27 28 Professional Public Adjusters, LLC Tony Sherriff 3379 Howard Rd Waxahachie Texas 75165 55 62-ENTRY FOYER Date Taken: 8/14/2012 Taken By: Tony Sherriff 56 63-FOYER CEILING CRACKS Date Taken: 8/14/2012 Taken By: Tony Sherriff CALLAWAY_ 11/1/2016 Page: 28 29 Professional Public Adjusters, LLC Tony Sherriff 3379 Howard Rd Waxahachie Texas 75165 57 64-FOYER CROWN CRACK Date Taken: 8/14/2012 Taken By: Tony Sherriff 58 65-FOYER DRYWALL CEILING CRACK Date Taken: 8/14/2012 Taken By: Tony Sherriff CALLAWAY_ 11/1/2016 Page: 29 30 Professional Public Adjusters, LLC Tony Sherriff 3379 Howard Rd Waxahachie Texas 75165 59 67-FAMILY DINING ROOM OVER VIEW Date Taken: 8/14/2012 Taken By: Tony Sherriff 60 68-FAMILY DINING ROOM Date Taken: 8/14/2012 Taken By: Tony Sherriff CALLAWAY_ 11/1/2016 Page: 30 31 Professional Public Adjusters, LLC Tony Sherriff 3379 Howard Rd Waxahachie Texas 75165 61 69-SEPARATED CROWN Date Taken: 8/14/2012 Taken By: Tony Sherriff 62 71-FAMILY ROOM OVER VIEW Date Taken: 8/14/2012 Taken By: Tony Sherriff CALLAWAY_ 11/1/2016 Page: 31 32 Professional Public Adjusters, LLC Tony Sherriff 3379 Howard Rd Waxahachie Texas 75165 63 72-FAMILY ROOM WITH CENTRAL FIREPLACE Date Taken: 8/14/2012 Taken By: Tony Sherriff 64 73-FAMILY ROOM Date Taken: 8/14/2012 Taken By: Tony Sherriff CALLAWAY_ 11/1/2016 Page: 32 33 Professional Public Adjusters, LLC Tony Sherriff 3379 Howard Rd Waxahachie Texas 75165 65 74-FAMILY ROOM/STAIRS Date Taken: 8/14/2012 Taken By: Tony Sherriff 66 75-FAMILY ROOM CEILING Date Taken: 8/14/2012 Taken By: Tony Sherriff CALLAWAY_ 11/1/2016 Page: 33 34 Professional Public Adjusters, LLC Tony Sherriff 3379 Howard Rd Waxahachie Texas 75165 67 77-HALLWAY OVER VIEW Date Taken: 8/14/2012 Taken By: Tony Sherriff 68 78-GARAGE ENTRY FROM HALLWAY Date Taken: 8/14/2012 Taken By: Tony Sherriff CALLAWAY_ 11/1/2016 Page: 34 35 Professional Public Adjusters, LLC Tony Sherriff 3379 Howard Rd Waxahachie Texas 75165 69 79-SAM_0320 Date Taken: 8/14/2012 Taken By: Tony Sherriff 70 80-SAM_0321 Date Taken: 8/14/2012 Taken By: Tony Sherriff CALLAWAY_ 11/1/2016 Page: 35 36 Professional Public Adjusters, LLC Tony Sherriff 3379 Howard Rd Waxahachie Texas 75165 71 82-master bedroom over view Date Taken: 8/14/2012 Taken By: Tony Sherriff 72 83-master bedroom over view Date Taken: 8/14/2012 Taken By: Tony Sherriff CALLAWAY_ 11/1/2016 Page: 36 37 Professional Public Adjusters, LLC Tony Sherriff 3379 Howard Rd Waxahachie Texas 75165 73 84-master bedroom Date Taken: 8/14/2012 Taken By: Tony Sherriff 74 85-master bedroom fireplace Date Taken: 8/14/2012 Taken By: Tony Sherriff CALLAWAY_ 11/1/2016 Page: 37 38 Professional Public Adjusters, LLC Tony Sherriff 3379 Howard Rd Waxahachie Texas 75165 75 86-master bedroom crown Date Taken: 8/14/2012 Taken By: Tony Sherriff 76 87-master bedroom drywall damage Date Taken: 8/14/2012 Taken By: Tony Sherriff CALLAWAY_ 11/1/2016 Page: 38 39 Professional Public Adjusters, LLC Tony Sherriff 3379 Howard Rd Waxahachie Texas 75165 77 88-master bedroom crown sepaqration Date Taken: 8/14/2012 Taken By: Tony Sherriff 78 89-laster bedroom crown separation Date Taken: 8/14/2012 Taken By: Tony Sherriff CALLAWAY_ 11/1/2016 Page: 39 40 Professional Public Adjusters, LLC Tony Sherriff 3379 Howard Rd Waxahachie Texas 75165 79 90-master bedroom crwon and full hgt mirrors Date Taken: 8/14/2012 Taken By: Tony Sherriff 80 91-crown and mirros Date Taken: 8/14/2012 Taken By: Tony Sherriff CALLAWAY_ 11/1/2016 Page: 40 41 Professional Public Adjusters, LLC Tony Sherriff 3379 Howard Rd Waxahachie Texas 75165 81 92-Crwon separation Date Taken: 8/14/2012 Taken By: Tony Sherriff 82 94-master bathroom over view Date Taken: 8/14/2012 Taken By: Tony Sherriff CALLAWAY_ 11/1/2016 Page: 41 42 Professional Public Adjusters, LLC Tony Sherriff 3379 Howard Rd Waxahachie Texas 75165 83 95-master bathroom over view Date Taken: 8/14/2012 Taken By: Tony Sherriff 84 96-ceiling crack Date Taken: 8/14/2012 Taken By: Tony Sherriff CALLAWAY_ 11/1/2016 Page: 42 43 Professional Public Adjusters, LLC Tony Sherriff 3379 Howard Rd Waxahachie Texas 75165 85 97-master bathroom crown Date Taken: 8/14/2012 Taken By: Tony Sherriff 86 98-crown spearation Date Taken: 8/14/2012 Taken By: Tony Sherriff CALLAWAY_ 11/1/2016 Page: 43 44 Professional Public Adjusters, LLC Tony Sherriff 3379 Howard Rd Waxahachie Texas 75165 87 100-stair wall Date Taken: 8/14/2012 Taken By: Tony Sherriff 88 101-Stair over view Date Taken: 8/14/2012 Taken By: Tony Sherriff CALLAWAY_ 11/1/2016 Page: 44 45 Professional Public Adjusters, LLC Tony Sherriff 3379 Howard Rd Waxahachie Texas 75165 89 102-Stair ceiling with attic access Date Taken: 8/14/2012 Taken By: Tony Sherriff 90 103-stair top landing Date Taken: 8/14/2012 Taken By: Tony Sherriff CALLAWAY_ 11/1/2016 Page: 45 46 Professional Public Adjusters, LLC Tony Sherriff 3379 Howard Rd Waxahachie Texas 75165 91 104-Drywall crack Date Taken: 8/14/2012 Taken By: Tony Sherriff 92 107-bedroom 2 over view Date Taken: 8/14/2012 Taken By: Tony Sherriff CALLAWAY_ 11/1/2016 Page: 46 47 Professional Public Adjusters, LLC Tony Sherriff 3379 Howard Rd Waxahachie Texas 75165 93 108-bedroom 2 OV Date Taken: 8/14/2012 Taken By: Tony Sherriff 94 109-bedroom 2/ J&J bathroom Date Taken: 8/14/2012 Taken By: Tony Sherriff CALLAWAY_ 11/1/2016 Page: 47 48 Professional Public Adjusters, LLC Tony Sherriff 3379 Howard Rd Waxahachie Texas 75165 95 110-bedroom 2 wayy cracks Date Taken: 8/14/2012 Taken By: Tony Sherriff 96 111-bedroom 2 crown Date Taken: 8/14/2012 Taken By: Tony Sherriff CALLAWAY_ 11/1/2016 Page: 48 49 Professional Public Adjusters, LLC Tony Sherriff 3379 Howard Rd Waxahachie Texas 75165 97 113-Bedroom 2 crown Date Taken: 8/14/2012 Taken By: Tony Sherriff 98 115-Garage OV Date Taken: 8/14/2012 Taken By: Tony Sherriff CALLAWAY_ 11/1/2016 Page: 49 50 Professional Public Adjusters, LLC Tony Sherriff 3379 Howard Rd Waxahachie Texas 75165 99 116-Garage Date Taken: 8/14/2012 Taken By: Tony Sherriff 100 117-Garage Date Taken: 8/14/2012 Taken By: Tony Sherriff CALLAWAY_ 11/1/2016 Page: 50 51 Professional Public Adjusters, LLC Tony Sherriff 3379 Howard Rd Waxahachie Texas 75165 101 118-drywall cracks at wall and ceiling Date Taken: 8/14/2012 Taken By: Tony Sherriff 102 121-Garage drywall cracks Date Taken: 8/14/2012 Taken By: Tony Sherriff CALLAWAY_ 11/1/2016 Page: 51 Phone: 281-497-1522 Fax: 281-829-3023 Toll Free: 877-497-1527 PO Box 5306 Katy, TX 77491-5306 www.beckerengr.net DELIVERY VEHICLE COLLISION DAMAGE CAUSE AND ORIGIN ASSESSMENT REPORT OF FINDINGS PROPERTY: CALLOWAY RESIDENCE 12544 Renoir LN DALLAS, TX PREPARED FOR: MCCLENNY MOSELEY & ASSOCIATES, PLLC 1214 West Dallas HOUSTON, TEXAS 77019 Gregory T. Becker, PE Principal Engineer, Becker Engineering Prepared: October 20, 2016 Becker Engineering [F-672] File: 16-03-04-0024 TABLE OF CONTENTS Page EXECUTIVE SUMMARY ................................................................................................ 1 INTRODUCTION ............................................................................................................ 3 I. SITE BACKGROUND .......................................................................................... 4 II. OBSERVATIONS & DATA .................................................................................. 5 III. ANALYSIS & CONCLUSIONS ............................................................................ 7 IV. RECOMMENDATIONS ....................................................................................... 9 BASIS OF REPORT AND APPLICABLE DEFINITIONS.............................................. 10 REFERENCES ............................................................................................................ 12 ATTACHMENTS I. PHOTOGRAPHS & DATA II. SITE SCHEMATICS WITH DAMAGE OBSERVATIONS Prepared: October 20, 2016 Becker Engineering [F-672] File: 16-03-04-0024 EXECUTIVE SUMMARY Becker Engineering (BE) was retained by McClenny Moseley & Associates, PLLC to perform a Damage Cause and Origin Assessment of the Calloway Residence. BE visited the subject structure on September 26, 2016 to offer an opinion on the existence, extent and reparability of damage related to a major delivery vehicle collision on June 19, 2016. During the assessment, BE photographed the Calloway residence, interviewed Ms. Calloway and assessed damage related to the delivery vehicle collision. Accordingly, our conclusions are based on only our data, observations and supplied information as stated in this report. BE also recommends general remedies for repair of such damages, if possible for planning purposes. During this site visit, portions of the exterior of the building were visually inspected and photographs were taken. All observed damages were recorded as needed to support this assessment. These submitted technical conclusions are based upon scientific methods; the technical data referenced herewith, the applicable engineering guidelines in conjunction with the applicable Building Codes and General Industry Standards, our inspection, survey and examination results, the expert professional knowledge and many years of experience of the engineer in the forensic analysis of residential/commercial building structures. Such an inspection cannot detect all existing or potential defects and it should, therefore, be understood that future conditions affecting items discussed in this report cannot be predicted since they are all subject to change. The scope of this report extends only to the items related to the structural (wall/roof frame systems) and building envelope in relation to the vehicle impact identified in this report. Other observations are recorded only for preliminary planning/costing purposes. This engineering assessment report should not be considered a design, warranty or guarantee of any kind. The observations and analysis confirming the existence of damage related to the delivery vehicle collision is summarized in the following discussion. This summary not to be used independently of the total report since details are further explained in the body of this document. Damage distribution for the building is also depicted in the attached drawing(s). Damaged areas that are described in this report are related to the incident. The most severely damaged portions of wall and ceiling were associated with the lower wall that was displaced axially along the wall line causing separation of structural members near the impact area. Motion, deflection and vibration were carried through the structural members causing localized separations and cracks at the BE (F-672) File 16-03-04-0024 Calloway Residence building [Confidential] October 20, 2016 1 Damage Cause and Origin interior near the dining room. Exterior brick veneer in the area is cracked and separated. The cracking and separation of some areas reflect re-opening of previously repaired and stable areas related to foundation repair. The foundation appears relatively flat and stable from the recent underpinning approximately 5 years ago. At that time the interior was remodeled and any cracks and separations were addressed. Water intrusion has also caused some localized cupping of the hardwood floor. Based on the observations and analysis provided in this report, BE’s conclusions are summarized as follows: EXTERIOR The non-reinforced mailboxes were destroyed and must be rebuilt. The PVC sprinkler system and decorative bed lighting systems were also damaged as the vehicle approached the wall. These systems must also be repaired or replaced. EXTEIOR BRICK VENEER AND FRIEZE BOARD The brick veneer at the impact zone and adjacent areas shows new cracking and separations related to vibration and deflection at the time of impact and subsequent slow deformation to relieve stress. The exterior brick veneer must be replaced in the affected areas including those adjacent to the impact zone. This must be done in coordination with wall structural repairs. The separated frieze board at the front impact area is separated and must be repaired. WALLS AND WALL PENETRATIONS The wood structure (studs, top and bottom plates) are damaged at the front window and adjacent areas. These materials show bowing (deformation) and cracks. These must be exposed, reinforced or reattached, and cracked/damaged members replaced with careful attention to supporting and sealing the remaining structure temporarily to prevent further damage. The wall penetrations (windows and associated framing – see drawing) are damaged via separation and stress from deformation related to the impact. These also must be replaced to allow for proper function and performance. The window units (both sides including missing and separated glazing) must be replaced at the front along with any damaged shutters and trim. Damaged and separated windows must be replaced. INTERIOR WATER DAMAGE AND INTERIOR BUILDING MATERIALS The interior hardwood flooring near the impact zone was exposed to water intrusion and shows evidence of cupping from moisture changes. The water damage is indicated on the drawings and photographs. This flooring must be repaired or replaced. Interior sheetrock and trim shows evidence of cracking and separations from impact vibration and stress release. These damaged areas must be repaired after any structural repairs are complete. RISK AND HAZARD There is a current risk of injury from potential falling objects (brick or other building materials) during wall structural repairs of the impact area. There is also a real risk of electrical injury, injury during replacement of exterior wall and lighting. Thus, access to this area must be controlled for safety and water intrusion to the interior must be prohibited during repair work. BE (F-672) File 16-03-04-0024 Calloway Residence building [Confidential] October 20, 2016 2 Damage Cause and Origin INTRODUCTION McClenny Moseley & Associates, PLLC requested that Becker Engineering (BE) inspect the structural damage to the Calloway residence relating to reported delivery vehicle collision damage in July of 2013. The delivery vehicle collision on June 19, 2016 was confirmed and researched. The property was inspected by BE as requested on September 26, 2016. Background and historical information were provided by the Ms. Calloway. Historical information was confirmed where possible using police reports and previous photographs. BE has relied only upon the information gathered during the site visit, research and owner/occupant interviews as a basis for arriving at the opinions and conclusions in this report. The purpose of this investigation is to offer a professional opinion on the cause and extent of the damage to the subject building related to the delivery vehicle collision event. This report is based upon the information available to us at this time, and is not necessarily final. Should new or additional information be presented or discovered, we reserve the right to review and, if necessary, revise this report and our conclusions in light of that information. This report is specific in nature and not intended to be used for real estate transactions. This report is the sole property of McClenny Moseley & Associates, PLLC and the Ms. Calloway. Note that if excess moisture sources are not eliminated before and after repairs or reconstruction occurs, excess mold growth and water damage will likely recur. Since BE will not be involved in repairs or ongoing maintenance for this structure, BE offers no warranty of the future performance or success of our recommended actions. BE (F-672) File 16-03-04-0024 Calloway Residence building [Confidential] October 20, 2016 3 Damage Cause and Origin I. SITE BACKGROUND For the purposes of this report, the building will be described as if facing the front (i.e., front, right, left and rear from the entrance). Also, to simplify discussion, the structure will be discussed as if the building (home portion) is facing mainly west. The Calloway residence is one story, woodframed structure with a brick exterior. The pitched hip roof of the building is covered by standard shingled roofing. A slab-on-grade steel reinforced concrete foundation system supports the building. Walls are typical wood stud construction with sill (bottom) plate and a double top plate which connects to the roof structure. The roof structure is wood that bears load on the front exterior wall. The following information was obtained regarding the history of the structure: The building was built in approximately 1981. Ms. Calloway purchased the building in approximately 1989. The foundation was repaired approximately 8 years ago at the rear left and more recently (approximately 5 years ago) at the left and front sides. All interior and exterior cracks and separations were repaired completely at that time and there has been no further damage indicating movement since. Remodeling 3 years ago included new windows, newly surfaced hardwood floors, painting of walls, trim and ceiling in the dining room area. On the same day as the collision, the owner noticed damaged exterior lights, sprinkler system, shrubs and mail box along with damaged interior hardwood flooring, trim, and walls with new cracks and separations. The owner also noted the bowed interior walls adjacent to the destroyed front window area. The demolished window opening was temporarily covered the same night as the collision, but this area leaked when the damaged sprinkler system came on. The owner noticed the water intrusion and mopped the area. The exterior barrier was subsequently replaced and the sprinkler system was repaired. BE was contacted to document the damage extent; provide our professional opinion on causal event(s) and recommend overall repairs required. BE (F-672) File 16-03-04-0024 Calloway Residence building [Confidential] October 20, 2016 4 Damage Cause and Origin II. OBSERVATIONS AND DATA Becker Engineering assessed the property on September 26, 2016. During this inspection, the exterior and interior of the Calloway residence was visually inspected. Interview was conducted with Ms. Calloway via phone by September 26, 2016. The Calloway residence was photographed to document the findings and represent the damage present. Since there was new crack activity reported and previous foundation repair had been conducted, foundation topographic data was collected to document the current condition. It is not the intent of this report to document all damage in and around the building and other out buildings, but to show typical conditions that affect the opinions expressed in this report. Additional photographs are not included, but are available. Instruments used for BE assessments and data collection at this building include: Overall observations were documented with a digital camera. Based on exterior measurements, schematics were prepared to document our observations and determine any correlation between damage and damage sources. Plumb (vertical) measurements were taken at the impact area to determine remaining deflection with a torpedo level and a 4 foot level. Damaged (separated) areas were observed and documented. Damage occurrences consistent with deflection and displacement of structural members for all areas were observed and documented. Leak sources were identified based on remnant evidence of damage related to water exposure. All areas were currently dry and did not require material moisture level measurement. Foundation topographic measurement data was collected for the affected area and adjacent areas using a compulevel digital water meter. This data was used to determine if the foundation current condition appeared normal and stable. Aerial photographs and police records were analyzed to support this assessment as needed. BE (F-672) File 16-03-04-0024 Calloway Residence building [Confidential] October 20, 2016 5 Damage Cause and Origin Observations Observations are documented in the drawings and photographs. Inspection of the interior and exterior of the building carried out and documented in the drawing(s) attached. Repair information to damaged materials and components was provided to BE if available. The assessment of the exterior and interior revealed the following (see attached drawings): Exterior observations showed new cracks and separations in the brick veneer and the junction of the soldier course and the frieze board. Some of the cracks in the brick veneer at the adjacent areas outside the dining room showed previous repair and recent re-opening. The wall was bowed in the area of the collision. Also the smear coat on the foundation is cracked and now sloughing. The front showed evidence of vehicle contact. The right window unit was destroyed and the left glazing is separated from the frame. Window framing is bowed, cracked and separated. Damage was highest in the impact zone. The topography indicates that the foundation is currently level within normal tolerances and that the underpinning is performing as intended. New cracks and separations were observed in the interior that were fresh. Similar to the exterior brick veneer, some cracks had re-opened that had been previously successfully repaired and finished. This damage consistent with deflection in the area of the impact along with movement and vibration that causes stress release as the distance increases from the impact zone. The hardwood floor in the reported area of sprinkler water intrusion shows evidence of cupping. The junction with the base molding shows gaps consistent with hardwood floor moisture changes and/or wall movement. BE (F-672) File 16-03-04-0024 Calloway Residence building [Confidential] October 20, 2016 6 Damage Cause and Origin III. ANALYSIS & CONCLUSIONS The purpose of this investigation is to offer a professional opinion on the extent of damage to this structure related to the June 19, 2016 delivery vehicle collision with this structure. BE also recommends remedies for repair of such damages, if possible, for reparability purposes. Based on the inspection, available data, observations and analysis as noted in this report our analysis and conclusions are as follows: COLLISION DAMAGE MECHANISM Assuming a weight of 3200 lbs, and an impact speed of approximately 30 mph, the approximate impact force by the truck would be approximately 96,800 foot pounds assuming impact distance from contact to stopping in the structure was 1 foot. Higher speed or lesser stopping distance would cause greater force. The destruction of the non-reinforced mailboxes had little effect on the speed at impact. Given that the wall building materials are not designed to resist lateral loads of such magnitude, this impact was sufficient to cause the movement of connected building materials inward from the impact zone. Affects of vibration and deformation are absorbed in the building structural members as the distance increases from the impact zone. However, vibration and small movements allow release of stress at the contact points (joints) resulting in cracks and separations. The damage observed is consistent with this mechanism. COLLISION RELATED DAMAGE The damage observed is consistent with the collision and resulting forces levied on building and property materials. Generally, there remains a risk of further water intrusion and interior damage until the building envelope is fully repaired. The damages related to vehicle movement during this incident are summarized below, in the drawings and in the photographs. BE (F-672) File 16-03-04-0024 Calloway Residence building [Confidential] October 20, 2016 7 Damage Cause and Origin EXTERIOR The non-reinforced mailboxes were destroyed and must be rebuilt. The PVC sprinkler system and decorative bed lighting systems were also damaged as the vehicle approached the wall. These systems must also be repaired or replaced. EXTEIOR BRICK VENEER AND FRIEZE BOARD The brick veneer at the impact zone and adjacent areas shows new cracking and separations related to vibration and deflection at the time of impact and subsequent slow deformation to relieve stress. The exterior brick veneer must be replaced in the affected areas including those adjacent to the impact zone. This must be done in coordination with wall structural repairs. The separated frieze board at the front impact area is separated and must be repaired. WALLS AND WALL PENETRATIONS The wood structure (studs, top and bottom plates) are damaged at the front window and adjacent areas. These materials show bowing (deformation) and cracks. These must be exposed, reinforced or reattached, and cracked/damaged members replaced with careful attention to supporting and sealing the remaining structure temporarily to prevent further damage. The wall penetrations (windows and associated framing – see drawing) are damaged via separation and stress from deformation related to the impact. These also must be replaced to allow for proper function and performance. The window units (both sides including missing and separated glazing) must be replaced at the front along with any damaged shutters and trim. Damaged and separated windows must be replaced. INTERIOR WATER DAMAGE AND INTERIOR BUILDING MATERIALS The interior hardwood flooring near the impact zone was exposed to water intrusion and shows evidence of cupping from moisture changes. The water damage is indicated on the drawings and photographs. This flooring must be repaired or replaced. Interior sheetrock and trim shows evidence of cracking and separations from impact vibration and stress release. These damaged areas must be repaired after any structural repairs are complete. RISK AND HAZARD There is a current risk of injury from potential falling objects (brick or other building materials) during wall structural repairs of the impact area. There is also a real risk of electrical injury, injury during replacement of exterior wall and lighting. Thus, access to this area must be controlled for safety and water intrusion to the interior must be prohibited during repair work. BE (F-672) File 16-03-04-0024 Calloway Residence building [Confidential] October 20, 2016 8 Damage Cause and Origin IV. RECOMMENDATIONS All general recommendations for damaged items are summarized in the executive summary. Based on the conclusions, it is our recommendation that: The mail boxes, exterior lighting and sprinkler system must be repaired and/or replaced accordingly. The brick veneer at the front left side must be replaced. The new cracks at the left side can be tuck pointed. The separation at the frieze board must be addressed when the brick is replaced. The foundation smear coat at the front below the brick must be replaced in coordination with brick replacement. The full window structure in the impact area (dining room) must be replaced. Damaged interior trim in the impact zone must be replaced. Cracks and separations at interior walls and ceilings near the dining room must be repaired. The cupped hardwood floor areas must be repaired or replaced. All replacement materials and reconstruction must meet or exceed local code requirements for current construction and development. We recommend that all replaced building materials be properly protected against wetness and high moisture during reconstruction. windows and doors must be fully flashed. All replacement All exposed areas must be protected from water intrusion during construction. If significant repairs are needed that expose the interior to the outside environment, it is the contractor’s responsibility to cover all exposed areas during all phases of the work to prevent further water intrusion. Construction must meet current state and local codes. All structural repairs must be conducted under the direction of a Texas licensed professional engineer. All repairs (i.e. electrical and plumbing) must be under the direction of appropriately licensed professionals. BE (F-672) File 16-03-04-0024 Calloway Residence building [Confidential] October 20, 2016 9 Damage Cause and Origin GENERAL BASIS OF REPORT AND APPLICABLE DEFINITIONS This report is based on the following: Visual observation of the Calloway residence. Data collection within the Calloway residence. History of the incident as described by the Ms. Calloway and confirmed as needed by data analysis. Police records for this incident. Observations and analyses as noted in this report. If applicable and requested, current code requirements as listed in references may be used to determine needed upgrades and/or compliance. BE (F-672) File 16-03-04-0024 Calloway Residence building [Confidential] October 20, 2016 10 Damage Cause and Origin General Definitions as applicable: Damage: Exterior damage (e.g., water damage, etc.) directly or indirectly related to the excess moisture intrusion and impact forces acting on this building. Deflection: For the purposes of this report, deflection is net movement or displacement of a structure from a point of equilibrium resulting in damage. Damage (permanent deformation) normally results from displacement or bending beyond the elastic tolerance of the structure, joint or member. Excessive or high moisture: For the purposes of this report, this refers to moisture in building materials that has been high enough to leave stain traces from free water migration through the material, cause material degradation (deterioration) or cause excessive mold growth. If the high material moisture condition remains it may be documented with moisture meter measurements. Pressure: For the purposes of this report, pressure refers to static or dynamic pressure force exerted by air molecules on an interior or exterior surface. Renovation or repair: Refinishing, resurfacing, rebuilding/repairing structural framework, new drywall, taping, floating, painting, flooring and other items needed to put the interior of the building back to its original condition before the hurricane. All repairs must comply with new construction code requirements. Shear Force: For the purposes of this document shear force is horizontal or lateral force (pressure) exerted by impact on a vertical surface or plane. Force from horizontal impact: ½ M(V2). Vibration: For the purposes of this report, vibration refers to shaking or structure particle movement. Vibration parameters such as frequency, amplitude, and wave length or particle velocity are not used and are not applicable in this discussion since these properties are not measured for this particular structure under impact conditions. Water Intrusion: Non-flood water penetration to the interior as a result of openings or breaches created in the building envelope by the delivery vehicle collision force. Wicking, absorption or seepage: Water movement through porous media by capillary forces following gradients into dry construction materials from wet areas. BE (F-672) File 16-03-04-0024 Calloway Residence building [Confidential] October 20, 2016 11 Damage Cause and Origin REFERENCES: 1. American Society of Civil Engineers (ASCE) Standard, Guideline for Condition Assessment of the Building Envelope, SEI/ASCE 30-00, 2000. 2. American Society of Civil Engineers – “Guideline for the Structural Condition Assessment of Existing Buildings”, ANSI/ASCE 11-90, ANSI Approved August 1991. 3. American Society of Civil Engineers – “Minimum Design Loads for Buildings and Other Structures”, ANSI/ASCE 795, Approved June 1996. 4. American Architectural Manufacturers Association, Voluntary Specification for Field Testing of Windows and Sliding Glass Doors, AAMA 502-02. 5. American National Standards Institute & II CRC, Standard and Reference Guide for Professional Water Damage Restoration (S500), 2006. 6. American Society for Testing and Materials, ASTM, Standard Test Method for Field Determination of Water Penetration of Installed Exterior Windows Skylights, Doors and Curtain Walls by Uniform or Cyclic Static Air Pressure Difference, Designation: E1105-00. 7. ASTM Special Technical Publication 901,Building Performance: Function, Preservation, and Rehabilitation, 1983. 8. Building Research Advisory Board, Criteria for Selection and Design of Residential Slabs-On-Ground, Publication 1571, 1968. 9. Building Officials & Code Administrators International, Inc. The BOCA National Building Code/ 1996, Country Club Hills, IL, 1996. 10. Carper, Kenneth L., Forensic Engineering, CRC Press, 1998. 11. FEMA, Coastal Construction Manual, Principles and Practices of Planning, Siting, Designing, Constructing, and Maintaining Buildings in Coastal Areas, November 2003. 12. Forest Products Laboratory, Wood Handbook, 1999. 13. International Conference of Building Officials. 1997 Uniform Building Code Volume 1, Wittier, CA, 1997. 14. International Building Code Council, Inc. International Residential Code for One-and Two Family Dwellings, 2006. 15. International Building Code Council, Inc. International Building Code 2000, Falls Church, VA, 2000. 16. Oxley, T.A., and Gobert E.G., Dampness IN Buildings, Diagnosis – Treatment – Instruments, 1989. 17. Southern Building Code Congress International, Inc. 1997 Standard Existing Buildings Code, Birmingham, AL, 1997. BE (F-672) File 16-03-04-0024 Calloway Residence building [Confidential] October 20, 2016 12 Damage Cause and Origin ATTACHMENT I PHOTOGRAPHS & DATA BE File #: 16-03-04-0024 Calloway Residence Collision October 20, 2016 Confidential Damage Cause & Origin Assessment Photo 1: Front (northwest) side view of home before the collision. Photo 2: BE File #: 16-03-04-0024 Calloway Residence Collision Front side view after the collision. October 20, 2016 Confidential Damage Cause & Origin Assessment Photo 3: Brick mailboxes destroyed in vehicle pathway to home. Photo 4: BE File #: 16-03-04-0024 Calloway Residence Collision Damage remaining during BE visit. October 20, 2016 Confidential Damage Cause & Origin Assessment Photo 5: Fresh brick crack and mortar separations adjacent to impact area. Photo 6: BE File #: 16-03-04-0024 Calloway Residence Collision Fresh mortar separations adjacent to impact area. October 20, 2016 Confidential Damage Cause & Origin Assessment Photo 7: Fresh brick cracks and smear coat cracking at impact area. Photo 8: BE File #: 16-03-04-0024 Calloway Residence Collision Window frame damage at impact area. October 20, 2016 Confidential Damage Cause & Origin Assessment Photo 9: Photo 10: BE File #: 16-03-04-0024 Calloway Residence Collision Closeup of interior window trim damage at impact area. Close up of window frame damage at impact area. October 20, 2016 Confidential Damage Cause & Origin Assessment Photo 11: Remaining window frame separation from glazing at impact area. Photo 12: Remaining window frame separation from glazing at impact area. BE File #: 16-03-04-0024 Calloway Residence Collision October 20, 2016 Confidential Damage Cause & Origin Assessment Photo 13: Photo 14: BE File #: 16-03-04-0024 Calloway Residence Collision Inward window frame bow or displacement out of vertical at impact area. Outward bow or displacement at the upper window frame above impact area. October 20, 2016 Confidential Damage Cause & Origin Assessment Photo 15: Photo 16: BE File #: 16-03-04-0024 Calloway Residence Collision Separation of soldier brick near the impact area. Brick veneer separations and cracks adjacent to the impact area. October 20, 2016 Confidential Damage Cause & Origin Assessment Photo 17: Photo 18: BE File #: 16-03-04-0024 Calloway Residence Collision Close up of previous photo. Brick veneer separations and cracks adjacent to the impact area. October 20, 2016 Confidential Damage Cause & Origin Assessment Photo 19: Photo 20: BE File #: 16-03-04-0024 Calloway Residence Collision Brick veneer separations and cracks adjacent to the impact area. Close up of fresh separations and cracks in previous photos. October 20, 2016 Confidential Damage Cause & Origin Assessment Photo 21: Brick veneer separations and cracks adjacent to the impact area. Photo 22: BE File #: 16-03-04-0024 Calloway Residence Collision Close up of previous photo. October 20, 2016 Confidential Damage Cause & Origin Assessment Photo 23: Photo 24: BE File #: 16-03-04-0024 Calloway Residence Collision Separation of the gutter and frieze board at the impact area. Separation of the frieze board and the soldier course adjacent to the impact area. October 20, 2016 Confidential Damage Cause & Origin Assessment Photo 25: Existing bow or deflection of approximately ½” at the impact area framing. Photo 26: BE File #: 16-03-04-0024 Calloway Residence Collision Close up of deflection in previous photo. October 20, 2016 Confidential Damage Cause & Origin Assessment Photo 27: Photo 28: BE File #: 16-03-04-0024 Calloway Residence Collision Remaining vehicle body parts in the bed outside impact area. New interior ceiling cracks adjacent to impact area. October 20, 2016 Confidential Damage Cause & Origin Assessment Photo 29: Photo 30: BE File #: 16-03-04-0024 Calloway Residence Collision New interior wall cracks adjacent to impact area. New interior cracks adjacent to impact area. October 20, 2016 Confidential Damage Cause & Origin Assessment Photo 31: Photo 32: BE File #: 16-03-04-0024 Calloway Residence Collision New interior cracks adjacent to impact area. Bowed wall area adjacent to impact area. October 20, 2016 Confidential Damage Cause & Origin Assessment Photo 33: Photo 34: BE File #: 16-03-04-0024 Calloway Residence Collision Base molding gaps at the uneven areas of the hardwood floor. New interior ceiling cracks adjacent to impact area (dining room). October 20, 2016 Confidential Damage Cause & Origin Assessment Photo 35: New wall crack and trim separation in the dining room at the entry to the kitchen. Photo 36: BE File #: 16-03-04-0024 Calloway Residence Collision Close up of previous photo. October 20, 2016 Confidential Damage Cause & Origin Assessment Photo 37: New interior call crack in the dining room at the entry to the kitchen. Photo 38: BE File #: 16-03-04-0024 Calloway Residence Collision Close up of previous photo. October 20, 2016 Confidential Damage Cause & Origin Assessment Photo 39: New wall crack and trim separation in the kitchen at the entry to the dining room. Photo 40: New wall and ceiling separation in the kitchen near the entry to the dining room. BE File #: 16-03-04-0024 Calloway Residence Collision October 20, 2016 Confidential Damage Cause & Origin Assessment Photo 41: Corner separation at the bathroom opposite the cracks in the dining room wall. Photo 42: New crown molding separation at the bathroom opposite the dining room wall. BE File #: 16-03-04-0024 Calloway Residence Collision October 20, 2016 Confidential Damage Cause & Origin Assessment Photo 43: Photo 44: BE File #: 16-03-04-0024 Calloway Residence Collision Separation at the wall ceiling junction in the dining room entry from the hallway. Uneven flooring and base molding gap adjacent to the impact area. October 20, 2016 Confidential Damage Cause & Origin Assessment Photo 45: Cupped flooring at the impact area where rainwater intruded. Photo 46: Cupped flooring at the impact area where rainwater intruded. BE File #: 16-03-04-0024 Calloway Residence Collision October 20, 2016 Confidential Damage Cause & Origin Assessment Photo 47: BE File #: 16-03-04-0024 Calloway Residence Collision Police report confirming the Amazon delivery vehicle impact. October 20, 2016 Confidential Damage Cause & Origin Assessment Photo 48: BE File #: 16-03-04-0024 Calloway Residence Collision Police report confirming the Amazon delivery vehicle impact.. October 20, 2016 Confidential Damage Cause & Origin Assessment Pier plan with prior topography (leveled after underpinning). BE File #: 16-03-04-0024 Calloway Residence Collision October 20, 2016 Confidential Damage Cause & Origin Assessment ATTACHMENT II SCHEMATICS BE File #: 16-03-04-0024 Calloway Residence Collision October 20, 2016 Confidential Damage Cause & Origin Assessment SEISHS 17 ON .LI-IHS ELLO .O L=u ZEWVOS 17800-170-80?91. aomaixa 3? 30013 _-lO ouvwaHos zawvu 09sz Xi U1 HOUSE WQZL SSOEIC) uogsulog 2)on eouepgsea zuaadoad HHXOHH WOLLOEI .LV NI 1333 MOVED 35' Gavoe 323m ad xoa saxoaww MOIHS \9 HOVWVG 7? wouoa 1v NI GEIMOS HWVEIJMOCINIM avaws AHLNE EL-I 08 I. I. - GHAOELLSECI CIEIOVWVCI MOCINIM HOVJ NOIHEI LIJ (HEDGE W?l?llV ?(Hana 13 wave 00 (D 3 EXTERIOR 1 ATRIUM DINING 10 BOWED CD CC EN .N I ENTRY DESTRO ED QC) 8? . 3? 17? LEGEND CC CEILING CRACK CMS CROWN MOLDING OR WALL CEILING SEPARATION 0::10 TD TRIM DAMAGE SCALE IN TS TRIM SEPARATION WC WALL CRACK sucm cuppme BECKER ENGINEERING SEPARATION OF WOOD FLOORING PROPERTY: . . . Collewoy ReSIdence Home HARDWOOD FLOORING 12544 Renoir Ln Dallas, Tx 75230 (D TILE FLOORING DWG. NAME: SCHEMATIC OF FLOOR PLAN FILE WITH INTERIOR OBSERVATIONS 16_03_04_0024 SCALE: 1"=10? SURVEYED BY: GTB SHEET NO 2 OF 4 SHEETS 0.5 0.5 0 no 0.9 EXTERIOR ATRIUM LEGEND ELEVATION MEASURED CONTOUR PRESSED PILE (APPROX 5 YEARS OLD) ENTRY 0 10 SCALE IN BECKER ENGINEERING PROPERTY: Collewoy Residence Home Collision 12544 Renoir Ln Dallas, Tx 75230 DWG. NAME: SCHEMATIC OF FLOOR PLAN FILE WITH ELEVATIONS 16-03-04-0024 SCALE: 1"=10? SURVEYED BY: GTB SHEET NO 3 OF 4 SHEETS DRIVEWAY GARAGE LEGEND (X) PIER (APPROX. 8 YEARS OLD) PRESSED PILE (APPROX 5 YEARS OLD) FP PORCH 15 SCALE IN FEET BECKER ENGINEERING PROPERTY: Calleway Residence Home Collision 12544 Renoir Ln Dallas, Tx 75230 DWG. NAME: SCHEMATIC OF Ist FLOOR PLAN WITH PILE LOCATIONS SCALE: 1"=15? SURVEYED BY: GTB FILE 16-03-04-0024 SHEET NO 4 OF 4 SHEETS