IN THIS ISSUE:

DECEMBER 2014

NEW CONSTRUCTION FAST-TRACK TO TROUBLE: CONTRACTOR ALLOWED TO STOP WORK AND TERMINATE CONTRACT FOR AGENCY’S FAILURE TO ENSURE CONSTRUCTABILITY OF DESIGN WITHIN CONTRACT PRICE

UNDER CONSTRUCTION CONSTRUCTION COMPANIES MAY NOT BE LIABLE FOR OBVIOUS AND APPARENT CITY OBSTRUCTIONS THEY CREATE COST BUT NOT CAUSE— A PLAINTIFF’S BURDEN IN RECOVERING UNANTICIPATED EXPENSES THROUGH QUANTUM MERUIT DUTY OF CARE EXTENDS FROM ARCHITECT TO THIRD PARTIES NOT IN PRIVITY

OTHER CONSTRUCTIVE THOUGHTS CONSTRUCTION GROUP

NEW CONSTRUCTION FAST-TRACK TO TROUBLE: CONTRACTOR ALLOWED TO STOP WORK AND TERMINATE CONTRACT FOR AGENCY’S FAILURE TO ENSURE CONSTRUCTABILITY OF DESIGN WITHIN CONTRACT PRICE Introduction On December 9, 2014, a three-member panel of the Civilian Board of Contract Appeals (CBCA) issued a decision concluding that the Department of Veterans Affairs (VA) was contractually obligated to provide its contractor, Kiewit-Turner, a Joint Venture (KT), a design that could be built for the agreed-upon cost limitation; that the VA materially breached the contract by failing to do so; and as a result of the VA’s material breach, the contractor was entitled to stop the work and cancel the contract. Kiewit-Turner, A Joint Venture v. Dep’t of Veterans Affairs, CBCA No. 3450 (Dec. 9, 2014). The decision is significant in a number of respects, but most notably because it authorized a government contractor to stop the work on a federal construction project and cancel the underlying contract because the design procured by the government from its chosen designer could not be constructed for the agreed-upon stated cost limitation. In reaching this result, the CBCA also concluded that the contractor could not adequately be compensated in monetary damages for the VA’s failure to provide such a design since the underlying contract did not incorporate any particular set of construction drawings from which changes could be priced under a traditional changed conditions analysis. The CBCA also concluded it would be manifestly unfair to require the contractor to construct the project without any guarantee of full payment since the agency lacked sufficient funds to pay for the estimated construction cost of the project as currently designed and had no plans to request further appropriations.

Background On August 31, 2010, the VA awarded KT a contract for preconstruction services for a medical center campus to be constructed in Aurora, Colorado. The project is commonly known in the industry as “the Denver VA.” The VA hired the contractor under an integrated design and construction services contract (IDc) to provide preconstruction services during the design phase, with an option for the VA to award the contractor the actual construction work. Under the IDc contract, and as part of its preconstruction services, the contractor analyzed and priced the various design iterations and provided the owner value engineering (VE) advice to reduce construction costs. The owner retained the responsibility for managing the design and ensuring it could be built for the owner’s budget. According to the CBCA, the VA had never previously used this project delivery method and did not use it properly. By the time KT was brought into the process, the design was 50 percent complete and the agency already had made significant budgetary decisions, including—on the very day KT was hired—the establishment of the estimated construction cost at award, or ECCA, at $582,840,000. The CBCA observed that these actions significantly limited the agency’s flexibility to make modifications to the design based upon KT’s preconstruction advice. In short, the design was already too far along for the contractor’s preconstruction services to result in the desired level of integration into and constructive impact on the design. During the preconstruction services phase, KT submitted numerous reports to the agency informing it at many stages that the design lacked coordination and completeness and that the estimated cost of constructing the various design iterations exceeded the VA’s ECCA. The contractor also advised that the design included elements that were above the typical standards for a health care facility and repeatedly advised the VA that agreed-upon VE modifications were not being incorporated into the design. When the design reached 65 percent completion, KT submitted a construction cost estimate of $664 million or $81,160,000 more than the ECCA. Despite the obvious trajectory the anticipated cost of the design was taking, the VA asked KT to prepare a formal proposal for the construction work based on the incomplete design. KT honored the VA’s request and submitted a proposal valued at $603 million (including payment for all preconstruction 1

services) with a ceiling price of $609 million. KT’s proposal predictably was accompanied by a litany of clarifications and assumptions, reflecting the evolving nature of the design. Two of the more significant assumptions were that the VA would include at least $23 million of VE items in the final design documents and that KT could negotiate at least $31 million in cost reductions from its subcontractors. At the same time, an independent estimate issued by the VA’s construction manager pegged construction costs for the then-current design at $677,697,408, nearly $100 million above the ECCA. The VA and KT engaged in months of negotiations to settle upon a cost of construction (in the form of a fixed target price, or FTP) notwithstanding the still-incomplete design. Those efforts ultimately resulted in the parties agreeing, during a multiday meeting, that KT would remove all clarifications, qualifications, and assumptions from its earlier proposal and commit to an FTP of $604 million (with a commensurate ceiling price of $610 million) in exchange for the VA’s commitment to cause the design team to produce a design that met the VA’s ECCA of $582,840,000. Since the current design did not meet this cost limitation, this agreement required the VA, through the use of VE and other means, to have its designer produce a design that could be constructed for less than the current estimated cost of the project, which KT then estimated as $664 million. The VA and KT memorialized their agreement in a change order that exercised the construction phase option and established the FTP at $604,087,179. As the CBCA’s decision explains in detail, notwithstanding the commitments memorialized in the change order, the VA did not take control of the design and did not reduce the estimated construction costs. The projected cost of the “new” design remained far in excess of the stated cost limitation. While the VA issued perfunctory directives to the design team to redesign the project to bring the estimated cost of construction below the ECCA, at the same time the VA directed KT—over KT’s strenuous objections—to proceed with the construction based on the then-existing and over-budget design. In an effort to right the ship, KT provided additional value engineering suggestions, many of which were rejected by the VA; and other suggestions, though agreed to by the VA, were not incorporated by the designer into the design. The result was obvious and predictable: the gap between the agreed-upon construction cost limitation and the estimated cost of construction did not narrow. The VA ultimately failed to change the design and failed or refused to seek additional appropriations to pay for the anticipated costs of construction. 2

The CBCA Proceedings

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In April 2013, KT filed a claim with the Contracting Officer seeking a determination of whether the VA was in breach of the contract for failing to provide a design that could be built for the cost limitation and, if so, whether KT was entitled to suspend work on the project. In June 2013, the Contracting Officer issued a decision determining that no breach had occurred and directing KT to continue with the work based upon the current design, which at that time KT estimated might cost as much as $1.085 billion. KT appealed the Contracting Officer’s decision to the Civilian Board of Contract Appeals, seeking a declaration that the VA was in breach and that KT could suspend the work. The VA moved to dismiss the appeal, arguing that the contractor was not entitled as a matter of law to declaratory relief since if the contractor demonstrated that the VA had breached its duty to produce a design within the ECCA, the contractor had an adequate remedy in monetary damages. According to the VA, the contractor could use the contract’s changes clause to seek additional compensation once the project was completed, which alleviated the need for declaratory relief. KT disputed the VA’s contention and asserted that it was critical to resolve these contractual interpretation issues immediately so that the contractor and its numerous subcontractors would know whether they were required to continue to perform in the face of the VA’s alleged breach of contract and the potential financial difficulties associated with financing the completion of the project. On May 22, 2014, the CBCA denied the VA’s motion to dismiss. In that order, the CBCA concluded that declaratory relief could be an appropriate remedy under the circumstances alleged because monetary damages would not adequately protect KT’s interests. Critical to the CBCA’s decision was the fact that requiring the contracting team to rely solely on the contract’s changes clause to recoup the funds expended to construct the project would be both unfair to the contractor and an inadequate remedy particularly where, as here, completion of the work as currently designed could increase the cost of the project by at least $200 million, or more than 30 percent of the initial ECCA. According to the CBCA: This would be, at the least, a cardinal change to the contract, and would require appellant to serve as long-term banker for the Government, while it makes its way through the pitfalls of submitting claims under the changes clause to a contracting officer who, according to KT, does not have funds allocated to the contract beyond the $582,000,000 ECCA. At this stage, appellant’s legal remedy must be assumed to be inadequate and it has a special need for early interpretation of the contract. 2

The case then proceeded to a hearing on the merits. After eight days of testimony, the CBCA made a number of findings, including, significantly, the determination that the VA failed to pursue a redesign of the project to meet the ECCA as it had contractually agreed to do and had not sought additional funding it knew was necessary to construct the project as currently designed. From these facts it necessarily followed that the VA had breached its contractual obligation to provide a design for the project that could be built for the stated cost limitation. As part of its analysis, the CBCA considered whether the VA’s breach was “material,” in other words, whether it concerned a fundamental and essential term of the contract. Applying the factors cited in the Restatement (Second) of Contracts § 241, the CBCA concluded that the breach went to the essence of the agreement and indeed was material, focusing particularly on the fact that the contractor had been deprived of the benefit of the bargain because it was not given a design that could be constructed for the ECCA and could not be compensated adequately in monetary damages for the VA’s failure to provide such a design. In reaching this conclusion, the CBCA focused on the lack of baseline design documents against which the value of changes could be measured. In addition, the CBCA found it significant that the agency did not have sufficient funds to pay for the estimated costs of construction of the entire project as currently designed and had no plans to ask for more appropriations to do so. The CBCA also found there was little likelihood that the VA would cure its contractual default, given its insistence that it would neither redesign the project nor seek additional appropriated funds to complete it. Lastly, the CBCA concluded that the VA breached its duty of good faith and fair dealing by failing to provide a design that could be constructed within the ECCA by ignoring the VE suggestions made by the contractor and its independent construction manager and by disregarding the cost estimates that had been prepared, all of which showed the design exceeded the ECCA by material margins. Against this evidence, the CBCA concluded that the VA was in material breach, which entitled the contracting team as the nonbreaching party to discontinue performance of and terminate the contract.

Decision Takeaways

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The VA could seek appellate review of the CBCA’s decision by the Federal Circuit Court of Appeals, where legal conclusions of the boards of contract appeals are subject to de novo review, but factual determinations, if adequately supported by the evidence, are final and conclusive. An appeal seems unlikely, however, because the VA, within days of the CBCA’s decision and in the face of significant congressional pressure, agreed to allow the Army Corps of Engineers to take over responsibility for administering completion of the Denver VA project.1 Regardless of whether the decision is appealed, it addresses a recurring issue on modern federal construction projects: an agency’s failure to align its wants with its budget. All too often, agencies use integrated project delivery methods borrowed from the private sector, but are faced with institutional constraints, procurement rules, and budgetary limitations that prevent the project delivery method from properly working. Design modifications and value engineering changes face user group opposition, and decision making is delayed or nonexistent. All too often, the end result is a directive to the contactor to commence performance of the work, even though the contractor’s estimate shows that the design exceeds the stated cost limitation. Efforts to reduce costs, once construction commences, are inevitably unsuccessful and lead to the filing of claims by the contractor. In fairness, these challenges are not unique to the VA and frequently occur with other governmental agencies. If nothing else, the CBCA’s decision highlights the risks for government agencies that head down this path. For contractors, the CBCA’s decision serves as a timely reminder that the prosecution of work clause does not always require the contractor’s continued contract performance absent a declared cardinal change. This is especially true in situations where, as here, contractors are integrated into the design phase but lack any control over the design process and ultimately are faced with the challenge of constructing a design that materially exceeds the stated cost limitation. The decision gives contactors some added leverage to push back against an agency and demand that it manage the design to its budget. Making a contractor build what an agency wants, and then file claims to get paid for the work it was directed to perform, is very expensive and unfair to the contactor. The government should either appropriate sufficient funds for the project it wants or reduce the scope of the project to what it can afford. The CBCA’s decision is also significant for design professionals, since most design agreements obligate the designer to produce a design that can be built for a specified amount and require the designer to revise the design at its own expense if the estimated costs of construction exceed the stated cost limitation. Faced with an agency that cannot or will not control its user groups, design firms need to protect themselves by keeping detailed and accurate records of agency directives that prevent the design from complying with applicable cost limitations and records of advice the designer gave the agency that its requirements or desires are misaligned with its budget. Such evidence could be critical in shielding designers from liability when agencies seek to blame them for the cost of designs the agency directed the designers to produce. 1

“VA Agrees to Let Army Corps Oversee Troubled Aurora Hospital Project,” Denver Business Journal, Dec. 10, 2014.

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UNDER CONSTRUCTION CONSTRUCTION COMPANIES MAY NOT BE LIABLE FOR OBVIOUS AND APPARENT CITY OBSTRUCTIONS THEY CREATE Commercial construction projects in urban areas present unique risks to everyday pedestrians who may come into contact with the project’s site conditions. Commonly, municipalities have a duty to ensure its public sidewalks or access ways are safe; but when a construction company exercises control of a given urban space, the construction company may take on particular legal duties regarding the public spaces being used. In a recent Louisiana case, one construction company avoided the burden of tort liability from a public sidewalk by establishing that its large sidewalk dumpster was an obvious and apparent obstruction that any pedestrian could have taken upon himself to avoid. But, had the company not taken active precautionary measures, the result may not have been in the company’s favor. In December 2011, one New Orleans resident was crossing the street in the French Quarter near a large dumpster and a construction barrier when he was hit by a bicyclist. The dumpster and barrier had been placed by a construction company in connection with a renovation project. The renovation project had begun about six months earlier, and the construction company had obtained permits from the city to close the sidewalk, redirect foot traffic to the other side of the street, and rent three abutting parking spaces to temporarily house the dumpster. At the project site, the dumpster construction company displayed a 4 foot by 3 foot sign in contrasting lettering stating “SIDEWALK CLOSED” and “PLEASE USE OTHER SIDEWALK” and showing a large redirection arrow. The dumpster was red and about the size of a pick-up truck. Yet, the obstruction created a blind spot for the pedestrian, who was able to avoid cars passing along the road but not an oncoming bicyclist-delivery-person. The pedestrian filed a personal injury lawsuit against all the property owners, the property owner’s insurer, the construction company, the bicyclist-delivery-person, and the bicyclist’s employer, seeking compensation for damages.

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The pedestrian claimed the construction company was negligent for creating a line-of-sight obstruction by placing the dumpster immediately next to the street without a buffer zone. Additionally, the pedestrian alleged the area should have been fenced off to form a visible buffer zone. Further, the pedestrian alleged that the construction company’s sign should have warned not only of the sidewalk closure but also of a “blind spot,” and he alleged the sign should have directed all pedestrian crossings to the street corner. After some procedural discovery in the case, the construction company filed a motion for summary judgment. In its motion, the construction company stated that the pedestrian could not prove that the construction company had any legal duty to warn the pedestrian to look both ways before crossing the street. The district court heard the motion but determined that the issue was a factual issue rather than legal, denying the construction company’s motion. Disagreeing with the decision, the construction company appealed to the state’s appellate court, then to the Louisiana Supreme Court. The Louisiana Supreme Court narrowed the issues to this: [W]hether the sidewalk condition, created by [construction company]’s allegedly insufficient posted warnings and the placement of the large curbside dumpster, produced a vision obstruction for pedestrians crossing the street at that location that was unreasonably dangerous, and, if so, whether [the construction company] owed a duty to place additional warnings on its signage and/or to construct a buffer zone that would mitigate against any vision obstruction created. In the resulting opinion, the Louisiana Supreme Court reversed the district court, acknowledging that the primary issue in whether the construction company was negligent would depend on whether the company owed a duty to the pedestrian—which could be determined by the law (instead of by the facts of the particular case). Further, the Louisiana Supreme Court analyzed the legal duty based on a risk-utility analysis that had been developed by the state’s courts. Under such analysis, the court was required to balance (1) the utility of the complainedof conditions; (2) the likelihood and magnitude of the harm, including any obviousness or apparentness of the condition; (3) the cost of preventing the harm; and (4) the nature of the pedestrian’s activities—whether the activities had social utility or were dangerous by their nature. The Louisiana Supreme Court found that there was utility in the construction company’s site conditions because the French Quarter needed such repairs and renovations. However, the court did not reach analysis of the third or fourth prongs of the balancing test because the court found the second prong to be determinative: whether the allegedly dangerous project site condition was “obvious” and “apparent” (meaning, the hazard should be one that is open and obvious to everyone who may potentially encounter it). Notably, two common rules were at play: a defendant does not have a duty to protect against that which is open and obvious to everyone who may potentially encounter it versus the rule that a defendant may be liable for the unreasonably dangerous conditions it creates if a defendant assumes custody of a public sidewalk. The court was convinced by physical pictures showing the size and scale of the dumpster, deposition evidence that the pedestrian had admitted to having seen the large dumpster for about four months, 4

and the pedestrian’s admission to knowing that bicyclists often rode down the streets, even in the wrong direction at times. Thus, the Louisiana Supreme Court determined that as a matter of law the construction company had no legal duty to warn the pedestrian of any vision obstruction caused by the dumpster; crossing the street was safe for persons exercising ordinary care and prudence. This Louisiana case may be instructive in other settings of heavy pedestrian traffic or urban redevelopment. As walkability becomes a desired goal of many urban centers, commercial construction companies working on projects in and around public spaces should consider the risks of any obstructions they create as part of project work. In many municipalities, the general legal rule may be, as it is in this case, that the construction company is responsible after having assumed control of the city’s space. Only in some cases, as was here, will any of the construction company’s obstructions be deemed “open,” “obvious,” or “apparent” obstructions to put the duty to exercise caution back on pedestrians. A preliminary legal analysis of city rules in the project area and controlling court cases may help to mitigate construction liability. Bufkin v. Felipe’s Louisiana, LLC, 2014 WL 5394087 (La. Oct. 15, 2014) (full citation forthcoming in S.3d reporter)

COST BUT NOT CAUSE—A PLAINTIFF’S BURDEN IN RECOVERING UNANTICIPATED EXPENSES THROUGH QUANTUM MERUIT A contractor who seeks payment for uncompensated services that he or she has provided may bring an action in quantum meruit, which is Latin for “as much as he deserved.” Quantum meruit entitles a person who has rendered services to the amount of payment deemed appropriate by a court. Proving a prima facie case for quantum meruit requires a plaintiff to show that the defendant received a benefit from services provided by the plaintiff and that withholding payment would unjustly enrich the defendant. One scenario where a contractor may seek recovery under quantum meruit is when a construction mishap requires a contractor to perform additional, unanticipated work. What must a contractor show to recover unexpected costs in such a situation? The Rhode Island Supreme Court recently addressed this issue, clarifying that the contractor need not prove who was at fault for the increased costs, but merely that the contractor bringing the action was not at fault.

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This case pertains to the replacement of high-pressure water pipes on Brown University’s campus. One subcontractor, DiGregorio, hired another subcontractor, Process Engineers & Constructors, Inc., to install the pipes. Months after installation, the parties noticed that a pipe was leaking and required replacement. Process replaced the pipe and finished the project, but DiGregorio did not pay Process for this additional, unanticipated work. Process brought a quantum meruit action against DiGregorio, and the case proceeded to trial. DiGregorio’s president testified at trial that DiGregorio withheld almost $150,000 in payments from Process because DiGregorio believed that Process was to blame for the pipe damage. The trial court determined that Process sufficiently proved its lack of fault and awarded damages to Process. DiGregario appealed the case to the Rhode Island Supreme Court, contending that to succeed under quantum meruit, Process must not only show a lack of fault, but the cause of excess costs as well. The court disagreed, holding that Process’s ability to show that the additional costs were not caused by Process’s “own inefficiencies or job preparation” was enough to satisfy the burden of proof, clarifying that a plaintiff in a quantum meruit suit for additional costs need not prove who was at fault, but only that fault did not belong to the plaintiff. This Rhode Island Supreme Court holding is favorable to plaintiffs in quantum meruit suits who find themselves unpaid for work performed. Rather than require plaintiffs to spend time and money ascertaining the root causes of potentially unknown problems before recovering damages, this case explains that such a burden does not exist. Rather, plaintiffs may recoup payment for additional costs by showing only that the plaintiff’s actions did not cause them. Process Eng’rs & Constructors, Inc. v. DiGregorio, Inc., 93 A.3d 1047 (R.I. 2014)

DUTY OF CARE EXTENDS FROM ARCHITECT TO THIRD PARTIES NOT IN PRIVITY Until recently, an architect of a new residential construction in California could arguably avoid liability to an eventual purchaser of the project for negligence because the architect owed no duty of care to an eventual purchaser based on lack of privity. The Supreme Court of California held in Beacon Residential Cmty. Assn. v. Skidmore, Owings & Merrill LLP, 59 Cal. 4th 568, 327 P.3d 850 (2014), that as a matter of first impression, a principal architect—i.e., an architect that provides professional design services and is not subordinate to other design professionals—owes a duty of care to future homeowners in the design of a residential building. The duty extends to the architects even if they do not actually build the project or exercise ultimate control over the construction. In Beacon, a homeowner association brought suit on behalf of its members for construction design defects that allegedly made the homes unsafe and uninhabitable. Two of the defendants, which were both architectural firms, allegedly designed the homes negligently, but did not make the final decisions regarding the manner

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that the homes were built. The trial court sustained the architects’ demurrer, stating that an architect that merely made recommendations, but did not have final decision making or authority, owed no duty of care to future homeowners in which it was not in privity, or in other words, had no contractual relationship. The court in Beacon recognized that privity is not a prerequisite to demonstrate that duty is owed from an architect to a third-party homeowner: “Although liability for the supply of goods and services historically required privity of contract between the supplier and the injured party, the significance of privity has greatly eroded over the past century.” The court in Beacon gave great weight to the following factors set forth in Biakanja v. Irving, 49 Cal. 2d 647, 320 P.2d 16 (1958), when determining whether a duty of care exists between a plaintiff and a defendant in the absence of privity: (1) the extent to which the transaction was intended to affect the plaintiff; (2) the foreseeability of harm; (3) the degree of certainty that the plaintiff suffered injury; (4) the closeness of the connection between the defendant’s conduct and the injury suffered; (5) the moral blame attached to the defendant’s conduct; and (6) the policy of preventing future harm. Although the defendants were not in privity with the homeowners, the defendants’ responsibilities included (1) providing original design services at the outset of the project, and (2) playing an active role throughout the construction process—i.e., coordinating efforts of the design and construction teams, conducting weekly site visits and inspections, recommending design revisions as needed, and monitoring compliance with design plans. In analyzing the Biakanja factors, the court stated: (1) [The] Defendants’ work was intended to benefit the homeowners living in the residential units that defendants designed and helped to construct. (2) It was foreseeable that these homeowners would be among the limited class of persons harmed by the negligently designed units. (3) Plaintiff’s members have suffered injury; the design defects have made their homes unsafe and uninhabitable during certain periods. (4) In light of the nature and extent of defendants’ role as the sole architects on the Project, there is a close connection between defendants’ conduct and the injury suffered. (5) Because of defendants’ unique and well-compensated role in the [ ] Project as well as their awareness that future homeowners would rely on their specialized expertise in designing safe and habitable homes, significant moral blame attaches to defendants’ conduct. (6) The policy of preventing future harm to homeowners reliant on architects’ specialized skills supports recognition of a duty of care . . . no reason appears to favor homeowners as opposed to architects as efficient distributors of loss resulting from negligent design. 6

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Accordingly, the court held that the architects owed the homeowners a duty of care even though the architects had no contractual relationship with the homeowners, nor had ultimate control over the construction. Based on the decision in Beacon, design professionals should exercise caution to avoid potential liability to eventual homeowners, even when they do not actually exercise ultimate control over the construction. Although the decision in Beacon was specific to principal architects, it is conceivable that the court’s holding could extend to other design professionals, such as engineers. Additionally, even if design professionals are not sued directly by homeowners, this case potentially strengthens equitable indemnity and contribution claims against design professionals by builders, developers and contractors, even in the absence of an express contractual indemnity provision or the lack of a contractual relationship with the design professional. Beacon Residential Cmty. Assn. v. Skidmore, Owings & Merrill LLP 59 Cal. 4th 568, 327 P.3d 850 (2014)

OTHER CONSTRUCTIVE THOUGHTS Mark Johnson participated in a panel presenting a seminar titled “How Come Different Delay Methodologies Reach Different Conclusions and What to Do About It” given at The Construction Super Conference in Las Vegas December 1-3, 2014. On January 22, 2015, Andy Howard and Jessica Sharron will be presenting a seminar titled “The False Claims Act – Be Careful What You Ask For” at The Grand Long Beach in Long Beach, CA, in connection with the Construction Managers Association of America – Southern California Chapter. On April 23, 2015, Kevin Collins and Nathan Sinning will be presenting a seminar titled “Construction Law Update” at The Grand Long Beach in Long Beach, CA, in connection with the Construction Managers Association of America – Southern California Chapter.

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Alston & Bird Construction Group Group Leaders Jeff Belkin [email protected] 404.881.7388 / 202.239.3065

Chris Roux [email protected] 202.239.3113 / 213.576.1103

Group Members

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Steven Campbell [email protected] 404.881.7869

Bill Hughes [email protected] 404.881.7273

Debbie Cazan [email protected] 404.881.7667

Scott Jarvis [email protected] 404.881.7438

Kevin Collins [email protected] 213.576.1184

Mark Johnson [email protected] 213.576.1089

Jake Dean [email protected] 213.576.1072

Mike Shanlever [email protected] 404.881.7619

Eleanor deGolian [email protected] 404.881.7186

Jessica Sharron [email protected] 213.576.1164

Dan Diffley [email protected] 404.881.4703

Nathan Sinning [email protected] 213.576.1134

Erica Harrison [email protected] 404.881.7865

John Spangler [email protected] 404.881.7146

Andy Howard [email protected] 213.576.1057

Breana Ware [email protected] 404.881.4457

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