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CF-Fire Station Moore-CS 860603,June 3, 1986 Mrs. Vernon Proctor, President Mart, Inc~ PO Box 150983 1503 Perry Road Irving, Texas 75015 Re: Coppell Fire Station No~2, Moore Road Dear Vernon, I am in receipt of your letter of May 28 regarding the Liquidated Damages provision with the City, as well your Application for Payment dated May 31 and Change Order No.~4~ Following are our appraisals of each of these issues and our recommendations to Mart and the City for action% Application for Payment~ In your Application dated 5-31-86, you are asking for 100% of the Contract Amountc According to the Owner-Contractor Agreement, you are not due the full contract amount until Final Completion, that is, the completion of all items on the Final Punch List.~ As you know, the punch list is being rewritten this week both to include some problems that have been discovered only recently and to combine the various partial punch lists into one.~. This list will be finalized and distributed under separate cover later this week=, Since we have already authorized the contractural limit of 95%, I am returning Application Noel4 (attached),;' You should resubmit a revised No:14 as the final at the appropriate time~ It is my understanding that submittal of the final application does not need to fall on the 25th of the month as before% Change Order No~4~ I have reviewed these items with the Project Architect and am sending three copies to you for your approval and signature~ Return them to me for processing on to the City,~ Liquidated Damagese I have talked with Chief Mayfield on several occasions lately about the City's disposition toward leniency on the damages~ He is not encouragingT There are two apparent primary arguments against leniency at the present time~ One is the general attitude of the City Council toward construction delays, not just on FS No~2, but even more so on the City Hall project~ Secondly, the Chief told me of several fire alarms that he would have been able to service out of the new station between the final approved completion date and actual Substantial Completion%, The impact of the delay on these calls is certainly difficult to measure, but it nevertheless represents a valid counterpoint and must be considered in making an equitable decision.~ Proctor/6-3-86/Page 2 At this point, my recommendation to you is simply to wrap up the Punch List as quickly and as thoroughly as possibleT Mart has demonstrated committment beyond the norm throughout the project, but the project is now suffering from a very common ailment - the last 10% of the project consuming 90% of the frustration and effortT Your performance in the next two weeks will, I predict, have a great deal to do with your chances of recovering all or some port$on of the Liquidated Damages~ I would be happy to elaborate on any part of these recommendations and will work overtime to assist in wrapping the project up quickly for everyone's benefitT Yours faithfully, David ~= Dillard, President cccw/letter Chief Jackie Mayfield, Coppell Fire Department Mr: Ed Powell, City Engineer Mr: Wayne Ginn, Ginn, Inc~ encl~, MART, INC. GENERAL CONTRACTORS P. O. BOX 150983 · 1503 PERRY F~D · IRVING, TEXAS 75015 · (214) 721-1522 May 28, 1986 Dillard Architects, Inc. 4310 Westside Drive, Suite C Dallas, Texas 75209 Attn: Mr. David A. Dillard RE: Coppell Fire Station #2 Dear David: David, pursuant to our conversation, please accept this letter as our respectful request to waive the liquidated damages on the above referenced project. As we discussed, the reason for liquidated damages is to prevent the General Contractor from injuring the owner through an untimely completion of the project. David, we did not complete the project in the time allowed by the contract and subsequent time extensions, but we were delayed by many reasons that were totally out of our control and as a result suffered substantial financial loss. Partly as a result of the general finanoial climate of the construction industry as a whole, several of our subcontractors and suppliers went out of business and in one case moved out of state. This alone greatly inhibited us from completing the project. David, as we have indicated by this letter, w~ agree that the project was not completed as required, bat w~ do not feel that we have injured the City of Coppell in any way° We again respectfully ask that you consider this request and in all fairness grant a waiver to the liquidated damages so that we can complete the accounting with you on this project. We trust you will find this in order, but should you have any questiDns please do not hesitate to call. Re ~pect fully, Pre side VRP:rb