ST9601-CS 991119 PAVING COMPANY
419 East Highway 80 P.O. Box 270040 Dallas, Texas 75227-0040 Tel 214-289-0723 Fax 214-216-5637
Friday, November 19, 1999
City of Coppell
Via Hand Deliver
Attn: Larry Davis
Re: Wrangler Drive
Tiseo Paving Company is contesting any liquidated damages being charged against the
above referenced project. This project had a start date of June 8th, 1998 and an ending
date of April 14th, 1999; however due to utility conflicts, change orders, extra work and
an unusual amount of rain this project was completed July 19th, 1999. This is an overrun
of 96 days from the original contract. Please find listed below the specific reasons that
we feel the original end date of April 14th, 1999, is no longer valid:
1. The City of Coppell issued Change Order No. 1. Tiseo Paving Company requested
an additional 9 days be added to our contract to complete this work.
2. In a letter dated July 16th, 1998, Tiseo Paving Company requested an additional 7
days to perform extra work requested (storm sewer).
3. The normal allocated time for rain and holidays is 54 days; however work was
delayed on this project due to rain and holidays 104 days. (See attached list.)
4. Tiseo Paving Company encountered utility conflicts with both TU Electric and TU
Services (formerly Lone Star Gas) in October of 1998. Various meetings were held
with the City of Coppell regarding this matter, but it was not resolved until January.
The utility companies failure to complete their work as committed caused a delay of
approximately 90 days.
Tiseo Paving Company encountered numerous delays beyond its control on the Wrangler
Drive project. There were a total of 156 days in which Tiseo Paving Company was
unable to work or was performing extra work for the City of Coppell. We believe we did
everything in our power to complete this project in a timely manner. This is apparent
when you note that we believe that 156 days should be added to our contract time and we
completed this job only 96 days over the original contract time. Taking in account the
information above Tiseo Paving Company should not be charged any liquidated damages.
Should you have any questions regarding this matter, please feel flee to contact me.
Sincerely,
Robert Caudill
Project Admn.
RAIN DAYS
September 98 (Normal Allocated Time 4 Days)
Sept. 12, 13,14, 15,16, 17, (too wet), 19 and 20 (too wet)
October 98 (N.A.T. 4 days)
Oct. 2, 5, 6 (too wet), 16, 17, 18 (too wet), 19, 20, 21 and 22 (too wet)
November 98 (N.A.T. 4 Days)
Nov. 2, 3, 7, 8, 9, 10, 11 (too wet), 12, 13, 14,15 (too wet), 16, 20, and 21 (too wet) and
Nov. 25 (Holiday)
December 98 (N.A.T. 5 Days)
Dec. 3, 4, 5, (too wet), 6, 7, 8 (too wet), 9, 10,11, 12 (too wet), 18, 19, 20, 21, 22 (too
wet/cold), 23 (frozen rail), 24 (too wet/cold), 25 (holiday), 26 (too wet/cold), and Dec. 31
(Holiday)
January 99 (N.A.T. 7 Days)
Jan. 1 (Holiday), 4 (too cold) and 31.
February 99 (N.A.T. 8 Days)
Feb. 1 (too wet) and 2 (too wet)
March 99 (N.A.T. 6 Days)
March 8, 9, 10, 11, 12, 13 (too wet), 18, 19, 20 (too wet), 27, 28, 29, 30, and 31 (too wet)
April 99 (N.A.T. 6 Days)
Apr. 1, 2, 3, 4, 5, 6, 7, 8, 9 (too wet), 26 and 27 (too wet)
May 99 (N.A.T. 6 Days)
May 1, 2, 3, 4, 5 (too wet), 17, 18 (too wet), 23, 24 (too wet), 25, 26, 27, and 28 (too wet)
June 99 (N.A.T. 4 Days)
June 10, 11 (too wet), 21, 22, 23, 24, 25, and 26 (too wet)
Normal Allocated Time is: 54 Days
Rain Days/Holidays is: 104 Days
TISEO PAVING CO__MPANY
PO Box 270040 Dallas, Texas 75227-0040
M~'~thly Subconiracfor EMimate
Project Name: WRANGLER DRIVE Tiseo Job No.: 234~
~ubcontmctor: AMERICAN LANDSCAPE SY~TEM'S
Estimate No.: ~5 Contract Amount: $ 8,000.00
Est Period - From: 07/0~/99 to 07/3~/99 Percent Complete: ~0.00%
Item Description Unit Qty. Price Contract $ Previous Current Total Done, $ Amount
1 SPRINK1,ER REPAIR LS 1.00 8,000.00 8,000.00 1.00 1.00 8,000.00
2 SPRINKLER REPAIR LS 1.00 96.00 96.00 1.00 1.00 96.00
3 ISPRINKLER REPAIR LS 1.00 10,500.00 10,500,00 1.00 1.00 10,500.00
4 SPRINKLER REPAIR LS 1.00 300.00 300,00 1.00 1,00 300.00
APPROVED: AMERICAN LANDSCAPE SYSTEM'S TOTAL AMOUNT OF WORK COMPLETED $ 18,896.00
Retainage 0%
AMOUNT PAYABLE ON CONTRACT 18,896.00
LESS:
APPROVED: TISEO PAVING COMPANY - DALLAS, TEXAS Paymertls 18,896.00
date: DUE THIS ESTIMATE $
8/19/99 10:48 AM 2341.xis A. LS,