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Freeport AALC Force Majeure Attorney Letter 0727211 Jamie Brierton From:Jacob Masters <jmasters@njh-law.com> Sent:Tuesday, July 27, 2021 3:36 PM To:'John.Nicholson@strlco.com'; 'Joe.Soto@strlco.com'; 'greg.attrep@strlco.com'; Marcus Marion; Darryl Zbranek; Jamie Brierton; FreeportProjectST1501; 'Jim.Thull@strlco.com' Cc:Tony Jach Subject:RE: AALC Pass through claims to The City of Coppell Good afternoon, Further to Travis’s email below, we are counsel for AALC in connection with this matter. Be advised AALC disagrees with the City’s decisions denying AALC’s request for payment for the change order work and materials in connection with the winter storm and with respect to liquidated damages being unjustifiably assessed against AALC. As you aware, in the event AALC disagrees with an owner decision regarding the price for extra work, Article 6(a) of AALC’s Subcontract allows AALC to present, “a request for equitable adjustment or sponsored claim consistent with the General Contract and Subcontract Agreement.” Since attempts to reach an equitable resolution of AALC’s claims have failed, please be advised AALC intends to escalate this matter as contemplated in the Subcontract. In that regard, AALC will be pursuing legal action directly against the City and against Texas Sterling. Be further advised we will be seeking to recover not only the principal amount owed but will also be seeking to recover all attorneys’ fees, costs, and interest allowed by Texas law. Demand for full payment to AALC for its claim, including the change order work and all other amounts due under the Subcontract, is hereby re-iterated. Should you have any questions or wish to discuss this matter, please contact me to discuss. Otherwise, we will be proceeding with our claims against the City and Texas Sterling as referenced above. Thank you, Jacob Masters Nixon Jach Hubbard, PLLC JPMorgan International Plaza III 14241 Dallas Parkway, Suite 575 Dallas, Texas 75254 Telephone: 972-503-7000 Direct Line: 972-503-7007 Facsimile: 972-503-7001 jmasters@njh-law.com CONFIDENTIALITY NOTICE: The information contained in this email message may be confidential and/or legally privileged. This email message is intended to be reviewed by only the individual(s) recipient(s) named herein. If the reader of this email message is not the intended recipient, such reader is hereby notified that any review, dissemination, or copying of this email message or the information contained herein is prohibited. The transmittal and/or subsequent dissemination of this email message shall not be deemed to waive any attorney- client privilege which may exist with the intended recipient(s). If the reader of this email message has received 2 it in error, the reader should immediately notify the sender by email or by telephone, delete from their system the original email message and return this email message to the sender. From: travis@aalctx.com Date: July 22, 2021 at 3:01:00 PM CDT To: Jim Thull <Jim.Thull@strlco.com> Cc: John Nicholson <John.Nicholson@strlco.com>, Joe Soto <Joe.Soto@strlco.com>, Greg Attrep <greg.attrep@strlco.com>, Tony Jach <tjach@njh-law.com>, mmarion@coppelltx.gov, dzbranek@coppelltx.gov, Jamie Brierton <JBrierton@coppelltx.gov>, freeportprojectst1501@coppelltx.gov Subject: RE: AALC Pass through claims to The City of Coppell Jim, This is outlandish and we don’t accept this decision. I have full intent on pursuing these claims. $134,000 is just way too big of a hit for our small company to take. Especially when we have bent over backwards to finish up this job and deliver a project the city is happy with. I cant help but think that Texas Sterling has upset the City of Coppell throughout this project as I have NEVER seen this stance taken from the city in my 20+ year relationship with them. Passing these fees along to AALC is unfair. My council will be in touch very soon. Thanks! Travis Baird │ President O: 214.421.7663 │ M: 817.937.8323 617 N Cowan Ave., Lewisville, TX 75057 www.aalctx.com From: Jim Thull <Jim.Thull@strlco.com> Sent: Tuesday, July 20, 2021 4:49 PM To: travis@aalctx.com Cc: John Nicholson <John.Nicholson@strlco.com>; Joe Soto <Joe.Soto@strlco.com>; Greg Attrep <greg.attrep@strlco.com>; Tony Jach <tjach@njh-law.com> Subject: AALC Pass through claims to The City of Coppell Travis Unfortunately, The City of Coppell has rejected both of AALC’s appeals. See attached emails from The City to Joe Soto. 3 Let me know if you have any questions. Jim Texas Sterling Construction Co. James E. Thull | Commercial Director | | 1441 Airport Freeway, Suite 350 | Euless, Texas 76040 | | Main: 682.292.9150 | Cell: 832-367-4167 | Jim.Thull@strlco.com