John Bell Construction

CHASE-PRELIMINARY REPORT —WHAA v. John Bell Construction

“Based on these Report findings, elaborated through discussions, exhibits, and other information contained
herein, my professional opinions regarding the John Bell Construction’s Due Care is as follows: It is my considered opinion that John Bell Construction. Inc. was negligent and failed in its
Standard Duty of Care and Contractual obligations by (A) preparing a Flawed, Self-Serving
Construction Agreement, (B) Under Pricing the Project, (C) Breaching the Village of Pinecrest
Chapter 30, Article 6-Div. 6.12-Excavation and Fill Ordinance and (D) causing a Stop Work
Order on May 6, 2020, permanently closing down the Project.”

Expert David Erik Chase, AIA