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DRC Emergency Services- Form 8FORM 8 CONTINUED DRC EMERGENCY SERVICES, LLC FIVE YEAR LITIGATION (Updated and Revised: May 16, 2018) The following is a list of all litigation involving DRC Emergency Services, LLC (“DRCES”) related to emergency disaster recovery and management services pending or resolved in a five year period commencing May 16, 2013 and ending May 16, 2018. ALABAMA 1.Fuzzell v. DRC Emergency Services, LLC, No. 14-904190, Jefferson County Cir. Ct., AL. Claim by Stewart G. Fuzzell for breach of an alleged verbal employment agreement which included a purported verbal revenue share. Plaintiff claimed $26 million. Matter settled and dismissed on April 19, 2016. 2.Cahaba Disaster Recovery, LLC v. DRC Emergency Services, LLC, Civil Action No. 01-CV-2015-903953, Circuit Court, Jefferson County, Alabama removed to U.S. Dist. Court for the Northern Dist. Of Alabama, Case No. 15-2096. Payment claim for $2,477,680.29 by plaintiff for work allegedly performed on a Joplin, MO tornado debris removal project. Matter settled and dismissed on April 22, 2016. 3. DRC Emergency Services, LLC and Liberty Mutual Insurance Company v. R. Baker, Inc., Civil Action No. 14- 2281, United States District Court for the Northern District of Alabama, Birmingham Division. Declaratory action filed by DRCES and its surety against a sub-subcontractor regarding non-liability for lower tier sub- subcontractor claims. Franklin County and Town of Phil Campbell tornado recovery projects. Matter settled and was dismissed on February 12, 2016. 4. B&B Environmental Services, et al v. DRC Emergency Services, LLC, et al, Mobile County, Alabama Circuit Court, Case No. 14-903439. Unquantified suit by lower tier sub-subcontractors for payment claiming existence a partnership/joint venture between DRCES and its former subcontractor. Multiple disaster recovery projects. Matter settled and dismissed on March 21, 2016. 5. Weston v. DRC Emergency Services, LLC, et al, Civil Action No. 13-900067, Marshall County, Alabama Circuit Court. Unquantified personal injury/wrongful death claim. Decedent was an employee of a lower-tier subcontractor. OSHA investigated and issued no citation. Alabama Dept. of Conservation tornado recovery project. All claims against DRCES were dismissed (no liability) on January 12, 2015. 6. Luc Raymond v. DRC Emergency Services, LLC, Case No. 2012-CV-901342, Mobile County, Alabama Circuit Court. Lawsuit for earthquake related work performed in Haiti. Case Settled for $175,000 and dismissed July 24, 2014. 7. Group CG Builders v. DRC Emergency Services, LLC, et al, United States District Court for the Southern District of Alabama, Case No. 11-729, on appeal to the U.S. 11th Circuit Court of Appeals, Case No. 12-14586. $900,000 claim by sub-subcontractor for disaster recovery work performed in Haiti. Suit in United States against DRCES dismissed by district court; dismissal affirmed on appeal August 12, 2013. Suit in Dominican Republic pending. 8. Black Warrior Solid Waste Authority v. DRC Emergency Services, LLC, Tuscaloosa County, Alabama Circuit Court, Case No. 2013-900472. $30,000 collection dispute involving disposal fees on Tuscaloosa tornado recovery project. Case settled and dismissed on August 15, 2013. 9. Acton Plumbing & Heating Co., Inc. v. DRC Emergency Services, LLC, Case No. 2014-904235, Jefferson County, Alabama Circuit Court. Claim by lower-tier sub-subcontractor for Birmingham tornado recovery work. Case settled for $17,896.29 and dismissed on November 12, 2014. 113 9A. International Camp Sales & Service v. DRC Emergency Services, LLC, et. al., Circuit Court of Mobile County, AL, Case No. 09-902111. Dispute over an alleged commission agreement for sale of equipment. Lawsuit removed to United States District Court for the Southern District of Alabama, Case No. 09-775, then remanded to state court. Matter stayed pending arbitration. Arbitration ruling against DRC final. DRC satisfied and paid claimant. Lawsuit dismissed August 22, 2014. FLORIDA 10. DRC Emergency Services, LLC v. Ashbritt, Inc., United States District Court for the Southern District of Florida, Civil Action No. 14-62924. $50,000,000 business disparagement claim by DRC. Matter voluntarily dismissed on September 16, 2015. KENTUCKY 11. Bellsouth Telecommunications, Inc. v. DRC Emergency Services, LLC, Case No. 11-37, Hickman County Circuit Court, Kentucky. Minor property damage claim to utility pole. Case settled and dismissed on February 20, 2014. LOUISIANA 12. Fin & Feather v. Plaquemines Parish, Cahaba Disaster Recovery, All South Consulting Engineers and DRC Emergency Services, LLC, Civil Action No. 56-844, 25th Judicial District Court, Plaquemines Parish, Louisiana. Unquantified claim for damage to a pier and boat-house. DRCES and Cahaba’s motion for summary judgment based on the Hurricanes Katrina and Rita Immunity Statute was granted on October 29, 2015; affirmed on appeal. 13. Cora Williams v. DRC Emergency Services, LLC, Beck & City of New Orleans, Civil Action No. 2009-4151, Orleans Parish Civil District Court. Unquantified property damage claim in connection with New Orleans demolition project. DRCES insurer defending. Case settled and dismissed on appeal. 14. Gulf State Construction v. DRC Emergency Services, LLC, Civil Action No. 2012-10783, Orleans Parish Civil District Court. Pro se lawsuit by a subcontractor seeking $180,000 payment for site work and demolition work on the Orleans Parish Sheriff’s Office construction project. DRCES disputes plaintiff’s claims on several procedural and substantive grounds: (1) Gulf States had no Louisiana contractor’s license and, therefore, the subcontract is unenforceable as a matter of law; (2) Gulf States performed only minimal site work for which it was paid; (3) Gulf States was paid for mobilization but only mobilized three pieces of equipment to the job site and, therefore, could not execute the site work. No action has been taken in this matter for over four years. 15. McGraw v DRC Emergency Services, LLC, Case No. 2009-51580, First City Court of New Orleans. Property damage claim during a New Orleans demolition project. Plaintiff sued DRCES and lower-tier subcontractor. Matter was dismissed on May 29, 2015. 16. Down South Services, LLC v. DRC Emergency Services, LLC, Case No. 59-035, 25th Judicial District Court for Plaquemines Parish, Louisiana. Claim by equipment supplier in connection with the BP oil spill project. DRCES disputed plaintiff’s claim and tendered 68% of plaintiff’s demand pending further backup detail from plaintiff. No backup detail was provided. The lawsuit is open but plaintiff has abandoned the claim under Louisiana law having taken no step in the litigation since 2011. 17. American Amphibious Equipment and Rental, Inc. v. Brookhaven Maintenance South Contract Corp., et al, Case No. 55-252, 25th Judicial District Court for Plaquemines Parish, Louisiana. Collection claim by an equipment supplier to a lower-tier subcontractor on the Hurricane Katrina project. On April 13, 2009, one of the lower-tier subcontractors 114 filed for Chapter 11 bankruptcy relief (USDC SD Miss. Case No. 09-50745) and the instant lawsuit was stayed. The Chapter 11 reorganization proceeding was converted to a Chapter 7 liquidation on July 23, 2009. The plaintiff in the instant case did not seek to lift the bankruptcy stay and did not otherwise take any steps in the instant litigation since 2009. The instant matter, therefore, has been abandoned under Louisiana law. 18. Hatcher v. DRC Emergency Services, LLC, et al, Case No. 09-7695, Civil District Court of Orleans Parish, Louisiana. Property damage claim for striking a fence attached to an abandoned home. Hurricane Katrina demolition project. Case settled for nuisance value and dismissed on February 6, 2014. 19. Lincoln v. Plaquemines Parish, et al, Case No. 57-205, 25th Judicial District Court, Plaquemines Parish, Louisiana. Unquantified property damage claim arising out of the Hurricane Katrina canal debris removal project. Case settled and dismissed on April 30, 2013 (main demand) and July 23, 2013 (third party demand and cross claims). 20. B&S Equipment v. DRC Emergency Services, LLC, et al, Case No. 708-443, 24th Judicial District Court for Jefferson Parish, Louisiana. Lawsuit removed to United States District Court for Eastern District of Louisiana, Case No. 11-3144, then remanded to state court. Claim by lower-tier sub-subcontractor for unpaid work. Hurricane Katrina project. Case settled for $175,000 on July 3, 2014. 21. Harbor Community Church v. Cahaba Disaster Recovery, LLC, et al, Case No. 2013-10113, Orleans Parish, Louisiana Civil District Court. Property damage claim: Hurricane Ike recovery project. Case settled for $10,000 and dismissed on June 23, 2014. 22. DRC Emergency Services, LLC v. Welborn, Clerk of Court, et al No. C658294, 19th JDC, East Baton Rouge Parish. Suit to cancel improperly recorded lien. Defendant voluntarily released its lien. 23. Ultra Lane, Ltd. v. DRC, et al, No. 17-430, USDC MDLA Suit by Ultra Lane, lower-tier sub-subcontractor for payment. DRC dismissed from litigation. 24. Baker v. DRC, No. USDC WDLA. Collection lawsuit. DRC disputed the claim. Matter settled for $125,000 and dismissed September 26, 2017. 25. Infinity Trucking v. Cahaba Disaster Recovery, et al, USDC EDLA, Case 18-1700. $94,000 claim by lower tier subcontractor on a demolition project. Claim is disputed by DRC based on no contract privity. MISSISSIPPI 26. DRC Emergency Services, LLC v. City of Louisville, Mississippi, Case No. 2014-087-CVM, Circuit of Winston County, Mississippi. Disaster debris removal contract award protest by DRCES. Dismissed February 26, 2015. MISSOURI 27. Environmental Works, Inc. v DRC Emergency Services, LLC, Circuit Court, Greene Co., MO, Case No. 1331- CC00237. Suit for breach of contract for work in Joplin, MO regarding air monitoring services. USACE Joplin tornado recovery project. Case settled for $135,000 and dismissed on June 10, 2014. 115 28. Hershewe v. DRC Emer. Services, LLC, Case N0. 17-181, Jasper County, MO. Suit for an accounting and claim for payment by an attorney arising out of the Joplin, MO tornado project. NORTH CAROLINA 29. Caroline-A-Contracting v. DRC, Inc. d/b/a DRC Group DRC Emergency Services, LLC and Ray Peele, Case No. 12- CvD-0394. Claim by lower-tier subcontractor for non-payment. Birmingham tornado recovery project. Case settled for $27,000 and dismissed on December 16, 2014. TEXAS 30. Wells v DRC Emergency Services, LLC, Case No. JC-134-11, Small Claims Chambers, Texas. Suit for alleged minor damage to land. Hurricane Ike, Chambers County recovery project. Case settled for $4,750 on August 6, 2013. 34. Mustang Rentals v. DRC Emergency Services, LLC, et al, District Court, Harris, Texas, Case No. 2013-22617. Claim for rental fees owed by subcontractor. Case settled for $25,000 and dismissed on June 11, 2013. 31. Contreras v. Terrence, et al, No. 18-3519, 134th Dist. Court, Dallas County, TX. Claim by a fourth tier subcontractor for payment. The lawsuit states damages are between $50,000 and $200,000. 32. Allstate Indemnity Co. v. DRC Emergency Services, LLC, Case No. 184100222525, Justice Court, Harris County, TX. Auto accident case. Settled for $2500 by payment from lower tier subcontractor. BP OIL SPILL RELATED LITIGATION 33. The lawsuits set forth in Sub-paragraphs 33(a)-(ll) below arise out of the BP oil spill clean-up/recovery project. The lawsuits relate to general economic loss claims, personal injury tort-based claims, contract-based charter-hire payment claims and purported discrimination claims. Pursuant to the BP-DRCES Master Subcontract Agreement, BP is obligated and has defended and indemnified DRCES. a. In Re: Oil Spill By The Oil Rig "Deepwater Horizon" In The Gulf of Mexico, United States District Court for the Eastern District of Louisiana, Civil Action No. MDL 2179. This is the lead case in the BP Multi-District Litigation. With the exception of a few state court cases, all cases below have been consolidated into the lead MDL case. Pursuant to the District Court’s February 2016 ruling, many personal injury claims below have been dismissed; however, out of an abundance of caution, these cases remain listed until a formal dismissal order is issued. By court order, all non-personal injury cases consolidated in the MDL are stayed and unserved on the defendants until further notice by the District Court. b. Caulfield v. DRC Emergency Services, LLC, et al., United States District Court for the Eastern District of Louisiana, Civil Action No. 11-1891. c. Black v. DRC Emergency Services, LLC, et al, United States District Court for the Eastern District of Louisiana, Civil Action No. l 1-867. Dismissed. d. Pearson v. DRC Emergency Services, LLC, et al, United States District Court for the Eastern District of Louisiana, Civil Action No. 11-863. e. Lambert v. DRC Emergency Services, LLC, et al, 24th Judicial District Court for Jefferson Parish Louisiana, Civil Action No. 702311. f. Baudier v. DRC Emergency Services, LLC, et al., 24th Judicial District Court for Jefferson Parish Louisiana, Civil Action No. 703-286. 116 g. Turner v. DRC Emergency Services, LLC, et al, Case No.52826, Harris County, Texas Circuit Court, removed to USDC EDTX, Civil Action No. 12-64, remanded. Settled and dismissed on February 10, 2015. h. McCormick v. DRC Emergency Services, LLC, 11-2141 Civil Action No. 11-2141. Settled and dismissed on March 18, 2013. i. Turlich v. DRC Emergency Services, LLC, et al., 25th Judicial District Court for Plaquemines Parish Louisiana, Civil Action No. 59-076. j. Luke Boudreaux v. The DRC Group, et al, United States District Court for the Eastern District of Louisiana, Civil Action No. 11-03179. k. Fitzgerald v. DRC Emergency Services, LLC, et al, United States District Court for the Eastern District of Louisiana, Civil Action No. 13-650. 1. Matherne Business Associates v. DRC Emergency Services, LLC, United States District Court for the Eastern District of Louisiana, Civil Action No. 11-449. m. Rodrigue Business Associates v. DRC Emergency Services, LLC, United States District Court for the Eastern District of Louisiana, Civil Action No. 11-445. n. Pearson and Black v. DRC Emergency Services, LLC, 24th Judicial District Court for Jefferson Parish Louisiana, removed to USDC EDLA, Civil Action No. 11-778. o. Chad Rogers v. DRC Emergency Services, LLC, et al., 19th Judicial District Court for East Baton Rouge Parish Louisiana, Civil Action No. 601084 removed to USDC MDLA Civil Action No. 11-331, transferred to USDC EDLA Civil Action No. 11-1295. p. Frelich v. DRC Emergency Services, LLC, et al., 25th Judicial District Court for Plaquemines Parish Louisiana, Civil Action No. 59-616. q. Foussell, et al, v. DRC Emergency Services, LLC, et al, United States District Court for the Eastern District of Louisiana, Civil Action No. 11-1195. r. Trung v. Emergency Services, LLC, United States District Court for the Eastern District of Louisiana, Civil Action No. 11-2766. s. Daigle v. DRC Emergency Services, LLC, United States District Court for the Eastern District of Louisiana, Civil Action No. 11-2499. t. Duong, et al v. Emergency Services, LLC, United States District Court for the Eastern District of Louisiana, Civil Action No. 12-814. (DRCES tendered to BP for defense/indemnity; awaiting response). u. Duong, et al v. DRC Emergency Services, LLC, United States District Court for the Eastern District of Louisiana, Civil Action No. 13-605. v. Dinwiddie v. DRC Emergency Services, LLC, United States District Court for the Eastern District of Louisiana, Civil Action No. 12-426. (DRCES tendered to BP for defense/indemnity; awaiting response). w. Brown v. DRC Emergency Services, LLC, United States District Court for the Eastern District of Louisiana, Civil Action No. 12-2333. (DRCES tendered to BP for defense/indemnity; awaiting response). x. Elmer Rogers v. DRC Emergency Services, LLC, Orleans Parish Civil District Court, Civil Action No. 14-8304, Div. "J" removed to USCD EDLA Civil Action No. 14-2285 (DRCES tendered to BP for defense/indemnity; awaiting response). y. Gros, et al v. DRC Emergency Services, LLC, et al, United States District Court for the Eastern District of Louisiana, Civil Action No. 11-1824. Wage claim. Settled and dismissed March 21, 2013. Related matter DRC 117 Emergency Services, LLC, et al v. BP Exploration & Production, Inc., et al, United States District Court for the Eastern District of Louisiana, Civil Action No. 12-2510. Settled and was dismissed on March 7, 2014. z. Hayden v. Mitchell Liftboats, LLC v. DRC Emergency Services, LLC, et al, 25th Judicial District Court, Plaquemines Parish, Louisiana, Civil Action No. 60-624. Lawsuit removed to U.S. Dist. Court for Eastern District of Louisiana, Case No. 13-5234 and consolidated with MDL 2179. Case settled and dismissed on December 5, 2014. aa. Hayden v. A.M.C. Liftboats, Inc. v. DRC Emergency Services, LLC, et al, 25th Judicial District Court, Plaquemines Parish, Louisiana, Civil Action No. 60-624. Lawsuit removed to U.S. Dist. Court for Eastern District of Louisiana, Case No. 13-5235 and consolidated with MDL 2179. Case settled and dismissed on December 5, 2014. bb. In re Triton Asset Leasing GmbH, U.S. Dist. Court for Eastern District of Louisiana, Case No. 10-2771. Statutory limitation of liability proceeding invoked by a vessel owner which was consolidated with MDL 2179. cc. Alexander v. DRC Emergency Services, LLC, et al, United States District Court for the Eastern District of Louisiana, Civil Action No. 11-951. DRCES is named as a defendant but was never served with legal process. Lawsuit was consolidated in MDL 2179. dd. Strike Zone Charters v. BP, United States District Court for the Eastern District of Louisiana, Civil Action No. 16-5960. ee. Reefkeeper, LLC v. BP, United States District Court for the Eastern District of Louisiana, Civil Action No. 16- 5955. ff. Terry v. BP, United States District Court for the Eastern District of Louisiana, Civil Action No. 16-4137. gg. Lim v. BP, United States District Court for the Eastern District of Louisiana, Civil Action No. 16-3950. hh. Duong v. BP, United States District Court for the Eastern District of Louisiana, Civil Action No. 16-3953. ii. Ly v. BP, United States District Court for the Eastern District of Louisiana, Civil Action No. 16-3957. jj. Ly v. BP, United States District Court for the Eastern District of Louisiana, Civil Action No. 16-4027. kk. Nguyen v. BP, United States District Court for the Eastern District of Louisiana, Civil Action No. 16-3952. ll. . Nguyen v. BP, United States District Court for the Eastern District of Louisiana, Civil Action No. 16-3955. DOMINICAN REPUBLIC 34. Group CG Builders v. DRC Emergency Services, LLC, et al. Suit by sub-subcontractor for disaster recovery work performed in Haiti. Suit in the United States against DRCES dismissed by federal district court; dismissal affirmed on appeal August 12, 2013. Suit in Dominican Republic pending but inactive for over three years. REGULATORY 35. DRC Emergency Services, LLC was suspended by the U.S. Air Force in September 2014 for 22 business days relating to a project in Joplin, Missouri that occurred over five years ago when the company was operated under previous ownership. Following a detailed response at the direction of DRC’s new ownership and management, the suspension was lifted. None of the individuals that were named in the suspension are currently employed by DRC Emergency Services, LLC. Moreover, the company implemented a robust corporate responsibility, compliance, safety and ethics 118 program at all employment levels. DRC Emergency Services, LLC currently operates in good standing with all branches of Government. 36. On September 12, 2014, the Louisiana Department of Natural Resources, Office of Coastal Management issued a Compliance Order to DRC Emergency Services, LLC for the temporary damage to marsh grass (e.g. tracks in marsh grass caused by marsh buggy and work staging) and ordering a contribution of $144,058.00 to the State’s Coastal Mitigation Account. The Consent Order expressly acknowledged that the habitat area had been naturally restored. The Compliance Order was appealed and the parties subsequently settled the matter which included a non-admission of liability by DRC Emergency Services, LLC. The matter was dismissed on October 5, 2015. 37. By Consent Order dated March 9, 2015, the South Carolina Department of Health and Environmental Control assessed a $10,000 civil penalty against DRC Emergency Services, LLC for burning vegetative debris within 1000 feet from a public roadway. The incident was self-reported by DRC Emergency Services, LLC. 119