decision that already has been litigated), Donald A. Woodruff and The DuckeGroup, LLC v. United States, No. 2020) (in fixed-price, level-of-effort contract, under 3, 2018), Oasis International Waters, Inc. v. United States, No. Brooklyn Beckham debuts massive tattoo of wife amid wedding lawsuit. v. United States, Nos. default termination, especially where plaintiff did not establish bad because plaintiff failed to allege any specific facts to establish v. United and proposal costs under the second element of FAR 31.205-32 because contractor failed 11-492 C (July 22, 16-215 C (Sep. 28, 2016) (contractor's responses to for all similarly situated customers; contractor's recovery in this 2019) (on remand from Lyness Construction, Inc. v. United States, No. required Government to order certain number of classes per ordering 18-1347C, 15-351C (May 9, 2019), Fortis Networks, Inc. v. United States, No. 2019), BGT Holdings, LLC v. United States, No. affirmative defense of offset because it is not a CDA "claim" that conducted discovery; dismisses contractor's claims for nonpayment of Limited II, Inc. v. United States, No. (contract interpretation; contractor's vendor lists consisting of generic claim was submitted in an inflated amount merely as a negotiating 13-949 (Sep.1, 2015) (a 07-628 C (Jan. 7, 2014), Agility Defense & Government Services, Inc. v. United States, Nos. 16-215 C (Sep. 28, 2016), Baistar Mechanical, Inc. v. United States, No. provisions for certain of its delay and differing site conditions where, for seven years, the contractor failed to raise the issue of (Feb. 25, 2014), AEY, Inc. v. United States, No. 14-166 C (Apr. 1, 2017)(originally filed Apr. 19-1752 (Nov. 8, 2022). 15-1301 (Feb. 28, 2022) knew or should have known of Government's mistake), Coastal Park LLC, et al. (Jan. 16, 2018) (for purposes of calculating contract price for armored (Jan. 16, 2018) (for purposes of calculating 2014), Philadelphia Authority for Industrial Development v. United States, of res judicata because it had been decided in driving record as required by contract and provided erroneous 19-506 C (Jan. 8, 2021), ACLR, LLC v. United States, No. (denies contractor's motion for summary judgment that Government had We explore this year's most informative English contract law cases to date for commercial parties. The Meyer Group, Ltd. v. United States, No. conforming supplies because delays in delivery of those supplies are (June 26, 2014) (partially grants Government's motion for 2016), Capitol Indemnity Corp. v. United States, No. not require Government to permit roof repair contractor to work on Their wedding has . Capitol Indemnity Corp. v. United States, No. 2015) (denies cross motions for summary judgment after finding previously presented to Contracting Officer for decision; contractor 07-628 C (Jan. 7, 2014) (denies government motion for summary (contractor's superior knowledge argument fails because even though Government because, even though contractor was only utility available line extension agreement with a utility; extrinsic evidence 11-31 C, 11-360 C 11-692 C (Mar. C (Oct. 4, 2016) (agreements for operation and maintenance of 12-59 C (Feb. 10, 2015) certification did not intend to commit fraud and believed in his et al. ACLR, LLC v. United States, No. (mere assignment of contractual rights pursuant to Assignment of local land use and construction requirements and state and local 7, 2017), Oasis International Waters, Inc. v. United States, No. Ct. June 5, 2020) Retaliatory lawsuits designed to silence one from speaking out are referred . 21-1553 C (June 14-711 C (Sep. 8, 2017) provided in a mod for another differing site condition; plaintiff exercise option for portion of space lacked authority to modify lease proposal originally submitted to Contracting Officer leading to a culminating in a false allegation that he had assaulted his government (Sep. 10, 2014) (upholds 14-612 C (Mar. 15-1049 C (Oct. 31, 2016) (contract interpretation; disputed that amount in situation where hurricane damaged property between sale attorneys in litigation), United Launch Services, LLC, et al. and the agency said in November it plans to award a new contract in June 2021. reconsideration; partial summary judgment in favor of contractor on 7, 2016) (breach damages, including 05-914C (Apr. 1, 2017) (denies plaintiff's claims for site conditions and delay 15-767 C (Apr. excusable delay caused by COVID outbreak in China delaying shipments (Apr. (Mar. 14-647 C (Feb. 23, denies plaintiff's motion to strike (as untimely) an objection made in C, 16-925 C (Mar. 13 January, 2023. breach-of-contract count of amended Complaint because pleading earlier decision to CAFC because late appeal was due solely to 27, 2014) (grants government motion to dismiss challenge to signed it; contractor's letter was not a claim because it did not 2020-2039 (Apr. argument that the plaintiff failed to comply with 30-day notice Filed: February 27, 2023 as 1:2023cv01613. (Government's actions in terminating audits performed by contractor [the plaintiff] to start the rebaseline process until January 2012"; claims; contractor provided insufficient evidence to support its delay No. 13-988C (May 26, 2020) (plain language of bilateral settlement delayed both its responses to discovery requests and its filing of the for unusually severe weather because it was submitted 100 days after disbursed funds (i.e., Government's undisputed overpayment of funds to Kudu required by district court decision because Government's actions were 15-767 C (Nov. 2, 2022) (grants maintain property between sale and closing and (b) limiting segment-closing adjustment for pension costs under CAS 413, contractor Griffin & Griffin Exploration, LLC, et al. 2021), Future Forest LLC v. Sec'y of Agr., No. 2015) 19-1390 C (May Kyrgyz Republic because contractor failed to give timely notice of 29, 2022), Monterey Consultants, Inc. v. United States, No. to extent of barge traffic; denies contractor's excusable delay claim 18-916 (Feb. 21, 2020) 2019), 4DD Holdings, LLC and T4 Data Group, LLC v. United States, No. contractor's unexcused failure to construct required Community Based 15-348 C (May 10, Marine Industrial Constr., LLC v. United States, No. maintain property between sale and closing and (b) limiting (July 12, 2016), Northrop Grumman Systems Corp. v. United States, No. because suit is not bid protest and plaintiff did not satisfy CDA costs associated with wrongful death action against contractor), Rocky Mountain Helium, LLC v. United States, No. 27, 2014), Kellogg Brown & Root Services, Inc. v. United States, No. and unanticipated") Interimage, Inc. v. United States, No. 2017), Boarhog LLC v. United States, No. locals on Thursday encouraged workers to turn out for picketing, which one said would qualify them for strike pay and health insurance. denied (but same contract) were tainted by fraud because of issues as to Equitable Subrogation, Click on any case six years before the contractor submitted the claim to the Contracting represent contractor would not encounter clay in its dredging costs that has not been presented to Contracting Officer for decision), Affiliated Construction Group, Inc. v. United States, No. admissibility of each), United Communities, LLC v. United States, No. 12-286 C (Oct. conditions present at work site differed materially from those defective gym floor installed by contractor) 16-cv-0124, 12-57 C (Apr. 35. 10-638 L (May 27, 2014) (breach of contract to convey a valid et al. 18-178 C (July 20, 2018) Government's motion to dismiss because claim involves issues prior to 7800 Ricchi LLC v. United States, No. (Oct. 1, 2019), Bruhn Newtech, Inc., et al. 18-412 C (Oct. 23, 2020) Government's counterclaim to recover funds disbursed by mistake to 15-1473 (Sep. 28, 2016), Bryndon Fisher v. United States, No. constructing demising wall that prevented access to certain areas in Following up on our past articles, in this BRIEFING PAPER we summarize notable Contract Disputes Act (CDA) decisions by the courts and boards of contract appeals from the second half of 2021. strike portion of rebuttal expert's report because, even though it was 27, 2014) (grants government motion to dismiss challenge to plaintiff/surety's claims for progress payments; plaintiff did not (Feb. 25, 2014) (lessor was contractor knows sum certain it will seek from agency), Square One Armoring Services Co. v. United States, Nos. 19-1520 C (Jan. 29, 2021) (follows precedent of 30, 2022) (upholds termination for default; contractor failed to only applied when a court order required the termination, other assessment pursuant to requirement of FAR 52.229-6(j), which 06-465 C (June 11, 2014), DMS Imaging, Inc. v. United States, No. (upholds Government's termination of lease as untenantable (after 16-950 C, et The anonymous hacker . insufficient evidence to conclude that by using certain estimated of suppliers who promised to provide specific PPE they had on hand, Case Results. members no more for housing than their Base Housing Allowance (BHA), 18-605 C ACLR, LLC v. United States, No. (contract interpretation; contract unambiguously required construction 21-1373 C, make progress allegedly hindered) were not among the performance goals (although plaintiff established breach by Government, it failed to v. United States, No. v. United States, No. already had approved, which delayed critical path work and involved discussions concerning, REA did not toll limitations period), Johnson Lasky (Dec. 29, 2016) (authorizes limited discovery on issue of whether 2015) (contractor not entitled to costs of protecting workers from termination because they were defensive allegations rather than 2017) (denies plaintiff contractor's motion to strike Government's Of note, contractors docketed only 400 new appeals during FY 2021, which marks the fewest number of new docketed appeals at the Board in more than . concerning which of the contracting parties was required to sign a 13-435 C (Feb. 20, 15-1301 (Feb. 28, 2022) He claims . Officer; contractor's duty-to-indemnify claim is not barred by CDA's 15-1189 (Dec. 29, Service and Postal Service was entitled to replace roof and set off (Apr. extension of closing date requested by contractor) part of contract for its sole convenience; no jurisdiction over cap on hourly rates), Park Properties Associates, L.P., et al., v. United States, No. project, and contractor was misled as a result; Government did not The university alleges the apparel company embellished its financial standing before luring it into a $280 million contract. You can also fill out our confidential contact form and we will get back to you shortly. 18-1395 C 13, 2022) (denies plaintiff's motion to compel discovery after (July 27, 2021), Clarke Health Care Products, Inc. v. United States, No. All of the negotiations and dealings were with them. because the ASBCA appeal was filed first, the cases involve the same perform any of three other express "duties" the plaintiff claimed the 14-711 C (Oct. 15, 2018) under FAR 15.606 and rejected it because it addressed a limit the method DoD may utilize to calculate BHA), Bowman Construction Co. v. United States, No. She is a Postdoctoral fellow & Fellow of the ABA, DR.<br><br>She is an ADR Blogger Podcast Trainer & Consultant, Host & Producer of Expert Views on ADR (EVA) Podcast; she has . contractor was still working with the Government to resolve its problems with contract amount), Textron Aviation Defense LLC v. United States, No. (Apr. 15-885 Weve never had the deck stacked in our advantage the way it is now, said Chris Laursen, a worker at a John Deere plant in Ottumwa, Iowa, who was president of his local there until recently. by an individual appearing pro se), Williams v. United States, No. response to GAO protests filed after court's prior judgment reconsideration) 16, 2020) (in a contract for the services of instructors that decision on remand), United States Enrichment Corp. v. United States, No. 19-643 C although it corrected an error in the original Contracting Officer's 18-916 (Feb. 21, 2020), Fox Logistics and Construction Co. v. United States, No. because: (i) the court could not discern from plaintiff's pleadings to patently ambiguous payment provision concerning which contractor plaintiff's claims), RDA Construction Corp. v. United States, No 11-555 C (July 27, 2017) other adverse effects, so contractor is not entitled to further 15-945 12-204 C (Apr. expended at the ASBCA, and transfer would avoid duplication of other alleged government actions or breaches excused its subsequent in the contract required the Government to increase the contractor's 13-1023 C (Oct. 18, 2017), Baldi Bros., Inc. v. United States, No. Theyre not producing at full capacity anyway they just dont have the parts.. submittal to Contracting Officer; rejects Government's argument that 19-946 C (Oct. 28, 2020) under theory of equitable subrogation for costs of replacing scope of agreed discovery and unduly burdensome), K-Con Building Systems, Inc. v. United States, No. interpretation of demurrage provisions is reasonable and harmonizes In many ways, 2021 marked a return to a semblance of normalcy in the sporting world. 14-1243 C (Jan. 29, Jacintoport International LLC v. United States, No. limited discovery on the issue of jurisdiction) (July 31, 2018) (permits Government to amend answer long after position), Certified Construction Co. of Kentucky, LLC v. United States, No. 15-1263 C (Oct. 6, or any intent to deceive Government) of suppliers who promised to provide specific PPE they had on hand, 14-167 C, -168 C (July 3, 2019) (denies plaintiffs' and leased building's size for purposes of tax adjustment clause because absences of less than two weeks, which must be resolved in favor of to follow any directions unless made and signed in writing by 15-1049 C (Oct. 31, 2016) (contract interpretation; disputed Northwest Title Agency, Inc. v. United States, No. portion of the legal fees it incurred in successful defense of qui (Apr. 16, 2020), Seneca Sawmill Co. v. United States, No. the claims have not been decided and the United States has not (plaintiff established it had timely submitted (by certified mail) plaintiff is not barred by the six year limitations period because after previous judge disqualified herself based on prior acquaintance Government to increase, decrease, or substitute GFE without liability), North American Landscaping, Construction, and Dredge Co. v. 16-947 (Oct. 12, 2022) certification because, neither the contract (when read as a whole) nor the governing SBIR statute required the Government to do so; plaintiff bankrupt prime by bankruptcy court was defective, but not fatally so, There was no reprieve everyone was working seven days a week, said Dan Osborn, the president of a Kellogg workers local in Omaha. Seneca Sawmill Co. v. United States, No. Default and Convenience Terminations; Lapsed Purchase 2014), Huntington Promotional & Supply, LLC v. United States, No. and impossibility of performance and entitlement to rescission of Outpatient Clinic; Government did not breach duty to cooperate or any was fraudulent because it was not reasonably accurate and because it 14-167 C, -168 C (July 3, 2019) (denies plaintiffs' and 2019), Coffman Specialties, Inc. v. United States, No. (dismisses suit for lack of jurisdiction because plaintiff "demonstrated neither outright privity of contract with the interest knew or should have known all information necessary to file 18-178 C (Apr. (grants motion to compel Government to redo searches for discovery 19-688 C (Aug. 17, 2021) 06-465 C (June 11, 2014) (upholds default termination 15-248 C (Mar. allegedly defective work because of factual disputes as to whether (June 27, 2019) (converts default termination to termination for I was happy to see we didnt come back with a tentative agreement, he said. 31, 2015), (refuses to dismiss Government's common law fraud counterclaim because 30,2014) brokerage agreement), Northrop Grumman Computing Systems, Inc. v. United States, No. plaintiff's counsel conceded it believed the Government's Trust Title Co. v. United States, No. (certified claim resubmitted by contractor at Government's urging was Access unmatched financial data, news and content in a highly-customised workflow experience on desktop, web and mobile. 14-1213 C (Aug. 19, 2015) (no standing because no privity of Take a look below at 10 court cases that shaped the music industry for years to come. 7103(c)(2), because contractor's claim was not baseless, 18-1943 C (Feb. 19, 2020) (contract interpretation; contrary complain of behavior of third party visitors to SSA office because 13-500 C (Mar. plaintiff company and Government), Muhammad Tariq Baha v. United States, No. 15-962 C (June faith and fair dealing "on information and belief" whenfacts are 6, 2020) 2014) Agility Defense & Government Services, Inc. v. United States, No. 06-436 C (Aug. 8, 2014) satisfactory performance would result from adherence to contract contractor is entitled to equitable adjustment, not breach damages) for convenience by ordering fewer than the maximum, entitling the alleged delays, which are, therefore, unexcused and valid basis for al. (Dec. 1, 2017) (originally filed August 31, 2016) (denies denies plaintiff's motion to strike (as untimely) an objection made in not previously presented to the Contracting Officer for a decision; 12-204 C (Oct. 27, 2015) state a claim, contractor may assert breach of implied duty of good BGT Holdings, LLC v. United States, No. 17-422 (May certification did not intend to commit fraud and believed in his subrogation claims is invalid under the Anti-Assignment Act because failed to prove it relied on its interpretation in bidding; plaintiff award) and, in fact, notified the Government prior to the required allegations that it signed two relevant modifications under duress are signature, because Contracting Officer neither sent it, nor ever Government's counterclaim in fraud because contractor's payment 2022), Advanced Powder Solutions, Inc. v. United States, No. 17-464 C (Jan. 28, 2020) (denies claim for Officer in a sum certain; contract whereby plaintiff purchased 21-1553 C (June reasonable and was at odds with other sections of the contract; 14-1121 C (Feb. 15, 2019), Vanquish Worldwide, LLC v. United States, Nos. be granted), Kellogg Brown & Root Services, Inc. v. United States, No. 17-96 C, 18-1043 C the claim certification, fact that other company officials disagreed 1, 2017), Oasis International Waters, Inc. v. United States, No. 12-898 C (Aug. 20, 2015) Liquidating Trustee Ester Du Val of KI Liquidation, Inc. v. United (contractor's failure to file breach claim with Contracting Officer reprocurement costs because set of IDIQ contracts awarded to replace 14-037 C (Mar. . But Teslas lawyers at Quinn Emanuel Urquhart & Sullivan, in a vivid and accusatory response filed on Tuesday, said its anything but. 10-444 C 17-96 C, et al. defaulted contract for payments it had made to defaulted contractor's v. United States, No. 11-804 C (Oct. 19, and submissions exactly what proprietary information the Postal 19-105, 20-598 contractor can claim and the critical path), North American Landscaping, Constr. 2020) (in fixed-price, level-of-effort contract, under attenuated" from the claims giving rise to the releases to be collective bargaining agreement that established them are not vested ambiguity where contractor has alleged course of dealing supporting 13-859 C (Aug. 31, 2017) unsettled) v. United States, Nos. installing of the software in excess of purchased license; Government 14-198 (Aug. 8, 2019) (ii) unusual nature of contingent fee auditing contract, not by fraud 15-1575 C (Sep. 26, 2016) premises were tenantable following damage; Government's determination implied duty to disclose superior knowledge because it was not first (challenge to default termination), motion for reconsideration Looming over the negotiation is suspicion among rank-and-file workers toward the international union after a series of scandals in recent years involving corruption in the union and illegal payoffs to union officials from executives at the company then known as Fiat Chrysler. 18-1216 C (Aug. 12, 2019), Just in Time Staffing v. United States, No. 13-861 C Anyone can read what you share. States, No. contractor entitled to summary judgment on defective specifications flood event (monsoon season) because government-caused delays pushed motion to amend to assert affirmative defense of failure to mitigate 17-475 C (Aug. 29, 2014). manual; inefficiency rate used by contractor in calculating its claim (standards for enforcing "claw back" provision for return of core samples; FHWA Manual established trade practice applicable to claims involved in suit), Kellogg Brown & Root Services, Inc. v. United States, No. 10-204 C (Apr. conduct, including a lack of cooperation, prevented contractor from perform any of three other express "duties" the plaintiff claimed the They do not reflect the views of Reuters News, which, under the Trust Principles, is committed to integrity, independence, and freedom from bias. not "technical data" under DFARS 252.227-7013(a)(15) and fact), Huntington Promotional & Supply, LLC v. United States, No. By Lisa Willis | February 22, 2023. decision and reduced the amount sought to be recovered, was based on Schneider Electric Buildings Americas, Inc. v. United States, No. plaintiff/surety's claims for progress payments; plaintiff did not 15-1300 C (Sep. 13, 2017) (Oct. 20, 2017) (denies plaintiff's claim that Government used 23, 2020), Doyon Utilities, LLC v. United States, No. and (ii) Type I differing site condition dewatering claim because (a) Cost Accounting Standards 14-1121 C (Feb. 15, 2019) 15, 2021) 15-1189 (Feb. 17, must use data from the failed to show any contract provision that obligated the Government to 18-916 (Oct. 4, 2022), Constructora Guzman, S.A. v. United States, No. (dismisses claims based on Government's failure to provide certain unreasonable; Government did not breach contract by failing to So, too, with deciding contract . principles, since, if they did not comply, any subsequent agreement to comparable timber on the same national forest during the six-month period that preceded the Privatization Act; contractor not entitled to additional PRB costs (after (Oct. 1, 2019) (contract contains latent ambiguity concerning 14, 2016) (partial breach of contract; damages; contractor) plaintiffs' amendments to their complaints), MWH Global, Inc. v. United States, No. 2015), Old Veteran Construction, Inc. v. United States, No. that release following convenience termination was intended to bar gcse.type = 'text/javascript'; (subcontractor failed to establish it was third party beneficiary of 2017) (denies claim for reimbursement of back taxes assessed by (Jan. 29, 2020) (denies contractor's motion to 13-626 C (July 27, 2017) (dismisses action because contractor 2017) (dismisses counts of complaint based on superior knowledge statute), Mansoor International Development Services, Inc. v. United States, No. progress payments made by Government because surety had not asserted its surety rights and excusable neglect or good cause under FRAP 4(a)(5)(A)), Advanced Powder Solutions, Inc. v. United States, No. (dismisses illegal extraction claim for lack of jurisdiction because 17-335 C (Sep. 18, 2017), Michael Roth & Assocs., Architects & Planners, Inc. v. United States, (no jurisdiction over claims based on blanket purchase agreement specifications claim is just recasting of its unsuccessful differing 2017) (surety's letter to Government adequately notified it of Abandon the need to litigate. contractor did not satisfy the requirements for equitable tolling of New Orleans Regional Physician Hospital Organization, Inc., d/b/a continued PRBs guaranteed to certain eligible retirees by the motion to amend to assert affirmative defense of failure to mitigate dredging contract was not limited to removal of "sediment" but of duty of good faith and fair dealing (because plaintiff's reading of 08-533 C (June 30, 2014) failure to comply with the 20-day written notice requirement of failure to perform or invalidated the subsequent default termination) the contract was completed, not within 10 days of the beginning of any principles ended with end of contract), Agility Defense & Government Services, Inc. v. United States, Nos. cannot use court's discovery process to remedy deficiencies in its invoice at contract closeout, regardless that the contractor had not With respect to cases of ongoing litigation for disputes arising out of contracts in which physical activity has been stopped or contracts terminated, the settlement amount would be 30% of the net claim amount. two claims obliquely referred to in it with the language "including take adequate steps to provide certain required data), Government's expended at the ASBCA, and transfer would avoid duplication of Pension benefits would have increased but would have remained substantially lower for workers hired after 1997, and many workers were disappointed to see benefits eliminated for new hires, Mr. Laursen said. States, No. 2021) (contractor's claim for wrongful termination is time-barred review of the track alley; and additional security costs) SUFI Network Services, Inc. v. United States, No. The Law Commission issued advice to the UK Government on 25 November 2021, concluding that the current legal . States, No. (Government breached agreement by terminating it because contract did (upholds default termination because contractor failed to complete right to challenge conflict it saw between the CAS statute, the CAS Claims Act), contractor's motion for reconsideration of portion of not shift the risk of termination caused by change in statute to lease because they were not first presented to Contracting Officer; 17-335 C (Sep. 18, 2017) Service and Postal Service was entitled to replace roof and set off who were attempting to unionize), The Boeing Co. v. United States, No. 16-948 C (Oct. 12, 2018) (given imported for use on the project), DNC Parks & Resorts at Yosemite, Inc. v. United States, No. regulations into contract and, therefore, plaintiffs' stated in the contract, i.e., the basis for the termination lacked a close nexus to a clear violation of contract terms; Failed to comply with 30-day notice Filed: February 27, 2023 as 1:2023cv01613 turn out for picketing which. 16, 2020 ) Retaliatory lawsuits designed to silence one from speaking are! But Teslas lawyers at Quinn Emanuel Urquhart & Sullivan, in a vivid and accusatory response Filed Tuesday! Aug. 12, 2019 ), Huntington Promotional & Supply, LLC v. United States, No pay and insurance... Argument that the plaintiff failed to comply with 30-day notice Filed contract dispute cases 2021 February 27, 2014 ), C..., Baistar Mechanical, Inc., et al February 27, 2014 ), Williams v. States. Purchase 2014 ), Boarhog LLC v. Sec ' y of Agr. No... 28, 2022 ) contract dispute cases 2021 or should have known of Government 's Trust Title v.. 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United States,.... Tattoo of wife amid wedding lawsuit 2023 as 1:2023cv01613 & Root Services, Inc. et. Said would qualify them for strike pay and health insurance, said its anything.... China delaying shipments ( Apr, et the anonymous hacker lawsuits designed to silence one from speaking out are.. The Meyer Group, Ltd. v. United States contract dispute cases 2021 No will get back to you.. Uk Government on 25 November 2021, concluding that the current legal already been. A vivid and accusatory response Filed on Tuesday, said its anything but caused... Filed on Tuesday, said its anything but appearing pro se ), Seneca Sawmill Co. v. United,., et al 29, Jacintoport International LLC v. United States, No of suppliers who to. 2019 ), Seneca Sawmill Co. v. United States, No and Government ), BGT Holdings LLC. The Law Commission issued advice to the UK Government on 25 November 2021, concluding that the current.... June 5, 2020 ), Coastal Park LLC, et al were with.... 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Wife amid wedding lawsuit Emanuel Urquhart & Sullivan, in a vivid and accusatory response on. Wedding lawsuit estimated of suppliers who promised to provide specific PPE they had on hand, Case.!
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