Please mail the completed form to:

Georgia:
Pendley Law Firm
24110 Eden Street
Plaquemine, LA 70765
Phone: (888) 725-2477
Fax: (225) 687-6398
Email Pendley Law Firm
www.pendleylawfirm.com

Illinois:
Edward Eshoo, Jr.
Childress & Zdeb, Ltd.
6 West Hubbard Street
Chicago, Il 60610
Phone: (312) 494-0200
Fax: (312) 494-0202

E-mail Edward Eshoo, Jr.
www.childresszdeb.com

Lousiana:
Pendley Law Firm
24110 Eden Street
Plaquemine, LA 70765
Phone: (888) 725-2477
Fax: (225) 687-6398
Email Pendley Law Firm
www.pendleylawfirm.com

Mississippi:
Robert Chapman Williamson
Law Offices of
Robert Chapman Williamson
755 North Congress Street
Jackson, Mississippi 39202
Phone: (601) 948-6005
Fax: (601) 948-0306
E-mail Robert C. Williamson




North Carolina:
Dan Bryson
Lewis & Roberts, PLLC
1305 Navaho Drive
Suite 400
Raleigh, NC 27609
Phone: (919) 981-0191
Fax: (919) 981-0199
E-mail Dan Bryson

Joel Robert Rhine
Lea, Clyburn & Rhine, PLLC
314 Walnut Street
Suites 1000 & 2000
Wilmington, NC 28401
Tel: (910) 772-9960
Fax: (910) 772-9062
E-mail Joel Robert Rhine
www.lcrlawfirm.com

South Carolina:
Brandt Shelbourne
116 South Oak Street
Summerville, SC 29483
Phone: 843.871.2210
E-mail Brandt Shelbourne

Kimberly Campbell
Patrick, Chandler & Campbell, L.L.C.
412 N. Poplar Drive
P.O. Drawer 15669
Surfside Beach, SC 29587
Phone 843.238.5618

Virginia:
Paul Thomas
Smink, Thomas & Associates, P.C.
1812 Baltic Avenue
Virginia Beach, VA 23451
Phone: (757) 491-4141
Fax: (757) 491-2253
E-mail Paul Thomas



 

Thank you for visiting the EIFS Legal Network Website. Prompt completion of this questionnaire is critical in the evaluation of your potential legal recourse and will facilitate the filing of a lawsuit if necessary. However, it is not a pop test. Only answer the questions to which you easily know the answers. If you have any questions, please call or email the attorneys listed above.

IMPORTANT: Completion of this questionnaire does not mean that the above listed firms are representing you. One of the purposes of this questionnaire is to ascertain potential conflicts that these firms may have in representing you. Following our review of the completed questionnaire, if there is no conflict and you desire to retain us, an engagement letter will be forwarded to you for execution. In the event that we do not ultimately represent you, please be advised that the law imposes time limits on which a lawsuit may be filed. Failure to file within these time limits will constitute an absolute bar to a lawsuit. In the event that we do not represent you, we urge you to contact another attorney to evaluate your case.

Date:

1. Your full name and address and all other homeowners:

County:

Telephone: (Day)
(Evening)
(Fax)

Address of the property at issue (if different from above):

County:

2. General contractor (name, address and telephone number):

3. General contractors's insurance company (name, address, telephone number, adjuster, if available):

4. Stucco applicator (name, address, telephone number, and insurance company, if available)

5. Stucco product (name, manufacturer, address, telephone number, if available):

6. Roofer (If you know) (name, address, telephone number, if available):

7. Window Manufacturer (If you know) (name, address, telephone number, if available):

8. Window installer (If you know) (name, address, telephone number, if available):

9. Realtors involved (indicate buyer's and seller's companies and agents):

10. Did you purchase your lot from the contractor?

If not, from whom did you purchase your lot?

11. Do you have written contracts for any of the following:

Lot purchase:________ If so, date:___________________________
Contract with Builder:________ If so, date:_____________________
PLEASE ATTACH COPIES OF ANY CONTRACTS.

12. Date of closing:

When did you move into the house? _________________________________
Was a certificate of occupancy issued? If so, date? ________________

13. Was a punch list generated?

Were all punch list items completed? If not, please describe all uncompleted items (attach additional sheets if necessary).

14. What were the purchase amounts of the following:

Lot:__________ Residence:__________ Total:__________
Approximate total square footage: _________________
Have all purchase amounts been paid?
If not, please specify)

15. When did you first notice problems and how did you gain this knowledge? (Please be specific as to each date and each problem and attach additional sheets, if necessary.)

Describe each problem (this list should encompass all current problems with the house, including but not limited to problems with the stucco). (Attach additional sheets, if necessary):
List all communications with builder regarding the problems:
Attach copies of all written communications.

16. Homeowners insurance company, address and telephone number:

Please attach a copy
Have you filed a claim on your homeowners' insurance?

17. Have you taken pictures?

While house was under construction:
Later:
Please provide copies, if possible.

18. Last date of original construction activities by the following:

Builder:
EIFS applicator:
Roofer:
Window installer:
Flashing installer:
Have any of the above returned to your home at a later date to perform any activities? If so, when, why, who returned, and what was done?

19. Do you think anybody made misrepresentations to you? If so, who and in what way?

20. Have you conducted any construction activities following the completion of your residence (additions, modifications)?

If so, explain:

21. What role or input did you have in the construction of your home (did you direct any work, choose subcontractors, choose materials, etc.)?

Have you ever been involved in the construction business?
If so, in what way?

22. Prior to purchase, what statements were made to you about the following (important: identify the party and person making the statement.):

Repairing defects:
Windows:
EIFS :
Your maintenance responsibilities :

23. Were your house plans prepared by an architect?

If so, please provide name, address and telephone number:
If not, who prepared your house plans (provide name, address and telephone number):

24. Have you had any contact with any of the manufacturers?

If so, please explain and attach copies of any relevant documents:

25. If applicable: have you had any contact with any insurance companies other than already discussed herein?

If so, with whom (provide names, addresses and phone numbers)?

26. Have you had any moisture tests or other inspections performed?

If so, please provide names, addresses and telephone numbers. Attach copies of all reports.

27. List all persons who have knowledge of the relevant facts pertaining to the causes, necessary repairs and costs to repair your house:

28. Have you ever dealt with EIFS before?______ If so, explain:

29. Have you obtained any quotes to repair any aspect of your house?_____ If so, explain:

30. Have you had any physical difficulties which you believe to be caused by the condition of your house?

31. Personal information:

Profession:
How long have you been a resident of this area?
If you are a newcomer, where did you live before?
If you are a newcomer, were you familiar with EIFS before relocating to this area?

32. Have you been involved in any other lawsuits?____
If so, briefly explain:

33. What is your objective in this matter?

34. Please provide any additional information or documents that may be helpful.

PLEASE NOTE! WHILE YOUR RESPONSES TO EACH OF THESE QUESTIONS IS IMPORTANT, REGARDING OUR ABILITY TO REPRESENT YOU IN THIS SYNTHETIC STUCCO MATTER, THE FOLLOWING 'SHORT LIST' OF ITEMS ARE IMPERATIVE:

1. The names of the builder, applicator, and manufacturer of the EIFS;

2. A copy of the 'Purchase Agreement', 'Contract to Purchase', or 'Construction Contract';

3. A copy of the 'Closing Statement' or 'Settlement Statement';

4. Copies of any 'Moisture Intrusion Reports';

5. The date (or a close approximation thereof) when you first came to believe that you may have a 'problem', either real or perceived, with the synthetic stucco applied to your house; and

6. The circumstances relating to the 'discovery' of your synthetic stucco 'problem'.

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