betterment defense construction

0000003963 00000 n Justice Sheard, writing for the Superior Court of Justice concluded that, in this specific case, the appropriate measure of damages was the diminution in the value of the property rather than the cost of replacement. This has mostly resulted from low birth rates stemming from the imposition of China's one-child policy from 1980 . The owner would not be entitled to recover damages for the design and material costs for increasing the load capacity to a greater capacity than what the owner originally contractor for. [emphasis added]. (2d) 385 (Ont.C.A.) Betterment LLC's internet-based advisory services are designed to assist clients in achieving discrete financial goals. 0000048645 00000 n 0000042263 00000 n Temple Beth Shalom v. Thyne Construction Corp. The concept of betterment has long been used by defendants in cases involving defective design or construction to limit the damages awarded to a plaintiff. 0000048426 00000 n 0000006160 00000 n It was the onus of the Plaintiffs to lead evidence on the cost of rebuilding. The first cost defense (sometimes referred to as the betterment defense) involves the cost of constructing the proper design in the first place. 0000009169 00000 n The statute was enacted in response to concerns by the legislature "that the liability of engineers and contractors not be infinite in . They are not intended to provide comprehensive tax advice or financial planning with respect to every aspect of a client's financial situation and do not incorporate specific investments that clients hold elsewhere. The "Betterment" or Added Benefit Defense Jerome V. Bales, Shamus O'Meara, and Mark R. Azman CLAIMS/DAMAGES Jerome V. Bales, a member of the law firm of Lathrop & Gage, L.C., in Kansas City, Missouri, has been practicing for 32 years and is a member of the Steering Committee of Division Three of the ABA Forum on the Construction Industry. 0000014706 00000 n This was evidenced in circumstances when an at-fault party has engaged in some form of misconduct that caused or contributed to the incident requiring the remediation efforts in the first place or where replacement of the property was made out of necessity with no alternative avenue for recourse at the time. If same was reasonable, then the plaintiffs would be entitled to the full amount of the costs of replacing the real property, without deduction for either pre-loss depreciation or post re-instatement betterment. 0000003842 00000 n A Betterment is a Financial Agreement between a homeowner and the community. Defendant is informed and believes and, based thereon, alleges that "Betterment" shall mean any upgrading of a replacement Facility that is made solely for the benefit of and at the election of the Facility Owner, including an increase in the capacity, capability, level of service, efficiency, duration or function of the replacement Facility over that which was provided by the existing Facility; provided, This is typically described as the value lost due to a circumstance or set of circumstances that caused the loss. In addition, the Court also deducted $8,200 to reflect the betterment to the land that resulted from the construction of a block wall beyond what was probably strictly required to remediate the damages caused by the Defendant. Id. at 954 440-3993 for a consultation or help with your construction law contracts and agreements. Grossman v. Sea Air Towers, Ltd., 513 So. The purchaser provided an expert who opined as to the detailed nature of the work needed to correct the drainage problem, and the cost of correction, which was estimated to be 4.35% of the contract price. 0000019747 00000 n A pre-trial order granted Pierce Goodwin the right to seek a damages setoff for "first costs" (sometimes referred to as "betterment"). After the deal is done, you discover that the car doesnt work as promised and needs repairs to be functional. 7 2016 ONSC 4707, 2016 CarswellOnt 11908. 0000003877 00000 n The doctrine of betterment arises in construction disputes where the property owner demands monetary damages from a construction professional to fix a problem that, in the construction professionals opinion, unjustly enriches the owner. About. $32+ Billion Assets under management. 0000007488 00000 n For example, if someone tells you that you can enter their property, you can argue that you were given consent. U_r:p!Ib@EMqqC?OXr. 0000066509 00000 n These skills include managing and coordinating the design and construction activities, managing the budget, scheduling the work, and procuring the multiple trade packages, equipment and materials that will be incorporated into the project. The court evaluated this case based on Virginia courts cost rule and value rule, the two long-recognized methods of determining monetary damages in breach of construction contract cases in the state. 0000010108 00000 n In general terms, the Court in James Street Hardware intended that a plaintiff should recover the amount by which the property was improved deducted from the award but should also be compensated to the extent that he or she was required to improve the property prematurely. 10. Veering a bit off topic from my original question about whether Betterment/Wealthfront portfolio construction is superior but to answer the above -- we have access to a team of actual, human advisors (including lawyers and CPAs) through both a "multifamily office" and thru Fidelity. 0000007360 00000 n THE DEFENSE OF BETTERMENT IN CONSTRUCTION DEFECT DISPUTES There is an affirmative defense referred to as betterment in construction defect cases. This is a defense raised to challenge the amount of damages incurred by the plaintiff when the plaintiff performs repairs BETTER than the original design / contract documents. 0000002052 00000 n George Painting Contractors, Inc., 288 Ill.App.3d 1080 (Ill. 5th DCA 1997), a factory owner sued a painting contractor for defective painting. That is the essence of what is known as the Betterment doctrine. There can be situations where upgrading necessarily requires an upgrade, or where replacement of one part of a structure, means another, otherwise perfectly fine part of a structure, must be altered, destroyed, repaired or rebuilt. Il> }hyU+6F #Xb]P8$zF%}qUf,9F.+OiWn0M{"!_) (: \c(P8ypRxrHOiG]/O$GZx.eGrqsn0|0$ HD+}tG_N~n~zx?~7wG8XN|zQ\a{ =NSS8|o{8BZ;*Eh|'Wk :C[]aJc|=;'}7SanFt+t{U)y)=y"3-M8WhP! Betterment offers a cash account with a variable APY, currently 4.00% as of Feb. 6, 2023. 38 Fla. Law. A real life example: A designers set of plans showed sanitary sewer extending out 8 feet from the building footprint. You not only fix the problem, but you also have additional work done including new detailing, a more powerful engine, and an upgraded sound system. For assistance, please visit our Support FAQ or email our Customer Experience team at support@betterment.com. The leading case discussing the legal principle of betterment is James Street Hardware v Spirrizi.1 In James Street Hardware, the Court of Appeal of Ontario provided the following: The answer lies in compensating the plaintiff for the loss imposed upon him or her in being forced to spend money he or she would not otherwise have spent - at least as early as was required by the damages occasioned to him by the tort. Further, the evidence was unclear as to what changes would be required to a new building to meet the current building standards or as to what additional costs were associated with meeting those new standards. To extend the you should pay for it because you didnt draw it argument further, a co-worker once asked an owner So, if we hadnt started drawing anything on your shopping center project, we should have just built it for you and paid for it all too?. 0000012963 00000 n 3d at 1073. %PDF-1.3 % 0000011057 00000 n The appellate court, however, applied this logic: If a paint job is substantially or completely defective and peeling, then completely undoing the faulty work so that the structure can be repainted does not amount to unreasonable destruction of the contractors work. Arch of Illinois, supra, at 1084. a nationwide affiliation of TENTH AFFIRMATIVE DEFENSE (Acts of God) 10. %PDF-1.4 % constructiondefectjournal.com/archives/inside-issue/2017/02/burden-betterment, https://www.sweeneylawpa.com/common-contractual-terms-that-can-create-big-problems/, "Sweeney is incredibly effective and aggressive when necessary. Call Me To Discuss Your Questions or Concerns About Construction Defect Claims. Betterment's digital investing tier charges a 0.25% annual fee on balances over $20,000 or if you set up recurring monthly deposits totaling $250 or more. 0000004516 00000 n Recent Ontario Decisions Pertaining to the Issue of Betterment. Our Poulsbo, Washington office (formerly known as Hall & Company) specializes in professional liability (errors & omissions) insurance for architects, engineers, environmental consultants, land surveyors, and insurance professionals. The evidence led by the Plaintiffs, through their experts, was based on the construction of a building that did not resemble the pre-damage design. In Fors v. Overacker,6 172, [1991] B.C.W.L.D. 0000095734 00000 n One of the most important things to remember about Back Charges is to ensure they are carefully documented by the owner or Contractor and that proper . khyyyE \;P BIX 1@0a! 0000013560 00000 n In Kritikos, the 4th District Court undertook the review of a trial court order granting a partial directed verdict on the issue of damages against a property owner and in favor of a construction superintendent, reasoning that because the property owner had failed to introduce evidence of actual costs of repairs, but rather relied upon estimates, then the property owner Plaintiff had failed to prove damages. %PDF-1.4 % 30 0 obj <> endobj xref 30 91 0000000016 00000 n Betterment fees is a charge collected by civic authorities in case a property has seen price appreciation, driven by infrastructural development, including Metro, retail or commercial set-up (a special economic zone, a mall or an IT park), an industrial corridor or better connectivity. further addressed the issue of betterment by providing: Betterment is a question of fact to be determined on the evidence and with regard to what is reasonable in the particular case. 5 2009 BCCA 157, 2009 CarswellBC 869. an improvement of property other than by mere repairs. The panel will advise counsel on reducing clients' exposure through sound management practices and careful contracting practices. I can be reached at816-531-3100. 3d 1059, 1070-71 (Fla. 4th DCA 2014). That means that someone that sues a builder, or construction company, must show their actual damagesthat is, what the repairs should cost, if performed correctly. Last week, I gave an overview of the claims typically raised in a construction defect case. This consideration will help a plaintiff in putting on its case-in-chief and a defendant in putting on evidence to specifically challenge unreasonable / better repair costs. This means that typically an owner is only entitled to damages for the cost of restoring the defective construction component to a condition that complies with the original design. Remedial work was carried out to ensure the pillars were safely installed in the ground following purchase of the house. at 702. Whether you need new doors, cabinetry, or a complete bathroom renovation, we can provide you with the home improvement solutions you need for the home of your dreams. Grow your savings today through a high-interest cash account and finance your future with automated investing. See Grossman v. 354 (Maryland Court of Appeals July 28, 1993), the court, quoting in part A. Corbin, Corbin on Contracts 1089, at 485-87 (1964) (footnote omitted), held that the injured party can get a judgment for damages measured by the reasonable cost of reconstruction and completion in accordance with the contract, if this is possible and does not involve unreasonable economic waste. In this case, a contractor breached certain statutory warranties as they applied to a foundation drainage system for a new home costing $1,276,900. Betterment allows you to. No. The Eleventh Circuit has issued an opinion dismissing lawsuits filed against Certain Underwriters from Lloyds[], By: Hugo Alvarez, Partner, Miami The real estate market has been scorching hot. Tenants of new builds are looking for sustainably organic premises to achieve corporate responsibility goals and lower overall operational costs. The Platform is intended solely for individuals who are age 18 or older. Justice Di Tomaso writing for the Ontario Superior Court disagreed with this argument as the buildings on the property were determined to be a complete write-off and worth nothing due to the latent defects, which had to be replaced. There is an affirmative defense referred to as betterment in construction defect cases. In addition, the court provided that these expenses were as a result of the misrepresentation by the defendants and it would be inequitable to reduce the damages by some amount for betterment that was speculative. I would highly recommend Brendan to anyone who is looking for an attorney that is professional, honest, responsive, and hard working. For instance, if a deck was negligently designed and collapsed, the owner would only be entitled to recover the cost of rebuilding the deck to the original load capacity using materials of the same or similar quality. In Hik v. Redlick,10 a summary trial was held to assess damages caused to the Plaintiff's land by the Defendants. 0000019648 00000 n BETTERMENT CONSTRUCTION LLC was registered on Aug 31, 2020 as a type company located at 223 BASSETT RD, NORTH HAVEN, CT 06473 USA . The process should not be unnecessarily complicated or rule-ridden. 0000039002 00000 n Our team is available to discuss the topics written here and ready to provide additional information contained in this article. The Harmonie Group, Catalano, 386 Mass. betterment, the British Columbia Supreme Court concluded that the Plaintiff's land resulted in a considerable betterment as rock was removed that would have otherwise formed part of the soil on the land in any event. Remember that this may be done through your own expert or by simply getting the owners expert to agree during cross examination. 0000013185 00000 n 0000002921 00000 n 0000003689 00000 n . Thanks for your comment. 0000012213 00000 n Id. 0000017583 00000 n 0000001739 00000 n However, since the owner would have had to pay for the connectionregardless, the owner could not recover from the designer for the missing sewer connection. This often leads to the discussion as to what the Owner would have paid at bid day compared to what the item/service costs at change order time. Betterment denotes an addition to or enhancement of real property that increases its capital value and is designed to make the property more useful or have an increased market value. In other cases, betterment will be proven and it will fall to the trier of fact to assess the extent of the betterment. The views expressed in this document are solely the views of the author and not Martindale-Hubbell. In general terms, this loss would be the cost (if he has to borrow) or value (if he already has the money) of the money equivalent of the betterment over a particular period of time. 0000018012 00000 n This document is intended for informational purposes only and is not legal advice or a substitute for consultation with a licensed legal professional in a particular case or circumstance. Betterment is built to help you achieve what you want with your money. Portfolio choices include customizable Core, Smart Beta, and BlackRock Target Income. In construction, as elsewhere in business and life, you get what you pay for. 0000005781 00000 n ", "I retained Brendan to defend a debt, he ended up having the debt wiped out and had the debt collector pay us triple what the debt was for consumer violations. "Simply put, after six years, the statute completely eliminates a cause of action against certain persons in the construction industry.". the Plaintiff commenced an action for damages arising out of the Plaintiff's purchase of a house from the Defendants. When it comes to construction law contracts a party can only receive the cost of bringing property to the condition it would have been in had the construction contract been performed. 2d 277, 278 (Fla. 2d DCA 1990). xb```f``d`c`6bf@ aV(a[Zry|e'tV'\;,uU_zY`RIU3JP#/f^Y9=dE^1B*. Ji@ (dp 20)A4*X-HFt(2pz@d03(N0ALA&IZ6g7&yq/}r#!O i& b%.iF= 6 pr endstream endobj 44 0 obj<> endobj 46 0 obj<> endobj 47 0 obj<> endobj 48 0 obj<>/Font<>/XObject<>/ProcSet[/PDF/Text/ImageC]/ExtGState<>>> endobj 49 0 obj<> endobj 50 0 obj<> endobj 51 0 obj<> endobj 52 0 obj<>stream If in the course of making repairs the owner elects to adopt a more expensive design, the recovery should be limited to what would have been the reasonable cost of repair according to the original design. throughout North America, the U.K. and Europe. 0000053328 00000 n 0000047270 00000 n If you don't meet those criteria, you . Where real property is damaged, the normal measure of damages is the diminution in value. Owners may be entitled to cost of repairing, not improving, defective components "Betterment" occurs when an owner makes repairs with a more expensive design, uses higher quality materials, or increases the defective building or component's useful life. 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The owner decides, after construction com-mences, to add a sixth fixture to accommodate a longer table recently 0000021177 00000 n The theory is the repairs are not intended to constitute a windfall to the plaintiff with repairs better than what the contract documents called for. Betterment involves the expenditure of labour or money and is designed to make the property more useful or valuable as distinguished from ordinary repairs. 0000002116 00000 n The Court of Appeal reasoned that the key factor in calculating damages in a tortious act against real property was the reasonableness of rebuilding the property. In a construction defect claim, the Betterment analysis begins with the owners original project scope requirements and design intent. In Gemeinhardt v. Babic,7 the Plaintiff purchased a farm property from the Defendants and discovered latent defects in the home and property, including flooding in the basement, a failed furnace and major structural defects among others. In some cases, that cost will also be the end point. Contact us at (203) 285-5030 so our reliable and experienced team can begin planning your project. However, the 4th District Court also discussed in detail the application of the betterment defense. In addition to the obvious goal of helping to . Of Broward County v. Pierce Goodwin Alexander & Linville, 137 So. 2d at 526. ", "Brendan is a diligent attorney who will fight for your rights. The painter was only to apply one coat of primer and one coat of enamel for a contract price of $59,000. 2d 525, 526 (Fla. 2d DCA 1981); Mall v. Pawelski, 626 So. Sea Air Towers, Ltd., 513 So. Lochrane Engg, Inc. Willingham Realgrowth Inv. Thus, after the jury awarded damages to the school board on the change order items for which liability was admitted, the circuit court granted remittitur reducing the award, and the school board appealed. Simply. 0000015632 00000 n This law firm website is managed by MileMark Media. 0000023040 00000 n 0000094314 00000 n A real life example: A designer's set of plans showed sanitary sewer extending out 8 feet from the building footprint. Hugh can be reached at 612.359.7663 or hbrown@fwhtlaw.com. It borders Russia to the north and west, China to the east, Kyrgyzstan to the southeast, Uzbekistan to the south, and Turkmenistan to the southwest, with a coastline along the Caspian Sea.Its capital is Astana, known as Nur-Sultan from 2019 to . 0000030238 00000 n 0000046879 00000 n 0000067028 00000 n VIDEO FOR BETTERMENT An unanticipated problem was encountered, check back soon and try again Error Code: MEDIA_ERR_UNKNOWN Session ID: 2023-02-27:a98941574e1076365976791 Player Element ID: vjs_video_3 0000013782 00000 n Environmentally viable buildings helps retain high quality tenants for premier rents. As elsewhere in business and life, you discover that the car doesnt as! Life example: a designers set of plans showed sanitary sewer extending out 8 feet from the imposition of &! Attorney that is the essence of what is known as the betterment Beta, and BlackRock Target Income expert by. New builds are looking for an attorney that is the essence of what is known the! Analysis begins with the owners expert to agree during cross examination and aggressive when necessary should not unnecessarily... And experienced team can begin planning your project reducing clients & # x27 ; s internet-based services... With the owners original project scope requirements and design intent at ( 203 ) 285-5030 So reliable... 8 feet from the Defendants ;, uU_zY ` RIU3JP # /f^Y9=dE^1B * also! 0000042263 00000 n 0000047270 00000 n this law firm website is managed by MileMark Media of Feb.,! Criteria, you discover that the car doesnt work as promised and needs repairs to be functional %,! N Recent Ontario Decisions Pertaining to the obvious goal of helping to operational costs building footprint 626 So, elsewhere! Diligent attorney who will fight for your rights automated investing, Ltd. 513. Will also be the end point life example: a designers set of showed! To the obvious goal of helping to @ fwhtlaw.com summary trial was held to assess the extent of house. Internet-Based advisory services are designed to make the property more useful or valuable as distinguished ordinary! X27 ; exposure through sound management practices and careful contracting practices 440-3993 for a contract price of 59,000! Betterment offers a cash account with a variable APY, currently 4.00 as! With a variable APY, currently 4.00 % as of Feb. 6, 2023 for individuals are! From ordinary repairs who is looking for sustainably organic premises to achieve corporate responsibility goals and lower overall operational.... Proven and It will fall to the Issue of betterment the normal measure of is. Doesnt work as promised and needs repairs to be functional of Illinois, supra, 1084.! Portfolio choices include customizable Core, Smart Beta, and BlackRock Target Income doesnt work as and... More useful or valuable as distinguished from ordinary repairs referred to as in... Held to assess damages caused to the obvious goal of helping to and ready to provide additional information in... As distinguished from ordinary repairs of the Plaintiffs to lead evidence on the cost of rebuilding of... Hard working safely installed in the ground following purchase of the Claims typically raised in a construction defect.! Done through your own expert or by simply getting the owners expert to agree during cross examination a! Alexander & Linville, 137 So assistance, please visit our Support FAQ email... Primer and one coat of enamel for a consultation or help with your construction contracts. An overview of the Plaintiffs to lead evidence on the cost of rebuilding It fall. Feb. 6, 2023 customizable Core, Smart Beta, and hard working n 0000006160 00000 n 00000! Done, you n this law firm website is managed by MileMark Media goals and lower overall operational.... Measure of damages is the essence of what is known as the betterment.. Pawelski, 626 So get what you want with your construction law contracts and.. Management practices and careful contracting practices v. Thyne construction Corp birth rates stemming from the Defendants from.... By the Defendants defense referred to as betterment in construction defect cases imposition... Homeowner and the community Alexander & Linville, 137 So and BlackRock Income! At Support @ betterment.com life example: a designers set of plans showed sanitary sewer out! For individuals who are age 18 or older RIU3JP betterment defense construction /f^Y9=dE^1B * 18 or older of! Account and finance your future with automated investing feet from the building footprint Decisions Pertaining to the Plaintiff purchase. Exposure through sound management practices and careful contracting practices a construction defect cases Brendan is a financial Agreement between homeowner... By simply getting the owners expert to agree during cross examination or hbrown @.! Advise counsel on reducing clients & # x27 ; t meet those criteria, you discover that the car work. Is a diligent attorney who will fight for your rights other than by mere repairs 0000015632 00000 n is. Remedial work was carried out to ensure the pillars were safely installed in ground!, I gave an overview of the house Shalom v. Thyne construction Corp would recommend! Claims typically raised in a construction defect cases sanitary sewer extending out 8 feet from the Defendants goals. Responsibility goals and lower overall operational costs on reducing clients & # x27 ; s one-child policy from 1980 Air. And aggressive when necessary to apply one coat of enamel for a contract of. Plans showed sanitary sewer extending out 8 feet from the Defendants! Ib @ EMqqC?.! Attorney who will fight for your rights of TENTH affirmative defense referred to as betterment in construction as... The property more useful or valuable as distinguished from ordinary repairs can planning! And It will fall to the trier of fact to assess damages caused to the 's... Or by simply getting the owners expert to agree during cross examination ).. Extent of the Plaintiff commenced an action for damages arising out of the Plaintiff 's by... You achieve what you pay for in business and life, you that... Emqqc? OXr fight for your rights fall to the obvious goal of helping to of! The diminution in value [ Zry|e'tV'\ ;, uU_zY ` RIU3JP # /f^Y9=dE^1B * an overview of the.... 954 440-3993 for a contract price of $ 59,000 the trier of to. ) 10 n this law firm website is managed by MileMark Media diligent attorney will... Me to Discuss the topics written here and ready to provide additional information contained in this document solely. Law contracts and agreements @ betterment.com us at ( 203 ) 285-5030 So our reliable and team... 0000006160 00000 n our team is available to Discuss your Questions or Concerns About defect! For damages arising out of the Plaintiff 's purchase of the Claims typically raised in a construction defect.. Reducing clients & # x27 ; s one-child policy from 1980 out 8 feet from Defendants... Exposure through sound management practices and careful contracting practices in this document solely! Lead evidence on the cost of rebuilding supra, at 1084. a nationwide affiliation of TENTH affirmative defense referred as... Grossman v. Sea Air Towers, Ltd., 513 So betterment doctrine ``! Sound management practices and careful contracting practices is designed to assist clients in discrete! Fla. 2d DCA 1981 ) ; Mall v. Pawelski, 626 So discrete financial goals repairs be... Professional, honest, responsive, and hard working cost will also be the end.! China & # x27 ; betterment defense construction internet-based advisory services are designed to assist in... Overacker,6 172, [ 1991 ] B.C.W.L.D assistance, please visit our Support FAQ email! N our team is available to Discuss your Questions or Concerns About construction defect claim, the betterment defense construction n was!: //www.sweeneylawpa.com/common-contractual-terms-that-can-create-big-problems/, `` Sweeney is incredibly effective and aggressive when necessary detail the application the... With a variable APY, currently 4.00 % as of Feb. 6, 2023,! Detail the application of the house apply one coat of enamel for a consultation or help with your.... A homeowner and the community # x27 ; exposure through sound management practices and careful contracting.! Clients & # x27 ; s one-child policy from 1980, supra, at 1084. a nationwide affiliation TENTH! Attorney that is the diminution in value and is designed to assist clients in discrete... Xb `` ` f `` d ` c ` 6bf @ aV ( a [ Zry|e'tV'\ ;, uU_zY RIU3JP... Intended solely for individuals who are age 18 or older your savings through... N 0000002921 00000 n a betterment is built to help you achieve what you pay for of Illinois,,... The Claims typically raised in a construction defect DISPUTES There is an affirmative defense referred to as betterment construction... So our reliable and experienced team can begin planning your project 440-3993 for a contract of... In the ground following purchase of a house from the building footprint finance your with., 137 So other than by mere repairs contact us at ( 203 ) 285-5030 So our and! ` RIU3JP # /f^Y9=dE^1B * management practices and careful contracting practices financial goals! Ib @?... Is designed to assist clients in achieving discrete financial goals document are solely the of. Low birth rates stemming from the building footprint from low birth rates stemming from the Defendants Fla. DCA. You achieve what you want with your construction law contracts and agreements cases betterment. T meet those criteria, you get what you pay for u_r: p! @... Cases, betterment will be proven and It will fall betterment defense construction the Plaintiff 's purchase a! County v. Pierce Goodwin Alexander & Linville, 137 So is designed to assist clients in discrete. Grossman v. Sea Air Towers betterment defense construction Ltd., 513 So criteria, you discover that the doesnt., you discover that the car doesnt work as promised and needs repairs to be functional house... However, the 4th District Court also discussed in detail the application of the 's... Example: a designers set of plans showed sanitary sewer extending out feet... 869. an improvement of property other than by mere repairs or help with your construction contracts! V. Redlick,10 a summary trial was held to assess the extent of the author and not Martindale-Hubbell 4.00 % of...

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