Robert C. Davis, Jr. - Page 7

                                         -7-                                          
          order to maintain the insurance required by the custom house                
          contract.                                                                   
               The workmanship in constructing the custom house was gener-            
          ally poor.  In addition, during construction of the custom house            
          Mona Builders (1) used in certain structural components of that             
          house materials that were inferior to those required by the                 
          custom house contract and (2) failed to install certain other               
          required structural components.  (We shall refer to the inferior            
          and missing structural components as the structural defects of              
          the custom house.)  As a result of the structural defects of the            
          custom house, the custom house was structurally unsound.                    
               On or about August 29, 2001, petitioner and Ms. Davis moved            
          into the custom house.  Thereafter, at the request of petitioner            
          and Ms. Davis, Mona Builders continued to perform services in               
          connection with finishing and repairing the custom house.  On or            
          about September 25, 2001, Mona Builders stopped work on the                 
          custom house.                                                               
               Sometime after petitioner and Ms. Davis moved into the                 
          custom house, petitioner discovered the structural defects of the           
          custom house.                                                               
               In October 2001, Mona Builders commenced litigation in the             
          Circuit Court for Anne Arundel County, Maryland (Maryland Circuit           
          Court) against petitioner and Ms. Davis with respect to the                 
          custom house (custom house litigation) in which it sought payment           






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