Barbara Ann Tudyman - Page 6

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          December 5, 1989, he estimated that replacing the foundation                  
          would cost from $90,000 to $130,000, and that chemical adhesive               
          injection would cost about $30,000.  On December 20, 1989, Cook               
          estimated that foundation repairs would cost from $30,000 to                  
          $150,000.  Petitioner submitted Cook’s estimate to USAA.                      
               c.   Construction Management Associates and Frank Lewis                  
               The Homeowners’ Association hired Construction Management                
          Associates (CMA) to oversee the repair of damage caused by the                
          earthquake.  Frank Lewis (Lewis) worked for CMA.  Lewis is a                  
          civil engineer and a land surveyor.  He has extensive knowledge               
          of earthquake damage.  He examined 40 to 50 homes damaged by the              
          Loma Prieta earthquake.                                                       
               Lewis first inspected petitioner's unit on December 8, 1989.             
          He investigated whether the house was safe after the earthquake.              
          At trial, he said that a foundation has serious problems if it                
          has 20 or more cracks.  He said that the foundation for                       
          petitioner’s home had 4 cracks wider than three thirty-seconds of             
          an inch (about the width of a nickel), and at least 25 hairline               
          cracks.  On February 5, 1990, he said that the earthquake caused              
          petitioner’s home to appear to be rotating off its foundation.                
               Graham & Kellam were structural engineers who reviewed the               
          structural adequacy of the Crestview Park units for CMA in 1990.              
          After inspecting petitioner’s home with Lewis on April 19, 1990,              
          Leslie Graham (Graham) of Graham & Kellam said that the                       
          foundation was stable.                                                        

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