PPT Slide
18. It is the opinion of the Structural Consultant that the Decks need immediate attention (life safety concerns). There is immediate potential for the failure of the Deck planks, support joists and stringers, metal fasteners and joist hangers, piling attachments and guardrail elements. Serious if not fatal injuries could occur if immediate repair is not made.
19 . Despite the strong warnings of the Structural Consultant, the Association, led by President & Defendant Rosso, decided to merely perform remedial work on the Decks (i.e. flipping over the boards) .
20. The Structural Engineer concluded that the remedial work implemented by the Association was completely insufficient and left the same life threatening deficiencies in the Decks.
21. To date, despite professional advice to remedy the Decks to a safe state, Defendants have decided to ignore the problem (with the Decks) in willful disregard of the human rights, safety, and property of its members, including the Plaintiffs.