Case 3:03-cv-00977-CFD Document 79 Filed 05/05/2006 Page 1 of 3
UNITED STATES DISTRICT COURT
DISTRICT OF CONNECTICUT
WENDELL HARP and : ‘
ARCHITECTS E`NVIROl\’l3./EENTAL :
COLLABORATIVE INTERNATIONAL, PC., 2
; CASE NO: 3:03CV9'/7(CFZD)
Plaintiffs, 1
v.
JOHN DeSTEFANO,
CITY OF NEW HAVEN and :
NEW HAVEN BOARD OF EDUCATION, :
Defendants.
: MAY 4, 2006
SUPPLEMENTAL DECLARATION OF CLAUDE WATT
I, CLAUDE WATT, state under the pains and penalties of perjury as follows:
i. I am over the age of eighteen (18) and understand my obligations when rnaking a
statement to this Court under the pains and penalties of perjury.
2. I was the Program Manager for the Prince—Welch School.
3. The contract awarded by the Board of Education on May 27, 2003, was for
$1,374,500. The proposed contract that I negotiated with Architects Environmental Collaborative
International, P.C. ("AECF’) for the redesign work for the Prince—Welch Schoot was for this
sarne amount- $1.,37-4,500. Under the contract that ABCE had with the School District for the
redesign ofthe Prince~·Welch School, AECI had been paid for the schematic design documents
andthe design development documents for the school. Under the proposed contract for the
redesign ot` the school with AECI, AECI would have been paid again for the schematic designs
and the design deveioprnent documents for the new school. in addition, AECI would have been
paid for a number of tasks that were inctuded in its original contract, but for which it was not
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Case 3:03-cv-00977-CFD Document 79 Filed 05/05/2006 Page 2 of 3
paid under its original contract, including preparation of construction documents, construction
administration, additional design services and consuitanfs services that had not been performed
under the oid contract. The proposed contract with AECI for the redesign work was not for
$700,000.
The foregoing statements were made under the pains ` ' of perjury.
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Claude Watt i __.¢~·
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Case 3:03-cv-00977-CFD Document 79 Filed 05/05/2006 Page 3 of 3
CERTIFICATE OF SERVICE
Ihereby certify that on May 5, 2006, a copy of the foregoing was tiled electronically [and
served by mait on anyone unable to accept electronic tiling]. Notice of this tiling will be sent by
e—mail to ai} parties by operation of the Couxt’s electronic tiling system [or by mailto anyone
unable to accept electronic tiling].
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