Free Answering Brief in Opposition - District Court of Delaware - Delaware

Case1:04-cv-00163-GIVIS Document188-3 Filed 08/24/2006 Page1of1
Ellen Cavallaro
. · Page 6
1 Q. Same question. The copy to Matthew E. Lubin, §
2 who is he?
3 A. He would be —— I don’t know the title, but he §
4 would be a supervisor to Waiter Norris, and so would Gary
5 aispaii. § y
9 Q. it starts out by stating, "Donald Durkin was
7 low (very low} on their 4/2," April 2 bid for the City of i
9 Newark project. i
9 Is it customary for your underwriters to
$9 worry about a contracter's bid being too low? g
ll A. If they feei that there is a significant g
12 spread, they will ask additional questions, yes.
19 Q. Why is that a concern? i
14 A. They want to assure themselves that there was i
19 no mistake ia the bid, that there was no simple i
16 mathematical error or something ot that kind, or a i
17 failure to consider ail of the circumstances regarding
@9 performing the work.
29 Q. Is there some concern that the contractor is i
22 bid too low just to get the job and they are iooking for 5
21 their profit in the change orders to come? E
22 MR. BOLGER: Objection to the form.
29 MR. KINGSLEY: Same objection. §
24 BY MR. corrastt: §
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Corbett & Wilcox
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Case 1:04-cv-00163-GMS

Document 188-3

Filed 08/24/2006

Page 1 of 1