UNITED STATES DISTRICT COURT 

NORTHERN DISTRICT OF FLORIDA 

PENSACOLA DIVISION 

IN THE MATTER OF IN RE 

SKANSKA USA CIVIL 

SOUTHEAST INC. AND 

SKANSKA USA, INC. AS 

OWNERS OF THE BARGE KS 

5531 PRAYING FOR 

EXONERATION FROM OR 

LIMITATION OF LIABILITY 

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ADMIRALTY RULE 9(H)

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CIVIL ACTION NO.

3:20-CV-05980 – RV / MJF

DIRECT FILING SHORT FORM

CLAIM IN LIMITATION

JOINDER IN CLAIM AND MASTER ANSWER

INTERVENTION AND JOINDER IN MASTER COMPLAINTS

CLAIMANT PROFILE FORM

Authorized by Order of the Court, Civil Action No. 3:20-cv-05980-RV-MJF, Dkt. 

No. 7.

By submitting this document, I am asserting a claim in In re Skanska USA Civil Southeast Inc. 

and Skanska USA, Inc., as Owners of the Barge KS 5531 Praying for Exoneration From or 

Limitation of Liability, Case No. 3:20-cv-05980-RV-MJF;1 adopt and incorporate the Master 

Answer [Docket #66] and/or intervene into, join, and otherwise adopt the Master Claim [Docket

#60] for damages arising from barges 460007, CBR 758, KS 6011, and KS 5531, which 

impacted the Pensacola Bay Bridge.

 1 See Dkt. No. 7, Notice to Claimants, filed 12/14/2020. To note: all Limitations proceedings were consolidated 

before Judge Rodger Vinson on February 15, 2021 [Dkt. No. 9]. This form should be filed with the U.S. District 

Court for the Northern District of Florida, 100 N. Palafox Street, Pensacola, Florida 32502, in Civil Action No. 

3:20-cv-05980 and with Defense Counsel at the following address: Kenneth H. Tribuch, Chaffe McCall LLP, 801 

Travis, Suite 1910 Houston, Texas 77002.

Case 3:20-cv-05980-LC-HTC Document 96 Filed 04/23/21 Page 1 of 6
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Short Form Joinder

IN RE: SKANSKA USA CIVIL SOUTHEAST, INC. AND SKANSKA USA, INC.

EXONERATION FROM OR LIMITATION OF LIABILITY

DIRECT FILING SHORT FORM

Authorized by Order of the Court, Civil Action No. 3:20-cv-05980-RV-MJF, Dkt. No. 7.

Claimant Information

Name

Last Name

Amberson

First Name

Scott

Middle Name/Maiden

J.

Suffix

Phone Number

850-232-4999

E-Mail Address

peglegs1@yahoo.com

Address

203 Sabine Drive

City / State / Zip

Pensacola Beach, FL 32561

Is this an Individual Claim or a Business Claim?

Individual Claim Business Claim

If this is an individual claim, complete the following:

Name

Occupation

Case 3:20-cv-05980-LC-HTC Document 96 Filed 04/23/21 Page 2 of 6
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Address

City / State / Zip

Last 4 digits of your Social Security Number

If this is a business claim, complete the following:

Business Name

Beach Bum Rental, LLC

Type of Business

Recreation

Address

203 Sabine Drive

City / State / Zip

Pensacola Beach, FL 32561

Last 4 digits of your Tax ID Number

0014

Attorney Information

Attorney Name: Sam Geisler

Firm Name: Aylstock, Witkin, Kreis & Overholtz, PLLC

Address: 17 East Main Street Suite 200

City / State / Zip: Pensacola, Florida, 32502

Phone Number: (850) 202-1010

E-Mail Address: sgeisler@awkolaw.com

Claim Type

Claim Type (Please check all that apply)

Earnings / Profit

Loss / Commuting

Expenses

Other (describe in

Question 4)

Brief Description

Case 3:20-cv-05980-LC-HTC Document 96 Filed 04/23/21 Page 3 of 6
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1. Whether you are an individual or business, for earnings/profit loss claims, please include

either your annual salary / hourly wage or your annual profit(s) in the two years before

Hurricane Sally struck the Gulf Coast on September 16, 2020.

2018 - Approximately $65,000.

2019 - Approximately $85,000.

During the March 18, 2021 status and scheduling conference, the Court expressed a preference

to complete discovery in two separate phases. Specifically, the first phase of discovery would

focus on issues relevant to jurisdiction and the limitation of liability actions. Thereafter,

following a trial on these limited issues, the parties would turn to discovery relating to

claimants’ damages. To the extent that claimants are still calculating their damages, the

calculations and underlying documentation will be the subject of the damages phase of this

litigation.

2. If you claim lost earnings/profits/income, please state the approximate amount of loss you

have experienced since the Pensacola Bay Bridge closed on September 16, 2020.

Approximately $10,000.

Claimant claims damages for past and future economic losses as a result of Skanska’s

negligence. Because the Pensacola Bay Bridge has not yet been repaired, Claimant’s economic

losses are continuing and will continue in the future beyond the claim deadline until such time

as the bridge is repaired and fully operational at the pre-Hurricane Sally level of traffic flow.

The aggregate value of claims arising from the bridge outage necessarily exceeds the aggregate

value of all barges that Skanska alleges struck the bridge. During the March 18, 2021 status

and scheduling conference, the Court expressed a preference to complete discovery in two

separate phases. Specifically, the first phase of discovery would focus on issues relevant to

jurisdiction and the limitation of liability actions. Thereafter, following a trial on these limited

issues, the parties would turn to discovery relating to claimants’ damages. To the extent that

claimants are still calculating their damages, the calculations and underlying documentation

will be the subject of the damages phase of this litigation. The past economic losses sustained

by Claimant are approximate and quantified from September 16, 2020 until the date of the

claim.

3. If you claim commuting expenses, please state the approximate increase in commuting

expenses that you attribute to the Pensacola Bay Bridge Outage.

N/A

4. If you checked “other” as your claim type, please describe the injury, as well as how and

when it was sustained.

Case 3:20-cv-05980-LC-HTC Document 96 Filed 04/23/21 Page 4 of 6
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N/A

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By signing this form, Claimant agrees to share the information provided above and any accompanying documents with the 

Defendants in Case No. 3:20-cv-05980-RV-MJF. 

Claimant or Attorney Signature 

E. Samuel “Sam” Geisler

Print Name 

Date 

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