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IN RE: SKANSKA USA CIVIL SOUTHEAST, INC. AND 

SKANSKA USA, INC. EXONERATION FROM OR 

LIMITATION OF LIABILITY DIRECT FILING SHORT 

FORM1

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

JUDGE ROGER VINSON 

CLAIM IN LIMITATION--JOINDER IN CLAIM AND MASTER ANSWER— DIRECT 

PROPERTY DAMAGE CLAIM - INTERVENTION AND JOINDER IN MASTER 

COMPLAINTS – CLAIMANT PROFILE FORM 

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 [_____] and/or intervene into, join, and otherwise adopt the Master Claim [ ] 

Last Name First Name Middle Name/Maiden Suffix 

Phone Number E-Mail Address

Address City / State / Zip 

Name of Property Owner(s) Type of Property (Residence/Business/Other) 

Contact Name Type of Business if applicable 

Physical Address of Damaged/Destroyed Property Current Mailing Address of Property Owner 

City / State / Zip City / State / Zip 

Attorney Name Firm Name 

Address City / State / Zip 

Phone Number E-Mail Address

See Page 3 provides a listing fopr your selection of the involved Construction Barges by Original LLA and Number. 

Claim Type (Please check all that apply): 

□ Destroyed or Damaged Physical Property

□ Other:____________________________________________ 

1

 All Limitations proceedings were consolidated before Judge 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. 

#66 #60

City of Pensacola

850-435-1603

222 W. Main Street Pensacola, FL 32502

City of Pensacola Governmental

Heather Lindsay Governmental

222 W. Main Street

Pensacola, FL 32502

Bayfront Parkway

Pensacola, FL 32502

J. Michael Grimley, Jr. Galloway Law Firm

118 E. Garden Street Pensacola, FL 32502

850-436-7000 JMGservice@gallowaylawfirm.com

X

Case 3:20-cv-05980-MW-MJF Document 1039 Filed 05/03/21 Page 1 of 3
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1. Describe the physical damage to property you are claiming. Provide as much detail as possible as to the physical structures damaged or

2. If you checked “other” as your claim type, please describe the injury, as well as how and when it was sustained.

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 

Print Name 

Date 

Brief Description: 

destroyed.

The investigation into the nature and extent of damage to the property of the City of Pensacola is ongoing. However, it is currently

known that four barges owned by Skanska broke loose from their moorings in Pensacola Bay and ran aground on the property of the

City of Pensacola. The known damages resulting from the barge emplacement and/or barge removal activities of Skanska and/or its

contractors, include three damaged stormwater outfall pipes and headwalls and cracked and broken concrete along the headwall. The

damages include multiple areas along the sidewalks that are undercut due to the erosion of the slope face. The Gabion mattresses are

now exposed and the metal caging is torn due to the heavy equipment used to remove the barges. The estimated cost for remediation of

the damaged property exceed $500,000. This estimate may be supplemented as more damage is discovered. 

 

/s/ J. Michael Grimley, Jr.

J. Michael Grimley, Jr.

05/03/2021

Case 3:20-cv-05980-MW-MJF Document 1039 Filed 05/03/21 Page 2 of 3
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Select the Skanska Construction Barge that impacted your property, if you are uncertain of the identity of the particular 

construction barge involved, check “uncertain.” 

Barge # 

2 The Skanska Exoneration and Limitation Complaint at 3:21-CV-00056 [Doc. 1] lists Barge KS 6013, however, the three 

attachments [Doc. 1-1, 1-2 and 1-3] concern Barge M 8002. 

3 The Skanska Exoneration and Limitation Complaint at 3:21-CV-00057 omits Brown and Adams as potential claimants 

impacted by Barge M 8021, however, it is believed the Brown and Adams claimants were impacted by Barge M8021.

4 The Skanska Exoneration and Limitation Complaint at 3:21-CV-00062 includes Brown and Adams as potential 

claimants impacted by Barge M 8033, however, it is believed the Brown and Adams claimants were impacted by Barge 

M8021.

□ KS 5531

□ 460007

□ CBR 758

□ KS 6011

□ KS 6010

□ 470037

□ M 8026

□ KS 1453

□ KS 4004

□XKS 4015

□ KS 5533

□ 460005

□ 470027

□ KS 6013

□ 471205

□ M8002

□ M 8021

□ U 1511

□ U 1506

□ U 1505

□ M 8033

□ MCD 360

□ Uncertain

Case 

3:20-cv-5980 

3:20-CV-5981 

3:20-RV-5982 

3:20-CV-5983 

3:20-CV-5984 

3:21-CV-0044 

3:21-CV-0045 

3:21-CV-0047 

3:21-CV-0048 

3:21-CV-0050 

3:21-CV-0051 

3:21-CV-0052 

3:21-CV-0053 

3:21-CV-0054 

3:21-CV-0055 

3:21-CV-00562

3:21-CV-00573

3:21-CV-0058 

3:21-CV-0060 

3:21-CV-0061 

3:21-CV-00624

3:21-CV-0063 

Please see attached as Exhibit "A".

Case 3:20-cv-05980-MW-MJF Document 1039 Filed 05/03/21 Page 3 of 3