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 [Dkt. 66 ] and/or intervene into, join, and otherwise adopt the Master Claim

[Dkt. # 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-MW-MJF Document 1040 Filed 05/03/21 Page 1 of 5
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

Thiengtrong

First Name

Anek

Middle Name/Maiden

Suffix

Phone Number

562 499 9150

E-Mail Address

Vince2534@gmail.com

Address

4301 Creighton Rd # 139

City / State / Zip

Pensacola, FL 32504

Is this an Individual Claim or a Business Claim?

Individual claim

If this is an individual claim, complete the following:

Name

Anek Theingtrong

Occupation

Works at Flounders on Pensacola Beach

1

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Address

4301 Creighton Rd #139

City / State / Zip

Pensacola, FL 32504

Last 4 digits of your Social Security Number

If this is a business claim, complete the following:

Business Name

Type of Business

Address

City / State / Zip

Last 4 digits of your Tax ID Number

Attorney Information

Attorney Name: Joseph A. Zarzaur, Jr.

Firm Name: Zarzaur Law, P.A. 

Address: 100 Palafox Place

City / State / Zip: Pensacola, FL 32502

Phone Number: 850 444 9299

E-Mail Address: service@zarzaurlaw.com

Claim Type

Claim Type– Other

Brief Description

2

Case 3:20-cv-05980-MW-MJF Document 1040 Filed 05/03/21 Page 3 of 5
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.

n/a

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

complete discovery in 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 claimaints’ 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.

Claimant’s economic and non economic damages are still growing. 

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-Hurrican 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 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 claimaints’ 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 deadline. 

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.

On 2/28/2021, at approximately 10:30 PM, Mr. Thiengtrong was driving from Pensacola to his place of work on 

Pensacola Beach. Because the bridge had collapsed, he had to take the Garcon Bridge route, much like many other 

drivers. As a result of the massive amount of drivers being diverted to the Garcon Point bridge, traffic was more 

dense than it ever was before the bridge collapse. Skanska’s negligence was the proximate cause of the bridge 

collapse and was as such the proximate cause of the dense traffic on Garcon Point bridge. Due in part to the density 

of traffic caused by Skanska’s negligence, another car veered into Mr. Thiengtrong’s lane and smashed into his car 

head on. Because the traffic density was so great and because Mr. Thiengtrong never would have been on Garcon 

Point bridge at the time of the wreck if not for Skanska’s negligence, Skanska is responsible for the injuries he 

suffered. 

Case 3:20-cv-05980-MW-MJF Document 1040 Filed 05/03/21 Page 4 of 5
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.

/s/ Joseph A. Zarzaur, Jr.

Claimant or Attorney Signature

Joseph A. Zarzaur, Jr.

Print Name

May 3, 2021

Date

2

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