Name: Raymond Garcia

Affiliation: Counsel for KBE

Location: UConn Storrs

Request Date Start: 12/12/2010

Request Date End: 12/16/2024

Details: At all times relevant hereto, the “Project” to which this request relates is the Werth Residence Hall, constructed by KBE Building Corporation (KBE) under a design build contract with UConn.
1. Provide the documentation provided to prospective bidders which defined the HVAC system for the proposed dormitory (suggested design).
2. Provide the information that supports the suggested HVAC system before the prospective bidders submitted proposals.
3. Provide the documentation that exists demonstrating that UConn’s design consultants reviewed the proposed HVAC design prior to approval after submission of the proposed design for the Project and or compared it to the suggested design.
4. Provide all documents recording the changes, modifications, alterations or adjustments to the HVAC system made after the Project was taken over from KBE.
5. Provide all records of complaints about the HVAC system and any mold or other deleterious conditions which the proposed work is intended to remediate.
6. Provide documentation indicating when the conditions were first reported and subsequently tracked.
7. Provide all maintenance records regarding the HVAC system from and after the date upon which UConn took over the operation of the HVAC system from KBE to date of this request.
8. Provide all records of the use of the rooms complied and or retained by the University after taking the Project over from KBE to date of this request. Include specifically complaints made by occupants and any record of work performed to address the complaints.
9. Provide any and all records of atmospheric conditions and weather upon which the University or its consultants relied in preparing the Van Zelm report, any report or recommendations provided by WSJ and based upon which any of UConn’s consultants based their recommendations for corrective work.
10. Provide all records of use of the rooms of the Project from and after the date UConn took the building over from KBE.
11. Provide all records of the consideration and or analysis of the proposed remediation plan and alternates considered by UConn.
12. Please provide the information requested in the letter dated October 3, 2024 From KBE to Mr. Vollaro,

Notes: