This newsletter from the Construction Law Committee discusses various topics: - The vice chair provides a leadership note encouraging more involvement from committee members to strengthen the team. - An article summarizes three approaches to incorporating weather days into construction schedules: modifying work calendars, increasing activity durations, or adding an adverse weather activity. - An article discusses an Illinois appellate court ruling that allows construction defendants to introduce evidence that a settling defendant was the sole proximate cause of the plaintiff's injury. - A brief announcement promotes the committee's partnership with the National Association of Women in Construction.

1. The Critical Path
The newsletter of the
Construction Law Committee
Committee Leadership
Chair
Diana M. Gerstberger
Axis Insurance Company
Alpharetta, GA
Vice Chair
David L. Jones
Wright Lindsey & Jennings LLP
Little Rock, AR
Editors
Ryan L. Harrison
Paine Bickers LLP
Austin, TX
Christopher Moore Sweeney
Peckar Abramson
Washington, DC
Click here to view entire Leadership
10/18/2018 Volume 22, Issue 3
In This Issue
Leadership Note
From the Vice Chair: The Season to Get in the Game............ 2
By David L. Jones
Feature Articles
Incorporating Weather Days into Your Project’s CPM
Schedule................................................................................................ 3
By Bill Haydt and Mark Nagata
Illinois Appellate Court Ruling Is a Major Victory for
Construction Law Defendants........................................................ 6
By Brent Eisenberg
Pennsylvania’s Superior Court Does Not Extend the Rule
of Capture to Companies Engaged in Subsurface Hydraulic
Fracturing............................................................................................. 8
By Joseph J. Bosick
Announcement
DRI Construction Law Committee’s Partnership with the
National Association of Women in Construction..................... 9
By Mary Jay Torres-Martin

2. The Critical Path | Volum 22, Issue 3 2 Construction Law Committee
Back to Contents
Leadership Note
From the Vice Chair: The Season to Get in the Game
By David L. Jones
The seasons are ever-changing. For some,
these seasons are spring, summer, fall, and
winter. Others, particularly those who live
squarely within the confines of SEC country,
the seasons are measured by the sport most
widely played during a particular period in time. By that
measure, we are squarely in football season. Given that,
resort to football analogies seems mildly appropriate.
Understandably, one of the highlights of football is the tail-
gating. If you haven’t already experienced a true football
tailgate, this is a bucket list experience that you should
immediately set about realizing. One of the greatest fea-
tures of tailgating is the fact that shared allegiance to a
sports team is an almost universally accepted invitation to
interact with folks with whom you apparently have nothing
else in common. Those who have tailgated can almost cer-
tainly remember the time when the right t-shirt garnered
an unsolicited offer of their adult beverage of choice. For
fans, tailgating is a fun experience that can sometimes
seem to be the best of football. However, through all of the
variations that a tailgate can take, there is one constant.
There can’t be a tailgate without a game.
For the DRI Construction Law Committee, the metaphor-
ical “tailgate” is the many creative, fun-filled networking
events that accompany our substantive programming.
However, much like football, the substantive programming
is the main event that drives the “tailgating” opportunity.
Quietly, this Committee has assembled a team with gifted
skill players. But those who know football know that team
success doesn’t just depend on skill players. It depends
on a collective effort by folks willing to block and tackle,
sometimes with very little fanfare. Extended success
depends on the ability to recruit well and develop a deep
bench of talented players ready and willing to step in and
execute the game plan. That’s why we need you.
Football aficionados also know that donning the uniform
and stepping on the playing field deepens one’s connection
to the team and its connection and loyalty to you. If you’re
not closely engaged with our Committee, we need you to
bring your skills to the playing field by accept volunteer
opportunities and getting involved. If you are engaged,
we need you to recruit your colleagues to become
involved. There is no better way to reward yourself and
your practice.
The DRI Construction Law Steering Committee has
pivoted to marketing the 2019 Construction Law Seminar,
scheduled for April 10–12 in Las Vegas. We are also
marketing the Construction 101 Bootcamp scheduled for
November 8, 2018, in Chicago. We invite you to join those
efforts and encourage you to save the date and recruit
a friend.
David L. Jones is a partner in the law firm of Wright Lindsey
Jennings in Little Rock, Arkansas. His practice focus is
construction defect and related contract litigation, including
representation of owners, contractors, design professionals,
sureties, and suppliers. He is a contributing author to several
construction law publications. He also presents on construc-
tion topics and is an active member of the DRI Construction
Law Committee, currently serving as vice chair. He previ-
ously served as board chair of a not-for-profit residential
builder and as a board member for ACE (Architecture,
Construction, and Engineering) Mentor Program of Indiana.

3. The Critical Path | Volum 22, Issue 3 3 Construction Law Committee
Feature Articles
Incorporating Weather Days into Your Project’s CPM Schedule
By Bill Haydt and Mark Nagata
An often-debated question is “How
should a project schedule incorpo-
rate the workdays that might be
lost to adverse weather?”
While there is not one perfect
solution for all projects, there are at least three approaches
to incorporating weather into your CPM schedule. These
approaches are:
• Incorporating non-workdays into the schedule’s work
calendars to represent the workdays that might be lost
to adverse weather.
• Increasing the durations of weather-sensitive work
activities to represent the workdays that might be lost to
adverse weather.
• Adding an “adverse weather” activity at the end of proj-
ect with a duration that equals the number of workdays
that might be lost to adverse weather.
(Of course, there is always a fourth option, which is to
assume that every day lost to weather will be made up by
working on Saturdays or by working overtime. If this is the
assumption upon which both your costs and your schedule
are based, and both your contract and your other team
members are on board, then you may not have to bake any
weather into your schedule at all.)
Each of these three options (except the one in which
you do nothing to the schedule) will be discussed in more
detail below.
Incorporating Adverse Weather
Workdays in Work Calendars
In CPM scheduling software packages, users have to create
or modify work calendars that identify when the contractor
plans to work. For example, the most common work calen-
dar is an eight-hour-per-day, five-day workweek calendar
that includes holidays and weekends as non-workdays.
Each schedule activity is assigned to the work calendar
that best represents when that particular work activity will
be performed.
One way to account for adverse weather is to identify
days that would otherwise have been workdays as non-work
days in the work calendars.
The advantage of this approach is that the contractor can
show that it separately accounted for anticipated adverse
weather in its project schedule by simply referencing the
calendars that have adverse weather workdays built into
them. It also provides a somewhat realistic depiction of
when the project might incur adverse weather conditions
and, thus, may more accurately forecast the dates that work
will actually be performed on longer projects.
For example, let’s say the contract states that the contrac-
tor should plan to lose 4 workdays to adverse weather in the
month of June. The default five-day workweek calendar for
June includes no holidays and, therefore, every weekday is
an available workday (see Figure 1, below).
In this scenario, to accommodate the contract’s require-
ment to assume 4 workdays lost to adverse weather in
June, this calendar could be modified to block out 4 work-
days as non-workdays. In Figure 2, below, four of the Fri-
days in June have been identified as non-workdays.
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4. The Critical Path | Volum 22, Issue 3 4 Construction Law Committee
Another option is to create project or activity-specific
work calendars for operations that are subject to additional
working restrictions. An example of a project-specific
calendar is a weather-sensitive or winter work calendar
for activities that are subject to seasonal or winter work
limitations. In these work calendars, all of the workdays in
the winter months are identified as non-workdays in the
work calendar.
For example, let’s say that there is hot mix asphalt
(HMA) paving work required on a highway project, and the
contract requires that “no base paving (HMA) placement
will occur between November 15 and April 1 without the
written permission of the Engineer.” In this scenario, a work
calendar could be created that specifically includes these
work restrictions by marking all workdays during that time
period as “non-work” (see Figure 3, below).
The primary criticism of blocking out non-workdays in
advance for adverse weather is that no one can predict
when it will rain or snow in the future, and when work
won’t be able to occur. For example, some work that usu-
ally cannot occur during the winter can and is performed,
particularly if the winter is unusually mild. However, by
including the anticipated non-workdays due to adverse
weather in work calendars, it is possible to ensure that the
contractor’s plan, as depicted in the project schedule, pro-
vides a realistic forecast of when future work is planned to
occur by accounting for workdays that might be lost to
adverse weather in the project schedule.
Note that the success of this approach depends on
the how carefully and honestly the contractor puts the
schedule together. For example, many times the owner
does not identify the number of days that the contractor
should plan to lose to adverse weather. Even if the contract
does provide a number, the contractor may not be obli-
gated by contract to incorporate these days into its work
calendar. Lastly, contractors may address weather delays
differently from what the schedule assumes. For example,
if the contractor plans to work Saturdays or overtime to
overcome weather-related delays, then some owners might
take the position that a certain number of Saturdays should
be added workdays—in addition to blocking out workdays
for adverse weather.
Increase Durations of Weather-
Sensitive Work Activities
A second way of accounting for or incorporating
anticipated workdays lost to adverse weather into the
project schedule is to increase the durations of the weath-
er-sensitive work activities. This approach is as simple
as it sounds. By simply increasing durations for activities
that may be subject to adverse weather, those activities
will then take into account the anticipated delay from that
adverse weather.
For example, for a basic roadway project, a simple
schedule is identified in Figure 4, below. This schedule
does not take into account workdays that might be lost to
adverse weather.
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5. The Critical Path | Volum 22, Issue 3 5 Construction Law Committee
Assume that the contract for this project states that the
contractor should anticipate losing six lost workdays in
March, five lost workdays in April, four lost workdays in May,
and four lost workdays in June. Using this approach, the
anticipated lost workdays are simply added to the durations
of the work activities that fall within those respective months
(see Figure 5, below).
While this approach is probably the most direct way of
ensuring that you’ve accounted for the anticipated work-
days lost to adverse weather, it has several weaknesses.
The first criticism is that the incorporation of adverse
weather days in this manner is not always transparent
and obvious. For example, it is not always obvious if and
to what extent an activity’s duration was increased to
account for time that might be lost to adverse weather.
If transparency is important, the obvious solution to this
problem would be to identify the number of workdays that
represent adverse weather in the activity’s description
or name.
The second criticism of this approach is the need to
change the durations of the weather-sensitive activity
durations when they are delayed from one month to
another. For example, as identified above, the number of
workdays lost to adverse weather can and does fluctuate
from month to month. As such, when weather-sensitive
work activities are moved or delayed from one month to
another, which is common on construction projects, the
durations of the weather-sensitive activities would need to
be changed to reflect the number of anticipated adverse
weather workdays in the new month within which the
activity is now forecast to occur.
Said another way, if an excavation activity is delayed
from March into April, there is a good chance that the num-
ber of anticipated workdays lost to weather in April is less
than in March. If the activity’s duration includes anticipated
workdays lost to weather in March, then when the excava-
tion activity is delayed to April, it would be appropriate for
the contractor to reduce the activity’s duration to reflect
the anticipated number of workdays lost in April. However,
this sort of change in an activity’s duration, to reflect the
anticipated number of workdays lost to adverse weather
when an activity is delayed from one month to another, is
almost never done and on large projects would be difficult
to maintain on a monthly basis.
Also, it is unusual for a contract to list the number of
workdays a contractor should anticipate each month. Most
contractors do not increase the duration of work activities
based on the month the work is planned to be performed.
Rather, they use a thumb rule. For example, one contractor
client assumed that it would lose one workday in seven
to adverse weather over the life of the project. Using this
thumb rule, the contractor increased the duration of activ-
ities. Because the thumb rule was based on an average
across the entire project, there was no need to adjust
durations each month if the project was delayed.
Insert an “Adverse Weather” Activity
for All Anticipated Adverse Weather
for the Project Duration
Instead of burying anticipated adverse weather days in
the schedule work calendars or weather-sensitive activity
durations, another option would be to add an “Anticipated
Adverse Weather” activity at the end of the schedule, but
before the project’s completion milestone, to represent all
of the required anticipated adverse weather (see Figure
6, below).
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6. The Critical Path | Volum 22, Issue 3 6 Construction Law Committee
As the project progresses, and adverse weather is
encountered, the duration of this activity is reduced to
account for the amount of adverse weather that was
actually experienced on the project.
This approach is a clean way to account for anticipated
adverse weather without having to predict and select the
workdays lost to adverse weather in the schedule’s work
calendar or bury them in activity durations.
However, a significant criticism of this approach is
that on multi-year projects where “all” of the anticipated
adverse weather is included at the end of the schedule,
the schedule would fail to reasonably forecast the early
start and early finish dates for all of the work activities. For
example, for the work in the second or third year, the work
activities would be forecasted to begin much earlier than
would reasonably be expected because the first year of the
schedule would not include any anticipated workdays lost
to weather. Depending on the project type, this issue may
or may not be a problem.
Another criticism of this approach is that the added
adverse weather activity would apply not only to the
weather-sensitive work, but also to non-weather-sensitive
work, as well. This approach may be better suited for
projects with shorter durations.
When selecting a method to incorporate adverse
weather into their project schedules, contractors should
make their decision on a project-by-project basis. Taking
into consideration their contractual requirements, the type
of project being built, and the project’s location-specific
weather conditions when they develop, their baseline
schedule will help ensure that they select the best
approach for demonstrating that they’ve properly
accounted for anticipated adverse weather in their con-
struction plan.
Bill Haydt and Mark Nagata are directors and shareholders
of TRAUNER. Their expertise lies in the areas of construction
claims preparation and evaluation, development and review
of critical path method (CPM) schedules, delay analysis,
training, and dispute resolution. They direct and perform
all types of analyses from schedule delay analyses to ineffi-
ciency analyses and the calculation of damages. Bill can be
reached at bill.haydt@traunerconsulting.com. Mark can be
reached at mark.nagata@traunerconsulting.com
Illinois Appellate Court Ruling Is a Major Victory
for Construction Law Defendants
By Brent Eisenberg
A landmark opinion by the Illinois Appellate
Court ruled that construction law defendants
can introduce evidence at trial of the negligent
conduct of multiple settling defendants as the
sole proximate cause of the plaintiff’s injury.
Under Illinois’ rules of apportionment, settled parties,
non-parties and bankrupt entities are not allowed on the
verdict form. Ready v. United Goedecke Services, Inc.,
238 Ill.2d 582 (2010); 735 ILCS 5/2-117. During pre-trial
hearings Illinois plaintiffs’ attorneys frequently attempt to
manipulate this rule of apportionment by moving in limine
to exclude evidence of settling parties’ negligent conduct
at trial. The Illinois plaintiffs’ bar even termed this legal
fiction the “Lipke Exclusionary Rule.” Nolan v. Weil McLain,
233 Ill.2d 416, 437 (2009). Astute defense attorneys should
be able to successfully combat this trial tactic and prevail
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7. The Critical Path | Volum 22, Issue 3 7 Construction Law Committee
at the pre-trial hearing because the Illinois Supreme Court
has ruled that defendants can introduce evidence of
settling parties’ negligent conduct in support of its sole
proximate cause defense at trial even though such entities
are not permitted on the verdict form. Id. at 448–49.
A good example of how this issue is litigated in the
construction law context can be found in the Ready case.
Ready v. United Goedecke Services, Inc., 238 Ill.2d 582
(2010). In Ready, the plaintiff’s decedent was killed when
a scaffolding truss fell eight stories and hit him. Id. at 585.
Prior to trial, the plaintiff settled with the general contrac-
tor and the decedent’s employer. Id. The only defendant
left was the subcontractor. Id. The plaintiff filed a pre-trial
motion to exclude evidence of the settled general con-
tractor and employer’s conduct. Id. The trial court granted
plaintiff’s motion in limine and barred the defendant from
introducing evidence of the settling parties’ conduct. Id.
at 586. The jury found the defendant liable. Id. at 587. The
Illinois Supreme Court ruled that the trial court erred in
excluding evidence that would have supported the subcon-
tractor’s sole proximate cause defense at trial. Id. at 592.
Here is where things can get confusing for the con-
struction law defense practitioner. The word sole in sole
proximate cause means one, doesn’t it? Do I have to focus
during discovery on one defense theory of alternative
causation because there cannot be multiple sole proximate
causes of the plaintiff’s injury? In Ready, the general con-
tractor and the employer settled out and the subcontractor
was the only party left. What if in support of its sole proxi-
mate defense the lone remaining defendant subcontractor
in Ready wanted to present evidence to the jury of the
negligent conduct of both the general contractor and the
employer? On June 29, 2018, the Illinois appellate court
resolved this issue by ruling in the Rene Douglas case that
defendants can argue that the actions of more than one
nonparty tortfeasor was the sole proximate cause of the
plaintiff’s injury. Rene Douglas v. Arlington Park Racecourse,
LLC, et al., 2018 IL App (1st) (162962), available at http://
www.illinoiscourts.gov/Opinions/AppellateCourt/2018/1st-
District/1162962.pdf.
The Rene Douglas case involved a plaintiff who was a
professional jockey. Rene Douglas was paralyzed after
he fell from his horse during a race at the Arlington Park
racetrack. Rene Douglas and his wife sued Arlington
Park racetrack, the racetrack owner Churchill Downs, the
manufacturer of the synthetic horse racing surface Martin
Collins, and the distributor of the synthetic horse racing
surface Keeneland Ventures. Douglas settled with the
manufacturer and the distributor, and only the premises
defendants, Arlington and Churchill Downs, remained
at trial.
The plaintiffs argued at trial that Rene Douglas’ injury
was caused by the defendant’s negligent maintenance of
the track and not by any defect in the racetrack’s synthetic
surface. The premises defendants argued that the sole
proximate cause of the plaintiff’s injury was caused by
either the negligence of a non-party jockey or the negli-
gence of the settled manufacturer of the synthetic track
Martin Collins. At trial, the premises defendants presented
evidence that the conduct of a non-party jockey named
Theriot was the sole proximate cause of the plaintiff’s
injuries because Theriot’s horse clipped plaintiff’s horse,
causing the fall. The defendants also presented evidence
that the track manufacturer, Martin Collins, failed to
notify the racetrack of the need to monitor the dynamic
shear angle and vertical load of the track. The Illinois First
District Appellate Court explained that the jury could have
accepted either argument and ruled that the defendant
should be allowed to present both arguments to the jury.
The Douglas court reasoned that the “sole proximate
cause defense” or “empty chair defense” is not really an
affirmative defense because the burden is on the plaintiff
in a negligence action to prove proximate cause. Therefore,
a defendant can argue that: non-party A’s negligence
was the proximate cause of the plaintiff’s injuries, that
non-party B’s negligence was the proximate cause; or that
the negligence of non-party A and non-party B collectively,
was the sole proximate cause. According to the Illinois First
District Appellate Court so long as the defendant’s level of
contribution to the plaintiff’s injury is 0 percent, whether
100 percent of the blame falls on non-party A or non-party
B does not matter. The court explained that it does not
matter how many different parties are to blame so long as
the defendant is not one of them. The First District held
that the premises operator could present multiple sole
proximate cause defense arguments to the jury.
The First District’s ruling was in accord with Illinois
Pattern Jury Instruction 12.04 on sole proximate cause
which provides:
More than one person may be to blame for causing an
injury. If you decide that a [the] defendant[s] was [were]
negligent and that his [their] negligence was a proximate
cause of injury to the plaintiff, it is not a defense that
some third person who is not a party to the suit may also
have been to blame. However, if you decide that the sole
proximate cause of injury to the plaintiff was the conduct
of some person other than the defendant, then your verdict
should be for the defendant.
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8. The Critical Path | Volum 22, Issue 3 8 Construction Law Committee
IPI Civil 12.04 (emphasis added).
In light of Douglas, construction law defense attorneys
would be wise to develop evidence of alternative theories
of causation during discovery in multi-party actions and
present juries with more avenues to reach a defense verdict
at trial.
Brent Eisenberg is a partner with Matushek Nilles LLC. He
concentrates his practice on the defense of construction
claims, product liability, premises liability and toxic
tort claims. He is licensed to practice law in both Illinois
and Missouri. Mr. Eisenberg received the highest rating,
“AV-Preeminent” from Martindale-Hubbell Law Directory,
and was named by Illinois Super Lawyers as a “Rising Star”
in litigation in 2017 and 2018. Brent Eisenberg is a member
of the DRI Construction Law Committee and Construction
Defect Subcommittee.
Pennsylvania’s Superior Court Does Not Extend the Rule of Capture
to Companies Engaged in Subsurface Hydraulic Fracturing
By Joseph J. Bosick
In the case of first impression called Briggs v.
Southwestern Energy Production Company, No.
1351 MDA 2017 (Pa. Super. Ct. April 2, 2018),
the Superior Court of Pennsylvania held that
the rule of capture does not preclude liability
for trespass due to hydraulic fracturing.
The Briggs plaintiffs owned an 11 acre parcel of land.
Defendant Southwestern Energy Production Company
(Southwestern) is the lessee of oil and gas rights on a
tract of land adjoining Plaintiffs’ property. Southwestern
engaged in hydraulic fracturing to extract natural gas from
a Marcellus Shale Formation. The Marcellus Shale Forma-
tion was on both plaintiffs’ property and on the property
that Southwestern was engaged in fracking. Southwestern
did not have an oil and gas lease with the plaintiffs.
Hydraulic fracturing is done by pumping fluid down a
well at high pressure and it is forced out into a Marcellus
Shale Formation. The pressure creates cracks in the rock
that propagate along the natural fault lines. Behind the
fluid comes a slurry containing sand, ceramic beads, or
bauxite that lodge themselves in the cracks. The fluid is
then drained leaving the cracks open for gas or oil to flow
to the wellbore.
The plaintiffs in this case made claims of trespass and
conversion alleging that Southwestern had been extracting
natural gas from beneath the plaintiffs’ property.
The trial court applied the rule of capture and granted
summary judgment in favor of Southwestern. According
to Black’s Law Dictionary, the Rule of Capture is a funda-
mental principle of oil and gas law holding that there is no
liability for drainage of oil and gas from under the lands
of another so long as there has been no trespass and all
relevant statutes and regulations have been observed (10th
ed. 2014). In Pennsylvania, the rule of capture had long
been applied in conventional oil and gas drilling.
Plaintiffs appealed the trial court’s decision and the
Superior Court of Pennsylvania reversed the trial court and
sent the case back to the lower court for a determination
as to whether there was a trespass. Additionally, because
the superior court found that the rule of capture was not
applicable to hydraulic fracturing, the superior court said
that plaintiffs must be afforded the opportunity to develop
their conversion claim.
The Pennsylvania Superior Court held that hydraulic
fracturing is distinguishable from conventional methods of
oil and gas extraction. As the court explained:
Traditionally, the rule of capture assumes that oil and
gas originates in subsurface reservoirs or pools, and can
migrate freely within the reservoir and across property
lines, according to changes in pressure … Unlike oil and
gas originating in a common reservoir, natural gas when
trapped in a shale formation, is non-migratory in nature …
Instead, the shale must be fractured through the process
of hydraulic fracturing; only then may the natural gas
contained in the shale move freely through the artificially
created channels.
The superior court went onto say that:
… precluding trespass liability based on the rule of capture
would effectively allow a mineral lessee to expand its lease
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9. The Critical Path | Volum 22, Issue 3 9 Construction Law Committee
by locating a well near the lease’s boundary line and with-
drawing natural gas from beneath the adjoining property,
for which it does not have a lease. Such an allowance would
nearly eradicate a mineral lessee’s incentive to negotiate
mineral leases with small property owners, as the lessee
could use hydraulic fracturing to create an artificial channel
beneath an adjoining property, and withdraw natural gas
from beneath the neighbor’s land without paying a royalty.
Constructors and operators of horizontal Marcellus Shale
wells should consider the risk of trespass and/or conversion
claims when planning wellbores that are located near
property where the minerals are not leased.
Joseph J. Bosick, a partner in the Pittsburgh office of the
law firm of Pietragallo Gordon Alfano Bosick Raspanti
LLP, serves as chair of the construction practice consortium.
Joe Bosick’s phone number is (412) 263-1828 and his email
address is jjb@pietragallo.com.
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Announcement
DRI Construction Law Committee’s Partnership with the
National Association of Women in Construction
By Mary Jay Torres-Martin
DRI has recently formed a partnership with the National
Association of Women in Construction (NAWIC). NAWIC
is an organization founded in 1953 by sixteen women
working in the construction industry. The founders
organized NAWIC to create a support network for women
in Construction knowing that there were very few women
in the industry. The mission of NAWIC is to provide its
members with opportunities for professional development,
education, networking, leadership training, public service
and more.
Over the years, DRI has recognized the importance of
providing educational programs to other industry associ-
ations. This exciting partnership with NAWIC is going to
help provide their members with access to legal expertise
through our educational programs and seminars. It will
also give DRI members an opportunity to stay in touch
with industry people who have boots on the ground doing
the actual work, as well as those managing a construc-
tion organization.
There are plenty of ways to take advantage of this
partnership. As a national organization, NAWIC has
chapters in almost every State. They have regional
meetings where DRI members attend or even participate
as a speaker. This is a terrific opportunity to network with
potential clients and referral sources. Likewise, if writing
articles is your area of interest, you can get published on
NAWIC’s newsletter.
We hope that you take advantage of this wonderful
opportunity and stay involved in this mutually benefi-
cial partnership.
Mary Jay Torres-Martin
Business Development Manager
Trauner Consulting Services, Inc.
1617 JFK Boulevard, Suite 475, Philadelphia, PA 19103
215-814-6421