Legoland Case number #CAUSE NO. 342-275920-14 BACKGROUND FACTS 1. Legoland is the owner of a business enterprise known as the LEGOLAND Discovery Center, which leases real property located 3000 Grapevine Mills Parkway, Suite 519, Grapevine, Texas 76051-0918 (hereinafter, the “Discovery Center” or “Property”). This lawsuit arises out of construction work performed by Plaintiff at the Property. 2. In 2014, Legoland decided to expand its operations at the Discovery Center by constructing a Splash Pad at the exterior adjacent to the Property and a 1,0000 square foot addition containing a pump room, dressing rooms, and bathrooms (hereinafter, the “Project”). In this regard, Legoland tabbed its employee and agent, Rod Caskey to serve as the Project Manager and general contractor for the project. Under Mr. Caskey’s supervision of the Project, which as described herein was grossly negligent, Legoland contracted with multiple contractors to complete the Project.
In this regard, Legoland contracted with Vortex USA, Inc. (“Vortex”), who was not a licensed plumber or electrician and who failed to obtain a permit for its work, to serve as the “superintendent” and pseudo general contractor for the construction of the actual splash pad. Legoland also retained Plaintiff to serve as the “superintendent” and pseudo general contractor for the construction of the 1,000 square foot addition and concrete surrounding the splash pad (hereinafter, “Plaintiff’s Scope”). Legoland also retained James Reese dba All-Pro Electrict (“All-Pro”), whose management had close ties with Mr. Caskey, to complete the transformer and electrical panel for the Project. (KIDS PLAY ON THIS AQUATIC SPLASH PARK IN GRAPEVINE, NO ENGINEER WAS CONSULTED FOR THE TANK UNDERGROUND, vortex was not a licensed plumber or a electrician and did all of the underground work without a permit and covered it with concrete.)