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Forensic Engineers and Associates, Inc.

Gulf Coast Metals, Inc. v. Crane Structures, Inc.


Affidavit of Oswaldo Jose Russian Aranda
THE STATE OF TEXAS

COUNTY OF HARRIS

Before me, the undersigned authority, on this day personally appeared Oswaldo Jose Russian Aranda
who under oath said:

1. My name is Oswaldo Jose Russian Aranda. I have never been convicted of felony, and I am
competent to make this affidavit. I have personal knowledge of the matters contained in this
affidavit, and they are true and correct.
2. The affidavit is submitted pursuant to the requirements of TEXAS CIVIL PRACTICE AND
REMEDIES CODE 150.002, with respect to the structural design provided by Crane
Structures, Inc. for Gulf Coast Metals, Inc. located at 1234 Any Street, Houston, Texas.
3. I am a licensed professional engineer in the State of Texas, I am competent to testify, and I am
actively engaged in the practice of structural engineering. A true and correct copy of my resume is
attached hereto as Exhibit A.
4. Based on my experience in the industry, Forensic Engineers and Associates, Inc. was retained
on this case to Evaluate Structural Integrity of the A Frames Supporting 40 Ton Bridge
Crane, hereinafter called the Project.
5. As shown in my attached resume, I am licensed to practice structural engineering, and have for the
past 30 years, been actively engaged in providing structural engineering services for clients similar
in nature and geographic location to the referenced Project.
6. Based on my education and professional experience, I have personal knowledge of the acceptable
standards for the practice of structural analysis, design and construction of crane structures in
the State of Texas and the greater Houston area which was the task to be provided by Crane
Structures, Inc. on this project.
7. I have reviewed the following documents relating to the Project and the services provided by
Crane Structures, Inc.
a. Front-View Drawing of the Crane Frame (dated 01/01/1990)
b. Project Manual, Geotechnical Reports, Material Testing Reports, Shop
Drawings, Construction Logs and Site Observation Reports
8. Based on my education, experience and review of the documents listed above, it is my
professional opinion that Crane Structures, Inc. is responsible for at least the following acts,
errors and/or omissions that exist on the Project:
a. The elements selected by the EOR for the top of the A Frame had yield and
ultimate stresses that were in certain cases below the stresses exerted on them as a
consequence of the applied loads. Note that this is without taking into account any
magnification factors for the loads or reduction factors for the allowable stresses.
That is, this observation is independent of any applicable codes and represents a
physical reality. Since codes introduce conservatism to designs in order to guarantee
safety, it is considered that the elements selected by the EOR would not satisfy the
criteria of any code. Indeed, they do not satisfy the minimum requirements imposed
by the laws of physics. It is hypothesized that this may have occurred because the

3225 W OODLAND PARK DRIVE, HOUSTON, TC 77082


Affidavit of Oswaldo Jose Russian Aranda
Gulf Coast Metals, Inc. v. Crane Structures, Inc.

Page 2 of 2

EOR wrongly estimated the applied loads, which is one of the most critical tasks in
the practice of structural engineering.
9. The acts, errors and/or omissions show that Crane Structures, Inc. failed to meet the applicable
standard of care for structural design professionals
10. My investigation is ongoing, and further examination may lead to the discovery of additional
negligent acts, errors and/or omissions in the work performed by Crane Structures, Inc. As a
result, I reserve the right to supplement and/or expand my opinions and conclusions with respect
to the performance of Crane Structures, Inc.

Further affiant sayeth naught.

Signature ___________________________

Name Oswaldo Jose Russian Aranda

Subscribed and sworn to before me by the said Oswaldo Jose Russian Aranda, on this the 29th day of
November 2016 to certify which witness my hand and seal of office.

___________________________________

NOTARY PUBLIC IN AND FOR


THE STATE OF TEXAS

My Commission Expires: ___________________