Molyneux complaint-Charles Miller

Issue

Damages incurred by Client

Claims against Molyneux

Did he represent himself as a reputed architect and interior designer?

Client

·        had specific vision of home and other facilities and sought to find an architect with experience, artistry and skill  in neoclassical design who would completely design for permit and construction the home

Did Molyneux inform client?

·        he had studied at Ecole des Beaux Arts and represented himself as an Architect

Did Molyneux

• show blue prints of other projects representing that they were the level of detail client could expect with abundant detail of interior and exterior designs sufficient to provide all detail necessary for permit, bid, award and build?

Did Molyneux misrepresent  in that he;

•  Led client to believe he understood and would;
• deliver designs and construction documents in keeping with clients vision?
•  provide designs and construction documents in accordance with applicable building codes and rules and regulations of all agencies having jurisdiction over the work?
•  provide to Clients engineers detailed construction drawings for them to coordinate and incorporate   in to their engineering drawings?
• Provide required designs and construction documents in a reasonable time to allow work to progress and client to obtain early utilization and enjoyment of the facility to be constructed?

At the time of employment of Molyneux did he fail  to disclose and  did he otherwise conceal material facts?

• Not a licensed architect within the United States and Virgin Islands
• Did not have the requisite knowledge of the applicable codes and regulations
• Did not intend to perform the requisite design and architectural services
• Did not intend to follow the clients design vision

As of March 7 2008 Molyneux has failed to

• Provide designs according to clients requirements
• Failed to develop construction documents

As of March 6 Molyneux

·        has required client to employ others to develop details for construction drawings, details Did Molyneux allege they would be provided by them?

An example of unacceptable design  was proposed Office structure Air conditioning

·        located Air outlets in base counter to engineering criteria recommended by clients engineers

Were selections of finish materials for exterior of office building?

·        not as per clients vision for stone, or roofing materials