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236. Plaintiffs have suffered damages as a result of JNJ's and Brennan <br /> Properties' breaches of statutory home improvement warranties. <br /> 237. To the extent these damages can be measured, they include at least the cost <br /> of repairs necessary to correct the defects to the Property. Recovery of reasonable <br /> damages in an amount greater than $50,000 is sought. <br /> COUNT XVII (JNJ, Brennan Properties, and Brennan) <br /> Contractor Negligence <br /> 238. Plaintiffs restate and re-allege all preceding paragraphs of this Complaint as <br /> if fully set forth herein. <br /> 239. In agreeing to complete repairs on the Property, including major structural <br /> repairs, JNJ, Brennan, and Brennan Construction undertook a duty of care to perform <br /> such work competently and without major defects, and consistent with the standards of <br /> contractors within the community. <br /> 240. Plaintiffs have discovered substantial defects in the Property caused by <br /> faulty workmanship and defective materials, noncompliance with building standards, and <br /> major construction defects, as well as faulty installation of heating and cooling systems. <br /> 241. The substantial defects Plaintiffs have discovered include, but are not <br /> limited to, improper grading around the improvements on the Property, inadequate <br /> moisture abatement measures in the home, the connection of a gas range to a propane <br /> line, the installation of a dishwasher without a drainage line, and the installation of an <br /> HVAC system that is inadequate for reasons including the fact that the ductwork was <br /> filled with trash and construction debris. <br /> 36 <br />