Mr. Paul D. Ferreira CM, CS
Lebanon, CT 06249
Construction experience
Mr. Ferreira is the owner and general manager of Eleuthera Associates, LLC. and PDF Construction
Co. Inc. He has over 43+ years of “hands on” experience in construction, project management,
estimating, safety, and cost management related to municipal and state, heavy and highway
construction, as well as institutional, commercial, and residential construction.
Mr. Ferreira’s possesses in-depth construction experience in excavation, grading, concrete
construction, streetscapes, underground utilities (sewer, drainage, and water), roadway and
parking lot construction and improvements (landscaping, sidewalks, ramps, grading, paving, and
walls), building site excavation, guardrail and fencing, highway and street lighting, traffic
signalization, landscaping, roadway signage, pavement striping, traffic control in work zones, DOT
traffic control and permitting requirements and pedestrian safety, and more.
Mr. Ferreira has established expertise in:
✓ Safe and unsafe operational means and methods practiced in the construction
industry
✓ Safe and proper operation of heavy equipment, tools, and trucks
✓ Roadway accidents caused by defective pavements and/or other infrastructure
deficiencies.
✓ Construction-related accidents: public, commercial, private, and residential
✓ OSHA rules and regulations pertaining to the construction industry
✓ ADA requirements pertaining to walking surfaces and ramps
✓ Slips, trips, and falls resulting from defective pavements and ramps
✓ Work zone and site safety requirements
✓ Pedestrian safety in work zones and finished pavements
✓ American Traffic Safety Services Association (ATSSA) safe traffic management guidelines
✓ Work zone traffic safety procedures and maintenance and protection of traffic requirements
✓ Construction industry standards
✓ Construction project plans, details, schedules, and specifications
✓ Defective materials and poor workmanship claims
✓ Personal injury and damages resulting from negligent operations
✓ Soil erosion, flooding, and other property damages resulting from poor workmanship or
negligence
✓ Predictive site sequencing analysis
✓ Analysis of predictive worker and equipment movements
✓ And many other areas
Mr. Ferreira possesses diplomas in Construction Management and Construction Safety, as well as a
variety of industry-specific certifications.
He is highly experienced in not only the customary documentation, procedures, and
communications used in the construction industry, but also applicable industry standards and
methods.
Expert witness experience
Mr. Ferreira possesses over 43+ years of daily “in the trenches” field experience that provides him
the ability to objectively analyze a case based on practical experience, complemented with
theoretical knowledge. His practical experience is what sets him apart from most other experts in
this field.
Over decades, Mr. Ferreira has witnessed established and questionable practices performed. This
exposure, combined with his practical experience and expertise, has helped numerous clients
settle cases. He is available to consult with law firms in all 50 states.
Mr. Ferreira has been retained and consulted on a variety of cases since 2008. He has provided
his expertise to Plaintiff and Defendant clients alike in cases relating to:
▪ Defective pavements resulting in motor vehicle and motorcycle accidents
▪ Pavement and walkways slips, trips, and falls resulting in pedestrian injuries
▪ Worksite and safety practices resulting in worker injuries
▪ Roadway work zone accidents resulting in worker injuries
▪ Heavy equipment operation
▪ Loading and off-loading of construction materials resulting in injuries
▪ Personal injury due to lack of work zone pedestrian safety measures
▪ Worker injury due to temporary stair collapse
▪ Defective materials and installations
▪ Property flood damage resulting from negligent maintenance
▪ Concrete mixer operation resulting in worker injury
▪ Premises damage and claims due to defective workmanship
Services offered
▪ Consultation
▪ Document review
▪ Assistance with deposition questions
▪ Analysis and research
▪ Opinions and reports
▪ Expert testimony
▪ Drone site photography
- Accident Investigation
- Americans with Disabilities Act (ADA)
- Concrete/Cement
- Construction
- Construction Damages
- Construction Safety
- Construction Site
- Demonstrative Evidence/Exhibits
- Equipment & Machinery
- Labels & Warnings
- Lost Profits
- Materials
- Personal Injury
- Photography
- Real Estate Damages
- Slip, Trip & Fall
- Traffic/Highway Safety
- Transportation Construction
- Utilities
- Video
- Walking & Working Surfaces
- Q: Please list your professional accreditations, degrees, licenses, and certificates granted:
- A: State of Connecticut Licensed Sewer, Water and Drainage Contractor. License #PLM.0208491-P7
Construction Management Diploma
Construction Safety Diploma
OSHA 30 Certification
New York 811 Excavator Training & Education Certificate Program
Accident Investigation Reporting Training Certificate Program
Confined Space Training Certificate Program
Pipeline Emergency Response and Damage Prevention Training Programs Certification
Certified Traffic Director: ATSSA Certification
Previous Concrete Technician Certification
ARTBA FHWA - Work Zone - Speed Management Certification
Asphalt Institute - Understanding Pavement Distress Certification
360 Training - Materials Handling & Storage Safety Certification
Compliance Training - Construction Signs, Signals and Barricades Certification
360 Training - Excavator Operator Safety Training Certification
360 Training - Excavation Safety in Construction Certification
Hard Hat Training - OSHA Concrete Truck Certification
360 Training - Walking and Working Surfaces Certification
- Q: Please list your affiliations or memberships in any professional and/or industry organizations:
- A: Life long member of the International Union of Operating Engineers
- Q: Have any of your accreditations ever been investigated, suspended or removed? (if yes, explain)
- A: No
- Q: On how many occasions have you been retained as an expert?
- A: Upon request
- Q: For what area(s) of expertise have you been retained as an expert?
- A: Construction site accidents resulting in personal injury
Slip and falls from defective pavements, resulting in personal injury
Heavy equipment accidents resulting in personal injury
Defective workmanship claims
Materials and installation analysis
Soil erosion and subsequent property damage
Concrete construction defect analysis
Temporary stair collapse
Pedestrian trip and fall within a work area
Workers run over by heavy equipment
Slip and falls
Tripping hazards
Pedestrian Safety on public sidewalks
Worker safety
Utility construction
Safe hoisting and movement of construction materials and equipment
Unsafe off-loading of trailers
Failure to safely secure work area
Fatal steel erection accident
Construction worker manhole injury
Concrete mixer driver injury
Roadway work zone accident - Q: In what percentage of your cases were you retained by the plaintiff?
- A: Approximately 75%
- Q: In what percentage of your cases were you retained by the defendant?
- A: Approximately 25%
- Q: On how many occasions have you had your deposition taken?
- A: Upon request
- Q: When was the last time you had your deposition taken?
- A: 9/27/2022
- Q: For how many years have you worked with the legal industry as an expert?
- A: 16
- Q: What services do you offer? (E.g.: consulting, testing, reports, site inspections etc.)
- A: Document Review
Site Inspections
Research
Opinions/Reports
Consultation
Reconstruction: photo, videographic, and physical mockup representations - Q: What is your hourly rate to consult with an attorney?
- A: Upon request
- Q: What is your hourly rate to review documents?
- A: Upon request
- Q: What is your hourly rate to provide deposition testimony?
- A: Upon request
- Q: What is your hourly rate to provide testimony at trial?
- A: Upon request
- Q: Please list any fees other than those stated above (E.g.: travel expenses, copy fees, etc.)
- A: Upon request
Upon request, depending on the type of case