G21 Base Damages — Blue Volume 05¶

PART A — Purpose and Scope¶

Blue Vol 05 ("G21 Base Damages") is the receipt-anchored, category-based damages model for the G21 flood loss and its direct aftermath.

This page is the attorney-facing entry point to: - How Blue is organized - Where the math lives - Where the evidence inventories live - How to cite Blue outputs without duplicating the underlying schedules

Scope boundaries (discipline): - Blue is base / out-of-pocket / direct-loss damages organized by category (property, housing, credit, etc.). - Blue does not attempt to do multipliers or punitive scaling (see Pink (Punitive Execution) Entry). - Blue does not attempt to price opportunity/displacement (see Red (Freeman Opportunity) Entry).

PART A.1 — G21 Base Damages at a Glance (Consensus v1.2)¶

Source: Blue Tab 002 Section 5.1.5 (locked 2026-01-07)

Scenario	Economic w/Interest	Pain & Suffering	G21 Base Total
Conservative	$3.13M	$1.14M	$4.27M
Moderate	$3.13M	$2.28M	$5.41M
Enhanced	$3.13M	$3.50M	$6.63M

Economic Composition: - Tier 1 (Documented Floor): $1,456,433 — Property, Housing, Liquidation, Transportation - Tier 2 (Working Additions): $988,499 — Business Income, Admin/Legal, Credit Impairment - Economic Principal: $2,444,931 - Interest (~28% blended): ~$685,000 - Economic w/Interest: ~$3.13M

Pain & Suffering: Per-diem model (2,278 days × $500/$1,000/counsel-gated rate). Enhanced tier requires counsel citation of comparable verdicts.

PART B — Blue Vol 05 Structure (What to Read / Where to Click)¶

B.1 Governance Tabs (Read first)¶

Blue Tab 000 — Executive Overview
Orientation: what Blue covers, what it does not cover, and how it connects to the rest of the binder.
Blue Tab 001 — Framework & Evidence Standards
"Rules of the road" for evidence intake, de-duplication, and category routing.
Blue Tab 002 — Mathematical Verification / REPL Appendix
Single source of truth for totals and interest outputs. If a number is quoted outside Blue Vol 05, it should trace here.

B.2 Category Tabs (Evidence inventories; no local math)¶

In the current Blue build, the category tabs are numbered 101–109:

Blue Tab 101 — Property Damage & Restoration (Parent)
Includes sub-tabs 101.1–101.8 for property sub-categories (receipts and inventories).
Blue Tab 102 — Business Income / Business Interruption
Blue Tab 103 — Alternative Housing Costs
Blue Tab 104 — Administrative & Operational Costs
Blue Tab 105 — Credit Impairment
Blue Tab 106 — Forced Liquidation
Blue Tab 107 — Transportation Impacts
Blue Tab 108 — Pain & Suffering (Non-Economic)
Blue Tab 109 — Health & Medical Costs

Operational rule: the category tabs are evidence-first inventories that route their totals into Tab 002. They should not become competing calculators.

PART C — Where Totals Live (and How to Cite)¶

C.1 Totals / interest outputs¶

If you need a total (or an interest-bearing total), use Blue Tab 002.
Blue Tab 002 is designed to sum category totals and apply the interest posture used for Blue Vol 05.

C.2 Citation templates (practical)¶

Use the patterns below when drafting correspondence, pleadings, or settlement summaries that quote Blue outputs.

Template 1 — Full Blue total (with interest posture pinned)

"Blue Vol 05 total per Blue Tab 002, using AS_OF_DATE = [YYYY-MM-DD], with interest applied per Tab 002's configuration."

Template 2 — Category subtotal (paired with evidence location)

"Category subtotal per Blue Tab 002, Category [101–109] (see evidence inventory at Blue Tab [same number])."

Template 3 — Evidence support (no dollars)

"Supporting receipts/inventory are organized at Blue Tab [101.x / 102 / 103 / …], with line-item identifiers and exhibit hooks."

PART D — Open Items & Caveats¶

These notes flag categories with pending work or time-sensitive considerations.

D.1 Tab 101.8 is a staging / placeholder area¶

Blue Tab 101.8 ("Storage Unit Property Damage") is explicitly marked as in development and contains placeholder estimates pending receipt-level capture.

For counsel onboarding: treat 101.8 as staging until replaced by a finalized inventory and integrated totals.

D.2 Alternative housing is inherently time-sensitive (incurred vs continuing)¶

Blue Tab 103 is structured as a housing-cost schedule and is marked as ongoing.
Any external citation of housing figures should distinguish between: - Incurred to date (documented spend), and - Continuing / projected costs (post-AS_OF_DATE), which should be treated as updateable until counsel selects a cut-off.

END — G21 Base Damages — Blue Volume 05 v1.0