CONTACTS 
0201 - O-0432 0101 High-Point Schaer
020101 - Mr. Alexander B. Vollmer, P.E., Regional Manager
0202 - O-0432 0201 High-Point Schaer
020201 - Mr. Bill Ma, Phd., P.E., Project Manager
0203 - O-0432 0202 High-Point Schaer
020301 - Mr. Roy I. Kim, Engineer

SUBJECTS
HPS, CSCJ, Internal meeting
Summary

0404 -
0404 -    ..
0405 - Summary/Objective
0406 -
040601 - Follow up ref SDS 4 0000.
040602 -
040603 - HPS will propose improved coordination between counsel and HPS staff,
040604 - per ref DCP 1, during the meeting with NW next week.
040606 -  ..
040607 - The Claim #15 opinion, ref OF 1, shows the administrative claim record
040608 - contains the information needed to develop HPS opinion in the case.
040609 - Bill feels it should be presented to counsel.
040611 -  ..
040612 - Alex feels Rod's proposed recommendations to counsel re deposition
040613 - support and use of admin claim record are repetitious, and constitute
040614 - legal management that exceed HPS scope.
040616 -  ..
040617 - Other issues were not discussed due to limited time.
040618 -
040619 -
0407 -

SUBJECTS
HPS, CSCJ, Internal meeting
Coordination with Counsel
Deposition support

0805 -
080601 -  ..
080602 - Recommendations to Counsel Exceed HPS Scope
080604 -  ..
080605 - Alex and Bill objected to the recommendations set out in memo,
080606 - ref DCP 2 (memo of SDS ref 3), re deposition procedures and developing
080607 - coordination with counsel, on the grounds of repetition.
080609 -  ..
080610 - Alex said he and Bill have presented in prior meetings with counsel
080611 - the views contained in memo ref DCP 2, and that counsel has failed to
080612 - accept such recommendations.  As a result, he feels it is not
080613 - worthwhile to pursue it further.
080615 -  ..
080616 - Bill was concerned about the characterization in the memo of
080617 - "misleading" regarding counsel's reported evaluation of HPS questions
080618 - for the McFarland depostion as "helpful."  He analagized this as a
080619 - student rejecting a professor's grade of "A" on a school assignment.
080621 -  ..
080622 - I cited the grounds set out in the memo (see ref SDS 3 lines 04060307
080623 - 04060319).  HPS is not a student, but rather is an "expert," with the
080624 - express task to offer its opinion to counsel on matters within its
080625 - expertise.
080627 -  ..
080628 - Deposition questions can be "helpful" without being as helpful as they
080629 - should be in light of the information known or believed can be
080630 - adduced from a deponent.  In this limited sense, the term "helpful"
080631 - can be correct, yet misleading.
080632 -
080633 -
080634 -
0807 -

SUBJECTS
Writing "everything" down Not Needed to
Work Performed Shows Correct or Erroneous Understandings Don't Confir
Doing Work Confirms Correct or Erroneous Understanding from Conversat
Write Everything Down Unnecessary Capture Information Important to Ob
Overkill Proactive Problem Handling Fix Small Problems Analysis Intel
Bad Management Overwhelming Tendency Good Management Culture Resists
Expedite Conversation No Time Documentation Paperwork Talking Fast an
Bad Management Overwhelming Tendency People Lazy Like to Work Fast Ea
Unnecessary Overkill Intelligence Analysis Correlations Implications

3311 -
331201 -  ..
331202 - Writing Everything Down Thinking Through Writing Objection
331203 -
331204 - Alex feels that analysis showing alignment between management guidance
331205 - and instructions presented in meetings and other discussion, with the
331206 - record of prior work, meetings, discussion and documents is
331207 - unnecessary.  He wants less time on thinking through writing to
331208 - discover correlations, implications and nuance, so there is more time
331209 - to expedite getting things done on assignments he makes.  Alex
331210 - indicated this procedure will improve productivity, because doing the
331211 - work shows communications are accurately understood, or reveals
331212 - mistakes that require correction, which can be accomplished by having
331213 - another meeting.
331214 -
331215 -     [On 891205 Alex discussed management practice of relying on doing
331216 -     the work as a practical metric of accurately understanding daily
331217 -     communication. ref SDS 5 1848
331219 -      ..
331220 -     [On 911123 Morris explained management training teaches executives
331221 -     feel good management to expedite by relying on conversation.
331222 -     ref SDS 6 1331
331224 -      ..
331225 -     [On 940609 Henry Kissinger reports daily management relying on
331226 -     conversation is an Alice in Wonderland of continual bumbling.
331227 -     ref SDS 7 4238
331229 -      ..
331230 -     [On 950426 executive training teaches top people to expedite by
331231 -     relying on conversation. ref SDS 8 4392
331233 -      ..
331234 -     [On 960205 study shows managers waste 70% of day in unproductive
331235 -     meetings because people are not prepare and this causes mistakes
331236 -     understanding in communication. ref SDS 9 5222
331238 -      ..
331239 -     [On 990527 powerful cultural forces resist overcoming ignorance,
331240 -     fear and denial that prevent good management. ref SDS 10 1233
331242 -      ..
331243 -     [On 020504 study shows communication requirements for good
331244 -     management specified in FAR, ISO, Health Care, Covey, Drucker,
331245 -     law, contract notice provisions, and 2,000 years of literacy for
331246 -     contemporaneous documentation of alignment and feedback to work
331247 -     intelligently, quickly, and accurately are ignored in government,
331248 -     business, health care, every sector. ref SDS 11 NS6F
331250 -      ..
331251 -     [On 030826 NASA chief administrator testifies before Congress that
331252 -     coporate culture resists improvement because people interpret
331253 -     requirements as suggestions rather than try to get approval for
331254 -     improvements. ref SDS 12 8K4G
331256 -      ..
331257 -     [On 040116 example corporate culture resists good management using
331258 -     feedback to verify accuracy understandings. ref SDS 13 4L5J
331260 -  ..
331261 - Alex feels NW has indicated prior efforts up until now by HPS have
331262 - been "very helpful," and so this shows improvement is not necessary.
331263 - He acknowledged it would be helpful for HPS staff to have direct
331264 - access to counsel, but that NW has indicated this is to be avoided on
331265 - this case.
331267 -  ..
331268 - Recommended consideration for presenting this matter (ref DCP 1)
331269 - during the pending coordination meeting on Tuesday.
331271 -  ..
331272 - The relationship between NW and HPS is evolving based upon
331273 - demonstrated ability to produce, and the gradual realization by NW
331274 - that certain of its positions with respect to HPS coordination are not
331275 - effective.  Several positions NW took initi- ally, have been modified.
331276 - Therefore, the mere fact HPS has advanc- ed views in various forums on
331277 - prior occassions, does not mean that continued efforts will not yield
331278 - positive results for NW and HPS.
331280 -  ..
331281 - Alex indicated HPS will present this position  ref DCP 2, at the
331282 - pending coordination meeting.
331283 -
331284 -
331285 -
331286 -
331287 -
3313 -

SUBJECTS
HPS, CSCJ, Internal meeting
Coordination with Counsel
Claim files, Claim #15

3705 -
370601 -  ..
370602 - Reported results of claim review, per Bill's request at the previous
370603 - regular progress meeting, ref SDS 1 line 210904.
370605 -  ..
370606 - Pursuant to the opinion, ref OF 1, HPS can greatly expedite its work
370607 - by seeking the admin claim record for discovering the documents needed
370608 - to evaluate the record.
370610 -  ..
370611 - Bill asked Alex to read the Claim #15 opinion  ref OF 1, prior to
370612 - attending the coordination next week.
370614 -  ..
370615 - Roy reported that NW para legals maintain they cannot find the
370616 - administrative claim files within OKA's records.  Alex indicated HPS
370617 - should be cautious in seeking "all of the information in the record."
370618 - He feels this is unrealistic.
370619 - ..
370620 - I urged that HPS recommend that counsel pursue the admin claim
370621 - record through pending depositions, subpenas, interogatories, and
370622 - re-depose K. Mayo and B. Proctor, if necessary, with the objective of
370623 - either obtaining the record, or showing that OKA grossly mismanaged
370624 - the project.
370626 -  ..
370627 - Second, even if the admin claim record was not maintained in tact by
370628 - OKA, it will exist with varying degrees of completeness within the
370629 - records of DHP, the County, and each Contractor.  HPS should there-
370630 - fore recommend that NW cull these records in order to provide a fully
370631 - assembled admin claim document sequence to HPS.
370633 -  ..
370634 - Third, I explained that if this information is provided to HPS, the
370635 - expense to the client will be significantly reduced.
370637 -  ..
370638 - The critical point is that, since OKA had a contractural duty to
370639 - determine claims, and to maintain the records on the project  each
370640 - comprises a target of opportunity for us in defending DHP.
370641 - ..
370642 - Alex feels HPS should not make such a recommendation, since it
370643 - entails legal management which is not our assignment.  He feels my
370644 - efforts toward this end are not productive and conflict with the HPS
370645 - assignment.
370647 -  ..
370648 - I pointed out that HPS need merely indicate its opinion will be
370649 - greatly influenced with respect to DHP's liability, if the record
370650 - shows, as we are beginning to believe it does  that OKA failed to
370651 - perform certain duties which affected DHP's work.
370653 -  ..
370654 - Bill indicated the Claim #15 opinion, ref OF 1, should be edited for
370655 - presentation to counsel to show how the admin claim record can be
370656 - applied.
370657 -
370658 -
370659 -
370660 -
370661 -
3707 -

SUBJECTS
HPS, CSCJ, Internal meeting
Coordination Meeting with Counsel

3904 -
390501 -  ..
390502 - Alex asked Bill to develop talking points for the coordination meeting
390503 - with counsel next Tuesday, 891031.
390504 -
390505 -
390506 -
390507 -
3906 -