CONTACTS 

SUBJECTS
CSCJ, Litigation, Document Inventory

0603 -    ..
0604 - Summary/Objective
0605 -
060501 - Inventoried documents received from NW, ref DRT 1.
060502 - Discovered indication CM responsible to perform "plan check."
060503 -
0606 -
0607 - Assignment
0608 -
060801 - Bill advised HPS has received 3 boxes of documents from NW.  He asked
060802 - that I inventory the received material and examine in detail matters
060803 - that relate to Issues.
060804 -
0609 -
0610 - Received ref DRT 1.
0611 -
0612 - Document Inventory
0613 -
061301 - Generally NW transmitted meeting minutes and drawings C1.1 to 2.2 of
061302 - Contract "A."
061303 -
061304 - "Meeting Minutes" Volumes I - IX beginning 820427 to 861210.
061305 -
061306 - These "Meeting Minutes" are for official and ad hoc meetings.  Weekly
061307 - Progress meeting #90 is the last document in the series (binder IX),
061308 - but it is not clear from a cursory examination whether all "Weekly
061309 - Progress" meetings are included, or whether these are duplicated in
061310 - other assembleges eleswhere in the HPS inventory.  I did a physical
061311 - examination of the HPS binders in the lobby shelves, and did not
061312 - notice any other binder series labeled "Meetings."  This indicates NW
061313 - commingled minutes for all meetings into a single series, except for
061314 - those transmitted separately under the heading in DRT 1 item 2,
061315 - "Various Meeting Minutes;" these materials have no apparent data
061316 - structure.
061317 -
061318 - There are two other groups of documents.  One titled "Misc. Meetings"
061319 - that is bound by a rubber band.  Another is simply a group of loose
061320 - documents with no identification of any kind.  I checked and found the
061321 - top document of this group replicates one contained within the binders
061322 - identified as "Meeting Minutes."
061323 -
061324 -
061325 - Drawings C1.1 to 2.2
061326 -
061327 - These are for Contract "B" as requested by HPS letter ref DRP 1  and
061328 - and cited by NW in its letter ref DRP 4.
061329 -
0614 -

SUBJECTS
CSCJ, Litigation, Document Inventory
Issue 01103, OKA mismanagement
Issue 01203, Design Errors & Ommissions
Dispute Resolution, Fast Track

1107 -
1108 -
1109 -
110901 -  ..
110902 - DHP "CONFERENCE REPORT" 840306
110903 -
110904 - Describes results of meeting attended by Bill Proctor, who became
110905 - OKA's project coordinator, Carol Knapel, Program Manager for CSC,
110906 - and DPH staff.
110907 -
110908 -    [Note this record was applied at ref SDS 2 3890]
110909 -
110910 -
1110 -
1111 -
1112 - Affirmative defense
1113 -
111301 - Found above document indicating at para 4, that Bill Proctor who at
111302 - the time in 1984 was employed by MK, was responsible for hiring a
111303 - structural engineer to perform a "plan check" on JN's structural
111304 - drawings.  This comports with the OKA contract provision to perform a
111305 - "Constructability Review."  If DHP was relying on OKA to perform a
111306 - "plan check," as indicated in the letter, then it may be relieved of
111307 - major responsibility for dimension and other errors for which Blount
111308 - and various cross-complainants seek recovery, since it appears that
111309 - this was OKA's responsibility and not Dworsky's job.
111310 -
111311 - Para 5 describes the project as being performed under a "Fast-track
111312 - schedule" and para 2 indicates a Mr. Jay Smith was to complete a "CPM
111313 - schedule for design and construction" as soon as possible.
111314 -
111315 -   We need to find this document created by Mr. Smith.
111316 -
111317 -
111318 - These facts provide two defense opportunities for the architect:
111319 -
111320 -   1.  The owner (CSC) was aware the design was "Fast-track" and
111321 -       thereby accepted that the quality of the plans and specs would
111322 -       not meet the standards of accuracy for ordinary public bid work,
111323 -       and further chose to assume the risk of claims arising from such
111324 -       plans in order to benefit from the earlier completion that could
111325 -       be achieved by reducing the time required to prepare convention-
111326 -       al project plans and specifications.  This is a well accepted
111327 -       industry practice.
111328 -
111329 -   2.  The CM (first MK, then OKA) was responsible to "plan check" the
111330 -       drawings, and so DHP is not responsbile for errors and ommis-
111331 -       sions complained of by the plaintiff and cross-complainants, or
111332 -       at best, their responsibility is shared by OKA to the extent
111333 -       that industry practice establishes the scope of "plan check" and
111334 -       "constructability review" activities.
111335 -
111336 - Blount's suit against the owner for $65M, and the owner's cross
111337 - complaint against DHP for "errors and omissions" means the position
111338 - taken by the owner vis a vis DHP, may have relieved DHP of part or
111339 - all liability.
111340 -
111341 -
111342 -