THE WELCH COMPANY
440 Davis Court #1602
San Francisco, CA 94111-2496
415 781 5700


S U M M A R Y


DIARY: November 20, 89 03:17 PM .......; Rod Welch

CSCJ schedule analysis coordination meeting agenda, prepare.

1...Summary/Objectiver Schedule analysis meeting
2...Schedule Analysis


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CONTACTS 

SUBJECTS
Schedule Analysis
HPS coordination meeting
Discovery Strategies for Construction Claims

0605 -    ..
0606 - Summary/Objectiver Schedule analysis meeting
0607 -
060701 - Bill came by with a record of a meeting HPS Phoenix held recently to
060702 - discuss progress and objectives.  He and Alex are going to Phoenix
060703 - tomorrow to meet and discuss these matters.  Bill wanted some
060704 - talking points.  The agenda contained points in the margin entered
060705 - by someone else.
060706 -
060707 - I added some and discussed with Bill.
060708 -
060709 - Received ref DRT 1 and 2
060710 -
06071001 - Gordon cites an attached Daily Inspection Report (DIR) for 861103,
06071002 - which relates a comment by the inspector that MEM demanded $50K per
06071003 - floor additional payment because of installed ductwork and plumbing
06071004 - that delayed his work.
06071005 -
06071006 - The report of delayed shipment of security doors and frames on the
06071007 - same report, indicates Blount permitted the plumber and HVAC to
06071008 - proceed ahead of MEM while waiting for the Security PM frames.
06071009 -
06071010 - We need to analyse the MEM complaint against Blount carefully to see
06071011 - if Blount mismangement installing plumbing ahead of masonry walls
06071012 - resulted in actual or at least concurrent delay.
06071013 -
060711 -
060712 - HPS Phoenix progress
060713 - Schedule Analysis
060714 -
060715 - DRT 2 is a progress report, as requested by Alex and Bill at the SF
060716 - HPS coordination meeting, ref SDS 3 line 2201.  It indicates Gordon
060717 - still needs Amoroso CPM schedule, a legible schedule by OKA and the
060718 - Pour schedule on Contract B.  He also seeks OKA "Scheduler Reports."
060719 -
060720 -
060721 - My main point is that the missing data needs to be cleared up by
060722 - counsel through discovery.  That is the purpose of discovery.  Thus,
060723 - most of Gordon's concerns need to be addressed during the pending
060724 - coordination meeting with counsel.
060725 -
060726 - In order for Blount and Amoroso to succeed in their litigation, they
060727 - must present competent evidence and it must in the main be disclosed
060728 - in advance of trial.  Therefore, if we ask through interogatories for
060729 - certain evidence, and they say it does not exist  it will be diffi-
060730 - cult for them to introduce it at trial.  Our focus then should be to
060731 - inventory the gaps in the record, as Gordon has done, and counsel
060732 - should place requests for the data into the litigation record.
060733 -
060734 - Another option is to seek separate meetings with OKA schedule staff
060735 - (e.g. McFarlane), Blount and Amoroso, supervised by counsel and on
060736 - the record, if necessary, to get an explanation of the schedule data.
060737 - That is, we need to have more firmly in mind what the record should
060738 - be to compare it with what we have.  Like the proposed meeting with
060739 - DHP, this would greatly expedite our efforts and save all parties a
060740 - good deal of money.
060741 -
060742 - I recommended to Bill that Gordon might be able to develop some
060743 - general overall summary schedules that fit on an 8.5 x 11 sheet to
060744 - show the major delays.  The bar charts do not establish causation.  I
060745 - explained that Gordon has indicated these can be prepared  but are
060746 - time consuming.   We will need some simple graphs like this that are
060747 - fully connected to the logic of the actual schedule to support our
060748 - opinion at trial.
060749 -
0608 -