CONTACTS 
0201 - Gensler/Michael Willis/Kwan Henmi    415 433 3700 fax 415 627 3700
020101 - Mr. Robert Rudeen; Architect
020102 - Kwan Henmi Architects
020103 - Interior Design/Documentation

SUBJECTS
Project Work Summary

0403 -    ..
0404 - Summary/Objective
0405 -
040501 - Follow up ref SDS 27 3885, ref SDS 22 4602.
040502 - ..
040503 - Entered, organized and aligned Robert's Project Work Summary for
040504 - week ending 981113. ref DIT 1 7788
040505 -
040506 - KH efforts to use an effective Work Planning system were undermined
040507 - this week by Gensler's refusal to work through KH management in
040508 - changing assignments of staff.
040509 -
040510 -     [On 981118 developed ideas to improve project management that
040511 -     support effective work planning. ref SDS 41 0000]
040512 -
040513 -
040514 -
040515 -
0406 -

SUBJECTS
50% Interior Package
Project Management
PM Interfers with KH Work Plans
Unneeded Drawing Changes Increase Costs
Acceleration Due to Instruction Corrections
Orders Unnecessary Corrections for Printing

1009 -
100901 -  ..
100902 - Construction Drawings 30% Complete - Gensler Causes KH to Accelerate
100903 -
100904 - Follow up ref SDS 27 7350, ref SDS 22 7350.
100905 -
100906 - Robert reports under a subject "50% CD printing Update" that...
100907 -
100908 -    a.  Clonia returned to work this week from emergency leave on
100909 -        981110, in the Project Summary on 981106. ref SDS 27 7350
100910 -
100911 -    b.  Clonia instructed Kwan Henmi to make corrections prior to a
100912 -        printing, which Gensler continues to call a 50% CD set, despite
100913 -        Kwan Henmi's notice to Gensler on 981102, received into the
100914 -        record on 981109, ref SDS 28 2808, that Kwan Henmi drawings for
100915 -        interior work will be 50% complete OA 981216.
100916 -
100917 - Since, as reported at the Kwan Henmi staff meeting today (981113),
100918 - Michael Willis' drawings are behind Kwan Henmi's progress, it is
100919 - unclear how the current printing can be a 50% CD set.
100920 -
100921 - Robert advises that Gensler's instructions impacted Kwan Henmi's
100922 - production on other tasks. ref DIT 1 7788  On 981023 KH Work Plan for
100923 - the 50% CD OA 981216 was based on available staff and production, that
100924 - is reasonably possible under conditions of congestion due to limited
100925 - space at the Project Office provided by Gensler, as noted in the
100926 - record of the JV coordination meeting on 980929. ref SDS 1 4966
100927 -
100928 - Gensler's instruction this week to make corrections for a current
100929 - printing forces Kwan Henmi to accelerate, since those corrections
100930 - would otherwise have been performed as part of doing other work
100931 - required for the 50% printing due on 981216.  Demanding that work be
100932 - performed out of sequence with no discernable professional benefit to
100933 - the project or the client, causes extra cost to Kwan Henmi and harms
100934 - the client. This conflicts with Gensler's goal to save money for the
100935 - client, reported in a memorandum to Kwan Henmi on 980917.
100936 -
100937 -
100938 -
100939 -
1010 -

SUBJECTS
Telecom Meeting, 981021
PM Refuses to Review Telecom Meeting Notes,
Refusal to Review Telecom Meeting Notes
Notes for Meetings
Project Management
PM Assigns MW to Coordinate KH Work, 981113
Assigns MW to Coordinate KH Work
Forces KH to Rework Meeting Notes on False

2711 -
271101 -  ..
271102 - Telecon Meeting Note Review, Clonia Objects as Too Wordy
271103 -
271104 - Follow up ref SDS 37 0000.
271105 -
271106 - On 981111 Robert asked Clonia to review the notes of the Telecom
271107 - meeting held on 981021. ref SDS 10 0000   Clonia refused to review the
271108 - notes, alleging they are "too wordy." ref DIT 1 4686
271109 -
271110 - A claim of "too wordy" requires initial review to determine whether
271111 - there are more words than are needed for effective communication,
271112 - i.e., clear, concise and complete. ref OF 1 1218
271113 -
271114 - This information supplements discussion yesterday where Robert
271115 - indicated that Clonia was not cooperative. ref SDS 33 2635
271116 -
271117 - On 980929 Gensler did not want detailed notes of Kwan Henmi's
271118 - understandings, and asked that meetings be summarized in 5 or so
271119 - bullet items. ref SDS 1 1184
271120 -
271121 - Robert indicates that Clonia wants MW to prepare meeting notes because
271122 - MW prepares "very brief" notes. ref DIT 1 4686
271123 -
271124 - On 981007 Clonia claimed nobody will read notes that are too long....
271125 - ref SDS 4 7210
271126 -
271127 -     [On 981117 Gensler issued coordination notes on meetings with
271128 -     structural and mechanical consultants which required correction by
271129 -     KH. ref SDS 40 1581]
271130 -
271131 -     [On 981118 reviewed with Kwan Henmi management Gensler's complaint
271132 -     about meeting notes being "too wordy," and the risks and
271133 -     implications that flow from Gensler's conduct in failing to
271134 -     perform its duty under the JV Agreement to review and distribute
271135 -     meeting notes issued by Kwan Henmi. ref SDS 41 4440]
271136 -
271137 - Robert's report today explains why he requested this morning another
271138 - copy of the Telecom notes to do further editing. ref SDS 37 4042
271139 -
271140 - He was forced to second-guess himself doing more editing without
271141 - feedback from Gensler on what might be "too wordy."  Performing rework
271142 - without guidance of review is unproductive, costly and wastes Robert's
271143 - time which is extremely limited due to his jury duty the past several
271144 - weeks. The very essence of citizenship requires that everyone pull
271145 - together where one member is called upon to perform community service,
271146 - as in being a juror in a trial.  Gensler is unjustly punhishing Robert
271147 - by making frivolous claims at a time when he lacks the time to
271148 - consider the merits of unfounded complaints about routine
271149 - administration of major public works improvement.
271150 -
271151 -     [On 981116 SF Chronicle reports that the state legislature
271152 -     recognizes unprofessional management that causes excessive and
271153 -     unnecessary stress, impacts productivity. ref SDS 39 6480]
271154 -
271155 - Robert says he will continue to prepare meeting notes, indicating
271156 - confusion among management with respect to procedures, and inviting
271157 - complexity into the record that will confuse staff and future review
271158 - as to what transpired that supports the design of the project.
271159 -
271160 -     [On 981123 Robert's Project Work Summary says Gensler assigned MH
271161 -     and Michael Foegelle with Kwan Henmi to prepare meeting notes on
271162 -     behalf of Kwan Henmi. ref SDS 42 4883]
271163 -
271164 -
271165 -
271166 -  ..
271167 - Kwan Henmi has a Duty to Coordinate MEPS
271168 - Gensler Must Make Good Faith Review of Kwan Henmi Coordination
271169 -
271170 - The Joint Venture agreement is vague on the scope of project
271171 - management assigned to Gensler, under Appendix D, para A Construction
271172 - Document Phase.  However, it clearly states that Gensler has a duty to
271173 - "review" Coordination with structural, mechanical, electrical and Fire
271174 - Protection" assigned to KH and MW under Appendex E para V.
271175 -
271176 - Appendix E section I seems to set scope of Project Management, and it
271177 - could be interpreted to require Gensler to prepare all meeting notes,
271178 - as reviewed on 980930. ref SDS 2 3192, ref SDS 2 3666
271179 -
271180 - Since Clonia refused to make an initial review, the allegation that
271181 - the document is "too wordy" is unsupported, and therefore indicates
271182 - willful refusal to perform a required duty which Gensler owes to Kwan
271183 - Henmi and to the client, causing rework for Kwan Henmi and extra cost
271184 - for the client.
271185 -
271186 -     [On 981118 analysis shows Gensler's documents have more words than
271187 -     the record Gensler refused to review. ref SDS 41 5005]
271188 -
271189 - Arbitrary refusal to conduct business in a professional manner causes
271190 - stress and frustration by KH management in being unable to carry out
271191 - ordinary tasks with Gensler's assigned project manager, as analysed on
271192 - 981113 (this morning). ref SDS 36 2673  This harms the individuals
271193 - involved, and damages Kwan Henmi is loss of productivity and, where
271194 - staff leave office, loss of capable people, and it damages the client
271195 - because of increased cost and delay of the work.
271196 -
271197 -     [On 981116 SF Chronicle reports that the state legislature
271198 -     recognizes unprofessional management that causes excessive and
271199 -     unnecessary stress, impacts productivity. ref SDS 39 6480]
271200 -
271201 -  ..
271202 - Gensler's Direction for MW to Record KH Coordination is Incorrect
271203 -
271204 - The joint venture agreement states that for Construction Documents,
271205 - Gensler is assigned to provide interior design review and coordination
271206 - of architectural associates, and global review of engineering
271207 - drawings.
271208 -
271209 - Gensler should review Coordination with Structural, Mechanical,
271210 - Electrical and Fire Protection, which MW and KH are assigned to
271211 - perform.
271212 -
271213 - Gensler's failure and refusal to review the record of coordination by
271214 - KH for the Teecom meeting held on 981021, particularly, where as here,
271215 - Gensler expressly requested that Kwan Henmi perform such coordination
271216 - on 981120, ref SDS 9 3120, violates a duty which Gensler owes to KH
271217 - and to the client.
271218 -
271219 - There is no evident authority for Gensler to direct that MW perform
271220 - coordination behalf of Kwan Henmi, as reported in the Project Work
271221 - Summary for today, ref DIT 1 4686; nor is Kwan Henmi requred to permit
271222 - another firm to provide the record of work performed by Kwan Henmi,
271223 - which directly bears on the exposure of Kwan Henmi for errors and
271224 - omissions, and on its ability to produce construction drawings.
271225 -
271226 -     [On 981118 reviewed Kwan Henmi's right to inform the JV team of
271227 -     its progress. ref SDS 41 6480]
271228 -
271229 -     [On 981123 Robert's Project Work Summary says Gensler assigned MH
271230 -     and Michael Foegelle with Kwan Henmi to prepare meeting notes on
271231 -     behalf of Kwan Henmi. ref SDS 42 4883]
271232 -
271233 -
271234 -
2713 -

SUBJECTS
Structural Meeting, 981111

2904 -
290401 -  ..
290402 - Structural Coordination Meeting
290403 -
290404 - Follow up ref SDS 27 1708.
290405 -
290406 - Robert notes that this meeting, ref DIT 1 2548, was held on 981111.
290407 - ref SDS 32 0000
290408 -
290409 -     [On 981117 Gensler issued coordination notes on meetings with
290410 -     structural consultants which required correction by KH. ref SDS 40
290411 -     1581]
290412 -
290413 -
290414 -
290415 -
2905 -

SUBJECTS
Mechanical Meeting, 981112

3104 -
310401 -  ..
310402 - Mechanical Coordination Meeting
310403 -
310404 - Follow up ref SDS 27 1708.
310405 -
310406 - Robert notes that this meeting, ref DIT 1 2538, was held on 981112.
310407 - ref SDS 35 0000
310408 -
310409 -     [On 981117 Gensler issued coordination notes on meetings with
310410 -     mechanical consultants which required correction by KH. ref SDS 40
310411 -     1581]
310412 -
310413 -
310414 -
310415 -
3105 -

SUBJECTS
Stair Sections
PM Interferes KH Work Plan Assignments on

3605 -
360501 -  ..
360502 - Gensler Delays Kwan Henmi Work on Stair Sections
360503 -
360504 - Robert reports Gensler interfered in Lawrence Kwan's work on stair
360505 - sections. ref DIT 1 7025
360506 -
360507 - Lawrence's work, along with that of other KH staff had been assigned
360508 - within Kwan Henmi's planning system to maintain progress of the work,
360509 - in relation to other related assignments, in the KH team meeting on
360510 - 981106.
360511 -
360512 - There is no mention in the record of a study or other justification
360513 - offered by Gensler showing that alternate work plan would reduce the
360514 - time and cost of the project.
360515 -
360516 -
3606 -

SUBJECTS
Operable Walls
PM Interferes KH Work Plan Assignments on
Moveable Wall Package Due to Consultant on 981221

4206 -
420601 -  ..
420602 - Moveable Wall Package (Operable Partitions)
420603 -
420604 - Follow up ref SDS 27 1960.
420605 -
420606 - Robert reports that Phillip was interrupted in performing his KH work
420607 - plan assignment to prepare a moveable wall package, for most of the
420608 - week by instructions from Clonia to make changes to the Fire
420609 - Separation Plans and Sections at the elevator 7 & 8 Core. ref DIT 1
420610 - 3748
420611 -
420612 - Clonia set a target date for submission of the Moveable Wall package
420613 - to the consultant OA 981221.  At the KH team meeting on 981113
420614 - (today), Robert reported that Clonia indicated this target date could
420615 - be moved to the first part of next year.  There was no explanation of
420616 - why this date could be moved and others cannot.  Gensler has not
420617 - provide information to calculate or otherwise establish a completion
420618 - date for the moveable wall package, as critical to the project
420619 - schedule, similar to discussion on 981015 concerning elevator machine
420620 - rooms on 981015. ref SDS 7 5840
420621 -
420622 - As a result, KH cannot determine a basis for planning work
420623 - assignments, and there can be no basis for scheduling any of the work
420624 - without first identifying...
420625 -
420626 -      1.  Schedule milestones?
420627 -
420628 -      2.  Activities critical to meeting those milestones?
420629 -
420630 -      3.  Activities with float that can be deferred to level
420631 -          resources?
420632 -
420633 - These ordinary and essential planning criteria require effective,
420634 - professional project management that is lacking, as set out in the
420635 - record on 980929. ref SDS 1 6020
420636 -
420637 -
420638 -
420639 -
4207 -

SUBJECTS
Layouts/Slopes
Floor Plan Dimensions
PM Interferes KH Work Plan to Dimension Floor Plans
50% Interior Package, 981216

5207 -
520701 -  ..
520702 - Floor Plan Updates
520703 -
520704 - Robert reports Bolivar was assigned to do dimensions for floor plans.
520705 - They are needed to accomplish the 50% CD set due on 981216.
520706 -
520707 - Bolivar was interrupted this week to make floor plan changes for
520708 - Clonia. ref DIT 1 4140
520709 -
520710 -     [On 981120 Bolivar reported he made no progress on his work plan
520711 -     assignments for the week, because Gensler's project manager
520712 -     directed that he perform unassigned work.
520713 -
520714 -
520715 -
520716 -
5208 -

SUBJECTS
Elevator Machine Rooms, CADD
Drawings input into CADD

5505 -
550501 -  ..
550502 - Elevator Machine Rooms Put into Plans
550503 -
550504 - Robert reports that elevator machine rooms were put into plans. see
550505 - ref DIT 1 4141
550506 -
550507 - On 981112 machine rooms were reviewed with A&P for...
550508 -
550509 -        elevators 5 and 6. ref SDS 34 0450
550510 -
550511 -        elevators 7 and 8. ref SDS 34 1848
550512 -
550513 - On 981111 machine rooms were noted in meeting with SDE for...
550514 -
550515 -        elevators 1 and 2. ref SDS 31 8260
550516 -
550517 -
550518 -
550519 -
5506 -

SUBJECTS
Escalator Sections
CADD put into Plans
PM Conflicting Instructions on Escalators,
50% Interior Package, 981216
Acceleration Due to Instruction Corrections

6608 -
660801 -  ..
660802 - Escalator Sections Reworked Due Conflicting Insructions by Gensler
660803 -
660804 - Robert reports that rework was required on escalator dimensions and
660805 - sections.  KH initially followed Clonia's instructions to put the
660806 - escalator in per the DD set, then had to change the plans because
660807 - Gensler's designer, Peter, gave different instructions. ref DIT 1 7685
660808 -
660809 -
660810 -
660811 -
6609 -

SUBJECTS
Ceiling Details, Plans, Layouts

6804 -
680401 -  ..
680402 - Ceilings Enlarged Plan Details
680403 -
680404 - Robert reports that enlarged ceiling plan details were prepared this
680405 - week per Clonia's request. ref DIT 1 2572
680406 -
680407 - There is no information from Gensler on how this impacts the project
680408 - critical path, nor on impact to KH Work Plans.
680409 -
680410 -
680411 -
6805 -

SUBJECTS
Design, Wall Types
PM Interferes KH Work Plan Assignment on
Interfers KH Work Plan Assignment on Wall
50% Interior Package, 981216
Wall Types Delayed by Instructions from PM

7308 -
730801 -  ..
730802 - Wall Types Completed for this Printing
730803 -
730804 - Follow up ref SDS 27 3850, ref SDS 22 4785.
730805 -
730806 - Robert says that Bolivar's assignment for last week to "Clean-up wall
730807 - types," shown in the Project Work Summary dated 981106, ref DIP 7
730808 - 5948, had to be re-scheduled for this week because instructions from
730809 - Gensler prevented progress this past week. ref DIT 1 6450
730810 -
730811 -     [On 981120 Boliver reported at KH Team Meeting that he is not
730812 -     making progress on any assigned tasks due to instructions from
730813 -     Gensler's project manager.
730814 -
730815 -
730816 -
730817 -
7309 -

SUBJECTS
Interior Elevations Not Provided by Gensler
50% Interior Package, 981216
Interior Elevations Not Provided by Gensler

7806 -
780601 -  ..
780602 - Interior Elevations Not Provided by Gensler
780603 -
780604 - Robert says in task #13 that KH work on Interior Elevations needed for
780605 - 50% CD are on hold because Gensler is making changes.
780606 -
780607 - Gensler has not submitted its study to KH. ref DIT 1 4032
780608 -
780609 -     [On 981123 Project Work Summary for period ending 981120 says
780610 -     Prefunction interior elevations are complete. ref SDS 42 4839]
780611 -
780612 -     [On 981123 also report that Gensler provided information on
780613 -     interior elevations for exhibit hall. ref SDS 42 4840]
780614 -
780615 -
780616 -
780617 -
780618 -
7807 -