CONTACTS 
0201 - O-0432 0101 High-Point Schaer          415 495 2242 fax 3559
020101 - Mr. Alexander B. Vollmer, P.E., Regional Manager
0202 - O-0432 0201 High-Point Schaer          415 495 2242 fax 3559
020201 - Mr. Bill Ma, Phd., P.E., Project Manager
0203 - O-0432 0202 High-Point Schaer          415 495 2242 fax 3559
020301 - Mr. Roy I. Kim, Engineer
0204 - O-0437 0201 High Point Schaer          602 944 7737 fax 8272
020401 - Mr. Gordon H. Aronson, P.E.

SUBJECTS
CSCJ, Litigation, Issue Analysis
Mislocated Dowels

0404 -    ..
0405 - Summary/Objective
0406 -
040601 - There is more chronology, but the essential stuff that covers the
040602 - period of the work is now logged so I can begin writing an opinion.
040603 -
040604 - Some additional research is needed to verify that plans for contract
040605 - A and B are not conflicting (we do not have contract A plans yet).
040606 - See also "Missing Documents" on page 21.
040607 -
0407 -
0408 - 0820 Alex requested work product to review this afternoon.
0409 -
040901 - Prepared preliminary draft analysis, ref OF 1 and submitted under
040902 - memo ref DCT 1 to Alex, Bill and Roy for comment.
040903 -
040904 - Sent copy to Gordon requesting schedule analysis IAW comments at
040905 - line 061105.
040906 -
0410 -
0411 - Remaining activity
0412 -
041201 - An opinion should be crafted, ref OF 2, to establish:
041202 -
041203 -    1.  DHP is not liable for delays and expense in this matter.
041204 -
041205 -    2.  The fair and reasonable impact of Claim A of which
041206 -        mislocated dowels is the principal cause.  This is mainly
041207 -        a schedule analysis.
041208 -
041209 - These steps will show the extent to which claim A for which DHP has
041210 - no exposure, caused delay being charged under claim B, where DHP may
041211 - have some exposure.
041212 -
0413 -

SUBJECTS
CSCJ, Litigation, Issue Analysis
Gordon's schedule analysis
Mislocated Dowels

0806 - Received ref DRT 1, Issue Phasing
0807 -   ..
080701 - Roy gave this to me this morning to hang on the wall.
080702 -
080703 - The part that relates to mislocated dowels is not clear.
080704 -
080705 - The date of completion of the mudmat at or near the elevator pit
080706 - which Blount and OKA agree was the critical milestone (see ref OF 1
080707 - line 1178 and 1446), is not shown on this document (that may not the
080708 - purpose of the document).
080709 -
080710 - Mislocated dowel issue is not mentioned except by inference from the
080711 - phrase "Concrete Interface Problems."  Would be nice to show the
080712 - entire period through which mislocated dowels were discovered.
080713 -
0808 -
0809 - Reviewed ref DCP 1 - schedule report
0810 - Timeline of dowel mislocation problems
0811 -
081101 - This compares in bar chart format Blount's position  presumably as
081102 - set out in its Claim A document dated 861008, with OKA's response in
081103 - the 870116 letter (shown on the schedule report, DCP 1  as 860126).
081104 -
081105 - It would be helpful if we can try to carry the schedule analysis
081106 - another step and create a network based upon the chronology, ref OF
081107 - 1, to show what planned activities were impacted and in what manner
081108 - by the mislocated dowel events.
081109 -
081110 - Show specific rain delay periods.
081111 -
081112 - Show completion of the mudmats, and indicating what follow on
081113 - activities this work controlled.  Blount and OKA seem to agree this
081114 - was critical.  Objective of schedule exercise is  to the extent
081115 - possible, to show the activities that caused the increase from
081116 - planned to actual completion date of the mudmats.
081117 -
081118 - See also "Comments" within ref OF 1 line 1165  1381
081119 -
081120 -
081121 - Called Gordon to explain these ideas and let him know a memo is
081122 - coming.
081123 -
081124 - Explained general ideas in this memo, ref DIT 1. Gordon indicated he
081125 - would take a look at doing an as-built CPM on this thing IAW line ref
081126 - DIT 1 line 127. Initially he asked why we should do this given the
081127 - conclu- sion the architect has minimal exposure.  I cited the grounds
081128 - at ref DIT 1 line 93.
081129 -
0812 -
0813 -

SUBJECTS
CSCJ, Litigation, Issue Analysis
Gordon's work plan for schedule analysis
HPS summary schedule
Discovery Strategies for Construction Claims

1307 - Analysis procedures
1308 - 1532 telecon with Gordon
1309 -
130901 - Gordon said he is preparing a list of defects in the schedule data
130902 - which is preventing a schedule analysis.
130903 -
130904 - Gordon related a discussion with Alex about the importance of focus-
130905 - ing on the "Issues" where the architect has maximum exposure, and/or
130906 - matters that may relieve DPH of responsibility under a concurrent
130907 - delay theory.
130908 -
130909 - He cited precast as the next big issue and indicated he and his group
130910 - may do it.  I have indicated I would do the precast issue next, but
130911 - if Gordon does it I can do Security PM frames.
130912 -
130913 - I mentioned the following points.
130914 -
130915 -
1310 -
1311 -
1312 - Received ref DRT 2, Notes of Meeting 891121
1313 -
131301 - 1.  Project Update
131302 -
131303 -   HPS deposition preparation
131304 -
131305 -   Gordon expressed concern about having to be deposed without having
131306 -   more schedule data.
131307 -
131308 -   This is an incorrect view.  We should testify about the poor
131309 -   quality of the record and as a result are unable to determine any
131310 -   liability for DHP.  Testify that DHP has incurred unnecessary
131311 -   expense due to inadequate and defective records maintained by OKA,
131312 -   and that we can find no basis for complaints against DHP until we
131313 -   get the testimony from plaintiff's experts and percipient
131314 -   witnesses.
131315 -
131316 -   This should be topic for pending coordination meeting with counsel.
131317 -
131318 -
131319 -
131320 - 2.  Gordon's (Phoenix) Project Overview
131321 -
131322 -   Summary Hammock report
131323 -
131324 -   "The use of activity `hammocks' greatly reduces the usefulness of
131325 -   the summary schedule because of the missing logic lines  especially
131326 -   on critical path activities.  The consensus is not to use `hammock'
131327 -   restricted summary schedule."
131328 -
131329 -   Under this position, the question remains how are we going to
131330 -   prepare an as-built summary schedule that shows the impact of the
131331 -   "issues" in the case.  We need a summary that can be shown on a
131332 -   single sheet, and subnets or fragnets that detail the impact of
131333 -   "issues" and tell our story as we understand the record.
131334 -
131335 -   If this cannot be done using the project as-built schedule  then we
131336 -   must state why, and then proceed to assemble our points using the
131337 -   data available from other sources.
131338 -
131339 -
131340 -
131341 -
131342 -