CONTACTS 

SUBJECTS
HPS, CSCJ Litigation
Administration, receive
documents, etc.

0406 - This is to review correspondence that has accumulated the past week
0407 - while I was in depositions in San Jose.
0408 -
0409 - Yesterday was devoted to debriefing HPS staff and reviewing exhibits
0410 - for incorporation into opinion.
0411 -
0412 -
0413 -

SUBJECTS
HPS, CSCJ Litigation, Issues
Mislocated Dowels
Errors & Omissions
Amoroso Delay impact to BBC
Architect, DHP

0808 -
0808 -    ..
0809 - Received Roy's notes of meeting with Architect, DCT 3
0810 -
081001 - Roy's notes on page under heading Contract A v B.
081002 -
081003 - HPS needs Amoroso's grid survey expert report
081004 -
081005 - HPS needs to analyse the changes approved by CSC during the job  for
081006 - which it is seeking to recover funds from DHP.
081007 -
081008 - See DCT 3 page 4 Major Issues, re PMA list.
081009 -
081010 -
081011 -

SUBJECTS
HPS, CSCJ Litigation, Issues
BBC as-planned schedule,
narrative received 891206
Schedule, Data Understanding
Pending Documents Requested
Dawson-Edwards, (BBC,
EX) 891211

1210 - Received Gordon's report, DCT 5
1211 -
121101 - This a large body of Primavera reports, plus some narrative by
121102 - Gordon explaining his understandings.  Included are some schedule
121103 - network charts, presumably generated by Primavera.
121104 -
121105 - Read Gordon's preliminary schedule report.
121106 -
121107 -
1212 -
1213 - Received HPS letter to NW re missing data, DCT 13
1214 -
121401 - This explains why the schedule data provided on disketts by NW is
121402 - inadequate to analyse the as-built schedule.
121403 -
121404 - It requests the schedule data cited by OKA contract and McFarlane
121405 - depo indicating Master schedule maintained by OKA.
121406 -
121407 - We know now the answer to question #3 on page 2, which asks if the
121408 - schedule data supplied by NW to HPs is the schedule data being
121409 - relied on by BBC and CSC to present the claims and develop CSC's
121410 - position relative thereto.
121411 -
121412 - Dawson-Edwards' depo established he did not rely on the OKA as-built
121413 - schedule.
121414 -
121415 -
1215 -
1216 - Gordon requests exhibits from Dawson-Edwards' depo  ref DCT 14
1217 -
121701 - This is a list of exhibits and other information Gordon requests
121702 - from the deposition conducted last week.
121703 -
1218 -
1219 -

SUBJECTS
HPS, CSCJ Litigation, Issues
Schedule analysis, acceleration
DHP, BBC
Precast structural concrete
Schedule approval process by OKA/BBC
Project Planning & Oversight

1809 - Received transmittal with various materials, ref DCT 6
1810 -
181001 - This has the design schedule prepared by DHP on 840127.  We should do
181002 - a study to see if the record shows any material deviations from the
181003 - portion of the schedule for which DHP was not responsbile  such as
181004 - CSC review period, increased work mandated by CSC, increased design
181005 - complexity.
181006 -
181007 -
1811 -
1812 -
1813 - Received correspondence review by Gordon, DCT 9
1814 -
181401 - This summarizes correspondence by OKA and its consultants on
181402 - schedule review and analysis based on the original bid plans.
181403 -
181404 - Contains recommendations by Proctor to mandate two cranes  and
181405 - similar acceleration measures contractors could have taken to meet
181406 - the completion date.
181407 -
181408 - Acceleration
181409 - Two cranes
181410 -
18141001 - I called and discussed this point with Gordon.  He said BBC's
18141002 - original schedule showed it intended to use two cranes.  The
18141003 - schedule shows two parallel paths for performance of construction,
18141004 - each of which required a crane.
18141005 -
18141006 - CEG's report discusses use of cranes and production by cranes
18141007 - under various configurations.  This should provide information
18141008 - from which to determine whether BBC's claim for an extra crane is
18141009 - supported.
18141010 -
18141011 - BBC makes request for a separate concrete pump truck.  Concrete
18141012 - pumping is generally more efficient means to pour than a crane and
18141013 - buckets.
18141014 -
18141015 - Did BBC make any allowance in their bid for pumping?  If so, their
18141016 - request for extra payment on this basis is unfounded  except that
18141017 - they may have needed increased pumping.
18141018 -
18141019 -
181411 -
181412 -
181413 - Schedule feasiblity
181414 -
18141401 - I suggested to Gordon that he consider whether the approved BBC
18141402 - planned schedule provided sufficient time for the finish trades.
18141403 - This is should be studied because Dawson-Edwards testified that
18141404 - BBC's schedule did not allow enough time for this work, because in
18141405 - his opinion, too much time was alloted for the earlier work.
18141406 -
18141407 -
18141408 - HPS needs to juxtapose more carefully the schedule defects cited
18141409 - by OKA's schedule expert and site consultant, Noel McFarlane,
18141410 - together with the errors HPS finds, in order to show OKA failed to
18141411 - properly manage the job to avoid delay in permitting BBC to
18141412 - proceed with defective materials under the pretense that this was
18141413 - an "...excellent tool for controlling the activities in Contract
18141414 - B."
18141415 -
18141416 -
181415 -
181416 -
1815 -
1816 -