Expert Reports & Testimony

A delay expert whose analysis follows the record

Retained by construction counsel, sureties and insurers for owners, GCs and subcontractors. Schedule and delay opinions built under AACE RP 29R-03, written to the rules of the forum, and defended in deposition, arbitration and trial.

AACE RP 29R-03 SCL Delay and Disruption Protocol Expert and rebuttal reports Deposition and hearing testimony Owner and contractor side PSP certified
Working with counsel

How an engagement runs with counsel

01Conflict check first. Parties, project and counsel are cleared before we look at a document.
02Initial assessment before a full report. A defined first phase with its own scope and budget, so you know what the record supports before committing further.
03Coordinated through counsel. We work under counsel's direction and to the case schedule, and communications run through you.
04Reproducible analysis. Native P6 files, documented assumptions, and backup the other side's expert can rerun to the same answer.
05Exhibits a non-scheduler can follow. Critical path and delay graphics built for a panel, judge or jury.
Where we come in

From the first look at the file to the witness stand

We can come in at any stage. The same analyst carries the record from early consulting through the report and testimony, so the work builds on itself as the matter develops instead of starting over with someone new.

01

Early case assessment

Before the demand goes out or the answer is filed: what the schedules support, where the exposure sits, how many calendar days are realistically in play, and what is missing. A defined scope and budget, so you know where you stand before committing to a full report.

02

Consulting expert

Confidential analysis under counsel's direction while strategy is decided, plus help with document requests so the native schedule files get produced.

03

Affirmative expert report

Opinions on critical path, delay, concurrency and time extension entitlement, with the method selected from RP 29R-03 and the reasons stated.

04

Rebuttal report

The opposing analysis tested point by point: schedule validity, method choice, a recalculated day count, and the concurrent delay it left out.

05

Deposition and testimony

Deposition, arbitration and trial testimony, prepared with counsel and delivered in plain language.

06

Mediation and settlement

A supportable range of calendar days and delay cost for the mediation statement, and someone in the room who can answer the other side's scheduling arguments.

Built for technical scrutiny

The opinion is only as strong as the method under it

Daubert and the other side's expert

Recognized method, validated schedules, reproducible math

Federal and Florida courts apply the Daubert standard, and arbitrators ask the same questions: is the method recognized, was it applied correctly to these facts, and can someone else get the same answer. We use the methods in AACE RP 29R-03 and the SCL Delay and Disruption Protocol, validate every schedule before it carries weight, state each assumption, and trace every calendar day to a critical path activity and a document in the record. Where the record has limits, we disclose them.

Forensic methodology per AACE RP 29R-03 · SCL Protocol · TIA per RP 52R-06 · Validation per DCMA 14-point
Both sides of the table

Retained for owners and for contractors

The method doesn't change with the client, and that consistency is what makes the opinion credible.

01

Owners and developers

Evaluating the contractor's delay claim and time extension requests, and supporting liquidated and actual delay damages.

02

General contractors

Claims for owner-caused delay, and defense against liquidated damages and subcontractor pass-through claims.

03

Subcontractors

Every trade (mechanical, electrical, plumbing, fire protection, site and more) facing delay, resequencing and acceleration pushed down from the GC, or backcharges that don't match the schedule record.

04

Sureties and insurers

Schedule and delay evaluation on performance bond claims, default terminations, and builder's risk delay in startup claims.

Background

Built from the field up

FIELD

18+ years in project controls

Field scheduling on industrial EPC, water and power projects, owner's representative scheduling on a Florida intercity rail program, and federal P6 scheduling on USACE and VA work.

FORENSIC

Delay and cost analysis

Contemporaneous windows with the progress and non-progress split, time impact analysis, collapsed as-built, concurrent delay analysis, measured mile lost productivity, and extended general conditions.

CREDENTIALS

PSP certified

Planning and Scheduling Professional through AACE International. Work performed to AACE RP 29R-03, RP 52R-06, and RP 91R-16, and the SCL Delay and Disruption Protocol.

Nationwide, handled remotely. We build the analysis from the baseline, updates, as-built data and correspondence. Recent work includes a default termination defense for a contractor in New Mexico. Every engagement is handled by Mr. James, PSP, personally.
Expert FAQ

Questions counsel asks before retaining us

Do you take delay and claims work outside Florida?
Yes. The work runs from the schedule files and project record, so location doesn't matter. We have handled claims in New Mexico and across the Southeast. Testimony travel is billed at cost.
Can you write a rebuttal to the other side's expert report?
Yes. We test their schedules, method and delay math against the record and AACE RP 29R-03, rerun their analysis where it matters, and show where the days do not hold up. Rebuttal-only engagements are common.
Our expert was conflicted out. Can you step in?
Yes. We run the conflict check first, then pick up the record and any prior work and tell you up front what can be relied on and what has to be redone to meet the disclosure deadline.
Can you give us a quick read before we set strategy?
Yes. A short, fixed-fee case assessment: what the schedules support, the realistic range of calendar days in play, the weak spots on both sides and the delay method that fits the record. It helps you decide whether to push, settle or designate a testifying expert.
Can you start as a consulting expert and be designated later?
Yes. Many matters start that way. Counsel directs how early analysis is handled and what must be disclosed if we are designated. The analysis is updated as the record develops.
Do you work for owners and contractors?
Both, plus subcontractors, sureties and insurers. The method stays the same whichever side retains us, a point opposing counsel tends to test and one we can answer cleanly.
What do you need to give an early read on a case?
The contract and general conditions, the baseline and updates in native P6 format if they exist, the pleadings or claim documents, and the other side's analysis if there is one. From that we can tell you what the record supports and what is missing.
The schedules were never updated properly. Can you still give an opinion?
Usually. A thin update record points to as-planned versus as-built or collapsed as-built and narrows the precision. The report says so and explains how those limits affect the opinions.

Discuss a matter

Send the parties, the project type and location, and where the case stands. We will run a conflict check and come back with an initial scope, usually within a business day or two.

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