Records Paul Typically Requests
| Record | What it shows |
|---|---|
| Contract, proposal and scope documents | What was agreed and at what price |
| Drawings and specifications, with addenda | What was designed and specified |
| Change orders and RFIs | How the requirements changed and why |
| Submittals and product data | What products and details were approved |
| Schedules and daily reports | Sequence, staffing and problems as they happened |
| Inspection reports and punch lists | What was checked, found and corrected |
| Photographs and video | Conditions during and after construction |
| Invoices, pay applications and correspondence | Progress, disputes and acknowledgments |
Not every project has every record. Missing records are noted, because the absence of a record can be significant.
Reading the Records in Order
Construction requirements change over the life of a project. A detail on the original drawings may have been revised by an RFI response, replaced by an approved submittal and modified again by a change order. Paul reviews records in date order to establish what the requirement was when each item was installed. That chronology often resolves disputes about whether a condition was a defect or an approved change.
Photographs and Field Records
Photographs taken during construction are often the best evidence of concealed work: framing before drywall, substrates before flooring, blocking before cabinets. Paul reviews them alongside daily reports and inspection records to understand what was covered and when. He relies on photographs for what they show and notes where the date, location or source of a photograph cannot be confirmed.
Helping Counsel With Discovery
Early document review often identifies records that should exist but have not been produced, such as daily reports for a key period, inspection records for a particular area, or manufacturer instructions for a product. Paul can provide counsel with a list of those gaps and suggested topics for contractor depositions. His observations are provided to counsel; legal strategy remains counsel's decision. See expert witness services for the scope of consulting engagements.
Keeping the Record Organized
Large productions can run to thousands of pages and photographs. Paul indexes the materials he relies on so that each opinion can be traced back to specific documents. That index becomes part of the list of materials reviewed in his report and makes it easier for counsel to respond quickly to questions at deposition about what Paul did and did not consider.