Contractor standard of care expert witness for construction litigation773-619-1226 | paul@expertwitness.co

Planning, Implementation and Administration

Construction Management Expert Witness

A construction management expert witness evaluates how a contractor planned, implemented and administered a project: scheduling, procurement, submittals, change management, communication and close-out. Paul Gaston draws on his experience as a project manager, superintendent and general foreman to explain whether the contractor's management practices were consistent with its obligations and recognized practice.

Construction workers in safety vests on several floors of a steel frame building

Planning

Good construction starts before the first trade arrives. Planning includes reviewing the documents for constructability, preparing a realistic schedule, procuring materials with adequate lead time, and organizing the site. Paul reviews pre-construction records, schedules and procurement logs to see whether the project was set up to succeed, and whether problems that later developed were foreseeable from the start.

Implementation

Implementation is the day-to-day management of the work: updating the schedule, coordinating trades, managing access and logistics, holding meetings, and responding to issues as they arise. Paul looks at meeting minutes, look-ahead schedules and daily reports to see how the project was actually run and how the contractor responded when conditions changed.

A drone flying over a concrete building under construction while a worker in an orange jacket watches

Project Administration

Administrative processWhat Paul reviews
SubmittalsWhether products and details were submitted, reviewed and approved before installation
RFIsWhether questions were raised promptly and answers followed
Change ordersWhether changes were documented, priced and approved before or as the work proceeded
Pay applicationsWhether billing tracked actual progress
Close-outPunch lists, warranties, manuals and as-built records

Weak administration often leaves a record that makes it difficult for a contractor to show what was agreed, and those gaps can be as significant as problems in the work.

Changes and Their Management

Changes are inevitable on construction projects; how they are managed varies. Disputes arise when work proceeds on verbal direction, when changes are not priced or approved, or when the contract's change procedure is not followed. Paul reviews how changes were requested, documented and approved, and how they affected the work. He does not provide schedule delay analysis, which requires a scheduling specialist, but he can describe whether management of the work was consistent with recognized practice.

Construction Managers and Owner Representatives

On some projects a construction manager or owner's representative manages the work on the owner's behalf. Their responsibilities are defined by their contracts and can differ significantly from a general contractor's. Paul reads those agreements carefully and evaluates the construction manager's conduct against its own obligations, rather than assuming it carried general contractor responsibilities. See general contractor responsibilities for comparison.

Close-Out and Turnover

Close-out is the last stage of project management and often the first stage of a dispute. Paul reviews how punch lists were developed and completed, whether warranties, manuals and as-built records were delivered, and whether the owner accepted the work. Incomplete close-out frequently leaves open questions about what was finished and who accepted it.

Questions

Common Questions

What does construction management cover?

Planning, scheduling, procurement, trade coordination, submittals, RFIs, change management, billing and close-out.

Does Paul provide schedule delay analysis?

No. Critical path delay analysis requires a scheduling specialist. Paul can describe how the work was managed and coordinated.

Why do change orders matter in a contractor dispute?

They show what was agreed and when. Work performed on verbal direction without documentation often leads to disputes about scope and payment.

Are construction manager responsibilities the same as a general contractor's?

Not necessarily. They depend on the construction manager's contract, which Paul reviews before evaluating its conduct.

Is the dispute about how the contractor ran the job?

Send the party names for a conflict check. Paul will review the contracts, records and conduct at issue and tell you what the evidence shows.