36+ Years of Construction Leadership
What documents are needed to evaluate a construction dispute?
What does a project’s recordkeeping reveal about contractor performance?
How should payment applications and construction draws be reviewed?
What information is required to evaluate delays or change orders?
How can lenders identify a potential funding shortfall?
What should be documented before corrective work begins?
How should owners evaluate a distressed or underperforming project?


Construction Litigation
Construction Defects
Delays and Scheduling
Change Orders and Costs
Contractor Performance
Project Documentation
Construction Risk
Draw Reviews
Capital Projects
Healthcare and Corporate Interiors
Construction disputes are often won or lost through the project record. This article identifies the contracts, drawings, schedules, change orders, requisitions, daily reports, meeting minutes, photographs, and corrective-work records counsel should request early in a matter.
When I review a construction dispute involving payment, one of the first documents I am usually given is the contractor’s payment application. It may show the original contract amount, approved change orders, work completed during the current billing period, stored materials, retainage and the balance remaining.
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