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Expert Forensic Schedule Analysis for Construction Litigation

Your delay dispute needs an analyst whose work is built to withstand cross-examination.

When a construction matter turns on the schedule, and it almost always does, the forensic analysis has to hold. Not just in the report. In deposition. In rebuttal. On the stand. Under direct. Under cross. In front of an arbitrator who's seen a hundred delay claims and knows the difference between rigorous methodology and consultant theater. That's the work Critical Path Partners does.

What Counsel Gets

A defensible forensic analysis, start to finish.

Every piece of the deliverable is built to be cross-examined: published methodology, dual-method validation, single-analyst chain of custody, and a reproducibility manifest opposing counsel's expert can re-run and verify.

Mohan · White Burgess · r. 53.03

Built for the Standard Your Court Applies

In Ontario, the admissibility of expert evidence is governed by R. v. Mohan (relevance, necessity, the absence of an exclusionary rule, and a properly qualified expert) and White Burgess (the expert's independence and impartiality as a threshold question), with the expert's duty to the court stated in Rule 4.1.01 of the Rules of Civil Procedure and acknowledged in the form required under Rule 53.03. The same reproducible, published-method analysis is built for FRCP 26(a)(2)(B) disclosure and Daubert scrutiny when a matter reaches a US court. One analysis, written to the reliability standard whichever forum applies it.

AACE · SCL Protocol

Methodology That Holds Up

Every CPP analysis is built on published standards: the AACE Recommended Practices for Windows Analysis (RP 29R-03 §3.3), Collapsed As-Built (§3.8), and Time Impact Analysis (RP 52R-06), plus the SCL Delay & Disruption Protocol, 2nd Edition. No house-brand methods. No proprietary black boxes. The standard is named in every conclusion, traceable in every exhibit, defensible under cross-examination because it was built that way from the first window.

MIP 3.3 + MIP 3.8

Dual-Method Validation

Where the contract or the matter warrants it, CPP runs both Windows Analysis (MIP 3.3) and Collapsed As-Built (MIP 3.8) independently, then reconciles the results. Opposing counsel cannot dismiss the finding as single-method bias when two methods converge on the same number.

Chain of Custody

One Chain of Custody

One analyst reads the XER, runs the engine, writes the narrative, and prepares the exhibits. No handoffs between junior analysts, no hours lost in internal review loops, no conclusion that drifts from the data because three people touched the file before the senior analyst saw it. The deliverable traces back to one person, and that person can explain every number in it.

Reproducibility

Audit-Trailed, Reproducible Math

Every CPP deliverable embeds a reproducibility manifest: XER hashes, parser version, engine version, methodology parameters. If opposing counsel's expert re-runs the same inputs, they get the same outputs. That's not a feature. That's the minimum standard for forensic work, and most shops don't meet it.

The Deliverables

What lands on your desk.

A coordinated set: the analytical workpaper, the narrative for the trier of fact, the validation, the exhibit package, the claim submission, and the formal expert report. Each one references the others. Each one names its standard.

HTML

Forensic Delay Analysis Dashboard

Self-contained HTML dashboard, the analytical workpaper. Per-window concurrent analysis, attribution by party, critical-path tracking, slip register, and embedded reproducibility manifest. The single document that lets a reviewer audit every conclusion in the case.

DOCX

Executive Narrative

Plain-language Word document explaining what happened on the project, in what order, who caused which delay, and why the math says what it says. Written for the trier of fact (judge, arbitrator, mediator), not for another scheduler.

HTML

Collapsed As-Built Validation

Independent MIP 3.8 collapsed as-built analysis run as a check on the windows analysis. Two methods, two numbers, one reconciled conclusion. The dual-method gap is reported explicitly so opposing counsel cannot accuse single-method bias.

Independent in methodology (windows + collapsed are mathematically distinct approaches); both are computed by CPP's open-source engine. See DAUBERT.md §3 and the published cross-validation results for the same-author caveat.

XLSX

Forensic Workbook

The underlying numbers in spreadsheet form: per-activity slip, per-window attribution, concurrency matrix, calendar tables, raw activity dumps. The exhibit your expert hands to opposing counsel during discovery so the math can be independently re-derived.

DOCX / PDF

EOT Claim Package

If the matter is contractor-side, a complete extension-of-time submission ready for the owner: cover letter, per-event exhibits, mitigation log, supporting-documents index, and owner-submission QC. Built to the contract's notice and substantiation provisions, following the guidance in the SCL Delay & Disruption Protocol, 2nd Edition, §3.

DOCX

Expert Report

Formal expert report compliant with the relevant rules of court: qualifications, scope of opinion, methodology, findings, opinions, and exhibits incorporated by reference. Written to be filed, served, and defended in deposition and at trial.

Expert Qualifications

About the analyst.

CPP is a one-analyst boutique. The analyst you retain for the preliminary assessment is the same analyst who runs the engine, writes the report, and sits for cross-examination.

Critical Path Partners
Boutique forensic schedule analysis practice

Twenty-four years in construction project controls and planning. Twenty inside nuclear and energy programs: refurbishment, new build, and ongoing maintenance outage planning at facilities where the schedule is a regulator-facing document, not just a project-management tool.

Relevant Experience
  • Forensic delay analysis across nuclear, energy, municipal infrastructure, mining, and commercial sectors, both as the analyst preparing the contractor's claim and as the rebuttal lead defending against an owner's counter-claim
  • Delay-claim work carried through negotiation, mediation and arbitration preparation, on both the claiming and the defending side
  • Primavera P6: production-grade fluency, 20+ years
  • AACE Recommended Practice methodology: Windows (MIP 3.3), TIA (MIP 3.7), Collapsed As-Built (MIP 3.8)
  • DCMA 14-Point Schedule Assessment: full-suite implementation
  • SCL Delay & Disruption Protocol, 2nd Edition: applied across active claims
  • Monte Carlo schedule-risk simulation: AACE 122R-22 QRAMM-aligned
Engagement Model

How we work with counsel.

Four ways to engage, scoped to the stage of the matter. Most engagements start with the preliminary assessment so counsel and the analyst can both decide whether full forensic work is warranted before either side commits the budget.

Notes for Counsel

Four notes on Ontario practice.

Written for counsel who retain schedule experts, and for in-house counsel reading the other side's report. Each note takes a position and says what it does not know. Statutory references are current to the e-Laws currency date of 13 August 2026. Each one prints to Letter as a clean document.

ON-01

Prompt Payment and Adjudication Timelines, and What They Do to a Delay Claim

The statutory timetable in Parts I.1 and II.1 of the Construction Act, current to 13 August 2026, and what it does to a delay claim. The 90 day post-completion bar makes adjudication a during-performance remedy, and the document set closes five days after the adjudicator is appointed. The analysis has to be finished before the notice goes out.

ON-02

GC 6.5 of CCDC 2 - 2020, and How a Schedule Analysis Maps onto It

GC 6.5 does not ask whether the job was late. It asks who caused each delay, and sorts causes into paragraphs with different consequences. Why the unit of analysis is the event, why every event needs two labelled dates, and why calendar mismatch is the defect that most often sinks an otherwise good time claim.

ON-03

The Deemed Undertaking, and What an Expert May Reuse Between Matters

Rule 30.1 is usually discussed as a constraint on lawyers. The harder problem is the expert, whose working library is built out of other people's productions. Why traceability is the line that works in practice, and why produced native schedule files must never enter a shared scheduling database.

ON-04

White Burgess, and How to Instruct a Schedule Expert

The impartiality threshold is easy to clear, which is why parties keep losing motions built on it. What White Burgess actually gives a construction file: how to instruct the expert, why the consultant who built the schedules has a stake in them, and the technical signature of advocacy in a delay report.

Discuss your matter.

A 15-minute call to determine whether CPP is the right fit. No obligation, no hourly charge for the conversation. If the matter is better served by a larger firm or a different methodology, we'll say so.