Critical Path Scheduling: A Properly prepared CPM schedules is of paramount importance to recovering delay and impact damages. Ideally, you have a good original or baseline schedule, regular updates, and final As-Built CPM schedule. Proper CPM schedules are the best and perhaps the only realistic means to recover delay damages, or to escape assessment of liquidated damages. There are several analysis methods used by consultants.
Resource Charts and Curves: The plotting of man-hours, or resources over time combined with annotations of events or periods of impact are quite important to demonstrate that the events resulted in changing the planned and proper execution of the contract. Such curves can be prepared with scheduling software or even MS Excel.
Combinations of bar-charts and resource curves: When these two are combined, a clear picture of what happened during a project can be demonstrated. For example, when critical and heavily cost loaded activities are lengthened/delayed significantly, the resource curves will deform from the planned or normally expected shapes. Properly filtered and annotated graphics are of considerable value as proof of impact.
Event time-line: One of the first steps in preparation of almost any claim is the development of a timeline of events. This is usually a spreadsheet that is created from documents such as daily reports, test records, quality control reports, correspondence, email, etc. The time-line can then be used for preparation of other proofs.
Exhibit list: Regardless of your venue of settlement, having the key documents organized, listed, and cataloged in an exhibit list is essential. It is also possible to combine the Event time-line and the Exhibit list in a single spreadsheet. The exhibit list can be hyper-linked to marked electronic versions of the documents. If you are trying to keep your preparations to appear less legalistic you can call exhibits, attachments.
Cause and Effect
There are a few tried and true tools or methods that can be used to prove causality for damages. These data models have been used for many years to prove causality. It is not enough to show that you are damaged. You must show that actions or inaction of others caused your damages. Further, there must be either contractual and/or tortious interference by the offending party. The following have been used by ALLEN BALLEW & Associates Consulting to obtain a proper recovery for clients.