§15.9 Lists of Documentary Evidence

• Jurisdiction: Washington

§15.9 LISTS OF DOCUMENTARY EVIDENCE

This discussion provides lists of documentary evidence that should be obtained to analyze a claim, with respect to project daily reports, prebid records, project events generally, labor costs, material costs, operating costs (see below), subcontractor costs, and owner damages.

Specific items that should be recorded daily in the project report include

(1)	manpower of all contractors on site;
(2)	equipment used and idle;
(3)	work activities;
(4)	all problems encountered or discovered;
(5)	areas of work not available;
(6)	safety and accidents;
(7)	oral instructions;
(8)	meetings;
(9)	weather conditions and
(10)	visitors.

A properly prepared jobsite daily report could be a primary source of proof for a variety of claims. Significant amounts of raw data also may be extracted from the jobsite daily reports relative to preparation of damage calculations.

The following types of prebid records should be created in the ordinary course of business and can be used to provide proof of the quantum of damages:

(1)	request for bid/quotation
(2)	bid package drawings and specifications
(3)	addenda
(4)	prebid correspondence
(5)	prebid meeting minutes

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(6)	prebid telephone conversation logs
(7)	prebid contractor site investigation reports
(8)	prebid photographs
(9)	quantity take-offs
(10)	prebid proposed progress schedules
(11)	prebid proposed manner method, and means analyses
(12)	manpower, equipment, and material calculations
(13)	subcontractor and supplier quotations
(14)	bid worksheets
(15)	summary sheets with overhead and profit calculations
(16)	bid submittal package

Documentary items that will substantiate the project events include the following:

(1)	correspondence
(2)	meeting minutes
(3)	shop drawing logs
(4)	RFI logs
(5)	drawing and specification revision logs
(6)	project schedules and updates
(7)	daily diaries, logs, or reports
(8)	project cost reports
(9)	"measles" diagrams
(10)	punch lists

Documentary items that can substantiate labor costs...