REA Final - 22 Dec 20 - eBook - 1682 pages

The movement / out of alignment of the steel also impacted the roof and deck elevations. Spearhead had to routinely “come back” or change ceiling elevations as a result of differing field conditions while the GFRC bases had to be cut along the uneven concrete deck that was “flat, but not level.” Lack of Schedule Despite repeated requests 8 , SWJV refused to provide a current, official project schedule to Spearhead. Without even a 2-week “Look Ahead,” Spearhead was left to make sense of images stitched together during the mandatory Pull Sessions hosted by SWJV back in July 2019. The lack of Schedule created an atmosphere of The Wild West with poor coordination leading to issues including, but not limited to:

• Congestion • Trade Stacking • Out of sequence work • Out of sequence fabrication of GFRG/C • Hoist delays • Stop-and-go work • Re-work • Comebacks • Short notice stoppages • Short notice delivery moratoriums • Poor access to work areas • Other delays such as wait time for 3 separate inspectors • “Hey you” extra work • Damage to installed work

In Summary Each of these issues created cascading delays, productivity losses and escalated costs. As the pace became frenetic, Spearhead proactively hosted weekly collaboration meetings to help SWJV meet a “schedule” Spearhead was only saw one time, in July 2019, on Post-It notes. Throughout the construction timeframe, Spearhead informed SWJV, daily, about these issues with minimal resolution. Detailed project notes and communications are provided to validate these claims. Spearhead Construction respectfully requests an immediate and equitable resolution in the amount of $2,265,784 before January 30, 2021. The delayed close out of this project continues to have a meaningful, negative financial impact on Spearhead Construction, and its owner.

Thank you for your attention.

8 Requests made in 23 Jan 19, 20 Mar 19, 10 May 2019, 14 May 19, 25 Jun 19, 16 Sep 19, 9 Oct 19, 23 Oct 19, 24 Oct 19, 4 Nov 19, 7 Nov 19, 9 Dec 19, 23 Dec 19.

Spearhead Construction, LLC * PO Box 575 * Fort Montgomery, NY 10922