STEPHEN P. WARHOE, PH.D., P.E., CCP, CFCC

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1 STEPHEN P. WARHOE, PH.D., P.E., CCP, CFCC Dr. Warhoe is a Senior Principal with Long International and has a proven background in the planning, control, and management of multiple major design and construction projects. With 30 years of experience in the project controls and project management fields, he is a recognized expert in the area of schedule delay analysis, productivity loss, project controls and construction dispute avoidance and resolution. Dr. Warhoe is an expert in retrospective CPM schedule delay analysis and also specializes in system dynamics and wrote his Ph.D. dissertation on the subject: Applying Earned Value Management to Design-Bid-Build Projects to Assess Productivity Disruption A System Dynamics Approach. The recognition for his expertise and respect in the project controls field culminated with his election as the president of AACE International during Additionally, with his extensive experience in schedule and cost control, he continually demonstrates his value to clients having planned and controlled multibillion-dollar budgets and schedules. He is also skilled in the negotiation, audit, evaluation, and administration of contractor, consultant, vendor, and service contracts. EDUCATION Ph.D., Strategy, Project & Program Management, Skema Business School, Lille, France, 2012 M.B.A., Colorado State University, Denver, 1993 B.S., Civil Engineering, University of Colorado, Denver, 1986 PROFESSIONAL REGISTRATIONS AND CERTIFICATIONS Professional Engineer, Colorado, No Certified Cost Professional (CCP), AACE International, No Certified Forensic Claims Consultant (CFCC), AACE International, No. 12 PROFESSIONAL AFFILIATIONS Association for the Advancement of Cost Engineering (AACE): Association President, Technical Board Member, 2010 Present Construction Management Association of America (CMAA), Past Chapter President, Colorado Chapter TEACHING EXPERIENCE Adjunct Professor, Masters in Project Management, Skema Business School, Paris, France, Cost Engineering Topics, Adjunct Professor, International Masters degree in Business Administration program, Tongji University, Shanghai, China, Topics in Project Management and Cost Engineering, TECHNICAL EXPERIENCE Representative U.S. and international technical experience includes: Construction claims preparation, analysis, defense, and negotiation of settlements.

2 Resume of Stephen P. Warhoe, Ph.D., P.E., CCP, CFCC Page 2 Development of project and risk management plans and procedures for complex, mega projects. Management of commercial and heavy construction projects, including program and project management, and the management of major domestic and international engineering and construction contractors as the owner s representative. Identification and systematic evaluation of major engineering and construction problems and their cause/effect relationship on cost and schedule overruns. Management of project performance measurements and assessments. Deposition and expert witness testimony. Speaker and author of numerous articles on the subject of construction claims, project cost and schedule control, change order management, and project management. Development of computerized database management systems. CPM schedule analyses of the impacts of delays, disruption, acceleration and loss of labor productivity. Contract/entitlement analysis. Direct and indirect costs calculation and assessment. PROJECT EXPERIENCE As an expert in program/construction management and claims and disputes resolution consultant, Dr. Warhoe has worked on numerous projects in the U.S. and internationally; representing owners, designers, contractors and insurance underwriters. Representative Project and Construction Management Experience Lead Schedule Engineer in the construction of Limerick nuclear generating station, unit #2, located in southeast Pennsylvania. Responsibilities included performance tracking and forecasting of all civil construction on the US$4 billion program. As the lead schedule engineer, responsible for directing the civil construction superintendents on a daily basis of what work was highest priority for completion, tracking the performance, forecasting completion dates, coordinating with the work of other craft areas, and tracking delayed and disrupted work on the project. Worked with representatives of BAA to create the risk management program for Heathrow International Airport s US$6 billion capital improvement program. Helped create architecture for risk program that integrated BAA s updated policies and procedures with new software infrastructure. Risk management processes and procedures were developed at the project, program and portfolio levels. Represented the Malaysian government as a construction manager and project controls expert overseeing 21 civil and process projects, cumulatively valued over US$1 billion on the Kuala Lumpur International Airport, a green-field mega civil construction program, valued at over US$3.6 billion. One of the largest projects was the construction of the airport fueling lines, fuel tank farm and transition structure for the external fuel supply line. Managed 20 capital improvement projects simultaneously, on average, with a budget of approximately US$ 40 million, for the Coors Brewing Company in Golden, Colorado and Memphis, Tennessee. Developed and implemented all program management level processes and procedures for a US$4.3 billion floating bridge and freeway replacement in the Seattle area for the Washington State Dept. of Transportation.

3 Resume of Stephen P. Warhoe, Ph.D., P.E., CCP, CFCC Page 3 Developed and implemented risk management processes and procedures for a US$4 billion tunnel/freeway design and construction program for the Washington State Dept. of Transportation in Seattle, Washington. Managed a US$25 million nationwide construction management Indefinite Delivery/Indefinite Quantity (ID/IQ) contract with the U.S. National Park Service. Construction manager on a US$13 million middle school construction for the Poudre School District in Fort Collins, Colorado. Program and construction management consultant for the Clark County School US$1 billion school construction program in Las Vegas, Nevada. Duties included evaluation of claims and disputes received by school district from construction contractors and advising district management on construction management issues. Representative Claims and Disputes Resolution Experience On behalf of the Independent Electricity System Operator (IESO), formerly the Ontario Power Authority (OPA), considered Bruce Power s request concerning alleged delay impacts resulting from a May 2012 force majeure shut-down event of Unit II at its Unit A LP (BALP). Based on document review and analyses, provided opinions concerning: a) whether delay impacts to the Unit I commissioning period occurred coincident with the Unit II force majeure event, and b) if the resulting Unit I delays were attributable to work associated with or caused by the Unit II force majeure event. Assisted in cost analyses concerning disputed design and construction cost over-runs for the initial construction and ensuing Three Mile Island retrofit work, for the multi-billion-dollar Zimmer nuclear power plant located in central Ohio. Evaluated and performed schedule delay expert witness services regarding an approximate $25 million dispute between an electric power generator and a power distribution company in Alberta, Canada. Services included identifying and analyzing project records to determine schedule impacts resulting from accelerating the start of planned outage work to be in parallel with necessary work associated with a forced outage on a coal-fired power plant. Performed schedule delay expert witness services, including testimony, with respect to an approximate US $30 million dispute between an electrical power generator and a consortium of power distributors in Alberta, Canada on a coal-fired power plant. Arbitration Testimony. Represented a major EPC firm s commercial general liability insurance underwriter relative to major rework that a EPC firm was required to perform concerning the $500 million construction of eight scrubber units located at four coal-fired power plants in the central United States. Duties included review and evaluation of EPC firm s cost and schedule reports for its rework efforts on behalf of the underwriters. Deposition Testimony. Retained by counsel for Qui Tam plaintiff to review prime construction contractor s pricing procedures and the pricing for various Bid Unit Prices involved in the construction of major U.S. Corps of Engineers dam in southern California. In addition, provided opinions regarding the adequacy and accuracy of data provided in support of the procedures and preparation of various Bid Unit Prices. Assisted with the CPM schedule and productivity analyses relative to the construction of a major oil and gas management facility for the Kuparuk oil field near Prudhoe Bay, Alaska. Weather conditions played a major role in the analyses. On behalf of a general contractor who was engaged to construct a storm water (snowmelt runoff) collection system feeding a diversion through the Continental Divide to enhance the water supply system of the city of Cheyenne, Wyoming municipal water system, assisted in preparation of a claim

4 Resume of Stephen P. Warhoe, Ph.D., P.E., CCP, CFCC Page 4 for an equitable adjustment. Issues included constructive changes to the contract occurring in an environmentally and seasonal weather-restrictive contract framework and resulting delays and cost impacts. Evaluated CPM schedule delay and damage analyses submitted by general contractor, and performed separate CPM schedule delay, productivity and damage analyses regarding the construction of a plant to manage used deicing fluid at the Denver International Airport. Delay analysis including contractor s claim that delays caused by owner affected its ability to complete on time due to movement of critical work into periods of cold weather conditions. Damage analysis included evaluation of contractor's expended costs, base bid estimate, delay analysis, and change orders. Deposition Testimony. Aided in the analysis and expert strategy in defense of a delay claim by a contractor building a school in a coastal village located in western Alaska. The contractor was responsible for the delivery of construction materials to the construction site. Much of the materials were delivered via barge, limited by a relatively short delivery window due to Alaskan coastal climate conditions. Sensitivity to the local climate was an important factor in the schedule analysis. Representing the owner, led negotiations of over $7 million in changes disputed by the general contractor on a $7 million renovation on a steel manufacturing plant in Pueblo, Colorado. Provide construction management and dispute resolution expertise concerning the major renovation and upgrade of a meat processing plant in southwest Oklahoma. Represented the owner concerning disputes it had with design/builder on work performance and compliance with performance specifications. Analysis included a review of the contractor s CPM schedule and payment applications. Evaluated circumstances leading to a construction accident resulting in the electrocution of a construction worker in a project to add to a hospital located in Edmonds, WA. Wrote expert report addressing the prime contractor s liability associated with the accident. Deposition Testimony. Evaluated schedule delay analysis submitted by contractor concerning additions and modifications to Washington State SR-518. Evaluated project baseline CPM schedule and updates and reconciled with state inspection reports, along with contractor's narrative delay claim. Submitted a report to State's executive management with recommendations. Performed CPM schedule delay, productivity and damage analyses in support of contractor's claim relative to construction of luxury condominium units in Telluride, Colorado. Developed CPM schedule delay analysis on behalf of developer in dispute with contractor that was terminated for convenience relative to multi-unit apartment complex in Denver, Colorado. Arbitration Testimony. Performed construction performance analysis and CPM schedule delay analysis for general contractor disputing services provided by its glass subcontractor on the construction of an engineering classroom building on the University of Colorado campus in Boulder, Colorado. Arbitration Testimony. Performed contract evaluation, CPM schedule delay and cost analyses, representing the architectengineer, concerning a dispute with the Crawford county commissioners for the design and construction management of a jail in central Ohio. Performed delay and productivity analyses on behalf of the City of Dayton, Ohio with respect to the construction of airplane taxi-ways at the City s primary airport. Deposition Testimony. Representing an Italian general contractor, assisted in the CPM schedule delay analysis for the construction of two hospitals in Kuwait. Assisted in the cost analysis of the post-fire reconstruction of the MGM Grand hotel, Las Vegas, Nevada.

5 Resume of Stephen P. Warhoe, Ph.D., P.E., CCP, CFCC Page 5 PROFESSIONAL EXPERIENCE Long International, Inc. Suquamish, Washington (June 2009 to Present) Dr. Warhoe provides a variety of dispute resolution services, including but not limited to schedule delay and acceleration analyses, productivity analysis, change order analysis, cost and damages analyses, review of bids, estimates, and contract documents, and claims preparation. Baillie & Associates Seattle, Washington (July 2006 to June 2009) Served as Senior Consultant to the Washington State Department of Transportation regarding $4 billion+ SR-520 Bridge Reconstruction projects. Set program controls performance standards and developed management processes and procedures. Recruited, hired, and trained all project team members. Developed, reviewed, negotiated, and approved all consultant contracts. Delivered executive reports, presentations, and training sessions to senior management and project staff. URS Corporation Denver, Colorado (July 2002 to June 2006) Performed as Regional Manager for its Claims & Dispute Resolution Practice, and oversaw the corporate regional construction projects. Managed all aspects of construction services division s dispute resolution services encompassing a nine-state region. Directed business development and marketing for construction management and disputes practice divisions. Mr. Warhoe was the company s primary testifying expert for Rocky Mountain region on issues of delay and damages related to construction project disputes. Additionally, he analyzed and wrote comprehensive and cogent expert reports pertaining to delay disputes, leading a profitable office with direct staff reports. PEAC, LLC/CDI Denver, Colorado (September 1998 to June 2002) As a Senior Project Manager for the Coors Brewing Company, planned and managed all phases of all building, plant infrastructure and utility projects at Coors plants in Golden, Colorado and Memphis, Tennessee. Reviewed process flow diagrams, P&ID s, and electrical single line diagrams. Led and coordinated several highly motivated project teams including design consultants, construction contractors and corporate project engineering and construction staff. Led, negotiated and competitively bid construction contract procurements. Negotiated all changes to contracts. Delivered presentations to and interfaced regularly with executive management. Prepared expert delay, productivity, and damage analyses as an independent consultant, supporting another claims and disputes firm. Additionally provided litigation support including expert testimony concerning construction disputes. URS Corporation Denver, Colorado (October 1990 to September 1998) As a Project Controls Manager, Mr. Warhoe focused on managing project controls for major environmental contracts out of the company's Denver and Seattle offices. Services provided include simultaneously managing the controls for two $100 million+ federal environmental mitigation programs, as well as several

6 Resume of Stephen P. Warhoe, Ph.D., P.E., CCP, CFCC Page 6 other projects in various business sectors. Successfully, created and implemented the company's first Earned Value Management System used to manage the performance of both environmental programs. CRSS, Inc. Greenville, South Carolina and Los Angeles, California (July 1987 to October 1990) Served as a Project Controls Engineer on numerous projects including the design of microchip manufacturing plants and amusement parks. Mr. Warhoe was responsible for developing and implementing a design performance management system for a multi-discipline design project, ensuring on time and under budget delivery. Bechtel Western Power Company Pottstown, Pennsylvania (January 1987 to July 1987) As a Schedule Engineer, Mr. Warhoe was responsible for all civil construction scheduling associated with the construction of the Limerick Nuclear Generating Station located near Pottstown, Pennsylvania. He established use of Primavera scheduling software as a tool for the civil construction department. The construction work that was being scheduled included structural erection, major concrete structures, pipe penetration seals, carpentry, structural footings, and major excavation. Kellogg Corporation Littleton, Colorado (November 1984 to December 1986) As a Senior Claims Analyst, performed schedule and cost/damage analyses relative to various construction dispute and litigation matters. The projects included nuclear power plants, major hotels, airports, pipelines, hospitals, and manufacturing plants. PUBLICATIONS, SEMINARS AND SPEAKING ENGAGEMENTS Third Party Cold-Eyed Estimate Reviews and Validations, AACE International Annual Meeting, New Orleans, LA, June Applying Earned Value Management to Design-Bid-Build Projects to Assess Productivity Disruption A System Dynamics Approach, Ph.D. Dissertation, Skema Business School, Lille, France, August Understanding the Effects of Rework and Change of Scope on Productivity and Project Performance Using Systems Thinking, System Dynamic Society Annual Conference, Seoul, South Korea, July Schedule Specifications Handle with Care, Cost Engineering Magazine, January/February Is the Theory of Cumulative Impact a Provable Reality? Cost Engineering Magazine, July Is the Theory of Cumulative Impact a Provable Reality? AACEI Annual Meeting, Las Vegas, Nevada, June What Can Be Done to Avoid Claims? A Common-Sense Approach to Avoid Claims for Project Managers, City of Boulder, Colorado, January Construction Management: A Concept in Search of a Definition, SuperConference, San Francisco, co-presenter, December Cumulative Impact Claims Are they Real, Colorado Bar Association, Denver, November 2005.

7 Resume of Stephen P. Warhoe, Ph.D., P.E., CCP, CFCC Page 7 Project Documentation Use It or Lose It, Los Angeles Bar Association, Los Angeles, co-presented with John Hanover, Esq., Peckar & Abramson, P.C., September Mitigate and Manage Adverse Weather Impacts, URS Corporation s Claims & Disputes Newsletter, February The Basics of Earned Value Management, AACEI Annual Meeting, Washington D.C., June Understanding Risk to Mitigate Changes and Avoid Disputes, AACEI Annual Meeting, Orlando, Florida, co-authored with Adam Winegard, URS Corporation, June Define Allowable Project Indirect Costs Early, URS Corporation s Claims & Disputes Newsletter, March TESTIMONY EXPERIENCE 2016 Estate of Jason F. Vanlandingham v. Sellen Construction Co. Washington State Superior Court; Seattle, Washington. Deposition Testimony Black & Veatch, Inc. v. Insurance Underwriters U.S. Federal Court, Kansas City; Berkeley, California. Deposition Testimony TransAlta Generation Partnership v. ASTC Power Partnership Calgary, Alberta, Canada. Arbitration testimony City and County of Denver, Colorado (Denver International Airport) v. TechSites, Inc. Denver, Colorado. Deposition testimony Alliance Construction Solutions, Inc. v. GlassTech, Inc. Boulder, Colorado. Arbitration testimony Del Norte Neighborhood Development Co. v. Stanisz Construction Co. Denver, Colorado. Arbitration testimony City of Dayton, Ohio v. Excel Construction Co. District Court, State of Ohio; Columbus, Ohio. Deposition testimony.

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