## Pleading-to-Evidence Position Matrix | Proposition ID | Source / Paragraph | Party | Party Position | Factual Proposition | Issue | Supporting Evidence | Contrary Evidence | Evidence Status | Evidence Citation | Conflict / Gap | Notes | | -------------- | ----------------------------------------------- | ------------------------- | ---------------------------------- | ------------------------------------------------------------------------------------------------------------------------------------------------------------ | ---------------------------------------- | ------------------------------------------------------------------------------------------------------------------------------------------------------------------ | ------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | ------------------- | ----------------------------- | --------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | --------------------------------------------------------------------------------------------------------------------------- | | P-01 | Complaint / Claim ¶18 | Northfield Mechanical LLC | ALLEGATION | Revised Drawing M-204 was issued on March 14, 2026. | Timing/existence of revised drawing | Revised Drawing M-204 dated March 14, 2026; Site Instruction SI-17 dated March 16, 2026 refers to revised duct routing. | None identified. | SUPPORTED | Evidence 3; Evidence 6 | None identified. | Harbor Ridge expressly admits issuance. | | P-02 | Answer, admission concerning Complaint ¶18 | Harbor Ridge Builders | ADMISSION | Harbor Ridge admits that Revised Drawing M-204 was issued on March 14, 2026. | Timing/existence of revised drawing | Revised Drawing M-204 dated March 14, 2026. | None identified. | SUPPORTED | Evidence 3 | None identified. | Pleading admission aligns with documentary record. | | P-03 | Complaint / Claim ¶18 | Northfield Mechanical LLC | ALLEGATION | Revised Drawing M-204 materially changed the mechanical routing in the east wing. | Scope/routing change | Revised Drawing M-204; SI-17 directs Northfield to revise duct routing; Weekly Site Report Mar. 16–20 states Northfield began revised duct routing. | Harbor Ridge Answer states revised routing was required only to reflect field conditions already contemplated by the subcontract. | UNRESOLVED | Evidence 3, 6, 7; Answer | Material dispute over whether routing change was beyond the original contemplated scope. | The supplied record does not include a detailed comparison of original and revised M-204 sufficient to resolve materiality. | | P-04 | Answer, response to Complaint ¶18 | Harbor Ridge Builders | DENIAL | The revised routing did not materially change Northfield's contractual scope and instead reflected field conditions already contemplated by the subcontract. | Scope/routing change | Original subcontract; Original Drawing M-204; Revised Drawing M-204 may provide relevant comparison material. | Northfield alleges added ductwork and fire-damper work; SI-17 directs revised routing; March 16–20 report confirms revised work began. | UNRESOLVED | Evidence 1, 2, 3, 6, 7 | No supplied provision or drawing comparison conclusively establishes whether the revised routing was already contemplated. | This is the principal factual scope dispute. | | P-05 | Reply; Northfield position responding to Answer | Northfield Mechanical LLC | ALLEGATION | Revised routing required additional duct fabrication beyond the original subcontract documents. | Additional work / scope change | Revised Drawing M-204; SI-17; cost worksheet estimating additional duct fabrication. | Harbor Ridge denies material scope change and characterizes routing as within contemplated field conditions. | PARTIALLY SUPPORTED | Evidence 3, 6, 11 | The supplied record does not itself quantify or conclusively establish that the fabrication was outside the original subcontract scope. | Cost worksheet supports claimed additional fabrication cost but does not independently establish contractual scope. | | P-06 | Reply; Northfield position responding to Answer | Northfield Mechanical LLC | ALLEGATION | Revised routing required additional fire-damper installations beyond the original subcontract documents. | Additional work / scope change | Revised Drawing M-204; cost worksheet estimating fire-damper costs; Reply expressly identifies added fire dampers. | Harbor Ridge denies that the revised drawing materially changed contractual scope. | PARTIALLY SUPPORTED | Evidence 3, 11; Reply | Original Drawing M-204 and subcontract are supplied but no extracted comparison identifies the number or location of additional dampers. | Documentary support exists for the claimed additional-cost category, but scope comparison remains incomplete. | | P-07 | Complaint / Claim ¶21 | Northfield Mechanical LLC | ALLEGATION | Northfield submitted written notice of the resulting additional work and expected cost on March 19, 2026. | Notice of additional work/cost | Northfield email dated March 19, 2026, subject "East Wing Revision – Additional Work." | Harbor Ridge denies receiving a valid notice of additional cost on March 19; however, project manager email states March 19 email was "received and under review." | PARTIALLY SUPPORTED | Evidence 4, 5 | Receipt is supported, but the characterization of the email as a notice of additional cost, including its contents, is not fully reproduced in the supplied record. | Distinguish receipt of correspondence from characterization/adequacy of its contents. | | P-08 | Answer, response to Complaint ¶21 | Harbor Ridge Builders | DENIAL | Harbor Ridge denies receiving a valid notice of additional cost on March 19, 2026. | Notice of additional work/cost | Project manager email dated March 21 states March 19 email was "received and under review." | March 19 Northfield email exists and is titled "East Wing Revision – Additional Work." | PARTIALLY CONTRARY | Evidence 4, 5 | Record supports receipt of the email but does not contain its full text or establish whether it expressly identified expected cost in sufficient detail. | The dispute concerns characterization/content of notice more than whether an email was received. | | P-09 | Reply; Northfield position responding to Answer | Northfield Mechanical LLC | ALLEGATION | Northfield's March 19 correspondence identified the added work and anticipated schedule impact. | Notice / schedule impact communication | March 19 email exists; subject identifies "Additional Work." | Supplied record does not reproduce the body of the March 19 email. | INSUFFICIENT RECORD | Evidence 4 | Full email content is not supplied, so identification of the added work and schedule impact cannot be independently verified from the evidence description alone. | This proposition depends substantially on the contents of Evidence 4. | | P-10 | Complaint / Claim ¶24 | Northfield Mechanical LLC | ALLEGATION | The revised work delayed completion of Northfield's east-wing activities by 18 calendar days. | Delay and causation | March 12 progress schedule planned east-wing completion Apr. 3; Apr. 15 updated schedule shows completion Apr. 21; Mar. 16–20 report states revised routing began. | April 1–10 site reports show several periods when east wing was occupied by another trade. Harbor Ridge denies revision caused delay. | PARTIALLY SUPPORTED | Evidence 7, 8, 9, 10 | Schedule evidence shows a later completion date, but supplied record does not isolate 18 days as caused by the revised work. Access interference is a competing delay factor. | Apr. 3 to Apr. 21 is an 18-calendar-day difference, but causation remains unresolved. | | P-11 | Answer, response to Complaint ¶24 | Harbor Ridge Builders | QUALIFIED ADMISSION | Northfield's east-wing work was completed later than originally scheduled, but Harbor Ridge denies that the delay was caused by the drawing revision. | Delay and causation | Mar. 12 planned completion Apr. 3; Apr. 15 updated schedule shows completion Apr. 21. | Revised-work evidence and SI-17 provide a potentially competing cause; Apr. 1–10 reports identify access restrictions. | PARTIALLY SUPPORTED | Evidence 9, 10; Evidence 6, 8 | Timing of completion change is supported; causal attribution remains disputed and unresolved. | This position accepts lateness but not causation. | | P-12 | Amended Claim | Northfield Mechanical LLC | ALLEGATION | Access to the east wing was unavailable for several work shifts in early April because the area remained occupied by another trade. | Access / delay cause | Weekly site reports Apr. 1–10 show several periods when the east wing was occupied by another trade. | No supplied evidence directly establishes that the occupied periods prevented Northfield from performing particular scheduled tasks or caused a specific number of lost shifts. | PARTIALLY SUPPORTED | Evidence 8 | Occupancy is documented, but operational impact and exact duration of resulting delay are not fully established. | Amended access allegation has documentary support but causation/quantification remains incomplete. | | P-13 | Original subcontract dated Jan. 8, 2026 | NOT APPLICABLE | NOT APPLICABLE | The original subcontract contains mechanical scope and schedule provisions relevant to determining original work scope and planned performance. | Original scope / schedule baseline | Original subcontract. | None identified from supplied evidence. | SUPPORTED | Evidence 1 | The actual text of the relevant scope and schedule provisions is not reproduced in the supplied record. | Underlying terms require direct review for precise scope comparison. | | P-14 | Original Drawing M-204 dated Jan. 12, 2026 | NOT APPLICABLE | NOT APPLICABLE | The original Drawing M-204 provides the original mechanical drawing against which the March 14 revision can be compared. | Scope/routing baseline | Original Drawing M-204; Revised Drawing M-204. | None identified. | SUPPORTED | Evidence 2, Evidence 3 | No detailed drawing comparison is supplied. | Direct comparison is necessary to identify the precise routing and damper changes. | | P-15 | Site Instruction SI-17 dated Mar. 16, 2026 | NOT APPLICABLE | NOT APPLICABLE | Harbor Ridge issued SI-17 directing Northfield to revise duct routing in the east wing. | Scope change / direction to perform work | SI-17 dated Mar. 16; Weekly Site Report Mar. 16–20 records that Northfield began revised duct routing. | Harbor Ridge's position that the work reflected already-contemplated field conditions. | SUPPORTED | Evidence 6, Evidence 7 | SI-17 establishes direction to revise routing, but does not by itself establish that the work was contractually additional. | Distinguishes occurrence of instruction from characterization of contractual scope. | | P-16 | Weekly Site Report Mar. 16–20 | NOT APPLICABLE | NOT APPLICABLE | Northfield began revised duct routing during the week of March 16–20, 2026. | Performance of revised work | Weekly Site Report Mar. 16–20; SI-17 dated Mar. 16. | None identified. | SUPPORTED | Evidence 7, Evidence 6 | None identified. | Documentary record corroborates performance of revised routing. | | P-17 | Northfield cost worksheet | Northfield Mechanical LLC | ALLEGATION / CLAIMED FACTUAL BASIS | Northfield incurred or projected additional costs for duct fabrication and fire-damper work associated with the revised work. | Additional cost | Cost worksheet estimating additional duct fabrication and fire-damper costs. | Harbor Ridge disputes the underlying scope change; no independent invoice/payment record is supplied. | PARTIALLY SUPPORTED | Evidence 11 | Worksheet is an estimate and does not independently establish actual incurred cost or that the costs were outside original scope. | Characterized as claimed/estimated cost, not established actual cost. | | P-18 | Evidence 8; Amended Claim | NOT APPLICABLE | NOT APPLICABLE | During Apr. 1–10, the east wing was occupied by another trade during several periods. | Access condition | Weekly site reports Apr. 1–10. | None identified as to the occurrence of the occupancy itself. | SUPPORTED | Evidence 8 | Exact affected shifts, tasks, and resulting delay are not fully specified in supplied material. | Supports occurrence of access interference, not necessarily delay causation. | | P-19 | Evidence 9 vs Evidence 10 | NOT APPLICABLE | NOT APPLICABLE | The scheduled/planned east-wing completion moved from April 3 to April 21. | Delay chronology | Northfield progress schedule dated Mar. 12; Updated progress schedule dated Apr. 15. | None identified regarding the dates shown on the schedules. | SUPPORTED | Evidence 9, Evidence 10 | Schedule movement is documented, but the supplied record does not establish the cause or whether the April 15 schedule reflects actual completion versus forecasted/revised completion. | Important chronology evidence; causation remains unresolved. | ### Key unresolved factual conflicts captured by the matrix | Conflict / Gap | Supplied record | | ------------------------------------------------------------------------------------------------------- | ---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | | Whether Revised M-204 materially changed Northfield's contractual scope | **UNRESOLVED.** Northfield alleges additional routing, fabrication, and fire-damper work; Harbor Ridge says the routing reflected field conditions already contemplated by the subcontract. Evidence includes the original subcontract and both versions of M-204, but no detailed comparison is supplied. | | Whether March 19 correspondence constituted notice of additional cost/work | **PARTIALLY RESOLVED.** Receipt is corroborated by Harbor Ridge's March 21 email, but the full March 19 email content is not supplied, so the precise contents and characterization of the notice remain unresolved. | | Whether revised work caused the claimed 18-day delay | **UNRESOLVED.** The schedules show April 3 versus April 21 completion dates, while revised-routing work began March 16–20 and early-April access restrictions are documented. The supplied record does not allocate delay days between these causes. | | Whether early-April access restrictions caused delay to Northfield's work | **PARTIALLY SUPPORTED / UNRESOLVED.** Site reports document occupation by another trade, but the supplied material does not identify all affected shifts/tasks or quantify the resulting delay. | | Whether claimed additional duct/firedamper costs were actually incurred and were outside original scope | **PARTIALLY SUPPORTED / UNRESOLVED.** The cost worksheet supports the existence of claimed estimates, but the record does not include independent cost documentation or a sufficiently detailed original-versus-revised scope comparison. | **Record limitation:** The matrix is limited to the pleadings and 11 evidence items supplied in the prompt. Where document contents are described but not reproduced—particularly the March 19 email, the subcontract scope provisions, and the original/revised drawing details—the matrix preserves that limitation rather than treating the description as conclusive.