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Expert building evidence, from first advice to the witness box.

Engagements are accepted from solicitors, barristers, insurers and owners corporations, and are scoped to the questions the forum has to decide.

Expert witness reports

Code-compliant expert reports for NCAT and the NSW courts, including the expert's acknowledgment of the applicable code of conduct, a clear statement of instructions, assumptions, facts observed, reasoning and opinion, and the qualifications relied on.

  • Reports in the form required by NCAT Procedural Direction 3
  • Reports in the form required by UCPR Schedule 7, rule 31.23
  • Supplementary and reply reports
  • Expert determination and arbitration reports

Forensic defect investigation

Root-cause investigation of building defects and failures. Investigation begins non-destructively; where cause cannot be established without it, invasive investigation or testing is recommended and scoped in writing before it is carried out.

  • Water ingress, waterproofing and drainage failure
  • Structural movement, cracking and foundation performance
  • Concrete, façade and cladding defects
  • Workmanship, compliance and non-conforming building products
  • Storm and impact damage, and its separation from pre-existing defect

Rectification quantum and schedules

Independent costing of rectification works, built from a defined scope of works rather than a lump-sum allowance, so each item can be traced to the defect it answers and tested line by line.

  • Scope of works and rectification methodology
  • Bills of quantities and rectification cost estimates
  • Scott Schedules
  • Loulach Schedules for statutory duty of care claims

Conclaves, joint reports and hearings

Participation in expert conclaves and preparation of joint reports, and oral evidence at hearing. The expert who inspected the building attends, so the reasoning in the report is defended by the person who formed it.

  • Expert conclaves and joint reports
  • Concurrent evidence, including hot-tub sessions
  • Evidence in chief and cross-examination
  • Technical input to mediation and settlement conferences

Preliminary and merits advice

Early, unpublished technical advice on whether a defect case is worth running, what evidence would be needed, and where the technical weaknesses sit, before the cost of a full report is committed.

  • Review of another expert's report and schedule
  • Identification of the evidence a matter is missing
  • Realistic assessment of the technical case

Specialist assessments

Assessments in the areas the principal's standards and committee work draw on directly, including waterproofing, concrete, swimming pools and foundation movement.

  • Waterproofing and wet area compliance
  • Concrete durability and defects
  • Swimming pool construction and barriers
  • Foundation and footing performance
How an engagement runs

Four stages, each with something you can hold the office to.

Conflict check and scope

Parties and site address first. Independence is confirmed before any brief is opened. The issues requiring expert opinion, the documents to be reviewed, site access and the deliverables are then defined in writing, with an hours estimate and a delivery date.

Site inspection and investigation

The building is inspected methodically and conditions are recorded through photographs, measurements and, where required, moisture, level or other instrument readings. Non-destructive first; invasive investigation only where it is needed and only with instructions.

Analysis and report

Findings are analysed against the contract documents, the National Construction Code, the relevant Australian Standards, manufacturers' requirements and accepted construction practice. The report separates what was observed from what is inferred, and states the reasoning for each opinion.

Conclave, joint report and evidence

Where the matter continues, the same expert attends the conclave, signs the joint report and gives oral evidence. Areas of agreement and disagreement with the other expert are recorded with reasons, not just recorded.

Deliverables

What is delivered

In the report

  • Acknowledgment of the applicable expert code of conduct
  • The instructions and questions asked, reproduced in full
  • Facts observed, separated from assumed facts and from opinion
  • The standards, codes and documents relied on, cited specifically
  • Reasoning for each opinion, and the limits of each opinion
  • A disclosure of any generative AI use, and the annexed record of it

With the report

  • Photographic annexure, indexed and referenced from the body
  • Defect schedule in the form the forum uses
  • Rectification scope and costing where quantum is in issue
  • Curriculum vitae and list of documents provided
  • A statement of any matter that materially qualifies the opinion
Before you brief

Questions solicitors ask before briefing

How quickly can a report be delivered?
That depends on site access, the size of the brief and the current hearing-driven queue. An honest delivery date is given in writing with the fee estimate before the engagement is accepted, and if that date is going to move you will hear about it early rather than the week it is due.
Will you act only for owners, or only for builders?
Neither. Instructions are accepted from either side of a building dispute and from insurers and owners corporations. An expert who only ever appears for one side invites an obvious line of cross-examination, and this office does not create it.
What if the evidence does not support the case?
You are told, in a conference or a short written note, before a report is finalised. That is a cheaper outcome than a report that cannot be relied on, and it is required by the codes of conduct in any event.
Do you use generative AI in preparing reports?
Not to draft or prepare the content of an expert report, unless leave has been granted. Where AI is used for permitted purposes, the use is recorded contemporaneously and disclosed. The Independence and AI use page sets out exactly what is and is not used, and why.
What do you need to start?
The parties and site address for the conflict check, then the pleadings or points of claim, any existing expert reports and schedules, the contract and any variations, the relevant approvals and certificates, and the questions you want answered.

Considering John Cunniffe for a matter?

Send the parties and a short description of the issue. A conflict check is run before anything else, and you will have a reply within one business day.