The mountain, mapped

apply spearin doctrine (united states v. spearin, 248 us 132 (1918)) and design defect warranty to owner-side construction defect litigation. allocates design risk to owner (impliedly warrants design), but identifies cross-claims against architect/engineer for design defect, contract carve-outs (design-build), and disclaimer effectiveness.

compute and apply state statute of repose (sor) and statute of limitations (sol) for owner-side construction defect litigation. distinguishes absolute sor (runs from substantial completion, no discovery rule tolling) from sol (discovery rule applies). maps 50 states; refuses to certify a claim live when sor is closed.

structure pleadings, summary judgment opposition, and daubert / rule 56 record for owner-side construction defect cases. covers twombly/iqbal plausibility, expert affidavit requirements, genuine-issue creation, anderson "judge cannot weigh credibility" framework, and mid-litigation amendment strategy.

build expert testimony and daubert/rule 702 record for water intrusion, mold, and toxic-causation claims in construction defect litigation. distinguishes property damage causation (lower bar) from personal-injury / health-effect causation (daubert-vulnerable). covers astm standards, irmi/ansi envelope theory.