“An opinion is only as strong as the record behind it. I document what the surface was, what the code and the manufacturer required, and what the owner’s logs show they did about it. Evidence Before Opinion.”


Illinois state courts apply the Frye standard as adopted in Donaldson under Illinois Rule of Evidence 702; federal courts apply Daubert. Paul's opinions are experience-based and rely on established, non-novel methods, tied to ASTM F1637, the applicable building code, ADA requirements and the manufacturer's installation and maintenance instructions.
The full testimony history and a current fee schedule are available in the curriculum vitae upon request for Rule 26 disclosure.
The as-found condition is recorded on site with photographs, dimensional measurement and moisture readings before any opinion is formed.
Scope limits are set out on the face of the report rather than left to emerge under cross-examination.
Every finding is tied to ASTM F1637, the building code, ADA requirements or the manufacturer's instructions.
Inspection logs, work orders, janitorial records and prior complaints are read together with the physical evidence.
The same method is applied whichever side retains him, and the opinion does not move to suit the party paying for it.
Findings are written in plain terms, with the standard applied and the scope limit stated on the face of the report.
No opinion is offered before the record supports it. Where the documentation will not carry a conclusion, that is said plainly.
Every observation is recorded and photographed so the basis for each opinion can be followed and tested by another expert.

Slip and fall / personal injury. Retained for the plaintiff. Work performed: review, report and deposition.

Construction defect. Retained for the plaintiff. Work performed: review, site visit, report, deposition and trial testimony.

Construction defect. Retained for the defendant. Work performed: site visit, review, report and arbitration hearing.

Construction defect. Retained for the plaintiff. Work performed: site visit, review, report and deposition.
Retained by Plaintiff & Defense Counsel