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Entity & Relationship Mapping

Who is who in the record, and who dealt with whom.

Overview

In a large record the same company or individual appears under several names, initials and email addresses, and the relationships that matter to liability are spread across contracts, correspondence and minutes. Entity & Relationship Mapping reconciles those names to the party behind them and sets out the parties, the individuals who acted for them and the dealings between them.

Counsel sees who contracted with whom, who gave notice to whom and who acted for which side, and can open any party to see everything the record holds on it, in date order.

Where it is used

Witnesses

Identifying the individuals who took the decisions in issue, and the documents each of them wrote, received or signed.

Liability

Tracing the contractual chain that frames indemnity, contribution and third-party claims.

Disclosure

Identifying the custodians whose documents the case turns on.

Witness preparation

Everything the record holds on one person, in one place and in date order, before that person gives evidence.

In practice

The principals to the dispute in the matter shown, by side and role.

The map

RRivergate TowerKKelmar ConstructionAAtlas CurtainwallBBrantley RoweVVantage FireCCorvalis PanelsPPriya RamanMMarcus OstrowDDaniel FerraraDDr. WhitfieldGGregory NunesHHarrow & FinchNNYC Dept. of Buildings
In disputeRelianceSupplyNotice givenEmployment

Each side’s dealings can be followed on their own by hiding the other groups.

One party, opened

Defendant, Facade Subcontractor

Atlas Curtainwall Systems Inc.

Mentioned in 92 places in the record
4 Oct 2020Insurance certificate renewedPROD-2649, p.11
3 Nov 2020Facade Subcontract - Kelmar and Atlas CurtainwallSubcontract, p.18, cl. 3.4
3 Nov 2020Schedule of Values, Facade PackageSchedule of Values, p.2, line 05 and note
Connected to
Subcontract, indemnity soughtKelmar ConstructionPurchase order ATL-PO-2207Corvalis PanelsData sheet disclosed 17 Jun 2021Brantley RoweVP OperationsMarcus Ostrow

Atlas Curtainwall: its role, its appearances across the record in date order, and the parties it dealt with.

A chain of connections

Rivergate Tower Owner LLCPlaintiff · claims not less than $96,400,000
↓  Prime contract, breach alleged
Kelmar Construction Group LLCDefendant · general contractor
↓  Subcontract, indemnity sought
Atlas Curtainwall Systems Inc.Defendant · facade subcontractor
↓  Purchase order ATL-PO-2207
Corvalis Composite Panels Inc.Third-party defendant · manufacturer

The contractual chain from owner to manufacturer that frames the indemnity and third-party claims.

How it works

The map is built from what the documents say, so contracts, certificates, correspondence and scanned letters all contribute, not only email traffic. Names are joined only where the record connects them. Counsel can merge, split or correct any party, and those decisions are kept as further disclosure is added.

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