This case involves a dispute between the owner and the contractor for the construction of a large chemical plant. The defendant won a commercial bid for an engineering, procurement, and construction (EPC) contract for plaintiff’s petrochemicals plant, but fell behind schedule and ultimately produced a project that was $400 million over budget and more than 21 months late. The plaintiff alleges that the defendant fraudulently misrepresented its capabilities and personnel prior to the contractual agreement and brought in undermanned and inexperienced engineering teams which caused delays and process errors. An expert in process engineering was sought to review the analysis carried out by the defendant, review the P&ID information and assess its level of design maturity, determine key changes, examine warranty standards, and opine on findings.