The Problem

Tile and Stone Claims Need a Technical Expert Who Has Actually Done the Work

Most construction defect experts come from engineering or architecture backgrounds. They know how structures behave, but they have never managed a tile installation schedule across multiple hotel floors simultaneously, or coordinated a stone package from overseas fabrication to finished lobby floor.

That gap matters in litigation. A defense expert with field installation experience can challenge academic opinions by demonstrating what the installation conditions actually required. Tactile CG brings 20 years of hands-on luxury hotel tile and stone installation to every engagement — the credibility of someone who has executed the work at the highest level, not just studied it in a manual.

Our reports are written to survive Daubert challenges — with documented methodology, instrument-based measurements, peer-reviewed industry standards as the reference framework, and conclusions that follow directly from the documented findings.

Claim Types We Support

Hotel tile and stone construction defect claims
Pool and spa deck failure — liability and remediation scope
Shower and bath waterproofing failure disputes
Exterior façade tile delamination and displacement
Material substitution disputes — approved equal vs. installed product
Specification deficiency claims against design professionals
Natural stone cracking — workmanship vs. inherent material defect
Multi-party disputes — installer, GC, designer, product manufacturer

We work for both plaintiff and defense counsel. Our obligation is to a technically accurate opinion — not to an advocacy position. Attorneys who retain us understand that our reports reflect what the evidence shows, which is why they are credible under cross-examination and effective at driving settlement.

How We Work

A Methodology Built for Legal Scrutiny

Expert opinions are only as strong as the methodology behind them. Every Tactile CG engagement follows a structured, documented process designed to produce findings that can withstand deposition questioning, Daubert challenges, and opposing expert rebuttal. We build the record correctly from the first site visit forward.

01

Case Document Review & Assessment

We begin with a thorough review of all available project documentation: original specifications, submittals and approved product data sheets, inspection records, change orders, photos from construction, prior expert reports, and any deposition transcripts. Understanding the full project record before the site visit ensures the investigation targets the right conditions and collects the right evidence.

02

On-Site Forensic Investigation

Site investigation uses the same instrument-based methodology as our forensic analysis service: thermal imaging, PosiTest AT-A bond pull testing, systematic sounding, physical measurements, and photographic documentation of conditions. Selective removal is performed where authorized to expose mortar beds, membranes, and substrate conditions. Chain of custody for physical samples is maintained from collection through laboratory analysis.

03

Expert Report Preparation

The written expert report is the foundation of the engagement. It includes a complete methodology description, findings with photographic and instrument data documentation, standards analysis for each deficiency, causation opinions, responsible party analysis within the project's construction chain, and remediation scope. Every opinion is directly supported by documented evidence — nothing is assumed or extrapolated without documented basis.

04

Rule 26 Disclosure & Rebuttal Reports

Expert disclosures are formatted to comply with Federal Rule of Civil Procedure 26(a)(2)(B) requirements, including a complete statement of opinions, the basis and reasons for each, the facts and data relied upon, and a list of materials reviewed. When opposing expert reports are served, we prepare rebuttal reports that address the methodological basis and technical accuracy of opposing opinions — not just conclusory disagreement.

05

Deposition Preparation & Testimony

We work with retaining counsel in advance of deposition to review the record, anticipate opposing counsel's challenge areas, and prepare to explain complex technical findings clearly and concisely. Deposition testimony is fact-based and technically precise — the same standard whether opposing counsel is attacking methodology, standards citations, or causation logic.

06

Mediation, Arbitration & Trial Testimony

We participate in mediation sessions with technical presentations designed to translate findings for non-technical decision makers. For arbitration and trial, we provide qualified expert testimony that explains how industry standards define competent practice, what the documented evidence shows, and why the identified deficiencies caused the failure at issue. The ability to explain technical complexity clearly — not just document it — is what moves cases toward resolution.

Technical Scope

What Our Expert Engagements Cover

A complete tile and stone expert engagement covers the full record of the installation — from the specification that governed the work to the conditions that exist today. These are the technical elements that determine causation, liability allocation, and remediation scope.

Project specification analysis — does the specification comply with TCNA, ANSI, and NSI requirements? Were the requirements adequate for the application, and did the installation meet them as written?

Submittal and approved product review — what setting materials, waterproofing products, and tile were approved? Were what was submitted and what was installed consistent with each other and with the specification?

Change order and substitution documentation — were material substitutions properly evaluated and approved? Did scope modifications eliminate required installation elements — such as movement joints or waterproofing — without owner knowledge?

Bond strength testing with PosiTest AT-A — quantified adhesion data at failure locations and control areas, measured in psi, referenced against ANSI A108 minimum requirements and manufacturer published values

Thermal imaging of failure patterns — FLIR camera documentation of delamination extent, hollow areas, moisture intrusion patterns, and bonding anomalies across the full installation scope

Mortar and material laboratory analysis — certified laboratory testing of mortar samples for composition, sand ratio, and Portland content; adhesive residue testing to confirm product identity; stone specimen analysis where applicable

Movement joint presence, placement, and sizing — are field joints and perimeter joints present, correctly located at intervals required by TCNA EJ171, and properly filled with compressible sealant rather than rigid grout?

Waterproofing membrane condition and continuity — is the membrane intact, continuously bonded, and properly detailed at drains, penetrations, and changes of plane? Were flood test results documented?

Causation opinion and responsible party analysis — which deficiency caused the failure, in what sequence, and which party in the construction chain — installer, GC, designer, manufacturer — bears responsibility for each identified deficiency?

Remediation scope documentation — technically grounded scope narrative for the corrective work required, structured to give estimators and contractors measurable, enforceable remediation requirements

Opposing expert rebuttal analysis — review of opposing expert methodology, standards citations, and opinion conclusions for technical accuracy; preparation of written rebuttal addressing each area of disagreement with factual and standards basis

Non-testifying consulting review — for attorneys who need a technical sounding board for trial preparation without retaining a testifying expert, available for confidential consulting review of documents, reports, and deposition transcripts

Standards & References

Every Opinion Grounded in Published Industry Standards

The legal standard for a qualified tile and stone expert is whether the methodology and opinions reflect what is generally accepted within the industry. These are the published standards that define accepted practice — and the basis for every deficiency opinion we issue.

TCNA

Tile Council of North America Handbook

The primary reference for installation method selection in the industry

EJ171 — the published standard for movement joint design and placement

Method-specific substrate and material requirements for each application

Waterproofing and crack isolation requirements for wet and exterior areas

ANSI

American National Standards Institute

A108.01–A108.19 — the workmanship standards courts look to for industry practice

A108.5 — the 95% bond coverage minimum for wet areas and exterior applications

A118 series — material performance classifications for setting and grouting products

A136.1 — organic adhesive limitations, including application restrictions for wet areas

NSI

Natural Stone Institute

Dimension Stone Design Manual — governing reference for natural stone installation

Minimum grout joint widths to accommodate dimensional variation in stone

Classification standards distinguishing installation failure from material defect

Sealing and maintenance requirements relevant to claims of owner-caused damage

Who We Work With

Expert Witness Clients We Serve

Plaintiff & Defense Construction Attorneys

You need a technical expert whose opinion will withstand the other side's challenge. We provide written reports structured for legal use, depositions that hold up under aggressive cross-examination, and testimony that translates complex technical findings for judges and juries. We work for both sides — our obligation is to the facts, which is why we are effective.

Insurance Adjusters & Coverage Counsel

Coverage decisions on tile and stone claims require a technically credible determination of cause and scope. We provide independent expert reports that document what caused the failure, what the remediation scope requires, and what the responsible installation standard required — giving adjusters and coverage counsel a defensible technical basis for their decisions.

Owners, GCs & Subcontractors in Dispute

When a tile or stone failure generates a claim, the critical first question is who is responsible and for what scope. An independent expert investigation establishes the technical record before positions harden. Whether you are pursuing a claim or defending one, a standards-referenced expert opinion establishes the basis for your position at every stage of the process — from demand letter to trial.

What You Receive

Tangible Outcomes from an Expert Witness Engagement

Professionally Formatted Expert Report

Complete report with methodology description, instrument data, photographic documentation, standards citations for each finding, causation opinions, responsible party analysis, and remediation scope — structured for legal use from the outset.

Rule 26 Compliant Expert Disclosure

Expert disclosures formatted to satisfy FRCP 26(a)(2)(B) requirements — complete statement of opinions, bases and reasons, facts relied upon, and all materials reviewed — ready for filing on the disclosure deadline.

Rebuttal Report Against Opposing Expert

A technical rebuttal that addresses the opposing expert's methodology and conclusions directly — identifying where their investigation was incomplete, their standards citations were incorrect, or their causation logic does not follow from the documented evidence.

Deposition & Trial Testimony

Testimony that holds up under cross-examination — technically precise, grounded in documented evidence, and capable of explaining industry standards to non-technical decision makers without oversimplification or loss of accuracy.

Standards-Referenced Deficiency Documentation

Every deficiency tied to the specific TCNA, ANSI, or NSI section that was violated — the standard, the requirement, and the measured shortfall. This is the documentation that creates settlement leverage and survives Daubert challenge.

Settlement Leverage from Day One

Reports structured for impact at the earliest stage of the claim — a technically credible, standards-referenced expert opinion changes the negotiating dynamic before depositions are taken and before trial preparation costs mount.

Project Experience

Every forensic investigation Tactile CG conducts is structured from the first site visit to support expert testimony if the matter proceeds to litigation. The cases below represent the quality of technical documentation we deliver.

Pool Deck

Luxury Hotel Pool Deck · Travertine

Travertine Pool Deck Failure: "Miami Sandwich" Mortar Composition Defect

Pool deck travertine lifting and cracking investigated to determine liability for a remediation claim exceeding six figures. Laboratory analysis of mortar samples confirmed an oversanded mixture inconsistent with project specifications. The "Miami Sandwich" installation pattern — dry sand beneath set mortar — was identified and documented as the primary structural failure mechanism, establishing the installer's liability for the full remediation scope.

Expert Outcome Lab analysis confirmed mortar composition violated specification. Standards-referenced report established contractor liability.

Hotel Lobby

Luxury Hotel Lobby · Porcelain Tile

Lobby Tile Cracking: Missing Movement Joints Throughout Field

Systematic diagonal cracking across a hotel lobby tile installation investigated for a construction defect claim involving both the tile subcontractor and the project architect. Investigation documented a complete absence of movement joints in the field area and evaluated whether the project specification's failure to require EJ171 compliance shared causation with the installer's failure to provide joints per industry standard practice.

Expert Outcome Causation analysis assigned liability across both the installer and the specifying architect. Multi-party settlement followed report issuance.

View All Case Studies

Retain an Expert

Need a Tile or Stone Expert for an Active Claim?

Early expert retention produces better outcomes. The investigation shapes the record, the record shapes the report, and the report shapes the case. Contact us to discuss your matter — we respond within one business day.

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