Client now delaying Completion Date with Damages (where previously both Client & Contractor have caused delays)

Hi all,

I've been tasked with looking at claiming EOT on a contract that's using NEC3 and there are damages attached to the Completion Date - without any real commercial training (so apologies if using incorrect terminology).....

The duration has previously been extended - we were cuplerable for some delays and the client for others (resulting in Completion Date and our paid prelimns extending, but not covering the whole period up to our current Planned Completion).

The client is now preventing access to an area of works, preventing 4 months remaining of works from being completed.

By impacting the last accepted programme, adding the movement in Planned Completion onto the previously accepted Completion Date gets our prelimns paid for that period, but it looks like we're still exposed to damages.

Based on the arguement that we couldn't have completed the works any earlier due to not having access, should it move our Completion Date (for avoiding Damages) to after those 4 months?

Thanks in advance,

Chris