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VRIJLING, JOHANNES KORNELIS

1/8/2008

Page 1
UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF LOUISIANA

IN RE: KATRINA CANAL BREACHES CIVIL ACTION


CONSOLIDATED LITIGATION
NO. 05-4182
"K" (2)
PERTAINS TO: ROBINSON JUDGE DUVAL
NO. 06-2268

MAG. WILKINSON

Videoconferenced Deposition of
JOHANNES KORNELIS VRIJLING,
Professor of Hydraulic Engineering at TU
Delft, Avenue Concordia 78, 3062 LL,
Rotterdam, Netherlands, reported in the
offices of Bruno & Bruno, 855 Baronne Street,
New Orleans, Louisiana 70113, on Tuesday, the
8th day of January, 2008.

Johns Pendleton Court Reporters 800 562-1285


VRIJLING, JOHANNES KORNELIS
1/8/2008
Page 2 Page 4
1
2 APPEARANCES:
1 STIPULATION
3 2
4 LAW OFFICE OF JOSEPH M. BRUNO
BY: JOSEPH M. BRUNO, ESQ. 3 It is stipulated and agreed by and between
5 SCOTT JOANEN, ESQ.
835 Baronne Street
4 counsel for the parties hereto
6 New Orleans, Louisiana 70113
PLAINTIFFS LIAISON COUNSEL
5 that the deposition of the aforementioned
7 6 witness is hereby being taken under the
8 UNITED STATES DEPARTMENT OF JUSTICE
BY: JACK WOODCOCK, ESQ.
7 Federal Rules of Civil Procedure, for all
9 Torts Branch, Civil Division
1331 Pennsylvania Avenue N.W.
8 purposes, in accordance with law;
10 Room 8095N 9 That the formalities of reading and
Washington, D.C. 20004
11 ATTORNEYS FOR UNITED STATES OF AMERICA 10 signing are specifically waived;
12
(PRESENT VIA TELECONFERENCE) 11 That the formalities of certification and
13 12 filing are specifically waived;
---- ALSO PRESENT-----
14 13 That all objections, save those as to the
15 MCCRANIE, SISTRUNK, ANZELMO, HARDY, MAXWELL &
MCDANIEL
14 form of the question and the responsiveness of
16 BY: THOMAS P. ANZELMO, ESQ. 15 the answer, are hereby reserved until such
Suite 800
17 3445 North Causeway Blvd. 16 time as this deposition, or any part thereof,
18
Metairie, Louisiana 70002
ATTORNEYS FOR ORLEANS LEVEE DISTRICT
17 may be used or sought to be used in evidence.
19 18
BURGLASS & TANKERSLEY
20 BY: KEA SHERMAN, ESQ. 19 * * * *
5213 Airline Drive 20
21 Metairie, Louisiana 70001
ATTORNEYS FOR JEFFERSON PARISH 21 ROGER D. JOHNS, RDR, CRR, Certified Court
22
CHAFFE, MCCALL 22 Reporter for the State of Louisiana,
23 BY: PARKER HARRISON, ESQ.
Suite 2300 Energy Centre
23 officiated in administering the oath to the
24 1100 Poydras Street 24 witness.
New Orleans, Louisiana 70163
25 ATTORNEYS FOR LNA 25
Page 3 Page 5
1 1 INDEX
APPEARANCES CONTINUED:
2 2
3 LISKOW & LEWIS 3 PAGE
BY: DON HAYCRAFT, ESQ. 4 Vrijling 702-C Exhibit 1................... 13
4 Suite 5000 One Shell Square
701 Poydras Street 5 Vrijling 702-C Exhibit 2................... 26
5 New Orleans, Louisiana 70139 6 Kemp Exhibit 4............................. 35
ATTORNEYS FOR INGRAM
6
7 Vrijling 702-C Exhibit 3................... 36
7 8 Vrijling 702-C Exhibit 4................... 57
SHER, GARNER, CAHILL, RICHTER, KLEIN & HILBERT 9
8 BY: MEGAN DUPUY, ESQ.
Suite 2800
10
9 909 Poydras Street 11
New Orleans, Louisiana 70112 12
10 ATTORNEYS FOR XAVIER
11 13 EXAMINATION BY MR. WOODCOCK..................8
12 14
13 15
14 REPORTED BY:
ROGER D. JOHNS, RMR, CRR, RDR, CSR 16
15 Certified Court Reporter 17
State of Louisiana 18
16
17 19
18 20
19
20 21
21 22
22 23
23
24 24
25 25

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VRIJLING, JOHANNES KORNELIS
1/8/2008
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1 JOHANNES KORNELIS VRIJLING, 1 EXAMINATION BY MR. WOODCOCK:
2 Professor of Hydraulic Engineering at TU 2 Q. Professor Vrijling, can you hear me?
3 Delft, Avenue Concordia 78, 3062 LL, 3 A. Yes, I can hear you.
4 Rotterdam, Netherlands, after being duly 4 Q. Well, it's morning here. It's
5 sworn, did testify as follows: 5 probably afternoon there. So good afternoon.
6 MR. BRUNO: 6 A. Yes. Thank you.
7 Counsel, did Robin -- 7 Q. My name is Jack Woodcock and I am an
8 MR. WOODCOCK: 8 attorney with the U.S. Department of Justice
9 Yes. 9 and I represent the United States in this
10 MR. BRUNO: 10 matter, Robinson V. the United States, which
11 Counsel, did Robin give to you 11 is pending in the Eastern District of
12 the most recent hydrographs that I 12 Louisiana. Have you had your deposition taken
13 emailed him this morning -- 13 before?
14 MR. WOODCOCK: 14 A. Only in -- assisted with Bruno's
15 Yes. We received those 15 15 office. So not officially with an attorney of
16 minutes before 9:00 o'clock. 16 the United States government.
17 MR. BRUNO: 17 Q. Well, what I am going to be doing
18 Good. 18 today is I am going to ask you some questions
19 MR. WOODCOCK: 19 which you are under oath to fully and
20 So we have them. 20 completely answer.
21 Should we enter appearances? 21 A. (Witness nods head affirmatively.)
22 MR. BRUNO: 22 Q. If you don't understand a question
23 Yes. 23 or cannot hear the question, please tell me.
24 You ready, Roger? 24 Otherwise, I will assume that you have
25 MR. WOODCOCK: 25 understood my question. May we agree to that
Page 7 Page 9
1 Okay. 1 --
2 THE WITNESS: 2 A. Yes. I understand.
3 What was the question, please? 3 Q. And because a Court Reporter is
4 MR. WOODCOCK: 4 producing a transcript, it's important that we
5 My name is -- 5 not speak over each other and one person speak
6 MR. BRUNO: 6 at a time. And this is particularly true in a
7 No, just for us. 7 situation that we have today where we have
8 MR. WOODCOCK: 8 people all over the world together.
9 My name is Jack Woodcock 9 A. (Witness nods head affirmatively.)
10 representing the Defendant, the United 10 Q. Is there any reason that you cannot
11 States. 11 testify today?
12 MR. BRUNO: 12 A. No.
13 Joseph Bruno, Plaintiffs Liaison 13 Q. Have you taken --
14 Counsel. 14 A. There's no reason.
15 You all just here observing, 15 Q. -- any medication that may impact
16 huh? 16 your ability to testify?
17 MS. HARRISON: 17 A. No.
18 Correct. 18 Q. As this deposition continues, if
19 MR. BRUNO: 19 there's any reason that comes up that you
20 No one else is participating but 20 cannot testify, please let us know.
21 myself. 21 A. Yes, I will do.
22 MR. WOODCOCK: 22 Q. And if -- also, if you need to take
23 Okay. Great. 23 a break, we can do that. Just let us know.
24 MR. BRUNO: 24 A. Yeah.
25 You can go. 25 Q. Do you understand these instructions
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VRIJLING, JOHANNES KORNELIS
1/8/2008
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1 -- 1 MR. BRUNO:
2 A. Yes. Certainly. 2 Okay.
3 Q. Would you please state your full 3 MR. WOODCOCK:
4 name. 4 -- as exhibit numbers.
5 A. Johannes Kornelis Vrijling. 5 EXAMINATION BY MR. WOODCOCK:
6 Q. Are you currently employed? 6 Q. So Professor?
7 A. With the University of Technology in 7 A. Yeah.
8 Delft. 8 Q. Is this the first time you have seen
9 Q. And what do you do there? 9 the renotice of deposition, today?
10 A. I am a Professor of hydraulic 10 A. Yeah, I think so. I am not quite
11 engineering and risk management. 11 clear. I have here Exhibit A to notice of
12 Q. Now, have you been handed a packet 12 videotaped deposition and it's questions, any
13 of papers today? Have you been supplied with 13 all and materials considered or relied upon by
14 exhibits, potential exhibits? 14 the deponent in connection with the
15 A. No, except from the ones that were 15 litigation, is the first question. And --
16 mentioned, this exhibition that was mailed to 16 Q. Thank you.
17 you with these extra graphs. 17 A. -- under the fourth and the fifth
18 Q. Okay. That is all you have? 18 and the sixth questions regard the typical
19 A. Yeah, and I have such a list of 19 extra grafts that we had to produce.
20 questions which is an exhibit to videotaped 20 Q. And you have brought those -- you
21 Notice of Deposition. 21 have those hydrographs with you today?
22 Q. So you have -- Renotice of 22 A. (Indicating). I have them here.
23 deposition? 23 Q. Okay.
24 A. Yeah. 24 MR. WOODCOCK:
25 Q. Is that entitled "Renotice of 25 I would like to mark this
Page 11 Page 13
1 deposition"? 1 Renotice of Deposition Exhibit 1.
2 A. A, Exhibit A to notice of videotaped 2 MR. BRUNO:
3 deposition. And the first question -- 3 Give me a second, please. Just
4 Q. Okay. Thank you. 4 the --
5 MR. BRUNO: 5 MR. WOODCOCK:
6 Are they labeled? Counsel, are 6 Sure.
7 they labeled? Mine are not labeled 7 MR. BRUNO:
8 yet. 8 Just the notice or you want the
9 MR. WOODCOCK: 9 attachment as well?
10 No, mine are not. It was my 10 MR. WOODCOCK:
11 understanding that you were to -- that 11 The attachment as well, please.
12 they're going to be entered and 12 MR. BRUNO:
13 labeled in New Orleans. 13 All right.
14 MR. BRUNO: 14 MR. WOODCOCK:
15 They will be. 15 Exhibit A.
16 MR. WOODCOCK: 16 MR. BRUNO:
17 So if we could -- 17 Exhibit A. I am marking that now
18 MR. BRUNO: 18 as Exhibit Number 1. Well, I guess --
19 That's fine. I just didn't 19 I guess Vrijling 1 or --
20 understand why the Professor's were 20 MR. WOODCOCK:
21 labeled. Just so we have no confusion 21 We have been doing Vrijling --
22 with him. 22 What we have done for the other 702-C
23 MR. WOODCOCK: 23 depositions, Vrijling Exhibit 1.
24 Yes. They should not be labeled 24 MR. BRUNO:
25 -- 25 Let's call it have Vrijling 702-C
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1/8/2008
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1 1, because he's been deposed once 1 expertises or your two main expertises?
2 before. 2 A. No, we said I studied also
3 MR. WOODCOCK: 3 economics. So also economics.
4 Fair enough. 4 Q. Okay. Thank you. But in this case,
5 MR. BRUNO: 5 do you rely mostly on your hydraulic
6 702-C 1. Got it. Okay. 6 engineering?
7 You got yours, Roger? 7 A. Yeah, mostly on hydraulic
8 MR. WOODCOCK: 8 engineering.
9 Great. 9 Q. And probabilistic design?
10 EXAMINATION BY MR. WOODCOCK: 10 A. Yes.
11 Q. Professor Vrijling, -- 11 Q. Professor Vrijling, how did you
12 A. Yes. 12 become involved in this litigation? How did it
13 Q. -- it's my understanding that you 13 first start?
14 have two Master's degrees? 14 A. I think we were interested generally
15 A. Yes. 15 because the Dutch look to the terrible example
16 Q. And what are those in? 16 of the flooding of New Orleans and then in
17 A. Master in civil engineering and 17 some or other way, I don't know exactly, Mr.
18 Master in economics. 18 Kok, my co-worker, was in contact with Mr.
19 Q. And what time did you become a 19 Bruno and so things got rolling.
20 professor? 20 Q. And who is Mr. Kok?
21 A. In 1989. 21 A. Mr. Kok is the guy who wrote the
22 Q. And what did you do between your 22 first report. He is a co-worker of mine, part
23 Master's degree and the time you became a 23 time, and besides that, he has an engineering
24 professor? 24 firm, a small engineering firm.
25 A. At first I was employed by a 25 MR. BRUNO:
Page 15 Page 17
1 contractor here in the Netherlands and later I 1 Counsel, I don't know if you are
2 changed over to Rijkswaterstaat, which could 2 aware or not, but Professor Vrijling
3 be compared with the Corps of Engineers in 3 was subjected to 14 hours of
4 America. 4 deposition in connection with the
5 Q. And now you're a full professor at 5 expert exchange, and the United States
6 Delft University? 6 of America attended and participated.
7 A. Yes. 7 It was my understanding this was a
8 Q. And what specific areas of study do 8 supplemental deposition to address the
9 you highlight at Delft? 9 702-C issues. I don't mind you doing
10 A. I highlight here in Delft the 10 what you want to do, but given a
11 hydraulic engineering and in regards storm 11 limited time, I don't know if you're a
12 surge barriers, locks and weirs, sea walls, 12 conveyor of that. That's all.
13 these kind of structures, dikes, and all -- as 13 MR. WOODCOCK:
14 I said, I teach risk analysis, risk 14 Counsel, I am aware and the
15 management, which regards also risk of 15 background information, it's intended
16 flooding and the risk of failure of structures 16 to be summary and cursory in nature.
17 and so on. 17 MR. BRUNO:
18 Q. And how long has the hydraulic 18 No problem. I'm with you. I
19 engineering been an expertise of yours? 19 didn't know if you realized that or
20 A. Since the start of my career in -- I 20 not.
21 finished, I got my civil engineering Master's 21 MR. WOODCOCK:
22 in '74, so from 74 until now I am hydraulic 22 Thank you.
23 engineering engineer. 23 EXAMINATION BY MR. WOODCOCK:
24 Q. All right are the probabilistic 24 Q. So Professor Vrijling, I think you
25 design and the hydraulic engineering your only 25 have just last said that Mr. Kok first
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VRIJLING, JOHANNES KORNELIS
1/8/2008
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1 initiated contact with Mr. Bruno? 1 EXAMINATION BY MR. WOODCOCK:
2 A. Yes. 2 Q. We'll pass it along to the
3 Q. And then how did it progress from 3 Plaintiffs.
4 there? 4 MR. BRUNO:
5 A. I think then Mr. Bruno called upon 5 Actually, no, this is your bill,
6 us to help him solve this problem of -- if we 6 bud.
7 could divide up a little bit the causes of 7 EXAMINATION BY MR. WOODCOCK:
8 flooding to the various breaches and the 8 Q. Professor Vrijling, you just
9 various origins. So -- And then we undertook 9 mentioned the preparation of a report you did
10 an effort to make these calculations. 10 in July of 2007?
11 Q. And what exactly was that effort? 11 A. Yes. Or Mr. Kok did in principle.
12 A. That effort was to simulate flooding 12 Q. Okay. And that report simulates the
13 of New Orleans for each of the three bowls, 13 flooding of greater New Orleans using the
14 given the outside water levels as a fraction 14 Sobec D1-2D model?
15 of time and given the number of breaches that 15 A. Yeah, 1D2D.
16 were developing during that storm surge. 16 Q. 1D2D.
17 Q. Are you familiar with the legal 17 A. Yeah.
18 issues involved in this case? 18 Q. Is that a standard model used to
19 A. Partly. Partly. I am -- 19 simulate floods?
20 Q. What is your understanding? 20 A. Yeah, that's a standard model to
21 A. I understand there is various 21 simulate flooding in areas where you have
22 litigation going for people who lost their 22 canals and ditches as well as flat areas. So
23 homes against the state of the U.S.A. to get 23 that's the reference 1D models best, canals.
24 compensation. That's my impression, but I am 24 And 2D is for the flat areas in between.
25 not fully aware exactly of the legal case. 25 That's why we choose this particular package.
Page 19 Page 21
1 Q. And are you or Delft being 1 Q. Now, how old is the model?
2 compensated by the Plaintiffs in this matter 2 A. It is not -- It is redone every
3 -- 3 time. Every time it is improved. So I
4 A. We are only compensated by Mr. 4 wouldn't know how old the last release is, but
5 Bruno. That's the only one we have contact 5 I estimate three years old or something like
6 with. 6 that.
7 Q. You personally or Delft -- 7 Q. Was the 1D aspect developed before
8 A. Delft University. 8 the 2D aspect --
9 Q. -- University? 9 A. Yeah.
10 A. (Witness nods head affirmatively.) 10 Q. -- of the model?
11 Q. Okay. Do you have any idea what the 11 A. Yes. We --
12 amount of that compensation? 12 Q. So that --
13 A. Now, we have an hourly rate and we 13 A. For all time we have already for 20
14 charge for the making of the report this 14 years, we already have 1D models. And the
15 hourly rate. We even have no agreement 15 1D2D is a recent, relatively recent
16 strictly speaking for this deposition, so we 16 development.
17 -- 17 Q. What type of simulations have been
18 Q. Okay. 18 conducted with the model?
19 A. I will charge the normal rate. 19 A. Now, then, what type of simulations?
20 MR. BRUNO: 20 We put in the water levels as a function of
21 Just make sure -- Professor, send 21 time at the outside of the dikes. Then we let
22 a bill to the government for your 22 the dikes breach, the levees, and then the
23 deposition today. Okay? 23 water flows in. Then you see the time pattern
24 THE WITNESS: 24 of the flow and the rising of the water level
25 Okay 25 inside each bowl. And we did it for three
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VRIJLING, JOHANNES KORNELIS
1/8/2008
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1 bowls, the St. Bernard, the central bowl, and 1 and hydraulics. First with Delft Hydraulics
2 the East bowl. And then in addition to that, 2 at the famous Dutch laboratory and later with
3 we separated the causes by looking only to 3 his own firm, HKV, HKV. So he is --
4 rain, looking only to a hole on one side, only 4 Q. Does he -- Does he work under you at
5 to a hole in another side, and all combined. 5 --
6 Q. So you used the model to simulate 6 A. What's your question?
7 the flooding of New Orleans? 7 Q. -- Delft?
8 A. (Witness nods head affirmatively.) 8 A. At Delft he works under me, yeah.
9 Q. Have there been other incidents, 9 Q. Now, how about the two students, Mr.
10 flooding incidents in history which the model 10 Aalberts and Mr. Maaskant? What are their
11 has also simulated? 11 expertises?
12 A. Yes. It is also used in Holland to 12 A. Mr. Maaskant has just finished his
13 simulate the flooding of our Dutch polders in 13 master's thesis, which was also about the New
14 case it happens. But luckily it has never 14 Orleans flooding. And Mr. Aalberts is still
15 happened, so it -- that's just an academic 15 working on his Master's thesis, and he will
16 exercise and we are happy, so to say, with 16 try to do it on the basis of these
17 this New Orleans case because now we can see 17 calculations that we are discussing today.
18 if it works in reality, too. 18 Q. Are they students of yours?
19 Q. So is this the first time that the 19 A. Yes, they are students of mine.
20 model has been used to depict an actual flood 20 Q. And how about Mr. DeWit?
21 -- 21 A. Mr. DeWit is an employee by another
22 A. Yeah. In the -- So this is the 22 little firm, Svasek, and this Svasek company
23 first time that we are able to compare the 23 is also very familiar with making these
24 results of the model with actual observations 24 hydraulic calculations. That's their
25 of people who condemn its houses and 25 specialization.
Page 23 Page 25
1 property. 1 Q. What type of coordination did Delft
2 Q. What is your familiarity with the 2 and Svasek do together in the report?
3 model? 3 A. Now, there was one project team.
4 A. I am familiar with it from the point 4 They were working together in a room at Delft
5 of view of a user. I don't know exactly the 5 University making the calculations under the
6 calculations that go inside, but I know how to 6 guidance of Mr. Kok, so it was more a sort of
7 use these models. 7 body shopping, let's say, for Mr. DeWit than
8 Q. Do the authors of the report have a 8 actual involvement of Svasek in the
9 familiarity with the model? 9 calculations.
10 A. Yeah, they have also familiarity 10 Q. What was your role in the process --
11 with the model and -- because they were some 11 A. I was supervising the process.
12 students of mine involved. They have even 12 Setting it up and looking to the results if I
13 better knowledge than I do. 13 saw them believable.
14 Q. Who are those individuals involved 14 Q. What did you do to supervise?
15 in drafting the report? 15 A. I am looking to the results and
16 A. These were Mr. Kok as our main 16 asking questions, how they did it, what their
17 co-worker; he is a teacher at Delft 17 approximations were, how they -- which type of
18 University. And then the students are Mr. 18 sensitivity studies they did and so on.
19 Maaskant and Mr. Aalberts. And then there was 19 Q. And have you adopted the opinions
20 also Mr. DeWit involved in the July report. 20 and conclusions in the report?
21 Q. What expertise does Mr. Kok have? 21 A. Yes.
22 A. Mr. Kok is a mathematician whose 22 Q. So those are your -- essentially
23 specialty is decision theory and risk 23 your own conclusions?
24 analysis, but he has worked since his Master's 24 A. Yeah. In fact, they are.
25 degree in the field of hydraulic engineering 25 Q. Okay. Professor Vrijling, I would
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1/8/2008
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1 like to turn to the July, 2007 report. And if 1 This is not a brand new deposition.
2 I could, mark this as Exhibit 2. 2 This is a supplemental deposition.
3 MR. BRUNO: 3 You were in attendance at the original
4 There is just the Vrijling report 4 deposition. The report is identical
5 and not the declarations? 5 to the report submitted at that time.
6 MR. WOODCOCK: 6 The purpose of this deposition is to
7 Well, it's -- I think the 7 supplement. Okay? We are not, and I
8 declarations should be -- should have 8 repeat, we are not going to recover
9 been included with the report. 9 the same ground that was covered the
10 MR. BRUNO: 10 first time around. If that's your
11 No, they are, but they're 11 intent, tell me know now, we'll call
12 separate documents. Do you want them 12 the Magistrate, get a ruling, and move
13 to be all marked in globo? 13 on.
14 MR. WOODCOCK: 14 MR. WOODCOCK:
15 Could you -- 15 What I intend to do is to ask
16 MR. BRUNO: 16 about the polders and about the input
17 I'm happy to do either. 17 data in the report and then
18 MR. WOODCOCK: 18 specifically go through the
19 Yes, in globo, please. 19 hydrographs which -- two of which are
20 MR. BRUNO: 20 included within the report, and the
21 All right. So we have marked as 21 hydrographs were only provided to us
22 Exhibit Number 2, Vrijling 702-C 22 15 minutes before this deposition was
23 Number 2. 23 scheduled to start.
24 MR. WOODCOCK: 24 MR. BRUNO:
25 Thank you. 25 You're welcome to make --
Page 27 Page 29
1 EXAMINATION BY MR. WOODCOCK: 1 MR. WOODCOCK:
2 Q. Professor Vrijling, if you could 2 That's what I intend to do.
3 please turn to page 2 of the report itself -- 3 MR. BRUNO:
4 A. Yeah. 4 Well, you can go into the
5 Q. -- on which figure 1.1 is situated. 5 hydrographs that were submitted this
6 A. Yes. I have it. 6 morning, because that was something,
7 Q. Could you describe what a polder is 7 by the way, that your -- your lawyers
8 -- 8 asked us to provide to you. That was
9 MR. BRUNO: 9 an exercise that we did not do in
10 Oh, Counsel, I have to tell you, 10 connection with the original report.
11 we have covered this for 14 hours. If 11 It's something you asked us to do. So
12 we go with this kind of detail, I'm 12 we did it and you have got it. But I
13 going to have to call a Magistrate. 13 am not going to let --
14 This is not supposed to be a 14 MR. WOODCOCK:
15 redeposition of Professor Vrijling. 15 So your position --
16 He went -- I mean, you can't possibly 16 MR. BRUNO:
17 tell me you need another definition of 17 My position is really simple. I
18 the word "polder". 18 am not going to let you go back and
19 MR. WOODCOCK: 19 cover all the ground that's already
20 Counsel, it's inherent within the 20 been covered. Did you at least review
21 702-C process that we need to ask what 21 that deposition?
22 these polders are. 22 MR. WOODCOCK:
23 MR. BRUNO: 23 Yes, of course I did.
24 No. No, you don't understand. 24 MR. BRUNO:
25 This is a supplemental deposition. 25 All right. Well, then you know
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1 that I am speaking the truth when I 1 structures designed to hold back floods and
2 say these questions have already been 2 flood waters?
3 asked. Right? 3 A. Yes, exactly. Yeah. Exactly. And
4 MR. WOODCOCK: 4 then only the St. Bernard polder has a
5 They have been asked in a 5 secondary levee in the middle which divides it
6 situation which is not akin to the 6 into the marsh on the right side and to the
7 702-C motion here. 7 village, the city area on the left side.
8 MR. BRUNO: 8 Q. If I could ask you to please turn to
9 Well, I don't know what that -- 9 page 5 of the report?
10 MR. WOODCOCK: 10 A. Uh-huh (affirmatively). Yeah.
11 We are looking for very specific 11 Q. I would like to ask you questions
12 definition -- This deposition is not 12 about the input data you used. The first one
13 going to go on all day. This is a two 13 is "Digital elevation model" which you got
14 hour exercise. 14 from Mr. Chad Morris.
15 MR. BRUNO: 15 A. Yes.
16 All right. Well, then, based 16 Q. Have you met with Mr. Morris?
17 upon that representation, fine. I 17 A. I met him in New Orleans.
18 mean, I just don't see it and I really 18 Q. And do you know his qualifications
19 don't want to take your or my time, 19 --
20 but go ahead. I mean if it gets too 20 A. Yeah, I think so, but -- he's also a
21 burdensome, we'll revisit. But, you 21 geologist or geographist, something in that
22 know, 702-C issues are what they are 22 area.
23 and they don't deal with these issues 23 Q. The second bullet point there,
24 that have already been covered. But 24 "Surge hydrographs", have you met with Dr.
25 go ahead. 25 Kemp who provided those to you?
Page 31 Page 33
1 MR. WOODCOCK: 1 A. Yeah. We met him, too, in New
2 Thank you, Counsel. 2 Orleans; and Mr. Kok met him quite a few
3 THE WITNESS: 3 times.
4 Now, I have to explain the 4 Q. And so you know his qualifications
5 polders? 5 --
6 EXAMINATION BY MR. WOODCOCK: 6 A. Yes.
7 Q. If you would, please. 7 Q. Now, the third bullet point is
8 MR. BRUNO: 8 "Information on the breach locations and
9 If you want. Yes, go ahead. 9 sizes". You also obtained that from Mr.
10 THE WITNESS: 10 Morris?
11 Okay. So what we call a polder 11 A. Yeah, the measurements, the depths
12 is such an area which is in principle 12 and the widths we got from Mr. Morris. And
13 low-lying, below the water level, and 13 the general information we got from the
14 which is surrounded by closed 14 various reports, too, in addition. The ASCE
15 encirclements of levees or dikes. The 15 report and the various elite and so on, the
16 St. Bernard is one polder, the Orleans 16 analysis reports.
17 metro bowl is one polder, and the New 17 Q. And how did you use that in your
18 Orleans East is one polder. 18 modeling? How did you use the information --
19 EXAMINATION BY MR. WOODCOCK: 19 A. I step-by-step saw the bowls are
20 Q. And how did you determine the -- how 20 formed by this information about the levels
21 each of those polders were separate? 21 provided by Mr. Morris. Then you have to
22 A. Because they are surrounded around 22 model the breaches, how deep and wide they
23 by one close perimeter of levees. 23 are, and to make some estimate how they
24 Q. So on figure 1.1, the areas in red 24 develop over time. And then on the outside of
25 outline the polders which are man-made 25 the bowls we have the water levels as provided
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1 by Mr. Kemp, who showed how the hurricane 1 4.
2 rises and falls afterwards. And this is to 2 MR. BRUNO:
3 calculate how quickly the water flows into the 3 Yes.
4 bowl. 4 MR. WOODCOCK:
5 Q. Now, the last point there, 5 If we could just enter that for
6 "Eyewitness reports from IPET and Team 6 the record.
7 Louisiana", how did you use those in the 7 MR. BRUNO:
8 report, in your report? 8 You mean you want to attach it?
9 A. We did -- This -- This whole 9 MR. WOODCOCK:
10 exercise is an expert exercise, because all 10 Please.
11 the data that you put in are all a little bit 11 MR. BRUNO:
12 fuzzy -- so the size of the holes, the exact 12 Thank you. All right. I am
13 location. So we tried to calculate the rise 13 going to cover -- I am going to put
14 of the water level in the bowl and we checked 14 the exhibit sticker on top of the
15 that with the eyewitness reports. And then we 15 other one so it's not confusing and
16 looked with our expertise if this fitted or if 16 mark it Vrijling 702-C 3.
17 we could understand why it did not fit, and 17 MR. WOODCOCK:
18 then we tuned the data little bit to get the 18 Thank you.
19 best possible approximation between the data 19 EXAMINATION BY MR. WOODCOCK:
20 on the outside and the observations inside. 20 Q. Professor, if we could turn to page
21 Q. In a way, that's a way of 21 7 of your report, the general model setup.
22 double-checking your results? 22 A. Yeah.
23 A. Exactly. And getting in a way the 23 Q. In terms of the grid, why did you
24 best possible interpolation by means of this 24 use a 50 by 50 grid?
25 model between the few observations that you 25 A. Yeah, that's a choice based on the
Page 35 Page 37
1 have. And observations in the sense of 1 data, amount of data that was available of
2 outside water levels, observations in the 2 this level information and what you need to
3 sense of breach holes and breach times, and 3 get a reliable calculation. If the grid size
4 observations to the water levels inside the 4 is too wide, then you have unreliable
5 bowls. And then in effect you do an 5 results. And the 50 by 50 meters is quite
6 interpolation to predict intermediate points 6 small grids to make these calculations to get
7 in time and intermediate points in space. 7 accurate results.
8 Q. Professor Vrijling, have you been 8 Q. Now, you used not 50 by 50, but
9 provided with a document entitled "Data 9 shorter distant marks for the tops of the
10 supplied to Delft team modeling, internal 10 levees themselves; is that correct?
11 flooding of greater New Orleans during 11 A. Yeah, in case there were breach
12 Hurricane Katrina"? 12 geometries that required it, we need -- we
13 A. I think so. I am not -- I am not 13 made to shorter distances.
14 positive. Maybe. If Mr. Kok got it, it will 14 Q. So you had greater resolution on the
15 be -- it should then be in the literature. 15 top of the levees?
16 Q. Okay. 16 A. Yeah, locally where the breaches.
17 A. So all were used, is in the 17 Q. Just where the breaches were?
18 reference of the reports. So all the -- 18 A. Yeah.
19 Q. On page 5? 19 Q. Or along the entire tops of the
20 A. Yeah, yeah. And then on page 57, 20 levees?
21 all the references are listed. 21 A. No, just where the breaches were.
22 Q. Thank you. 22 Q. Okay. And the rest of the levees
23 MR. WOODCOCK: 23 you had, they were 50 by 50 average height?
24 Counselor, if I could just enter 24 A. Yeah.
25 Exhibit -- It's marked as Kemp Exhibit 25 Q. Now, how did you model overtopping
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1 -- 1 A. Yeah, exactly. That was the
2 A. Just by the engineering formula to 2 intention.
3 predict how much water flows over the crest of 3 Q. If you could turn the page to page
4 the levee is the standard engineering 4 34, figure 3 point -- figure 4.6, "Water
5 formula. 5 levels at location 1", --
6 Q. And you used Dr. Kemp's surge -- 6 A. Yes.
7 A. Outside polder areas. 7 Q. -- if you could, I would like to
8 Q. -- materials -- 8 have you explain this for us. The vertical
9 A. Yeah. 9 axis is in feet. Is that in --
10 Q. -- to get the water levels outside 10 A. Yeah.
11 the polders? 11 Q. -- NAVD-88? Is that the markation --
12 A. Yes. 12 A. Yeah. I think so.
13 Q. Now, in your report you graphed 13 Q. -- of feet? And can you just tell us
14 water heights for the three different 14 in the most simple terms possible what NAVD
15 polders. If I could turn to the New Orleans 15 means?
16 East polder, you graphed that for five 16 A. That's the -- roughly the average
17 different locations. Is that correct? On page 17 sea level. The chart datum that was used in
18 26 -- 18 New Orleans to compare levels of the ground
19 A. We're not going -- Which -- New 19 surface, the levee heights, and building
20 Orleans East or -- 20 positions in the vertical axis.
21 MR. BRUNO: 21 Q. Is that a common level? Have you
22 Page 26, Professor. 22 used that in the Netherlands?
23 THE WITNESS: 23 A. We have similar leveling elements.
24 26. Yeah. 24 Here it's called the new Amsterdam level.
25 EXAMINATION BY MR. WOODCOCK: 25 Q. But it's an engineering practice --
Page 39 Page 41
1 Q. You analyzed that polder separately 1 MR. BRUNO:
2 and then used five different locations in 2 Counsel, --
3 which to conduct hydrographs? 3 EXAMINATION BY MR. WOODCOCK:
4 A. Yes. Yes, as we explained earlier, 4 Q. -- to use a base level?
5 the data available for all areas, all 50 by 50 5 MR. BRUNO:
6 areas, but we choose to depict them only for 6 Counsel, he didn't finish his
7 the ones mentioned here. So that was the 7 answer.
8 reason why we could also provide you with more 8 THE WITNESS:
9 data and other points as requested later, on 9 Yes.
10 the basis of the same calculations. 10 MR. BRUNO:
11 Q. Okay. On page 33 those locations 11 Professor, finish your answer
12 are depicted. Who chose where those locations 12 first before we get -- over-talk each
13 are? 13 other.
14 A. I think they were given to us by Mr. 14 THE WITNESS:
15 Bruno because he had interest, and maybe -- if 15 We have -- Yeah, we have in the
16 there were witness, eyewitness accounts to 16 Netherlands a similar datum that is
17 verify, then we choose also a point there. 17 the new Amsterdam level. And that's
18 Q. So they gave you the points and then 18 similar to this New Orleans level.
19 you put them in your output and modeled each 19 EXAMINATION BY MR. WOODCOCK:
20 with a hydrograph? 20 Q. So this is very familiar to you?
21 A. Yes. And in addition, if there were 21 A. Yes.
22 eyewitness reports in a certain point, then we 22 Q. Now, on the horizontal axis, you
23 modeled -- we put them also in the model. 23 have outputs every three hours?
24 Q. Those, in that way, you were able to 24 A. Yes.
25 double-check your results again? 25 Q. And how did you choose three hours
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1 as an output? 1 Q. And how do you calculate overtopping
2 A. Yeah, but many more. It's the -- 2 -- is that --
3 what you mentioned now are the black lines in 3 A. I said that's the level on the
4 the graph. There are many more calculations. 4 outside and then the engineering formula would
5 So every three or five minutes there is a 5 give you the amount of water that flows over
6 separate calculation in the model. So that 6 the crest.
7 there are many more data points than you 7 Q. Is that the wave -- Do you calculate
8 assume now. So only -- The Xs is divided into 8 the height of the water at wave crest height?
9 -- 9 A. No, no, no. The wave overtopping is
10 Q. So this is a -- Excuse me for 10 not included.
11 interrupting. This is just a simpler visual 11 Q. Okay.
12 model of the outputs? 12 A. It's only the fixed water levels.
13 A. Yeah. Yes. And the number of the 13 So there is -- In reality there might be a
14 points is far larger. So there's -- every 14 little bit more due to the wave topping.
15 three or five minutes there's a separate 15 Q. Now, if I could take you through the
16 result. 16 differences between these lines, what -- at
17 Q. Now, the last output you have on the 17 location 1, the difference between the black
18 graph is August 30th at zero hundred hours. 18 line and the orange dashed line, what does
19 A. Uh-huh (affirmatively). 19 that represent?
20 Q. Is that how far the model goes or is 20 A. That's the contribution due to the
21 -- just for this representation? 21 breaches in the dikes. So the red line gives
22 A. No, that is just for this 22 you the result of all the sources except the
23 representation. Because then the storm surge 23 breaches. And then in addition to that, you
24 is at a maximum -- the flooding is at a 24 get the inflow due to the breaches. That's
25 maximum. The storm surge has already passed. 25 the difference between the red line and the
Page 43 Page 45
1 Q. And so after this time, the flooding 1 black line.
2 diminishes? 2 Q. And what about the difference
3 A. Yeah, it flows out again. The water 3 between the orange line and the green dashed
4 flows from the New Orleans bowls into the sea 4 line depicting "Only overtopping"?
5 again. 5 A. That -- That's the difference
6 Q. Okay. If I could just briefly have 6 between, if you have only overtopping and no
7 you go through each of these five scenarios 7 rain and overtopping plus rain. So that
8 and tell us what that means. 8 should -- it's more or less the same as the
9 A. Yes. 9 distance between the bottom of the graph and
10 Q. Could you tell us what "All causes", 10 the blue line.
11 the black line, what that encompasses? 11 Q. Okay. So does that depict in
12 A. That line encompasses if you take 12 essence rainfall?
13 into account all sources of water. So all 13 A. Yeah. Yes.
14 breaches, all overtopping, and the rain. What 14 Q. Now, if you could explain why there
15 would be the speed of filling of the bowl and 15 is a huge delay and then you have a
16 the water levels that are reached. 16 precipitous rise at about 0900 hours on the
17 Q. How about "No breaches"? 17 morning of August 29th.
18 A. That is if there -- the holes are 18 A. I don't remember now. But there's
19 excluded and there is only overtopping or -- 19 some reason for it. I can't reproduce it
20 and rain. 20 now.
21 Q. And "Only overtopping"? 21 Q. So you can't -- you don't know
22 A. "Only overtopping" is what it says. 22 exactly why it raised so quickly?
23 That only the overtopping of the levees is 23 A. I don't know now. I cannot --
24 considered, and not the rain and not the 24 Yeah. I don't know now. I could provide you
25 breaches. 25 with a reason because there is a reason. I
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1 why it was. 1 accurately, this is the only exceptions. So
2 Q. Now, what about -- It goes -- The 2 the picture is true except if you would have
3 graph goes markedly up and then it dips down a 3 one local area which is laying three feet
4 bit -- 4 deeper, and it would fill more quickly with
5 A. Yeah. 5 rain and it would have more flooding depth due
6 Q. -- and then it continues up again. 6 to rain only. But generally speaking, this is
7 Do you know -- 7 the true picture.
8 A. Yeah. 8 Q. Thank you. If I could just have you
9 Q. -- why it went down and then up 9 go through one more graph included in your
10 again? 10 report, the St. Bernard polder. On page 46,
11 A. I have to question the guys. I 11 figure 5.6.
12 don't know now what was the reason exactly. 12 A. Which figure you mentioned? 5 --
13 Q. Okay. Looking at this graph, is it 13 Q. The top one, 5.6.
14 apparent that breaches and overtopping are the 14 A. 5.6, yeah.
15 major sources of flooding at this location? 15 Q. Location 1. Now, --
16 A. Yes. And the rain has a minor 16 A. Yeah.
17 contribution, and the major contributions are 17 Q. -- this is one of the ten
18 from overtopping and breaches. 18 hydrographs you did for the St. Bernard polder
19 Q. And the maximum flood level at 19 --
20 height is what in this graph? 20 A. Yeah.
21 A. Five and a half -- Five and a half 21 Q. And you have seven scenarios here,
22 feet above datum. 22 five of which are the same that you did for
23 Q. And rain had only a nominal impact 23 the New Orleans East polder?
24 -- 24 A. Yeah.
25 A. Yeah, depending if the pumps were 25 Q. But you have two new ones. "No
Page 47 Page 49
1 working or not, it is one and a half feet, one 1 breaches MRGO". Could you explain that, what
2 and a half foot. 2 that means?
3 Q. So in the report you conclude that 3 A. That means that we excluded the
4 breaching and overtopping dominate the 4 breaches in the levees along the MRGO because
5 flooding within the New Orleans East polder -- 5 for the flooding of Bernard there are two
6 A. Yes. 6 sources. One is flooding from the MRGO by the
7 Q. And that's true for this location 7 breaching of this earthen levee, and the other
8 and the other locations which you provided 8 is along the Industrial Harbor Canal where the
9 hydrographs for? 9 sheet piling was failing. So there are two
10 A. Generally speaking, that is true. 10 ways in which the water ingresses into this
11 But if you would have a sort of depression in 11 bowl. And just to see the relative influences
12 the terrain, a local depression, then that 12 of each, we separated these two cases in the
13 would be filled up by rain very quickly. So 13 graph.
14 if there would be a local hole in the area, 14 Q. And so for this polder you have two
15 then the rainwater would flow into that and it 15 lines which demark the relative influence of
16 could be completely filled. So locally it 16 the MRGO and the IHNC breaches on the flooding
17 might be more, but generally on average this 17 within the polder?
18 is the true picture. 18 A. Yeah. That's correct.
19 Q. And those local variances, how great 19 Q. You have the same vertical and
20 are those within the polder? 20 horizontal axis --
21 A. I think they are small, because it's 21 A. Yes.
22 a fairly even area. But there might be some 22 Q. -- in this graph as in the other
23 local depressions or houses that are sending 23 graph?
24 especially deep by coincidence, but I am not 24 A. Yes.
25 aware of it. But just answering your question 25 Q. Now, I would like to take you
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1 through the difference in the lines again. 1 Harbor Canal where the sheet pile failed on
2 Could you explain why the gray line, which is 2 the east side of this canal.
3 "No breaches IHNC", is greater than the black 3 Q. And how would you quantify that
4 line at the very end of the time frame there? 4 contribution? Is that a large or small portion
5 A. Yeah, presumably that's the result 5 of flooding?
6 of the outflow again. So after the maximum -- 6 A. Oh, that -- that's a large portion
7 Q. Could you explain what? 7 of the flooding. That's the main contribution
8 A. After the maximum of the storm 8 here at this place.
9 surges has passed, the flooding had passed, 9 Q. So at location 1, the IHNC is the
10 the water starts to flow out again into the 10 greatest contributor --
11 sea. And if there is -- are two breaches, 11 A. Yes.
12 then the outflow is quicker than when there is 12 Q. -- to flooding?
13 only one breach. So the gray line is no 13 A. Yes.
14 breaches in the harbor canal. So that means 14 Q. And the MRGO is also a heavy
15 that the water will not flow out along this 15 contributor?
16 route and only through the MRGO. So that 16 A. Exactly.
17 means that it takes more time and that the 17 Q. And rain is a minimal or less
18 water level is a little bit higher. 18 important contributor?
19 Q. So the water, if there's no 19 A. That's our opinion.
20 breaching in the IHNC, has to flow out all the 20 Q. Professor, if I could have you turn
21 way easterly across the polder, which is a 21 to page 44 of your report. If you could just
22 much greater distance, than out of the IHNC 22 read the last paragraph, and then there's one
23 breach? 23 more sentence on page 45, out loud.
24 A. Exactly. It's a greater distance 24 A. And this is -- is this "At ten
25 because it's two points. Over the marsh is 25 locations", this paragraph?
Page 51 Page 53
1 one point and the second point is that there 1 Q. It begins "The overtopping of the
2 is only one route out and not two routes out. 2 MRGO", it's on page 44 of your report. The
3 Q. Okay. And what impact does the 3 last paragraph on the page.
4 internal 40 Arpent Levee have on that outflow? 4 A. I think we have not exactly the same
5 A. Yeah, it's included in the 5 -- Oh, here. Yeah, I have it. "The
6 calculation. We did not separate it out. 6 overtopping of --"
7 Q. Okay. Now, in the graph, what is 7 Q. Could you please --
8 the difference between the black line, "All 8 A. Yeah, this is "The overtopping of
9 causes" and the purple dashed line, "No 9 the MRGO levee is not enough to fill the
10 breaches MRGO"? 10 wetlands basin between MRGO and the 40 Arpent
11 A. That's that -- The purple line gives 11 levee to a crest elevation of the 40 Arpent
12 you the inflow of water only due to the breach 12 Levee. This is significant, as the model
13 of the sheet pile levee near Ninth Ward. And 13 shows that if the structures along the IHNC
14 the difference between the black line and the 14 and MRGO had not breached, there would have
15 purple line is the contribution of the MRGO. 15 been limited flooding in the St. Bernard
16 Q. And just to clarify, the inflow of 16 bowl." That's what you mean?
17 the water in the sheet pile levee, that's from 17 Q. Yes, and then the very next sentence
18 the breaching along the easterly side of the 18 on the next page.
19 IHNC? 19 A. "Therefore, the main causes for the
20 A. Yeah. Yes. 20 flooding of the populated area inside St.
21 Q. What is the difference between the 21 Bernard bowl are the breach of the IHNC and
22 purple line, "MRGO" and the orange line, "No 22 the MRGO."
23 breaches at all"? 23 Q. Do you agree with the conclusions
24 A. So that's the contribution by the 24 within that paragraph and next sentence?
25 hole that you pointed out along the Industrial 25 A. Yes, in the -- I do. Because we
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1 made also separately with students 1 will know the exact dates. We visited the
2 calculations to study what would have happened 2 site in order to study the results.
3 if this levee along the MRGO had been intact. 3 Q. Is that Mardi Gras 2006?
4 If that would have been built of clay and it 4 A. '6, yes.
5 would have not been eroded, then the city 5 Q. March of 2006?
6 would have been saved. So -- 6 A. Yes.
7 Q. Could you explain that first 7 Q. So that occurred a number of months
8 sentence, "The overtopping of the MRGO is not 8 after the --
9 enough to fill the wetlands basin"? Is -- 9 A. Yeah, yeah.
10 A. Yeah. If -- If the MRGO levee would 10 Q. -- events of Hurricane Katrina?
11 have been built from very good clay, then the 11 A. And repairs were already in full
12 overtopping would not have eroded this levee. 12 swing in those days.
13 And that would only had wave overtopping and a 13 Q. Lastly, I would like to turn to the
14 little bit overtopping of this dike. And then 14 email that was provided to us this morning.
15 this amount of water would be just sufficient 15 A. Yes.
16 to fill the marsh, but not sufficient to 16 Q. Do you have a copy of the email?
17 overtop the arpent levee. 17 A. (Indicating).
18 Q. Okay. You just -- 18 Q. Is it in color?
19 A. If the -- If it would have held it, 19 A. Yeah, it's in color.
20 then the city would have been safe from -- 20 Q. Great. What we requested from the
21 speaking from this side (indicating). 21 Plaintiffs to ask for you is the -- are
22 Q. You just mentioned the composition 22 hydrographs for various locations within the
23 of the MRGO levee. You're not a geotechnical 23 New Orleans East polder and within the St.
24 engineer, are you? 24 Bernard polder.
25 A. Now half. I am a hydraulic 25 A. Yes.
Page 55 Page 57
1 engineering specialist, so I know about soil 1 Q. And there's one individual who's a
2 mechanics and dikes. 2 Plaintiff in this case who resided in the New
3 Q. But have you examined the 3 Orleans East polder, and the graph of his --
4 composition, the technical composition of 4 the hydrograph of his location is figure 2 on
5 those levees? 5 the second page of the document.
6 A. No, not myself, but the American 6 A. Uh-huh (affirmatively). Mr. Norman
7 Society of Civil Engineers team, what went 7 Robinson.
8 wrong and why, and Professor Butkus is a 8 Q. Yes. If I could have you go through
9 colleague of mine, so I got information from 9 what we have been doing before and talk about
10 him about the quality of the soil and the 10 the differences in between the sources of
11 behavior of this levee. 11 flooding.
12 Q. So you're relying upon his opinions 12 MR. BRUNO:
13 for your conclusion in that respect? 13 Counsel, if you may -- if I
14 A. I am relying in effect on two 14 might, let me mark this for you as 4.
15 things. I am relying on his opinion and I 15 MR. WOODCOCK:
16 have there to visit the site and I have seen 16 Oh, excuse me. Sorry.
17 how the dike had failed under the force of the 17 MR. BRUNO:
18 hurricane. And then from the pattern that was 18 So I am marking --
19 over with, I have viewed erode holes, it was 19 MR. WOODCOCK:
20 clear that the soil was not resistant to 20 Please mark it.
21 erosion as it should have been with a good 21 MR. BRUNO:
22 design. 22 I marked it 4 and it's attached.
23 Q. When did you visit New Orleans and 23 MR. WOODCOCK:
24 observe the levees? 24 Thank you.
25 A. In the Mardi Gras period. Mr. Bruno 25 EXAMINATION BY MR. WOODCOCK:
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1 Q. Professor, if you could explain the 1 different than the ones included in your
2 difference between the "All causes" line and 2 report. They all start at 0.00, which is
3 the "Overtopping and rain" line. 3 different. That's not an NAVD-88 marker. Is
4 A. Yeah, that's the contribution -- 4 that --
5 Q. The black line and the red line? 5 A. Yeah, I think it should be. I think
6 A. Yeah, yeah, yeah. That's the 6 all elevations are with regard to the datum.
7 contribution to -- due to the breaches. So if 7 Q. But in this report in this email, it
8 no dike was breached and we had only 8 starts on 0.00 feet. Does that correspond to
9 overtopping and rain, it would have been the 9 ground level?
10 red line. And due to breaches, it increases 10 A. I don't think so. I think it's
11 to the black line. 11 NAVD.
12 Q. And where are those breaches located 12 Q. So if I could have you return to
13 -- 13 your report, --
14 A. Yeah, they are depicted in the main 14 MR. BRUNO:
15 report. In the main report there's an 15 It's in meters.
16 overview given of where the breaches are 16 EXAMINATION BY MR. WOODCOCK:
17 modeled. 17 Q. -- like, for instance, on page 44,
18 Q. So the breaches that are located in 18 the location that we went over, one in the
19 your report are the same breaches involved 19 same polder there, New Orleans East, --
20 here? 20 A. Yeah.
21 A. Yes. Yeah. 21 Q. -- okay, for instance, there the
22 Q. Modeled here? 22 starting location is about 7.5 feet minus.
23 A. Yeah, even -- This is output from 23 And here it just starts at zero. Could you
24 the same calculation. So it is not a new 24 explain what that means?
25 calculation. Just additional output from the 25 A. Yeah, I think then there is a
Page 59 Page 61
1 same computer files. So these were already -- 1 difference that is the water depths really.
2 Q. So you're saying exactly the same 2 Yeah, I think it's the water depths related to
3 information and the same model, everything's 3 the surface. You are right. Because the axis
4 the same? 4 calls it "water depths" and the other graph
5 A. Yeah, even the same results. These 5 says "water level". So I think your
6 are in fact the July results, strictly 6 interpretation is right, --
7 speaking. 7 Q. Okay.
8 Q. Okay. 8 A. -- that it is the depths with regard
9 A. It's reproduced now, but it is a 9 to the location.
10 calculation made already months earlier. 10 Q. So all this is calculating water
11 Q. Once you are provided with a 11 depth at a particular location?
12 location, how long does it take to come up 12 A. At a location. Yeah, just as the
13 with a graph like this? 13 caption says, "Flood depths changes in
14 A. Yeah, if it is clear exactly what 14 location 1". So it's related to the bottom
15 location we need, it's within a day. But it 15 level.
16 appears that there's a lot of communication 16 Q. Basically this depicts how much
17 difficulty between America and us about the 17 water is at a particular location?
18 location and the colors of the graphs and so 18 A. Yeah. Yeah.
19 on, huh? 19 Q. And I noticed that the water depth
20 Q. Okay. 20 is given in meters --
21 A. But if we take that out, then within 21 A. Yes.
22 a day I can provide you with a graph of any 22 Q. -- on the vertical axis.
23 position you mention. 23 A. Yeah.
24 Q. Great. If I could talk about the 24 Q. How many feet are in a meter?
25 axis here, it seems to be a little bit 25 A. Approximately three feet.
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1 Q. As in this -- This graph, as in the 1 to figure 3 immediately below that --
2 graph depicted on figure 4.6 of your report, 2 A. Yes.
3 there's a long lag time in "Breach and no 3 Q. Pardon me. This is a location
4 flooding" and then a precipitous rise 4 located within the St. Bernard polder.
5 approximately at 9:00 A.M. on the morning of 5 A. Yeah.
6 August 29, 2005. 6 Q. Again, we have the precipitous rise
7 A. Yes. 7 occurring at about 9:00 o'clock.
8 Q. And as on this graph, you don't know 8 A. Yes.
9 why that long lag time and then the 9 Q. And that occurs because the water is
10 precipitous rise occurred? 10 being held back by the levees surrounding the
11 A. Yeah, I think that's due to the 11 St. Bernard polder?
12 arrival of the water after the flooding, huh? 12 A. Indeed.
13 The certain instance the areas reached and 13 Q. And then you have breaching --
14 then it goes up very quickly. 14 A. Yes.
15 Q. Okay. So at approximately 9:00 at 15 Q. -- and it precipitously rises.
16 location 1, the water outside the polders in 16 A. Yes indeed.
17 St. Bernard -- outside the levees in the New 17 Q. Now, could you tell me why there's a
18 Orleans East polder was being held back by the 18 difference between the "All causes" black line
19 levees? 19 and the dashed blue line. "No breaches IHNC"
20 A. Yeah, I think so. And then once 20 -- is that what we talked about before, the
21 they breached, then it took some time to reach 21 outflow?
22 the location and then it goes up. 22 A. Yeah, that's the same reason.
23 Q. And then you had a downfall 23 That's the outflow that is retarded a little
24 immediately after that sharp rise? 24 bit if there is only one hole.
25 A. Yeah. 25 Q. And so without the IHNC at the
Page 63 Page 65
1 Q. Can you explain that? 1 location here, the water would have taken a
2 A. Well, as we discussed it already 2 longer time to clear the residence?
3 earlier, after you asked, I don't remember. 3 A. Yeah, indeed. It would have been a
4 There was a reason, but I cannot -- 4 little bit lower at the maximum as you see,
5 Q. Okay. 5 but it would have persisted a little bit
6 A. -- give it to you now. But if you 6 longer on the high level.
7 want to, I can provide you with some written 7 Q. And could you tell me the difference
8 statement of what it is, some explanation. 8 between the black line and the reddish dotted
9 Q. Thank you. Now, I believe we did 9 dashed and dotted line?
10 the difference between the black line and the 10 A. So the reddish dotted line is the
11 red line. What's the difference between the 11 line that we would have seen if there would
12 red line and the green line there? 12 have been no breaches in the MRGO. So only at
13 A. That's the difference due to rain. 13 the Inner Harbor Navigation Channel. And then
14 Q. And compared with breaching, that is 14 the black line --
15 a smaller difference than breaching? 15 Q. So that -- that difference is the
16 A. Yeah, generally the rain is a small 16 contribution of the IHNC to the flooding
17 contribution as we explained earlier. 17 within that location?
18 Q. And the maximum flooding, what was 18 A. Let's see. No breaches. No, that's
19 the maximum level of flooding at Norman 19 the difference within the reddish dotted line,
20 Robinson's location? 20 which is "No breaches MRGO", and the black
21 A. The graph says it reaches 4 meters 21 line is the contribution of the Inner Harbor
22 above ground level. 22 Navigation Channel.
23 Q. So about 12 feet? 23 Q. Great. And the difference between
24 A. Yeah. 24 the "No breaches MRGO" line and then the -- It
25 Q. So if I could direct your attention 25 looks like a combination of lines in the
17 (Pages 62 to 65)
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1 bottom there. It looks like a "No breaches" 1 A. Yeah, 1.8 meters.
2 and maybe some other -- 2 Q. Okay. If I could have you turn to
3 A. Yes, some rain, I think. 3 the next figure, figure 4, --
4 Q. What is the difference there? 4 A. Yeah.
5 A. I think here, no breaches and the 5 Q. -- here we have the same phenomena
6 rain is the similar. They're over each other. 6 with the IH -- with no breaches, the IHNC, the
7 Q. Okay. So -- 7 outflow. It takes longer. Is that correct?
8 A. The lowest line is the rain if the 8 A. Yes. Yes, please. Yeah.
9 pumps had been working full, in full 9 Q. And then could you explain to me the
10 capacity. 10 parabola line, the "No breaches of the MRGO",
11 Q. Okay. So what's the difference 11 it starts at about 12 --
12 between that line and then the "No breaches 12 A. Yeah.
13 MRGO" line? 13 Q. -- And then continues out. Could
14 A. That's the contribution of the 14 you explain to me why that happens or what
15 failure of the Inner Harbor Navigation Channel 15 that indicates?
16 breach. 16 A. Then indicates what I explained a
17 Q. If we look in total the 17 moment ago to you. That the water from Inner
18 contributions of flooding at this location on 18 Harbor Navigation Channel takes longer to
19 figure 3, what are the major contributions of 19 reach this far away location. So it is later
20 flooding? 20 and it is less in this location. Because it
21 A. The major contribution is the 21 has to travel further. And in this case, the
22 failure of the Inner Harbor Navigation 22 major contribution comes from the blue dotted
23 Channel. 23 line, which is the breaches in the MRGO,
24 Q. If we could turn to the next -- 24 because that is the nearest to this house of
25 A. The second -- Oh, yeah, the second 25 Mr. Smith's.
Page 67 Page 69
1 -- 1 MR. BRUNO:
2 Q. Okay. Continue. Sorry. I didn't 2 Counsel, we lost --
3 mean to interrupt. 3 EXAMINATION BY MR. WOODCOCK:
4 A. Yeah. And the small largest 4 Q. So the MRGO --
5 contribution is due to the MRGO. And the 5 MR. BRUNO:
6 smallest contribution is due to rain. 6 Excuse me, Counsel. Forgive me.
7 Q. So the breaches along the MRGO and 7 EXAMINATION BY MR. WOODCOCK:
8 the breaches along the IHNC are the major 8 Q. -- arrives faster and has a greater
9 contributors to flooding at that location? 9 time --
10 A. Yeah. Yeah. And then you -- Maybe 10 MR. BRUNO:
11 an explanation, if you look on figure 1, and 11 Excuse me, Counsel.
12 if you have -- Looks like Mr. Franz. Yeah. 12 EXAMINATION BY MR. WOODCOCK:
13 Q. Yes. 13 Q. And has a greater contribution than
14 A. Then the water comes in the first 14 the IHNC?
15 instance from the Inner Harbor Navigation 15 A. Exactly. At this specific location.
16 Channel because that is nearest, and there are 16 MR. BRUNO:
17 further to the east, then the MRGO is quicker 17 Did you get that Roger? Never
18 to reach the area. 18 mind.
19 Q. Okay. What is the level -- Can you 19 EXAMINATION BY MR. WOODCOCK:
20 determine from this graph what the level of 20 Q. I'm sorry. We appear to have a
21 flooding would be, the highest level of 21 marching band going on behind us. I don't
22 flooding would be without breaching along the 22 know if you're picking that up.
23 MRGO? 23 MR. BRUNO:
24 A. That would be 1 meter 80. 24 It's not New Orleans, but I'm
25 Q. 1.8 meters? 25 happy to go wherever it is.
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Page 70 Page 72
1 EXAMINATION BY MR. WOODCOCK: 1 contribution. And that's the smaller one.
2 Q. Okay. To head back to the 2 Q. And so at this location, the IHNC
3 difference in lag between the waters which 3 had a greater influence on flooding than the
4 flowed from breaching along the MRGO, that 4 MRGO because it's -- she is located closer to
5 took -- It's a difference of about three hours 5 the IHNC?
6 on this graph? Is that correct? 6 A. Yeah.
7 A. Yeah. That's correct. 7 Q. And what is the maximum level of
8 Q. And how much water occurs in this 8 flooding experienced at this location?
9 location for Tanya Smith solely because of the 9 A. The maximum is a short moment. It's
10 IHNC? 10 2 meters 70. 2.7.
11 A. That's about 1 meter 20. 1.2 11 Q. What level of flooding would this
12 meters. 12 location have experienced without breaching
13 Q. Okay. Again, here as we have seen 13 along the MRGO?
14 before, the MRGO and the IHNC breaches are the 14 A. Then it would have reached 1.7
15 major contributors to the flooding at this 15 meters.
16 location? 16 Q. And the breaching along the MRGO,
17 A. Yeah. Exactly. And in this case, 17 how much does that contribute to -- what level
18 the MRGO is the largest contributor because 18 of flooding does she experience at this
19 this lady is living further to the east. 19 location due to flooding along the MRGO?
20 Q. So we have one more figure here, 20 A. That would have risen --
21 figure 5. This depicts flooding at location 5 21 Q. Excuse me. That was a bad
22 for Lucille and Anthony France? 22 question.
23 A. Yes. 23 What is the level of flooding
24 Q. And we recognize many of the same 24 experienced solely due to breaching along the
25 phenomenas that we have seen in these previous 25 MRGO at this location?
Page 71 Page 73
1 graphs? 1 A. That's 2 meters 50.
2 A. Yes, exactly. 2 MR. WOODCOCK:
3 Q. The difference between the IHNC 3 Okay. That's all I have.
4 breaches and all causes shows that outflow is 4 Counsel, may I have a second to
5 reduced without the breaching on the IHNC? 5 confer with my colleagues?
6 A. Yeah. Indeed. 6 MR. BRUNO:
7 Q. And what's the difference between 7 Absolutely.
8 the black "All causes" line and the "No 8 MR. WOODCOCK:
9 breaches MRGO" line? 9 Thank you.
10 A. That's the contribution due to the 10 (Whereupon a discussion was held
11 Inner Harbor Navigation Channel. No, let -- 11 off the record.)
12 It's so difficult -- The red line is -- So 12 MR. WOODCOCK:
13 from the bottom to the red line is the 13 Counselor, that's all the
14 contribution of the Inner Harbor Navigation 14 questions I'd have.
15 Channel. So that's the major. Because this 15 Professor Vrijling, thank you
16 house is near to the Ninth Ward. And then -- 16 very much for your time and intellect.
17 Q. Okay. So we have the difference 17 MR. BRUNO:
18 between the very bottom of the graph and then 18 Okay. Thank you.
19 the line which is dashed and dotted, that's 19 THE WITNESS:
20 the contribution of the IHNC? 20 Thank you very much, Mr.
21 A. Yes. So that's -- Here it's the 21 Woodcock, for your kind questioning.
22 bigger one because this house is nearer to the 22 MR. WOODCOCK:
23 Inner Harbor Navigation Channel. And then the 23 Thank you.
24 second contribution, which is between the red 24 MR. BRUNO:
25 line and the blue line, this is the MRGO 25 All right.
19 (Pages 70 to 73)
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Page 74
1 * * *
2 REPORTER'S CERTIFICATE
3
4 I, ROGER D. JOHNS, RMR, RDR, CRR,
5 Certified Court Reporter, do hereby certify
6 that the above-named witness, after having
7 been first duly sworn by me to testify to the
8 truth, did testify as hereinabove set forth;
9 that the testimony was reported by me in
10 shorthand and transcribed under my personal
11 direction and supervision, and is a true and
12 correct transcript, to the best of my ability
13 and understanding; that I am not of counsel,
14 not related to counsel or the parties hereto,
15 and not in any way interested in the outcome
16 of this matter.
17
18
19
20 ROGER D. JOHNS
21 CERTIFIED COURT REPORTER
22 STATE OF LOUISIANA
23
24
25

20 (Page 74)
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A answer 4:15 8:20 authors 23:8 51:8,14 58:5,11 7:6,12,13,19,24


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above-named 74:6 2:16 40:16 47:17 Blvd 2:17 19:20 20:4 26:3
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adopted 25:19 areas 15:8 20:21,22 barriers 15:12 50:13,23 51:12 burdensome 30:21
affirmatively 8:21 20:24 31:24 38:7 base 41:4 53:21 62:3 66:16 BURGLASS 2:19
9:9 19:10 22:8 39:5,6 62:13 based 30:16 36:25 breached 53:14 Butkus 55:8
32:10 42:19 57:6 arpent 51:4 53:10 Basically 61:16 58:8 62:21
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4:5 arrival 62:12 basis 24:16 39:10 18:15 33:22 37:16 CAHILL 3:7
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ago 68:17 ASCE 33:14 behavior 55:11 43:25 44:21,23,24 44:1,7
agree 8:25 53:23 asked 29:8,11 30:3 believable 25:13 46:14,18 49:1,4 calculating 61:10
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ahead 30:20,25 aspect 21:7,8 31:16 32:4 48:10 58:12,16,18,19 58:25 59:10
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America 2:11 15:4 attached 57:22 best 20:23 34:19,24 70:14 71:4,9 42:4 54:2
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American 55:6 attendance 28:3 better 23:13 49:7 50:20 51:18 28:11 31:11
amount 19:12 37:1 attended 17:6 bigger 71:22 63:14,15 64:13 called 18:5 40:24
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Amsterdam 40:24 attorney 8:8,15 bit 18:7 34:11,18 72:12,16,24 canal 1:7 49:8
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analysis 15:14 2:11,18,21,25 3:5 54:14 59:25 64:24 briefly 43:6 canals 20:22,23
23:24 33:16 3:10 65:4,5 brought 12:20 capacity 66:10
analyzed 39:1 August 42:18 45:17 black 42:3 43:11 Bruno 1:22,22 2:4 caption 61:13
62:6 44:17 45:1 50:3 2:4 6:6,10,17,22 career 15:20

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case 16:4 18:18,25 colors 59:18 contractor 15:1 D 12:9,12 13:1 17:4
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causes 18:7 22:3 comes 9:19 67:14 52:4,7 58:4,7 51:9 64:19 65:9 depositions 13:23
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Causeway 2:17 communication 68:22 69:13 71:10 34:11,18,19 35:9 depressions 47:23
central 22:1 59:16 71:14,20,24 72:1 37:1,1 39:5,9 42:7 depth 48:5 61:11
Centre 2:23 company 24:22 contributions dates 56:1 61:19
certain 39:22 62:13 compare 22:23 46:17 66:18,19 datum 40:17 41:16 depths 33:11 61:1,2
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CERTIFICATE compared 15:3 52:15,18 70:18 day 1:24 30:13 describe 27:7
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certification 4:11 compensated 19:2 70:15 days 56:12 55:22
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changed 15:2 composition 54:22 38:17 49:18 68:7 Defendant 7:10 developed 21:7
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colleagues 73:5 continues 9:18 46:6 currently 10:6 10:21,23 11:1,3 55:2
color 56:18,19 68:13 cursory 17:16 diminishes 43:2

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dips 46:3 E entered 11:12 experience 72:18 68:3 70:20,21


direct 63:25 E 5:1 entire 37:19 experienced 72:8 files 59:1
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D.C 2:10 36:5 exhibition 10:16 57:4 62:2 64:1 50:10,15,20
D1-2D 20:14 exhibits 10:14,14 66:19 67:11 68:3 flowed 70:4

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flows 21:23 34:3 30:13,20,25 31:9 half 46:21,21 47:1 hourly 19:13,15 28:20 44:10 48:9
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top 36:14 37:15 University 10:7 33:25 34:3,14 36:19 38:25 41:3 68:4,8,12 70:7,17
48:13 15:6 19:8,9 23:18 35:2,4 38:3,10,14 41:19 57:15,19,23 71:6 72:6
topping 44:14 25:5 40:4 43:3,13,16 57:25 60:16 69:3 years 21:5,14
tops 37:9,19 unreliable 37:4 44:5,8,12 49:10 69:7,12,19 70:1
Torts 2:9 use 23:7 33:17,18 50:10,15,18,19 73:2,8,12,21,22 Z
total 66:17 34:7 36:24 41:4 51:12,17 54:15 word 27:18 zero 42:18 60:23
transcribed 74:10 user 23:5 61:1,2,4,5,10,17 work 24:4
transcript 9:4 U.S 8:8 61:19 62:12,16 worked 23:24 0
74:12 U.S.A 18:23 64:9 65:1 67:14 working 24:15 25:4 0.00 60:2,8
travel 68:21 68:17 70:8 47:1 66:9 05-4182 1:8
tried 34:13 V waters 32:2 70:3 works 22:18 24:8 06-2268 1:9
true 9:6 47:7,10,18 V 8:10 wave 44:7,8,9,14 world 9:8 0900 45:16
48:2,7 74:11 variances 47:19 54:13 wouldn't 21:4
various 18:8,9,21 way 16:17 29:7 1
truth 30:1 74:8 written 63:7
try 24:16 33:14,15 56:22 34:21,21,23 39:24 wrong 55:8 1 5:4 13:1,18,19,23
TU 1:19 6:2 verify 39:17 50:21 74:15 wrote 16:21 14:1,6 40:5 44:17

Johns Pendleton Court Reporters 800 562-1285


VRIJLING, JOHANNES KORNELIS
1/8/2008
Page 84

48:15 52:9 61:14 4 8095N 2:10


62:16 67:11,24 4 5:6,8 36:1 57:14 835 2:5
70:11 57:22 63:21 68:3 855 1:22
1D 20:23 21:7,14 4.6 40:4 62:2
1D2D 20:15,16 9
40 51:4 53:10,11
21:15 44 52:21 53:2 60:17 9:00 6:16 62:5,15
1.1 27:5 31:24 45 52:23 64:7
1.2 70:11 46 48:10 909 3:9
1.7 72:14
1.8 67:25 68:1 5
1100 2:24 5 32:9 35:19 48:12
12 63:23 68:11 70:21,21
13 5:4 5.6 48:11,13,14
1331 2:9 50 36:24,24 37:5,5
14 17:3 27:11 37:8,8,23,23 39:5
15 6:15 28:22 39:5 73:1
1989 14:21 5000 3:4
5213 2:20
2 57 5:8 35:20
2 1:8 5:5 26:2,22,23
27:3 57:4 72:10 6
73:1 6 56:4
2D 20:24 21:8
2.7 72:10 7
20 21:13 70:11 7 36:21
20004 2:10 7.5 60:22
2005 62:6 70 72:10
2006 56:3,5 70001 2:21
2007 20:10 26:1 70002 2:17
2008 1:24 701 3:4
2300 2:23 70112 3:9
26 5:5 38:18,22,24 70113 1:23 2:6
2800 3:8 70139 3:5
29 62:6 70163 2:24
29th 45:17 702-C 5:4,5,7,8
13:22,25 14:6
3 17:9 26:22 27:21
3 5:7 36:16 40:4 30:7,22 36:16
64:1 66:19 74 15:22,22
30th 42:18 78 1:20 6:3
3062 1:20 6:3
33 39:11 8
34 40:4 8 5:13
3445 2:17 8th 1:24
35 5:6 80 67:24
36 5:7 800 2:16

Johns Pendleton Court Reporters 800 562-1285

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