KTR00129

CLOUATRE, ALVIN
6/20/2008
UNITED STATES DISTRICT COURT 1 REPRESENTING THE U.S. ARMY CORPS OF ENGINEERS.
EASTERN DISTRICT OF LOUISIANA
2 CORPS OF ENGINEERS, OFFICE OF COUNSEL
IN RE: KATRINA CANAL BREACHES CIVIL ACTION
CONSOLIDATED LITIGATION NO. 05-4182 K2 3 (BY: JENNIFER LABOURDETTE, ESQUIRE)
JUDGE DUVAL
PERTAINS TO: MRGO AND ROBINSON
4 7400 Leake Avenue
(No. 06-2268) 5 New Orleans, Louisiana 70118-3651
Deposition of ALVIN JOSEPH CLOUATRE, 6 504-862-2843
III, given at the U.S. Army Corps of Engineers
New Orleans District offices, 7400 Leake 7
Avenue, New Orleans, Louisiana 70118-3651, on 8 ALSO PRESENT:
June 20th, 2008.
9 DEBRA S. CLAYMAN, ESQ.
10 KASSIE HARGIS, ESQ.
11 ROBERT FISHER, ESQ.
12 PHILIP WATSON, ESQ.
13
REPORTED BY:
JOSEPH A. FAIRBANKS, JR., CCR, RPR 14 PRESENT VIA I-DEP:
CERTIFIED COURT REPORTER #75005 15 BRENDAN R. O'BRIEN, ESQ.
16 CHRIS ALFIERI, ESQ.
17
18 VIDEOGRAPHER:
19 KARL STIEGMAN (DEPO-VUE)
20
21
22
23
24
25
Page 1 Page 3
1 APPEARANCES: 1 EXAMINATION INDEX

2 REPRESENTING THE PLAINTIFFS: 2
3 BRUNO & BRUNO 3 EXAMINATION BY: PAGE
4 (BY: JOSEPH M. BRUNO, ESQUIRE) 4
5 (BY: SCOTT JOANEN, ESQUIRE) 5 MR. JOANEN .................................7
6 855 Baronne Street 6 MS. CLAYMAN ...............................166
7 New Orleans, Louisiana 70113 7 EXHIBIT INDEX
8 504-525-1335 8
9 - and - 9 EXHIBIT NO. PAGE
10 LAMBERT AND NELSON 10 Exhibit 1 ................................19
11 (BY: CAYCE PETERSON, ESQUIRE) 11 Exhibit 2 ................................19
12 701 Magazine Street 12 Exhibit 3 ................................71
13 New Orleans, Louisiana 70130 13 Exhibit 4 ................................73
14 504-581-1750 14 Exhibit 5 ................................84
15 15 Exhibit 6 ................................87
16 REPRESENTING THE UNITED STATES OF AMERICA: 16 Exhibit 7 ................................89
17 UNITED STATES DEPARTMENT OF JUSTICE, 17 Exhibit 8 ................................94
18 TORTS BRANCH, CIVIL DIVISION 18 Exhibit 9 ................................95
19 (BY: RICHARD STONE, ESQUIRE) 19 Exhibit 10 ................................99
20 (BY: TAHEERAH K. EL-AMIN, ESQUIRE) 20 Exhibit 11 ...............................105
21 P.O. Box 888 21 Exhibit 12 ...............................106
22 Benjamin Franklin Station 22 Exhibit 13 ...............................107
23 Washington, D.C. 20044 23 Exhibit 14 ...............................108
24 202-616-4289 24 Exhibit 15 ...............................109
25 25 Exhibit 16 ...............................110
Page 2 Page 4
1 (Pages 1 to 4)
Johns Pendleton Court Reporters 800 562-1285
CLOUATRE, ALVIN
6/20/2008
1 Exhibit 17 ...............................115 1 ALVIN JOSEPH CLOUATRE, III

2 Exhibit 18 ...............................125 2 655 Plantation Boulevard, Mandeville, Louisiana
3 Exhibit 19 ...............................126 3 70448, a witness named in the above
4 Exhibit 20 ...............................132 4 stipulation, having been first duly sworn, was
5 Exhibit 21 ...............................137 5 examined and testified on his oath as follows:
6 6 EXAMINATION BY MR. JOANEN:
7 7 Q. Could you state your name for the
8 8 record, please?
9 9 A. Alvin Joseph Clouatre, III.
10 10 Q. Mr. Clouatre, my name is Scott Joanen.
11 11 I'm here on behalf of the plaintiffs to take
12 12 your deposition today.
13 13 Have you ever given a deposition
14 14 before?
15 15 A. One other time, yes.
16 16 Q. And what was that in conjunction with?
17 17 A. It had to do with an accident that was
18 18 on a job -- a project I was assigned to twelve
19 19 years ago or so.
20 20 Q. Were you the injured individual?
21 21 A. No.
22 22 Q. You were just a witness to that?
23 23 A. I wasn't a witness, I was just on the
24 24 project, so I wasn't actually there even when
25 25 the accident occurred.
Page 5 Page 7
1 STIPULATION 1 Q. In case you don't recall how a

2 IT IS STIPULATED AND AGREED by and 2 deposition works, this is an opportunity for us
3 among counsel for the parties hereto that the 3 to ask questions of you regarding issues
4 deposition of the aforementioned witness may be 4 relative to the lawsuit that was brought in
5 taken for all purposes permitted within the 5 relationship to levee breaches. The purpose of
6 Federal Rules of Civil Procedure, in accordance 6 this is to get the information that you would
7 with law, pursuant to notice; 7 give as if you were in court; therefore, this
8 That all formalities, save reading 8 is just as if you were in court. You've been
9 and signing of the original transcript by the 9 sworn in as a witness and you'll need to give
10 deponent, are hereby specifically waived; 10 us truthful answers.
11 That all objections, save those as to 11 Do you understand that?
12 the form of the question and the responsiveness 12 A. Yes.
13 of the answer, are reserved until such time as 13 Q. When I ask you questions I'm going to
14 this deposition, or any part thereof, is used 14 ask you to allow me to finish my question
15 or sought to be used in evidence. 15 before you give an answer because oftentimes if
16 16 you're speaking over me the court reporter
17 17 can't take everything down. That's very
18 * * * 18 important that he get everything down for this.
19 19 Do you understand that?
20 20 A. Yes.
21 21 Q. If at any time you don't understand a
22 JOSEPH A. FAIRBANKS, JR., CCR, RPR, 22 question just ask me to repeat, and I'll be
23 Certified Court Reporter in and for the State 23 glad to do so or I'll have the court reporter
24 of Louisiana, officiated in administering the 24 read that back. Is that okay?
25 oath to the witness. 25 A. Sure.
Page 6 Page 8
2 (Pages 5 to 8)
CLOUATRE, ALVIN
6/20/2008
1 Q. If you need to take a break at any 1 A. No.

2 time for whatever reason, speak to counsel or 2 Q. Did you, while you were at either
3 take a bathroom break, whatever, just say so 3 Delgado or UNO, get rated as a certain class,
4 and we'll be glad to do so. Okay? 4 whether it be sophomore, junior?
5 A. Okay. 5 A. Freshman.
6 Q. I'm going to assume that you 6 Q. What was the last year that you
7 understand my questions. And so the answers 7 attended either Delgado or UNO?
8 you give will be relied upon later with this 8 A. I'm going to guess and say 1987.
9 deposition transcript. You'll have an 9 Q. After 1987, did you take any more
10 opportunity, if you so choose, to review this 10 formal education?
11 transcript at a later date to determine whether 11 A. No.
12 there's any inconsistencies in that. Okay? 12 Q. Did you enter the workforce at that
13 A. Okay. 13 time?
14 Q. So if there's a point where you feel 14 A. Yes.
15 that you don't understand my question, again, 15 Q. And where did you start working?
16 ask me to repeat it. Is that okay? 16 A. I started working in 1986 or 1987 in
17 A. Sure. 17 Harahan at a business called Harahan Auto
18 Q. From where are you from, sir? 18 Parts, and I worked there until 1988 when I
19 A. I currently reside in Mandeville, 19 started with the Corps.
20 Louisiana. 20 Q. And what was your position when you
21 Q. Where did you grow up? 21 were hired on with the Corps?
22 A. Metairie, Louisiana. 22 A. Construction inspector.
23 Q. Where did you go to high school? 23 Q. And what prior qualifications did you
24 A. In New Orleans. St. John Prep. 24 have in construction to obtain the job of
25 Q. When did you graduate? 25 construction inspector?
Page 9 Page 11
1 A. 1985. 1 A. I came in as a trainee, but I had

2 Q. And after you graduated from high 2 worked -- my father is an electrician and I
3 school, did you enter the workforce or did you 3 worked with him for several years throughout
4 continue your education? 4 high school. And up until 1988 I worked with
5 A. I went to Southeastern Louisiana 5 him and also had worked with a couple of other
6 University in Hammond. 6 small companies. Not really companies, just
7 Q. And what did you study there? 7 people I know in construction.
8 A. Um -- general studies, initially. 8 Q. And as a trainee, what kind of
9 Well, general studies. And then -- I just went 9 training did you get from the Corps?
10 for one year and stopped going to school and 10 A. I would go to -- I took some courses,
11 then went -- took some courses, some night 11 initially, and also I worked under a
12 courses periodically throughout the next couple 12 construction inspector who was assigned to
13 of years. 13 projects. And, um -- and just I guess
14 Q. Where did you take those night 14 on-the-job training under these inspectors.
15 courses? 15 Q. Do you recall who that construction
16 A. Delgado and UNO. 16 inspector was that you first started with?
17 Q. And what were the night courses you 17 A. I think the first one was Henry
18 were taking, what were the subjects? 18 Broome.
19 A. English, math -- 19 Q. What kind of courses did you take as a
20 Q. Any engineering courses? 20 trainee in the construction inspector position?
21 A. No. 21 A. I think it was -- I don't really
22 Q. At UNO did you attain a degree? 22 remember the title of the courses, but it was
23 A. No. 23 construction quality verification courses, and
24 Q. At Delgado did you attain an 24 it had to do with -- different classes were
25 associate's degree? 25 soil classes, earthwork classes, concrete,
Page 10 Page 12
3 (Pages 9 to 12)
CLOUATRE, ALVIN
6/20/2008
1 um -- electrical, general construction. 1 Q. Do you recall how long that period of

2 I'm just trying to remember some of 2 time was?
3 the courses that I took. There were many more, 3 A. No.
4 I just can't recall all of them. 4 Q. Was there an event that took place
5 Q. How many earthwork courses do you 5 that you no longer needed those course
6 think that you took? 6 materials?
7 A. I would guess at three. 7 A. Not really. Just in my position you
8 Q. Do you recall the titles of those 8 move from project to project, and sometimes you
9 earthwork courses? 9 box things up and you accumulate things, and it
10 A. I know for sure two of them were 10 just probably didn't get unpacked at some
11 Earthwork I and II. I don't remember what the 11 point, I don't know. I really don't know.
12 third one might have been. 12 Q. On this Earthwork II course you took,
13 Q. And what was the type of things that 13 what kind of information was discussed in that
14 you studied in the Earthwork I course? 14 course?
15 A. Let's see: Construction methods in 15 A. I really don't remember the difference
16 building earthen -- not just levees but, you 16 between I and II. It was probably similar
17 know, this was a course that was taken by 17 information, but I don't remember specifically.
18 people throughout the country, so it wasn't 18 It was a long time ago.
19 just specializing in levee work, and it had to 19 Q. Do you remember about what year it
20 do with just verifying, or understanding the 20 was? Would that have been in '88, '89?
21 specifications, looking at contractor methods 21 A. Probably not. My guess would be early
22 and verifying the requirements that the 22 nineties.
23 specifications had in them. 23 Q. Do you recall whether that Earthwork
24 Q. You anticipated my next question. 24 II course covered topics related to levees?
25 Did this Earthwork I construction 25 A. Don't recall specifically. Probably
Page 13 Page 15
1 involve any subject matter regarding levees? 1 so.

2 A. I'm sure it did. I can't recall 2 Q. Do you recall whether that Earthwork
3 specifically. But I would -- my guess would be 3 II course covered topics related to seepage as
4 yes. 4 it relates to soils?
5 Q. Did this Earthwork I course contain 5 A. I don't recall.
6 any information or discussions regarding water 6 Q. Do you recall where the Earthwork I
7 seepage as it relates to soils? 7 course was held?
8 A. I can't recall. 8 A. To my best recollection, it was in
9 Q. Were there any course materials handed 9 Vicksburg.
10 out to you? 10 Q. Do you recall who your instructors
11 A. Yes. 11 were?
12 Q. Did you keep those course materials? 12 A. No.
13 A. Yes, initially. I couldn't tell you 13 Q. Do you recall whether they were Corps
14 where they are now. 14 of Engineers military people or civilian
15 Q. Was there a requirement for the job 15 personnel that were the --
16 that you keep certain course materials at your 16 A. I don't recall ever being instructed
17 desk or in your cube or in your office that 17 on these type of courses through military
18 would have to then refer to in furtherance of 18 people, so.
19 your job once you became whatever the next step 19 Q. On the Earthwork II course, do you
20 is over a trainee? 20 recall where that course was given?
21 A. Yes. 21 A. Where?
22 Q. And do you recall whether you kept 22 Q. Yes.
23 those Earthwork I course materials with you for 23 A. I believe it was the same location in
24 some period of time? 24 Vicksburg.
25 A. I did for some period of time. 25 Q. And again, as you recall, it was
Page 14 Page 16
4 (Pages 13 to 16)
CLOUATRE, ALVIN
6/20/2008
1 taught by civilian personnel? 1 in geotechnical issues?

2 A. Yes. 2 A. No.
3 Q. And what was the third earthwork 3 Q. Would you consider yourself an expert
4 course that you took? 4 in hydraulics issues?
5 A. I don't remember. And I was kind of 5 A. No.
6 guessing that there was a third one. It seemed 6 Q. Would you consider yourself an expert
7 like there was, but I really don't recall 7 in earthworks?
8 specifically. 8 A. No.
9 Q. At the either Earthwork I or Earthwork 9 Q. For purposes of the deposition I'm
10 II, were there any other individuals that were 10 going to mark as Exhibit 1 the Amended Notice
11 your colleagues from this New Orleans District? 11 of Deposition indicating that we asked you to
12 A. I don't recall. 12 be here today at this time.
13 Q. Did you get any certifications or any 13 A. (Nods affirmatively.)
14 other recognition as a result of completing 14 (Exhibit 1 was marked for
15 those two courses? 15 identification and is attached hereto.)
16 A. Yeah. Upon completing the course we 16 EXAMINATION BY MR. JOANEN:
17 got just a completion course type certificate. 17 Q. I'm going to show you what I'll mark
18 Q. To your knowledge, is that maintained 18 here now as Exhibit 2. And I'll tell you this
19 in some type of personnel file? 19 was produced to us by someone not in the Corps
20 A. I believe it is. I haven't seen it in 20 but it's been used in a prior deposition and
21 forever, so I really can't say for sure. 21 ask if you can look at that. (Tendering.)
22 Q. Were there any refresher courses that 22 Take your time to look at that and see if that
23 you had to take over the course of your career 23 looks familiar.
24 since that time, since the early nineties, 24 Have you had a chance to look at it?
25 regarding the Earthwork I or Earthwork II 25 (Exhibit 2 was marked for
Page 17 Page 19
1 courses? 1 identification and is attached hereto.)

2 A. Not that I recall, no. 2 A. Yeah.
3 Q. Have you taken any other courses that 3 EXAMINATION BY MR. JOANEN:
4 would relate in any way to earthwork, whether 4 Q. Have you seen that particular document
5 it be offered by the Corps or taken on your own 5 before that you know of?
6 at Delgado or UNO or any other type of 6 A. I don't remember seeing it. It looks
7 institution? 7 like it came from that class that I would have
8 A. No. 8 taken, but I don't remember specifically seeing
9 Q. You also said you took courses in 9 it.
10 soils. What kind of courses did you take in 10 Q. Just so I'm clear, this does look like
11 soils? 11 something you would have had as a result of
12 A. I don't remember. Those are the only 12 your Earthwork I or Earthwork II course?
13 two I specifically remember. 13 A. Probably so. I mean, it looks like a
14 Q. The earthwork courses? 14 roster or something of people that attended and
15 A. Yes. 15 some information on the class, yes.
16 Q. Do you recall whether you took any 16 Q. Okay. I'll turn your attention to I
17 courses as a trainee, or anytime since then, in 17 guess just on the top of the page it looks like
18 hydraulics? 18 VI.I.I, Part 1, seepage and groundwater
19 A. No. 19 control.
20 Q. Have you had any training, other than 20 A. Uh-huh.
21 potentially this Earthwork I course and 21 Q. Does that look like something that you
22 Earthwork II course, that you can recall that 22 would have studied while you were at the
23 would deal with geotechnical issues? 23 Earthwork I or Earthwork II course?
24 A. No. 24 A. Possibly, but I don't specifically
25 Q. Would you consider yourself an expert 25 remember it.
Page 18 Page 20
5 (Pages 17 to 20)
CLOUATRE, ALVIN
6/20/2008
1 Q. Do you recall during either that 1 Q. Do you recall discussing Artesian

2 course or anytime since taking that course that 2 heads at the Earthwork I or Earthwork II
3 it was the opinion or the viewpoint of the 3 course?
4 geotechnical laboratory of the U.S. Army 4 A. No.
5 Engineer Waterways Experimentation Station that 5 Q. Do you recall a discussion Artesian
6 perhaps no single feature of an earthwork 6 heads with any of your colleagues on any of the
7 project deserves as much attention during 7 projects you've had since the early nineties?
8 construction as the drainage system? 8 A. Not that term, no.
9 A. I don't specifically remember that, 9 Q. If you look a little further up in
10 no. 10 that paragraph, the term Artesian is defined as
11 Q. Is it possible that it was discussed 11 water in the sand being under pressure.
12 and you just don't recall as you sit here 12 Do you recall that?
13 today? 13 A. Yes.
14 A. That's possible, you know. 14 Q. Have you discussed that issue, water
15 Q. If you could turn four more pages to 15 in the sand being under pressure with a term
16 VI.I.5? 16 other than Artesian?
17 A. (Witness complies.) 17 A. I don't know what term specifically,
18 Q. If you look in the first full 18 but yes, that theory, yes.
19 paragraph it starts with the word dams. 19 Q. Just so that we can be on the same
20 A. Uh-huh. 20 page for later questions, what kind of term
21 Q. The second sentence says the seepage 21 would you use in your daily vernacular?
22 beneath the structure is commonly referred to 22 A. That would be like seepage, um -- I
23 as underseepage. You see that? 23 guess like through a levee when we have high
24 A. Yes. 24 river or things of that nature and we monitor
25 Q. Do you recall whether you studied any 25 the levee to see if there is any type of
Page 21 Page 23
1 of that information while you were at the 1 seepage, and, you know, or sand boils or things
2 Earthwork I or Earthwork II course? 2 like that. That's the extent of the terms that
3 A. I don't recall specifically, no. 3 I'm familiar with.
4 Q. Do you recall whether anytime since 4 Q. What is a sand boil?
5 the early nineties when you took those 5 A. To my knowledge, a sand boil is when
6 earthwork courses whether you have addressed 6 water is moving through sand. Typically, I
7 the issue of underseepage? 7 would look on a protected side of a levee to
8 A. No. Seepage -- the only time -- the 8 see if there was some sand coming up in an
9 only thing I would have talked about seepage 9 area, or some movement of water in sand.
10 would have been through colleagues at work, 10 Q. In your experience, have you seen sand
11 that I can recall. And I can't recall 11 boils before?
12 specifically who or what the conversation was, 12 A. Once or twice.
13 it was just kind of normal stuff that we would 13 Q. Do you recall where that was?
14 talk about during the course of work. 14 A. Once was on a project I was assigned
15 Q. The colleagues at work, what type of 15 to. It was in, um -- on the Davis Pond
16 expertise would they have in discussing 16 diversion structure.
17 underseepage or seepage? 17 Q. And what happened, or what did you do
18 A. It's more from experience. I don't 18 once you saw that sand boil?
19 know of any expertise anybody has specifically 19 A. I alerted -- well, I didn't really see
20 on seepage. 20 it, but, um -- someone else noticed it, and my
21 Q. A little further down on the next 21 supervisor alerted someone at the Corps, I
22 paragraph you have see underlined the word 22 believe in geotech, and they came out and took
23 Artesian head. Do you know what an Artesian 23 a look at it. And it was very small, and,
24 head is? 24 um -- they basically -- to my recollection,
25 A. No. 25 they said just continue monitoring it to see if
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CLOUATRE, ALVIN
6/20/2008
1 it gets any worse, and if it gets any worse to 1 flood stage on there --
2 alert them and they would come back out and 2 A. Yes.
3 check it out. 3 Q. -- indicates water up above what the
4 Q. Do you recall what year that Davis 4 normal river stage is?
5 Pond project diversion that you were involved 5 A. Yes.
6 with was? 6 Q. And that that would create additional
7 A. It was probably, let's see, late 7 water pressure going through the hole into the
8 nineties, 2000. 8 substratum of sand and gravel?
9 Q. Was that the first time that you had 9 A. Yes.
10 seen a sand boil or been associated with a sand 10 Q. That's what the Artesian head is. You
11 boil? 11 understand that?
12 A. Yes. 12 A. Yes.
13 Q. Did you know what a sand boil was 13 Q. As you view that drawing, do you now
14 before that time? 14 recall whether you discussed Artesian heads or
15 A. Only through discussing it with people 15 underseepage or anything of that nature while
16 at work, coworkers. 16 at your Earthwork I or Earthwork II projects?
17 Q. Do you recall whether the term sand 17 A. No, I don't remember specifically
18 boil was discussed in the Earthwork I or 18 discussing that in the class.
19 Earthwork II project? 19 Q. Do you recall whether a diagram like
20 A. I don't recall. 20 this would have been in your course materials?
21 Q. You indicated there was maybe once or 21 A. I don't recall.
22 twice that you saw sand boils, one time being 22 Q. What is your current position with the
23 the Davis Pond project in the litigation 23 Corps?
24 nineties, 2000. Do you recall what the second 24 A. What is my what?
25 one would have been? 25 Q. Current position.
Page 25 Page 27
1 A. During a high river stage. I don't 1 A. Current position? I'm a construction

2 recall how many years ago it was. I could 2 rep -- representative.
3 guess and say it's was five years ago or so, 3 Q. And what does that entail?
4 four or five years ago, um -- I think it's 4 A. There's I guess several different
5 called Big Mamou, if I'm not mistaken. And 5 things that we can do. Um -- sometimes you're
6 it's in the Lake Pontchartrain Levee District 6 assigned to a project as a project inspector.
7 south of Baton Rouge but north of New Orleans, 7 Um -- I have also been a project engineer on
8 and it's a -- basically, from what I 8 projects. And also we can, um -- oversee
9 understand -- and I've seen it. It's a huge 9 several inspectors on several different
10 sand boil and it's a mile or so from the river 10 projects.
11 levee. And it's a historical sand boil that's 11 Q. After you finished your training
12 there every year when the river reaches a 12 period, what was the first position you held a
13 certain level. 13 as non trainee?
14 Q. Before we move on, the paragraph I had 14 A. Construction inspector, project
15 referenced you to with the Artesian head, the 15 inspector. My title is construction inspector,
16 last sentence says, the height of this column 16 but I would have been a project inspector on a
17 of water, which would be indicated in Plate 3, 17 specific project.
18 above the substratum is the Artesian head. And 18 Q. And that was back in the early
19 so I'll ask you to turn a few pages back to 19 nineties after you finished your training
20 Plate 3 which is on VI.I, it looks like. Okay. 20 period?
21 You see that? Have you ever seen a 21 A. About then, yeah.
22 graph like that before? 22 Q. Is your title different now than it
23 A. No. I don't remember seeing anything 23 was back then?
24 like this. 24 A. Yes.
25 Q. Have, if you see, do you see the term 25 Q. How long did you have the title of
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CLOUATRE, ALVIN
6/20/2008
1 project inspector? 1 responsible for overseeing the construction of

2 A. Until early 2000s. 2 the levees?
3 Q. What were your responsibilities as a 3 Q. Perhaps it was a bad question, and for
4 project inspector? 4 that I apologize.
5 A. It was to, um -- monitor the project 5 We know from prior testimony that
6 and the contractor's operations to ensure 6 there are different parts of the construction
7 compliance with the Corps' safety regulations 7 division, different subsections of the
8 in the Corps' safety manual and to ensure 8 construction division, they have different
9 contract compliance with the requirements and 9 responsibilities.
10 the specifications and drawings. 10 A. Okay. Yeah.
11 Q. On any particular project, what would 11 Q. Some parts of the division have
12 you have to do to prepare yourself to make sure 12 responsibility for the hurricane protection
13 that you were capable of assuring that the 13 system, other parts have different
14 contractor was in compliance with the contract? 14 responsibilities. Did you, in the position you
15 A. Reviewing the plans and 15 held as the project inspector, have interface,
16 specifications, um -- understanding them, 16 if any, with anyone from the parts of the
17 looking at the project itself, um -- consulting 17 division that dealt with the hurricane
18 with my superiors. 18 protection levees?
19 Q. In the hierarchy of Corps of Engineers 19 A. My interaction was with members of the
20 in the New Orleans District, what division were 20 New Orleans area office, which were project
21 you in as a project inspector? 21 engineers, at the time supervisory civil
22 A. Construction division. 22 engineers or team leaders, and this is all the
23 Q. Would the construction division -- as 23 hierarchy in the New Orleans area office.
24 a member of the construction division, would 24 Within the Corps, I really as an inspector
25 you personally interact with members of the 25 really never dealt with anyone else outside of
Page 29 Page 31
1 engineering division to understand the plans 1 the safety office.

2 and specifications of a particular project? 2 Q. What experience did you have in
3 A. As a project inspector, no. 3 construction or maintenance with the hurricane
4 Q. As a project inspector, would you 4 protection levees here in the New Orleans
5 interact with anyone from the hydraulics 5 District?
6 department? 6 A. I was a project inspector on, um -- at
7 A. No. 7 least a couple of hurricane protection levees.
8 Q. Did the position you held as a project 8 Q. Which ones were those?
9 inspector in the nineties, in the construction 9 A. Plaquemines Parish, um -- in Port
10 division, have interface with the people who 10 Sulphur.
11 built the levees or maintained the levees as 11 Q. Any others?
12 part of the hurricane protection system? 12 A. I'm trying to recall. I mean, I've
13 A. Did I as a project inspector interface 13 worked on levees, on the Mississippi River
14 with the people who built the levees? 14 levee, which is I'm thinking separate from what
15 Q. Who either built or maintained -- the 15 you're speaking of as far as hurricane
16 division that built and maintained the levees 16 protection levees.
17 for the hurricane protection system. 17 Q. In your opinion, are the river levees
18 A. I don't understand your question. The 18 to be considered different than the hurricane
19 people who built the levees were the 19 protection levees?
20 contractors who were working for the Corps. 20 A. Again, from hearing from coworkers and
21 Q. No, the division that was responsible 21 other people within the Corps, yes.
22 for the construction and maintenance of the 22 Q. And what did you hear from coworkers
23 hurricane protection levees, within the Corps, 23 regarding how they should be viewed
24 within the New Orleans District. 24 differently?
25 A. Construction division. Who was 25 A. Well, I don't know about viewed
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CLOUATRE, ALVIN
6/20/2008
1 differently, but I always understood that they 1 A. Well, I knew this person just from
2 were constructed to a little different level 2 around the Corps. Um -- but for the river this
3 because of the, um -- the pressure of the 3 past season, for the levees that I was -- that
4 Mississippi River on the levees, the continual 4 I rode, I rode over the course of a couple of
5 pressure on the levees or the -- versus the 5 weeks I guess, the point of contact in
6 pressure on the hurricane protection levees. 6 engineering division was El Pilié. I think the
7 Q. On any of the works that you've done 7 first initial is E. Elsworth is his name,
8 on any of the levees, did you have to consider 8 actually.
9 underseepage as a factor? 9 Q. And my question was more directed to a
10 A. Um -- typically, it wasn't something I 10 project that you would be assigned to as a
11 did on a daily basis, no. It's not -- it 11 project inspector.
12 really -- no, I'd say no. 12 A. Uh-huh.
13 Q. On the projects that you were involved 13 Q. If you're inspecting a project, if
14 with that involved either river levees or 14 you're a project inspector on a project that's
15 hurricane protection levees, who would have 15 somewhere near or adjacent to either a river
16 been the person that would have been concerned 16 levee or a hurricane protection levee and you
17 about underseepage? 17 believe there's some reason to be concerned
18 A. I'm not sure. 18 about excavations near, to use your term, that
19 Q. Do you have any knowledge or 19 levee, was there a specific point of contact in
20 understanding of any limitations regarding 20 the engineering division that would be assigned
21 earthworks that can take place adjacent to 21 to that particular project?
22 either a river levee or a hurricane levee? 22 A. When I was a project inspector, if
23 A. Repeat the question. Sorry. 23 anything like that occurred I would alert my
24 (Whereupon the previous question was 24 project engineer.
25 read back.) 25 Q. And that's someone that is assigned to
Page 33 Page 35
1 A. I know that during the period of high 1 that particular project?

2 river, when the river reaches a certain level 2 A. Yes.
3 and we're put on, um -- alert as to monitoring 3 Q. And there would be documentation
4 the river levees, um -- that one of the things 4 indicating who that project engineer is?
5 we look for is to ensure that there's not 5 A. Yes.
6 excavation near the river levees. 6 Q. Would you have any obligation as part
7 EXAMINATION BY MR. JOANEN: 7 of your job to follow up with that project
8 Q. When you say no excavations near the 8 engineer to make sure that any of those
9 river levees, what do you mean by near; how 9 excavations were proceeding appropriately?
10 close or far would that be? 10 A. I'm sure I would ask them again about
11 A. Um -- I spoke to someone in 11 it, yes, just to find out what their answer
12 engineering division this past high river and, 12 would be.
13 um -- normally what happens is if I see 13 Q. Would any of these communications be
14 anything, you know, anywhere near the river 14 maintained in written format; written reports,
15 levee, meaning within a thousand feet or so, I 15 notations, E-mails, things of that nature?
16 usually go out and would take a measurement to 16 A. I would say yes, I put stuff like that
17 see how close or have an approximation of how 17 in my report.
18 close, and call point of contact in engineering 18 Q. And what kind of report would that be?
19 division and find out, you know, is this an 19 A. A QA log. QAR log.
20 issue or is this not an issue? That would be 20 Q. What is a QA log?
21 the protocol of what I would do. 21 A. It's the, um -- log of construction,
22 Q. This point of contact in the 22 it's a daily log of construction.
23 engineering division, was that someone that 23 Q. Is that something that as a project
24 would have been known to you beforehand, a 24 engineer -- or project inspector, I
25 specific individual for that project? 25 apologize -- project inspector that you're
Page 34 Page 36
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CLOUATRE, ALVIN
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1 required to do? 1 A. Yes.

2 A. Yes. 2 Q. And so in your advancing from GS-7 to
3 Q. Did you take any specific courses to 3 GS-11, you were also at some point a GS-8 and a
4 learn what kind of information needs to be in 4 GS-10.
5 this QA log? 5 A. Yes.
6 A. The best I recall is we had some 6 Q. The project inspector that you had as
7 probably in-house, um -- little course, but it 7 a GS-7, were you always a GS-7 as a project
8 was an unofficial type course, it wasn't 8 inspector or did you move up through -- and
9 anything near like these courses in Vicksburg, 9 what does GS stand for?
10 where we would just go over what type of 10 A. General schedule.
11 information would be needed in each block of 11 Q. Were you anything less than a GS-7
12 the report. 12 while in your tenure as a project inspector?
13 Q. Would you be involved as a project 13 A. Yes. In 1988, I started off as a
14 inspector in a project before the physical 14 construction inspector I think it was aid
15 labor took place? 15 actually was the title, and I was a GS-2.
16 A. Before the what? 16 Q. Moving above the term aid, then you
17 Q. The physical labor of the project took 17 became --
18 place, in the planning phase or design phase? 18 A. A 3.
19 A. As project inspector, no. 19 Q. -- project inspector?
20 Q. In the course of moving up the chain 20 A. I believe it changed to a project
21 of command above project inspector, have you 21 inspector or a GS-3, but I really don't
22 ever gotten to the point where you were 22 remember. That's probably how it went. I
23 involved in the design phase of projects? 23 think the title is construction inspector, not
24 A. Never. 24 project inspector, actually. The title.
25 Q. After you advanced past project 25 Q. The GS-7 title is construction
Page 37 Page 39
1 inspector, what was your next position? 1 inspector?

2 A. Construction rep. 2 A. Yeah.
3 Q. Which is what you are now? 3 Q. Did your job responsibilities change
4 A. It's what I am now, but there was -- 4 as you moved up from GS-3 to GS-7?
5 back then, project inspector, the top grade was 5 A. My job responsibilities never changed
6 a GS-7, and the next step in the promotion 6 other than at a certain point I was assigned my
7 ladder was a construction rep GS-9, which at 7 own projects.
8 that level you still functioned as a project 8 Q. Was there a certain grade you had to
9 inspector, we were just typically assigned to 9 reach to be assigned your own project?
10 either more complex jobs or bigger projects 10 A. No, I don't -- to my best
11 where you might have project inspectors working 11 recollection, I don't believe that it was,
12 more or less under you. And now I'm a 12 um -- a certain grade, I think it was based
13 construction rep GS-11. 13 upon your supervisor 's feel for if you were
14 Q. Is there a GS-8 or a GS-10? Or do you 14 ready to take on your own project.
15 just skip over those? 15 Q. Do you recall when it was you started
16 A. I think -- no, you have to go through 16 getting your own projects?
17 that. I believe one year at a time. Like if 17 A. I believe I was, um -- like a GS-3 or
18 you're a project inspector 7, if I remember 18 4.
19 correctly, and then you got the promotion, you 19 Q. Do you know what year that would have
20 would have to go as a construction rep GS-8 for 20 been?
21 a year, and then you would -- if everything was 21 A. Probably '90, '91.
22 satisfactory in your progress you would then 22 Q. Do you recall when you advanced from a
23 get the full promotion to construction rep 9. 23 GS-7 to a GS-8? What year?
24 Q. And would the same be true of GS-9 to 24 A. I could track it back from 1988 up.
25 10 and then GS-11? 25 Um -- it would have been probably around 1993,
Page 38 Page 40
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CLOUATRE, ALVIN
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1 1994. 1 Q. Would the supervisors under you report

2 Q. Is when you became a GS-8 or 9? 2 to you or would they report to the project
3 A. No, I thought you said 7. 3 engineer?
4 Q. Okay. In '94 you became a GS-7? 4 A. Would the supervisors under me?
5 A. '93 -- I don't know -- I don't recall 5 Q. The inspectors. I'm sorry.
6 exactly. I just have to one year at a time. I 6 A. The inspectors under me? They would
7 think it was quicker from a 2 to a 3, but then 7 probably go through me before the project
8 after that it was a full year. 8 engineer, but it's somewhat loose. I mean,
9 Q. And so to the best of your 9 it's not like they can't talk to the project
10 recollection, approximately, you were a GS-7 in 10 engineers or give them a call. But that would
11 1993, 1994? 11 be typical chain of command.
12 A. '93 I would guess. 12 Q. Would the inspectors under you, would
13 Q. Do you recall what your designation 13 they all be in one project or would you be
14 would have been in 1998? 14 supervising inspectors on a number of projects?
15 A. 1998. Probably a GS-9. 15 A. As a GS-9 I would be overseeing other
16 Q. So you would have been a construction 16 inspectors on the same project.
17 rep at that time? 17 Q. Would the inspectors that were under
18 A. Yes. 18 you make their own QA report or would they
19 Q. What's your current status? 19 report to you and then you would make the QA
20 A. My grade? GS-11. 20 report?
21 Q. Is there a next step that you're 21 A. Back then, um -- the GS-9 would
22 headed to, a 12 or 13? 22 typically make the report, and the lower grade
23 A. No. Not unless I would get promoted, 23 inspectors would probably submit a handwritten
24 and there's really not a place for my position 24 or typewritten supplemental report that we
25 to get promoted beyond a GS-11 in construction 25 would use the information from that to compose
Page 41 Page 43
1 division. 1 the QA log.

2 Q. The responsibilities you had as a 2 Q. In '98 or '99 when you were a GS-9,
3 GS-9, would that have been published in a 3 were you actually going out to the site of the
4 document? 4 projects for the inspectors or would you be
5 A. Yes. 5 more office based and have your sub-inspectors,
6 Q. What would that document have been 6 I guess, the inspectors under you, be in the
7 called? 7 field?
8 A. I don't know what it's called. Job 8 A. I would also go out to the project
9 standards -- I'm not sure. 9 site daily.
10 Q. How would you define the obligations 10 Q. When at the project site, who would be
11 or job description of a GS-9? 11 the ranking individual for the Corps of
12 A. GS-9 -- 12 Engineers, would that be the project engineer?
13 Q. When you were a GS-9. 13 A. It depends on how the project was set
14 A. Okay. When I was a GS-9, they would 14 up. Um -- on a typical project, the project
15 be the same as a GS-7 with the added, um -- 15 engineer would be the ranking field guy;
16 with the added that you may be assigned to 16 however, over us would be -- back then, I think
17 more -- you know, to complex jobs or to larger 17 it was supervisory civil engineer would be the
18 jobs with, um -- multiple inspectors on the 18 GS-12, and then, back then, I think the area
19 job, and you may have to -- I don't know if the 19 engineer -- or assistant area engineer and then
20 word was supervise but oversee other 20 area engineer would be the upper chain.
21 inspectors' work. 21 Q. At any time prior to 1999, had you
22 Q. Were there any particular courses you 22 worked on a contract that was referred to as a
23 had to take to qualify to supervise other 23 Total Environmental Remediation Contract, a
24 inspectors' work? 24 TERC contract?
25 A. Not a specific course for that, no. 25 A. I don't recall if it was called a TERC
Page 42 Page 44
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CLOUATRE, ALVIN
6/20/2008
1 or not, but I did work on a remediation 1 Yes.

2 project. It was a Superfund project. 2 MS. EL-AMIN:
3 Q. And which one was that? 3 Okay.
4 A. Bayou Bonfouca. 4 EXAMINATION BY MR. JOANEN:
5 Q. That was a creosote plant up there? 5 Q. What documents did you look at?
6 A. Yes. 6 A. I believe one was a QA assessment. It
7 Q. Is that waterway safe now to swim in 7 was a report, um -- done of -- someone in
8 and all? 8 construction division comes out to the project
9 A. Um -- I don't know. I mean -- 9 site and reviews your contract files and your
10 Q. Would you swim in it? 10 reports, your quality of work.
11 A. Probably not. 11 Q. Do you recall who prepared that
12 Q. I ask because I saw people catching 12 document?
13 fish in there the other day. 13 A. I believe it was Roger Gonzales.
14 (Off the record.) 14 Q. He was with the Corps?
15 EXAMINATION BY MR. JOANEN: 15 A. Yes.
16 Q. The Bayou Bonfouca remediation 16 Q. Do you remember the date of that
17 project, was Morrison Knudsen which later 17 report -- assessment?
18 became known as Washington Group International 18 A. Not exactly, no.
19 involved in that remediation? 19 Q. Was it in the early part of the
20 A. Bayou Bonfouca? 20 project or the latter part of the project?
21 Q. Yeah. 21 A. I really don't remember.
22 A. No. 22 Q. Do you recall that QA assessment when
23 Q. Who was involved in that, if you know? 23 it was generated, or do you only remember it
24 A. I believe it was IT and OHM was a 24 now after reviewing it yesterday?
25 joint venture. 25 A. I only remembered it when I looked at
Page 45 Page 47
1 Q. What was your first -- do you know -- 1 it yesterday.

2 I will use the term Task Order 26. Do you know 2 Q. Other than the QA assessment, what
3 when I'm talking about when I say that? 3 other documents did you look at in preparation
4 A. Yeah. If I remember correctly, Task 4 for this deposition?
5 Order 26 was the work -- the remediation and 5 A. I don't remember what I looked at. I
6 the demolition at IHNC. Is that correct? 6 think I glanced at a QA log that I had done,
7 Q. Yes. That's correct. 7 but I never really read it as to the content of
8 A. Yeah. 8 it.
9 Q. What was your first involvement with 9 Q. And what is a QA log?
10 that project? 10 A. I think I'd explained it earlier.
11 A. It was -- my position was a project 11 It's a report I would prepare daily on the
12 inspector and we were doing demolition work. 12 construction activities.
13 Q. Do you recall what year it was you 13 Q. Is that your daily reports?
14 first started working there? 14 A. Yes.
15 A. It was around '01. 2001. 15 Q. How many daily reports did you look
16 Q. In preparation for your deposition 16 at?
17 today did you review any documents? 17 A. I believe it was just one.
18 A. I looked at a couple of documents 18 Q. Do you remember the date of that daily
19 yesterday. 19 report?
20 Q. And what did you look at? 20 A. No.
21 A. Um -- one was a Q -- 21 Q. Do you remember the contents of that
22 MS. EL-AMIN: 22 daily report?
23 Objection. Are you asking him 23 A. No.
24 specific documents he looked at? 24 Q. Do you know why it was you looked at
25 MR. JOANEN: 25 that daily report as opposed to hundreds of
Page 46 Page 48
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CLOUATRE, ALVIN
6/20/2008
1 others? 1 notes or any other notations --

2 A. No. 2 A. No, because when I first found out I
3 Q. Who provided those documents to you to 3 didn't even know what I was being deposed over.
4 review? 4 Q. Since receiving that E-mail, have you
5 A. Um -- Taheerah. 5 reviewed any documents to refresh your
6 Q. Was there anyone else you met with in 6 recollection about the events that took place
7 preparation for this deposition other than 7 at the East Bank Industrial Area?
8 Taheerah? 8 A. None.
9 A. Taheerah and -- 9 Q. So as you sit here today, you have
10 THE WITNESS: 10 reviewed only two documents, the quality
11 Sorry. Your name? 11 assessment documents and the QA -- one
12 A. Richard, and Jennifer. 12 particular QA log?
13 EXAMINATION BY MR. JOANEN: 13 A. Those are the only took I looked at.
14 Q. Anyone else? 14 I wouldn't say I reviewed them because I really
15 A. No. 15 didn't read them.
16 Q. Have you met with -- before yesterday, 16 Q. Did you review or read anything --
17 had you met with anyone in preparation for a 17 A. Nothing.
18 deposition regarding the East Bank Industrial 18 Q. -- in preparation for this deposition
19 Area Task Order 26? 19 today?
20 A. No. 20 A. Sorry. Nothing.
21 Q. When did you first find out that you 21 Q. Thank you. Were you involved with the
22 were going to be deposed in this? 22 East Bank Industrial Area during any part of
23 A. Through an E-mail, um -- I think -- I 23 the design phase?
24 can't remember, it was either late, very late 24 A. No.
25 May or early -- the first part of June. I 25 Q. In preparation for your
Page 49 Page 51
1 think it was late May. 1 responsibilities as the construction inspector

2 Q. And what were your thoughts once you 2 for that East Bank Industrial Area project,
3 found out that you were potentially going to be 3 what documents did you review or would you have
4 deposed? 4 typically reviewed?
5 MS. EL-AMIN: 5 A. During the course of that project?
6 Objection. 6 Q. During the course of that project,
7 MR. JOANEN: 7 yes.
8 The basis? 8 A. Um -- on this particular contract, the
9 MS. EL-AMIN: 9 way it was set up, the contractor Washington
10 I'm sorry -- I lost my train of 10 Group, um -- they provided the work plans and
11 thought. 11 the scope of work for the work to be done. So
12 MR. JOANEN: 12 those were the plans that I reviewed, and any
13 I'm simply asking what his 13 drawings that might be associated with those
14 thoughts were. I'm not asking for 14 plans. And that became what that I verified
15 anything that went on with the 15 that the contractor was doing. So that was in
16 communication between you and him. 16 the sense the plans and specifications on the
17 MS. EL-AMIN: 17 project.
18 Okay. 18 Q. At the project you worked on in Bayou
19 EXAMINATION BY MR. JOANEN: 19 Bonfouca, was that project one where the plans
20 Q. What were your thoughts when you found 20 and specifications were generated by the
21 out that you were going do be deposed? 21 contractor?
22 A. Just wasn't something I was looking 22 A. I think so.
23 forward to. 23 Q. Other than the Task Order 26 project
24 Q. Once you found out that you were going 24 and the Bayou Bonfouca project, were there any
25 to be deposed, did you look at any personal 25 other projects that you were associated with in
Page 50 Page 52
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CLOUATRE, ALVIN
6/20/2008
1 which the plans and specifications were 1 Q. Anything else?

2 generated by the contractor? 2 A. Um -- just -- if Washington would have
3 A. I think that was it. 3 amended, you know, the work plans or anything
4 Q. And again, that Bayou Bonfouca project 4 like that, sometimes something would come in,
5 was a hazardous -- HTRW project, which is a 5 you know, after the initial work plan, I would
6 hazardous toxic remedial waste? 6 have incorporated that into the work plans and
7 A. Yes. I believe that was it. 7 looked at that, as well.
8 Q. Do you still have those documents that 8 Q. Was it your understanding that the
9 you reviewed yesterday in your possession? 9 project work plan was going to be a stand-alone
10 A. I never did have them in my 10 document?
11 possession. No, I don't. 11 A. All I know is that that's what I was
12 Q. Who had them? 12 to look at to do my job.
13 A. Counsel. 13 Q. What was your understanding of what
14 MR. JOANEN: 14 your job was on that project?
15 We'll ask for production of those 15 A. Um -- as a project inspector on that
16 documents. 16 project, I was to ensure that the contractor
17 MS. EL-AMIN: 17 performed the work according to the work plan
18 They've already been produced. 18 requirements, performed the work safely
19 MR. JOANEN: 19 according to the Corps' safety requirements,
20 Can you identify them, the 20 and also because it was a, um -- I'm not sure
21 numbers? 21 if this is the right term, but I think it was a
22 MS. EL-AMIN: 22 cost-plus type of project, well, um -- we just
23 I'll get that you to later. 23 ensured that, um -- that the contractor was
24 MR. JOANEN: 24 working efficiently with their equipment and
25 Okay. 25 personnel on hand, that it wasn't -- which is
Page 53 Page 55
1 EXAMINATION BY MR. JOANEN: 1 different from a fixed-price contract that we

2 Q. Just so I'm clear, the only two 2 look for, we just make sure that they're not
3 projects you were involved with as a project 3 milking it.
4 inspector in which the plans and specifications 4 Q. Would you, as the inspector, have any
5 were provided by the contractor were the Bayou 5 involvement with subcontractors of the general
6 Bonfouca and Task Order 26, is that correct? 6 contractor?
7 A. Yes. That's correct. And I'm saying 7 A. My involvement would be the monitor
8 Bob Bonfouca. That's my best recollection that 8 their work.
9 they developed the plans. And I'm sure that on 9 Q. Do you recall the subcontractors on
10 Washington Group, that contract, that's how it 10 that, the major subcontractors; for example,
11 was done. 11 Hamps Construction?
12 Q. When you say sure of that, why is 12 A. Hamps Construction was involved with
13 that? 13 the demolition.
14 A. Just because it was more recent I can 14 Q. Envirocon?
15 recall it specifically. 15 A. Envirocon.
16 Q. And so you worked with the project 16 Q. Did you have any interaction with
17 work plans? 17 either Hamps Construction or Envirocon?
18 A. Sorry. 18 A. Again, my interaction would be to
19 Q. You looked at the project work plans 19 monitor the work and --
20 for that? 20 Q. In monitoring the work, would you be
21 A. Yes. 21 involved with evaluating whether they're
22 Q. And what other documents do you think 22 working efficiently?
23 you would have looked at? 23 A. With -- if I remember correctly, with
24 A. I would have looked at, um -- the 24 the subcontractor they were awarded a contract
25 safety manual. 25 from Washington more like on a fixed-price type
Page 54 Page 56
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1 of situation, so I didn't quite look at it the 1 Q. Would he be there on a daily basis?

2 same as the -- from the milking it aspect, I 2 A. Yes.
3 looked at it just to ensure that they were 3 Q. At the time, which is while you were
4 doing the work according to the work plan 4 there, 2001 until -- how long were you on that
5 requirements. 5 project?
6 Q. If you saw that something was 6 A. I believe it was around a year and
7 proceeding not in compliance with the work 7 half, maybe slightly under that.
8 plans, as you understood them to be, what would 8 Q. And why did your term with them end?
9 you do? 9 A. Um -- I had gotten promoted to a
10 A. I would notify the, um -- QC 10 GS-11, which GS-10 is the first step, and,
11 representative who was more my direct point of 11 um -- before I was going to take my new
12 contact with the contractor, and, um -- and/or 12 position over, they wanted me to stay on the
13 the -- and also my supervisor Jim -- not 13 project for a while longer. I don't know if
14 really -- he's not really my supervisor, but in 14 that had to do with that project itself or just
15 the chain of command, he's my first point of 15 where I was going.
16 contact with the Corps was Jim Montegut. 16 Q. What was the next project you went to?
17 Q. Did you have any involvement while on 17 A. Well, I started working, actually, in
18 that WGI project with a guy named Weatherly? 18 the area office as opposed to -- even though I
19 A. John Weatherly, if I remember 19 worked for the area office on the Washington
20 correctly, was the contracting officer, and he 20 project, my office got located in the area
21 would come out periodically from Oklahoma, if I 21 office which is up here at the district, and I
22 remember right. 22 was working under a team leader and was working
23 Q. Tulsa? 23 as a project engineer over projects, dredging
24 A. Tulsa, yes. And he would come out to 24 projects.
25 the project periodically, and my interaction 25 Q. During the time period while you were
Page 57 Page 59
1 was more social than work-related. 1 with the WGI project, which is 2001 to
2 Q. Did you ever send any reports to him 2 approximately 2003, and Montegut, was he the
3 directly? 3 ranking individual in the field that entire
4 A. No. 4 time?
5 Q. Would you ever, in the course of your 5 A. Yes.
6 inspection duties, evaluate whether more money 6 Q. Was he assigned only to that project
7 was needed for the project or be involved with 7 or was he handling a number of projects?
8 requests for more money? 8 A. As far as I know, it was just that
9 A. No. 9 project. He was there every day all day.
10 Q. While on the project, did you have 10 Q. When you prepared your daily logs, who
11 interaction with a guy named Guillory? 11 would they have been addressed to?
12 A. Lee Guillory, yes. 12 A. I believe we addressed them to the
13 Q. What was that interaction? 13 area engineer, to the chief of construction. I
14 A. Lee was the construction division -- 14 don't remember who the -- if there's a third
15 our construction division manager I think is 15 person on there who we addressed them to, but
16 his position and, um -- he would come out to 16 that's the two main places that I'm familiar
17 the project. Again, he more -- he mostly dealt 17 with where they go. And also we keep a copy in
18 with Jim Montegut, so the work aspects that I 18 the field.
19 dealt with him on it would be more like he 19 Q. Is that standard that those
20 would just come out and was trying to get 20 individuals would be the ones receiving that
21 updated on status and stuff like that. That 21 documentation, or is this something unique to
22 was more or less my interaction with Lee. 22 this particular contract?
23 Q. Was Montegut the ranking individual 23 A. Well, to my understanding, the area
24 for the Corps at the project in the field? 24 engineer doesn't probably get all copies of the
25 A. In the field, yes. 25 reports in his hand. I think they're going to
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1 the area office files. 1 Q. Anyone who would have been responsible
2 Q. And who -- on that WGI project, who 2 for the maintenance and supervision of the
3 would have been the chief contractor, chief 3 levee.
4 construction contractor? Is that the term you 4 A. Maintenance and supervision of the
5 use? 5 levee. I don't know what that means exactly.
6 A. Yeah. Chief of construction. 6 Maintenance of the levee after its construction
7 Q. Chief of construction? 7 is usually turned over to the local levee
8 A. At the time? I think it was Jim 8 district. I had no interaction with them.
9 Miles. 9 Q. Okay. Did you have any interaction
10 Q. And where was he located, here in the 10 with anyone from the geotechnical department
11 New Orleans District or at a different area? 11 within the engineering and construction
12 A. He was located here in the New Orleans 12 division?
13 District at the time. 13 A. No.
14 Q. The area engineer, was that the New 14 Q. I know from some of the records that I
15 Orleans District area or a different area? 15 have, and we'll probably go through them in a
16 A. New Orleans area engineer. 16 little bit, that you attended some meetings
17 Q. Do you recall who that would have 17 that included both Corps individuals, WGI
18 been? 18 individuals and some other subcontractors of
19 A. Dom El Guezabal. 19 WGI.
20 Q. How do you spell last name? 20 Do you recall any of those
21 A. E-L, G-U-E-Z-B-A-L? Might be an A 21 specifically?
22 between the Z and the B, I'm not sure. 22 A. I don't recall any specific meeting.
23 D-O-M. Domingo I think is his first 23 I recall having meetings. We would have weekly
24 name. 24 status meetings. Um --
25 Q. Did you have any interaction with an 25 Q. What day were those weekly status
Page 61 Page 63
1 individual by the name of George Bacuta while 1 meetings held?

2 at this project? 2 A. I don't remember. Once a week, as
3 A. No. 3 best I recall. I don't remember the date.
4 Q. Any interaction with a guy by the last 4 Q. Was there a particular date and time
5 name Dicharry who I understand is retired now? 5 set or would they just try to marshal everybody
6 A. No. 6 together at a certain time when they could?
7 Q. How about an individual by the last 7 A. I think we tried to do it on a certain
8 name Grieshaber? 8 day and time as best we could.
9 A. No. 9 Q. Was there an agenda for the weekly
10 Q. Did you ever go up to Tulsa -- 10 meeting that would be published so when
11 A. No. 11 everybody walked in they passed it out and said
12 Q. -- in relationship to your involvement 12 this is what we're going to talk about today?
13 with this project? 13 A. I don't recall that specifically, but
14 A. No, I did not. 14 there probably was. I remember that we had
15 Q. Prior to this project, had you ever 15 some papers that we went off of and went item
16 had any interaction with Mr. Weatherly? 16 by item just down the list.
17 A. No. 17 Q. I know that there are some meetings in
18 Q. During this two-year period you were 18 which minutes were taken. Do you know whether
19 with the project, did you discuss this project 19 at all the meetings you attended minutes were
20 or your involvement in any way with anyone 20 taken?
21 associated with the hurricane protection 21 A. I don't know. I don't recall that.
22 project division? The levee division. 22 Q. On a lot of the meeting minutes I
23 A. With the levee division, as I know it 23 believe the name Sarah Alvey is indicated as a
24 with engineering division, no. I'm not sure 24 person that was taking them?
25 what you mean by levee division, actually. 25 A. Yeah. Sarah Alvey was I believe the
Page 62 Page 64
16 (Pages 61 to 64)
CLOUATRE, ALVIN
6/20/2008
1 QC and -- one of the safety persons on the job. 1 Q. As part of the cost plus analysis of
2 Q. She would have been with WGI? 2 this contract, would there be a difference in
3 A. Yes. 3 whether an excavation goes from twenty feet to
4 Q. Did the Corps have anyone who 4 twenty-two feet?
5 simultaneously took minutes? 5 A. Um -- I guess if they excavated deeper
6 A. No, and I think maybe with the minutes 6 it was -- of course would take more time and
7 you're talking about could be when we start up 7 labor and stuff like that, but that's not the
8 a phase of work we have what would be called 8 perspective I was looking at things as far as
9 the preparatory meeting, and that would be -- 9 watching the contractors' labor and equipment.
10 that's typical of any projects we have. And 10 Q. What was -- on in a particular
11 that usually would include the prime 11 excavation that they were considering going
12 contractor, any subcontractor doing the work, 12 from one level to the next level, what was your
13 the QC safety people for the contractor and the 13 perspective?
14 Corps reps on the job site. And the contractor 14 A. The difference was removal of the
15 typically -- the prime prepares the minutes of 15 objects that we were there to remove.
16 that meeting. 16 Q. Do you recall that there were certain
17 Q. When you attended these meetings, did 17 distinct sites within the East Bank Industrial
18 you have any input to them? Would you make a 18 Area?
19 presentation, would you have anything to say? 19 A. I remember some.
20 A. It's -- typically, those meetings are 20 Q. One of which -- the northern part has
21 the contractor's meetings. So no, I wouldn't 21 been referred to as the Boland site. Do you
22 have a presentation or anything like that. We 22 recall that?
23 would be attending the meeting, we would make 23 A. Boland Marine, yes.
24 comments, you know, if we felt like something 24 Q. Boland Marine. Were you involved with
25 was missed or something needed to be addressed 25 any excavations at the Boland Marine site that
Page 65 Page 67
1 specifically, or whether it was work related or 1 you recall?

2 safety related. 2 A. To be honest, I don't remember if it
3 Q. Do you recall whether at any of these 3 was the Boland Marine site, but if not -- it
4 preparatory meetings there was discussion about 4 was either the Boland Marine site or one right
5 the depth of excavations that were going to 5 adjacent to it in the area.
6 take place at the East Bank Industrial Area? 6 Q. What was the excavation that you
7 A. I don't remember specifically 7 recall?
8 anything, but I'm sure that during excavation 8 A. Um -- I remember the, um -- the -- I
9 if there were requirements on depths that it 9 don't remember the official name of it, but it
10 was discussed. 10 got referred to for a while as the wedding
11 Q. Do you recall whether there were any 11 cake.
12 requirements relating to the depth of 12 Q. And that was a concrete structure that
13 excavations? 13 was down there with pilings under it?
14 A. Um -- the only excavations I can 14 A. Yeah. It had support pilings under
15 recall, there were certain requirements tied to 15 it. If I remember correctly, it's was a huge
16 the depths that they excavated. Some of them 16 steel something or other that was used, you
17 had to do with, you know, obstructions in the 17 know, from that business that had been located
18 ground or so forth, and certain depths had 18 there previously, and the steel actually had to
19 different requirements on the bracing that were 19 be cut up. So when you say concrete, there may
20 bracing the holes we were excavating. 20 have been some concrete in it, but it was
21 Q. To your knowledge, was there any 21 primarily a big something steel. I don't know
22 limitation as to how deep WGI could go in a 22 if it was a press or something that was there,
23 particular excavation? 23 and they had to cut the steel up, and then we
24 A. I don't recall. I don't recall that 24 had to remove the pilings.
25 part of it. 25 Q. Do you recall any restrictions as to
Page 66 Page 68
17 (Pages 65 to 68)
CLOUATRE, ALVIN
6/20/2008
1 how deep that excavation could go? 1 pictures. Would have just kept them out on
2 A. I don't recall the restriction of the 2 project --
3 depth. I know -- and I don't remember what the 3 Q. Would you have noted those --
4 depth was, but I know that there was, on that 4 A. -- in the trailer.
5 particular excavation, there were, um -- 5 Q. -- in your daily log, that photographs
6 requirements on the waler system inside the 6 were taken by you?
7 bracing, and as they went to a certain depth 7 A. Probably not.
8 they had to install another waler system before 8 (Brief recess.)
9 they excavated down any further. 9 EXAMINATION BY MR. JOANEN:
10 Q. Waler system of course would be 10 Q. Mr. Clouatre, I have some documents
11 support for the cofferdam structure that had to 11 that have been produced by the government that
12 be built around it, correct? 12 your name was found on, I just have some
13 A. Correct. 13 questions to make sure it's the same person.
14 Q. And do you know why they had to build 14 I'm going to show you -- and I don't have
15 a cofferdam structure around the excavation? 15 copies of these, they were just given to me
16 A. The way I understand it, because 16 last night. I don't see that this even has a
17 you're going to be excavating a hole and so you 17 Bates stamp number. But I'll show it to your
18 want to support -- you want to support the 18 attorney and ask you to look at it and ask you
19 ground around it so it doesn't cave in while 19 if you can identify it. (Tendering.)
20 you're removing the objects you're excavating 20 A. Okay.
21 down to remove. 21 Q. We'll mark that as Exhibit 3.
22 Q. Do you recall during that excavation 22 What is that document, sir?
23 that WGI was hitting a lot of groundwater and 23 (Exhibit 3 was marked for
24 it had to be pumped out? 24 identification and is attached hereto.)
25 A. I remember there was, I guess, some 25 A. I don't know. I mean -- I don't
Page 69 Page 71
1 water down there. I don't remember a lot. If 1 recall seeing it specifically. It lacks
2 it was a lot or a little or what, I don't 2 somewhat like a status report.
3 remember. 3 EXAMINATION BY MR. JOANEN:
4 Q. Were you involved in taking any 4 Q. And your name is noted on that report,
5 photographs of the project or that excavation 5 correct?
6 as it was taking place? 6 A. Yes.
7 A. I may have taken some. I remember 7 Q. And what was the purpose for your name
8 there was were some photographs taken. I don't 8 being netted on that report?
9 remember if I took them or if Washington took 9 A. It looks like it showed that I was the
10 them. 10 project inspector on the site.
11 Q. Would that be something that you in 11 Q. Would you have been responsible for
12 your job responsibilities would have to take 12 generating that report?
13 photographs. There are photographs. 13 A. No.
14 A. Yeah. 14 Q. Would that have been a report that you
15 Q. But do you know whether they were 15 would have received?
16 taken by you or they were taken by WGI? 16 A. I don't remember specifically
17 A. I honestly don't remember if I took 17 receiving this. I'm not saying I didn't, I
18 some. I wouldn't be surprised if I had taken 18 just don't specifically remember receiving it.
19 some of them, but I don't remember specifically 19 Q. Fair enough. It indicates on here
20 taking them. 20 that there was a completion date anticipated
21 Q. If you had taken those photographs, 21 for that WGI project to be March 31, 2003? Do
22 what would you have done with them? 22 you recall that?
23 A. Um -- back then, I don't remember if 23 A. I don't recall that.
24 we had digital photographs or not, it was 24 Q. Do you recall when you first got
25 probably just producing the hard copies of the 25 involved with the project that there was an
Page 70 Page 72
18 (Pages 69 to 72)
CLOUATRE, ALVIN
6/20/2008
1 anticipated completion date that you knew of? 1 A. I would guess at a little over a year.
2 A. I think -- I'm sure there was an 2 Maybe a year and a half tops.
3 anticipated completion date. That date, I 3 Q. The reason I was kind of curious about
4 definitely don't recall what it was. 4 this is because the date of 2002 seems to
5 Q. Do you know while you were the project 5 coincide generally with the project that you
6 engineer -- project inspector whether the date 6 were working on with WGI. Do you recall
7 was, the completion date was moved back, was 7 whether you were -- had dual responsibility
8 extended? 8 during that time period?
9 A. I don't specifically recall that it 9 A. No.
10 was or wasn't. 10 Q. Do you know why it is that you would
11 Q. I'll show you what I'll mark as 11 be involved with that project?
12 Exhibit 4. 12 A. No, I mean, I never checked the date
13 MR. JOANEN: 13 on it to see if it overlapped, but, um -- I
14 For the purpose of the record, 14 was -- the best I can recall, I was assigned to
15 this is NED-023-000001783. 15 this project I thought about a year after I
16 (Exhibit 4 was marked for 16 left Washington 's project, roughly. I don't
17 identification and is attached hereto.) 17 remember -- I don't even remember the exact
18 EXAMINATION BY MR. JOANEN: 18 date I even left Washington's project. You
19 Q. And again I only have one copy so I'll 19 could probably tell me that, but I don't know.
20 show your attorney and let her look at it. 20 It was one of the projects that I took over as
21 MS. EL-AMIN: 21 a project engineer after I left the Washington
22 Thank you. 22 project.
23 MR. STONE: 23 Q. All right. It indicates that you
24 Scott, are you putting these in 24 would have attended a meeting on September 4th
25 with the highlighting on them and 25 of 2002 in which a contractor was discussing
Page 73 Page 75
1 marks and everything? 1 sheet piles and concrete flood wall layouts?
2 MR. JOANEN: 2 Do you recall that?
3 That's how they were given to me 3 A. I don't recall the meeting, but that's
4 I don't have any other copies. 4 what the report indicates.
5 MR. STONE: 5 Q. And it also indicates, Part 3, that
6 Just put on the record, please, 6 the sheet pile cutoff wall location -- talks
7 that there are markings and highlights 7 about sheet pile cutoff walls. Do you recall
8 on there that weren't on the documents 8 discussing, in relationship to this project,
9 originally. And we'll go ahead and 9 sheet pile cutoff walls?
10 use them. 10 A. I don't recall that specific
11 MR. JOANEN: 11 discussion.
12 We'll do the highlighted versions 12 Q. Do you recall why a sheet pile cutoff
13 simply when given to me to make sure 13 wall would be discussed at the London Avenue
14 that I saw the witness' name was on 14 Canal project?
15 it. 15 A. Not off the top of my head, no.
16 EXAMINATION BY MR. JOANEN: 16 Q. Do you know what a sheet pile cutoff
17 Q. Have you seen that document before? 17 wall is?
18 A. No. 18 A. I know -- yeah.
19 Q. It indicates that you were involved 19 Q. What is it?
20 with the flood protection project on the London 20 A. A sheet pile cutoff wall, to my best
21 Avenue Canal -- 21 knowledge, is a sheet pile wall driven to --
22 A. Yes. 22 for seepage purposes.
23 Q. -- and the Filmore bridge? 23 Q. It's designed to cut off underseepage,
24 How long were you involved in that 24 groundwater flow from the flood side to the
25 project? 25 protected side?
Page 74 Page 76
19 (Pages 73 to 76)
CLOUATRE, ALVIN
6/20/2008
1 A. That's -- to my best knowledge, yes. 1 anything within that range. You know, a
2 Q. How did you find out that that's what 2 thousand feet or so, um -- I would immediately
3 it was for? 3 stop at that location, note the work being
4 A. Through discussions throughout my 4 performed, get -- initially probably just get
5 Corps working -- you know, working years. 5 an estimated distance and then make a phone
6 Q. Would that have been anything that you 6 call to my engineering division point of
7 recall you would have studied in your 7 contact, let them know what was going on, you
8 Groundwater I and Groundwater II course 8 know, and then we could determine from at that
9 materials? 9 point, you know, what degree we would have to
10 A. Are you referring to Earthwork I and 10 investigate it and/or stop the work or not.
11 Earthwork II? 11 Q. In the Washington Group project, was
12 Q. Earthwork, yes. 12 there any distance at which excavation could
13 A. Again, I don't recall the specific -- 13 not take place near the floodwall that you were
14 you know, too many specific things in those 14 aware of?
15 classes. It was probably a long time ago. I'm 15 A. I really don't remember.
16 sure it was fifteen years ago. 16 Q. Would any, um -- discussions about
17 Q. Were sheet pile cutoff walls something 17 that be shown in the project preparatory
18 that was commonly discussed on the projects 18 minutes?
19 that involved hurricane protection project 19 A. I don't remember that specifically.
20 levees? 20 You know, this job was a remediation and
21 A. It was discussed on projects where I 21 demolition project, and so my focus was more on
22 had sheet pile cuttoff walls. 22 those aspects of the work, so I don't -- I
23 Q. Do you know whether the East Bank 23 can't recall. So that's my best recollection
24 Industrial Area had sheet pile cutoff walls 24 of that job.
25 under the levee that divided the East Bank 25 Q. Sure.
Page 77 Page 79
1 Industrial Area from the Lower Ninth Ward 1 A. So I don't specifically remember that.
2 neighborhood? 2 Q. Was there any time during your tenure
3 A. On the Washington project? 3 as the inspecting officer on that Washington
4 Q. Yes. 4 Group project where you recall having concerned
5 A. I have no idea. 5 about underseepage of the effect of the
6 Q. Who would know that information? 6 excavations on the stability of the floodwall?
7 A. I have no idea. I have no idea. I 7 A. I don't remember those concerns. Most
8 mean someone within the Corps, I would think, 8 of the excavations that we did -- I say most of
9 but I don't know. 9 them. The substantial excavations we did were
10 Q. That wouldn't have been any of the 10 braced -- you know, like the wedding cake were
11 information that was discussed at any of the 11 braced excavation. So, um -- you know, these
12 project meetings or the project preparation 12 were -- and this work was designed and approved
13 meetings? 13 and stamped by an engineer, and so I got the
14 A. No. 14 work after the fact. It wasn't at that point
15 Q. Project prep, rather, meetings? 15 my position to question the design, I just
16 A. No, because we didn't work on the 16 ensured that the work was performed according
17 levee system out there. 17 to the design.
18 Q. You had indicated previously that just 18 Q. That WGI prepared.
19 recently when you were riding the levees with 19 A. Yes.
20 the high river system that you wanted to make 20 Q. Okay. So it's your understanding of
21 sure there would be no construction taking 21 this project that WGI prepared the
22 place within a certain amount of distance from 22 specifications and plans?
23 the levee. You mentioned the term a thousand 23 A. The work plans, yes.
24 feet. 24 Q. They provided that to an engineer at
25 A. I think a thousand feet. Well, 25 the Corps.
Page 78 Page 80
20 (Pages 77 to 80)
CLOUATRE, ALVIN
6/20/2008
1 A. Um -- I don't really know if they 1 Q. Do you recall as the excavations were

2 provided them to the Corps of Engineers or if 2 taking place that there would be ground water
3 they did it through their own engineering 3 or water collecting in the excavations?
4 consultants and, you know, passed them through 4 A. I remember there was some ground
5 the Corps. I really don't know what that 5 water. I don't remember specifically how much,
6 process was. I got the end result. 6 to be honest, if we had a lot or we had a
7 Q. You had no involvement with any of the 7 little. It would -- mainly I'm coming to that
8 process that would have taken place after this 8 conclusion because it would be typical. If you
9 was signed, approved and stamped by the 9 dig a hole anywhere around here of any depth
10 engineer? 10 you're going to come across water.
11 A. None whatsoever. 11 Q. My next question was going to be, if
12 Q. Do you know what a growth fault is? 12 you did encounter ground water while you were
13 A. No. 13 at that area, was there an understanding of how
14 Q. Do you recall whether at any time 14 far you would go down before you would start
15 while you were at the East Bank Industrial Area 15 hitting water?
16 project that there was any discussion between 16 A. I don't recall how far, I really
17 anyone with the Corps and WGI or anyone else 17 don't.
18 that you recall about a growth fault in that 18 Q. I'm just going to ask you a number of
19 area? 19 questions about documents. If you recall them,
20 A. No. 20 good, if you don't, I'll just show them to you
21 Q. Did you have any discussions with 21 and let you see whether you had seen them
22 anyone in the engineering division or 22 before. The first one I'm just going to mark,
23 construction division with the Corps regarding 23 it's WGI 0381134. Just look at it. I'm going
24 the stratification of soils in that area going 24 to ask if you have had a chance to have seen
25 down? 25 that before.
Page 81 Page 83
1 A. No. 1 (Exhibit 5 was marked for

2 Q. Do you have at any time come to an 2 identification and is attached hereto.)
3 understanding or conclusion what type of soils 3 A. I can't recall if I've seen exactly
4 are in that East Bank Industrial Area going 4 this, but this appears to be the task order
5 down to depths of 25 to 30 feet? 5 that was issued to Washington. And I have seen
6 A. Repeat the question. I'm sorry. 6 something of that nature before, kind of I
7 Q. Do you have any understanding or 7 guess like the general guideline of what
8 conclusions that you've come to about the types 8 Washington was going to develop everything off
9 of soils that are at the East Bank Industrial 9 of. And I did look at something like that
10 Area going down 25, 30 feet? 10 before, but it was just briefly, probably once
11 A. No. 11 or twice, and it wasn't the -- my area of
12 Q. As the project inspector, would you 12 concern. My area of concern was the work
13 have had any reason to be concerned about the 13 plans.
14 types of soils that were there, whether it be 14 EXAMINATION BY MR. JOANEN:
15 sand or clays or marsh and peat, things of that 15 Q. This is dated June 1st of 1999. Your
16 nature? 16 name is not on it.
17 A. Um -- I really don't know how to 17 You would not have been involved in
18 answer that. I mean, if we would come 18 the project at this period to your
19 across -- if we would have a change of material 19 recollection; is that correct?
20 or something like that, we would note it. I 20 A. Right.
21 would let Jim know, you know, what we came 21 Q. If you look at the second page of this
22 across, but that would be it. 22 which Part 6 will be government furnished
23 Q. You were present when the excavation 23 information -- would look at that real quick?
24 was taking place; correct? 24 A. What page?
25 A. Yes. 25 Q. Just turn the page. It's Part 6.
Page 82 Page 84
21 (Pages 81 to 84)
CLOUATRE, ALVIN
6/20/2008
1 Government furnished information. 1 numbers just now, had you ever discussed the
2 MS. EL-AMIN: 2 sheet pile tip depth at the East Bank
3 That's going to be 5, that's 3 Industrial Area prior to today?
4 going to be 6? 4 A. No.
5 MR. JOANEN: 5 Q. Did you overhear anyone discussing the
6 I can mark it if you want to. He 6 sheet pile tip depth at the East Bank
7 hasn't seen it before. We'll mark 7 Industrial Area at any time while you were on
8 that as 5. 8 the project?
9 EXAMINATION BY MR. JOANEN: 9 A. No.
10 Q. Did you have a chance to review any of 10 Q. Do you recall whether anyone voiced
11 those documents that you recall? 11 any concerns about the excavations taking place
12 A. I don't recall reviewing these 12 at the East Bank Industrial Area while you were
13 documents. 13 there as they related to the sheet pile depths
14 Q. That was produced to us by the 14 of the adjacent flood wall?
15 Washington Group, so of course I'm just looking 15 A. No, I don't recall hearing any
16 at it from a layman's perspective, but my 16 conversation like that.
17 understanding is that the Corps of Engineers 17 Q. Let me have that back, I need to read
18 provided those documents to WGI to develop 18 the numbers into -- the next document I'm going
19 those plans and work plans and other things 19 to show you we will mark as Exhibit 6, WGI 619.
20 that they rely upon. 20 (Exhibit 6 was marked for
21 To your understanding as the 21 identification and is attached hereto.)
22 inspector, was there anyone at the Corps of 22 A. So is this mine here or is this
23 Engineers that was involved in the field with 23 something you need back?
24 this project that would have been responsible 24 EXAMINATION BY MR. JOANEN:
25 for understanding the contents of these 25 Q. That's Number 2.
Page 85 Page 87
1 documents? 1 So while you were the inspector at the

2 A. Um -- I could guess and say Lee 2 East Bank Industrial Area and the excavations
3 Guillory, maybe Jim, I'm not sure if -- you 3 were going on, and I'll show you what was Plate
4 know, Jim would have needed to go through all 4 3 of this, you were never concerned about
5 that, but that would be my guess. In the 5 something like this happening when a storm
6 field. 6 surge came into the Industrial Canal, were you?
7 Q. Do you know what the depth of the 7 A. I was never concerned of something
8 sheet pile was under the -- of the levee, the 8 like this happening?
9 floodwall in the East Bank Industrial Area? 9 Q. Right.
10 A. No. 10 A. I mean, if I had any idea something
11 Q. If I told you it was at -- designed to 11 like this would happen I would be concerned.
12 be at -8 feet and had settled to -10 feet, 12 MS. EL-AMIN:
13 would you have any reason to suspect that not 13 Objection. Are you asking him
14 to be true? 14 for an opinion?
15 A. -8 feet and settled two feet? 15 MR. JOANEN:
16 Q. To -10. 16 I'm asking him what he did at the
17 A. I don't know -- I guess I wouldn't 17 time, what his thoughts were at the
18 suspect that's untrue or true, I don't know. I 18 time while he was out there from 2001
19 really don't have a comment to that. 19 to 2003. I'm not asking for an expert
20 Q. Do you have any reason to believe that 20 opinion.
21 the sheet pile tips would have extended down to 21 A. Well, those were n't my thoughts at
22 25 feet below the surface of the soil? 22 the time because at the time anything that we
23 A. I don't have any reason to believe 23 did it was my understanding that it was okay to
24 that one way or the other. 24 do, it was approved to do, that the people in
25 Q. Other than me telling you those 25 the know, you know, was okay with this. So,
Page 86 Page 88
22 (Pages 85 to 88)
CLOUATRE, ALVIN
6/20/2008
1 again, you know, my concerns were to make sure 1 job, I probably wouldn't have thought about
2 they weren't going deeper than what it called 2 that first. I would have been focused in on
3 for or, you know, just doing it correctly. 3 other things.
4 Q. Right. And to be quite candid, the 4 Q. Sure. To use your term, the people
5 whole reason I asked you to come to the 5 that were "in the know" for that issue, at the
6 deposition today was to find out if you were 6 period when you first started looking at this
7 one of those people in the know. That's all 7 project work plan, who do you think the people
8 I'm asking. 8 in the know would have been, if you can name
9 A. Okay. 9 them individually?
10 Q. I mean, quite candidly you might have 10 A. I couldn't name them individually.
11 been the person to go out there and keep an eye 11 Q. Could you name them by title, or is
12 on this. I didn't know until I came here 12 that something that is a different division
13 today. 13 that you don't really interact too much with?
14 A. Okay. 14 A. I don't -- no. No, I don't -- I
15 Q. I have a Project Work Plan I'll show 15 wouldn't be able to name them by title. But I
16 you next to look at. 16 would think some people with geotechnical type
17 (Exhibit 7 was marked for 17 expertise would be looking at that. Whether
18 identification and is attached hereto.) 18 that would be Corps people and consultants of
19 A. Okay. 19 Washington, or a combination of the two, I
20 EXAMINATION BY MR. JOANEN: 20 really don't know.
21 Q. Have you seen that document before? 21 Q. If that would have taken place, would
22 A. Yeah. I'm sure I have. 22 that have taken place without your involvement?
23 Q. Does that look like the project work 23 A. Yes.
24 plan you would have reviewed in preparation for 24 Q. And if they -- if the Corps had
25 your tenure as the inspector for that East Bank 25 thought that in preparation for this project
Page 89 Page 91
1 Industrial Area project? 1 you were a good fit as an inspector for this
2 A. Yes. Yeah, it would have been one -- 2 project, would that have been the type of thing
3 I believe there were other documents, you know, 3 you would expect they would have brought you in
4 that they developed as we went along with the 4 for, for those type of discussions?
5 job, and so I would have reviewed the 5 A. I don't know necessarily that they
6 individual documents that were prepared for the 6 would have brought me in for that. It may have
7 phase of work coming up, and that's primarily 7 been discussed at right above my level and it
8 the ones that I would use, the ones specific 8 just filtered down to me.
9 for the work we were about to do. 9 Q. Let me show you -- and I'm not going
10 Q. Do you recall in that project work 10 to mark these, I'll just tell you what the
11 plans whether there was any areas where the 11 Bates ranges are for the record. I just ask if
12 excavation work or the project work was going 12 you've even looked at them in preparation to be
13 to be done keeping in mind that there was a 13 an inspector. It's the Mississippi River Gulf
14 flood wall adjacent to the project? 14 Outlet New Lock and Connecting Channels
15 A. I don't recall off the top of my head. 15 Evaluation Report, Volume 1, which is NPM-0061
16 I do not. 16 through 324. And the reason I was sweating so
17 Q. If there was nothing in there that 17 much when I got here, I was lugging these big
18 indicated that there should be some concerns 18 things just to show them to you, to be fair to
19 about underseepage or anything of that nature 19 you, and see if that was something you had look
20 for the floodwall adjacent to the work, that 20 at in preparation.
21 would that have been something that would have 21 A. No, I don't think I really looked at
22 popped up based upon your expertise and 22 this. I'm not saying it wasn't out there on
23 training as being suspicious? 23 the job site, but I don't think I really looked
24 A. Quite honestly, probably the eyes that 24 at this.
25 I was looking at through this, you know, in my 25 Q. I understand.
Page 90 Page 92
23 (Pages 89 to 92)
CLOUATRE, ALVIN
6/20/2008
1 A. I mean, I understood there was going 1 EXAMINATION BY MR. JOANEN:

2 to be a new lock, where it was going to be 2 Q. Would that be the type of document
3 located between the two bridges and we were 3 that you would have had to review as the
4 doing this because of a bypass channel that was 4 inspector?
5 going to be excavated. 5 A. If it was pertaining to some work that
6 Q. But they didn't tell you as part of 6 we were, you know, going to start doing, then
7 your job to be inspector, you need to go review 7 yes.
8 these volumes of materials to make sure you 8 Q. That was dated June, 2000.
9 know everything that's going on out there. 9 A. Right.
10 A. No. No. No. 10 Q. There was testimony from WGI to
11 Q. Likewise, I'm going to show you the 11 indicate this is the first time they sent this
12 same report, but it's Volume 5, which is 1605 12 to the Corps was at that time. That's why I
13 through 2295. That's that. And here's the 13 have that copy. But the one that's signed is
14 appendix which is -- okay, this is a WGI 14 this June, 2001. Quite candidly, I don't know
15 appendix, I didn't bring the one for that 15 nor does WGI really know which one of these is
16 one -- WGI 245973 through 246210, but it's the 16 the main one, so I'll just attach them both.
17 same, and ask you just to glance at those. 17 All right. I'm going to show you what
18 Same questions I had about Volume 1; 18 I'll mark as Exhibit 9 which is the June, 2001
19 was this the type of -- did you review this 19 recap submittal report criteria document and
20 information in preparation to be the inspector? 20 ask if you can look at that and see whether
21 A. No. 21 you've ever looked at that before.
22 Q. And it indicates on the front page 22 (Exhibit 9 was marked for
23 that that was produced by the hydraulics 23 identification and is attached hereto.)
24 division -- and what's the other one? I 24 A. That the same thing I just looked at?
25 forget. 25 EXAMINATION BY MR. JOANEN:
Page 93 Page 95
1 A. Hydraulics and hydrologic branch? 1 Q. It is, but it's got a different date.
2 Q. Yeah. Did you have any interaction 2 I believe it's the same with a different date.
3 with that branch as the inspector at that East 3 And I'll ask you to turn the Page 25,
4 Bank Industrial Area project? 4 Section 4.2, I believe.
5 A. No. 5 A. 4.2?
6 Q. That little blue tab I have there, 6 Q. Yes.
7 that's where I found that the sheet pile tip 7 A. Okay.
8 was recognized as going down to -8 feet. 8 Q. You see in that paragraph where it
9 You have no reason to believe that to 9 indicates that they're talking about ground
10 be inaccurate, do you? 10 water flow?
11 A. No. 11 A. Yes.
12 Q. I show you next what I'll mark as 12 Q. And this criteria document, throughout
13 Exhibit 8. 13 the body of it, indicates that this is supposed
14 Do you know what a recap submittal 14 to be the master document for all six distinct
15 report is? 15 areas and that they would develop recap
16 A. No. 16 documents for the various six sites. But on
17 Q. Were you involved with any part of the 17 this one, it indicates that the sheet pile tip
18 recap part of this project? 18 reaches down to -25 feet and would essentially
19 A. No. 19 interrupt ground water flow to that depth.
20 Q. I show you what I'll mark as Exhibit 8 20 Do you see that?
21 and just ask if you can identify that. Or if 21 A. Yes.
22 you've ever seen it before. 22 Q. The reason I bring this to your
23 (Exhibit 8 was marked for 23 attention, I would like to know whether anyone
24 identification and is attached hereto.) 24 with WGI, while you were inspector out at the
25 A. I don't recall seeing that. 25 project, commented that the sheet pile depth
Page 94 Page 96
24 (Pages 93 to 96)
CLOUATRE, ALVIN
6/20/2008
1 reached down to 25 feet. 1 knowledge of it, you know, what the tip
2 A. I don't recall hearing that from 2 elevation was.
3 anyone. 3 Q. Do you know, at the site at that time
4 Q. Do you recall -- and when you say 4 who would have been person to alert you of
5 anyone from WGI, how about anyone from the 5 that, if it were in fact true?
6 Corps, that they thought the sheet pile went 6 A. Chain of command would have been Jim
7 down to 25 feet? 7 Montegut.
8 A. I don't remember hearing that from 8 Q. I'm going to show you what I've marked
9 anybody. 9 as Exhibit 10, it's WGI 037607 through WGI
10 Q. In the course of your interacting with 10 037615. I show it to your counsel.
11 people out there, did you ever discuss with 11 MR. JOANEN:
12 anyone from WGI what type of investigation 12 Sorry. I only have one of these.
13 process they did to develop these work plans? 13 (Exhibit 10 was marked for
14 A. No, not really. It just -- no. That 14 identification and is attached hereto.)
15 wouldn't have been something that I probably 15 EXAMINATION BY MR. JOANEN:
16 would have discussed with them. 16 Q. Have you seen that document before?
17 Q. Would that be something that would 17 A. If that was the work plan we used for
18 have been discussed at a level higher than you 18 that, yeah, then I read it before. I mean,
19 during the design phase, or was that something 19 I --
20 that just in the nature of the work doesn't 20 Q. And this anchor foundation block,
21 really come up? 21 that's that wedding cake structure you were
22 A. I would think it would have been 22 talking about --
23 discussed, but I really don't know. It would 23 A. I believe that's it, yes.
24 have been above my level. 24 Q. -- at the north site.
25 Q. Do you have any knowledge either from 25 It indicates in here that excavation
Page 97 Page 99
1 your training or your exposures with the Corps 1 would take place to a total depth of 25 feet.
2 that if the sheet pile tip does not go down to 2 Do you know why 25 feet was selected
3 25 feet, but you have excavations adjacent to 3 as the depth that was put in the plan?
4 this, that will allow water to reach soil 4 A. To my best recollection, I wouldn't
5 stratifications below the sheet pile depth? 5 have known that it would have been 25-foot
6 A. Say that one more time. 6 until I read it in that or you mentioned that,
7 (Whereupon the previous question was 7 but I know that when digging the bypass channel
8 read back.) 8 there was a depth we were going to be digging
9 MS. EL-AMIN: 9 to, and I thought -- it was my understanding
10 I'm going to object to the form 10 that that had something to do with the depths
11 as a hypothetical. 11 we were going to remove objects or remove
12 MR. JOANEN: 12 materials for dredging purposes.
13 I'm asking if he has any -- in 13 Q. That leads us into the next part of
14 his exposures, his experience, does he 14 the scope of work, which indicates the second
15 know about that. 15 phase of the southern block excavation shall
16 MS. EL-AMIN: 16 take place only after determination is made to
17 Same objection. 17 continue excavation past the 25-foot depth.
18 EXAMINATION BY MR. JOANEN: 18 The total depth to which the excavation shall
19 Q. You can answer. 19 go will also be determined at that time.
20 MS. EL-AMIN: 20 Would that be the type of information
21 You can answer. 21 that you were knowledgeable of at the time that
22 A. Um -- I mean, I would have to be 22 this project was taking place?
23 probably alerted that this is something to 23 A. Yes.
24 watch out for because the sheet pile, you know, 24 Q. And again, your answer as to why the
25 the tip was not low enough. But I had no 25 stop at 25 feet has to do with things that you
Page 98 Page 100
25 (Pages 97 to 100)
CLOUATRE, ALVIN
6/20/2008
1 don't necessarily know of, but it has to do 1 to a number of different depths?

2 more related to the future dredging of the 2 A. Yes.
3 bypass channel? 3 Q. Why is it that those depths would be
4 A. To my knowledge, that was it. 4 selected, do you know?
5 Q. As the inspection, and keeping in mind 5 A. The -15, -18 and -28?
6 that you were involved with the cost plus 6 Q. Yes, sir.
7 analysis just to make sure you were getting 7 A. The way I understood it is that when
8 what you were paying for, was the use of a 8 you excavated to a certain depth you had to
9 excavator bucket and the length of the arm a 9 have a waler installed to prevent the sheet
10 factor that you would have taken into 10 pile from caving in because of the pressures
11 consideration? 11 from the ground surrounding. So if the objects
12 A. What do you mean by that? 12 we were removing weren't removed and we had to
13 Q. To go down to 25 feet, the 13 go excavated further to remove them, we would
14 subcontractor that was doing that excavation, 14 then have to install another set of walers on
15 were they limited to go down that far because 15 the inside of the structure, of the sheet pile
16 they only had an excavator arm that could go so 16 to support the weight from the outside
17 far deep in, and that if that excavator arm 17 pressures.
18 wasn't going to be appropriate they would have 18 Q. Were you involved with the gathering
19 to bring in another subcontractor? 19 of information for the technical assumptions to
20 A. That could be the case. I mean, but I 20 be incorporated into this statement of work; is
21 want to make sure I'm answering this correctly. 21 that something that you would have been
22 We wouldn't have had them stop removing what 22 involved with as the inspector?
23 they had to remove because the excavator 23 A. The gathering of technical
24 couldn't reach any further. 24 information?
25 Q. Okay. So as an inspector, you don't 25 Q. Right. These technical assumptions
Page 101 Page 103
1 believe the 25-foot depth demarcation has 1 that are referenced. Like when they say there
2 anything to do with the type of excavator you 2 were 1783 tons of concrete, 990 linear feet of
3 were using, is that correct? 3 treated wood, and they believed that the
4 A. Right. I believe that the depths 4 excavation would need to reach 25 feet, and if
5 were -- you know, to me, we were removing an 5 it was to go deeper than that then they would
6 object, it was estimated to be a certain depth, 6 reevaluate.
7 and if it went deeper or if we had to go deeper 7 A. Yeah. No, I wasn't.
8 for the dredging purposes for the bypass 8 Q. Who would have come up with all that
9 channel, then we had to do -- you know, we had 9 information, WGI or --
10 to mobilize in whatever we had to to remove the 10 A. I believe Washington Group.
11 object. I just don't remember -- I can't 11 Q. To your knowledge, was there any
12 recall what the depth was for the -- for 12 documentation that was available to you that
13 dredging purposes. 13 would limit where or how close to the floodwall
14 Q. Okay. The cofferdam that was 14 excavations could take place?
15 constructed around the wedding cake structure 15 A. I don't recall that. Um --
16 to allow for its excavation, do you recall how 16 Q. Obviously it's nothing you relied
17 deep that sheet pile went? 17 upon?
18 A. No. 18 A. Right.
19 Q. Going back to Exhibit 6 which dealt 19 Q. You also were involved with the
20 with the statement of work for the excavation 20 Sewerage & Water Board lift station removal,
21 of the wedding cake structure, if you look at 21 weren't you? Do you recall whether there was a
22 the Number 3 project requirements, technical 22 limitation as to how deep that excavation would
23 assumptions, and it indicates that the 23 go?
24 cofferdam will be built and walers would be 24 A. No. I really don't remember. I'm a
25 installed and there was going to be excavation 25 little more vague in my memory on that. Um --
Page 102 Page 104
26 (Pages 101 to 104)

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6/20/2008
1 last night I actually kicked that around and I 1 face to face where ideas were kicked around and
2 remembered -- I didn't remember it at first, 2 then what developed was maybe a more precise
3 and then last night I did recall that we 3 plan?
4 removed that, but I just have a better memory 4 A. That would be my guess. Best guess.
5 of the wedding cake. 5 Q. Because I'll show you what I'll mark
6 Q. I show you what I'll mark as Exhibit 6 as Exhibit 13, which is WGI 76654, which is a
7 11 and let your counsel look at it. This is 7 transmittal of this October 10th document.
8 WGI 52123 through 52127. 8 (Exhibit 13 was marked for
9 Have you seen that document before? 9 identification and is attached hereto.)
10 (Exhibit 11 was marked for 10 A. Uh-huh.
11 identification and is attached hereto.) 11 EXAMINATION BY MR. JOANEN:
12 A. I believe I have. 12 Q. And there's a note on here, from
13 EXAMINATION BY MR. JOANEN: 13 December 11th, 2001, indicating that it was
14 Q. When is the first time you saw that 14 disapproved. And I'll show you that.
15 document? 15 You see the handwriting in the
16 A. Um -- probably -- I don't know for 16 comments where it says disapproved?
17 sure, but I'm guessing it probably would have 17 A. Yeah.
18 been before we started the work, probably going 18 Q. It's signed also it looks like by Jim
19 into the preparatory meeting. 19 Montegut, is that correct?
20 Q. The reason I ask that is because I'm 20 A. Yes.
21 trying to get an understanding of how this all 21 Q. The person who would have written
22 works with you guys. 22 disapproved on there, would that have been Jim
23 A. Uh-huh. 23 Montegut?
24 Q. I'll show what I'll mark as 24 A. Um -- yes.
25 Exhibit 12, which is WGI 36981 and 82, which 25 Q. So something about that one he didn't
Page 105 Page 107
1 indicates it would be a preparatory phase 1 like and it was sent back, correct?
2 inspection checklist regarding the sewer lift 2 A. Yeah. Typically, there would be a
3 station removal. 3 response sheet attached if it was disapproved
4 You were present at that meeting? 4 with comments.
5 (Exhibit 12 was marked for 5 Q. We then had, on October 12th,
6 identification and is attached hereto.) 6 Exhibit 14 is WGI 52145 through WGI 52147 dated
7 A. I think I was. I mean, I remember 7 October 12th, 2001. (Tendering.)
8 being at a meeting with Hamps, at least one 8 (Exhibit 14 was marked for
9 meeting. And he did the demolition of the 9 identification and is attached hereto.)
10 building, so I don't remember specifically 10 A. What was the other one dated?
11 being at this meeting but I probably was. 11 EXAMINATION BY MR. JOANEN:
12 EXAMINATION BY MR. JOANEN: 12 Q. The 10th.
13 Q. Can you tell me why you would have 13 A. Okay.
14 meeting and then a work plan developed as 14 Q. Had you seen that Revised Addendum 1
15 opposed to the other way around? 15 plan?
16 A. No. Typically, you would have a work 16 A. I don't recall it but I'm sure I did
17 plan, but I believe on that work plan it had 17 because that seems to be an addendum to the
18 revised on it, which would indicate there was a 18 revised plan.
19 work plan in place beforehand. And I'm 19 Q. Were you involved in the interaction
20 assuming revised means for some reason they 20 between WGI and the Corps that led to the
21 changed their method or they determined 21 addendum and any changes that were --
22 something else to be in the field different or 22 A. I could have been, because it appears
23 something of that nature. 23 to be safety related, so in all likelihood I
24 Q. So you think there was a plan in place 24 was but I don't really remember specifically.
25 originally, there was a meeting with everybody 25 Q. To your recollection, was Mr. Montegut
Page 106 Page 108
27 (Pages 105 to 108)

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1 the person that was heading up this process for 1 Q. Right. October 19th, before they
2 the Corps? 2 started putting spades to the ground, had you
3 A. Process being what -- 3 reviewed that to get an understanding what the
4 Q. The developing this plan and the 4 scope of work was?
5 ultimate approval? 5 A. That would be typically the way it
6 A. I don't know if he -- I think Jim is 6 would work. I don't remember -- I don't know
7 one in a chain of doing that, I don't know if 7 what date they actually started work, so I
8 he was the only one that reviewed that. 8 can't answer that question.
9 Q. Do you know whether any of the 9 Q. It indicates on here that the type of
10 geotechnical engineers were involved in this? 10 excavator to be used would be a PC 270 and a PC
11 A. I don't know. 11 400. That's two separate excavators.
12 Q. To your knowledge, is Jim Montegut a 12 Are you familiar with those two pieces
13 geotechnical engineer? 13 of equipment?
14 A. I don't believe he is. 14 A. I'm familiar with them, yeah.
15 Q. I'll show you next what I'll mark as 15 Q. The PC 400 is a bigger --
16 Exhibit 15 which seems to be a transmittal of 16 A. Yeah.
17 this addendum, and he still had issues with it. 17 Q. -- piece of equipment, correct?
18 (Exhibit 15 was marked for 18 Do you know what the extension of the
19 identification and is attached hereto.) 19 arm is, to what depths it can remove soil?
20 A. Okay. 20 A. I don't know what the extension is.
21 EXAMINATION BY MR. JOANEN: 21 There's also longer arms that they can put on
22 Q. Were you involved with any of the 22 these things, so I really don't know.
23 conclusions or comments that are indicated on 23 Q. Were you, as the inspector of this,
24 there by Mr. Montegut? 24 involved in any way with the determination of
25 A. I don't remember specifically, but 25 what type of sheet pile would be utilized for
Page 109 Page 111
1 safety -- you know, if there were safety 1 the cofferdam?

2 concerns than I'm sure I voiced them to Jim. 2 A. No.
3 Q. When you say safety concerns, would 3 Q. Who would have been responsible for
4 that deal with like OSHA standards, things of 4 that, the contractor or subcontractor?
5 that nature? 5 A. I would think the contractor or the
6 A. OSHA standards -- well, Corps 6 sub initially would have probably submitted
7 standards. That's what we operate on out 7 what type he wanted to use, and then whoever
8 there. The Corps safety manual is our safety 8 reviewed it would have agreed to that or not.
9 Bible. 9 Q. And that would have been Mr. Montegut?
10 Q. And that deals with human interaction 10 A. Well, Jim would be the final one
11 with the works? Does it have anything to do 11 signing off on the submittal. I don't know who
12 with the safety standards regarding adjacent 12 else reviewed the submittal prior to that.
13 floodwall? 13 Q. Would there be other reviews, other
14 A. No. 14 than that are indicated in these transmittals
15 Q. And then I'll show you Exhibit 16 15 of shop drawings such as Exhibit 13 in which
16 which appears to be -- and it's WGI 48621 16 Jim Montegut says it's disapproved?
17 through WGI 48630. I'll let you look at that. 17 A. When you say other reviews, do you
18 This appears to be the one that finally passed 18 mean other plans or do you mean other
19 muster. 19 reviewers --
20 Had you reviewed that document prior 20 Q. Other reviewers, or how does that
21 to this project taking place? 21 work?
22 (Exhibit 16 was marked for 22 A. How it typically works is when you get
23 identification and is attached hereto.) 23 a submittal, depending on the type of submittal
24 A. Prior to the project taking place? 24 it is, that would dictate who would review the
25 EXAMINATION BY MR. JOANEN: 25 submittal before it comes back to the
Page 110 Page 112
28 (Pages 109 to 112)

CLOUATRE, ALVIN
6/20/2008
1 contractor with comments in approval or 1 and how they relate to levees and other
2 disapproval or partial approval form. I'm not 2 protection structures?
3 sure who else was in the chain here to review 3 A. I don't know one way or the other
4 this. 4 whether he has it or not, the expertise.
5 Q. So it's possible, and the reason I've 5 Q. I'll show you what I'll mark as
6 asked the question, when you look at this and 6 Exhibit 17. This is, I believe, one of your QA
7 it's just Jim Montegut signing disapproved, he 7 daily reports. It's WGI 8583 through 8585.
8 might not necessarily even be making that 8 I'll let you look at that.
9 determination, he could just be the one signing 9 (Exhibit 17 was marked for
10 off on what was vetted by people with other 10 identification and is attached hereto.)
11 knowledge than him, correct? 11 A. Okay.
12 A. Very possible. 12 EXAMINATION BY MR. JOANEN:
13 MS. EL-AMIN: 13 Q. Did you generate that document?
14 Objection to the hypothetical. 14 A. It appears that I did. I see it's not
15 EXAMINATION BY MR. JOANEN: 15 signed, but my name is on the bottom of it --
16 Q. With that type of process and 16 typed in on the bottom of it. It looks kind of
17 procedure, what type of documentation is 17 like my writing.
18 generated to show who would have -- if it was 18 Q. Would that be a typical document that
19 done, if it was reviewed by someone other than 19 you would create as your daily log?
20 just Jim Montegut, what would you call the 20 A. Yes.
21 document that would indicate who reviewed and 21 Q. And the information contained in there
22 signed off on it as approved, disapproved or 22 is, I guess to the best of your ability, an
23 disapproved with some -- 23 accurate depiction of what happened on that
24 A. Limitation? I don't know the form 24 day?
25 number if there's a form number, but the 25 A. Yes.
Page 113 Page 115
1 process would be to go to review to the 1 Q. And that's the information that would
2 appropriate office who would be reviewing that 2 be provided to the various people supervising
3 if it was outside of construction division, and 3 the project above you to understand what was
4 they would send their comments back. It's 4 happening?
5 typically some type of form. You know, I don't 5 A. Yes.
6 know if it was done E-mail or not. I have no 6 Q. It indicates, if you turn to the
7 idea because it wasn't part of that process. 7 second page when you talk about the scope of
8 Q. It indicates this what appears to be 8 the work that they were removing the cofferdam
9 the sequence of operations for the lift station 9 from the sewer lift station area?
10 removal. I'm just going by what would be 10 A. From what I can determine from this,
11 perhaps a final plan where they indicate they 11 it looks like they were in the process of
12 drive the sheet piles around the perimeter to 12 removing the pilings inside and were
13 60 feet. Were you involved in any way with 13 backfilling up as they were coming up. That's
14 making the determination that 60 feet was 14 what it kind of reads -- how it reads to me.
15 appropriate? 15 Q. But they're -- the 60-foot sheet pile
16 A. No, I was not. 16 that was put down there to make the cofferdam,
17 Q. Do you know, in your experience as an 17 that was removed as that lift station project
18 inspector, why they would go down to 60 feet as 18 was completed, is that correct? In essence,
19 opposed to 55 or 65? 19 they weren't left there.
20 A. No, I don't know why. I would imagine 20 A. Right. Yeah. I believe they were
21 that typically that's determined by an 21 removed.
22 engineer. 22 Q. Because I've read some reports, not
23 Q. Do you know of your own knowledge 23 particularly here, where if they can't get the
24 whether Mr. Montegut has professional 24 sheet pile up they just cut it off at a certain
25 expertise in underseepage and Artesian heads 25 spot.
Page 114 Page 116
29 (Pages 113 to 116)

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1 That didn't occur here, to the best of 1 Q. Knowing nothing about sheet pile
2 your knowledge? 2 driving, is there different procedures that a
3 A. I don't remember whether it did or 3 sheet pile driver has to take to make it
4 didn't, honestly. 4 watertight?
5 Q. You don't recall as you sit here today 5 A. Well, the way they made it watertight
6 whether in fact you witnessed that cofferdam 6 was something I had never really come across
7 being removed? Cofferdam structure? 7 before. And I can't remember what it was, it
8 A. It's real hazy on that. I don't have 8 was some kind of wood or paper products or
9 a clear recollection of that happening. I 9 something like that where basically they put
10 remember that taking place, I just don't have a 10 them around the sheet pile to where the
11 lot of clear detail on it. 11 pressure of the water was coming in it would
12 Q. How about for the wedding cake 12 just kind of seal off the joints of the sheet
13 structure, do you recall whether that cofferdam 13 pile and then they would continually pump. So
14 was removed? 14 it wasn't true watertight, it just tremendously
15 A. The best I remember, it was removed. 15 slowed the water intrusion into that area and
16 I have a little bit clearer detail on that. 16 then they would keep it pumped out.
17 Q. Were you involved with the removal of 17 Q. To your knowledge, the lift station
18 the train car that was in the waterway? 18 excavation removal, that project was completed,
19 A. Yes. 19 correct?
20 Q. They built a cofferdam for that, as 20 A. To my knowledge, yes.
21 well; correct? 21 Q. The wedding cake structure, was that
22 A. Yes. 22 project also completed?
23 Q. And then they had to remove the train 23 A. Yes.
24 car? 24 Q. Did you have any involvement with a
25 A. Yes. 25 guy named Richard Lesser?
Page 117 Page 119
1 Q. Did they remove that cofferdam? 1 A. I don't remember Richard Lesser.

2 A. Yes. 2 Q. My understanding was he was with WGI.
3 Q. Do you recall whether there was any 3 A. I don't remember a Richard Lesser.
4 excavation that needed to be done to remove 4 Q. You said earlier you had no
5 that train? 5 involvement with George Bacuta?
6 A. I don't recall any excavation. I 6 A. Right.
7 recall that it was along the canal bank, more 7 Q. Do you even know who he was or what
8 or less, and we had to drive it -- and the work 8 his title was for this project?
9 was performed from the waterway, and they had 9 A. I know he's with the Corps and
10 to pump the water out -- watertight the 10 engineering division. I don't remember. I
11 cofferdam and pump the water out. I don't -- I 11 mean I recall -- his name is a familiar name,
12 don't remember if there was any excavation or 12 but I don't -- I never really had any personal
13 not. If there was, it had to be fairly minimal 13 dealings with him.
14 because it was kind of tight in there. 14 Q. Let me ask you some questions about an
15 Q. The cofferdam installation for that 15 E-mail that was sent. You may have no
16 project, when you said to make it watertight, 16 knowledge of it, but I need to ask the question
17 was the same type cofferdam installation used 17 anyway. They're talking about a 1997 report
18 on the sewer lift station and wedding cake to 18 dealing with ground water flow information,
19 make it watertight? 19 indicating the influence of the structures
20 A. I don't think so. I don't remember 20 present at the time -- I believe they're
21 that there was. But I think it was two 21 talking about subsurface structures --
22 different things here. You had -- one was in 22 affecting ground flow. That's probably one of
23 the water, and these other were on the land. 23 these documents right here.
24 And so you didn't have the same water 24 You would not have been involved in
25 intrusion, the same problems. 25 reviewing these documents and/or discussing
Page 118 Page 120
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1 that with Mr. Bacuta in any way? 1 Did you have any communications with
2 A. No. 2 anyone regarding your involvement with the
3 Q. Or Mr. Lesser? 3 project at the East Bank Industrial Area?
4 A. No. 4 A. No.
5 Q. It indicates that -- this is 5 Q. Did anyone from Washington Group ever
6 Mr. Bacuta saying this -- that the structures 6 contact you after the storm to discuss with you
7 were removed and the soil subsurface was 7 your recollection of the project as it took
8 modified on account of the excavation, and that 8 place while you were out there in relationship
9 the ground water flow had changed to a flow 9 to either of those two floodwall failures?
10 instead of going both ways, towards and away 10 A. The only person that contacted me is
11 from the canal, now to away from the canal. 11 Sarah Alvey, who I got along with real well out
12 Had you ever, as the inspector, 12 there, and she called just to see how we were
13 discussed any issues like that with Mr. Bacuta? 13 doing. And she said she heard the floodwall
14 A. No. 14 failed where the areas we were working and all
15 Q. With anyone else at the project site 15 that. But it was nothing -- neither one of us
16 while you were there? 16 thought it had anything to do with our project,
17 A. No. 17 it was more a call out of concern of how
18 Q. Do you recall whether anyone at the 18 everybody was doing down here.
19 project site ever discussed the fact that the 19 Q. The -- this IPET report seemed to
20 ground water flow had been altered and changed 20 indicate that they believed that the north
21 to flow now away from the canal, towards the 21 breach, the Boland site, resulted as a -- I'm
22 floodwall, while you were out there? 22 misusing the term, I'm sure I'll get an
23 A. No. 23 objection -- a foundational failure, it didn't
24 Q. Since -- you know that the floodwall 24 necessarily result from overtopping, it was
25 that was adjacent to the East Bank Industrial 25 from underseepage.
Page 121 Page 123
1 Area failed in two places during Hurricane 1 Have you, in your involvement with the
2 Katrina. 2 Corps, done any of your own research regarding
3 A. Yes. 3 that issue?
4 Q. The north breach is what's commonly 4 A. No.
5 referred to as where the Boland site is, it's a 5 Q. Do you have any information of your
6 little smaller. The south breach was -- at the 6 own based upon your involvement with this
7 Saucer site was larger than that. 7 project and your knowledge regarding the sheet
8 A. Yes. 8 pile depth, or sheet pile as a ground water
9 Q. Have you been contacted by anyone with 9 seepage cutoff, have you done any of your own
10 the Corps to discuss your involvement at those 10 investigation to determine whether in fact any
11 areas in relation -- since Hurricane Katrina, 11 of the excavations that took place at the East
12 to discuss any efforts at the project or 12 Bank Industrial Area led to that foundational
13 information you would have about the project 13 failure?
14 that would relate to the investigation of that? 14 A. No.
15 A. Not until I received the E-mail later 15 MS. EL-AMIN:
16 that this deposition was going to take place. 16 Are you not going to make that an
17 Q. Just this past month or so? 17 exhibit?
18 A. Exactly. 18 MR. JOANEN:
19 Q. Were you contacted by anybody that was 19 What's that?
20 with a group called the IPET team? Do you know 20 MS. EL-AMIN:
21 what that is, the IPET? 21 Are you not going to make that an
22 A. No. 22 exhibit?
23 Q. It's a group of engineers, I think 23 MR. JOANEN:
24 sponsored by the Corps, I'm not sure, that did 24 He doesn't know anything about
25 a pretty exhaustive study. 25 it.
Page 122 Page 124
31 (Pages 121 to 124)

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1 MS. EL-AMIN: 1 of the project. It's sometime after the award

2 Could you at least read the 2 of the project and usually after the notice to
3 numbers? 3 proceed is issued, or around the time the
4 MR. JOANEN: 4 notice to proceed is issued, and it involves
5 I'll make it an exhibit if you 5 the Corps representatives that are going to be
6 want. Which one are we on? 6 involved in the job, it involves the prime
7 MS. EL-AMIN: 7 contractor that's going to be involved with the
8 18. 8 job, and usually an officer from the company
9 MR. JOANEN: 9 and the on-site supervision on the project, as
10 It's WGI 262217 to WGI 262221. 10 well as possibly utility owners or concerned
11 In fairness, I guess I ought to show 11 agencies to that project.
12 it to the witness. If you want to 12 Q. At that meeting was it discussed that
13 look at it, you can. 13 the scope of the remediation, the removal of
14 (Exhibit 18 was marked for 14 soils was going to extend anywhere -- not
15 identification and is attached hereto.) 15 involving the deep removal of subsurface
16 (Brief recess.) 16 structures, just removal of contaminated soils,
17 EXAMINATION BY MR. JOANEN: 17 was going the extend much past five feet? That
18 Q. I'm going to show you a document which 18 you recall?
19 I will mark as Exhibit 19, it's WGI 041373 19 A. I don't recall that.
20 through WGI 041379. And I'll tell you that it 20 Q. Would that have been something that
21 was produced in these numbers, I don't have any 21 you would have been involved with knowing at
22 knowledge whether it's complete or not. It 22 that time?
23 would appear to be. The reason I show it to 23 A. Um -- I don't know if I would have
24 you is because it's got your name on it. It 24 been -- I don't know if I would have known
25 indicates that at the preconstruction minutes 25 about it at that time or not. Like I said,
Page 125 Page 127
1 meeting dated February 19th, 2001, you're 1 typically I get more involved with the meat of
2 indicated as being present, as well as Joe 2 the specific plans as they come around.
3 Dicharry. Which I noticed he signed off on 3 Q. Okay. Do you recall whether any --
4 these big documents right here. (Indicating.) 4 and feel free to review the document -- whether
5 As well as a number of other people. I'm going 5 any of the deep excavations, the wedding cake
6 to ask you the look at this, and I'll -- again, 6 structure, the sewer lift station, whether
7 I only have one copy because these were given 7 those were discussed at that meeting?
8 to me this morning. 8 A. I mean, I could review these minutes
9 (Exhibit 19 was marked for 9 and answer as to what was reported in these
10 identification and is attached hereto.) 10 minutes, but I don't remember specifically a
11 A. Okay. 11 knowledge of what was at the meeting from
12 EXAMINATION BY MR. JOANEN: 12 memory.
13 Q. Do you have a recollection of being at 13 Q. That's fine. And I really was asking
14 that meeting? 14 for your knowledge. Obviously the information
15 A. I know I was at the precon meeting. 15 in the document will speak for itself.
16 You know, I don't remember the specifics of the 16 A. Yeah.
17 meeting. 17 Q. I'm just not trying to hoodwink you,
18 Q. Do you recall whether there were any 18 I'm want to give you as much time as you need
19 meetings that you would have attended prior to 19 to review it, because some of my questions,
20 that one? 20 when you review it the first time you may not
21 A. I don't recall. 21 be thinking of that, if I ask the question and
22 Q. And what was the purpose for having a 22 you want to review it --
23 meeting such as that? 23 A. Right.
24 A. Preconstruction meeting is a meeting 24 Q. -- feel free to.
25 we have for all projects prior to the startup 25 The date of that is in April of 2001?
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1 A. February, 2001. 1 you're ensuring that the inspector is doing his

2 Q. February. Okay. Was there any 2 duties, you're dealing with the contractor's
3 discussion, if you recall, about the works 3 invoices, you're taking the submittals from the
4 taking place in the East Bank Industrial Area 4 contractor, you're processing them by sending
5 by WGI and the subcontractors affecting the 5 them to the different divisions within the
6 floodwall adjacent to that project? 6 Corps that have to review them. You're getting
7 A. I don't recall on way of the other. 7 their comments, you're sending them back to the
8 Q. Do you recall whether anyone in that 8 contractor.
9 meeting discussed the fact that the floodwall 9 Q. Was Jim Montegut the project engineer
10 sheet pile tips extended down to 8 feet or 10 for the East Bank Industrial Area?
11 25 feet? 11 A. He was the contracting office's
12 A. I don't recall one way or the other. 12 representative on the site. But on the job
13 Q. Do you recall whether there was any 13 site he was functioning -- we actually had a
14 discussion about the removal of subsurface 14 project engineer on the site, Robert Ariatti I
15 structures below 8 feet that would affect 15 believe at this time or at the beginning stages
16 ground water flow? 16 was the project engineer. But Jim was like the
17 A. I don't recall one way or the other. 17 equivalent of the team leader or the
18 Q. Do you recall whether there was any 18 supervisory civil engineer who was one step
19 discussions at that meeting about the removal 19 above the project engineer, but Jim had more
20 of subsurface structures that would affect 20 field experience, you know, so he kind of did
21 underseepage of the levee? 21 all the above. He was the COR, contracting
22 A. I don't remember. 22 officer representative, he was the supervisory
23 Q. Looking at the people who were at that 23 civil engineer, but he was on the job site
24 meeting, who at that meeting would have known 24 full-time, which most people in the supervisory
25 about the interaction between the ground water 25 civil engineer position would not be.
Page 129 Page 131
1 in East Bank Industrial Area and the flood wall 1 Q. Do you know whether he's an engineer
2 adjacent to it? 2 by training, a licensed engineer?
3 A. This is an assumption, but typically 3 A. I haven't seen his degree, but as far
4 it would be people in engineering division. 4 as I know he's a civil engineer.
5 Q. Are any of the people indicated there 5 Q. And how about Ariatti, do you know if
6 that you know of in the engineering division? 6 he's an engineer, as well?
7 A. I believe -- I don't remember if Joe 7 A. He's an engineer. I'm not sure, he
8 Dicharry was engineering division or project 8 may be mechanical or something like that, if I
9 management. Um -- I really don't know. 9 remember correctly.
10 Because prior to being a project engineer I had 10 Q. I show you Exhibit 20 which is a WGI
11 little contact with engineering division and 11 8196 through 8198.
12 other divisions within the Corps. Mainly my 12 Can you review that for me, please?
13 interaction was within the construction 13 (Exhibit 20 was marked for
14 division. So I really don't remember who was 14 identification and is attached hereto.)
15 engineering folks and who were the other folks 15 A. Okay.
16 there. 16 EXAMINATION BY MR. JOANEN:
17 Q. How do you get the title as the 17 Q. Is that a document that you would have
18 project engineer if you're not an engineer? 18 generated?
19 A. You're functioning as a, um -- you're 19 A. It appears to be that.
20 not performing engineering duties, you're not 20 Q. And that's your daily log, the QA
21 designing any -- you're not making engineering 21 report that you referenced earlier?
22 calls, but what that position does is you're 22 A. Yes.
23 one level in the chain of command above a 23 Q. If you look at the second page it
24 project inspector, and you're basically going 24 indicates that there are matters that involve
25 out to the field, checking on the project, 25 the flood wall and that there should be
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1 notification to the levee board? 1 A. I assume up the chain of command, Jim

2 MS. CLAYMAN: 2 and, um -- and whoever else was involved in
3 Excuse me, Scott. Can you tell 3 permitting, operations division or -- which is
4 me what the date is on the document? 4 a Corps division, or, I don't know if
5 THE WITNESS: 5 engineering -- that would be engineering
6 It's April 6, '01. 6 division or not.
7 A. Yes. 7 Q. Do you recall whether the levee
8 EXAMINATION BY MR. JOANEN: 8 district had any inspectors out there working
9 Q. What was your involvement with 9 in conjunction with you inspecting the work --
10 notifying the levee board about events going on 10 A. No, they did not.
11 at the East Bank Industrial Area that related 11 Q. -- to ensure that none of their issues
12 to the flood wall? 12 were affected, none of their structures,
13 A. I didn't have involvement with 13 facilities, anything of that nature?
14 notifying them. 14 A. No, I don't recall seeing any levee
15 Q. Why would that be something that you 15 board inspectors.
16 would note in your daily log? 16 Q. If they had been out there, would they
17 A. I don't recall. I mean, I could make 17 have had to report to you?
18 my best guess. Um -- I'm assuming there was 18 A. No. Well, let me take that back.
19 some kind of permit that Cox had with the levee 19 Q. The reason I ask, because there's a
20 board and there was going to be a revision or 20 visitors section that you seem to keep up with
21 there was some change to it that looked to be 21 who was there.
22 having to do with poles running inside the 22 A. Right. Well, that's what I was going
23 floodwall or outside that I guess was a change 23 to say. Anybody, a visitor type person who
24 from that original permit, and I'm assuming 24 wasn't assigned to the job, would have had to
25 that we must have had the permit on hand to 25 report to us. In fact, there was a security
Page 133 Page 135
1 notice the changes, and so they would have had 1 guard at the gate, and we all had little
2 to resubmit. 2 badges, and if you didn't have one he would
3 Q. As the inspector for that project, 3 stop and he would log in who was coming onto
4 would the permitting process that was taking 4 the site and check with Washington to see if
5 place with the levee district been something 5 they were okay to come on site or check with
6 that you were involved with or concerned with? 6 us.
7 A. Not involved with. Concerned with 7 Q. And y'all had built a fence around the
8 regarding just reviewing the permit, you know, 8 area, too, correct?
9 of any work that was going to be taking place 9 A. Yes.
10 out there. 10 Q. Was that fence built on the inside or
11 Q. Do you know what the scope of the work 11 the outside of the floodwall?
12 of the permit would be? 12 A. I don't remember. Um -- if I remember
13 A. I don't know. I don't know based upon 13 correctly -- I don't remember. I'm trying to
14 what I'm reading from this report. 14 picture it right now. I can't even picture it.
15 Q. Do you have any information that would 15 Q. Do you remember why they would have
16 lead you to believe that WGI would have to get 16 had a fence there?
17 an approval from the levee district after it 17 A. Security purposes. Normally, we put
18 completed the work to make sure that none of 18 some type of security fence up around all of
19 its work had done anything to harm the 19 our projects where we can.
20 integrity of the levee? 20 Q. Remembering what that floodwall was
21 A. I don't know if they were -- if they 21 like out there, it was pretty high. Why would
22 had to get that or not. 22 you have to have a fence with that big old
23 Q. If you wouldn't know that as the 23 piece of concrete?
24 inspector, who would be the person that would 24 A. Well, I mean, anybody can get over a
25 know that? 25 wall if they want to, you know. They can put a
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6/20/2008
1 ladder up to it or whatever. 1 was performed here was performed by a

2 Q. And was there anything about the fence 2 subcontractor. And typically, their work was
3 that would prevent people from getting over it? 3 not time and materials or cost plus, it was a
4 Did it have barbed-wire across it? 4 fixed price type subcontract. So that wouldn't
5 A. I don't remember that. I really 5 have any difference on costing more money to
6 don't. Sorry. 6 the government by Washington Group.
7 Q. No need to apologize. 7 Q. If the subcontractor felt that they
8 That was a chain-link fence? 8 had to do more work than originally they had
9 A. I'm pretty sure it was, yeah. 9 planned, they would take that up with WGI to
10 Q. Do you remember how tall it was? 10 get more money?
11 A. No. 11 A. Yes.
12 Q. I'll show you number Exhibit 21 is WGI 12 Q. Would there be -- if WGI played
13 8595 to 8597. Again, this is a daily log. 13 hardball with them and said we're just not
14 It's going to indicate that sheet piling was 14 giving it to you, would they file some type of
15 removed. I'm just going to ask you to look at 15 lien like you would have, say, like in a
16 that and tell me if that refreshes your 16 construction project building a house?
17 recollection as to whether sheet pile was 17 A. If, um -- if Washington didn't agree
18 removed from the cofferdam. 18 that they had a claim for more money --
19 (Exhibit 21 was marked for 19 Q. Uh-huh.
20 identification and is attached hereto.) 20 A. -- then they could file a claim with,
21 A. Okay. 21 um -- I guess Washington is the way it would
22 EXAMINATION BY MR. JOANEN: 22 work. Typically -- I haven't been involved
23 Q. Have you had a chance to review that? 23 with many claims at all, but typically, I
24 A. Yes. 24 believe if a subcontractor has a claim they
25 Q. What's the dates of that document? 25 claim the prime, and then the prime would claim
Page 137 Page 139
1 A. 10 to 12 November, 2001. 1 the government if they want to get reimbursed

2 Q. And does that refresh your 2 for that, or they would fight it out with their
3 recollection regarding the removal of sheet 3 subcontractor.
4 pile from the cofferdam? 4 Q. As the inspector for that project, if
5 A. Somewhat. Somewhat. 5 any of that took place would that have funneled
6 Q. The fact that it was removed and laid 6 through you in some sort?
7 on the side, would that indicate that it was 7 A. I'm sure I would have known about it
8 taken out? 8 but I don't recall that happening.
9 A. Yes. 9 Q. If there were issues that WGI had with
10 Q. If the entire sheet could not have 10 the quality of work that its subcontractors
11 been taken out -- I know at some point it said 11 were doing, would that be something you would
12 the sheet pile may have reached down to fifty 12 have been involved with?
13 feet or so. 13 A. Yes.
14 A. Uh-huh. 14 Q. And how would you have been involved
15 Q. If the entire amount wasn't able to 15 with that? Would you have attended the
16 take place, it had to be cut off, would that 16 meetings that it was discussed?
17 have been noted in your quality log -- quality 17 A. Probably not in a meeting between them
18 assurance log? 18 and their subcontractor. We would have only
19 A. I would normally note something like 19 attended a meeting probably if we would have
20 that, yes. 20 called for a meeting involving this work or if
21 Q. Would that be something that would 21 they would invited us. But typically they have
22 require additional payment to WGI by the Corps 22 their in-house meetings with their own
23 because maybe the work was more than was 23 subcontractors on things of this nature.
24 originally intended? 24 Q. If there were a process taking place
25 A. No. Well, first of all, the work that 25 during a project that you weren't satisfied
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1 with, would you take it upon yourself to 1 about 25 feet was there any process in place at
2 address that to the, like, say, Sarah Alvey who 2 this meeting where there would be discussion
3 was that QC person, or would you have to get 3 about the interruption of ground water flow and
4 approval from your supervisor to then express 4 underseepage and Artesian head as indicated in
5 that concern on behalf of the Corps to the 5 that Plate 3?
6 contractor? 6 MS. EL-AMIN:
7 A. It depended on who was close. I 7 Objection to form.
8 probably typically would have talked to the QC 8 EXAMINATION BY MR. JOANEN:
9 person first, noted it in my report. But all 9 Q. You can answer.
10 this happening would have been simultaneous, it 10 A. Um -- would this meeting have been the
11 would have been -- with informing my chain of 11 forum for discussing that? Is that what you're
12 command. 12 asking me?
13 Q. So it happens right there; if 13 Q. I'm looking for some level of checks
14 something is happening, you basically deal it 14 and balances maybe.
15 with right then. 15 Was there any procedures in place at
16 A. Yes. 16 that meeting to discuss that? Because this
17 Q. Okay. At a meeting like this, do you 17 meeting took place after this -- or it appears
18 know whether anyone there would have known 18 that this document was generated, so that the
19 about the discrepancy about what the actual 19 assumption was that this was generated and
20 sheet pile tip depths was and the sheet pile -- 20 given to the Corps, somebody read it and read
21 MS. EL-AMIN: 21 it saying that they believe the sheet pile tip
22 Objection to form. 22 was 25 feet --
23 MR. JOANEN: 23 A. Uh-huh.
24 I'm not finished yet. 24 Q. -- and then there's going to be
25 MS. EL-AMIN: 25 excavations that we know from the prior
Page 141 Page 143
1 I'm sorry. 1 documents are going to go down to 22 to

2 EXAMINATION BY MR. JOANEN: 2 25 feet --
3 Q. In reviewing that document which is 3 A. Uh-huh.
4 the meeting minutes, do you know whether there 4 Q. -- would there be any checks and
5 is anyone there that would have known whether 5 balances at that meeting to realize that -- or
6 there was a discrepancy between what the actual 6 to consider the interruption of ground water
7 sheet pile depth of this floodwall was and the 7 flow and Artesian head?
8 sheet pile depth that was indicated by WGI in 8 A. I mean, I don't know that this meeting
9 its recap submittal report? 9 is exactly to discuss that kind of issue. It's
10 MS. EL-AMIN: 10 to discuss a wide range of issues, so it could
11 I remove my objection. 11 have been, or that could have been discussed
12 A. I don't know what anybody there would 12 after the submission of that prior to this
13 have known. 13 meeting. I really don't know.
14 EXAMINATION BY MR. JOANEN: 14 Q. And really the basis for my questions
15 Q. I'm going to ask you a hypothetical 15 is that first document I showed you which says
16 question. Just assume certain facts. Assuming 16 in your, um -- what was the name of the course,
17 that this document was relied upon by the 17 Earthworks I and II? Those type of documents
18 Corps, because it's the recap submittal report 18 that say one of the most important things to
19 generated by Washington Group to the Corps of 19 think about is underseepage and issues related
20 Engineers, and that this would have been 20 with that.
21 reviewed by somebody in preparation for the 21 A. Uh-huh.
22 project, and in reviewing this document they 22 Q. Were there any checks and balances
23 believed the sheet pile depth was 25 feet, then 23 with this group of individuals addressing that,
24 when they realized there was going to be 24 that you recall?
25 excavations that are going down to a depth of 25 A. Not that I recall.
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6/20/2008
1 Q. Looking at it now, the individuals 1 would have been Jim 's place or somebody else's
2 that were in place and knowing, as best you 2 place.
3 can, their background and qualifications, were 3 Q. Well, that leads me to a good
4 there any checks and balances in place to 4 question. Because this dealt with the Tulsa
5 address that issue? 5 district so much, do you know whether those
6 A. I don't think there was a certain spot 6 submissions to review in detail were coming to
7 during the meeting where we discussed seepage, 7 the New Orleans office or going to the Tulsa
8 you know, outlined an agenda part seepage 8 office?
9 discussion. I don't remember anything like 9 A. I don't know.
10 that. 10 Q. If you don't know as an inspector, who
11 Q. In your level as an inspector, I have 11 would know that would be on the ground?
12 to ask you why would that not be an issue 12 A. Jim would know because he would
13 brought up when it seems to be very important 13 probably be receiving the document from
14 in the earthwork issues? 14 Washington and forwarding to whoever is
15 A. Yeah. I don't know. I can't answer 15 appropriate.
16 that. I don't know if it was discussed prior 16 Q. The next question is similar dealing
17 to -- you know, it could have been discussed 17 with Lee Guillory. Based upon your working
18 prior to this meeting with dealings with 18 relationship with him and knowing whatever his
19 Washington. I don't know. I'm answering for 19 qualifications are that you know of, do you
20 people -- I can't answer for other people. 20 think that the discrepancy between what WGI
21 Q. I'm not asking for other people. What 21 said the sheet pile tip depth was and the
22 you know of their experience and background. 22 actual sheep pile depth of 8 feet would have
23 Do you know whether anyone there had the 23 been something he should have caught?
24 experience to catch this mistake? 24 A. I don't know if it was his place in
25 MS. CLAYMAN: 25 the review process to look that in depth at it
Page 145 Page 147
1 Objection to form. 1 or not. I don't know.

2 MS. EL-AMIN: 2 Q. Specifically with the excavation that
3 Objection to form. 3 took place at the Boland site, was there a
4 EXAMINATION BY MR. JOANEN: 4 preparatory meeting similar to this where
5 Q. You know it was a good question with 5 issues regarding the excavation took place?
6 both of them objecting. 6 A. Well, again, this is the
7 I'm asking about your knowledge. 7 preconstruction meeting which is like the big
8 A. I mean, I don't have a very big 8 meeting -- usually the big single meeting that
9 knowledge of the people that were there other 9 kicks off the job. The preparatory meetings
10 than the immediate people I deal with through 10 are smaller meetings that are typically held in
11 construction division. So I don't know. 11 the field, not nearly this number of people,
12 Q. In your experience in dealing with 12 mostly the people who are going to be directly
13 Montegut, would the fact that there's a 13 involved at the field level on a phase of work.
14 discrepancy between the 25-foot sheet pile 14 Q. Would you say that this meeting was a
15 depth as reported by WGI and actual sheet pile 15 fairly substantial meeting in the lifespan of
16 depth, would that be the type of thing that he 16 the project?
17 should have caught? 17 A. Yes. Probably the biggest meeting.
18 A. I don't know. I don't know. Like I 18 Q. The meeting that would have taken
19 said, normally construction division forwards 19 place with the sewerage lift station, would
20 those submittals and plans and stuff like that 20 that also have been one that would have taken
21 through other divisions in the Corps. And I 21 place in the field?
22 think that the other divisions, whether it's 22 A. Yes.
23 engineering division or operations or whoever, 23 Q. The ones that are taking place in the
24 it's going through, I think they look at these 24 field, both the wedding cake structure
25 plans in great detail. So I don't know if it 25 excavation and the sewer lift station, what
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1 individuals for the Corps would have been in 1 and said there's only an 8-foot sheet pile
2 the field to attend that meeting? 2 depth there, you may think there's a 25-foot
3 A. Normally -- for the Corps? The 3 sheet pile depth there, what would the steps
4 project inspector, project engineer -- 4 have been by either the project engineer or
5 Q. That would be you? 5 Mr. Guillory to address that discrepancy?
6 A. Well, no, I wasn't the project 6 MS. EL-AMIN:
7 engineer on this project. I was the inspector. 7 Objection to form.
8 Q. So you would have been there? 8 A. My best guess is that they would have
9 A. I would have been there. 9 alerted probably Washington Group so they could
10 Q. Montegut is the engineer? 10 talk to their engineering consultant, as well
11 A. Montegut would have been there, 11 as I would think we would talk to engineering
12 Ariatti, and Lee Guillory attended I believe 12 division here at the Corps.
13 some of the preparatories. 13 EXAMINATION BY MR. JOANEN:
14 Q. At the excavation dealing with the 14 Q. Is it possible that since no one said
15 wedding cake structure and the sewer lift 15 anything about the discrepancy at these
16 station, when they're talking about how deep 16 preparatory meeting phases that the people who
17 they're going, do you recall whether there was 17 were at the preparatory meetings phases of the
18 any discussion about ground water flow? 18 wedding cake structure and the sewer lift
19 A. I don't recall. 19 station didn't know what the actual depth of
20 Q. Do you recall whether there was any 20 the sheet pile was?
21 discussion about the interruption of ground 21 MS. EL-AMIN:
22 water flow with the sheet pile depth? 22 Object to form.
23 A. I don't remember. 23 A. I don't know. I don't know.
24 Q. Do you remember whether there was any 24 EXAMINATION BY MR. JOANEN:
25 concern voiced by anyone with the Corps to WGI 25 Q. Knowing full well the importance of
Page 149 Page 151
1 or one of the subcontractors doing the deep dig 1 seepage and underseepage and Artesian heads,
2 to say, you're going down a certain depth, we 2 would that be the type of thing that would be
3 want to keep an eye on the floodwall over 3 considered at these types of meetings, the
4 there? 4 preparatory meeting for the wedding cake
5 A. I don't recall. 5 structure and the sewer lift station?
6 Q. Based upon your knowledge of the 6 A. If it's a known issue, yes.
7 people when were present at that on behalf of 7 Q. The inverse being true, if it's not a
8 the Corps, would anyone there have had the 8 known issue it's not brought up, right?
9 experience or knowledge to catch the 9 A. Right.
10 discrepancy of the reported 25-foot sheet pile 10 (Brief recess.)
11 depth and the actual sheet pile depth of 8 11 EXAMINATION BY MR. JOANEN:
12 feet? 12 Q. You had mentioned previously that part
13 MS. EL-AMIN: 13 of your job description as the inspector was to
14 Objection to form. 14 assure safety on the job site.
15 You can answer. 15 You recall that?
16 A. You want to repeat it again? I'm 16 A. Yes.
17 sorry. 17 Q. Can you give me some examples of what
18 (Whereupon the previous question was 18 type of things you'd be looking for as the
19 read back.) 19 inspector?
20 EXAMINATION BY MR. JOANEN: 20 A. Yes. Um -- we would be looking at the
21 Q. I'm asking about your knowledge of 21 equipment on site and we would be making sure
22 those people there. 22 the equipment, as it comes on the job site or
23 A. It's possible, but I don't know. I 23 before putting it into use, meets the safety
24 don't know for sure. 24 requirements and the Corps' safety manual. We
25 Q. If someone had caught the discrepancy 25 do equipment inspection sheets on each piece of
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1 equipment. In fact, the contractor does the 1 Q. From theft, things of that nature?
2 actual inspections and we witness the 2 A. Yes.
3 inspections. We try to witness 100 percent 3 Q. And vandalism?
4 but, you know, we don't always. But it does 4 A. Yes. And in the case of an
5 fall back on the contractor's responsibility to 5 environmental job, I would think steps would
6 do this. 6 probably be taken to keep people from harming
7 We ensure that the contractor's 7 themselves environmentally.
8 operating safely. We ensure that they're 8 Q. With this type of project -- this was
9 wearing the proper protective equipment. Um -- 9 an environmental job; is that correct?
10 we ensure that the particular phase of work has 10 A. It was an environmental remediation
11 the activity hazard analysis which applies to 11 and a demolition job, I guess.
12 that work. The contractor develops this, as 12 Q. Is it common that the Corps would
13 well. And he states, you know, what's going to 13 utilize environmental resources to handle
14 take place, what are the hazards involved in 14 demolition projects?
15 this work, and what are the proactive ways to 15 A. I'm not sure I understand.
16 do this work safely. And we ensure that he 16 Environmental resources? What do you mean by
17 follows up on how he does that. 17 that?
18 Q. That involves the slips, trips and 18 Q. The monies, the funds, the utilization
19 falls events? 19 of the individuals with that expertise to
20 A. Yes. 20 handle what was a demolition job? I mean, you
21 Q. In the activity hazard analysis, where 21 don't need someone who's an expert in arsenic
22 is that specified, is that in the Corps' safety 22 to knock a building down, necessarily.
23 manual? 23 A. Right.
24 A. Yes. 24 Q. Maybe you do, I don't know. But is it
25 Q. In the Corps' safety manual, does that 25 common in your practice, in your experience,
Page 153 Page 155
1 also specify that fences are going to be built 1 that the Corps would utilize those resources
2 around the perimeter? 2 for a project like this?
3 A. I think it does say something in there 3 A. Yes.
4 about fences. But typically, the fences come 4 Q. And why is that?
5 more from the contract specs or, you know, that 5 A. Well, environmental is a little out of
6 they are to be installed and where they are to 6 the realm of the construction of a levee
7 be installed, and usually shown located on the 7 project or, you know, building a floodwall or a
8 drawings where they are to be installed. So 8 pump station. So I believe that we used the
9 yeah, I think it does say something in the 9 Tulsa District to administer the contract
10 safety manual. But that's typically spelled 10 because they had something set up for this, for
11 out in each contract. 11 TERC contracts. I believe they had an avenue
12 Q. And you said that all the projects 12 to award the contracts. So I would imagine up
13 that you've been associated with, they have 13 in Tulsa there's, you know, some expertise up
14 built fences around the project? 14 there involving environmental stuff.
15 A. Not all of them. It depends on -- 15 Q. Well, and of course it then begs the
16 where applicable. You might have miles of 16 question, if you take someone who's an expert
17 levee and you can't. 17 in the environmental stuff may not necessarily
18 Q. So when they're doing work out on the 18 be an expert in protection of hurricane levees.
19 MRGO levee, would they put fences out there? 19 A. It's possible.
20 Probably not, huh? 20 Q. And so that's why I ask why the
21 A. No. And also, the fences I guess 21 interaction here, in your experience.
22 really are around where like the office 22 A. Sorry. The interaction what now?
23 compounds are going to be and parking areas are 23 Q. That's why I'm asking about the
24 going to be, and it's to protect the property 24 interaction. Do you know whether the Tulsa
25 there. 25 District was interacting with anyone down here
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1 that is involved with the supervision of the 1 A. Mostly it involves on the site, but,
2 levees? 2 you know, there could be some issue like you
3 A. I don't know if they were or weren't. 3 just mentioned, you know, where dust could be
4 Q. In your experience -- and of course on 4 an issue and so you want to keep the ground
5 some of the projects you were working directly 5 watered and so forth because you don't want
6 with the sheet piles and there was specific 6 dust kicking up to affect the workers and/or
7 concern about underseepage -- are the projects 7 the surrounding area.
8 that deal with non environmental issues more 8 Q. And I know just from reviewing some of
9 likely to take into consideration the potential 9 the notes that there was concern about dust.
10 impacts on the adjacent levees? 10 A. Yeah.
11 A. Can you repeat that? 11 Q. Noise?
12 (Whereupon the previous question was 12 A. (Nods affirmatively.)
13 read back.) 13 Q. There was some concern about odors. I
14 MS. EL-AMIN: 14 guess that you were digging up diesel laden
15 Object to the form. 15 fuels they were worrying about odors emanating
16 A. I still don't think I follow that 16 into the neighborhood.
17 completely. 17 A. Yes.
18 EXAMINATION BY MR. JOANEN: 18 Q. Were those the types of things, the
19 Q. In your experience working with 19 type of safety issues that you were responsible
20 projects that don't involve environmental 20 for as the inspector?
21 remediation, that involve just excavation, 21 A. Yes. Some of them could be. It's
22 demolition or building something, is it more 22 kind of gray whether is that safety or
23 likely that those projects that don't involve 23 environmental issues.
24 the environmental remediation are more 24 Q. That's what I'm building to. Where
25 likely -- is it more likely they'll take into 25 does it fall in, where is that line of
Page 157 Page 159
1 consideration the effects of their works on the 1 demarcation? Were those environmental issues
2 hurricane protection structures? 2 or safety issues?
3 A. I mean, I think for sure those 3 A. It's kind of gray. I mean, dust could
4 projects that are non environmental would take 4 be both. Um -- I would say probably, um -- I
5 that into effect, um -- I don't know any more 5 would probably lean toward more environmental
6 or any less than the environmental projects. 6 issues on those particular things.
7 Q. Well, you may because you've been at 7 Q. Did you have any supervision of the
8 these, especially that preparatory kickoff 8 environmental people who may be responsible for
9 meeting where the levee wasn't even discussed. 9 that issue?
10 In fact, you didn't even know that it was an 10 A. I didn't have any supervision over any
11 issue. 11 of the contractors.
12 A. (Nods affirmatively.) 12 Q. That would be an issue that the
13 Q. Nor did anybody else at the time, I 13 contractor is responsible for, the noise
14 guess. 14 abatement, dust, trucks with bad soils on their
15 A. I didn't recall it being discussed or 15 tires?
16 didn't recall it being an issue. 16 A. He's responsible for that, but we're
17 Q. When you talk about safety and your 17 responsible to ensure that he's doing what he's
18 responsibilities as the safety inspector, 18 supposed to do there and staying within the
19 obviously that involves public safety, but does 19 safety -- our environmental requirements. And
20 that involve public safety only on your site 20 if not, then we at that point discuss the
21 specific or does it also involve public safety 21 issues with them and get them to correct them.
22 for the public on the other side of the 22 Q. Do you personally have the expertise
23 floodwall; for example, noise, dust, things of 23 to know how much dust is okay to get into the
24 that nature? Was that something you had to 24 neighborhood?
25 worry about? 25 A. No, I think there's certain type of
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1 monitoring that -- you know, that regulates 1 A. Yes.

2 that. 2 Q. What is a piezometer?
3 Q. And who would be responsible for that 3 A. It's a well or a casing in the ground
4 monitoring, the contractor? 4 where they measure the water level.
5 A. Yes. The contractor -- his 5 Q. You also know that with piezometers
6 environmental subcontractor would. 6 you can monitor ground water flow?
7 Q. Have you had any education or training 7 A. Why -- I don't recall that it's
8 regarding environmental issues to be capable of 8 capable of doing that but I don't doubt it.
9 questioning the environmental monitor? 9 Q. Was WGI monitoring ground water flow
10 A. Questioning the monitor? The person 10 with piezometers at that location?
11 monitoring? 11 A. Now that you say that I believe they
12 Q. Making sure he's doing his job right. 12 were, but I don't remember that aspect of it
13 I'm trying to figure out how you know that 13 too well.
14 contractor's environmental monitor is doing the 14 Q. Were you responsible for monitoring
15 right thing. 15 the checks and balances that WGI was supposed
16 A. We ensure that he's checking the 16 to be taking care of with that piezometer
17 monitors when he's supposed to be. And as far 17 array?
18 as the data, you know, they produce the data. 18 A. If that's one of the things they were
19 I'm not looking over their shoulder at the lab 19 supposed to be doing, yes.
20 to see. I don't have that expertise. 20 Q. If there was in fact underseepage
21 Q. So that's the checks and balances; 21 taking place but it wasn't so great that it was
22 there's a monitor set up that the contractor is 22 creating sand boils, would you have had any way
23 supposed to put in place -- 23 to know that -- at the time you were at the
24 A. Yes. 24 project, would you have had any way of knowing
25 Q. -- retrieve the data and provide it to 25 that?
Page 161 Page 163
1 whatever agency or department needs that 1 MS. EL-AMIN:

2 information, correct? 2 Objection. Hypothetical.
3 A. Correct. 3 MR. JOANEN:
4 Q. And it's your responsibility to make 4 If it was taking place, would he
5 sure that the contractor keeps those checks and 5 have had any way of knowing that?
6 balances going. 6 A. If seepage was taking place or --
7 A. Yes. 7 EXAMINATION BY MR. JOANEN:
8 Q. Now going to underseepage on that, we 8 Q. Yes. Underseepage without sand boils.
9 know there's obviously no checks and balances 9 A. I don't know.
10 in place, based upon that meeting. 10 Q. To your knowledge, based upon your --
11 MS. EL-AMIN: 11 at these preparatory meetings and all, were
12 Objection to form. 12 there checks and balances in place to monitor
13 MS. CLAYMAN: 13 underseepage of the floodwall?
14 Objection. 14 A. Um -- again, not even remembering that
15 EXAMINATION BY MR. JOANEN: 15 they had the piezometers and stuff out there
16 Q. You would have no way of monitoring 16 until you just mentioned that, I don't recall
17 whether there are any checks and balances that 17 that it was for underseepage. You know -- they
18 the contractor will be following to prevent 18 were measuring the water levels out there. I
19 underseepage; is that correct? 19 don't recall what the purpose was for
20 A. Repeat the question. 20 everything.
21 Q. As the inspector of this, you weren't 21 Q. Preventing underseepage and sand boils
22 monitoring underseepage, correct? 22 and failures of flood walls, that's part of the
23 A. Correct. 23 public safety issues that the Corps undertakes,
24 Q. You know how to operate -- you know 24 correct?
25 what a piezometer is? 25 A. (Nods affirmatively.)
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1 Q. You have to answer yes. 1 WITNESS' CERTIFICATE

2 A. Yes. 2
3 Q. Was that public safety element part of 3 I, ALVIN JOSEPH CLOUATRE, III, do
4 your job description at the inspector for that 4 hereby certify that the foregoing testimony was
5 project? 5 given by me, and that the transcription of said
6 A. No. 6 testimony, with corrections and/or changes, if
7 MR. JOANEN: 7 any, is true and correct as given by me on the
8 I have no other questions. 8 aforementioned date.
9 MR. STONE: 9
10 Okay. 10 ______________ _________________________
11 (Off the record.) 11 DATE SIGNED ALVIN JOSEPH CLOUATRE, III
12 EXAMINATION BY MR. JOANEN: 12
13 Q. Do you know who constructed the 13 _______ Signed with corrections as noted.
14 chain-link fence that protected the perimeter 14
15 of the project? 15 _______ Signed with no corrections noted.
16 A. I don't remember. 16
17 Q. Do you know whether that was something 17
18 that WGI -- that the Corps of Engineers 18
19 specified to WGI for a project work plan or 19
20 whether it was something that WGI would have 20
21 come up with on their own? 21
22 A. I don't remember, but it seems to me 22
23 that because we had project trailers in there 23
24 that we would have had a fence. I don't 24
25 remember who instructed it or who required it. 25 DATE TAKEN: June 20th, 2008
Page 165 Page 167
1 EXAMINATION BY MS. CLAYMAN: 1 REPORTER'S CERTIFICATE

2 Q. I just have one or two questions. 2 I, JOSEPH A. FAIRBANKS, JR., CCR, RPR,
3 This will be very short. 3 Certified Court Reporter in and for the State
4 I just want to ask you, you mentioned 4 of Louisiana, do hereby certify that the
5 piezometers located in the East Bank Industrial 5 aforementioned witness, after having been first
6 Area site. Where were they? 6 duly sworn by me to testify to the truth, did
7 A. I don't remember where they were 7 testify as hereinabove set forth;
8 located. I really don't. I have a very vague 8 That said deposition was taken by me
9 memory of that. 9 in computer shorthand and thereafter
10 Q. Do you know for a fact that Washington 10 transcribed under my supervision, and is a true
11 Group was responsible for putting them out on 11 and correct transcription to the best of my
12 the site? 12 ability and understanding.
13 A. No. 13 I further certify that I am not of
14 Q. And do you know if anyone from 14 counsel, nor related to counsel or the parties
15 Washington Group discussed with you what the 15 hereto, and am in no way interested in the
16 purpose of those piezometers was? 16 result of said cause.
17 A. I don't remember. 17
18 Q. That's it. 18
19 MR. JOANEN: 19
20 That's it. 20
21 21
22 22
23 23 ____________________________________
24 24 JOSEPH A. FAIRBANKS, JR., CCR, RPR
25 25 CERTIFIED COURT REPORTER #75005
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CLOUATRE, ALVIN
6/20/2008
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6/20/2008
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CLOUATRE, ALVIN

1 APPEARANCES: 1 EXAMINATION INDEX

1 Exhibit 17 ...............................115 1 ALVIN JOSEPH CLOUATRE, III

1 STIPULATION 1 Q. In case you don't recall how a

1 Q. If you need to take a break at any 1 A. No.

1 A. 1985. 1 A. I came in as a trainee, but I had

1 um -- electrical, general construction. 1 Q. Do you recall how long that period of

1 involve any subject matter regarding levees? 1 so.

1 taught by civilian personnel? 1 in geotechnical issues?

1 courses? 1 identification and is attached hereto.)

1 Q. Do you recall during either that 1 Q. Do you recall discussing Artesian

1 A. During a high river stage. I don't 1 A. Current position? I'm a construction

1 project inspector? 1 responsible for overseeing the construction of

1 engineering division to understand the plans 1 the safety office.

1 A. I know that during the period of high 1 that particular project?

1 required to do? 1 A. Yes.

1 inspector, what was your next position? 1 inspector?

1 1994. 1 Q. Would the supervisors under you report

1 division. 1 the QA log.

1 or not, but I did work on a remediation 1 Yes.

1 Q. What was your first -- do you know -- 1 it yesterday.

1 others? 1 notes or any other notations --

1 think it was late May. 1 responsibilities as the construction inspector

1 which the plans and specifications were 1 Q. Anything else?

1 EXAMINATION BY MR. JOANEN: 1 different from a fixed-price contract that we

1 of situation, so I didn't quite look at it the 1 Q. Would he be there on a daily basis?

1 individual by the name of George Bacuta while 1 meetings held?

1 specifically, or whether it was work related or 1 you recall?

1 A. Um -- I don't really know if they 1 Q. Do you recall as the excavations were

1 A. No. 1 (Exhibit 5 was marked for

1 documents? 1 So while you were the inspector at the

1 A. I mean, I understood there was going 1 EXAMINATION BY MR. JOANEN:

1 don't necessarily know of, but it has to do 1 to a number of different depths?

26 (Pages 101 to 104)

27 (Pages 105 to 108)

1 safety -- you know, if there were safety 1 the cofferdam?

28 (Pages 109 to 112)

29 (Pages 113 to 116)

1 Q. Did they remove that cofferdam? 1 A. I don't remember Richard Lesser.

30 (Pages 117 to 120)

31 (Pages 121 to 124)

1 MS. EL-AMIN: 1 of the project. It's sometime after the award

32 (Pages 125 to 128)

1 A. February, 2001. 1 you're ensuring that the inspector is doing his

33 (Pages 129 to 132)

1 notification to the levee board? 1 A. I assume up the chain of command, Jim

34 (Pages 133 to 136)

1 ladder up to it or whatever. 1 was performed here was performed by a

1 A. 10 to 12 November, 2001. 1 the government if they want to get reimbursed

35 (Pages 137 to 140)

1 I'm sorry. 1 documents are going to go down to 22 to

36 (Pages 141 to 144)

1 Objection to form. 1 or not. I don't know.

37 (Pages 145 to 148)

38 (Pages 149 to 152)

39 (Pages 153 to 156)

40 (Pages 157 to 160)

1 monitoring that -- you know, that regulates 1 A. Yes.

1 whatever agency or department needs that 1 MS. EL-AMIN:

41 (Pages 161 to 164)

1 Q. You have to answer yes. 1 WITNESS' CERTIFICATE

1 EXAMINATION BY MS. CLAYMAN: 1 REPORTER'S CERTIFICATE

42 (Pages 165 to 168)

A 159:6 128:9 143:9 April 128:25 98:13 128:13