SUZANNE HAWES 4/17/2008

UNITED STATES DISTRICT COURT

EASTERN DISTRICT OF LOUISIANA

IN RE: KATRINA CANAL BREACHES CIVIL ACTION

CONSOLIDATED LITIGATION
NO. 05-4182 "K" (2)
PERTAINS TO MRGO (Robinson) JUDGE DUVAL
(No. 06-2268) MAG. WILKINSON
-------------------------------------------------------
TRANSCRIPT OF THE VIDEOTAPE DEPOSITION OF
SUZANNE HAWES
Given at the U.S. Army Corps of Engineers,
New Orleans District Office, 7400 Leake Avenue, New
Orleans, Louisiana 70118-3651, on April 17, 2008,
commencing at 9:00 a.m.

Reported By:
Estella O. Champion, CRR, CCR
Certified Court Reporter (Certificate #76003)

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1 APPEARANCES 1 THE VIDEOGRAPHER: One moment please.
2 FOR PLAINTIFFS:
3 LAMBERT & NELSON, A LAW CORPORATION 2 This is the videotape deposition of
(BY: HUGH LAMBERT, ESQ.)
4 631 ST. CHARLES AVENUE 3 Suzanne Hawes. This deposition is being held
NEW ORLEANS, LOUISIANA 70130
5 -AND-
4 today at 7400 Leake Avenue in New Orleans,
BRUNO & BRUNO 5 Louisiana on April 17, 2008. The time is
6 (BY: FLORIAN BUCHLER, ESQUIRE)
855 BARONNE STREET 6 9:07 a.m.
7 NEW ORLEANS, LOUISIANA 70113
-AND- 7 Would counsel present please now
8 SHER, GARNER, CAHILL, RICHTER, KLEIN & 8 introduce themselves and which party they
HILBERT, LLC
9 (BY: R. SCOTT HOGAN, ESQUIRE) 9 represent.
909 POYDRAS STREET, 28TH FLOOR
10 NEW ORLEANS, LOUISIANA 70112-1033 10 MS. MILLER: My name is Kara Miller for the
11 FOR THE ARMY CORPS OF ENGINEERS:
12 CORPS OF ENGINEERS, OFFICE OF COUNSEL:
11 United States.
(BY: RITA TROTTER, ESQUIRE) 12 MS. SULLIVAN: Jessica Sullivan for the
13 7400 LEAKE AVENUE
NEW ORLEANS, LOUISIANA 70118-3651 13 United States.
14
FOR THE DEFENDANT UNITED STATES OF AMERICA: 14 MS. GREIF: Michele Greif for the United
15
U.S. DEPARTMENT OF JUSTICE
15 States.
16 TORTS BRANCH, CIVIL DIVISION 16 MS. TROTTER: Lanie Trotter for the Corps.
(BY: JESSICA SULLIVAN, ESQUIRE)
17 (BY: MICHELE GREIF, ESQUIRE) 17 MR. MALONE: Ryan Malone, EJLD AND LBLD, also
(BY: KARA MILLER, ESQUIRE)
18 P.O. BOX 888
18 present.
BENJAMIN FRANKLIN STATION 19 MS. SHERMAN: Kea Sherman, Jefferson Parish.
19 WASHINGTON, D.C. 20044
20 ALSO PRESENT: 20 MR. LAGARDE: Andre Lagarde for the Orleans
21 RYAN MALONE, ESQUIRE
ANDRE LAGARDE 21 Levee District.
22 KEA SHERMAN
ERIC GOLDBERG (Via I-DEP)
22 MR. BUCHLER: Florien Buchler for the
23 WILLIAM GARDNER (Via I-DEP) 23 plaintiffs.
BRIAN RYCKMEN (Via I-DEP)
24 24 MR. LAMBERT: My name is Hugh Lambert and I
VIDEOGRAPHER:
25 GILLEY DELORIMIER (DEPO-VUE) 25 represent the plaintiffs.
Page 3 Page 5
1 INDEX PAGE 1 MR. HOGAN: Scott Hogan for the plaintiffs.
2 TESTIMONY OF SUZANNE HAWES 2 MR. LAMBERT: All right. Would you swear in
3 DIRECT EXAMINATION BY MR.LAMBERT ........... 5 3 the witness, please.
4 *** 4 WHEREUPON, SUZANNE HAWES, having been
5 INDEX OF EXHIBITS 5 duly sworn, testified as follows:
6 EXHIBIT PAGE 6 DIRECT EXAMINATION
7 Plaintiffs # 1 Curriculum Vitae ..................9 7 BY MR. LAMBERT:
8 Plaintiffs # 2 Background of Mrs. Hawes .........19 8 Q. Mrs. Hawes, my name is Hugh Lambert and I
9 9 represent plaintiffs in connection with a lawsuit
10 10 brought involving the flooding in connection with the
11 11 MRGO. Do you understand that?
12 12 A. Uh-huh.
13 13 Q. Okay. And your name has appeared on a
14 14 witness list, and therefore you are here so I can find
15 15 out what it is that you're likely that you're to
16 16 testify about. All right?
17 17 A. All right.
18 18 Q. Have you given a deposition before, ma'am?
19 19 A. Yes.
20 20 Q. Okay. So you're familiar with the process?
21 21 A. Yes. Before we start, I have a unique health
22 22 problem.
23 23 Q. Okay.
24 24 A. I had throat cancer. They radiated my mouth
25 25 and my salivary glands died. About three months ago

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1 they came back, which is good news. The bad news is 1 Q. Okay. Do you respect them --
2 they secrete mucous, so I have to wipe my mouth out 2 A. Yes.
3 regularly. So please bear with me. It's rather gross. 3 Q. -- from a professional standpoint?
4 Q. Well, you know, I'll share with you, 4 A. Yes.
5 Mrs. Hawes, that a few years ago for no good reason I 5 Q. All right. Do you believe that they are
6 had a broken jaw, and my mouth was wired shut for about 6 truthful and straightforward people?
7 eight weeks. 7 MS. MILLER: Objection.
8 A. Yes. Yes. 8 MR. LAMBERT: How could you possibly object
9 Q. And so I walked around like this with my 9 to that question?
10 teeth completely wired together. 10 THE WITNESS: I sometimes disagreed with
11 A. Yes. 11 them.
12 Q. And I could only drink things. And by the 12 BY MR. LAMBERT:
13 time my session ended, I had gotten pretty comfortable, 13 Q. Okay. But you believe they are truthful in
14 so I did things that were sort of foolish. For 14 terms of their opinions?
15 example, I stopped at a McDonalds, got a chocolate 15 MS. MILLER: Objection.
16 shake and a cheeseburger, threw them in the blender, 16 THE WITNESS: They believed their opinions
17 ground them up and tried to drink it. My kids thought 17 but most people believe their opinions.
18 it was entertaining, but it really did plug up all of 18 BY MR. LAMBERT:
19 the -- yes, it was bad. 19 Q. I understand. I have no problem with people
20 A. Yes. I did that. 20 that believe their opinions. I have a problem with
21 Q. Yes, I understand that. 21 people that give opinions that are not supported.
22 A. I've been there. 22 A. Yes.
23 Q. So I share your sympathy. Or I sympathize 23 Q. Okay. And your belief is that these
24 with your situation, though mine was short lived. 24 gentlemen are credible; let's put it that way.
25 A. Yes. 25 MS. MILLER: Objection.
Page 7 Page 9
1 Q. We're going to be brief today. 1 THE WITNESS: I will answer you: Yes, I do.
2 A. Good. 2 BY MR. LAMBERT:
3 Q. I'm going to try and find out what it is that 3 Q. Okay, good. All right.
4 the U.S. Government finds it necessary to put you on a 4 Now I'm going to ask you: Have you reviewed
5 witness list for. And when I have finished doing that, 5 your curriculum vitae?
6 we're going to quit. Okay? 6 A. Yes.
7 A. Okay. 7 Q. And is it accurate?
8 Q. Good. 8 A. Yes.
9 Now, first of all, I see your counsel has 9 Q. We're going to attach it to the deposition so
10 provided me with a curriculum vitae, which shows that 10 we don't have to spend a lot of time with that.
11 you were educated at a number of universities, 11 A. Yes.
12 Stanford, Brown, botany at Brown University, and you 12 Q. Now, what is it -- what is it Mrs. Hawes that
13 also attended UNO. 13 you believe the government intends to call you for as a
14 A. Uh-huh. 14 witness? What is it that you believe that you're going
15 Q. And when I flipped through the publications, 15 to be asked to testify about?
16 I see that you coauthored with two gentlemen; one is 16 A. Frankly, I'm not sure.
17 named Day, John W. Day, and another Gary Shaffer. Do 17 Q. Okay.
18 you remember that? 18 A. I think maybe about the part I wrote about
19 A. Uh-huh. Yes. 19 the effects of MRGO.
20 Q. And was that good? 20 Q. Okay.
21 A. Yes. 21 A. That's -- I don't know.
22 Q. How are those guys? 22 Q. And do I have that report?
23 MS. MILLER: Objection. 23 A. I don't know.
24 THE WITNESS: They are my friends. 24 Q. Tell me about the report. When was it
25 BY MR. LAMBERT: 25 written?

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1 A. About 1998. Let's see. It might have been 1 A. All right.
2 '99. '99. 2 My copy is at home because I was reading it
3 Q. Okay. 3 the other night to refresh my memory or I would offer
4 A. And I was rotating with -- EPA had a sub, a 4 it to you.
5 committee in St. Bernard Parish. I was on the 5 Q. All right. Thank you.
6 environmental subcommittee, and we divided up the work, 6 MS. MILLER: Object to the question being
7 and I was asked to write a report about the impacts of 7 vague.
8 building MRGO. 8 BY MR. LAMBERT:
9 Q. Okay. Why don't you -- I don't have that 9 Q. Go ahead and answer it.
10 report. 10 THE WITNESS: Is it okay if I tell him?
11 MR. LAMBERT: I'm going to ask the government 11 MS. MILLER: Yes.
12 to provide me with a copy of it. 12 THE WITNESS: What I did first was they had
13 MS. MILLER: I believe you have a copy of it, 13 what we call a footprint.
14 of plaintiff's notice to 30(b)(6) with it 14 BY MR. LAMBERT:
15 attached recently. 15 Q. Okay.
16 MR. LAMBERT: Oh, really? 16 A. When they dug MRGO, what did we change. And
17 Have we got it? 17 so I found old quadrangle maps, the oldest I could in
18 MR. BUCHLER: Well, we haven't received it 18 the fifties or sixties.
19 yet, if it was just recently. 19 Q. All right.
20 MS. MILLER: You all provided it to us 20 A. And then I laid out on the maps, drew on the
21 recently via e-mail. 21 maps where MRGO, the channel was, where the disposal
22 MR. BUCHLER: Oh, okay. Good. That PSA 22 area was. And then I lifted -- the quadrangle maps had
23 thing. 23 habitat on them. They distinguished between water,
24 MR. LAMBERT: Okay. Well, then, maybe you 24 marsh and swamp, and I calculated the number of acres
25 can get him on the phone and see if we can 25 that were covered or changed by MRGO.
Page 11 Page 13
1 get a copy of it. 1 Q. Okay.
2 Do you have a copy of it here, since we 2 A. And frankly I don't remember numbers very
3 gave it to you? 3 well. I thought you would have them.
4 MS. GREIF: No, I don't think so. 4 Q. No. I agree. I wish I had.
5 MR. LAMBERT: Okay. Let me get this 5 A. About 20,000 acres were changed. I
6 straight: You guys are going to use this 6 distinguished between what was water that became land,
7 witness to testify with regard to a report 7 what was swamp that became water, what was marsh that
8 that you don't have here? 8 became water, swamp that became spoil, and marsh that
9 MS. TROTTER: Yes. I mean, you're the one 9 became spoil. And I then calculated the erosion
10 taking the deposition. 10 between 1965 and 1990. And I got a number of 15 feet a
11 MR. LAMBERT: Yes, I would like to know what 11 year from an older report; and I measured a few places,
12 it is that she's doing. I mean, we've got -- 12 and it appeared to be fifteen feet.
13 THE WITNESS: I'm finding this amusing, but 13 Now I know that was wrong because in 1993
14 anyway. 14 someone very carefully measured it, and it goes up to
15 BY MR. LAMBERT: 15 40 feet a year. But I made a mistake in my report. I
16 Q. It is amusing. I have to tell you, we asked 16 underestimated the amount of erosion that I calculated,
17 for documents in this case, and the government was kind 17 you know, what I believed was erosion.
18 enough to fill up a whole room in the Texaco building. 18 And then MRGO also brought in saltwater. And
19 And for me to find your report in that room is like 19 there was a ridge, the Bayou la Loutre Ridge. And it
20 looking for a needle in a haystack. 20 is right here -- it's this ridge (indicating).
21 But I understand that the report has 21 Q. Okay.
22 surfaced, so I'm going to rely on your memory to tell 22 A. And it, before MRGO, it separated the Gulf of
23 me as best you can what you got in that report -- 23 Mexico from Lake Borgne.
24 A. Okay. 24 Q. All right.
25 Q. -- that has to do with the MRGO. All right? 25 A. There was this ridge, that if a little surge

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1 came up from the Gulf, it would hit a ridge that was 1 A. And some of it came out.
2 then probably six to eight feet high and stop. So gulf 2 Q. All right. And with the severing of the
3 water could get into Lake Borgne south. MRGO severed 3 ridge by MRGO, that let the saltwater come in?
4 that and so saltwater came in. 4 A. Yep.
5 And there used to be cypress in this area in 5 Q. And what effect did that have on this swamp
6 here we called the Central Wetlands. 6 area?
7 Q. All right. And you're indicating in this 7 MS. MILLER: Objection.
8 area here. Just so the map is clear, that's sort of in 8 THE WITNESS: It killed the cypress.
9 the -- 9 BY MR. LAMBERT:
10 A. Well, it's near -- it's from here up to the 10 Q. It killed the cypress.
11 canal (indicating). 11 I was driving along Highway 310 yesterday on
12 Q. Okay. The whole reach where St. Bernard is? 12 the way down to New Iberia; and when you come off the
13 A. Yes, the whole area -- 13 freeway there and go west, on the west end of --
14 MS. MILLER: Objection. 14 A. 310.
15 THE WITNESS: -- west of MRGO. Between MRGO, 15 Q. On 310, going on the west end of the
16 and what they called the 40-Arpent Levee, 16 airport --
17 which was this levee, the Harvey central 17 A. Going south.
18 records. 18 Q. -- going south, right. There's a beautiful
19 BY MR. LAMBERT: 19 cypress swamp.
20 Q. All right. Now, Mrs. Hawes, let me do this 20 A. Yes, there's even an eagle nest.
21 right quick because that map is not on our camera and 21 Q. What?
22 I'm going to get one right here. 22 A. An eagle nest.
23 A. Okay. 23 Q. Yes. In that area?
24 That's even better. 24 A. Yes.
25 Q. Let's start off with the ridge. And the 25 Q. I've been told that.
Page 15 Page 17
1 reason I'm talking loud now is because I don't have my 1 A. There is.
2 microphone. 2 Q. I didn't spot it, but it's a beautiful
3 A. Yes. 3 cypress swamp.
4 Q. All right. So let's start off with showing 4 A. Yes.
5 us where the ridge was. 5 Q. Is that sort of the way that swamp looked in
6 A. This is Bayou la Loutre Ridge, and it goes 6 St. Bernard before the --
7 over that way. 7 MS. MILLER: Objection.
8 Q. Hold on one second. I'm going to get another 8 MR. LAMBERT: May I finish my question?
9 one. 9 MS. MILLER: Sorry. I thought you were
10 Here it is. 10 finished.
11 A. There it is, yes. 11 BY MR. LAMBERT:
12 Q. Kind of get these together. 12 Q. -- before the MRGO was cut through the ridge?
13 A. Yes. It is this ridge, that it's obviously a 13 MS. MILLER: Objection, calls for
14 different color. 14 speculation.
15 Q. Right. 15 THE WITNESS: I don't know because I never
16 A. It's higher. And that ridge MRGO cut across. 16 saw the swamp in St. Bernard.
17 Q. Okay. And then show us where that cypress 17 BY MR. LAMBERT:
18 swamp area was. 18 Q. Did you see photos?
19 MS. MILLER: Objection. 19 A. I don't think so.
20 THE WITNESS: It's all on this, so you don't 20 Q. Okay.
21 need that one, because these overlap. 21 A. I've seen some old photos of MRGO, but it's
22 BY MR. LAMBERT: 22 all about dredging it, so ...
23 Q. Okay. 23 Q. Okay. All right.
24 A. It was actually in here. 24 The maps that you told us about a minute ago
25 Q. All right. 25 that show the areas of the swamp that were converted as

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1 a result of the saltwater and so on -- 1 Q. I understand.
2 A. Uh-huh. 2 A. I sip water.
3 Q. -- do you have those at your house? 3 Q. I understand.
4 A. No. 4 It seems to me like in general you would
5 Q. They are here? 5 agree with me that the cutting of the ridge by the MRGO
6 A. I think they are here. I mean, I -- 6 and the accompanying saltwater intrusion that killed
7 unfortunately, when I was writing this, I barely could 7 the cypress swamp area in St. Bernard would have a
8 talk because my throat was radiated. And so I just did 8 negative effect in terms of preventing surge into that
9 my own thing, and I did not realize I could have had 9 area?
10 the maps scanned in. That was stupid but that's life. 10 MS. MILLER: Objection, vague. Calls for
11 And so I just have Xeroxes. And I am not sure; the 11 speculation.
12 originals are down somewhere in St. Bernard Parish. I 12 THE WITNESS: No, I would not agree with you
13 don't know where. They got lost. But I gave them the 13 that I'm not an expert.
14 colored originals with my markings on them. 14 BY MR. LAMBERT:
15 Q. Okay. 15 Q. Okay. So let's put it this way: You do not
16 A. And no one knows what happened to them. 16 expect to be asked questions with regard to surge?
17 Q. Yes. St. Bernard took a pretty good hit with 17 A. I don't think so. If I were a -- now --
18 Katrina. 18 Q. Let me ask you this, is that your area of
19 A. Yes, yes. And Junior is chairman of the 19 expertise?
20 Subcommittee I was on. 20 A. No.
21 Q. Junior Rodrigue? 21 Q. So you could tell us what saltwater does in
22 A. Yes. 22 terms of destroying a cypress swamp; correct?
23 Q. And so he would be the person who you would 23 MS. MILLER: Objection.
24 probably ask about those maps? 24 THE WITNESS: Uh-huh.
25 A. I guess. You know, I don't know that he 25 BY MR. LAMBERT:
Page 19 Page 21
1 would remember. He has had a few other things to worry 1 Q. And you agree with me that it did?
2 about since then. 2 A. Yes.
3 Q. No. I understand. I understand. 3 MS. MILLER: Objection.
4 Okay. I have a document which I'm going to 4 BY MR. LAMBERT:
5 mark for identification as Exhibit Number 2, which is a 5 Q. But you do not feel like it is part of your
6 fairly complimentary look at -- 6 area of expertise to comment on what effect that would
7 A. Okay. 7 have from a hydrological standpoint on a surge?
8 Q. -- at your background. 8 MS. MILLER: Objection.
9 MS. MILLER: Do you have an extra copy of 9 THE WITNESS: That is correct.
10 that? 10 BY MR. LAMBERT:
11 MR. LAMBERT: I sure do, just for you. 11 Q. That's correct. Okay.
12 MS. MILLER: Thank you. 12 Now, can you tell me about the mechanism
13 BY MR. LAMBERT: 13 for --
14 Q. And it looks to me like you've been pretty 14 And any time you want to take a break, we can
15 interested in the importance of wetlands for quite some 15 take a break.
16 time. 16 A. Uh-huh.
17 MS. MILLER: Objection, vague. 17 Q. Can you tell me about the mechanism for the
18 THE WITNESS: Yes. 18 effect of saltwater intruding into a freshwater or a
19 BY MR. LAMBERT: 19 brackish water swamp? And you can distinguish between
20 Q. I also guess, based on your curriculum vitae, 20 groups or types of swamp --
21 that you do not think that the government will ask you 21 A. I didn't know --
22 to comment on any sort of hydraulic calculations. 22 MS. MILLER: Objection --
23 A. Absolutely not. 23 BY MR. LAMBERT:
24 Q. Okay. But in general -- 24 Q. -- in your answer if you would like.
25 A. I drink water. That's it. 25 Go ahead and answer it, please.

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1 THE WITNESS: Can I answer it? 1 Q. I see. So, in other words, with treated
2 MS. MILLER: You may. 2 sewerage and freshwater, storm runoff in that area,
3 THE WITNESS: First of all there's only one 3 just to the east of the 40-Arpent Canal --
4 kind of swamp. 4 A. Yes. There are two places they pump it out.
5 BY MR. LAMBERT: 5 You can see little rings of cypress.
6 Q. Okay. 6 Q. Coming back?
7 A. Swamp is cypress trees and tupelo trees. And 7 A. Yes. Yes.
8 then marsh is wetlands with no trees; and there are 8 Q. That's interesting.
9 different kinds of marshes: Fresh, intermediate, 9 Do you agree with me that there's hope in
10 brackish and saline. But swamps are -- swamps are 10 terms of --
11 swamps. 11 MR. LAMBERT: You need to wait until I'm
12 Q. Okay. Swamp is a cypress-tupelo swamp? 12 finished my questions before you start
13 A. Yes. 13 interrupting because it's not right.
14 Q. Let's start with that. How does saltwater 14 MS. MILLER: I'm sorry.
15 effect the cypress-tupelo swamp? 15 MR. LAMBERT: And I'll finish my question
16 MS. MILLER: Objection. 16 and --
17 THE WITNESS: In some ways that's -- I'm not 17 MR. BUCHLER: Why can't we make the objection
18 a -- I'm not sure what you would call it, but 18 continuing?
19 someone that I know what the effect is. Too 19 MR. LAMBERT: No, no. We're not going to do
20 much salt kills the cypress. Now, there are 20 that. I'll be happy to, you know, give you
21 people that can give you all sorts of details 21 an opportunity to make your objection, but
22 about why. 22 interrupting isn't appropriate for either one
23 BY MR. LAMBERT: 23 of us.
24 Q. The mechanism, they will tell me about the 24 MS. MILLER: I'm sorry. It's been difficult
25 botany? 25 to tell when you're finishing.
Page 23 Page 25
1 A. Yes. The botany is. Seawater is 33 parts 1 MR. LAMBERT: Well, I'll let you know when
2 per thousand of salt. That's sort of a standard. 2 I'm finished with my question. Okay? Good.
3 Anything over six to eight parts per thousand for very 3 MS. MILLER: Okay.
4 long will kill cypress. And it goes to eight parts per 4 MR. LAMBERT: Now I'm going to go back to my
5 thousand at times to kill cypress. And you can 5 question.
6 still -- now the cypress -- when you kill marsh grass, 6 BY MR. LAMBERT:
7 it dies, falls over and disintegrates. 7 Q. Do you agree with me that there is hope for
8 Q. It dies, falls over and disintegrates. 8 projects which use technology to introduce freshwater
9 A. But then, when you kill cypress, it dies, but 9 and materials, sometimes pumped or dredged materials,
10 the trees stand there. So they have those swamps where 10 to recreate marsh and then hopefully swamp? Do you
11 there are dead trees just standing. And so you can in 11 agree with that?
12 many ways see where the cypress used to be in 12 A. Yes. Yes.
13 St. Bernard because you can see the dead trees. 13 MS. MILLER: Objection, vague and compound
14 Q. Right. And I have been there and there are 14 question.
15 some dead trees left, but there are some that aren't 15 BY MR. LAMBERT:
16 there anymore. 16 Q. Go ahead and answer.
17 A. They have fallen over. 17 A. Yes.
18 Q. Right. 18 Q. Okay.
19 A. But that's what's interesting, St. Bernard 19 A. So you can hear, yes.
20 pumps out, I don't know if it's treated sewerage or 20 Q. Okay. Good.
21 storm water, in two places and there are live, little 21 My counsel on the other side of the table
22 crescents of live cypress there. They freshened it 22 here, of which there are four, will speak through this
23 enough. It's right at the brink. They freshened it 23 young lady right next to you, and they are interposing
24 enough that there is cypress back. So that is 24 objections to some of my questions so that the record
25 interesting. 25 is preserved, so that a judge -- not them, and not

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1 me -- will decide whether that objection is 1 did you become aware of the salinity in the marshes and
2 appropriate. 2 swamps rising?
3 You're to answer the questions, unless you're 3 MR. LAMBERT: Objection, vague.
4 instructed by counsel not to, and she will make it 4 THE WITNESS: Yes.
5 clear if she doesn't want you to answer. And then the 5 BY MR. LAMBERT:
6 judge gets to decide whether the objection is 6 Q. And you've explained to us that the cypress
7 appropriate or fair or not. And because you've 7 swamp can live with six to eight parts per thousand of
8 answered the question, it will be there so we don't 8 salinity, and that seawater is 33 in general.
9 have to come back and ask you again. That's the reason 9 A. 32.
10 why this charade is going on here right now. 10 Q. 32, okay.
11 A. I hear you. 11 So obviously there's a significant effect to
12 MS. MILLER: Mr. Lambert, would it be okay to 12 a large tidal waterway being introduced into a marsh
13 take a break? 13 area?
14 MR. LAMBERT: If you would like. Would you 14 MS. MILLER: Objection.
15 like a break? 15 THE WITNESS: It did not make it 32 parts per
16 THE WITNESS: Yes. 16 thousand. It just raised it slightly, and
17 MR. LAMBERT: Okay. Be happy to. 17 the slightly was enough.
18 THE VIDEOGRAPHER: Off the record, it is 18 BY MR. LAMBERT:
19 9:32. 19 Q. I understand.
20 (Recess taken.) 20 Now, would you agree that if the channel in
21 THE VIDEOGRAPHER: Returning to the record, 21 the land cut -- not out in Lake Borgne, but in the land
22 it is 9:40. 22 cut north of the ridge -- if the channel had been
23 BY MR. LAMBERT: 23 maintained with banks and spoil on each side, rather
24 Q. All right. I was explaining to you the 24 than being allowed to erode so that it became a much
25 objection situation so that you're clear that the 25 wider presence and also a more direct pathway for
Page 27 Page 29
1 answers are appropriate for the record, unless you're 1 saltwater into the marsh, that the marsh would not have
2 asked not to, not to answer by the attorney. 2 been as severely affected?
3 Now, I had attached for the record this 3 MS. MILLER: Objection.
4 document as Exhibit Number 2 -- which shows back in -- 4 THE WITNESS: Not -- isn't within my area of
5 gosh, I think this was -- 5 expertise.
6 A. April 2005. 6 BY MR. LAMBERT:
7 Q. Right. There you go. Thank you. 7 Q. Okay. All right.
8 April 2005, your activities in terms of the 8 You would agree with me that the higher the
9 New Orleans District and so on. You are still active 9 salinity in the marsh and swamp areas, the more
10 with the Corps of Engineers? 10 significant the effect?
11 A. Yes. 11 MS. MILLER: Objection.
12 Q. And your current position is what, please? 12 THE WITNESS: Well, I mean, some marsh can
13 A. Project manager for the environment. 13 take higher salinity.
14 Q. Okay. And that's the area that I'm going to 14 BY MR. LAMBERT:
15 confine my questions to, pretty much the environment. 15 Q. Okay.
16 Now, I saw in some documents -- and I'm not 16 A. Some marsh was there that withstood the
17 going to dig them out individually -- that one of the 17 salinity and did not change.
18 concerns you had were for various species of animals 18 Q. Okay. Tell me about -- you told me there was
19 protected by, or, I'm sorry, that used the marsh and 19 only one swamp, and then I think you said there were
20 swamp areas as a habitat. 20 three kinds of marshes.
21 MS. MILLER: Objection, vague. 21 A. Yes, four.
22 BY MR. LAMBERT: 22 Q. Four. Okay. Let's go through those. What
23 Q. Correct? 23 are they?
24 A. Yes. 24 A. There's fresh, intermediate, brackish and
25 Q. Okay. Once the ridge was penetrated by MRGO, 25 saline.

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1 Q. All right. What effect does saltwater 1 A. Uh-huh, yes.
2 encrosion have on freshwater marshes? 2 Q. Okay.
3 MS. MILLER: Objection. 3 MS. MILLER: Objection.
4 THE WITNESS: Well, it isn't good. It kills 4 THE WITNESS: I didn't say it was a surge --
5 it. But there wasn't any freshwater marsh in 5 I did say for low surges. I mean, it was
6 St. Bernard. 6 only 6 to 8 feet high.
7 BY MR. LAMBERT: 7 BY MR. LAMBERT:
8 Q. All right. How about between, I guess 8 Q. I understand.
9 between Lake Borgne and the MRGO, that was also at 9 A. And hurricane surges, from what I've read,
10 least a brackish swamp? 10 can be twenty, so ...
11 A. It was a brackish marsh. 11 Q. Well, that all depends on who you talk to and
12 Q. Marsh. 12 as far as its effects go. The, quote, speed bump
13 A. Yes. 13 effect or the buffer effect, all that stuff I
14 Q. Okay. I've been told by some fishermen that 14 understand to be outside of your area of expertise.
15 the areas, some areas north of the MRGO, between the 15 A. Right. But I do know that it entered
16 MRGO and Lake Borgne also had cypress trees. 16 St. Bernard Parish, therefore it had to be over 17 feet
17 A. On the maps that I saw, very little. It was 17 high, so ...
18 like, when we built MRGO, we destroyed maybe 60 acres 18 Q. All because the design height of the --
19 of swamp that were -- I'm not sure of that number, but 19 A. Yes.
20 it was about that -- that was out that far. 20 Q. -- hurricane protection structures?
21 Q. Well, these fishermen friends of mine tell me 21 A. Yes. Yes.
22 that there are still stumps as you've described, 22 Q. Okay. Now you don't know what effect that
23 cypress stumps on the north side. 23 wave wash had, do you?
24 A. I don't recall seeing any. There could be. 24 A. No.
25 I don't know. 25 Q. You don't know whether or not the
Page 31 Page 33
1 Q. Okay. 1 configuration of the MRGO and the lack of swamp and
2 A. There's certainly no trees left. There may 2 marshland led to wave propagation, which then attacked
3 be stumps. 3 the levee and overtopped it? That's not your area of
4 Q. Okay. 4 expertise?
5 A. But I would have noticed trees, I think. 5 A. No.
6 Q. What about, are there any -- you said: 6 MS. MILLER: Objection.
7 Fresh, intermediate, brackish and saline? 7 BY MR. LAMBERT:
8 A. Uh-huh. 8 Q. Describe for me, if you would please, Hawes,
9 Q. In the area where the MRGO was dug -- and I'm 9 the type of swamp and marsh that existed in the land
10 going to focus now on the area through the land cut. 10 cut of the MRGO.
11 And we can start with the -- by the way, let me back up 11 MS. MILLER: Objection.
12 one second. The ridge that we just discussed -- 12 BY MR. LAMBERT:
13 A. Uh-huh. 13 Q. Pre-MRGO.
14 Q. -- is that the ridge where the closure is 14 A. From memory, there was a strip of
15 proposed? 15 intermediate marsh adjacent to the 40-Arpent Levee in
16 A. Yes, yes. 16 sort of the middle of the Central Wetlands. The rest
17 MS. MILLER: Objection. 17 of the area north of the ridge was brackish marsh, both
18 BY MR. LAMBERT: 18 on the north side of where MRGO ended up being and in
19 Q. So that's sort of the natural high area, and 19 the Central Wetlands. South of the ridge there was
20 that's where the proposed -- and I say closure. It's 20 some saline marsh at the south end, and then brackish
21 called a de-authorization plan -- intends -- 21 marsh.
22 A. It is -- part of the de-authorization plan is 22 Q. Okay. And the swamp that you described
23 to build a closure at the Bayou la Loutre Ridge. 23 was --
24 Q. And that's the ridge that you've told us 24 A. The swamp was sort of scattered through
25 about that was sort of the surge barrier? 25 batches. The man that mapped the wetlands in 1949 did

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1 not indicate swamp. Don't ask me why. He indicated 1 Levee and MRGO on the east and west.
2 marsh types. 2 Q. Okay.
3 When I looked at the quadrangle maps, they 3 A. Except it really isn't east and west and
4 showed where the cypress was. 4 north and south.
5 Q. The what kind of maps? 5 MR. LAMBERT: Florien, would you please get
6 A. The quadrangle maps. 6 this map and hold it up so Mrs. Hawes can
7 Q. Quadrangle? 7 show us.
8 A. Yes. 8 THE WITNESS: Yes, the Central Wetlands go
9 And then also I had data from the U.S.G.S, 9 from here, like that. It's these
10 that when we wrote Coast 2050, we divided the coast 10 (indicating).
11 into what we called mapping units that were areas of 11 BY MR. LAMBERT
12 similar vegetation, and one of the mapping units was 12 Q. Okay. Central Wetlands. Okay. And what's
13 the Central Wetlands. And we had, when we did 2050, we 13 the area around Lake Borgne referred to?
14 had U.S.G.S. go back and, from aerial photographs, 14 A. This mapping unit was I think called from --
15 attempt to identify what kind of plants were there. 15 I'm not sure. I think from here down to the ridge was
16 And so I had a spreadsheet that said, in the 16 called South Lake Borgne, and this was the land bridge
17 Central Wetlands in 1956, there were these kind of 17 up that way. I'm not sure. I think this piece is in
18 acres of swamp, marsh, et cetera. Then I had the same 18 South Lake Borgne. I don't remember.
19 data for 1976, I think it was, and 1990. 19 Q. Okay. And when you say "land bridge," what
20 Q. All right. 20 area --
21 A. And those are available in Coast 2050 -- 21 A. This one from here over to the Rigolets is
22 well, not really. They weren't available as 22 called the Pontchartrain-Borgne land bridge.
23 spreadsheets. They were described in words in Coast 23 Q. Okay. All right. All right.
24 2050. 24 And because we don't have a map, and I want
25 Q. Okay. And that's your report? 25 to make sure the record is real clear, I would like for
Page 35 Page 37
1 A. I was a coauthor among many, many people. 1 you to show -- to slowly describe where the cypress
2 Q. Okay. All right. 2 swamp area was before the MRGO was cut.
3 Okay. Now, the -- you've already shared with 3 A. Again, it's been a while since I looked at
4 us what effect the MRGO had on the swamp. 4 the map. There was some down -- there was some in here
5 A. Uh-huh. 5 (indicating).
6 6 Q. All right.
7 Q. Okay. And I would like for you to tell us if 7 A. There was some here (indicating). Then I
8 you would, please, in general terms what effect it had 8 think there was some out here (indicating), and maybe a
9 on the intermediate marsh. 9 little -- there were two places I think it extended
10 10 out, maybe not where we dug MRGO, but where we put the
11 MS. MILLER: Objection. Vague. 11 spoil at.
12 THE WITNESS: Well, that gets interesting 12 Q. Okay. All right. Thank you.
13 because it -- some years there was no 13 A. It wasn't much.
14 intermediate marsh in the Central Wetlands. 14 Q. Okay. Now, you told us that during the
15 Other years there was, after MRGO. It 15 cutting of the MRGO, you estimated a loss of
16 depends on rainfall. It depends on the way 16 approximately 60 acres.
17 the wind blows, depends on a whole bunch of 17 MS. MILLER: Objection.
18 things. And so intermediate marsh has come 18 THE WITNESS: Right, of cypress swamp, yes.
19 and gone in the Central Wetlands since MRGO. 19 BY MR. LAMBERT
20 BY MR. LAMBERT 20 Q. Yes. There was a significant amount, an
21 Q. When you say "Central Wetlands," what are we 21 additional amount of marsh that was cut?
22 talking about? 22 A. Yes. Yes.
23 A. I'm talking about an area from the Bayou la 23 Q. Can you estimate for me what that was?
24 Loutre Ridge here, up to the Inner Harbor Canal on the 24 A. As I recall, when I totaled land that was
25 north and south essentially, and between the 40-Arpent 25 wetlands that either became water or spoil, it was just

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1 under 20,000 acres. I think 19,400. And also because 1 there was continuing erosion along the canal?
2 of erosion. There was three causes. 2 A. Mostly on the north bank.
3 Q. Okay. Now, in later reports, like the 3 MS. MILLER: Objection.
4 Reconnaissance Report of 1988, and again the bank, I 4 BY MR. LAMBERT
5 think it was called St. Bernard Parish -- 5 Q. On the north bank, correct. And a
6 A. You didn't let me finish about the other 6 significant part of that erosion was attributable to
7 impacts. 7 ship wake?
8 Q. I'm sorry. 8 A. I don't want to go there. I have been told
9 A. I estimated the changes in habitat type 9 very clearly that is not my area of expertise.
10 caused by MRGO that swamp became -- the swamp died. 10 Q. Okay. I understand. Let me describe to you
11 The intermediate marsh came in under it. So the swamp 11 a phenomena.
12 became -- or brackish. I took from the numbers 12 Well, before I do that, let me ask you a
13 U.S.G.S. had and calculated how many acres of what 13 question about this situation: Sea level rise, okay?
14 switched to what: This many acres of intermediate 14 A. Yes.
15 marsh became brackish marsh, this many acres of 15 Q. I've heard it called "global warming"; I've
16 brackish marsh became saline. I did the acreages and 16 heard it called "climate change"; I've heard it
17 had that as impacts of MRGO in my report also. 17 called -- depends on what the spin is. But the
18 Q. The two reports that I just mentioned to 18 question is: Does a rise in sea level -- and I'm
19 you -- and I don't want to get them out. They are that 19 talking about a reasonable estimate of rise, which you
20 high. One of them is an Erosion Reconnaissance Report 20 probably know from a figure standpoint more than I
21 done in 1988. 21 do -- what effect -- or let's put it this way: How is
22 A. Yes. Yes. 22 a swamp able to manage that?
23 Q. And then there's another one done in 1994. 23 MS. MILLER: Objection, vague. Calls for
24 A. '94, okay. 24 speculation.
25 Q. A reconnaissance report on bank erosion. 25 BY MR. LAMBERT
Page 39 Page 41
1 A. Yes. 1 Q. And let me give you some more parameters.
2 Q. And then there was also, back in the 80s, 2 Let's say there's no saline increase. In other words,
3 there were design memorandums having to do with 3 let's just keep the salinity the same for the purposes
4 foreshoring along the south side of the MRGO in the 4 of the question. And my question is, and I'm starting
5 area of Chalmette. 5 with the swamp, tupelo-type-cypress swamp, which I
6 A. Uh-huh. 6 now -- every day I learn something -- now I know
7 Q. Okay. Those discussed what I think you told 7 there's only one kind of swamp. I'm happy to hear
8 us about was the erosion, and your original 8 that.
9 calculations were 15 feet per year? 9 A. And you learned it from the Corps.
10 A. Yes. I got that from the 1988 report. 10 Q. I did, absolutely.
11 Q. And then later you found out it was 11 So how does that handle a .4-inch sea rise in
12 significantly greater? 12 however many years?
13 MS. MILLER: Objection. 13 MS. MILLER: Objection, vague. Calls for
14 THE WITNESS: Right. It varies tremendously. 14 speculation, expert opinion.
15 BY MR. LAMBERT 15 BY MR. LAMBERT
16 Q. On where? 16 Q. Okay. Go ahead and answer it.
17 A. Along MRGO. 17 A. The mature trees really don't care. They
18 Q. Yes. 18 just keep on growing.
19 A. Some places it is 15 feet a year. 19 Q. Okay.
20 Q. Right. 20 A. But for a young cypress, for a cypress seed
21 A. Some places it's -- I think 43 was the 21 to sprout and grow, it needs the tip of its head above
22 biggest number I remember. But they actually measured 22 water.
23 it from area photos. 23 Q. Okay.
24 Q. You would agree with me that, after the 24 A. And so when the water gets too high, no more
25 construction of the MRGO, in the late fifties, that 25 young cypress come. And so you have happily growing

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1 mature trees, but there's no regeneration. 1 rise?
2 Q. Okay. 2 A. Sea level. Nutria sometimes eat it up. You
3 A. You know, as sea level rising, it's a very 3 can get, not -- get no nutrients perhaps. When waves
4 slow phenomenon, because some seeds will be a little 4 come in, sometimes they bring nutrients from the bottom
5 bit higher and will be able to grow. But eventually 5 of the lake or bay. Lack of sediments. Again, there's
6 you get to where there's no regeneration. 6 a whole bunch of things, and they all add up.
7 Q. Okay. So if I understand it, it would 7 Q. Okay. Let me describe to you a phenomenon
8 probably more be a factor of rate of change; and if the 8 which I believe relates to facts, a factual
9 rate of change is slow enough so that the little 9 circumstance given to me by a fisherman. And maybe
10 cypress, the sapling can keep its head out of the 10 you've experienced the same thing; I don't know.
11 water -- 11 He tells me that when he fishes along the
12 MS. MILLER: Same objection. 12 MRGO, or used to fish along the MRGO, in shallow water,
13 THE WITNESS: Well, you have a dry area, 13 meaning along the banks, that he would put his anchor
14 other than cypress pop up. 14 out and they would fish in the shallow water. And this
15 BY MR. LAMBERT 15 is where he bumped into the cypress swamp or stumps
16 Q. -- or a dry year, then as long as it can 16 situation. He had to know where they were to get in
17 germinate to the point where it gets high enough so 17 there.
18 that it can handle the delta, the change in water 18 A. Yep.
19 height -- 19 Q. And he said that when they would see a large
20 A. Yes. 20 ship coming, they would have to pull up the anchor
21 Q. -- then it's going to be all right? 21 right quick and scoot out into the deeper water
22 MS. MILLER: Objection. 22 because, as the ship approached, the following
23 THE WITNESS: Yes. 23 occurred: First of all there was a downward motion of
24 BY MR. LAMBERT 24 the water. In other words, I think it's called
25 Q. All right. What about the brackish marsh? 25 "downdraft" or down-something-or-other.
Page 43 Page 45
1 MS. MILLER: Objection. 1 A. Uh-huh.
2 BY MR. LAMBERT 2 Q. Depends, of course, on the size of the ship
3 Q. How does that handle sea level rise? 3 and the weight and so on. But he said, if it's a big
4 MS. MILLER: Same objection. 4 ship and it's coming pretty quick, it would be two or
5 THE WITNESS: Fairly well. I mean, when you 5 more feet of downward water motion. And then the next
6 talk about why the marshes are disappearing, 6 thing that would happen would be a 6-foot wave would
7 there's many, many reasons. One of them is 7 come from the ship wake and wash into the, over the --
8 sea level; you know, part of the problem is 8 over the berm and into the swamp. And then that wave
9 sea level rise. So it's just marsh can 9 would come back into the MRGO. And he said that after
10 handle a certain amount of flooding and 10 that first one, then there would be a few others from
11 handle it fairly well. 11 the wake that did the same thing, and that you could
12 MR. LAMBERT: Okay. 12 see the sediment coming from the brackish swamp area
13 MS. MILLER: I'd just like to make a 13 into the canal.
14 continuing objection to the line of 14 Have you seen that phenomenon?
15 questioning asking her for expert opinions in 15 MS. MILLER: Objection. Foundation,
16 this area. 16 incomplete.
17 MR. LAMBERT: Dandy. 17 THE WITNESS: To tell the truth, yes.
18 MS. MILLER: She is being produced as a fact 18 BY MR. LAMBERT
19 witness here. 19 Q. And of course the Corps spent 10 to 14 or 15
20 MR. LAMBERT: I understand. 20 million dollars a year dredging the channel, and other
21 MS. MILLER: All right. 21 witnesses have told us that part of that sediment that
22 MR. LAMBERT: I'm learning. Okay. 22 they would have to continually dredge from the MRGO
23 BY MR. LAMBERT 23 probably came from that process.
24 Q. So now I understand. What is it that 24 Would that sort of phenomena have a negative
25 affects, negatively affects a marsh, if not sea level 25 effect on the health of the brackish swamp?

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1 MS. MILLER: Objection, vague. Calls for 1 and again, we're doing a level salinity. We're not
2 speculation. 2 going to introduce salinity into the question right
3 THE WITNESS: Not my area of expertise. 3 now.
4 Other than someone that's seen it, yes, it 4 A. Uh-huh.
5 would. 5 Q. -- if there is subsidence?
6 And, by the way, there is no brackish 6 MS. MILLER: Objection.
7 swamp. 7 THE WITNESS: It depends how bad.
8 BY MR. LAMBERT 8 BY MR. LAMBERT
9 Q. Excuse me. 9 Q. Well, exactly. As long as it's a moderate or
10 A. You are untrainable. 10 a minimal subsidence on a rate basis?
11 Q. I'm sorry. Brackish marsh, I'm sorry. 11 MS. MILLER: Objection. Vague, calls for
12 Correct. 12 speculation.
13 Let me tell you how bad this guy said it was. 13 THE WITNESS: I don't know. Too much
14 He said a friend of his didn't move his anchor and he 14 subsidence and it becomes open water, but I
15 was sitting in his boat, and the downdraft came and the 15 don't know how much too much is.
16 boat was beached. 16 BY MR. LAMBERT
17 A. Yes. 17 Q. Okay. It's not your area of expertise for
18 Q. Now he can't move. He said the next thing he 18 what effect a cypress-tupelo swamp will have with
19 sees is a 6-foot wave breaking, which then broke into 19 regard to wind? No.
20 the boat. He said he learned his lesson. 20 A. I would assume they stop winds.
21 A. I can believe it. 21 Q. Right.
22 Q. The hard way, right. 22 A. But so does a marsh to a degree, so ...
23 MS. MILLER: Just object to the stories about 23 Q. Okay. I see. I understand.
24 the unidentified witness. 24 A healthy cypress swamp is able to withstand
25 MR. LAMBERT: I agree with you. It can be 25 wind in terms of a tree being blown down. Correct?
Page 47 Page 49
1 stricken. 1 MS. MILLER: Objection.
2 THE WITNESS: He didn't say that. 2 THE WITNESS: Well, Katrina took a few down.
3 BY MR. LAMBERT 3 So ...
4 Q. Right. 4 BY MR. LAMBERT
5 This outline, Exhibit 2, of your experience 5 Q. Right. But not all of them?
6 mentions your activities, not only with regard to the 6 A. No. I don't know.
7 wetlands themselves, but also the wetlands as a 7 MS. MILLER: Objection.
8 habitat. 8 BY MR. LAMBERT
9 And, by the way, I'm sorry about your loss, 9 Q. Okay. All right.
10 your husband. 10 A. I haven't been out in the swamp much since
11 A. Thank you. 11 Katrina.
12 Q. I saw something about turtle takings. Is 12 Q. A healthy cypress swamp has the
13 that something that happens with dredging sometimes? 13 characteristics of being able to withstand wind; I
14 MS. MILLER: Objection. 14 mean, up to a degree obviously?
15 THE WITNESS: That isn't my area of expertise 15 MS. MILLER: Objection, vague.
16 at all, but yes. 16 THE WITNESS: Yes, I mean, you can withstand
17 MR. LAMBERT: Okay. 17 wind up to a degree and then it blows over.
18 MS. MILLER: Would you like to take a minute 18 BY MR. LAMBERT
19 to read this? 19 Q. That's right. And the fact that they exist
20 THE WITNESS: I read fast. 20 for a long period of time through various weather
21 MS. MILLER: Okay. 21 conditions is a testament to their ability to withstand
22 THE WITNESS: Yes. 22 whatever they withstood in that timeframe. Correct?
23 BY MR. LAMBERT 23 MS. MILLER: Objection, vague, speculative.
24 Q. Now, in terms of wetland, particularly 24 THE WITNESS: Probably.
25 brackish marsh, can brackish marsh remain healthy -- 25 BY MR. LAMBERT

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1 Q. All right. Let me just look through my notes 1 REPORTER'S CERTIFICATE
2 here for a second. 2
3 With the exception of asking you where I can 3 I, Estella O. Champion, a Certified Court
4 find -- because I've got to look for some of this 4 Reporter (Certificate # 76003) in good standing with
5 historical stuff that you've told me about, these maps? 5 the State of Louisiana, as the officer before whom this
6 A. They are in my report. 6 testimony was taken, do hereby certify that SUZANNE
7 Q. Okay. 7 HAWES, after having been duly sworn by me upon
8 A. They are not very good copies, but they are 8 authority of R.S. 37:2554, did testify as hereinbefore
9 in the report. 9 set forth in the foregoing 51 pages; that this
10 Q. Okay. Let me ask you if you could do this 10 testimony was reported by me in the stenotype reporting
11 for us: If you would provide to your counsel a copy of 11 method; and transcribed thereafter by me on computer or
12 your report, because the ones I've got have been 12 under my personal direction and supervision, and that
13 scanned and Xeroxed and e-mailed and every other thing. 13 same is a true and correct transcript to the best of my
14 A. Mine has, too. 14 ability and understanding; that I am not of Counsel,
15 Q. Well, it's probably to -- 15 nor related to counsel or the parties hereto, and in no
16 A. Now I think it's on the Web somewhere in a 16 way interested in the outcome of this event.
17 fairly decent form. 17 MAY 2, 2008
18 Q. Okay. 18
19 A. I would have to make a phone call. 19
20 Q. Okay. Could you get me that? 20 ______________________________
21 A. Yes, I will. 21 ESTELLA O. CHAMPION, RDR-CRR
22 Q. However. 22 ***
23 A. I will give it to her. 23
24 Q. The link. Give it to her and she will give 24
25 it to me. 25
Page 51
1 A. All right.
2 MR. LAMBERT: Let's go off the record a
3 minute. I'm going to talk to my colleagues,
4 I think we're finished.
5 THE WITNESS: Okay.
6 THE VIDEOGRAPHER: Off the record, it is
7 10:15.
8 (Brief recess.)
9 MR. LAMBERT: Mrs. Hawes, thank you very much
10 for your patience with us, and I don't have
11 any further questions.
12 THE WITNESS: Okay.
13 MR. LAMBERT: Thank you.
14 Anybody have a question?
15 MS. SULLIVAN: No.
16 THE VIDEOGRAPHER: That concludes this
17 deposition at 10:16.
18 (Reporter's Note. Logged in through
19 IDEP are Eric Goldberg, William Gardner
20 and Brian Ryckmen.)
21 ***
22
23
24
25

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