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KTR00095

KTR00095

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Published by: KatrinaDocs on Apr 17, 2009
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SUZANNE HAWES4/17/2008JOHNS PENDLETON COURT REPORTERS800 562-1285UNITED STATES DISTRICT COURTEASTERN DISTRICT OF LOUISIANAIN RE: KATRINA CANAL BREACHES CIVIL ACTIONCONSOLIDATED LITIGATIONNO. 05-4182 "K" (2)PERTAINS TO MRGO (Robinson) JUDGE DUVAL(No. 06-2268) MAG. WILKINSON-------------------------------------------------------TRANSCRIPT OF THE VIDEOTAPE DEPOSITION OFSUZANNE HAWESGiven at the U.S. Army Corps of Engineers,New Orleans District Office, 7400 Leake Avenue, NewOrleans, Louisiana 70118-3651, on April 17, 2008,commencing at 9:00 a.m.Reported By:Estella O. Champion, CRR, CCRCertified Court Reporter (Certificate #76003)
 
SUZANNE HAWES4/17/2008JOHNS PENDLETON COURT REPORTERS800 562-12852 (Pages 2 to 5)
Page 2
1
APPEARANCES
2
FOR PLAINTIFFS:
3
LAMBERT & NELSON, A LAW CORPORATION(BY: HUGH LAMBERT, ESQ.)
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631 ST. CHARLES AVENUENEW ORLEANS, LOUISIANA 70130
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-AND-BRUNO & BRUNO
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(BY: FLORIAN BUCHLER, ESQUIRE)855 BARONNE STREET
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NEW ORLEANS, LOUISIANA 70113-AND-
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SHER, GARNER, CAHILL, RICHTER, KLEIN &HILBERT, LLC
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(BY: R. SCOTT HOGAN, ESQUIRE)909 POYDRAS STREET, 28TH FLOOR
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NEW ORLEANS, LOUISIANA 70112-1033
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FOR THE ARMY CORPS OF ENGINEERS:
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CORPS OF ENGINEERS, OFFICE OF COUNSEL:(BY: RITA TROTTER, ESQUIRE)
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7400 LEAKE AVENUENEW ORLEANS, LOUISIANA 70118-3651
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FOR THE DEFENDANT UNITED STATES OF AMERICA:
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U.S. DEPARTMENT OF JUSTICE
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TORTS BRANCH, CIVIL DIVISION(BY: JESSICA SULLIVAN, ESQUIRE)
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(BY: MICHELE GREIF, ESQUIRE)(BY: KARA MILLER, ESQUIRE)
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P.O. BOX 888BENJAMIN FRANKLIN STATION
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WASHINGTON, D.C. 20044
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ALSO PRESENT:
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RYAN MALONE, ESQUIREANDRE LAGARDE
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KEA SHERMANERIC GOLDBERG (Via I-DEP)
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WILLIAM GARDNER (Via I-DEP)BRIAN RYCKMEN (Via I-DEP)
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VIDEOGRAPHER:
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GILLEY DELORIMIER (DEPO-VUE)
Page 3
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INDEX PAGE
2
TESTIMONY OF SUZANNE HAWES
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DIRECT EXAMINATION BY MR.LAMBERT ........... 5
4
* * *
5
INDEX OF EXHIBITS
6
EXHIBIT PAGE
7
Plaintiffs # 1 Curriculum Vitae ..................9
8
Plaintiffs # 2 Background of Mrs. Hawes .........19
910111213141516171819202122232425
Page 4
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THE VIDEOGRAPHER: One moment please.
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This is the videotape deposition of 
3
Suzanne Hawes. This deposition is being held
4
today at 7400 Leake Avenue in New Orleans,
5
Louisiana on April 17, 2008. The time is
6
9:07 a.m.
7
Would counsel present please now
8
introduce themselves and which party they
9
represent.
10
MS. MILLER: My name is Kara Miller for the
11
United States.
12
MS. SULLIVAN: Jessica Sullivan for the
13
United States.
14
MS. GREIF: Michele Greif for the United
15
States.
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MS. TROTTER: Lanie Trotter for the Corps.
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MR. MALONE: Ryan Malone, EJLD AND LBLD, also
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present.
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MS. SHERMAN: Kea Sherman, Jefferson Parish.
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MR. LAGARDE: Andre Lagarde for the Orleans
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Levee District.
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MR. BUCHLER: Florien Buchler for the
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plaintiffs.
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MR. LAMBERT: My name is Hugh Lambert and I
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represent the plaintiffs.
Page 5
1
MR. HOGAN: Scott Hogan for the plaintiffs.
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MR. LAMBERT: All right. Would you swear in
3
the witness, please.
4
WHEREUPON, SUZANNE HAWES, having been
5
duly sworn, testified as follows:
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DIRECT EXAMINATION
7
BY MR. LAMBERT:
8
Q. Mrs. Hawes, my name is Hugh Lambert and I
9
represent plaintiffs in connection with a lawsuit
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brought involving the flooding in connection with the
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MRGO. Do you understand that?
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A. Uh-huh.
13
Q. Okay. And your name has appeared on a
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witness list, and therefore you are here so I can find
15
out what it is that you're likely that you're to
16
testify about. All right?
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A. All right.
18
Q. Have you given a deposition before, ma'am?
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A. Yes.
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Q. Okay. So you're familiar with the process?
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A. Yes. Before we start, I have a unique health
22
problem.
23
Q. Okay.
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A. I had throat cancer. They radiated my mouth
25
and my salivary glands died. About three months ago
 
SUZANNE HAWES4/17/2008JOHNS PENDLETON COURT REPORTERS800 562-12853 (Pages 6 to 9)
Page 6
1
they came back, which is good news. The bad news is
2
they secrete mucous, so I have to wipe my mouth out
3
regularly. So please bear with me. It's rather gross.
4
Q. Well, you know, I'll share with you,
5
Mrs. Hawes, that a few years ago for no good reason I
6
had a broken jaw, and my mouth was wired shut for about
7
eight weeks.
8
A. Yes. Yes.
9
Q. And so I walked around like this with my
10
teeth completely wired together.
11
A. Yes.
12
Q. And I could only drink things. And by the
13
time my session ended, I had gotten pretty comfortable,
14
so I did things that were sort of foolish. For
15
example, I stopped at a McDonalds, got a chocolate
16
shake and a cheeseburger, threw them in the blender,
17
ground them up and tried to drink it. My kids thought
18
it was entertaining, but it really did plug up all of 
19
the -- yes, it was bad.
20
A. Yes. I did that.
21
Q. Yes, I understand that.
22
A. I've been there.
23
Q. So I share your sympathy. Or I sympathize
24
with your situation, though mine was short lived.
25
A. Yes.
Page 71
Q. We're going to be brief today.
2
A. Good.
3
Q. I'm going to try and find out what it is that
4
the U.S. Government finds it necessary to put you on a
5
witness list for. And when I have finished doing that,
6
we're going to quit. Okay?
7
A. Okay.
8
Q. Good.
9
Now, first of all, I see your counsel has
10
provided me with a curriculum vitae, which shows that
11
you were educated at a number of universities,
12
Stanford, Brown, botany at Brown University, and you
13
also attended UNO.
14
A. Uh-huh.
15
Q. And when I flipped through the publications,
16
I see that you coauthored with two gentlemen; one is
17
named Day, John W. Day, and another Gary Shaffer. Do
18
you remember that?
19
A. Uh-huh. Yes.
20
Q. And was that good?
21
A. Yes.
22
Q. How are those guys?
23
MS. MILLER: Objection.
24
THE WITNESS: They are my friends.
25
BY MR. LAMBERT:
Page 8
1
Q. Okay. Do you respect them --
2
A. Yes.
3
Q. -- from a professional standpoint?
4
A. Yes.
5
Q. All right. Do you believe that they are
6
truthful and straightforward people?
7
MS. MILLER: Objection.
8
MR. LAMBERT: How could you possibly object
9
to that question?
10
THE WITNESS: I sometimes disagreed with
11
them.
12
BY MR. LAMBERT:
13
Q. Okay. But you believe they are truthful in
14
terms of their opinions?
15
MS. MILLER: Objection.
16
THE WITNESS: They believed their opinions
17
but most people believe their opinions.
18
BY MR. LAMBERT:
19
Q. I understand. I have no problem with people
20
that believe their opinions. I have a problem with
21
people that give opinions that are not supported.
22
A. Yes.
23
Q. Okay. And your belief is that these
24
gentlemen are credible; let's put it that way.
25
MS. MILLER: Objection.
Page 9
1
THE WITNESS: I will answer you: Yes, I do.
2
BY MR. LAMBERT:
3
Q. Okay, good. All right.
4
Now I'm going to ask you: Have you reviewed
5
your curriculum vitae?
6
A. Yes.
7
Q. And is it accurate?
8
A. Yes.
9
Q. We're going to attach it to the deposition so
10
we don't have to spend a lot of time with that.
11
A. Yes.
12
Q. Now, what is it -- what is it Mrs. Hawes that
13
you believe the government intends to call you for as a
14
witness? What is it that you believe that you're going
15
to be asked to testify about?
16
A. Frankly, I'm not sure.
17
Q. Okay.
18
A. I think maybe about the part I wrote about
19
the effects of MRGO.
20
Q. Okay.
21
A. That's -- I don't know.
22
Q. And do I have that report?
23
A. I don't know.
24
Q. Tell me about the report. When was it
25
written?

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