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Published by: KatrinaDocs on Apr 17, 2009
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Page 11 UNITED STATES DISTRICT COURT. EASTERN DISTRICT OF LOUISIANA234 IN RE: KATRINA CANAL CIVIL ACTION. BREACHES CONSOLIDATED5 LITIGATION NO. 05-4182 "K" (2)6 JUDGE DUVAL. PERTAINS TO: LEVEE7 MAG. WILKINSON8 FILED IN:9 05-4181, 05-4182, 05-4191,. 05-4568, 05-5237, 05-6073,10 05-6314, 05-6324, 05-6327,. 05-6359, 06-0020, 06-1885,11 06-0225, 06-0886, 06-11208,. 06-2278, 06-2287, 06-2346,12 06-2545, 06-3529, 06-4065,. 06-4389, 06-4634, 06-4931,13 06-5032, 06-5042, 06-5159,. 06-5163, 06-5367, 06-5471,14 06-5771, 06-5786, 06-5937,. 06-7682, 07-0206, 07-0647,15 07-0993, 07-1284, 07-1286,. 07-1288, 07-1289161718. Deposition of CHAD A. MORRIS, 545 Shady19 Lake Parkway, Baton Rouge, Louisiana 70810,. taken in the offices of Bruno & Bruno, 85520 Baronne St., Third Floor, New Orleans,. Louisiana on Thursday, the 23rd day of21 August, 2007 at 8:43 a.m.22232425Page 2123 APPEARANCES:4567 LAMBERT & NELSON. (By: Hugh P. Lambert, Esquire)8 701 Magazine St.. New Orleans, Louisiana 701309 (504) 581-1750. Attorneys for Plaintiffs10111213 SUTTON LAW FIRM, LLC. (By: Charles E. Sutton, Jr., Esquire)14 2101 N. Hwy. 190. Suite 10515 Covington, Louisiana 70433. (985) 249-599116 Attorneys for Defendant,. Orleans Levee District171819. LABORDE & NEUNER20 (By: Ben L. Mayeaux, Esquire). One Petroleum Center, Suite 20021 1001 West Pinhook Road. Lafayette, Louisiana 7050322 (337) 237-7000. Attorneys for Defendant,23 Orleans Levee District2425Page 312 APPEARANCES (continued):34. DUPLASS, ZWAIN, BOURGEOIS, MORTON,5 PFISTER & WEINSTOCK. (By: Gary M. Zwain, Esquire)6 3838 N. Causeway Blvd., Suite 2900. Metairie, Louisiana 700027 (504) 832-3700. Attorneys for Defendant,8 Board of Commissioners for the. East Jefferson Levee District9 and Lake Borgne Levee District10111213 CHRISTOVICH & KEARNEY. (By: Elizabeth Cordes, Esquire)14 Pan American Life Center. 601 Poydras St.15 New Orleans, Louisiana 70130-6078. (504) 593-427216 Attorneys for Defendant,. Sewerage and Water Board of New17 Orleans181920. BURGLASS & TANKERSLEY, L.L.C.21 (By: Monica Waldron, Esquire). 5213 Airline Drive22 Metairie, Louisiana 70001. (504) 836-222023 Attorneys for Defendant,. Parish of Jefferson2425Page 412 APPEARANCES (continued):345 JONES DAY. (By: Amy Payne, Esquire)6 2727 North Harwood Street. Dallas, Texas 75201-15157 (214) 220-3939. Attorneys for Washington Group8 International, Inc.9101112 LEAKE & ANDERSSON, L.L.P.. (By: Marc Devenport, Esquire)13 Suite 1700. 1100 Poydras St.14 New Orleans, Louisiana 70163-1701. (504) 585-750015 Attorneys for National Union. Insurance Company16171819 ALSO PRESENT:2021. MAPLES & KIRWAN22 (By: Todd Campbell, Esquire). 902 Julia St.23 New Orleans, Louisiana 70113. (504) 569-87322425
Chad Morris on date 08/23/2007Printed on 1/6/2009 6:05:33 PMPage 1
Page 512 ALSO PRESENT (continued):345. John Wadsworth, CLVS6 Hart Video of Louisiana, L.L.C.. (866) 649-4278789101112 REPORTED BY:13 MARGARET MCKENZIE, CCR, RPR, CMR, CRR. Certified Court Reporter141516171819202122232425Page 61 I N D E X23 EXAMINATION BY:45 MS. PAYNE.................................1067 MR. SUTTON................................778910 EXHIBITS:1112 Exhibit 1.................................161314 Exhibit 2.................................301516 Exhibit 3.................................351718 Exhibit 4.................................451920 Exhibit 5.................................592122 Exhibit 6.................................622324 Exhibit 7.................................7125Page 71 S T I P U L A T I O N2 It is stipulated and agreed by and3 between counsel for the parties hereto that4 the deposition of the aforementioned witness5 is hereby being taken under the Federal Rules6 of Civil Procedure, for all purposes, in7 accordance with law;8 That the formalities of reading and9 signing are specifically not waived;10 That the formalities of sealing,11 certification and filing are specifically12 waived;13 That all objections, save those as to14 the form of the question and the15 responsiveness of the answer, are hereby16 reserved until such time as this deposition,17 or any part thereof, may be used or sought to18 be used in evidence.1920 * * * * *2122 MARGARET MCKENZIE, Certified Court23 Reporter, in and for the Parish of Orleans,24 State of Louisiana, officiated in25 administering the oath to the witness.Page 81 CHAD A. MORRIS,2 545 Shady Lake Parkway, Baton Rouge,3 Louisiana 70810, after having been first duly4 sworn by the above-mentioned court reporter,5 did testify as follows:6 VIDEOGRAPHER:7 This is the video deposition of8 Charles Morris given at 855 Baronne9 Street in New Orleans, Louisiana.10 Today is August 23, 2007. My name11 is John Wadsworth with Hart Video,12 LLC. The court reporter is13 Margaret McKenzie with Johns14 Pendleton & Associates.15 Would the court reporter, please,16 swear in the witness.17 CHAD A. MORRIS,18 545 Shady Lake Parkway, Baton Rouge,19 Louisiana 70810, after having been first duly20 sworn by the above-mentioned court reporter,21 did testify as follows:22 MR. LAMBERT:23 For the record, my name is Hugh24 Lambert and I represent the25 plaintiffs.
Chad Morris on date 08/23/2007Printed on 1/6/2009 6:05:33 PMPage 2
Page 91 MS. PAYNE:2 Amy Payne representing defendant,3 Washington Group.4 MR. SUTTON:5 Charles Sutton for Orleans Levee6 District.7 MR. ZWAIN:8 Gary Zwain, East Jefferson Levee9 District and Lake Borgne Basin10 Levee District.11 MR. MAYEAUX:12 Ben Mayeaux, Orleans Levee13 District.14 MR. LAMBERT:15 Also present --16 MS. CORDES:17 Elizabeth Cordes, Sewerage and18 Water Board of New Orleans.19 MR. SUTTON:20 Also present is Mike Flores of21 G.C.R. & Associates.22 MR. LAMBERT:23 And Mr. Flores is an expert?24 MR. SUTTON:25 A consulting expert.Page 101 MR. LAMBERT:2 Consulting.3 And just so the record is clear,4 we're reserving objections except5 as to the form.6 MS. PAYNE:7 Okay. Thanks.8 EXAMINATION BY MS. PAYNE:9 Q. Good morning, Mr. Morris.10 A. Good morning.11 Q. We met earlier.12 A. Yes.13 Q. I represent defendant Washington14 Group, but today I'm asking questions on15 behalf of all defendants on the MRGO side of16 the litigation. How are you?17 A. I'm fine.18 Q. I understand you've been deposed19 before, but just a reminder about a couple20 things. If you don't understand one of my21 questions, let me know and I'll try to22 clarify it.23 A. Okay.24 Q. And if you want to take a break at25 any time, just let me know.Page 111 A. Okay.2 Q. Let's start off just talking a3 little bit about your background. Can you4 describe your educational background for me.5 A. I have a Bachelor of Science Degree6 in Surveying and Mapping from the University7 of Florida.8 Q. And you got that degree in 1991?9 A. Yes.10 Q. And after you received your degree11 where did you start working then?12 A. In Baton Rouge for a company called13 Hydro Consultants. We did all different14 types of surveying, mostly industrial,15 industrial surveying in plants and16 hydrographic surveying and pipeline17 surveying, topographic boundaries.18 Q. And about how many employees did19 that company have?20 A. Thirty.21 Q. And what job were you hired for,22 what was your title?23 A. Initially, I was the project24 coordinator and later operations manager.25 Q. When did you become operationsPage 121 manager?2 A. I would have to look back at the3 date. It was a -- probably shortly after I4 became registered as a professional land5 surveyor.6 Q. And why did you leave that job?7 A. For other opportunities.8 Q. Was that the LandSource, Inc.?9 A. Yes.10 Q. And tell me about that.11 A. LandSource is primarily a12 commercial firm. And I was bringing the13 industrial side to that, to that firm.14 Q. Can you explain that, bringing the15 industrial side to that --16 A. My background was in, with17 industrial clients, so my -- I essentially18 brought the ability to work for industrial19 clients.20 Q. Okay. Did you have any kind of21 ownership interest in that company?22 A. No.23 Q. Just -- you were just an employee24 of that?25 A. Yes.
Chad Morris on date 08/23/2007Printed on 1/6/2009 6:05:33 PMPage 3

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