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KEITH O'CAIN4/22/2008JOHNS PENDLETON COURT REPORTERS800 562-1285Page 1UNITED STATES DISTRICT COURTEASTERN DISTRICT OF LOUISIANAIN RE: KATRINA CANAL BREACHES CIVIL ACTIONCONSOLIDATED LITIGATION NO. 05-4182 K2JUDGE DUVALPERTAINS TO MAG. WILKINSON(Robinson, No. 06-2268)Deposition of KEITH O'CAIN, given atthe U.S. Army Corps of Engineers New OrleansDistrict offices, 7400 Leake Avenue, NewOrleans, Louisiana 70118-3651, on April 22nd,2008.REPORTED BY:JOSEPH A. FAIRBANKS, JR., CCR, RPRCERTIFIED COURT REPORTER #75005
 
KEITH O'CAIN4/22/2008JOHNS PENDLETON COURT REPORTERS800 562-12852 (Pages 2 to 5)
Page 21
APPEARANCES:
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REPRESENTING THE PLAINTIFFS:
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LAMBERT AND NELSON
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(BY: HUGH P. LAMBERT, ESQUIRE)
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701 Magazine Street
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New Orleans, Louisiana 70130
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504-581-1750
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- and -
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BRUNO & BRUNO
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(BY: FLORIAN BUCHLER, ESQUIRE)
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855 Baronne Street
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New Orleans, Louisiana 70113
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504-525-1335
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- and -
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SHER, GARNER, CAHILL, RICHTER, KLEIN &
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HILBERT, L.L.C.
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(BY: R. SCOTT HOGAN, ESQUIRE)
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909 Poydras Street, 28th Floor
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New Orleans, Louisiana 70112
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504-299-2100
2122232425Page 3
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- and -
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WIEDEMANN & WIEDEMANN
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(BY: KARL WIEDEMANN, ESQUIRE)
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821 Baronne Street
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New Orleans, Louisiana 70113
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504-581-6180
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REPRESENTING THE UNITED STATES OF AMERICA:
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UNITED STATES DEPARTMENT OF JUSTICE,
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TORTS BRANCH, CIVIL DIVISION
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(BY: SARA SOJA, ESQUIRE)
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(BY: PAUL LEVINE, ESQUIRE)
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P.O. Box 888
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Benjamin Franklin Station
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Washington, D.C. 20044
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202-616-4289
1718
REPRESENTING THE U.S. ARMY CORPS OF ENGINEERS.
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CORPS OF ENGINEERS, OFFICE OF COUNSEL
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(BY: NICK MARZONI, ESQUIRE)
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7400 Leake Avenue
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New Orleans, Louisiana 70118-3651
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504-862-2843
2425
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ALSO PRESENT:
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KEA SHERMAN, ESQ.
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JOSEPH E. BEARDEN, III, ESQ.
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THOMAS P. ANZELMO, ESQ.
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CHRISTOPHER THATCH, ESQ. (VIA I-DEP)
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KIRK AURANDT, ESQ. (VIA I-DEP)
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ADAM CHUD, ESQ. (VIA I-DEP)
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VIDEOGRAPHER:
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GILLEY DELORIMIER (DEPO-VUE)
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E X A M I N A T I O N I N D E X
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EXAMINATION BY: PAGE
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KEITH O'CAIN4/22/2008JOHNS PENDLETON COURT REPORTERS800 562-12853 (Pages 6 to 9)
Page 6
1
S T I P U L A T I O N
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IT IS STIPULATED AND AGREED by and
3
among counsel for the parties hereto that the
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deposition of the aforementioned witness may be
5
taken for all purposes permitted within the
6
Federal Rules of Civil Procedure, in accordance
7
with law, pursuant to notice;
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That all formalities, save reading
9
and signing of the original transcript by the
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deponent, are hereby specifically waived;
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That all objections, save those as to
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the form of the question and the responsiveness
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of the answer, are reserved until such time as
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this deposition, or any part thereof, is used
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or sought to be used in evidence.
161718
* * *
19202122
JOSEPH A. FAIRBANKS, JR., CCR, RPR,
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Certified Court Reporter in and for the State
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of Louisiana, officiated in administering the
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oath to the witness.
Page 7
1
KEITH O'CAIN
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43 Oak Alley Boulevard, Marrero, Louisiana
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70072, a witness named in the above
4
stipulation, having been first duly sworn, was
5
examined and testified on his oath as follows:
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MS. SOJA:
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Under the Federal Rules, yes.
8
MR. LAMBERT:
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And that rule includes reserving
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objections except to the form of the
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question until the time when the
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testimony is used.
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MS. SOJA:
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Correct.
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MR. LAMBERT:
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Good. Just wanted to make sure
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we were reading the same rule.
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EXAMINATION BY MR. LAMBERT:
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Q. Mr. O'Cain, my name is Hugh Lambert
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and I represent plaintiffs in this matter.
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I've reviewed two depositions that you've given
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in Katrina, one I think you were questioned by
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Mr. O'Donnell and another one by Mr. Wiles --
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steven Wiles.
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A. Yes, sir.
Page 8
1
Q. And I'm going to try not to dredge up
2
too much of that information over again.
3
A. Okay.
4
Q. I will, however -- I'm going to ask 
5
you sort of summary questions so I can get that
6
testimony a bit clearer in my own mind.
7
A. Okay.
8
Q. But I don't intend to trudge through
9
all that. All right?
10
A. Thank you.
11
Q. Good. So the record is clear, would
12
you given your full name and your current
13
address?
14
A. Home address.
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Q. Uh-huh.
16
A. Yes, sir, it's Keith O'Cain, 43 Oak 
17
Alley Boulevard, Marrero, Louisiana 70072.
18
Q. Okay. What's your current position,
19
Mr. O'Cain?
20
A. I'm currently a supervisory engineer
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in civil branch of the engineering division.
22
Q. Now, that's with the Corps of 
23
Engineers.
24
A. Yes, sir.
25
Q. Okay. Put me in a box; in other
Page 9
1
words, tell me, are you with the engineering
2
department or the operations department?
3
A. Engineering division.
4
Q. Engineering. Okay. Now, it seems to
5
me like you've testified about shore protection
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and your role in terms of engineering in shore
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protection.
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A. Yes, sir.
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Q. Is that still your bailiwick or are
10
you doing something else?
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A. Partially. Um -- mainly we're
12
involved in dredging of navigation channels.
13
But there is some shoreline protection work 
14
involved.
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Q. What involvement did you have with the
16
dredging of the MRGO -- maintenance dredging of 
17
the MRGO before Katrina?
18
A. I'm, like I said, supervisory engineer
19
in the civil branch of engineering. My unit is
20
responsible for the preparation of unit price
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contracts for maintenance dredging of all the
22
navigation channels, including MRGO.
23
Q. Okay. Now, you have a template that
24
you give out to the people that bid as far as
25
the profile that you're looking for post
of 00

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