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KTR00071

KTR00071

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Published by: KatrinaDocs on Apr 17, 2009
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POLLY BOUDREAUX3/5/2008JOHNS, PENDLETON & ASSOCIATES800 562-1285
Page 1UNITED STATES DISTRICT COURTEASTERN DISTRICT OF LOUISIANA
IN RE:
KATRINA CANAL BREACHES CIVIL ACTIONCONSOLIDATED LITIGATIONNO. 06-2268"K" (2)
PERTAINS TO:
ROBINSON JUDGE DUVALMAG. WILKINSONVIDEOTAPED DEPOSITION OFPOLLY CAMPBELL BOUDREAUX,4212 Florida Avenue, Meraux, Louisiana 70075,taken in the offices of Andry Law Firm, 610Baronne Street, New Orleans, Louisiana 70113,on Wednesday, March 5, 2008.
 
POLLY BOUDREAUX3/5/2008JOHNS, PENDLETON & ASSOCIATES800 562-1285
2 (Pages 2 to 5)
Page 2
1
 APPEARANCES:
234
ANDRY LAW FIRM
5
(BY: JONATHAN B. ANDRY, ESQ.)
6
610 Baronne Street
7
New Orleans, Louisiana 70113
8
ATTORNEY FOR THE PLAINTIFFS
91011
ELWOOD STEVENS LAW OFFICE
12
(BY: ELWOOD C. STEVENS, JR., ESQ.)
13
1205 Victor II Boulevard
14
Morgan City, Louisiana 70380
15
ATTORNEY FOR THE PLAINTIFFS
16
(NOT PRESENT)
171819
STONE PIGMAN WALTHER WITTMANN
20
(BY: CARMELITE BERTAUT, ESQ.
21
AGNIESZKA MCPEAK ESQ.)
22
546 Carondelet Street
23
New Orleans, Louisiana 70130-3588
24
ATTORNEYS FOR WASHINGTON GROUP
25
INTERNATIONAL, INC.
Page 3
1
 APPEARANCES CONTINUED:
23
UNITED STATES DEPARTMENT OF JUSTICE
4
(BY: KEITH LITTLE ESQ.
5
JESSICA SULLIVAN, ESQ.)
6
Post Office Box 888
7
Benjamin Franklin Station
8
Washington, D.C. 20004
9
ATTORNEY FOR UNITED STATES OF
10
AMERICA 
111213
BURGLASS & TANKERSLEY 
14
(BY: KEA SHERMAN, ESQ.)
15
5213 Airline Drive
16
Metairie, Louisiana 70001
17
ATTORNEYS FOR JEFFERSON PARISH
18192021
CHAFFE, MCCALL LLP
22
(BY: TOM FORBES, ESQ.)
23
2300 Energy Center
24
New Orleans, Louisiana 70163
25
ATTORNEYS FOR LAFARGE NORTH AMERICA 
Page 4
12
 APPEARANCES CONTINUED:
345
LABORDE & NEUNER 
6
(BY: GREG KOURY, ESQ.)
7
One Petroleum Center
8
1001 West Pinhook Road
9
Suite 200
10
Lafayette, Louisiana 70505-2828
11
ATTORNEYS FOR ORLEANS LEVEE DISTRICT
121314
 ALSO APPEARING AS ALSO PRESENT:
15
JOSEPH E. BENDER, ESQ. (LBLD)
1617181920
REPORTED BY:
ROGER D. JOHNS, RMR, CRR, CSR 
21
Certified Court Reporter,
22
State of Louisiana
232425
Page 5
1
S T I P U L A T I O N
23
It is stipulated and agreed by and between
4
counsel for the parties hereto
5
that the deposition of the aforementioned
6
witness is hereby being taken under the
7
Federal Rules of Civil Procedure, for all
8
purposes, in accordance with law;
9
That the formalities of reading and
10
signing are specifically not waived;
11
That the formalities of certification and
12
filing are specifically waived;
13
That all objections, save those as to the
14
form of the question and the responsiveness of 
15
the answer, are hereby reserved until such
16
time as this deposition, or any part thereof,
17
may be used or sought to be used in evidence.
1819
* * * *
2021
ROGER D. JOHNS, RDR, CRR, Certified Court
22
Reporter for the State of Louisiana,
23
officiated in administering the oath to the
24
witness.
25
 
POLLY BOUDREAUX3/5/2008JOHNS, PENDLETON & ASSOCIATES800 562-1285
3 (Pages 6 to 9)
Page 6
1
I N D E X
23
PAGE
4
Exhibit 1.................................. 61
5
Exhibit Number 2........................... 78
6
Exhibit 3.................................. 81
7
Exhibit 4.................................. 89
8
Exhibit 5.................................. 91
9
Exhibit Number 7.......................... 115
10
6......................................... 115
11121314151617
EXAMINATION BY BY MR. ANDRY:................ 7
18
EXAMINATION BY MR. LITTLE:................ 105
19
EXAMINATION BY MR. FORBES:................ 116
20
EXAMINATION BY MS. MCPEAK:................ 139
21
EXAMINATION BY MR. FORBES:................ 156
22232425
Page 7
1
VIDEO OPERATOR:
2
We're now on the record. It is
3
3:19, March 5th, 2008. Would the
4
Court Reporter now please swear in the
5
witness.
6
POLLY CAMPBELL BOUDREAUX,
7
4212 Florida Avenue, Meraux, Louisiana 70075,
8
after being duly sworn, did testify as
9
follows:
10
EXAMINATION BY MR. ANDRY:
11
Q. Mrs. Boudreaux, thanks for coming
12
down to give your deposition. I'm Jonathan
13
 Andry and, as you know, I represent Norman
14
Robinson and the Plaintiffs in the case of 
15
Norman Robinson versus the United States,
16
which deals with -- it's a Federal tort claim
17
against the government for negligence
18
associated with the Mississippi River Gulf 
19
Outlet.
20
Have you ever been deposed
21
before?
22
A. Yes.
23
Q. So you understand that in a
24
deposition I'll ask you the questions, I am
25
not trying to trick you or anything, --
Page 8
1
A. Uh-huh (affirmatively).
2
Q. -- I am just trying to get
3
information. I'll ask you the question and
4
then you respond with a verbal answer or a
5
verbal response so that the Court Reporter can
6
take that down.
7
A. Yes.
8
Q. And that you're also being
9
videotaped.
10
A. Okay.
11
Q. And I think beamed on the Internet,
12
too.
13
A. Okay.
14
Q. But nonetheless, you just have to
15
give a verbal response and if you don't
16
understand the question, please ask me and I
17
will repeat it.
18
A. Okay.
19
Q. But if you answer, I will interpret
20
that that you understood the question and
21
answered it to the best of your ability.
22
A. Okay.
23
Q. Could you please provide us your
24
educational background?
25
A. I hold a Master's degree in
Page 9
1
education administration from UNO;
2
undergraduate degree from Louisiana College,
3
Bachelor of Arts in French and biology.
4
Q. And when did you receive your
5
Master's degree from UNO?
6
A. 1997. Actually, 1994. I need to
7
say it right. The year my daughter was born.
8
Exactly a month after she was born.
9
Q. Where are you from originally?
10
A. Born in Denver, Colorado, but moved
11
very soon to Belle Chasse. Lived 12 years in
12
Belle Chasse and then my father took a
13
position overseas and we spent time in Saudi
14
 Arabia and then in Brussels, Belgium, and then
15
came back here to go to college; and from
16
college went straight to work in St. Bernard
17
Parish right out of college.
18
Q. So would it be fair to say that you
19
worked in St. Bernard Parish from
20
approximately '94 to 1997 -- I mean '94
21
through today? Excuse me.
22
A. Actually from 1984. I graduated in
23
1983 with my Bachelor's degree, so I began
24
working right after that.
25
Q. And where did you work after that?

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