POLLY BOUDREAUX 3/5/2008

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UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF LOUISIANA

IN RE: KATRINA CANAL BREACHES CIVIL ACTION

CONSOLIDATED LITIGATION
NO. 06-2268
"K" (2)

PERTAINS TO: ROBINSON JUDGE DUVAL

MAG. WILKINSON

VIDEOTAPED DEPOSITION OF
POLLY CAMPBELL BOUDREAUX,
4212 Florida Avenue, Meraux, Louisiana 70075,
taken in the offices of Andry Law Firm, 610
Baronne Street, New Orleans, Louisiana 70113,
on Wednesday, March 5, 2008.

JOHNS, PENDLETON & ASSOCIATES 800 562-1285

POLLY BOUDREAUX 3/5/2008

1 APPEARANCES: 1
2 2 APPEARANCES CONTINUED:
3 3
4 ANDRY LAW FIRM 4
5 (BY: JONATHAN B. ANDRY, ESQ.) 5 LABORDE & NEUNER
6 610 Baronne Street 6 (BY: GREG KOURY, ESQ.)
7 New Orleans, Louisiana 70113 7 One Petroleum Center
8 ATTORNEY FOR THE PLAINTIFFS 8 1001 West Pinhook Road
9 9 Suite 200
10 10 Lafayette, Louisiana 70505-2828
11 ELWOOD STEVENS LAW OFFICE 11 ATTORNEYS FOR ORLEANS LEVEE DISTRICT
12 (BY: ELWOOD C. STEVENS, JR., ESQ.) 12
13 1205 Victor II Boulevard 13
14 Morgan City, Louisiana 70380 14 ALSO APPEARING AS ALSO PRESENT:
15 ATTORNEY FOR THE PLAINTIFFS 15 JOSEPH E. BENDER, ESQ. (LBLD)
16 (NOT PRESENT) 16
17 17
18 18
19 STONE PIGMAN WALTHER WITTMANN 19
20 (BY: CARMELITE BERTAUT, ESQ. 20 REPORTED BY: ROGER D. JOHNS, RMR, CRR, CSR
21 AGNIESZKA MCPEAK ESQ.) 21 Certified Court Reporter,
22 546 Carondelet Street 22 State of Louisiana
23 New Orleans, Louisiana 70130-3588 23
24 ATTORNEYS FOR WASHINGTON GROUP 24
25 INTERNATIONAL, INC. 25
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1 APPEARANCES CONTINUED: 1 STIPULATION

2 2
3 UNITED STATES DEPARTMENT OF JUSTICE 3 It is stipulated and agreed by and between
4 (BY: KEITH LITTLE ESQ. 4 counsel for the parties hereto
5 JESSICA SULLIVAN, ESQ.) 5 that the deposition of the aforementioned
6 Post Office Box 888 6 witness is hereby being taken under the
7 Benjamin Franklin Station 7 Federal Rules of Civil Procedure, for all
8 Washington, D.C. 20004 8 purposes, in accordance with law;
9 ATTORNEY FOR UNITED STATES OF 9 That the formalities of reading and
10 AMERICA 10 signing are specifically not waived;
11 11 That the formalities of certification and
12 12 filing are specifically waived;
13 BURGLASS & TANKERSLEY 13 That all objections, save those as to the
14 (BY: KEA SHERMAN, ESQ.) 14 form of the question and the responsiveness of
15 5213 Airline Drive 15 the answer, are hereby reserved until such
16 Metairie, Louisiana 70001 16 time as this deposition, or any part thereof,
17 ATTORNEYS FOR JEFFERSON PARISH 17 may be used or sought to be used in evidence.
18 18
19 19 * * * *
20 20
21 CHAFFE, MCCALL LLP 21 ROGER D. JOHNS, RDR, CRR, Certified Court
22 (BY: TOM FORBES, ESQ.) 22 Reporter for the State of Louisiana,
23 2300 Energy Center 23 officiated in administering the oath to the
24 New Orleans, Louisiana 70163 24 witness.
25 ATTORNEYS FOR LAFARGE NORTH AMERICA 25
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2 (Pages 2 to 5)
JOHNS, PENDLETON & ASSOCIATES 800 562-1285
POLLY BOUDREAUX 3/5/2008

1 INDEX 1 A. Uh-huh (affirmatively).

2 2 Q. -- I am just trying to get
3 PAGE 3 information. I'll ask you the question and
4 Exhibit 1.................................. 61 4 then you respond with a verbal answer or a
5 Exhibit Number 2........................... 78 5 verbal response so that the Court Reporter can
6 Exhibit 3.................................. 81 6 take that down.
7 Exhibit 4.................................. 89 7 A. Yes.
8 Exhibit 5.................................. 91 8 Q. And that you're also being
9 Exhibit Number 7.......................... 115 9 videotaped.
10 6......................................... 115 10 A. Okay.
11 11 Q. And I think beamed on the Internet,
12 12 too.
13 13 A. Okay.
14 14 Q. But nonetheless, you just have to
15 15 give a verbal response and if you don't
16 16 understand the question, please ask me and I
17 EXAMINATION BY BY MR. ANDRY:................ 7 17 will repeat it.
18 EXAMINATION BY MR. LITTLE:................ 105 18 A. Okay.
19 EXAMINATION BY MR. FORBES:................ 116 19 Q. But if you answer, I will interpret
20 EXAMINATION BY MS. MCPEAK:................ 139 20 that that you understood the question and
21 EXAMINATION BY MR. FORBES:................ 156 21 answered it to the best of your ability.
22 22 A. Okay.
23 23 Q. Could you please provide us your
24 24 educational background?
25 25 A. I hold a Master's degree in
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1 VIDEO OPERATOR: 1 education administration from UNO;

2 We're now on the record. It is 2 undergraduate degree from Louisiana College,
3 3:19, March 5th, 2008. Would the 3 Bachelor of Arts in French and biology.
4 Court Reporter now please swear in the 4 Q. And when did you receive your
5 witness. 5 Master's degree from UNO?
6 POLLY CAMPBELL BOUDREAUX, 6 A. 1997. Actually, 1994. I need to
7 4212 Florida Avenue, Meraux, Louisiana 70075, 7 say it right. The year my daughter was born.
8 after being duly sworn, did testify as 8 Exactly a month after she was born.
9 follows: 9 Q. Where are you from originally?
10 EXAMINATION BY MR. ANDRY: 10 A. Born in Denver, Colorado, but moved
11 Q. Mrs. Boudreaux, thanks for coming 11 very soon to Belle Chasse. Lived 12 years in
12 down to give your deposition. I'm Jonathan 12 Belle Chasse and then my father took a
13 Andry and, as you know, I represent Norman 13 position overseas and we spent time in Saudi
14 Robinson and the Plaintiffs in the case of 14 Arabia and then in Brussels, Belgium, and then
15 Norman Robinson versus the United States, 15 came back here to go to college; and from
16 which deals with -- it's a Federal tort claim 16 college went straight to work in St. Bernard
17 against the government for negligence 17 Parish right out of college.
18 associated with the Mississippi River Gulf 18 Q. So would it be fair to say that you
19 Outlet. 19 worked in St. Bernard Parish from
20 Have you ever been deposed 20 approximately '94 to 1997 -- I mean '94
21 before? 21 through today? Excuse me.
22 A. Yes. 22 A. Actually from 1984. I graduated in
23 Q. So you understand that in a 23 1983 with my Bachelor's degree, so I began
24 deposition I'll ask you the questions, I am 24 working right after that.
25 not trying to trick you or anything, -- 25 Q. And where did you work after that?
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JOHNS, PENDLETON & ASSOCIATES 800 562-1285
POLLY BOUDREAUX
1 A. St. Bernard High School for 14 and a
2 half years. And then I moved to the central
3 office and worked there for six and a half.
4 Retired from the School Board office in 199-
5 -- I have to really think. In 19- -- 2003
6 and took the position as Clerk of Council and
7 was serving there at the time of Katrina and I
8 served there until just this past fall when I
9 went back into the school system to regain a
10 little of my sanity.
11 Q. And when you were Clerk of Council,
12 could you describe what that job entails?
13 A. It's a very large job. It requires
14 the management of the affairs of the seven
15 elected officials who serve St. Bernard Parish
16 as government leaders, and my position was
17 all-encompassing, from writing legislation to
18 making sure legislation was posted
19 appropriately, the correct amount of time,
20 advertised, given public hearing notices,
21 putting agendas together, coordinating daily
22 schedules, committee meetings; a very, very
23 large job.
24 Q. And you held that job from 2000 to
25 200- --
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1 A. 2003. And I am not a really good
2 number -- number person.
3 Q. Just approximate.
4 A. I can do math, but I have to go
5 backwards and try to remember. My -- My --
6 2003, we built a community playground and by
7 that fall I was courted very heavily to assume
8 the position of Clerk of Council. Myra
9 Kattengell who had been there for 12 years was
10 retiring due to medical issues and so they --
11 they came looking for me to come fill that
12 position. So I had been in right at the end
13 of 2003 as the Clerk of Council. So still
14 kind of a baby when the hurricane hit,
15 government experience-wise.
16 Q. So you were the Clerk of Council
17 from the fall of '03 --
18 A. Uh-huh (affirmatively), until just
19 this past fall, which is '07.
20 Q. Through the fall of '07?
21 A. Uh-huh (affirmatively).
22 Q. Who was the Parish President at the
23 time?
24 A. In '03 it would have been Charlie
25 Ponstein and then in '04 when I was sworn in,
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JOHNS, PENDLETON & ASSOCIATES
3/5/2008
1 so was a whole slew of new Council members and
2 Parish President, Junior Rodriguez.
3 Q. So when you were sworn in, Junior
4 was the Parish President. And then who were
5 the Councilmen?
6 A. Council members at that time sworn
7 in in '04 would have been Mark Madary, Judy
8 Hoffmeister, Kenny Henderson, Craig Tafaro,
9 Rickey Mellerine, Joey DiFatta, Lynn Dean.
10 There were seven. Five districts and then two
11 at-large positions.
12 Q. Did any of those Council members, or
13 did they serve from '03, excuse me, from '04
14 through the time of Hurricane Katrina?
15 A. Uh-huh (affirmatively). Yes, that
16 would have been the sitting Council. We were
17 all sworn in at the same time in '04.
18 Q. And as the Clerk of Council, did you
19 have any job dealings with regard to the
20 Mississippi River Gulf Outlet?
21 A. I had been through a number of
22 meetings that included discussion about the
23 Mississippi River Gulf Outlet. I had been
24 asked to pull legislation that had been
25 enacted in the years prior to my taking that
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1 position, the years since the Council form of
2 government which began in 1992, and had access
3 to a great number of files in my office that I
4 inherited by virtue of my position, quite a
5 number of very large folders full of
6 information about the MRGO and committee
7 meetings that had been held in years past. So
8 I had a working knowledge of the issues of the
9 MRGO by virtue of my position.
10 Q. And what was the working knowledge
11 that you possessed pertaining to the
12 Mississippi River Gulf Outlet by virtue of
13 your position?
14 A. My -- My understanding of it grew
15 tremendously in the time that I became Clerk
16 of Council. Prior to that, I had worked in
17 St. Bernard for all of my professional life
18 and had heard the cries against the MRGO; knew
19 several of the community activists who had
20 spoken against it. Had even had one of them
21 come speak to my biology class at St. Bernard
22 High School, but didn't really understand the
23 full impact of the -- of the body itself, the
24 body of water itself; had not actually ever
25 been in it and didn't even realize as I went
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800 562-1285
POLLY BOUDREAUX
1 over the green bridge, which is no longer
2 green, but we all still call it the green
3 bridge, that that's where it was, that that
4 was the MRGO I was going over. And know that
5 for many folks, kids even, that you heard
6 about it, but you really had no clue where it
7 was. So when I took the position, I became
8 much more aware because of all of the interest
9 and the outcries against it, and actually took
10 my first trip in the MRGO shortly after taking
11 the position of Clerk of Council. Somebody
12 felt I needed to see it if I was going to be
13 in meetings about it. I needed to understand
14 it.
15 Q. Was that Junior?
16 A. That took me in it?
17 Q. Yes.
18 A. No, actually it wasn't. It was one
19 of my playground construction guys that says,
20 "You're not going to understand any of this
21 stuff unless you see it" and took me in a boat
22 to see it, and I was in absolute awe at the
23 size of it. I don't -- Literally on our back
24 door, doorsteps, and I think most of us just
25 lived our lives completely oblivious of how
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1 close proximity it was to our homes.
2 Q. Let me go back a little bit. The
3 cries against the Mississippi River Gulf
4 Outlet you mentioned by community activists,
5 who were the community activists that cried
6 out against the Mississippi River Gulf Outlet?
7 A. The names that I remember and recall
8 very consistently were Don Duplantier, who was
9 a fellow biologist, naturalist. Pete Savoye,
10 Mr. Dan Arceneaux. Those are three, the three
11 big names that I really remember. I know Mr.
12 Rodriguez was in that number as well. Prior
13 to his position as Parish President, he had
14 been part of that cry against it.
15 Q. What were the cries against it that
16 you heard from the community activists?
17 A. They -- They seemed to always be --
18 I don't know that "grounded" is the word or
19 "based in". The fact that the MRGO had been
20 sold as a bill of goods, if you please, to the
21 parish of St. Bernard as a means of job --
22 increase in jobs for St. Bernard Parish. You
23 know, if we build this, this shortcut, we
24 build this waterway, that there will be a
25 great increase in the number of jobs that can
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JOHNS, PENDLETON & ASSOCIATES
3/5/2008
1 be provided to St. Bernard citizens, and the
2 realization in 2002, 2003, 2004 was in fact
3 that it had never provided any substantial
4 amount of jobs to the parish. That it had
5 continued to grow in size, had continued to be
6 dredged to depths that Mr. Dan Arceneaux was
7 constantly coming before the Council to speak
8 against the authorized depths. What depths
9 were actually needed and that it was a major
10 cause of erosion of land for St. Bernard
11 Parish marsh, protective marsh for the parish.
12 Q. Did you ever hear that F. Edward
13 Hebert used to say that the Gulf Outlet was
14 going to turn St. Bernard into the industrial
15 frontier of the Gulf South?
16 A. Yes. Yes. I think that that's in
17 print as well and I would assume in several of
18 the files that currently reside in the Council
19 -- Council office and Council possession.
20 I'm sure that you can find that. Yes.
21 Q. And what dealings did you have with
22 the Gulf Outlet as Clerk of Council?
23 A. I am not sure.
24 Q. As far as did you -- what matters
25 came before the Council when you were the
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1 Clerk of Council pertaining to the Gulf
2 Outlet, if any?
3 A. Let's see if I can remember from
4 early -- early on in my young government
5 career. There -- I remember an issue very
6 early on, and I want to say that it was on the
7 Gulf Outlet, Mr. Dan Arceneaux came asking for
8 speed limits to be set so that there were not
9 -- and by not just the large ships, but any
10 kind of vessel that would cause additional
11 erosion, and I believe we passed that at some
12 point, something requesting that speed limits
13 be enforced along the MRGO if I am remembering
14 correctly.
15 Q. So that was a resolution as passed
16 by the Council to impose speed limits on the
17 Gulf Outlet so as to reduce wave wash?
18 A. Reduce wave action and erosion.
19 Yes. There were several pieces of legislation
20 that called for the immediate closure of the
21 MRGO. We had a number of very long debates
22 about exactly what it meant to close the
23 MRGO. Was it reducing it to pleasure traffic
24 or fishing traffic as opposed to closing it
25 completely for any vessels to come up the
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800 562-1285
POLLY BOUDREAUX
1 MRGO. Did it mean fill in the whole thing in
2 or just blocking it off and allowing it to
3 fill in on its own. We had hours and hours of
4 discussion about that among Council members
5 prior to the passage of a, you know, piece of
6 legislation that would say "We wholeheartedly
7 support the closure of the MRGO." There were
8 several pieces passed during -- during that
9 tenure of Council.
10 Q. And did the Council pass resolutions
11 during your tenure as Clerk of Council urging
12 the closure of the Gulf Outlet because it was
13 a conduit for storm surge which would flood
14 St. Bernard Parish or cause damage to St.
15 Bernard Parish?
16 A. I don't remember that they were
17 specifically geared to being a flood conduit.
18 I know it spoke specifically of the great
19 destruction of coastal land, marsh land that
20 had taken place over the years. I do know
21 that just prior to -- actually just prior to
22 Hurricane Katrina we had -- we had been
23 through a few mock experiences. LSU came in,
24 and another -- another firm had come in, and
25 we had gone through a workshop as well with
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1 simulations of what would happen to the New
2 Orleans area were there to be a hurricane that
3 came, you know, up that direction. I have --
4 Q. Is that the Hurricane Pam exercise?
5 A. I am not sure if it was Pam or -- It
6 may have been -- It may have been a spin-off
7 from Pam; then they began to come down
8 locally, you know, to local groups. My most
9 vivid memory is -- was actually a presentation
10 that -- and I should remember his name,
11 because he's been a big name since the
12 hurricane. The LSU professor who, he spoke to
13 the St. Bernard Parish Chamber of Commence
14 just before the hurricane, just within the
15 last couple of months before the hurricane and
16 showed these models and kept showing the
17 models, you know, what would happen, what
18 would happen. And when it was over, having a
19 science background and being a little more
20 inquisitive than I guess most people about
21 science issues and biology issues, it had a
22 great rendering of what New Orleans was going
23 to face, but somehow the map never did show
24 what St. Bernard was going to endure. And I
25 raised my hand and asked that question,
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JOHNS, PENDLETON & ASSOCIATES
3/5/2008
1 "You're showing us what's going to happen to
2 New Orleans, but we're the St. Bernard Chamber
3 of Commerce. What's going to happen to St.
4 Bernard?" And he admitted then that there
5 were severe issues for St. Bernard and that
6 had just not been a part of their modeling.
7 That they hadn't shown it, I guess fleshed it
8 all the way out for St. Bernard, and that they
9 were working on that part of it and would be
10 happy to come back to show us that. And he
11 didn't have to come back, because we got to
12 experience it all by ourselves in person.
13 Q. Was that Professor Mashriky?
14 A. Mashriky, yes. Yes.
15 Q. And did you, in your capacity as
16 Clerk of Council, have any dealings with the
17 Hurricane Pam exercise, which was the
18 simulated hurricane that I think they did in
19 April or -- somewhere in '04, April to
20 November of '04?
21 A. We had -- I do remember going
22 through activities led by our OEP director and
23 I guess the -- it was mostly OEP director,
24 Larry Incajolia (phonetics) and a little bit
25 by Tommy Stone, just behind the Council
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1 chambers. We went through some exercises and
2 I was asked to be the represent- -- the
3 Council representative at, you know, at that
4 -- those particular exercises, and it's very
5 possible that the name was Pam. I remember
6 the name, the Hurricane Pam exercises, but I
7 was thinking that ours was called something
8 else. But --
9 Q. Were you aware or did you ever hear
10 of the term "The Mississippi River Gulf Outlet
11 Task Force"?
12 A. That was not an active body that I
13 know when -- when I took the position. I
14 didn't attend any of those particular
15 meetings. I know that that task force had
16 been in existence, but I would not be able to
17 accurately tell you. It was not an ongoing
18 committee when I took office that I remember.
19 Q. Do you know what happened to the
20 Mississippi River Gulf Outlet Task Force?
21 A. Do I know what happened? No. I
22 could -- I could venture a guess based on some
23 of the committees that we had enacted while I
24 was there and people just get busy and tied up
25 and, you know, kind of fizzles out. I am not
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800 562-1285
POLLY BOUDREAUX
1 sure. I am not remembering that particular
2 committee.
3 Q. Would it be fair to say that during
4 your tenure as Clerk of Council the closure of
5 the Mississippi Gulf Outlet was a major
6 concern of the Council members?
7 A. Yes. Yes. In fact, we had -- and I
8 have the documentation and the paperwork. Not
9 long after I took office, there was a deal
10 fashioned between the Port of New Orleans and
11 the Parish President to -- some agreement
12 concerning the Mississippi River Gulf Outlet.
13 And if you'll let me go through my mind and
14 remember. It is a very full mind. This is a
15 definite Katrina effect, is that you just --
16 It's a massive filing cabinet now it feels
17 like to go through. Can you tell me the port
18 -- the board?
19 Q. Lagrange.
20 A. Lagrange.
21 Q. It's about Lagrange and Junior.
22 We're talking about a deal with Lagrange and
23 Junior.
24 A. Yes. And that --
25 Q. Mr. Rodriguez.
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1 A. Yes. That would have been -- If I
2 had my records, I could flip right to it.
3 Q. Say right after the storm?
4 A. Right after. And they fashioned a
5 letter of language that didn't necessarily
6 support what Council members believed to be
7 the closure, the true closure of the MRGO. It
8 seemed to be more a deal that would protect
9 the financial interest of the port as opposed
10 to the complete concern of the safety and
11 welfare of St. Bernard Parish. It caused a
12 major outcry, a major rift among Council
13 members and the Parish President, and was not
14 supported by the Council. It resulted in
15 another piece of legislation that spoke
16 against any form of leaving the MRGO open.
17 And I do recall that very vividly there were a
18 lot of not nice words and very heated
19 argument, not just by the government
20 officials, but by those who -- those from the
21 public who had been able to make their way
22 back to St. Bernard who were just outraged
23 that anybody could -- could believe it needed
24 to still be here, you know. That there was
25 any way to justify it financially.
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JOHNS, PENDLETON & ASSOCIATES
3/5/2008
1 Q. I remember those meetings.
2 A. Uh-huh (affirmatively). That tent
3 is still standing.
4 Q. I participated in a bunch of them.
5 Tell me about your trip on the
6 Gulf Outlet that you told us about earlier.
7 A. I will tell you that the minute we
8 -- the boat got into the Gulf Outlet, we went
9 through the locks. I guess -- I am not even
10 going to say what, but I will say it wrong.
11 It wasn't down at Violet, --
12 Q. Bayou Bienvenue locks.
13 A. We went out the Bayou Bienvenue --
14 Q. Bienvenue.
15 A. -- locks first and then Violet
16 Canal. I think we came back through those.
17 And I have since been on it several times
18 since the hurricane with Mr. Rodriguez and the
19 Corps of Engineers and, you know,
20 politicians. I have been out a few times
21 now. We actually got stuck in it because they
22 had to close the locks and so we had to be
23 picked up along the levee and brought back to
24 the marina. But my -- my initial impression
25 when we left those locks and my friend said to
Page 24
1 me, "You're now in the MRGO," I really -- my
2 picture of it had been some small channel. I
3 mean, I grew up in -- or graduated from high
4 school in Belgium and canals there, you know,
5 are rather small. It's only wide enough for a
6 barge to go in it, and I think that's what my
7 picture was, was just this little, you know,
8 barge kind of canal. And we got into that
9 thing and it is absolutely massive. I mean,
10 you look at it and think this is not a canal.
11 This is not even a river. It is huge, you
12 know. Obviously it has eaten and eaten and
13 eaten away at the land in order to be so, you
14 know, so big. And I remember -- I remember
15 being upset at that point, thinking all of
16 those years I taught biology at St. Bernard
17 High School and I could have been bringing
18 kids -- I brought them all over to field
19 trips, south Louisiana. Never once brought
20 them on a field trip in the MRGO in St.
21 Bernard Parish, and I certainly could have.
22 There was nothing that limited me from doing
23 that. But I think we had grown so accustomed
24 to it being there that you just took for
25 granted where it was and what it meant, and
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800 562-1285
POLLY BOUDREAUX
1 had more -- more people been brought in a boat
2 in the middle of it, there would have been a
3 larger public outcry that this is crazy.
4 Q. Let me ask you, tell me about the
5 trips that you took on the Mississippi River
6 Gulf Outlet with Corps personnel.
7 A. Those were mostly to show off the
8 new levees that had been repaired and the
9 areas where the -- around the locks where the
10 water had eaten during the hurricane, had
11 breached those -- the big support bulwarks I
12 guess on either side of the locks. The water
13 had run and really damaged the levees there.
14 So we were -- we were there to see the new
15 work and, you know, see the glory of repair.
16 Q. But would it be fair to say that all
17 of the trips with the Corps personnel were
18 post Hurricane Katrina?
19 A. Mine? Yes. I would have to very
20 carefully remember and I don't have any of --
21 When you leave a government position, you
22 leave all of your stuff. So I would need to
23 reflect on whether or not we had taken a trip
24 prior to -- prior to Katrina. And I want to
25 say we did, because I remember there being two
Page 26
1 boats and Council being upset because they
2 didn't get on the first boat. It's crazy how
3 you remember things based on the political
4 underpinnings at the times at the time, and
5 that's what I am trying to remember when. I
6 think that was -- that was prior to the
7 hurricane. It was a -- It was kind of a
8 pleasant trip, if I remember, you know, like
9 we're going to see, we're going to look, and
10 not -- not a let's go look at repair, damage
11 after, is my memory. But I would -- I would
12 need to look through some things to refresh
13 that.
14 Q. From the time you took office as
15 Clerk of Council in '03 to before Hurricane
16 Katrina, were there ever any Corps personnel
17 that would come to the Council and talk about
18 the closure of the Mississippi River Gulf
19 Outlet?
20 A. Nothing with any frequency. Nothing
21 that would make me -- Maybe one meeting out of
22 any of the ones -- That was always an issue,
23 that they were very difficult to communicate
24 with. And we would send, you know, scathing
25 resolutions or very strong language
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JOHNS, PENDLETON & ASSOCIATES
3/5/2008
1 resolutions and get very little to no response
2 from anyone. And I remember not even knowing
3 if I was sending it to the right person. Who
4 am I supposed to send it to? Nobody's given
5 me a, you know, a direct contact that I can
6 send it to, that this -- you know, this very
7 strong resolution about closure needs to go to
8 the Corps of Engineers and they're a massive
9 business. Who did do you send it to?
10 Q. Would the letters and correspondence
11 that was sent -- And I take it that you sent
12 that letter as Clerk of Council, it would have
13 been on behalf of the St. Bernard Parish as a
14 legislative body; is that correct?
15 A. Absolutely. Yes. Yes. It would
16 have been a copy of -- you know, "Forwarded is
17 a copy of the resolution passed by the St.
18 Bernard Parish Council on such and such a date
19 requesting a complete closure of the MRGO" and
20 then attached would be the actual resolution
21 itself, an official copy of that resolution
22 would go in to -- to the Corps.
23 Q. Did you ever come across or see any
24 responses by the Corps of Engineers to the
25 scathing resolutions that you forwarded to the
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1 Corps on behalf of the St. Bernard Parish
2 Council?
3 A. No, nothing that would have
4 addressed the nature of -- of the content of
5 the resolution. There may have been "Thank
6 you, he have received -- you know, it's
7 forwarded here." We would also send it -- I
8 was always directed to send those to our
9 legislators as well, and so they would get a
10 copy and sometimes I would get a response back
11 from Mary Landrieu's office saying they had
12 been noted and received and "Thank you for
13 your continued interest in this issue" kind of
14 correspondence.
15 Q. Did the Council or did you on behalf
16 of the Council send correspondence to any of
17 the Louisiana Congressional delegation
18 regarding closure of the Mississippi River
19 Gulf Outlet prior to Katrina?
20 A. Yes. They would have been cc'd on
21 the correspondence to the Corps is typically
22 what would happen. It would go to each of
23 those offices as well as Senator Landrieu and
24 Senator Vitter at the time.
25 Q. And other than a cursory response of
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1 "Thanks for your interest", did you receive
2 any, as the Council, did the Council receive
3 any formal response dealing with those
4 resolutions on closure of the Gulf Outlet that
5 was a substantive response?
6 A. I do remember, after the hurricane,
7 receiving them from, especially from Senator
8 Landrieu's office. Prior to the hurricane we
9 may have had one from her that directly spoke
10 to that issue and this is a concern to me, you
11 know, a little bit more than just the "Thank
12 you for your" -- "Thank you for your piece of
13 paper" kind of response. And those would --
14 those responses would be on file now, because
15 I didn't lose any of my records. They would
16 still be in the MRGO files in my office -- not
17 my office any more. My used-to-be office.
18 They would still be there. So that's
19 certainly something that, you know, could be
20 looked at, could be researched.
21 Q. But tell me what type of documents
22 -- Was one of your job duties as Clerk of the
23 Council to maintain the documents and
24 correspondence historically for the
25 Mississippi River Gulf Outlet or pertaining to
Page 30
1 the Mississippi River Gulf Outlet?
2 A. Absolutely. Three or four large --
3 large bulging files that I would not take a
4 shred of paper out of. Only went through it
5 to find -- At one point, and I -- Again, I
6 will apologize I don't remember that it was
7 just prior to the hurricane or right after. I
8 was asked to look back in those files to find
9 every -- every piece of legislation. It was
10 unfortunately not -- had not been a practice
11 before I came of putting all -- putting
12 everything on --
13 Q. Disk?
14 A. In searchable format, right, that
15 you could just go back in and type "MRGO" and
16 see how many times it had been brought up. So
17 I physically had to go through the files and
18 pull anything that I saw. And I really think
19 that was just prior to the hurricane. Mr. Dan
20 Arceneaux wanted it to bring to one of the
21 meetings he was going to, either a PACE
22 meeting or a Corps meeting that he was
23 attending. He attended them rather regularly
24 and, you know, always spoke out in behalf of
25 St. Bernard.
Page 31
JOHNS, PENDLETON & ASSOCIATES
3/5/2008
1 Q. What is a PACE meeting?
2 A. Parishes Against Coastal Erosion.
3 Q. Okay. And go ahead with your
4 answer. I'm sorry.
5 A. That's okay. My memory, without
6 looking at anything, is that it was just prior
7 to the hurricane that I pulled how many times
8 the Council, since the Council form of
9 government, had made some kind of request or
10 demand concerning the MRGO.
11 Q. Are those documents still in the
12 files of the St. Bernard Parish Council?
13 A. When I left them, yes. I can't
14 vouch for them since last fall, but they
15 should -- they should all be there, yes.
16 Q. And are you aware of any other
17 documents pertaining to the history of the
18 Mississippi River Gulf Outlet that would have
19 been maintained by St. Bernard Parish?
20 A. There were -- There were -- There
21 were several boxes of old files upstairs on
22 the third floor that I recall the name being
23 written on and it may have been "Task Force".
24 It was some committee that was -- that was
25 going on years ago that I don't have any
Page 32
1 personal recollection of. I just remember
2 that the boxes were there. And there may have
3 been down -- downstairs, not far from my
4 office in the government building, there was
5 -- there was a vault where a lot of the
6 Council records were kept. And that would
7 have included committee minutes and tapes from
8 many years past. And while I was able to save
9 some of those the day before -- It was on
10 Saturday, pulled up a good deal of those, I
11 did not take everything and at that time took
12 things that I had found to be very helpful or
13 very important and we were not able to bring
14 it all up. So there may have been -- there
15 may have been a couple of boxes down in that
16 vault, but I don't -- I don't know how much.
17 That would have been MRGO. It was a big issue
18 and there were definitely boxes upstairs.
19 There were files in my office. There were I
20 am sure at least one box of files in the vault
21 as well.
22 Q. And wasn't there a significant group
23 of documents that we took and had restored and
24 provided back to St. Bernard Parish?
25 A. Yes. Yes. Absolutely.
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1 Q. Okay. But besides those and the 1 straightest shooting fellow out of that group,
2 ones you described in your office and the 2 and his -- his levee repair updates, he was --
3 boxes on the third floor, are you aware of any 3 he was always honest enough to say "We know
4 others? 4 this is not quite where it should be, but
5 A. Just the ones that may have been in 5 we're still working toward --" as far as the
6 the vault. And those were -- you know, we 6 repair heights of the levee. That's -- That's
7 would have lost because they were completely 7 really my only recollection of -- Colonel
8 -- 8 Beaddie made some comments based on studies
9 Q. Okay. And at the time of the storm 9 that he had -- that he had looked at, and
10 -- Let me, while we're on the subject, 10 that's when they were debating on the control
11 post-hurricane Katrina, did any Corps of 11 structure. They were talking about a control
12 Engineers employees appear before the 12 structure under the green bridge at one point
13 Council? 13 and then he wanted to move it up a little bit
14 A. Yes. Much more so than before 14 further where I guess Industrial Canal and the
15 Katrina. 15 MRGO joined.
16 Q. Did any of those -- Do you remember 16 Q. That's the Gulf Intracoastal
17 the names of those Corps employees? 17 Waterway and the Mississippi River Gulf
18 A. Chris Gilmore. Chris Gilmore gave 18 Outlet.
19 an often monthly account of levee repair. He 19 A. The GIWW and the MRGO.
20 usually came with a few other folks, and I can 20 Q. That's correct.
21 see the other gentleman's face. He was one of 21 A. Correct. I know those acronyms.
22 the names that you always saw when they were 22 But I remember him commenting about what he
23 -- when they were doing the study, trying to 23 had seen and the fact that their -- their
24 gather all the data to be able to tell 24 protection was not going to be adequate and
25 Congress that, you know, it needed to be 25 that we were definitely vulnerable right now
Page 34 Page 36

1 closed. 1 because of this time lag in what they were

2 Q. Was it Waggoner? 2 able to do. He commented on the models that
3 A. Waggoner is another one. Colonel 3 they had looked at to determine where that --
4 Waggoner, we did see him. A Colonel Beaddie, 4 you know, where that control structure went.
5 I guess Jeff Beaddie. 5 And that's one of the trips we went on, was
6 Q. It's Beaddie. He's the tall, 6 the trip for him to justify to the political
7 blond-haired guy. 7 leaders of the Parish exactly where they had
8 A. Tall, no hair, or close to no hair. 8 chosen to make that -- to put that structure,
9 Q. No hair guy with glasses. 9 the control structure.
10 A. Yes. But the other fellow, he 10 Q. Okay. Tell me, or tell us about the
11 facilitated the meetings at the Corps office 11 events leading up to Hurricane Katrina
12 on Leake. 12 starting on the weekend before the hurricane.
13 Q. Did any of the Corps employees that 13 What did you do?
14 appeared before the Council subsequent to 14 A. I attended a lot of meetings. We
15 Hurricane Katrina ever comment, to your 15 started having meetings I think Thursday
16 knowledge, on the role of the MRGO, if any, in 16 evening, and these would have been
17 the flooding in St. Bernard Parish? 17 State-called meetings where all the parishes
18 A. I don't recall anybody sticking 18 that they felt would be affected, or agencies
19 their neck out. Certainly not verbally. 19 that were preparing, would gather around a
20 Q. Did any Corps employee or 20 conference call in their own, you know, own
21 representative ever make any comment to you 21 offices and we would -- we would patch in to
22 individually about the role of the Mississippi 22 the conference call, and started having them a
23 River Gulf Outlet, if any, in the flooding in 23 little more frequently on the Friday. And by
24 St. Bernard Parish? 24 Friday -- Friday early afternoon, knew that
25 A. No. Chris Gilmore probably is the 25 there was -- there was some potential danger
Page 35 Page 37

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POLLY BOUDREAUX
1 for us and we began making some decisions of
2 who -- who was going -- and I say "we", I am
3 not a decision maker, I'm the recorder and,
4 you know, keeping notes and doing what I am
5 asked to do for the government officials.
6 Q. Let me go back just a little bit.
7 Where did you live at that time?
8 A. I lived on the last street in
9 Lexington subdivision. So my front door
10 looked at the 40 Arpent, which looked at the
11 40 Arpent Levee, and then the marsh and then
12 the MRGO.
13 Q. Okay. And who were you living with
14 at the time, or who lived with you at the
15 time?
16 A. The same people I live with today.
17 My two children, my daughter Sophie and my son
18 Alex, who are almost 11 and 14 now.
19 Q. Okay. And when Hurricane Katrina
20 was coming and it was the Friday before the
21 storm, what did you do with your son and your
22 daughter while you were tending to Parish
23 business?
24 A. Going to plenty meetings. It was a
25 naturally occurring weekend for them to be
Page 38
1 with their dad, and I had to make some phone
2 calls to kind of speed up the exchange process
3 with them and get them -- go pick them up
4 quickly, get them to his wife so that they
5 could take them on for the weekend and I could
6 get back to the next meeting that was being
7 called that evening. So they didn't go --
8 They did not leave with believing that
9 anything was going to happen. They left like
10 a regular weekend, which meant very little
11 things went with them, very few things.
12 Q. Where does their dad live? Where
13 did he live at the time?
14 A. At the time he lived in Morgan City,
15 in Berwick.
16 Q. And tell us what you did and what
17 actions you took beginning on Friday before
18 the storm.
19 A. Not very much personally, but
20 attending the meetings as they were called,
21 gearing up the office, my office for myself to
22 be the only one as a staff member. I believe
23 it was during the meeting Friday -- Hurricane
24 -- not Hurricane -- Tropical Storm Cindy had
25 occurred a month prior to Hurricane Katrina
Page 39
JOHNS, PENDLETON & ASSOCIATES
3/5/2008
1 and when it reached St. Bernard Parish, it
2 actually hit us with much greater than
3 tropical force winds. It was actually a very
4 frightening experience and nobody was gone.
5 You know, everybody was home. Lots of trees
6 had -- tree damage, limb damage, a lot of
7 electricity went out, and I had been called at
8 probably 3:00 o'clock in the morning and told
9 I needed to put my kids in the car and get to
10 the Council office because they needed me
11 there. And so I did. I drove up to the
12 office. They had Army cots for the kids to
13 sleep on and I began to field many phone calls
14 that were coming in at that point.
15 So because of that experience and
16 the necessity of having somebody there to
17 answer calls and to relay information to
18 Council members, because Council and
19 administration are two very separate entities,
20 legislative versus administrative.
21 Q. Administrative, you mean --
22 A. The Parish President's office.
23 Q. -- Mr. Rodriguez's office?
24 A. Yes. Versus the Council office.
25 Q. And the Councils office.
Page 40
1 A. So that Friday, sitting in one of
2 the meetings, I looked at a few of the Council
3 members that were there and I said "I know
4 what happened during Cindy. Aren't we going
5 to expect the same kind of response for the
6 hurricane that's coming?" And so at that
7 point I was named mandator- -- essential
8 personnel, meaning that I was going to stay
9 through the event. The first time ever.
10 Clerk of Council had never stayed, never been
11 considered essential personnel prior to that.
12 But I was -- I was made essential personnel
13 then. And so Saturday was more meetings and
14 kind of back and forth to the house.
15 Q. And with the meetings, who
16 participated in the meetings on Saturday?
17 A. Several department heads, Public
18 Works Director, Roads, the OEP Director, Fire
19 -- the Fire Chief, Ambulance, School Board,
20 Police -- Police Department. Somebody was
21 there always from the port. There were --
22 Q. And the port would be the Port of
23 St. Bernard facility. Is that right?
24 A. Yes. Yes. Yes. That Port
25 authority.
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POLLY BOUDREAUX
1 Q. As distinguished between the Port of
2 Orleans?
3 A. Between the Port of Orleans, right.
4 And there were always a representative each
5 from the two refineries in on those meetings.
6 And then a good number, but not all of the
7 Council members were there, which is why I was
8 always in attendance, so that every Council
9 member had access to whatever information was
10 relayed, you know, during those meetings
11 whether they were present or not.
12 Q. In going back a little bit, in your
13 capacity as Clerk for the Council, did you
14 ever hear of the term "funnel" or "the funnel
15 effect" of the Mississippi River Gulf Outlet
16 prior to the time of Hurricane Katrina?
17 A. I had heard it in Dr. Mashriki's
18 presentation definitely. I believe that was a
19 term that he used as they modeled what would
20 take place were the storm surge to come in
21 that direction. Pam, whatever, that name.
22 But I do remember that, definitely that
23 explanation from him, the water having nowhere
24 to go, coming -- coming up through this, what
25 doesn't seem narrow when you're in it, but in
Page 42
1 the large scale of things, it is very narrow
2 compared to the Gulf of Mexico itself.
3 Q. Okay. Now go back to -- Sorry for
4 that --
5 A. That's okay.
6 Q. -- deviation. Go back to the
7 telling us about the meetings on Saturday.
8 Who else was essential personnel besides
9 yourself?
10 A. Standard essential personnel for
11 administrative side of government would your
12 Water and Sewer Director, your Public Works
13 Director, your Transportation Director, Roads
14 Supervisor, Purchasing Agent, who would be
15 responsible for, you know, preparing supplies
16 or making -- you know, making things happen
17 financially in a quick turnaround. A few
18 secretarial positions from administrative side
19 who would man phones during -- you know,
20 during the night or morning hours as an event
21 is taking place for folks to call in to.
22 Finance Director was considered essential
23 personnel at that point.
24 Q. What about the Councilmen?
25 A. They --
Page 43
JOHNS, PENDLETON & ASSOCIATES
3/5/2008
1 Q. And Council women?
2 A. No, they're not -- they're not
3 officially named. There's actually an
4 ordinance in place. There was prior to the
5 hurricane. We had just revisited that
6 ordinance that lays out exactly -- exactly who
7 is considered essential personnel, because
8 it's a funding -- it's a payroll issue. You
9 have to -- You have to officially name who's
10 -- who's your first line of defense, who has
11 to be ready to be called back in and be ready
12 with, you know, with payroll issues based on
13 what the Parish President deems as necessary
14 for an event. And based on category. You
15 know, a category 1 versus -- There are
16 different types of personnel called out. Or
17 more personnel called out as the category
18 grows.
19 Q. And are all of these essential
20 personnel on the administrative side? Or --
21 A. Yes. Yes. Council would -- would
22 not have been named as essential personnel.
23 They assumed their essentialness. And mine.
24 Q. So the -- But what I am asking is
25 from the administrative as opposed to the
Page 44
1 Council side. Who in the presidential side of
2 the government was essential personnel?
3 A. That's all those department
4 directors.
5 Q. Okay.
6 A. That's all administrative. The only
7 -- The only Council staffing that they named
8 was myself, new. The TV studio director is
9 kind of a position that teeters between
10 administration and Council and he is also --
11 was also considered, our TV studio director
12 was concerned an essential personnel. At this
13 point he belonged to the Council. So we would
14 have been the only two kind of official
15 positions named.
16 Q. And what was the sentiment on
17 Saturday before the storm at the Council -- I
18 mean at the Council with all -- in all the
19 meetings?
20 A. There was growing concern, and the
21 later it got on Saturday, the more the concern
22 grew that it was indeed going to be a large
23 catastrophic event. We would watch the models
24 as the conference calls would come in. There
25 were modeling maps that would occur that would
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1 be shown in our -- in the room right off the
2 OEP office and --
3 Q. Who was providing you the models?
4 Any of those water models?
5 A. Let me think if we had -- We had a
6 number of models, but they were through our --
7 through the service there, the Internet
8 service that we had there at government. So
9 it would have been National Weather Service
10 and I don't know how many different news media
11 -- different folks they used.
12 Q. But were the models of the storm
13 track or were they models of --
14 A. A lot -- And lot of it was storm
15 track.
16 Q. -- what would happen when the storm
17 -- Okay.
18 A. Right. A lot of it was storm
19 track. I remember conversations in the
20 conference calls about what do you -- what do
21 you think we're going to experience
22 water-wise? What do you think we're going to
23 have surge -- You know, what's the surge model
24 look like? But I don't recall that we saw
25 that over and over. I remember the track over
Page 46
1 and over, and you could never see St. Bernard
2 Parish. Every time you would see the track,
3 it completely covered St. Bernard.
4 Q. And at the time who was present?
5 Was it the essential personnel you talked
6 about, the Council members --
7 A. Yes.
8 Q. -- or Mr. Rodriguez?
9 A. He -- He wouldn't have come in until
10 Saturday evening. He had just experienced
11 major surgery and a major setback from the
12 surgery and had not even been officially back
13 to work in a full time -- you know, in a daily
14 capacity, but he came in that evening,
15 Saturday evening. And maybe not even Saturday
16 evening. It may have been Sunday evening that
17 he finally came in, he and his family. And I
18 have notes about that.
19 Q. And when you have notes about that,
20 do you have written notes about that?
21 A. Uh-huh (affirmatively). Uh-huh
22 (affirmatively).
23 Q. And where are those written notes
24 today?
25 A. I have a copy of those, because I've
Page 47
JOHNS, PENDLETON & ASSOCIATES
3/5/2008
1 had to testify on behalf of the St. Rita's
2 Nursing Home trial. So I have copies of those
3 notes. But the originals are in -- should
4 still be in my office, Council office.
5 Q. I understand that you had a camera
6 with you. Do you know of anybody else that
7 was there that had a camera with them also?
8 A. Our TV studio director was filming
9 the entire time. Picture-wise, or camera-wise
10 I am sure there were a few others. But Ken
11 definitely had his and I had mine until the
12 battery died and we had no more electricity so
13 that was the end of picture taking.
14 Q. Besides Ken and yourself, do you
15 remember anybody that may have had a video
16 camera or a picture camera?
17 A. I really don't. I would assume that
18 there may have been some firemen who did. Our
19 Council chambers -- Our Council chambers, the
20 back of it faced Judge Perez Drive; all
21 windows, very large windows. So it was, at
22 the time the hurricane was hitting, it was an
23 unbelievable show to watch until it became
24 catastrophic and nobody could watch, but it
25 provided a great kind of ampitheater for the
Page 48
1 events of the hurricane as the wind was
2 blowing. And I'm -- I have never seen them,
3 but there could have been some fire personnel
4 who had originally camped out in that area for
5 the night that may have photographs.
6 Q. When did the storm's effect begin to
7 be felt at the St. Bernard Parish Council
8 chambers? Or I should say the Council
9 building.
10 A. Right. The Government Complex
11 building is what we call it. I slept the last
12 night in my house Saturday night, and by
13 Sunday, Sunday noonish we were loading buses,
14 the last of buses, the last of people we could
15 gather off the streets to get out of St.
16 Bernard, and the wind was -- was blowing
17 rather nicely at that point. You definitely
18 knew something was coming. I recall taking a
19 drive with Mr. DiFatta and Miss Hoffmeister,
20 and maybe Mr. Madary. I actually have picture
21 of this as well. We went across the green
22 bridge and went on -- Is that Chef Highway?
23 Q. Yes.
24 A. To where the locks are to see if the
25 water was coming up there. And I have a
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1 picture on top of the green bridge of the MRGO 1 Perez Extension? Or were you farther down?
2 which was already spilling over its banks. 2 A. No, further than that. Where you
3 Q. You have a photograph? 3 turn -- Where you turn to go into Fort --
4 A. Yes. And one on the way back. 4 Q. Proctor's Landing.
5 Q. Tell me when those were taken. 5 A. Yes. There's kind of a big -- kind
6 A. That would have been Sunday night, 6 of a circular area is my memory where they had
7 Sunday evening, and my only way to give you a 7 palm trees they had planted there, and there
8 better estimate of time would be to see my 8 -- I remember Joey pulling down what was kind
9 notes and see what time our next meeting was. 9 of like a ramp into the water and the water
10 Because we took the trip in between meetings. 10 was already there, much higher than it should
11 You know, raced to go take a look and then 11 have been, and we convinced him to please turn
12 drove all the way down beyond St. Bernard High 12 around and this was not where we wanted to
13 School to where Jack Stevens' home is, that's 13 be. And we went to St. Bernard High School.
14 where Beauregard -- 14 I have a couple of pictures there of folks who
15 Q. Correct? 15 were -- who had come there as a shelter of
16 A. -- Proctor? 16 last resort and some government staffing who
17 Q. It's Proctor's Landing. 17 were staffing that school.
18 A. Yes. We went there, couldn't go to 18 Q. Was there anybody else with you on
19 his home because water was already up on that 19 that trip that had a camera, or were you the
20 -- on that road significantly. Enough to -- 20 only one?
21 Q. What type of vehicle were y'all 21 A. No, I think -- I'm pretty sure I'm
22 traveling in? 22 the only one that had a camera then.
23 A. We were in a -- Mr. DiFatta 23 Q. And what type of camera did you
24 commandeered a vehicle from someone. It was 24 have?
25 our early attempt at commandeering. It -- It 25 A. It's in my purse. It's Minolta I
Page 50 Page 52

1 wasn't a car, I can tell you that, and it 1 think. A digital camera.
2 wasn't a truck, but it would have been in 2 Q. It's a digital camera?
3 between, and I am -- I don't remember. 3 A. Yes. Yes.
4 Q. Was it bigger than a pickup truck? 4 Q. And does it say pictures and save
5 A. It would have been as high. 5 them to a memory stick?
6 Q. When you say truck, was it like an 6 A. Yes.
7 Army personnel vehicle? 7 Q. And did you save those photographs
8 A. No. No, it was a -- I think it was 8 to the memory stick?
9 one of the OEP vehicles. So it was -- It 9 A. Yes.
10 wasn't one of these -- I mean, it's something 10 Q. And did you subsequently upload them
11 you could drive in today and not be considered 11 to a computer?
12 outlandish in some large vehicle. But it was 12 A. Yes. Our TV studio director
13 definitely -- I had a Montero at that time, 13 uploaded them to a CD. I have never even
14 Mitsubishi Montero, and it was, you know, a 14 looked at it, but asked him if he would please
15 little bit higher than that would have been. 15 put them on the -- on the CD.
16 Q. Did you take photographs when you 16 Q. And did you subsequent to taking the
17 went down to the eastern edge of the parish? 17 pictures do anything to edit or enhance the
18 A. I did. But they didn't come out 18 photographs?
19 really well. I did. I have one that is a 19 A. No. I didn't have time to play
20 little bit difficult to see. I used the 20 anything like that after the hurricane.
21 flash, but we had to turn around in that kind 21 Q. And subsequent to that point or up
22 of that large area before you go down where 22 until today, have you ever done anything to
23 the houses were; the water was already up to 23 edit or enhance those images?
24 that point then. 24 A. Uh-uh (negatively). No. I haven't
25 Q. That's like at the end of the Judge 25 had time to go back. I have looked at them,
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1 you know, several times, but no, I haven't 1 would take place, the time, you know, usually
2 done anything to them. 2 would write down who was present; kind of, you
3 Q. And in looking at -- When it was -- 3 know, quick sketch of who was there, and then
4 Was it the television director that put them 4 I took notes as the information unfolded as
5 on disk for you? 5 they, you know, gave any kind of updates. And
6 A. Uh-huh (affirmatively). 6 I have notes -- I have specific notes about
7 Q. Do you know if he did anything to 7 the surge, the water surge. I do remember
8 edit or enhance the photographs? 8 that. When they asked National Weather
9 A. There wouldn't have been any reason 9 Service and I questioned a couple of folks
10 to, no. I just asked him to please create a 10 about what they expected for St. Bernard.
11 backup in case something happened, you know, 11 Q. And were the notes that you were
12 to the memory stick. 12 taking personal notes for you or were they
13 Q. And would those photographs then be 13 notes that you were taking in the course and
14 a fair and accurate depiction of the events as 14 scope of your business as, or your occupation
15 you photographed them -- 15 as Clerk of the St. Bernard Parish Council?
16 A. Absolutely. 16 A. Yes, my duties as Clerk of Council.
17 Q. -- on the Sunday evening, is it 17 And understand, that as someone who has -- who
18 August 28 of 2005? 18 had never before been a government employee or
19 A. Yes. Is that right? Sunday 19 even government experience and no -- no real
20 evening. 20 transition time between the lady who had
21 Q. Well, the Sunday evening prior to 21 served as Clerk of Council for the entire time
22 the hurricane. 22 there had been a Council for St. Bernard
23 A. Whatever that date is. Sunday 23 Parish, she literally was out right as I came
24 evening, 28. 29 was Monday, right? Because 24 in, and so I learned a lot and did -- did
25 it was stormy all night long. I slept in Mr. 25 things based on my assessment of the need for
Page 54 Page 56

1 Dean's office and wind howling. 1 people to know, you know, know what happened.
2 Q. Approximately what time was that 2 Part of my job description was that -- was to
3 trip that y'all rode around the parish? 3 provide information to all Council members
4 A. It was already growing dark when we 4 regardless of whether or not they were present
5 left, so I am going to say 7:00, around 5 at a meeting. And I was their
6 7:00ish in the evening. And I would have to 6 representative. And if they were not --
7 see what time our -- what time our meeting was 7 unable to be there, I needed to be able to say
8 that evening, that Sunday night. Because we 8 this is what happened, and the best way I do
9 were taking the trip quickly before the next 9 that is taking notes, because I need a written
10 meeting was called. 10 format.
11 Q. And do you have any objection or 11 Q. So the notes were taken as part of
12 issues with us obtaining a copy of your notes 12 your, or in the ordinary course and scope of
13 and those photographs? 13 your occupation as the Clerk of Council?
14 A. Absolutely not. 14 A. As I saw it, yes. You won't see
15 Q. And then we would provide them to 15 that -- You won't see that anywhere in a job
16 every -- all the parties in the litigation. 16 description, but that was my understanding of
17 A. We are supposed to be the providers 17 how I would need to provide information to
18 of information to all the public so no, 18 those who would not -- you know, who would not
19 absolutely not. 19 be in attendance and --
20 Q. Were the notes that you took kept 20 Q. Let me ask you one other question
21 contemporaneously with the events that are 21 for our purposes about the notes. Did you
22 depicted in the notes? 22 take the notes contemporaneous with the events
23 A. In the pictures? 23 described in the notes?
24 Q. No, no. Like you said -- 24 A. Uh-huh (affirmatively). As they
25 A. I took the notes as each meeting 25 were -- As it was happening I was --
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1 Q. As they were occurring, you were 1 Q. I think I remember those.

2 taking notes; is that correct? 2 A. Uh-huh (affirmatively).
3 A. I was taking notes on a note pad and 3 Q. But let me ask you as part of the
4 just following one meeting after the next in 4 deposition, if you would, could you provide us
5 notes. 5 with an electronic version of those pictures?
6 Q. And did you transcribe those notes 6 A. Uh-huh (affirmatively).
7 or are they still handwritten? 7 Q. And we'll attach it to the
8 A. Still handwritten exactly as they 8 deposition and we'll print a set. The
9 were then. 9 electronic version should have metadata
10 Q. Okay. And then tell me about the 10 attached to it which will indicate when you
11 photographs that you described about the trip 11 took the photograph, what the exposure was.
12 that you took around the parish with Mr. 12 A. Okay.
13 DiFatta, Mr. Madary, and Miss Hoffmeister that 13 Q. So we'll know all about that based
14 you just told us about. 14 on the pictures. That's why we would like to
15 A. I would have taken those Sunday 15 get an electronic version if we could.
16 evening on our trip across the MRGO to check 16 A. And if it's still -- I don't know
17 on the locks at Chef Menteur to see where the 17 that it's still on the memory card, the
18 water level was there and then down eastern -- 18 original memory card. If it is, I'll be glad
19 the eastern portion of St. Bernard to see 19 to. I'll give what you I have. I definitely
20 water level down at that end, as well as visit 20 have the disk that Ken Winters burned with
21 the shelter at St. Bernard High School before 21 those photographs on it.
22 coming back up to go to the meeting, I believe 22 Q. Okay.
23 the last meeting of the night. 23 A. And that would include photographs
24 Q. And let me ask you, did you take any 24 the next day as the water is coming up in the
25 or do you have any -- 25 parking lot, you know, all the pictures I was
Page 58 Page 60

1 A. I didn't take notes during that 1 able to take until the battery went dead and
2 trip. 2 that's it.
3 Q. Okay. Do you have any recollection 3 Q. Okay. Thank you. And I will
4 of the water in the Mississippi River Gulf 4 coordinate with you about getting that and I
5 Outlet as you drove over it and back on Sunday 5 will attach it to the deposition and provide
6 evening? 6 copies to everyone.
7 A. Yes. I took -- took pictures of 7 And we'll attach that as Exhibit
8 both of those, going and coming, and asked Mr. 8 1, which will be the photographs for Miss
9 DiFatta to slow down so I could -- you know, 9 Boudreaux.
10 let me roll down the window, let me get a 10 A. Are you -- Do you want the notes
11 picture, because it was very obviously already 11 from those meetings as well?
12 spilling over its banks. As large as it 12 Q. Yes, but we might have to get that
13 looked when I had been in it in a boat, it was 13 from the St. Bernard Parish Council. Because
14 enormous at that point. It was phenomenal. 14 if it -- But I will address that and we'll
15 Q. At the time was it still daylight 15 provide --
16 outside? 16 A. Okay.
17 A. Enough that you can see the water. 17 Q. -- them, not attach them to the
18 No, it's not -- it's not -- It's definitely 18 deposition, but we'll provide them to
19 dusk, growing to evening when the pictures are 19 everybody once we obtain a copy of them.
20 taken, and I don't have the -- I have them at 20 A. Okay.
21 home. I don't have them in this -- I had them 21 MR. ANDRY:
22 -- I had ordered them a little bit larger and 22 Off the record for a second.
23 I had them on my door at the Council office. 23 (Whereupon a discussion was held
24 On my office door I had two pictures. And 24 off the record.)
25 that was the MRGO pictures. 25 THE WITNESS:
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POLLY BOUDREAUX
1 Yeah, minus a Xerox copy of what
2 originally was there. You know, what
3 should still be there.
4 EXAMINATION BY MR. ANDRY:
5 Q. Okay. What happened on Sunday
6 night?
7 A. Sunday night we had the last -- the
8 last meeting fairly, fairly late that
9 evening. I say 9:00 o'clock, 10:00 maybe, and
10 -- and the news -- the news or the projection
11 of the hurricane had by that time grown very
12 severe for St. Bernard and so we -- we went to
13 the different areas of the building. Council
14 went back to Council offices where we were
15 going to spend the night. Several Council
16 members had put cots in there, in their
17 offices to accommodate a spouse or, you know,
18 had their animals with them, whatever. And we
19 at some point, you know, lights out, the
20 wind's blowing the whole time. I remember
21 that, because that's my last night of sleep,
22 was Saturday night. I didn't sleep well at
23 all Sunday evening because the wind was
24 howling very loudly and I remember -- I
25 remember going to -- There was a bathroom in
Page 62
1 Mr. Dean's office, which is why I stayed there
2 rather than mine, and he also had a large
3 couch and I didn't have one in my office.
4 Q. Let me ask you this, for those who
5 have never been in the building, and that
6 would be the people reading the deposition and
7 watching the deposition.
8 A. Uh-huh (affirmatively).
9 Q. As best you can, could you describe
10 where those rooms are within the Council --
11 within the government building --
12 A. Okay.
13 Q. -- so that we understand where Mr.
14 Dean's office is and --
15 A. Okay.
16 Q. -- how that relates to the exterior
17 of the building, first floor, second floor?
18 A. Okay. The Council offices are
19 located on the -- were located on the first
20 floor of the Government Complex building. As
21 you enter the main lobby, Council assumed the
22 left wing of the building. Toward the back
23 corner.
24 Mr. Dean's office at the time was
25 what had formerly been the police jury
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JOHNS, PENDLETON & ASSOCIATES
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1 President's office. So it was rather large
2 and had a little bit more furniture in it than
3 other offices. But it would have been in the
4 corner -- corner of the first floor building.
5 The way the building is fashioned,
6 or it was constructed, they're very high
7 walls. The windows that you have are
8 significantly above eye level. So you really
9 can't see outside. It's windows so you get
10 light, but you can't see -- you can't see
11 trees, you can't see anything else. They're
12 very high ceilings on the first floor
13 offices. And that's where I stayed, because
14 he had a private bathroom in his office and
15 had a couch, so there was something to sleep
16 on without having to get a cot. That's where
17 I stayed.
18 There were other Council members
19 in other places. And we -- Miss Hoffmeister
20 had asked me to make sure that she was awake
21 by 6:30, 7:00 o'clock in the morning because
22 her daughter was calling from Florida and they
23 wanted to do a live radio interview with her,
24 because we would be in the midst of Hurricane
25 Katrina at that point.
Page 64
1 Q. And her daughter is a news reporter
2 in Florida? Is that correct?
3 A. She works with -- She worked then
4 with Innis Broadcast, I believe. She doesn't
5 do radio, but she works in the offices of N
6 Broadcasting.
7 Q. And did Miss Hoffmeister participate
8 in the interview on -- that would be Monday
9 morning?
10 A. I went to make sure she was awake,
11 and she was awake. She and her husband and
12 the dog were already awake. And I don't know
13 that anybody slept really well that night,
14 because it was very loud. It was not a
15 soothing noise. A howling wind through the
16 night. And I believe she -- she was able to
17 speak to them by phone. It was a phone
18 interview, a cell phone. I think she was on
19 cell phone at that time. But we were
20 scheduled to have a meeting, a conference call
21 the morning of Katrina's impact and at the
22 point we went up to begin that meeting is loss
23 of electricity and then the events that
24 unfold.
25 Q. Let's go back and do it slowly.
Page 65
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1 Other than the wind and the howling noise,
2 were there any significant events, to your
3 recollection, breaking glass or anything like
4 that on Sunday night?
5 A. No. Not in -- Not in that
6 building. Not at that point. No. To my
7 knowledge, there were none. But we are
8 talking about large -- mostly wall and then
9 window at the top which is over, you know, --
10 is under an overhang at the second floor. So
11 while it's exposed to the outside, it's still
12 very much like a fortress, you know, being in
13 that building.
14 Q. And when you awoke on Sunday morning
15 after you woke up Miss Hoffmeister, what did
16 you do?
17 A. Went upstairs -- Well, I was going
18 to tell you about having to go to the bathroom
19 in Mr. Dean's office and I had heard this --
20 the wind all night long and, I don't know, not
21 meaning to be more descriptive than I need to
22 be, but the toilet seat was completely wet and
23 I had this, "Oh, my gosh, how in the world is
24 water getting on the toilet seat? Is there
25 water coming up, you know, already through the
Page 66
1 word from somebody who -- whose windows had
2 just blown out of their car, and I, ridiculous
3 as it may sound, said, "Kenny, I wonder if my
4 windows blew out. I'm parked under the
5 awning, too." And this is obviously before
6 any water, before, you know, anything of that
7 nature has occurred. So Mr. Henderson and I,
8 who are probably the two smallest people on
9 the Council, in the Council entourage, decided
10 to go out of the side door. The door was just
11 sucked away from us as soon as we pushed it,
12 you know, pushed to have it open and he and I
13 had to fight to try to close it. Couldn't see
14 my car because there was another car blocking
15 it, and at that point realized we're not going
16 outside. I mean, he and I would have been --
17 would have been blown away God knows where
18 because the wind was so strong. So we had to
19 physically pull that door back, pull it
20 closed.
21 Q. And when you went outside, could you
22 tell which direction the wind was blowing
23 from?
24 A. No. I couldn't. I mean, I know
25 that it blew the door completely back against
Page 68

1 toilet? Is it spilling over?" You know, you 1 the wall as we opened it. So it would have
2 don't pay attention, you know, until you feel 2 been the door facing the auditorium on the
3 the wet and realized at that point that the 3 side of the Government Complex building.
4 wind had been blowing so significantly that 4 Q. So if I was facing the building from
5 the water was actually coming from the high 5 Judge Perez, you would have been going from
6 window, it was being blown through -- through 6 the left side of the building to the right
7 that, the crack I guess in the top or the 7 side of the building?
8 bottom of the window and down onto the-- onto 8 A. You're facing our building on Judge
9 the toilet. That's where the water -- It was 9 Perez, it would have been the right side. It
10 not coming from, you know, in the sewer system 10 blew the door back toward Torres Park. Sucked
11 itself, but the wind was so incredible through 11 it open and smacked it against the wall, that
12 the night that it had blown the water through 12 direction.
13 that -- blown the rain through that window 13 Q. And do you know what time that was?
14 into the -- you know, the carpeting was wet 14 A. I would say -- No. I don't. 9:30.
15 and the bathroom as well. 15 9:00, 9:30 maybe in the morning.
16 Q. And when you woke up that morning, 16 Q. Was it sunny outside?
17 did you have occasion to go outside? 17 A. It was -- It was light. It wasn't a
18 A. Mr. Henderson and I bravely tried to 18 pretty day, the day of the hurricane. So it
19 go outside at some point during the morning, 19 was daylight. But I can't tell you that it
20 but it would not have been until it was a 20 was a sunny day.
21 little bit later in the morning when the wind 21 Q. And could you tell us what happened
22 really began blowing much greater. We had 22 after that?
23 parked our cars under the awning of that 23 A. There were several places to watch
24 government building, convinced that we would, 24 what was going on. One was the Council
25 you know, be safe from all harm, and had got 25 chambers.
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1 Q. But let me ask you one question 1 folks would scatter out of that -- out of that
2 before. Was there any water outside -- 2 area, because it sounded very much like, you
3 A. Uh-uh (negatively). 3 know, all the glass was going to shatter. The
4 Q. -- of the Council chambers that you 4 sound was that great. And it never did.
5 saw -- 5 There were a couple of office windows that did
6 A. Not at that point. 6 break on the second floor because something
7 Q. -- when you and Mr. Henderson opened 7 blew into them. But we didn't experience that
8 the door at approximately 9:00 o'clock in the 8 personally.
9 morning? 9 Q. And speaking of the windows on the
10 A. No. So your time frame for what I 10 second floor of the building, was there
11 say, you know, I saw the water when it came 11 protection that was put on the windows from
12 up, but I -- the concept of time for many of 12 the outside?
13 us was kind of a lost point. You weren't 13 A. Uh-huh (affirmatively). Rather
14 looking at clocks anywhere, you know, all over 14 securely put on the outside.
15 the building and I wasn't wearing a watch. I 15 Q. What was that made of?
16 had a cell phone, but I wasn't using the cell 16 A. Some plexiglass kind of -- It almost
17 phone. It was just a lot of -- a lot of 17 looks like corrugated, like a corrugated
18 activity, a lot of loud noise and sound and 18 plexiglass. Very difficult to see out of.
19 watching the trees bending and the wind 19 You don't get a regular view of outside. It
20 blowing and rain. 20 made quite a few people unhappy because, you
21 Q. Had the storm, the eye of the storm 21 know, pre-hurricane, it took your view of
22 made landfall at that point in time? 22 nature away completely.
23 A. I don't -- We wouldn't have had a 23 Q. And when did you first notice that
24 reference point to that. I'd have to tell you 24 there was water coming up?
25 that based on after. I don't think it had. 25 A. I didn't notice it at all. Somebody
Page 70 Page 72

1 We hadn't experienced that quiet that you get, 1 said to me, "Did you see the water in the
2 you know, as the eye comes over you. 2 parking lot? You need to go downstairs and
3 Q. Did that happen at any point in 3 see the water in the parking lot." And so off
4 time? 4 I went down the stairs, back stairs by the
5 A. Jon, I am sure that it did, but it 5 Council office, past my office, got out into
6 was a rather unpleasant day. 6 the open foyer area where you enter the
7 Q. Well, tell us about what happened 7 building in normal operating times, and -- and
8 after 9:00 o'clock. When did you first see 8 I have pictures here of water up on the glass
9 water? 9 doors of the building already pouring in from
10 A. I was in the Council chambers 10 the parking lot.
11 watching the panoramic view of the hurricane, 11 Q. (Counsel hands documents to
12 the oak trees on Judge Perez bending, and went 12 Witness.)
13 back into the main part of the building, and I 13 A. And at this point I realize that I'm
14 think out into the -- to the foyer area was 14 also standing in water, but it's just the
15 where you really got a lot of the sound. It 15 soles of my tennis shoes. It's not -- You
16 seemed that I think it was picking up the 16 know, I wouldn't have noticed -- I wasn't
17 gravel off of the roof and it was slamming the 17 trudging through water. I was in just this
18 gravel into the windows in that -- where that 18 surface of water there. And the water was
19 open kind of atrium that goes all the way up 19 already up, I guess halfway up the tires of
20 -- 20 the cars, and the folks who where there who
21 Q. That's in the center of the 21 had watched it and we had --
22 building? 22 Q. Could you tell me who those folks
23 A. -- to the top. Yes. And so I would 23 were?
24 have gone in the second floor and you could 24 A. Government employees. Different
25 hear -- it would get really loud and then 25 folks.
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1 Q. Do you remember their names?
2 A. There are quite a number of them.
3 Some of the Public Works fellows, I have
4 pictures of them and I don't remember -- I
5 don't remember their names. But Donna Nye,
6 who was secretary to the CAO was there, and
7 she is one of the ones that called me to go
8 take a look at the parking lot. There were
9 quite a few people.
10 Q. Was Robert Turner there?
11 A. Yes, Bob Turner was there. He was
12 guesstimating at what point the water was
13 going to stop once the water, you know,
14 started coming in and rising significantly.
15 He was using a big mural in the bottom -- on
16 the bottom floor of the Government Complex and
17 saying, "It's going to get to this step and
18 then it's going to stop" or "It's going to get
19 to this step, this window, you know, in the
20 mural." So I do remember him there.
21 Q. And at that time when you looked
22 out, do you know what direction the water was
23 coming from?
24 A. At this point coming from the New
25 Orleans direction. From the Ninth Ward area.
Page 74
1 Guardsmen, who knew that his grandfather was
2 in Arabi and there was no water, and no water
3 coming up, but he and this National Guardsman
4 got up Judge Perez going towards New Orleans
5 in a Humm V, I think. They were in an a
6 military vehicle. And obviously I didn't go
7 with them, so this is the stories that he has
8 shared. He got up toward Arabi and the water
9 just poured in at an alarming rate, so quickly
10 that they didn't make it to the destination of
11 the grandfather's house. They -- The Humm V
12 started floating. They ended up under
13 awnings; had to pull themselves up on
14 buildings, and kind of go from building to
15 building for safety. Which would have been
16 the time, you know, shortly after that we
17 started seeing the water here in the parking
18 lot.
19 Q. Looking outside through that
20 photograph -- Can I take the photograph out?
21 A. This is Judge Perez. Uh-huh
22 (affirmatively). This is the Judge Perez side
23 of the lobby. And I have another picture that
24 would have been the Torres Park side. This is
25 the Torres Park side (indicating). And I
Page 76

1 Q. In looking out to the other side of 1 don't think you can see it, but the WDSU -- I
2 the building, was there any water coming from 2 think it was WDSU news van, Heath Allen was
3 the other side of the building? 3 with us, and lost one of their big pieces of
4 A. There -- We didn't go through the 4 equipment, parked like me under the awning.
5 doors at that point. The only -- The only 5 Thought we were all going to be so safe.
6 view -- At this point, there was water beyond 6 MR. FORBES:
7 this window so I don't -- I didn't note any -- 7 Just so -- We are already into
8 I mean, there was water everywhere you looked, 8 it, the front lobby of the building --
9 but you couldn't get a view on that. Like the 9 MR. ANDRY:
10 eastern end of the parish. There was no way 10 Let's take -- Hold that thought.
11 to really see that without trying to go 11 He needs to change --
12 outside or go up on the third floor. Your 12 MR. FORBES:
13 vision would have been fairly -- 13 We can do it off the record.
14 Q. Do you know if anybody went up on 14 VIDEO OPERATOR:
15 the third floor and viewed where the water was 15 We're off the record. It's
16 coming from? 16 4:46.
17 A. I'm sure there were some brave souls 17 (Recess.)
18 who did. I don't know that personally, but 18 VIDEO OPERATOR:
19 I'm sure there were. Either firefighters who 19 Returning to the record, it's
20 where there -- We had National Guardsmen who 20 5:08.
21 where there, who were stationed there with 21 EXAMINATION BY MR. ANDRY:
22 us. Mark Madary, who was the Council member 22 Q. For the purposes of the record of
23 from District A, had -- he left during the -- 23 the deposition, let's -- Do you have any
24 That's when he left, during the supposed eye 24 problem with me writing on the back of these
25 of the storm, with one of the National 25 photographs?
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1 A. No. I can make other copies. 1 A. Yes.

2 That's fine. 2 Q. -- near Jackson Barracks? Is that
3 Q. And the second -- If I write on the 3 correct?
4 back, could we at least make copies of them 4 A. Yes.
5 that are -- Do you have any problem with 5 Q. At approximately the parish line?
6 entrusting them to the Court Reporter, -- 6 A. Right. Right.
7 A. No, no. 7 Q. And did you, subsequent to taking
8 Q. -- having him make copies and 8 that photograph, attempt to look outside to
9 providing you the originals back? 9 see if you could see where the water was
10 A. No. That's fine. 10 coming from?
11 Q. And I think we're going to attach 11 A. I was in shock about the water
12 the photograph disk from her as Exhibit 1. So 12 itself and I remember looking as far as I
13 let me label this as Exhibit Number 2 and then 13 could see from that -- from that, you know,
14 ask you if you could show it to the video so 14 that -- as far as that window, you know, the
15 we know what Exhibit Number 2 is. 15 windowed area would allow you to see and it
16 A. Okay. (Indicating). 16 wouldn't give you kind of a sweeping vision.
17 Q. And then -- 17 It would have kind of blocked your vision from
18 A. Is that good? 18 really looking up the street or looking down
19 Q. Yes. Could you describe what's 19 the street. But it was -- it was not
20 depicted in that photograph? 20 difficult to see that the water was coming
21 A. This would have been the foyer 21 from that -- from that direction. That's
22 facing Judge Perez of the Government Complex 22 where the flow was. I don't know that you can
23 building and the water as I saw it when I was 23 tell that in the next picture that I took, not
24 called to the lobby to come see. 24 long after, was the parking lot on the back of
25 Q. And that's when y'all first noticed 25 the Government Complex. The same foyer, but
Page 78 Page 80

1 that there was water. Is that correct? 1 turning toward the Lake Borgne area of the
2 A. That's when I first saw the water. 2 parish.
3 There are others who had been watching the -- 3 Q. Excuse me. I'll label this as
4 watching the water come in. But it was very 4 Exhibit 3 and ask if you could show that to
5 -- moving very quickly. So it wouldn't have 5 the video and then describe what that picture
6 been an extended period of time, you know, 6 depicts.
7 that folks had been watching. It rolled in 7 A. This is the parking lot where access
8 very quickly. 8 is typical for the Government Complex
9 Q. And did anybody tell you in that 9 building. So it's actually behind the
10 area that had been there prior to the time you 10 Government Complex building, between the
11 got to that foyer area, did anybody in the 11 building and Torres Park. Beyond Torres Park
12 foyer tell you their impression of the water 12 would be your Lake Borgne area. And so
13 or where it came from or the speed prior to 13 direction-wise, you can tell me what that is.
14 the time you got there? 14 Somebody's got a map.
15 A. Yeah, there were several -- Yes. 15 Q. I think it's northeast.
16 There were several folks who were saying that, 16 A. Northeast?
17 "It came from the city. It came from the 17 Q. I think. It's either north --
18 city. The water is coming from the city." 18 probably north-northeast. Do you know how
19 And I believe Mr. DiFatta had received a call 19 much time, if any, elapsed between the time
20 not -- not long prior to this (indicating) 20 you took the photograph which is Exhibit 2 and
21 that alerted him to water at the Sheriff's 21 the time you took the photograph which is
22 substation in Arabi also. So they knew water 22 Exhibit 3?
23 was coming -- coming from that direction. 23 A. I would say, too, that there was not
24 Q. And the Sheriff's substation in 24 a lot of time. That I would have talked to a
25 Arabi is on St. Claude -- 25 couple of people who were looking here, maybe
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1 a few up on the balcony area, "You got to see,
2 the water's coming in, how much water is
3 coming in" and then I turned to look at the
4 back where the parking lot is to establish how
5 much water there was in that area.
6 Q. Would it have been five minutes, ten
7 minutes, half an hour?
8 A. Not more than five or ten minutes,
9 no.
10 Q. And the photographs -- Excuse me,
11 the cars, it looks like in photograph Exhibit
12 Number 2 there's a white car and then a black
13 SUV type of vehicle. In that photograph, it
14 doesn't look like the water is up to the top
15 of the tires.
16 A. No. Probably halfway up the tires
17 there. And these are cars, though, that are
18 parked -- That's not a typical place for cars
19 to be parked. Those were folks who had parked
20 the cars to keep them up on higher ground. So
21 these would have been cars parked up under the
22 awning kind of the second -- of the second
23 floor. So they're parked up close to the
24 lobby -- the Judge Perez lobby entrance to the
25 Government Complex. Typically you would not
Page 82
1 see any vehicles there. You would only see
2 them in the back.
3 Q. Well, let me ask you, if you could
4 determine by looking at the photographs,
5 Exhibit 2 and Exhibit 3, how much the water
6 actually rose as it relates to the ground
7 between the time you took the -- or in the
8 time you took these two photographs.
9 A. I would say, Jon, that it's maybe a
10 little deceptive to know. And I will give you
11 this as a for instance. My recollection is
12 that the water level on the foyer doors would
13 have been similar to one another, front of the
14 building to back of the building. But here
15 you have cars parked up on the cement that
16 surrounds the Government Complex, and here you
17 have cars parked down in the parking lot.
18 Q. When you say "here", could you tell
19 about which picture you're --
20 A. Yes. The Exhibit 3 picture would
21 have been the actual -- the true parking lot
22 for the Government Complex building. And when
23 you exited the Government Complex building,
24 you walked down -- down a sloped kind of ramp
25 to get into the parking lot. So these are not
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1 -- they're not the same level kind of
2 pictures. The water was rolling in very
3 quickly and I can tell you how I know that
4 beyond seeing it with my eyes out in the
5 parking lot that the water level is, you know,
6 on a steady rise up and a very quick rise up,
7 was noting the level here on the doors,
8 realization that I had passed my office and
9 while the day before I had trustees take out
10 filing cabinets with all the Council records
11 from years and years and years past, which is
12 why the MRGO records are still around, they
13 brought them up to the second floor. I had
14 actually not cleared anything off of my desk,
15 which would have been current legislation,
16 current, you know, current action by the
17 Council. And so at this point, the
18 realization is this water is coming up,
19 seriously coming up very quickly, the doors
20 are not going to continue to hold the water,
21 we're going to have water in the building and
22 I have all of these files all over my desk
23 that are much more current than everything I
24 brought up, you know, the day before. And so
25 at that point I went in my office, grabbed a
Page 84
1 load of whatever I could grab off the desk,
2 went upstairs, I had some National Guards
3 folks to come down with me, and at that point
4 we made three to four trips down the steps
5 into my office, grabbing, running back up the
6 steps, depositing, and coming back down; and
7 each time we would come back down, I had on a
8 pair of my daughter's shorts, which I am not
9 sure how I ended up with those, but I'm glad I
10 did, it was -- it was ankle deep, then came up
11 on my calves, then up to knees; the last trip
12 I went down, second-to-last and last trip were
13 to get things out of Council members' offices,
14 I realized their college diplomas are hanging
15 on their walls, too. I had saved mine at one
16 of the trips with National Guards. We go in
17 theirs grabbing things off the wall. The last
18 trip down, I'm in rushing, and when I tell you
19 rushing water, very, very powerful water,
20 right to the edge of those -- of those shorts
21 to go into Mark Madary's office, because
22 that's where a very large historical painting
23 of Andrew Jackson was and I realized that on
24 the way up, "Oh, my gosh, Andrew Jackson's in
25 Mark's office" and it's -- it had been taken
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1 down because Council chambers were leaking and
2 we didn't want to destroy the picture. But
3 now I've got water up to mid thigh and realize
4 that Andrew Jackson is now floating in water
5 or his -- so I went down with two of the
6 National Guardsmen to get that -- that
7 painting, which takes six men to move it in
8 normal times, two of them and me, and I have
9 to literally hold the door back to keep it
10 open because water is rushing, let them go
11 through, then get around them to go to the
12 stairway doors to hold a door back so that
13 they can get the painting out the -- up the
14 stairwell. So I know it was moving very
15 quickly because I was in it. I felt it moving
16 and felt things rushing against my legs.
17 Q. How deep did the water get
18 eventually?
19 A. It was into the stairwell on the
20 second -- the second landing, and there are
21 different numbers that I have heard. 18 to 22
22 feet. I think 22 feet would have been closer
23 to the 40 Arpent. Where we were was probably
24 about 18, 18 feet. We watched at that point
25 from the second floor lobby, we watched in the
Page 86
1 hole of the, you know, the lobby. We all
2 stood around there watching -- watching the
3 water come up. At this point we were not --
4 we weren't dodging wind. You know, it wasn't
5 wind sounds. It was this rising water that
6 took full center stage.
7 Q. Did the storm, as best you know, get
8 to y'all at that point in time?
9 A. I think the storm had gotten to us
10 at this point. There was -- You know, it was
11 still not beautiful weather, but the worst of
12 the wind blowing was more Sunday night, Monday
13 morning, and then the -- the water coming up
14 seemed, in my mind, that had a complete life
15 of its own. That was -- didn't seem to be
16 surrounded or encased in this high wind, you
17 know, or accompanied by necessarily high winds
18 at that point. I think we had -- I think we
19 had experienced the passing of the, you know,
20 the major parts.
21 Q. And did you have significant rain on
22 Monday associated with the storm?
23 A. Through the night and Monday
24 morning, yes, but at this point I think you
25 can see there's not -- there's some rain, but,
Page 87
JOHNS, PENDLETON & ASSOCIATES
3/5/2008
1 I mean, nothing like some rainstorms that we
2 have certainly experienced since then where
3 you can't see -- where you can't see very far.
4 Q. But based on your experience in the
5 storm or in the events of that day, is it your
6 belief that the storm came and then the water
7 followed?
8 A. Yes. Yes. I would say that. There
9 were fringes of the storm, but the water was
10 -- I think a lot of people thought, okay, we
11 made it, you know, and then all of a sudden
12 here comes -- here comes this rushing water.
13 And rushing water. Not, you know, glug, glug,
14 glug, glug, glug like you're filling up a
15 bathtub.
16 Q. Was it like a wave?
17 A. I didn't see any crested, you know,
18 big wave. I think we all would like to see
19 pictures like that because I think that's what
20 helped damage my house significantly. But I
21 have never seen any pictures that indicate
22 that -- that look. And maybe they're there.
23 I have seen video footage from a fellow who
24 stayed in Lexington about halfway up the
25 subdivision. I was all the way in the back
Page 88
1 and I have seen his footage, and it really is
2 this kind of -- It's almost like the water's
3 -- just all of a sudden it's there and then
4 it's just rising as quick as you can think.
5 Q. What is his name?
6 A. Fabian Garro.
7 Q. And is that the footage that's on
8 the St. Bernard disk, that St. Bernard -- the
9 Garro family footage that you're talking
10 about?
11 A. Yes. It should be. I have a copy
12 of it at home. He is a Parish worker. He was
13 one of our coastal inspectors staying in his
14 or his wife's sister's home. They had a home
15 down the road, but, yes, where you see
16 Lexington, you see the shot all the way out
17 the end of Lexington and it's water as far as
18 your eye can see.
19 Q. Well, tell me about the photograph
20 that I have marked Exhibit 4. Just kind of
21 hold it up so the camera can see it. And then
22 tell me what is depicted in that photograph.
23 A. This -- This was a shot that I took
24 the next morning. This would be the 30th of
25 -- Once we went up on the roof of the
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1 building with daybreak and I took it from the 1 have conscientiously -- it would have been all
2 Government Complex roof facing the new 2 ready to go.
3 Wal-Mart. And also, because I wanted the 3 Q. The camera, the clock in the camera,
4 parking lot that I knew I had taken a picture 4 to the extent there is one, as reflected, but
5 of when the water was coming up. There were 5 will be reflected in the metadata, would be
6 three, I believe three buses and I have a 6 correct also?
7 picture of those buses as the water's coming 7 A. Sure. Right. Right. Right.
8 up. And then the next morning I have the 8 Q. Would you tell us what Exhibit 5 is?
9 buses completely submerged in water. And 9 A. This is a picture from also the top
10 this, of course, would not have been your 10 of the building. It was actually the first
11 highest water mark. This would have been a -- 11 picture I took on the morning of the 30th. A
12 you know, already settled -- the water was no 12 picture of the community playground which is
13 longer coming in at this point. It had come 13 in Torres Park directly behind the Civic
14 in at its highest peak and then it had gone 14 Auditorium. The building next door to the
15 down. That's what this picture would be. At 15 Government Complex. And will show you as you
16 this point the water was -- was -- The 16 look back beyond the park, this would be
17 direction of flow of the debris was all toward 17 Buccaneer -- Buccaneer North. Buccaneer
18 New Orleans. Very bizarrely so. It seemed 18 North.
19 very bizarre, that it was kind of flowing 19 Q. Buccaneer Villa?
20 upriver. You know, we -- my concept as a 20 A. Yeah, the Buccaneer -- It sustained
21 biology science person was it should have been 21 quite a few floods.
22 going downriver, but it was flowing back to 22 Q. Buccaneer Villa North?
23 the city. It was flowing to New Orleans. And 23 A. Right. Buccaneer Villa North.
24 you could see that as the debris passed the 24 That's what -- That's the angle of this shot.
25 building. 25 This is all from the roof.
Page 90 Page 92

1 Q. How long did -- Let me -- We'll get 1 Q. And how was the night of the 29th?
2 to that. This other photograph that I will 2 Did y'all spend the night on the roof?
3 mark Exhibit 5, which indicates in the 3 A. We did. It was very warm inside the
4 photograph it was taken on the 30th. 4 building and so we spent the night on the
5 A. Uh-huh (affirmatively). 5 roof. How was the night?
6 Q. Let me ask you about your camera. 6 Q. Yes.
7 When you got your camera, did you set the date 7 A. Was -- Was not the Hilton or any
8 in the camera? 8 other comfortable place. Chairs were brought
9 A. Yes. It would have been -- It would 9 outside, you know, through the -- up through
10 have been set prior to -- prior to any of 10 the stairwell onto that roof level because it
11 these events. 11 was so miserably hot inside. The coolest
12 Q. And do you have any reason to 12 place was to be outside. And folks walking
13 believe or think that the camera, that the 13 around trying to make cell phone calls and get
14 date in the camera is incorrect and does not 14 some kind of service somewhere on the roof to
15 correspond to the actual date? 15 get ahold of family, find out where they were.
16 A. No. I do not. I know that that 16 Q. Was there water in every direction
17 happens and I have -- I have a Disney picture 17 as far as you could see?
18 to prove it, because we went in February and 18 A. Yes, there was.
19 they say January. But at this point, no, the 19 Q. Did you feel like you were in a
20 camera had not -- not lost battery power or, 20 lake?
21 you know, it hadn't died down to nothing, 21 A. Felt like we were an island, yes.
22 whatever resets that clock. This was with a 22 Q. Were there any people in the Regions
23 fresh battery and, you know, leaving from 23 Bank building also?
24 home, knowing I am going to the Government 24 A. There were firemen in the Civic
25 Complex to ride out the storm. So I would 25 Auditorium and I know that they did -- they
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1 brought people additionally to Regions Bank. 1 was kind of the last -- the first to get wet,
2 So there may have been folks there. I don't 2 the last to get dry.
3 know that there were that rode out the 3 Q. When you got to your street, what
4 hurricane, but I know that they -- they 4 did you see?
5 brought some people in by boat. I remember 5 A. Very stark difference on the two
6 them talking about people getting out of the 6 sides of the street. The 40 Arpent side of
7 boats, getting into the Regions Bank building. 7 the street, the majority of those houses were
8 Q. How long did it take before y'all 8 completely destroyed. There were three or
9 got off the roof of the building? 9 four that still had structural walls, but most
10 A. Tuesday. Tuesday we left for the 10 were -- were --
11 ExxonMobil building because there were reports 11 Q. Just a slab?
12 that the water had already receded there. So 12 A. -- leveled. Slab, debris all over.
13 it was dry ground close to the river, and 13 A lot of their debris was blown into our
14 there was a decision to move -- to move the 14 houses which were on the side that faced the
15 seat of government from the Government Complex 15 40 Arpent.
16 building to the ExxonMobil building because it 16 Q. Does your street run parallel to
17 was no longer surrounded by water or 17 Judge Perez at that point or does it run
18 flooding. It was -- It was just damp, but not 18 perpendicular to Judge Perez?
19 -- not under water. 19 A. No, it's parallel to Judge Perez and
20 Q. Did the ExxonMobil building flood? 20 parallel to the 40 Arpent as well.
21 A. There was water in the first floor. 21 Q. So one side of the street would back
22 Not as high as our -- as our level. The 22 up to the 40 Arpent --
23 closer you got to the river, the lower the 23 A. Yes.
24 level of water there was. But there was 24 Q. -- and then one side of the street
25 water. It was very obvious when we got there 25 would be across the street from the 40
Page 94 Page 96

1 that they had sustained water. 1 Arpent.

2 Q. How long did the water remain in the
3 parish after the storm?
4 A. The next set of pictures I have are
5 the -- when I came back in. I left on
6 Wednesday to take out some elderly Parish --
7 Parish government family members and I did not
8 come back because it was not passable by
9 vehicle except the big, you know, big
10 vehicles. I didn't come back until the 15th
11 of September.
12 Q. September?
13 A. That's first time I came back to the
14 Parish. There were still parts that were
15 wet. My own house, it was the first time I
16 had been given the "Yes, you're going to
17 believe able to, you know, see your house. We
18 can get you to your house." It was still
19 muddy in the streets. You can see that in
20 some of the photographs. It was still wet.
21 You could see lines on the house of where the
22 water had stayed, you know, the water lines.
23 It definitely didn't just sweep on out. It
24 stayed for quite a while. Especially on that
25 side of the parish, the 40 Arpent side. It
Page 95
2 A. Would look across to the 40 Arpent,
3 and that's the side that we were on.
4 Q. What was the condition of your house
5 when you returned?
6 A. Definitely not livable. A large
7 part of it already gutted because water --
8 water had been in it for so long, the
9 sheetrock absorbed it all and it fell;
10 insulation fell to the floor of the house.
11 You couldn't walk into the floor. You had to
12 take a big step to get into the home, into our
13 home. It was amazingly damaged but still
14 standing I think was the biggest shock. You
15 looked across the street and these people have
16 nothing, and then I have a front door and, you
17 know, a lot of damage, but still had a -- I
18 still had a structure. Fine -- I found very
19 interesting things that make no logical sense
20 whatsoever, you know. A piece of my China,
21 Bombay tea service right outside my kitchen
22 door completely untouched, no damage, under
23 the mud. And go in the house and find big
24 pieces of furniture completely shattered.
25 Nothing, nothing left to them. Very, very
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POLLY BOUDREAUX
1 bizarre. One piece of furniture in the
2 backyard. Nothing else got out of the house.
3 And the piece had to float perfectly out of
4 the kitchen door to get into the backyard.
5 Very, very bizarre. Looked like somebody had
6 put a blender inside the house and just
7 churned and churned and churned it all up.
8 And then the furniture was all jammed to the
9 back of the house, which would have been the
10 direction the water came. It was all in the
11 hallway so you couldn't get to my son's and my
12 daughter's rooms except from outside the house
13 through the window.
14 Q. Did you lose a lot of stuff in the
15 storm?
16 A. I did. Yes. Salvaged some dishes
17 that I still use today. We actually use them
18 every day. We eat on China every day now. I
19 learned a new lessen about that. But we lost
20 a considerable amount. I think many of us
21 have realized today, having begun to put our
22 lives back together, that we lost more than we
23 thought we lost. It's difficult to value
24 things when you just don't even realize how
25 much you have and why you have it. But we
Page 98
1 kind of learn that every day. You go to look
2 for something, "Well, why isn't it in that
3 drawer? Where is the -- where is this holder,
4 and pot holder?" That was before the
5 hurricane. That's not now. And a lot of
6 realizations now about how much we -- how much
7 we lost.
8 Q. Do you think it'll ever be the same?
9 A. I do not. No. I am absolutely
10 convinced that it can never be the same. It
11 has already structurally, physically changed.
12 He have -- We have lost -- We have lost
13 community members that -- You know, I think
14 about kids that my children went to school
15 with that they will never see again. Not
16 because they died, but because they have had
17 to reestablish their lives somewhere else and
18 people that, you know, before -- I'm sorry --
19 before the hurricane you took for granted.
20 You know, you had next door neighbors. I
21 don't have next door neighbors now. I have a
22 slab. We had -- Thank you -- children that my
23 kids played with that are now growing up in
24 another parish and they won't play with them
25 again. They're all getting older and, you
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JOHNS, PENDLETON & ASSOCIATES
3/5/2008
1 know, they will go their own ways. Lots --
2 Lots of changes that guarantee that St.
3 Bernard Parish will never, ever be the same.
4 We lost community that day, and it's not to
5 say that, you know, we can't build the sense
6 of community. We're in the middle of
7 preparing to rebuild the community playground,
8 the one that I showed in the picture, and
9 while it's going to feel good, it's going to
10 make us all feel good to do it, the
11 realization every single day is you don't live
12 in the same place.
13 I am one of three people on my
14 street. Three. And that'll probably be it
15 for a long time. There are less than 40
16 percent returned in -- in probably one of the
17 most established subdivisions in St. Bernard
18 Parish. Lexington had just over 700 homes and
19 we have recently done a poll of our own. I am
20 the block captain of Florida Avenue, which is
21 no grand task with three people living on the
22 street. I can keep up with what's going on on
23 the street very easily. But we were each
24 asked to survey how many folks are living in
25 homes, how many are for sale, all these
Page 100
1 figures, and the bottom line is two and a
2 half, almost three years later we have -- we
3 have less than 40 percent return. He have no
4 guarantee for all the homes that sit empty
5 that should be demolished because there's no
6 market for them and then all the homes that
7 sit with for sale signs around our total life
8 investment, our home. And so can St. Bernard
9 ever be the same? No way. No way.
10 Q. Do you think the Mississippi River
11 Gulf Outlet still poses a danger to the people
12 who live currently in St. Bernard Parish?
13 A. I do. There's not been anything
14 that would change -- change what it can do,
15 what it -- the conduit it provides for water,
16 for rushing water. It alone was responsible
17 for a great deal of coastal erosion on our
18 living side, you know, our marsh side, our
19 buffer zone, and it's not to say that we
20 haven't lost a great deal of coast line
21 because of the storm and because of years of,
22 you know, I think neglect. But to
23 purposefully build something that creates more
24 damage makes absolutely no sense to an already
25 receding coast line.
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1 MR. ANDRY: 1 EXAMINATION BY MR. ANDRY:

2 Okay. I have no other 2 Q. Do you notice -- One other
3 questions. Thank you for coming. 3 question. Do you notice in your students that
4 THE WITNESS: 4 everybody has like an edge, or like a
5 Thank you. 5 post-traumatic stress type of feeling about
6 MR. FORBES: 6 them?
7 Would you like to take a break 7 A. We do. We do. I do, too. I don't
8 for a minute? 8 think, you know -- I didn't grow up with a
9 MR. LITTLE: 9 violent bent, you know, that I would react
10 Would you like a glass of water? 10 that way. But I definitely see that. I think
11 THE WITNESS: 11 it plays out differently in children the way
12 No, I have to go build a 12 -- the way they were raised. I watch my own
13 playground. I have to go to this 13 two who have been raised, you know, in a good
14 meeting. No, I'll be okay. 14 home life and a fairly sheltered home life,
15 MR. ANDRY: 15 and my son doesn't want to pack up and go to
16 This is like a normal event for 16 his grandparents' house because he's afraid
17 -- 17 I'm going to leave him, because that's what I
18 THE WITNESS: 18 did for many months, going back and forth
19 It's a tough reality to live 19 working at the Government Complex, bringing
20 with. I told the fellow today from 20 him -- going to visit him for a few hours,
21 New York, he said, "Y'all are really 21 leaving in the middle of the night so I
22 resilient." I said, "You know, Dave, 22 wouldn't have to handle New Orleans traffic,
23 I struggle with the fact that we're 23 and he is afraid if we go to their house, I'm
24 really resilient or we're really 24 going to drop him off and I am going to go
25 stupid, you know, to come back knowing 25 back to St. Bernard. Two and a half years
Page 102 Page 104

1 that we're not any more protected than 1 later that's still -- it's still an issue for
2 we were before. Why, you know, why 2 him.
3 did -- Why did we do it?" 3 MR. ANDRY:
4 People have asked me, "Why did 4 Okay. I don't have any other
5 you go back in back of Lexington?" I 5 questions.
6 said, "Because the front of Lexington 6 EXAMINATION BY MR. LITTLE:
7 got just as much water as the back of 7 Q. I just have a few. Miss Boudreaux,
8 Lexington. So if I am coming back, 8 I'm Keith Little representing the United
9 I'm coming back to my house. I'm not 9 States.
10 going to go to somebody else's house. 10 A. Okay.
11 You know, it makes no sense." 11 Q. Earlier you testified about the
12 But it is a very long road for 12 first time you saw water was in the parking
13 St. Bernard. And there's no 13 lot.
14 guarantee. Nobody can guarantee that 14 A. Uh-huh (affirmatively).
15 you're okay. You know, that your 15 Q. Okay. And I think you had testified
16 interests are protected, that your -- 16 that some other people told you or said that
17 you know, your investment is secure. 17 the water was coming from the city.
18 Who can guarantee that for us? 18 A. Well, from New Orleans. From that
19 The school system has seen a 19 direction. Uh-huh (affirmatively).
20 massive change in population and I'm 20 Q. Is that your basis of your knowledge
21 back in it and I can tell you that 21 of in what direction the water was coming
22 it's a scary thing. You know, folks 22 from, is what these people told you?
23 are mentally so stressed out and it 23 A. That -- That would have been
24 shows heavily in the kids, you know, 24 confirmation. You could see still at that
25 the students. 25 point in the pictures that you see here, you
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1 can see the direction just as I saw the next
2 morning, you could see the water flow back
3 toward the city. You could see the direction,
4 you know, the direction of the water outside
5 the -- I can't tell you that I watched as the
6 water came down the street for the first
7 time. It was already there when I looked at
8 it. But you could see the direction, the
9 direction of the flow. And whatever, you know
10 -- I know that water -- water changes its
11 direction based on what it runs into and so,
12 you know, I am scientifically -- You would
13 have to confirm that in other ways. But that
14 was my observation as, you know, being there.
15 Q. Okay. You also testified about a
16 proposed resolution or legislation that, I
17 think, that Mr. Rodriguez and the rest of the
18 Council members disagreed on?
19 A. Yes.
20 Q. Tell me what was that proposed
21 resolution again?
22 A. It was a -- one side offering a
23 resolution of support in regards to the MRGO
24 and the Port of New Orleans to preserve their
25 financial -- their financial interest in
Page 106
1 things, and I am sure you know that, a lot of
2 things that take place much prior to whatever
3 you see publicly in government and, you know,
4 in politics. A lot of things that go on. So
5 we would have no knowledge of what all and who
6 all had been in the formation of that letter
7 and that position.
8 Q. Do you remember about the time
9 period about when this is happening?
10 A. It would have been fairly early on,
11 because I remember we were meeting in the
12 Council chamber. Again, I have to go by bench
13 marks of -- But the letter is on file in the
14 office. It is definitely something that was
15 submitted at a Council meeting so it is record
16 of that meeting.
17 Q. And when you say early on, you mean
18 early on in your time as the Clerk? Is that
19 what you mean?
20 A. Early on in my -- This is -- I am
21 picturing the -- I have to picture the
22 building and picture what condition we were in
23 when we met in the Government Complex building
24 to remember him coming in. And I, without the
25 documentation, my forte is not -- That's why I
Page 108

1 keeping it open. It was some form of, you 1 take notes, so I can use those to reestablish
2 know, a watered down version I guess of a 2 specific dates and times. So I would have
3 closure as opposed to the Council's opinion 3 notes that would tell you exactly when that
4 that closure meant close -- close it off. 4 was. My memory is that it was right before --
5 Q. And which side did Mr. Rodriguez 5 right before the hurricane, Mr. Lagrange came
6 fall? What did he want? 6 if and there was a big show of -- I just
7 A. On the side of the Port of New 7 picture the -- And I don't know, Jon, if you
8 Orleans at that point. He has since rescinded 8 remember. I remember it being --
9 that, but we have -- I have documentation in 9 MR. ANDRY:
10 the office that shows that he was leaning 10 It was late September, early
11 toward that -- that agreement, and it caused 11 October after the hurricane.
12 quite an uproar among the citizens as well as 12 THE WITNESS:
13 the Council. 13 It was after? So he came in when
14 Q. Who else, if anyone, was leaning 14 we were like destroyed --
15 towards that, the idea of not closing MRGO? 15 MR. ANDRY:
16 A. I don't know any other -- any other 16 It was the meeting after in the
17 major players outside of the Parish President 17 destroyed area where everybody was
18 and the Port. I'm sure there were other -- 18 sitting in the windows because all the
19 you know, there were other folks. We had not 19 windows were blown out.
20 been privy to those meetings. It was kind of 20 THE WITNESS:
21 a surprise. This is a letter that Mr. 21 The Council chambers. Yes.
22 Lagrange and I, Mr. Rodriguez presented, you 22 MR. ANDRY:
23 know, had put together and the Council was 23 There were two meetings in the
24 outraged and hadn't been a part of any of the 24 Council chambers.
25 negotiation, whatever. There are a lot of 25 THE WITNESS:
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1 Because we met a few times there 1 when I write the closure of the MRGO, I
2 and then we went to the ECLU 2 understood after that that was still a very
3 (phonetics). 3 broad term. What exactly does "closure", you
4 MR. ANDRY: 4 know, does "closure" mean? And that was one
5 That's right, in the back. 5 of the discussions, that how are we going to
6 THE WITNESS: 6 define "closure", whose definition of
7 I remember going there for the 7 "closure" are we going to use? And you can
8 very heated meeting. And this was the 8 read that in the minutes of Council meetings
9 ugly -- We don't want to repeat, you 9 that this -- or the taped, audiotaped versions
10 know, those exchanges. They were very 10 of what does "closure" mean. "This is what I
11 heated exchanges and the public was 11 think 'closure' means" one Council member
12 allowed to speak. Many people came, 12 would say. "This is what so and so thinks or
13 you know, residents came to voice 13 the president thinks or outside agencies
14 their shock about anyone who would 14 think". So there was a great deal of
15 consider that -- that kind of an 15 discussion about what exactly that meant.
16 alliance. 16 Q. Pre-Katrina do you remember any
17 EXAMINATION BY MR. LITTLE: 17 local groups or citizen groups or community
18 Q. And so this proposed resolution that 18 groups or local government groups that opposed
19 we have been talking about, this occurred 19 the closing of MRGO?
20 post-Katrina? 20 A. That opposed the closing of the
21 A. Yes. They would have made -- They 21 MRGO?
22 would have made another -- There were -- There 22 Q. Yes.
23 were resolutions pre-Katrina, but this -- 23 A. I don't recall St. Bernard groups
24 there would have been a post-Katrina 24 that would have been opposed to -- opposed to
25 resolution that called for the immediate 25 that. My understanding is that the closure
Page 110 Page 112

1 closure of the MRGO.
2 Q. Well, what about the one that Mr.
3 Rodriguez --
4 A. That was a letter of support and it
5 never -- it never culminated in any
6 resolution, because the Parish President
7 cannot -- he can't enact a resolution. The
8 Council has to do that. So without their
9 support, he could only offer a suggestion or
10 proposal, you know, an agreement with the
11 Port. And the letter would, you know, would
12 give you that information. It would speak to
13 that directly.
14 Q. Do you remember Mr. Rodriguez having
15 a position before Katrina involving not
16 closing MRGO?
17 A. He had for many years been -- been
18 speaking against the MRGO. I think the gray
19 area is in -- And I didn't understand this
20 until after sitting through long discussions,
21 that closure of the MRGO has a lot of
22 options. You know, a lot of different
23 concepts. And until people begin to speak
24 about it openly or publicly you don't even
25 really know. You assume, you know, we're --
Page 111
1 was always an issue to those who had financial
2 interests along the MRGO, and that would have
3 been folks in the port, folks along the GIWW,
4 anybody who had businesses there who would be
5 adversely affected by an inability to use the
6 MRGO. They had consistently lobbied against
7 any closure.
8 Q. They did lobby the Council, and you
9 were the Clerk?
10 A. They lobbied the -- I never
11 witnessed them openly lobbying Council
12 members. I think that would have been a -- I
13 don't know. I did not witness that. I
14 witnessed several interchanges when we went to
15 Corps meetings post-Katrina where the folks
16 who had apparently been at meetings
17 pre-Katrina appeared to give their same
18 arguments about leaving it open and very
19 heated exchanges in those meetings from Mr.
20 Rodriguez, who at this point has dropped the
21 Port alliance and returned to his closure
22 position, and some very -- very heated barbs
23 between them about "You all have been lobbying
24 this for years. It's just your own financial
25 interest. It has nothing to do with the
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1 safety or the, you know, the welfare of the 1 Q. Okay. Have you done anything --
2 residents of St. Bernard. We have lost 2 A. No.
3 everything. What do you want to do to us 3 Q. Have you done anything beyond
4 now?" I do recall those, you know, those kind 4 turning this in?
5 of open exchanges in meetings at the Corps. 5 A. No.
6 Q. Okay. When you were a Clerk of the 6 Q. So you're not a party in a lawsuit
7 Council, did you ever deal with funding 7 in Federal court right now against the United
8 issues? Was that part of your job, any sort 8 States?
9 of funding issues related to MRGO? 9 A. Not that I know of.
10 A. The Council had no control in 10 Q. Okay.
11 funding issues related to them. And the only 11 A. These have been taken somewhere. I
12 thing they could have taken a position on on 12 have no clue. Nobody's told us what's
13 the Army Corps of Engineers' request for -- 13 happened to these papers. We haven't been
14 you know, for funding for a study or funding 14 given any update. Unless it's been on TV, and
15 for the height of levees, you know, the levee 15 I don't watch a lot of television.
16 height to be raised. They could have -- They 16 MR. LITTLE:
17 could have by resolution made a request, but 17 I think that's all I have. Thank
18 they had no -- they had no power in affecting 18 you very much.
19 that. 19 THE WITNESS:
20 Q. Did you or someone on your behalf 20 Okay.
21 file a claim against the Army Corps or the 21 EXAMINATION BY MR. FORBES:
22 United States dealing with Katrina? 22 Q. Miss Boudreaux, I have just a
23 A. Yes. 23 couple, just a couple of questions and I'll
24 Q. Okay. 24 try to keep them --
25 MR. LITTLE: 25 VIDEO OPERATOR:
Page 114 Page 116

1 What exhibit number are we on? 1 Microphone, sir.

2 MR. ANDRY: 2 EXAMINATION BY MR. FORBES:
3 6. 3 Q. You described I think your last
4 EXAMINATION BY MR. LITTLE: 4 awareness of exactly what time it was as being
5 Q. So this will be 7. Exhibit Number 5 9:00 to 9:30 when somebody said -- when you
6 7. Do you recognize that? 6 looked out -- Is that when you looked outside
7 A. Uh-huh (affirmatively). 7 and it was still dry at that time? When you
8 MR. FORBES: 8 and this other individual --
9 What was 6? 9 A. Mr. Henderson, the Council member
10 MR. ANDRY: 10 looking at the car, that's my recollection of
11 This should be 6. 11 time. But I am not -- I will not claim to be
12 MR. FORBES: 12 great at doing that.
13 This should be 6. 13 Q. You said you weren't wearing a
14 MR. LITTLE: 14 wristwatch?
15 Oh, this should be 6. Okay. 15 A. No.
16 Change that to 6. 16 Q. And so you did have a cell phone
17 EXAMINATION BY MR. LITTLE: 17 which would show time, but you didn't
18 Q. And is that the claim that you filed 18 necessarily look?
19 against the Army Corps? 19 A. I wasn't -- right. I wasn't opening
20 A. Yes. 20 and closing it at this point.
21 Q. And are you now part of a litigation 21 Q. But, I mean, are you relatively
22 beyond the claim against the United States in 22 confident of that 9:00 to 9:30 when you looked
23 court? Are you a party member? 23 out and it was really hard to close that door?
24 A. Meaning what? I have turned this 24 A. Uh-huh (affirmatively).
25 in. I don't know what that means beyond -- 25 Q. But the parking lot at that point
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1 was still dry? 1 A. Yes.

2 A. Right. On that side, at that point 2 Q. -- photograph Exhibit 2?
3 of the building we weren't looking at water. 3 A. Yes.
4 We were looking for wind damage to the windows 4 Q. Out towards Judge Perez?
5 of the cars. 5 A. Right. And at this point I wasn't
6 Q. Yes. 6 paying attention to trees any more. The water
7 A. Because that's my -- 7 kind of took over everybody's thought.
8 Q. Because you had heard that somebody 8 Q. Yes. And this would be after that
9 had lost windows, car windows? 9 9:00 to 9:30 estimate when you looked out and
10 A. Right. Had heard the windows blow 10 there was no water? This was afterwards when
11 out or seen the windows blow out. 11 there was water?
12 Q. When you looked out, was that door 12 A. Right. Right.
13 on the Torres Park or the Lake Borgne side? 13 Q. And do you have an estimate as to
14 A. No. It would have been between the 14 how long after? Would it be an hour or
15 foyers of the building. 15 something like that? I am just trying to get
16 Q. Yes, I understand there's a river -- 16 your best estimate, and I don't want you to
17 A. It would be here the side. 17 outright guess, but if you have an estimate.
18 Q. Okay. There's a river side -- 18 A. It would be an outright guess. I'm
19 A. Yes. So it's not -- It would have 19 just going to tell you. I am historically
20 been looking this direction with the river 20 known for not guessing things well. That's
21 this way (indicating) and Lake Borgne this way 21 why I take plenty notes. And I wasn't taking
22 (indicating). So I would be looking between 22 any notes at this point. I was -- I was
23 two buildings. 23 looking at all of it.
24 Q. Back up towards the city, if you 24 Q. Okay. Looking at photograph Number
25 will? 25 3, which is the one where you're looking out
Page 118 Page 120

1 A. No, towards St. Bernard.
2 Q. Looking sort of downriver?
3 A. Down -- Downriver, yes.
4 Q. Okay. Now, the photographs that you
5 showed us, it looks like the first one, the
6 first photo which I think is Exhibit 2, you're
7 looking out toward St. Bernard, towards Judge
8 Perez Drive?
9 A. Yes.
10 Q. Is that sort of what you might call
11 the -- In sailing, we have a windward side and
12 a leeward side. The wind hits on one side and
13 the wind goes away on the other side. Are you
14 looking at sort of the leeward side where the
15 wind is blowing away from you at that point?
16 Towards the river, if you will?
17 A. I am not going to claim any
18 expertise at that. I really am not. I
19 remember looking in the Council chambers where
20 we would -- we would have had a view of Judge
21 Perez and watching the trees blow, you know,
22 being blown very heavily downriver.
23 Q. Downriver. And the Council chamber
24 windows would be looking in the same direction
25 as --
Page 119
1 the other end of the foyer, which is what we
2 might call the Lake Borgne, or the back side
3 of the building or the Lake Borgne side?
4 A. Uh-huh (affirmatively).
5 Q. It looks like -- It looks to me like
6 you've got more waves there and the wind is
7 kind of blowing towards that side. Is that
8 fair to say?
9 A. That it's flowing --
10 Q. Kind of towards that side.
11 A. I don't -- I mean, I -- It -- Again,
12 I am going to say because of the building,
13 because of the things around it, that I don't
14 know that you're getting a true sense of what
15 the water -- what the water is doing beyond
16 unaltered, you know, unhindered.
17 Q. Yes.
18 A. I don't think you can say that.
19 Because there were several -- There was a big
20 TV news truck here and so I would expect you
21 to have water -- you have water that swirls
22 regardless of which direction it's coming
23 from. It's not science.
24 Q. Okay. I was just trying to figure
25 out, you know, you have a side from which the
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1 weather is coming and the wind, and the side 1 that turn coming up. It may still be marked
2 from which it's not coming. 2 today.
3 A. And you cert- -- The picture is the 3 Q. So you're talking about just above
4 picture. So to -- I am not going to be your 4 the landing where you would turn and reverse
5 best person to remember, and I just have to 5 direction going up?
6 apologize. It's not my -- 6 A. Right. Right.
7 Q. But that was your view looking out 7 Q. And that's marked now? So you don't
8 toward Lake Borgne about, correct me if I am 8 have to remember it?
9 wrong, five to ten minutes or so after you 9 A. Right. Right. And again, that
10 took the one out the front door? 10 building was, you know, from pictures that I
11 A. Right. Right. Not a lot of -- Not 11 had of its original build, it's built in the
12 a lot of lapsed time. And it's not pointed 12 middle of the marsh, what was formerly a
13 directly at Lake Borgne. It's actually a -- 13 marsh, the whole area. I have a picture in my
14 This is toward the Super Wal-Mart 14 office, or did, of the Government Complex in
15 (indicating). The Lake Borgne would have been 15 construction and you see the cypress trees
16 (indicating) straight back this direction. 16 literally all around it. It was just a big
17 Q. Yes, you're pointing straight -- 17 marshy area. So it was -- it was built up,
18 looking straight out the door. 18 you know, out of -- up out of that marsh.
19 A. Yeah. I'm kind of taking -- I'm 19 Q. Okay. Well, I won't ask you too
20 more taking it on an angle -- 20 much about the heights of the government
21 Q. Okay. 21 building because I think it's still there and
22 A. -- toward -- headed toward my 22 we can look at them.
23 office. 23 A. Okay.
24 Q. Let me ask you a little bit about 24 Q. And I don't want to ask you too much
25 water heights. You said, you mentioned 18 to 25 about your house, because I know it's a
Page 122 Page 124

1 22 feet in the government building. Are you 1 difficult subject, but I know we all kind of
2 starting at zero right where the bottom of the 2 know now what the elevation of our houses are
3 door is? 3 in relation to sea level. Do you happen to
4 A. I am repeating a number that was 4 know what yours is?
5 said by other folks, so I don't have -- I 5 A. I am --
6 couldn't give you, you know, a marking or -- 6 Q. Are you like zero or are you minus 1
7 Q. At the height of the water, you were 7 or plus 1?
8 up on the second floor? 8 A. No, I think I'm plus 1.
9 A. Uh-huh (affirmatively). 9 Q. Plus 1?
10 Q. And is there a balcony? 10 A. Yes. The builder built them all at
11 A. No access to the first floor. 11 least a foot off of ground. They're up, up
12 Q. Is that sort of a balcony that looks 12 higher. You step up into the house, so I am
13 down on the foyer? 13 pretty sure it's a plus 1.
14 A. Uh-huh (affirmatively). Uh-huh 14 Q. So the ground might be zero and then
15 (affirmatively). 15 your floor might be plus 1?
16 Q. And from there could you kind of 16 A. Uh-huh (affirmatively).
17 tell how many steps from your floor was the 17 Q. Is yours a one story house in the
18 maximum height of the water? 18 photo?
19 A. I know that it's marked in the 19 A. Yes.
20 stairwell of the Government Complex. It was 20 Q. Do you have like eight foot ceilings
21 to the second -- the second stairwell, you 21 or nine foot or what?
22 know, the turn. You come up the first landing 22 A. I believe nine foot ceilings, and
23 -- 23 the water level was -- the visible water
24 Q. You turned -- 24 level, because you have -- you don't have your
25 A. -- and then go up, and it was on 25 -- I don't know how you gauge that initial,
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1 but the resting line -- 1 Q. Yes.

2 Q. The highest water line you could 2 A. Uh-huh (affirmatively).
3 see, was it -- 3 Q. I'm actually looking at a chart and
4 A. Was two feet in the attic. 4 I know what you mean. Was that part of your
5 Q. Two feet into the attic? 5 Sunday night ride?
6 A. Yes. 6 A. Uh-huh (affirmatively).
7 Q. So it would have been nine plus two? 7 Q. And is that where you went first?
8 A. Plus the one of the slab. 8 A. That's the direction we went first,
9 Q. Plus one. 9 yes.
10 A. Right. 10 Q. Okay.
11 Q. Okay. 11 A. Down Paris Road and to Chef Highway.
12 A. So 12, 13 feet I am guessing. 12 Q. And you went across Paris Road and
13 Q. I hate to keep asking you about time 13 then up to where?
14 since this is probably not your strong point 14 A. To -- It's Chef -- Is it Chef
15 from what you said. 15 Menteur Highway that goes to the locks? If
16 A. No. No. 16 you go toward --
17 Q. But did you have a sense of when the 17 Q. Yes. You went toward -- Did you go
18 waters had finally ceased rising in the 18 toward Chef Pass?
19 government building and started to recede or 19 A. Yes.
20 at least held level? 20 Q. Towards Fort McComb?
21 A. No, I remember watching it, I 21 A. Towards the -- Yes. Not toward the
22 remember Bob Turner giving us his best guess 22 city.
23 of where the line was going to finally stop, 23 Q. Yes. Okay.
24 where it was going to stop, where it was going 24 A. The other way.
25 to stop, and -- 25 Q. You went east, towards Mississippi?
Page 126 Page 128

1 Q. Did it stop sort of just a little 1 A. That may sound unintelligent, but
2 bit above that turn-around landing on the 2 that's not my --
3 stairs? Is that -- 3 Q. And then where did you turn around?
4 A. Yes. In the foyer it would have 4 A. We turned around at the locks
5 been -- the ceilings are rather high, but it 5 themselves --
6 would have been below -- It didn't come into 6 Q. Okay.
7 the level of the, you know, the second floor, 7 A. -- and came back. We didn't see any
8 which is a fairly thick separation, but it 8 water there.
9 didn't come into that. It stayed -- stayed 9 Q. Was that the Bayou Bienvenue locks
10 below -- you know, all the way up I guess to 10 you're talking about?
11 almost ceiling level of the first floor. 11 A. No, no, no. No, that's not what
12 Q. All right. If I go a little bit out 12 that's called. Bayou Bienvenue locks I think
13 of order, it's just because I made little 13 are in the --
14 notes in the margin because I guess I am a 14 Q. They are.
15 note taker, too. 15 A. Bayou Bienvenue going into MRGO.
16 You mentioned the green bridge. 16 Q. Yes.
17 Is that the bridge, for our benefit, is that 17 A. No. These are the locks on -- It's
18 the Route 47 Paris Road bridge where it passes 18 on Chef Menteur headed out toward -- Oh, I
19 over the Intracoastal Waterway -- 19 don't know. I would have to ask Joey. I'm
20 A. Yes. 20 sure it was Chef Menteur Highway and before
21 Q. -- going towards the north? 21 you get to -- what's all these people have
22 A. Right -- I guess right -- right 22 camps?
23 beyond or above where the MRGO meets the 23 Q. Route 90?
24 Intracoastal. They kind of Y -- Y into one 24 MR. ANDRY:
25 another. 25 By Downman Road? Or Haynes
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1 Boulevard? 1 School. So before we got to that Violet --

2 THE WITNESS: 2 over the -- that crossing, we turned in to St.
3 There are locks there? I don't 3 Bernard High School site, which was a shelter
4 know. 4 of last resort.
5 EXAMINATION BY MR. FORBES: 5 Q. Before you left the government
6 Q. Irish Bayou. 6 center on Tuesday, sounds like Tuesday
7 A. I don't know. There was no big sign 7 afternoon when you went over to ExxonMobil, --
8 that said "You are here." 8 A. Uh-huh (affirmatively).
9 Q. All right, look. I don't want to 9 Q. -- did you go by boat?
10 ask you something -- 10 A. Yes.
11 A. There's something that they can 11 Q. By the time you left had the water
12 close. 12 started to recede inside the government
13 Q. I don't want to ask you something -- 13 building or was it holding steady or what?
14 A. Right by railroad tracks or 14 A. No, it had -- it had started
15 something, they can close it up. Out on Chef 15 receding, I think. It was -- It was
16 Highway. I'm pretty sure. I would have to 16 definitely receding, and I guess another
17 call Joey to find out. 17 marker of that, we weren't going in the
18 Q. And then I take it you went back and 18 building itself. Like I wasn't going in that
19 you went over, back over the -- 19 stairwell. There was no reason to, because
20 A. The bridge. 20 you weren't going out through the bottom
21 Q. -- Route 47, Paris Road or green 21 floor. We went out of a window, down a ladder
22 bridge and went back into the parish? 22 to a -- the in-between walkway between the
23 A. Yes. To -- 23 government building and the Council chambers,
24 Q. Then you went on down -- 24 and that's where we got into the boat from,
25 A. To Judge Perez and we headed east. 25 from that -- from that walkway. But I did
Page 130 Page 132

1 Q. Judge Perez all the way down to 1 several trips on boat and can tell you that
2 where the next big highrise crosses the Violet 2 even in that span of time, we would go down
3 Canal? 3 Judge Perez to Paris Road; fire trucks would
4 A. Yes. We went beyond that. 4 back -- a fire track would back as far as it
5 Q. And then you went a couple of miles 5 could back on Paris Road from St. Bernard
6 until you got to that left turn that takes you 6 Highway; the boat would go as far as it could
7 out to Yscloskey? 7 go until it started scraping the concrete, the
8 A. The new extension, Judge Perez new 8 roadway, and you'd have to walk the distance.
9 extension, and we went further past that. 9 You would have to split that, you know, split
10 Q. Okay. And you went out there until 10 that distance. And so you could tell that the
11 you felt that you were getting too close to 11 water was going down by how far the boat could
12 real water? Or did you see water? I mean -- 12 go the next time, you know, the next trip you
13 A. Uh-huh (affirmatively). 13 were in it.
14 Q. -- was there water on your road or 14 Q. Sunday night when you were feeling
15 did you get as far as Shell Beach or how far? 15 that strong, strong wind, you were in Lynn
16 A. We got to wherever Jack Stevens' 16 Dean's office, which way -- did you have
17 house is. You could see -- We could see his 17 windows on just one side?
18 house, but you couldn't continue on the road 18 A. It's a corner office.
19 to his house because the water was already -- 19 Q. Corner office?
20 was already up there. 20 A. So the windows are on all sides of
21 Q. And then I take it you returned from 21 his walls. His two walls here. They're
22 there the same way you went down and went back 22 outside walls.
23 to the government building? 23 Q. Which side?
24 A. Well, we -- we returned the same 24 A. The windows --
25 route, but we stopped at St. Bernard High 25 Q. Which side were you -- were your two
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1 walls facing? 1 when I lost battery power. At that point it

2 A. Okay. This wall (indicating) is 2 was, you know, an overwhelming kind of
3 Torres Park. Lake Borgne. 3 experience and we were stuck in a building.
4 Q. That would be what we call the back 4 Q. In your neighborhood, your house,
5 side or the Lake Borgne side? 5 the front of your house faced the 40 Arpent
6 A. The back side. This wall 6 Canal; can you tell or did anyone tell you if
7 (indicating) is between the Government Complex 7 water came over the top of the 40 Arpent
8 and the Civic Auditorium. So it's in between 8 Canal?
9 those two buildings. Kind of looking 9 A. I was told that it did, that it
10 downriver. 10 breached that, the 40 Arpent, you know. The
11 Q. Okay. Okay. 11 pictures from the fellow who was there midway
12 A. Did I do that right? 12 up in the neighborhood towards Judge Perez,
13 Q. Yes. Well, no, I mean, I can't tell 13 his -- his video camera indicates that, you
14 you, but I understand what you said. 14 know, the water -- nowhere else it would have
15 A. It's between the two, so it's 15 come from. It had to come over that 40
16 looking down -- downriver. 16 Arpent.
17 (Whereupon a discussion was held 17 Q. And there's like debris patterns
18 off the record.) 18 that shows that the water came that way?
19 EXAMINATION BY MR. FORBES: 19 A. Uh-huh (affirmatively). Certainly
20 Q. You said your batteries ran out in 20 the furniture in the house all shoved to the
21 your digital camera at some point? When was 21 back of the house I think will tell you that
22 it? Because it looks like the last photo you 22 the impact was there and then that's where it,
23 took was on the morning of the -- that we saw 23 you know, it stuck.
24 here was the morning of the 30th. 24 Q. How about behind the government
25 A. Yes. I have no -- no pictures of 25 building? I know you go a little further
Page 134 Page 136

1 riding in the boat from Government Complex to 1 before you got to the 40 Arpent Canal, but do
2 the ExxonMobil building. I have no pictures 2 you know or did anyone tell you whether the 40
3 of ExxonMobil. 3 Arpent Canal got overtopped in that area as
4 Q. Do you have more photos on the 29th 4 well?
5 besides the two that you have here from the 5 A. I wouldn't have seen any evidence of
6 government building? 6 that. I'm sure there are folks who knew, you
7 A. Yes, I do. I have pictures in my 7 know, which -- who had -- We had -- We had a
8 office with things, an ice chest was already 8 crew of Public Works employees who were at our
9 beginning to float. 9 yard on Paris Road and so they would have --
10 Q. And -- 10 they would have a much better story of what
11 A. Two Parish working standing there. 11 they saw water-wise. We were -- We were
12 I have another picture of the boyfriend of one 12 closer to Arabi, Ninth Ward; we would have
13 of the Parish workers bringing a dog up the 13 seen water from that direction, you know, I
14 stairwell and you can see all the water, you 14 guess first. They would -- They would have a
15 know, behind him. 15 much better indication of where they saw that
16 Q. And are those photos that you will 16 water coming from.
17 make available to Mr. Andry? 17 Q. In that same vein, you mentioned
18 A. Yes. Yes. 18 that one of the Council members went upriver
19 Q. Okay. 19 -- up towards the city on Judge Perez in a
20 A. And those would have been pictures 20 vehicle with a National Guardsman and they
21 before I panicked about what's in the office 21 basically got caught by water and sort of
22 and then started doing the up and down, up and 22 stranded.
23 down, and I can't even tell you from doing up 23 A. Uh-huh (affirmatively).
24 and down, up and down, where the camera was 24 Q. Do you know what time that was or
25 after that, you know, for a while. If that's 25 how you heard about it?
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1 A. I knew that he left, because I 1 home.

2 wasn't happy that he had left. That he 2 Q. 2003?
3 thought there was a lull in the storm, the 3 A. Uh-huh (affirmatively).
4 eye, it must be the eye, "We're going to find 4 Q. Where did you live immediately
5 this fellow's grandfather." But I cannot tell 5 prior?
6 you -- I can't tell you the time. 6 A. In Belle Chasse.
7 Q. Did he leave while the parking lot 7 Q. In Belle Chasse?
8 was still dry outside of the building? 8 A. Uh-huh (affirmatively).
9 A. Uh-huh (affirmatively). Uh-huh 9 Q. Have you ever lived in the Ninth
10 (affirmatively). Yes. 10 Ward?
11 Q. So before you -- 11 A. No.
12 A. He saw the water coming down the 12 Q. And then at your current address,
13 street. 13 did you ever see street flooding like during
14 Q. Okay. So he left while it was still 14 the heavy rain?
15 dry around the government building? 15 A. No. No.
16 A. Uh-huh (affirmatively). 16 Q. You had mentioned Hurricane Cindy or
17 Q. Okay. And so that would have been 17 Tropical Storm Cindy.
18 before that 9:00 to 9:30 estimate at least of 18 A. Tropical storm, uh-huh
19 yours? 19 (affirmatively).
20 A. (Witness nods head affirmatively.) 20 Q. Did you see any flooding at all
21 Q. Okay. 21 during that storm?
22 A. If I am right. 22 A. No. Very high winds. I had water
23 Q. Yes. Okay. And do you know at 23 in my house, not because it came from the
24 least in rough terms how long afterwards it 24 street. Because the wind was blown almost
25 was that -- because did they call back or 25 completely horizontally and literally dripping
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1 radio back to tell anybody what happened? 1 from halfway on my door down. It was very
2 A. No, we didn't -- When did I see him 2 bizarre. The same thing in the windows. It
3 again? It was -- It wasn't even -- It wasn't 3 was driving the water through the cracks in
4 that same day. It was the next day before we 4 the window casings.
5 saw Mark. So we didn't have any communication 5 Q. And did you have any standing water
6 with him or many -- many other living people. 6 after that?
7 MR. FORBES: 7 A. In the streets? No. No. Uh-uh
8 I think that's all the questions 8 (negatively).
9 I have. Thanks for your time and 9 Q. And the winds that you have
10 patience. 10 described during Hurricane Katrina, those were
11 THE WITNESS: 11 I assume stronger than the ones you just
12 Okay. Thank you for your Kleenex 12 described for Tropical Storm Cindy?
13 or handkerchief. It reminds me of my 13 A. Yes. Now, the sense of it, I need
14 dad. 14 to tell you, is very different when you're in
15 MR. FORBES: 15 a home, your own home. I am sure I would have
16 You're welcome. 16 -- I would have a lot more trauma attached to
17 EXAMINATION BY MS. MCPEAK: 17 Katrina had I been in a home to hear those
18 Q. I have just a few questions. Again, 18 winds. We were in a very, very heavily
19 my name is Agnieszka McPeak and I represent 19 concreted building, so the sound was the wind
20 the Washington Group and I have just a few 20 rushing through, you know, thick glass as
21 follow-up questions for you. 21 opposed to Cindy, literally we felt the whole
22 A. Okay. 22 house move. It felt like it was picking the
23 Q. How long had you lived at your 23 house -- the roof of the house up and putting
24 current address on Florida Avenue? 24 it down. I had my children in the bathtub.
25 A. Since 2003 we have been in that 25 That's how unbelievable the winds were in that
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1 tropical storm. It was a very frightening
2 experience. I can only imagine anybody going
3 through the Katrina sounds, because they were
4 significantly higher winds. But my -- my
5 judgment is very, you know, very different
6 because of the kind of building that I was
7 in.
8 Q. And what sort of damage did you have
9 to your house after Cindy?
10 A. I had water that came in through
11 several windows and wet the sheetrock. Water
12 that came in through the door. It broke the
13 -- It broke the gate of my backyard,
14 literally just laid it -- laid it flat. It's
15 the last picture that I have of my home before
16 Katrina. I took a picture on the way out just
17 in case, because the wind was still blowing
18 when I left to go to the government building.
19 So I have one picture of this -- at mine. So
20 it was water and then you had fence damage to
21 the gate.
22 Q. And were you in that house during
23 any other storms beyond Tropical Storm Cindy?
24 A. No. No. It was never my pattern to
25 stay close. Especially if they called it a
Page 142
1 as you had described, where exactly were you?
2 In what direction were you looking?
3 A. I would have been in the Council
4 chambers looking toward the Mississippi River.
5 Q. And which direction were the trees
6 bending from that vantage point?
7 A. My memory is first bending downriver
8 and then as the wind direction changed -- at
9 -- at some point there was a significant wind
10 change, wind pattern change, and at that point
11 the glass began shattering. And, in fact, the
12 glasses there did shortly after. I was not in
13 the room when they did, but everyone came
14 flying out of that room because the -- those
15 windows were shattering with wind.
16 Q. And was that before you saw standing
17 water outside?
18 A. That would be my best guess, yes.
19 That there was glass damage to that area, not
20 in our lobby. Those glasses didn't -- we
21 didn't actually have shattered glass there. I
22 think it broke the door, the doors in, to come
23 into the building.
24 Q. Okay. And you described on Monday
25 morning when you were in -- was it Mr. Dean's
Page 144

1 hurricane. I was never around to go through 1 office? Where you had stayed that evening?
2 that. 2 A. Yes, Monday early morning, uh-huh
3 Q. Sure. I understand. Now, you had 3 (affirmatively).
4 described at one point when you were in the 4 Q. And you had described that the
5 government building being on the second floor 5 toilet seat was wet and that there was water
6 and looking out and seeing the wind bending 6 coming in?
7 trees. 7 A. Uh-huh (affirmatively).
8 A. No, that would have been the first 8 Q. Were you able to see out the window
9 floor. You can't see that on the second floor 9 at that time?
10 because of these corrugated whatever they're 10 A. They're very, very high windows.
11 called. 11 Very high.
12 Q. With the way the glass was for 12 Q. And are you aware of whether there
13 visibility? 13 was any water outside rising at that point?
14 A. Its -- It goes the outside of the 14 A. No, there wouldn't have been any
15 glass. It's bolted into the building to 15 water. That was very, very early that
16 protect the glass from shattering and also 16 morning.
17 rendering your vision very clouded. 17 Q. Okay. And then when you first saw
18 Q. So from the second point -- from the 18 water, you had mentioned going downstairs and
19 second floor vantage point, your visibility is 19 seeing the water, describe for me your
20 greatly limited? 20 impression of what direction the water was
21 A. Very distorted, right. You wouldn't 21 going.
22 -- Unless you were looking at a hole, you 22 A. In the building, at first it was not
23 wouldn't see clearly at all. 23 going anywhere. It was seeping in. So it
24 Q. Okay. And when you were on the 24 would just have been at the floor. We
25 first floor and you saw the wind bending trees 25 wouldn't have really seen movement. It was
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1 kind of filling up. The water was all on the 1 A. Uh-huh (affirmatively). Uh-huh
2 outside. So my only indication of a direction 2 (affirmatively).
3 is looking out of the windows and seeing 3 Q. Do you know if that was a wind
4 whatever it is, wind blowing, water, you know, 4 claim?
5 water direction; and my recollection is that 5 A. Sure. Let me think to that side.
6 it was coming from, you know, coming from the 6 It was -- They tried to say that it was all
7 city direction-wise. But inside the building, 7 water damage, so my argument with the
8 until -- until those doors were completely 8 insurance adjustor was what happened to, you
9 breached in different parts of the building, 9 know, external features. Why are boards blown
10 you know, there wasn't really a direction. It 10 through the roof and fencing down, and that
11 was just kind of seeping, seeping, and then 11 wouldn't have been water.
12 all of a sudden, you know, the big surge of 12 Q. So you did visually observe wind
13 water because the doors were breached. 13 damage to your property?
14 Q. So you were in the foyer looking out 14 A. Yes. And you can see them in the
15 the doors. And can you give me an idea of 15 picture. I have significant portions of the
16 sort of where you were standing and where you 16 roof that are off and bare two by fours that
17 were facing at that point? 17 are blown through the -- through the roof
18 A. Two different ways as the pictures 18 which would have come from the inside of
19 show. One looking out toward the direction 19 houses that were, you know, completely wiped
20 toward the Mississippi River and the other 20 out on the other side of the street. And
21 would have been looking out of the entrance 21 that's my -- my own, you know, guesstimate.
22 side of our building, which would have been 22 I'm not a weather expert either. But from
23 looking toward the Lake Borgne direction, the 23 being there, I know that there was significant
24 40 Arpent, Lake Borgne. 24 wind and water and, you know, there's still
25 Q. Okay. But you have no way of 25 some wind with the water, but the wind damage
Page 146 Page 148

1 knowing that this water was coming from the 1 -- or the wind, you know, the wind strengths
2 city? 2 were very strong prior to the water.
3 A. I'm -- I'm not a -- I can't be an 3 Q. And I only have a few more
4 expert to tell you that other than what I -- 4 questions. I wanted to ask you a little bit
5 what I saw it doing. 5 about some of the pictures that you took. You
6 Q. I only have a few more questions. 6 mentioned that your camera -- that you took a
7 In your neighborhood, you 7 photo that was on August 30th in the morning?
8 mentioned one neighbor who described his 8 A. Uh-huh (affirmatively).
9 experiences. Did you speak to any other 9 Q. When did your camera battery die,
10 neighbors who had stayed in your neighborhood 10 just to clarify?
11 during the storm? 11 A. It would be sometime on the 30th.
12 A. No. There was another gentleman who 12 Q. It would be on the 30th?
13 was there and who actually had called one of 13 A. Those are the last pictures I have.
14 our Council members asking for help. He was 14 I have a few others of Council members
15 in an attic halfway, you know, more toward 15 standing on that roof, on one of our first
16 Judge Perez, but I have never spoken to him 16 meetings on the roof, and our OEP Director
17 personally about that experience. And most of 17 attempting to make a -- to make a call on a
18 the folks that I lived around were long gone. 18 radio to get some communication, and I have
19 There were very few left. There were very few 19 one picture I think inside the building of our
20 people left in the neighborhood. There were 20 State representative and a Council woman
21 people, but not folks that I have spoken 21 attempting to fix their faces, you know, clean
22 with. 22 up before they emerged up on the roof. But
23 Q. Now, you did describe a lot of 23 that would have all been on the 30th.
24 damage to your home. Did you file an 24 Q. Okay.
25 insurance claim in relation to that damage? 25 A. I don't have anything once we left
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1 that building. I didn't have any more power, 1 A. Well, I have been able to see the
2 battery power. 2 map. It's I guess right beyond where the Y
3 Q. Now, for the pictures that you 3 is. When you see the picture, you will see
4 described from Sunday night when you were 4 that there's not a real definite shape to the
5 driving, you had mentioned that there was 5 -- to that channel, canal. It's definitely
6 already water when you reached Mr. Stevens' 6 a, you know, -- It's been filled over, spilled
7 house? 7 over. So it doesn't have its typical shape or
8 A. Uh-huh (affirmatively). 8 definition, bank definition.
9 Q. Where exactly is his house? 9 Q. And then at that point were there
10 A. Fort Beauregard, Fort Proctor. 10 any roads flooded in that area near MRGO when
11 MR. ANDRY: 11 you were driving?
12 It's Fort Beauregard, which is by 12 A. No. Not on anything that we were
13 Shell Beach? 13 on, no, there weren't.
14 THE WITNESS: 14 Q. Okay. Now, did the Parish keep any
15 Fort Beauregard. I don't go 15 official logs of damage due to rain or storms
16 there a whole lot. So I have been a 16 generally?
17 few, but -- 17 A. The administrative portion of
18 EXAMINATION BY MS. MCPEAK: 18 government would have had to keep any record
19 Q. But to get to his house then did you 19 of damages that were -- that were claimed by
20 drive down Paris Road on your way -- Was it on 20 government for FEMA reimbursement. So in any
21 your way back? 21 storm there's a record -- they would have a
22 A. No, Judge -- Yeah, after we came 22 record. It's not a duty of the Council. They
23 back from the trip over the bridge, we drove 23 would have a record of, you know, where limb
24 down Judge Perez to the lower end of the 24 are down, trees are down, where the debris has
25 Parish. 25 to be cleared, because it's all FEMA
Page 150 Page 152

1 Q. Okay. And what did you see when you 1 reimbursable expenses.
2 reached -- when you were approaching his house 2 Q. And is there a record of parts of
3 or approaching that area? 3 the Parish that traditionally flood during
4 A. Water in places where it typically 4 heavy rain, to your knowledge?
5 is not. You know, the waters down in the 5 A. Yes. I am not sure if the -- I
6 eastern end of the Parish can rise when the 6 don't know how that's -- how that's kept.
7 wind change and blows, you know, I guess 7 That's, again, not something that would fall
8 against the flow of the water. You will see 8 under the Council -- you know, under our
9 the water rise. And this was water already 9 purview. But there were -- there were areas
10 coming up significantly that night before. 10 that flood -- flood records or insurance
11 Q. Were there -- so you saw visible 11 records would have indicated claims and, you
12 flooding in that area? 12 know, in certain areas due to street flooding
13 A. Yes. And understand, those are 13 or whatever, storm, rainfall, that would
14 homes that are built significantly off the 14 indicate those. And I think that's part of
15 ground. They're outside of the levee 15 FEMA, too, and I think there's an acronym for
16 protection area. So it's street -- the street 16 the division that handles that. But they have
17 flooding that you're going to observe at that 17 records of your -- you know, of your insurance
18 point. 18 claims to determine where there's been
19 Q. Now, from that Sunday night drive 19 flooding previously.
20 you mentioned looking out at the MRGO and you 20 Q. And are there similar records for
21 said that the water was already overflowing? 21 Katrina-related flooding?
22 Is that correct? 22 A. Oh, I'm sure, yes.
23 A. Uh-huh (affirmatively.) 23 Q. And then just a few final
24 Q. What exactly did you see when you 24 questions. Have you ever been interviewed by
25 looked at the MRGO on Sunday night? 25 an attorney or by the media relating your
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1 experiences during Hurricane Katrina? 1 VIDEO OPERATOR:

2 A. Yes. 2 I have to change tapes. Off the
3 Q. What sort of media interviews have 3 record. It is 6:36.
4 you been involved in? 4 (Recess.)
5 A. For Katrina experiences, 48 Hours 5 VIDEO OPERATOR:
6 for the nursing home case. With -- Let me 6 Returning to the record, it's
7 think. The Discovery Channel did a feature 7 6:37.
8 show following one of our Council members 8 EXAMINATION BY MR. FORBES:
9 around and also interviewed me as the Council 9 Q. I just have one or two follow-up
10 Clerk. Let me think. We -- We had pictures 10 questions. During Hurricane Rita, which I
11 recovered in our home by -- by Extreme Home 11 think was the 21st or the 22nd of September,
12 Makeover. They didn't actually redo a home. 12 did your neighborhood take water again? Or
13 They came down and found pictures, restored 13 did it stay dry?
14 pictures, so there was some -- not -- not a 14 A. My neighborhood did not. It was
15 lot of actual events and, you know, more about 15 Arabi and upper Chalmette that took water
16 the losses, but they would have done 16 again in Hurricane Rita.
17 interviews about -- and I think that's -- I 17 Q. So your subdivision stayed dry?
18 think that's it. If I have left something 18 A. Uh-huh (affirmatively).
19 out, it's memory loss, it's not from -- It's 19 Q. What about the government building?
20 not from -- 20 Did that take additional water during --
21 Q. Sure. Have you ever given any 21 A. Yes. I was not there when that --
22 photos to the media? 22 when Hurricane Rita -- that was when I was
23 A. Whoever has -- Whoever's come in 23 traveling back and forth to come in to work
24 asking for information or whatever, we had 24 and they asked me not to come in until that
25 visually, we have provided either photos that 25 had passed. So I can't tell you I saw it, but
Page 154 Page 156

1 I had or that our government -- our TV access 1 yes, I was told it reflooded.
2 studio director, you know, film that he took. 2 Q. Did you learn at any point from
3 And these are not, you know, not actually 3 someone as to how high it had come up in the
4 photos taken with a government camera, but my 4 foyer from the floor?
5 -- my purpose serving as a Clerk of Council 5 A. In the Government Complex building?
6 was serving the public and folks who came in 6 Q. Yes.
7 to ask. So I can't tell you -- I don't know 7 A. It wouldn't have -- It wouldn't have
8 that I could remember exactly who. I know 8 rivaled the Hurricane Katrina levels at all
9 quite a number of people have seen the photos, 9 but I know it did come up. I know I was told,
10 but they have not -- I couldn't remember -- I 10 but I would be guessing to tell you two or
11 couldn't tell you right now how many may 11 three -- two or three feet there.
12 actually have copies of them. 12 MR. FORBES:
13 Q. And you mentioned that you were 13 All right. I think that's ALL I
14 deposed in relation to a nursing home case 14 have. Thank you.
15 after Katrina? 15 THE WITNESS:
16 A. Yes. 16 Okay.
17 Q. Have you participated in any 17 MR. ANDRY:
18 depositions after Katrina besides that one? 18 I don't have any questions.
19 A. No. No. That's the only one. 19 You're finished.
20 MS. MCPEAK: 20 THE WITNESS:
21 Then that's it for me. Thank 21 All right.
22 you. 22 MR. FORBES:
23 MR. FORBES: 23 Thank you.
24 Jon, before you wind up, could I 24 VIDEO OPERATOR:
25 ask one or two? 25 This concludes this deposition.
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1 It is 6:38. 1
2 * * * 2 REPORTER'S CERTIFICATE
3 3
4 4 I, ROGER D. JOHNS, RMR, RDR, CRR,
5 5 Certified Court Reporter, do hereby certify
6 6 that the above-named witness, after having
7 7 been first duly sworn by me to testify to the
8 8 truth, did testify as hereinabove set forth;
9 9 that the testimony was reported by me in
10 10 shorthand and transcribed under my personal
11 11 direction and supervision, and is a true and
12 12 correct transcript, to the best of my ability
13 13 and understanding; that I am not of counsel,
14 14 not related to counsel or the parties hereto,
15 15 and not in any way interested in the outcome
16 16 of this matter.
17 17
18 18
19 19
20 20 ROGER D. JOHNS
21 21 CERTIFIED COURT REPORTER
22 22 STATE OF LOUISIANA
23 23
24 24
25 25
Page 158 Page 160

1
2 WITNESS'S CERTIFICATE
3
4 I, POLLY CAMPBELL BOUDREAUX, read or have
5 had the preceding testimony read to me, and
6 hereby certify that it is a true and correct
7 transcription of my testimony, with the
8 exception of any attached corrections or
9 changes.
10
11
_____________________
12 (Witness' Signature)
13 ____________
DATE SIGNED
14
15 DEPONENT PLEASE INITIAL ONE:
16
_____ Read with no corrections
17
18 _____ Read and correction sheet attached
19
20
DATE TAKEN: MARCH 5, 2008
21
22
23
24
25
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33:8,13 34:24 administering 107:11 111:10 75:14 79:9,11 113:18
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accurately 21:17 121:4 123:9,14 ampitheater 80:5 56:25
accustomed 123:15 125:16 48:25 April 20:19,19 associated 7:18
25:23 128:2,6 131:13 Andrew 85:23 Arabi 76:2,8 87:22
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action 1:7 17:18 138:10,16,20 2:5 6:17 7:10 Arabia 9:14 111:25 141:11
84:16 140:3,8,19 7:13 61:21 Arceneaux assumed 44:23
actions 39:17 145:3,7 148:1 62:4 77:9,21 15:10 16:6 63:21
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activists 13:19 150:8 151:23 105:3 109:9,15 area 19:2 49:4 attach 60:7 61:5
15:4,5,16 156:18 109:22 110:4 51:22 52:6 61:7,17 78:11
activities 20:22 aforementioned 115:2,10 71:14 72:2 attached 28:20
activity 70:18 5:5 129:24 135:17 73:6 74:25 60:10 141:16
actual 28:20 afraid 104:16,23 150:11 157:17 79:10,11 80:15 159:8,18
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94:1 Agent 43:14 8:19 32:4 152:10 attendance 42:8
address 61:14 Agnieszka 2:21 40:17 areas 26:9 62:13 57:19

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attended 31:23 24:16,23 29:10 2:6 42:18 58:22 better 50:8

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ATTORNEYS 69:10 71:13 bathroom 62:25 BENDER 4:15 24:13,14 129:9
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audiotaped 85:5,6,7 86:9 141:24 benefit 127:17 33:17 52:5
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20:10,11 23:22 Baronne 1:24 23:23 39:22 160:12 blond-haired

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35:7 boxes 32:21 33:2 72:10 73:7,9 call 14:2 37:20 card 60:17,18
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5:11 chosen 37:8 114:6 154:10 85:3,7 87:3 committee 10:22

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concludes control 36:10,11 72:17,17 149:14,20 cursory 29:25

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JOHNS, PENDLETON & ASSOCIATES 800 562-1285