Professional Documents
Culture Documents
Page 1
UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF LOUISIANA
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.
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
Page 2 Page 4
2 (Pages 2 to 5)
JOHNS, PENDLETON & ASSOCIATES 800 562-1285
POLLY BOUDREAUX 3/5/2008
3 (Pages 6 to 9)
JOHNS, PENDLETON & ASSOCIATES 800 562-1285
POLLY BOUDREAUX 3/5/2008
1 A. St. Bernard High School for 14 and a 1 so was a whole slew of new Council members and
2 half years. And then I moved to the central 2 Parish President, Junior Rodriguez.
3 office and worked there for six and a half. 3 Q. So when you were sworn in, Junior
4 Retired from the School Board office in 199- 4 was the Parish President. And then who were
5 -- I have to really think. In 19- -- 2003 5 the Councilmen?
6 and took the position as Clerk of Council and 6 A. Council members at that time sworn
7 was serving there at the time of Katrina and I 7 in in '04 would have been Mark Madary, Judy
8 served there until just this past fall when I 8 Hoffmeister, Kenny Henderson, Craig Tafaro,
9 went back into the school system to regain a 9 Rickey Mellerine, Joey DiFatta, Lynn Dean.
10 little of my sanity. 10 There were seven. Five districts and then two
11 Q. And when you were Clerk of Council, 11 at-large positions.
12 could you describe what that job entails? 12 Q. Did any of those Council members, or
13 A. It's a very large job. It requires 13 did they serve from '03, excuse me, from '04
14 the management of the affairs of the seven 14 through the time of Hurricane Katrina?
15 elected officials who serve St. Bernard Parish 15 A. Uh-huh (affirmatively). Yes, that
16 as government leaders, and my position was 16 would have been the sitting Council. We were
17 all-encompassing, from writing legislation to 17 all sworn in at the same time in '04.
18 making sure legislation was posted 18 Q. And as the Clerk of Council, did you
19 appropriately, the correct amount of time, 19 have any job dealings with regard to the
20 advertised, given public hearing notices, 20 Mississippi River Gulf Outlet?
21 putting agendas together, coordinating daily 21 A. I had been through a number of
22 schedules, committee meetings; a very, very 22 meetings that included discussion about the
23 large job. 23 Mississippi River Gulf Outlet. I had been
24 Q. And you held that job from 2000 to 24 asked to pull legislation that had been
25 200- -- 25 enacted in the years prior to my taking that
Page 10 Page 12
1 A. 2003. And I am not a really good 1 position, the years since the Council form of
2 number -- number person. 2 government which began in 1992, and had access
3 Q. Just approximate. 3 to a great number of files in my office that I
4 A. I can do math, but I have to go 4 inherited by virtue of my position, quite a
5 backwards and try to remember. My -- My -- 5 number of very large folders full of
6 2003, we built a community playground and by 6 information about the MRGO and committee
7 that fall I was courted very heavily to assume 7 meetings that had been held in years past. So
8 the position of Clerk of Council. Myra 8 I had a working knowledge of the issues of the
9 Kattengell who had been there for 12 years was 9 MRGO by virtue of my position.
10 retiring due to medical issues and so they -- 10 Q. And what was the working knowledge
11 they came looking for me to come fill that 11 that you possessed pertaining to the
12 position. So I had been in right at the end 12 Mississippi River Gulf Outlet by virtue of
13 of 2003 as the Clerk of Council. So still 13 your position?
14 kind of a baby when the hurricane hit, 14 A. My -- My understanding of it grew
15 government experience-wise. 15 tremendously in the time that I became Clerk
16 Q. So you were the Clerk of Council 16 of Council. Prior to that, I had worked in
17 from the fall of '03 -- 17 St. Bernard for all of my professional life
18 A. Uh-huh (affirmatively), until just 18 and had heard the cries against the MRGO; knew
19 this past fall, which is '07. 19 several of the community activists who had
20 Q. Through the fall of '07? 20 spoken against it. Had even had one of them
21 A. Uh-huh (affirmatively). 21 come speak to my biology class at St. Bernard
22 Q. Who was the Parish President at the 22 High School, but didn't really understand the
23 time? 23 full impact of the -- of the body itself, the
24 A. In '03 it would have been Charlie 24 body of water itself; had not actually ever
25 Ponstein and then in '04 when I was sworn in, 25 been in it and didn't even realize as I went
Page 11 Page 13
4 (Pages 10 to 13)
JOHNS, PENDLETON & ASSOCIATES 800 562-1285
POLLY BOUDREAUX 3/5/2008
1 over the green bridge, which is no longer 1 be provided to St. Bernard citizens, and the
2 green, but we all still call it the green 2 realization in 2002, 2003, 2004 was in fact
3 bridge, that that's where it was, that that 3 that it had never provided any substantial
4 was the MRGO I was going over. And know that 4 amount of jobs to the parish. That it had
5 for many folks, kids even, that you heard 5 continued to grow in size, had continued to be
6 about it, but you really had no clue where it 6 dredged to depths that Mr. Dan Arceneaux was
7 was. So when I took the position, I became 7 constantly coming before the Council to speak
8 much more aware because of all of the interest 8 against the authorized depths. What depths
9 and the outcries against it, and actually took 9 were actually needed and that it was a major
10 my first trip in the MRGO shortly after taking 10 cause of erosion of land for St. Bernard
11 the position of Clerk of Council. Somebody 11 Parish marsh, protective marsh for the parish.
12 felt I needed to see it if I was going to be 12 Q. Did you ever hear that F. Edward
13 in meetings about it. I needed to understand 13 Hebert used to say that the Gulf Outlet was
14 it. 14 going to turn St. Bernard into the industrial
15 Q. Was that Junior? 15 frontier of the Gulf South?
16 A. That took me in it? 16 A. Yes. Yes. I think that that's in
17 Q. Yes. 17 print as well and I would assume in several of
18 A. No, actually it wasn't. It was one 18 the files that currently reside in the Council
19 of my playground construction guys that says, 19 -- Council office and Council possession.
20 "You're not going to understand any of this 20 I'm sure that you can find that. Yes.
21 stuff unless you see it" and took me in a boat 21 Q. And what dealings did you have with
22 to see it, and I was in absolute awe at the 22 the Gulf Outlet as Clerk of Council?
23 size of it. I don't -- Literally on our back 23 A. I am not sure.
24 door, doorsteps, and I think most of us just 24 Q. As far as did you -- what matters
25 lived our lives completely oblivious of how 25 came before the Council when you were the
Page 14 Page 16
1 close proximity it was to our homes. 1 Clerk of Council pertaining to the Gulf
2 Q. Let me go back a little bit. The 2 Outlet, if any?
3 cries against the Mississippi River Gulf 3 A. Let's see if I can remember from
4 Outlet you mentioned by community activists, 4 early -- early on in my young government
5 who were the community activists that cried 5 career. There -- I remember an issue very
6 out against the Mississippi River Gulf Outlet? 6 early on, and I want to say that it was on the
7 A. The names that I remember and recall 7 Gulf Outlet, Mr. Dan Arceneaux came asking for
8 very consistently were Don Duplantier, who was 8 speed limits to be set so that there were not
9 a fellow biologist, naturalist. Pete Savoye, 9 -- and by not just the large ships, but any
10 Mr. Dan Arceneaux. Those are three, the three 10 kind of vessel that would cause additional
11 big names that I really remember. I know Mr. 11 erosion, and I believe we passed that at some
12 Rodriguez was in that number as well. Prior 12 point, something requesting that speed limits
13 to his position as Parish President, he had 13 be enforced along the MRGO if I am remembering
14 been part of that cry against it. 14 correctly.
15 Q. What were the cries against it that 15 Q. So that was a resolution as passed
16 you heard from the community activists? 16 by the Council to impose speed limits on the
17 A. They -- They seemed to always be -- 17 Gulf Outlet so as to reduce wave wash?
18 I don't know that "grounded" is the word or 18 A. Reduce wave action and erosion.
19 "based in". The fact that the MRGO had been 19 Yes. There were several pieces of legislation
20 sold as a bill of goods, if you please, to the 20 that called for the immediate closure of the
21 parish of St. Bernard as a means of job -- 21 MRGO. We had a number of very long debates
22 increase in jobs for St. Bernard Parish. You 22 about exactly what it meant to close the
23 know, if we build this, this shortcut, we 23 MRGO. Was it reducing it to pleasure traffic
24 build this waterway, that there will be a 24 or fishing traffic as opposed to closing it
25 great increase in the number of jobs that can 25 completely for any vessels to come up the
Page 15 Page 17
5 (Pages 14 to 17)
JOHNS, PENDLETON & ASSOCIATES 800 562-1285
POLLY BOUDREAUX 3/5/2008
1 MRGO. Did it mean fill in the whole thing in 1 "You're showing us what's going to happen to
2 or just blocking it off and allowing it to 2 New Orleans, but we're the St. Bernard Chamber
3 fill in on its own. We had hours and hours of 3 of Commerce. What's going to happen to St.
4 discussion about that among Council members 4 Bernard?" And he admitted then that there
5 prior to the passage of a, you know, piece of 5 were severe issues for St. Bernard and that
6 legislation that would say "We wholeheartedly 6 had just not been a part of their modeling.
7 support the closure of the MRGO." There were 7 That they hadn't shown it, I guess fleshed it
8 several pieces passed during -- during that 8 all the way out for St. Bernard, and that they
9 tenure of Council. 9 were working on that part of it and would be
10 Q. And did the Council pass resolutions 10 happy to come back to show us that. And he
11 during your tenure as Clerk of Council urging 11 didn't have to come back, because we got to
12 the closure of the Gulf Outlet because it was 12 experience it all by ourselves in person.
13 a conduit for storm surge which would flood 13 Q. Was that Professor Mashriky?
14 St. Bernard Parish or cause damage to St. 14 A. Mashriky, yes. Yes.
15 Bernard Parish? 15 Q. And did you, in your capacity as
16 A. I don't remember that they were 16 Clerk of Council, have any dealings with the
17 specifically geared to being a flood conduit. 17 Hurricane Pam exercise, which was the
18 I know it spoke specifically of the great 18 simulated hurricane that I think they did in
19 destruction of coastal land, marsh land that 19 April or -- somewhere in '04, April to
20 had taken place over the years. I do know 20 November of '04?
21 that just prior to -- actually just prior to 21 A. We had -- I do remember going
22 Hurricane Katrina we had -- we had been 22 through activities led by our OEP director and
23 through a few mock experiences. LSU came in, 23 I guess the -- it was mostly OEP director,
24 and another -- another firm had come in, and 24 Larry Incajolia (phonetics) and a little bit
25 we had gone through a workshop as well with 25 by Tommy Stone, just behind the Council
Page 18 Page 20
1 simulations of what would happen to the New 1 chambers. We went through some exercises and
2 Orleans area were there to be a hurricane that 2 I was asked to be the represent- -- the
3 came, you know, up that direction. I have -- 3 Council representative at, you know, at that
4 Q. Is that the Hurricane Pam exercise? 4 -- those particular exercises, and it's very
5 A. I am not sure if it was Pam or -- It 5 possible that the name was Pam. I remember
6 may have been -- It may have been a spin-off 6 the name, the Hurricane Pam exercises, but I
7 from Pam; then they began to come down 7 was thinking that ours was called something
8 locally, you know, to local groups. My most 8 else. But --
9 vivid memory is -- was actually a presentation 9 Q. Were you aware or did you ever hear
10 that -- and I should remember his name, 10 of the term "The Mississippi River Gulf Outlet
11 because he's been a big name since the 11 Task Force"?
12 hurricane. The LSU professor who, he spoke to 12 A. That was not an active body that I
13 the St. Bernard Parish Chamber of Commence 13 know when -- when I took the position. I
14 just before the hurricane, just within the 14 didn't attend any of those particular
15 last couple of months before the hurricane and 15 meetings. I know that that task force had
16 showed these models and kept showing the 16 been in existence, but I would not be able to
17 models, you know, what would happen, what 17 accurately tell you. It was not an ongoing
18 would happen. And when it was over, having a 18 committee when I took office that I remember.
19 science background and being a little more 19 Q. Do you know what happened to the
20 inquisitive than I guess most people about 20 Mississippi River Gulf Outlet Task Force?
21 science issues and biology issues, it had a 21 A. Do I know what happened? No. I
22 great rendering of what New Orleans was going 22 could -- I could venture a guess based on some
23 to face, but somehow the map never did show 23 of the committees that we had enacted while I
24 what St. Bernard was going to endure. And I 24 was there and people just get busy and tied up
25 raised my hand and asked that question, 25 and, you know, kind of fizzles out. I am not
Page 19 Page 21
6 (Pages 18 to 21)
JOHNS, PENDLETON & ASSOCIATES 800 562-1285
POLLY BOUDREAUX 3/5/2008
1 A. Yes. That would have been -- If I 1 me, "You're now in the MRGO," I really -- my
2 had my records, I could flip right to it. 2 picture of it had been some small channel. I
3 Q. Say right after the storm? 3 mean, I grew up in -- or graduated from high
4 A. Right after. And they fashioned a 4 school in Belgium and canals there, you know,
5 letter of language that didn't necessarily 5 are rather small. It's only wide enough for a
6 support what Council members believed to be 6 barge to go in it, and I think that's what my
7 the closure, the true closure of the MRGO. It 7 picture was, was just this little, you know,
8 seemed to be more a deal that would protect 8 barge kind of canal. And we got into that
9 the financial interest of the port as opposed 9 thing and it is absolutely massive. I mean,
10 to the complete concern of the safety and 10 you look at it and think this is not a canal.
11 welfare of St. Bernard Parish. It caused a 11 This is not even a river. It is huge, you
12 major outcry, a major rift among Council 12 know. Obviously it has eaten and eaten and
13 members and the Parish President, and was not 13 eaten away at the land in order to be so, you
14 supported by the Council. It resulted in 14 know, so big. And I remember -- I remember
15 another piece of legislation that spoke 15 being upset at that point, thinking all of
16 against any form of leaving the MRGO open. 16 those years I taught biology at St. Bernard
17 And I do recall that very vividly there were a 17 High School and I could have been bringing
18 lot of not nice words and very heated 18 kids -- I brought them all over to field
19 argument, not just by the government 19 trips, south Louisiana. Never once brought
20 officials, but by those who -- those from the 20 them on a field trip in the MRGO in St.
21 public who had been able to make their way 21 Bernard Parish, and I certainly could have.
22 back to St. Bernard who were just outraged 22 There was nothing that limited me from doing
23 that anybody could -- could believe it needed 23 that. But I think we had grown so accustomed
24 to still be here, you know. That there was 24 to it being there that you just took for
25 any way to justify it financially. 25 granted where it was and what it meant, and
Page 23 Page 25
7 (Pages 22 to 25)
JOHNS, PENDLETON & ASSOCIATES 800 562-1285
POLLY BOUDREAUX 3/5/2008
1 had more -- more people been brought in a boat 1 resolutions and get very little to no response
2 in the middle of it, there would have been a 2 from anyone. And I remember not even knowing
3 larger public outcry that this is crazy. 3 if I was sending it to the right person. Who
4 Q. Let me ask you, tell me about the 4 am I supposed to send it to? Nobody's given
5 trips that you took on the Mississippi River 5 me a, you know, a direct contact that I can
6 Gulf Outlet with Corps personnel. 6 send it to, that this -- you know, this very
7 A. Those were mostly to show off the 7 strong resolution about closure needs to go to
8 new levees that had been repaired and the 8 the Corps of Engineers and they're a massive
9 areas where the -- around the locks where the 9 business. Who did do you send it to?
10 water had eaten during the hurricane, had 10 Q. Would the letters and correspondence
11 breached those -- the big support bulwarks I 11 that was sent -- And I take it that you sent
12 guess on either side of the locks. The water 12 that letter as Clerk of Council, it would have
13 had run and really damaged the levees there. 13 been on behalf of the St. Bernard Parish as a
14 So we were -- we were there to see the new 14 legislative body; is that correct?
15 work and, you know, see the glory of repair. 15 A. Absolutely. Yes. Yes. It would
16 Q. But would it be fair to say that all 16 have been a copy of -- you know, "Forwarded is
17 of the trips with the Corps personnel were 17 a copy of the resolution passed by the St.
18 post Hurricane Katrina? 18 Bernard Parish Council on such and such a date
19 A. Mine? Yes. I would have to very 19 requesting a complete closure of the MRGO" and
20 carefully remember and I don't have any of -- 20 then attached would be the actual resolution
21 When you leave a government position, you 21 itself, an official copy of that resolution
22 leave all of your stuff. So I would need to 22 would go in to -- to the Corps.
23 reflect on whether or not we had taken a trip 23 Q. Did you ever come across or see any
24 prior to -- prior to Katrina. And I want to 24 responses by the Corps of Engineers to the
25 say we did, because I remember there being two 25 scathing resolutions that you forwarded to the
Page 26 Page 28
1 boats and Council being upset because they 1 Corps on behalf of the St. Bernard Parish
2 didn't get on the first boat. It's crazy how 2 Council?
3 you remember things based on the political 3 A. No, nothing that would have
4 underpinnings at the times at the time, and 4 addressed the nature of -- of the content of
5 that's what I am trying to remember when. I 5 the resolution. There may have been "Thank
6 think that was -- that was prior to the 6 you, he have received -- you know, it's
7 hurricane. It was a -- It was kind of a 7 forwarded here." We would also send it -- I
8 pleasant trip, if I remember, you know, like 8 was always directed to send those to our
9 we're going to see, we're going to look, and 9 legislators as well, and so they would get a
10 not -- not a let's go look at repair, damage 10 copy and sometimes I would get a response back
11 after, is my memory. But I would -- I would 11 from Mary Landrieu's office saying they had
12 need to look through some things to refresh 12 been noted and received and "Thank you for
13 that. 13 your continued interest in this issue" kind of
14 Q. From the time you took office as 14 correspondence.
15 Clerk of Council in '03 to before Hurricane 15 Q. Did the Council or did you on behalf
16 Katrina, were there ever any Corps personnel 16 of the Council send correspondence to any of
17 that would come to the Council and talk about 17 the Louisiana Congressional delegation
18 the closure of the Mississippi River Gulf 18 regarding closure of the Mississippi River
19 Outlet? 19 Gulf Outlet prior to Katrina?
20 A. Nothing with any frequency. Nothing 20 A. Yes. They would have been cc'd on
21 that would make me -- Maybe one meeting out of 21 the correspondence to the Corps is typically
22 any of the ones -- That was always an issue, 22 what would happen. It would go to each of
23 that they were very difficult to communicate 23 those offices as well as Senator Landrieu and
24 with. And we would send, you know, scathing 24 Senator Vitter at the time.
25 resolutions or very strong language 25 Q. And other than a cursory response of
Page 27 Page 29
8 (Pages 26 to 29)
JOHNS, PENDLETON & ASSOCIATES 800 562-1285
POLLY BOUDREAUX 3/5/2008
1 "Thanks for your interest", did you receive 1 Q. What is a PACE meeting?
2 any, as the Council, did the Council receive 2 A. Parishes Against Coastal Erosion.
3 any formal response dealing with those 3 Q. Okay. And go ahead with your
4 resolutions on closure of the Gulf Outlet that 4 answer. I'm sorry.
5 was a substantive response? 5 A. That's okay. My memory, without
6 A. I do remember, after the hurricane, 6 looking at anything, is that it was just prior
7 receiving them from, especially from Senator 7 to the hurricane that I pulled how many times
8 Landrieu's office. Prior to the hurricane we 8 the Council, since the Council form of
9 may have had one from her that directly spoke 9 government, had made some kind of request or
10 to that issue and this is a concern to me, you 10 demand concerning the MRGO.
11 know, a little bit more than just the "Thank 11 Q. Are those documents still in the
12 you for your" -- "Thank you for your piece of 12 files of the St. Bernard Parish Council?
13 paper" kind of response. And those would -- 13 A. When I left them, yes. I can't
14 those responses would be on file now, because 14 vouch for them since last fall, but they
15 I didn't lose any of my records. They would 15 should -- they should all be there, yes.
16 still be in the MRGO files in my office -- not 16 Q. And are you aware of any other
17 my office any more. My used-to-be office. 17 documents pertaining to the history of the
18 They would still be there. So that's 18 Mississippi River Gulf Outlet that would have
19 certainly something that, you know, could be 19 been maintained by St. Bernard Parish?
20 looked at, could be researched. 20 A. There were -- There were -- There
21 Q. But tell me what type of documents 21 were several boxes of old files upstairs on
22 -- Was one of your job duties as Clerk of the 22 the third floor that I recall the name being
23 Council to maintain the documents and 23 written on and it may have been "Task Force".
24 correspondence historically for the 24 It was some committee that was -- that was
25 Mississippi River Gulf Outlet or pertaining to 25 going on years ago that I don't have any
Page 30 Page 32
1 the Mississippi River Gulf Outlet? 1 personal recollection of. I just remember
2 A. Absolutely. Three or four large -- 2 that the boxes were there. And there may have
3 large bulging files that I would not take a 3 been down -- downstairs, not far from my
4 shred of paper out of. Only went through it 4 office in the government building, there was
5 to find -- At one point, and I -- Again, I 5 -- there was a vault where a lot of the
6 will apologize I don't remember that it was 6 Council records were kept. And that would
7 just prior to the hurricane or right after. I 7 have included committee minutes and tapes from
8 was asked to look back in those files to find 8 many years past. And while I was able to save
9 every -- every piece of legislation. It was 9 some of those the day before -- It was on
10 unfortunately not -- had not been a practice 10 Saturday, pulled up a good deal of those, I
11 before I came of putting all -- putting 11 did not take everything and at that time took
12 everything on -- 12 things that I had found to be very helpful or
13 Q. Disk? 13 very important and we were not able to bring
14 A. In searchable format, right, that 14 it all up. So there may have been -- there
15 you could just go back in and type "MRGO" and 15 may have been a couple of boxes down in that
16 see how many times it had been brought up. So 16 vault, but I don't -- I don't know how much.
17 I physically had to go through the files and 17 That would have been MRGO. It was a big issue
18 pull anything that I saw. And I really think 18 and there were definitely boxes upstairs.
19 that was just prior to the hurricane. Mr. Dan 19 There were files in my office. There were I
20 Arceneaux wanted it to bring to one of the 20 am sure at least one box of files in the vault
21 meetings he was going to, either a PACE 21 as well.
22 meeting or a Corps meeting that he was 22 Q. And wasn't there a significant group
23 attending. He attended them rather regularly 23 of documents that we took and had restored and
24 and, you know, always spoke out in behalf of 24 provided back to St. Bernard Parish?
25 St. Bernard. 25 A. Yes. Yes. Absolutely.
Page 31 Page 33
9 (Pages 30 to 33)
JOHNS, PENDLETON & ASSOCIATES 800 562-1285
POLLY BOUDREAUX 3/5/2008
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
10 (Pages 34 to 37)
JOHNS, PENDLETON & ASSOCIATES 800 562-1285
POLLY BOUDREAUX 3/5/2008
1 for us and we began making some decisions of 1 and when it reached St. Bernard Parish, it
2 who -- who was going -- and I say "we", I am 2 actually hit us with much greater than
3 not a decision maker, I'm the recorder and, 3 tropical force winds. It was actually a very
4 you know, keeping notes and doing what I am 4 frightening experience and nobody was gone.
5 asked to do for the government officials. 5 You know, everybody was home. Lots of trees
6 Q. Let me go back just a little bit. 6 had -- tree damage, limb damage, a lot of
7 Where did you live at that time? 7 electricity went out, and I had been called at
8 A. I lived on the last street in 8 probably 3:00 o'clock in the morning and told
9 Lexington subdivision. So my front door 9 I needed to put my kids in the car and get to
10 looked at the 40 Arpent, which looked at the 10 the Council office because they needed me
11 40 Arpent Levee, and then the marsh and then 11 there. And so I did. I drove up to the
12 the MRGO. 12 office. They had Army cots for the kids to
13 Q. Okay. And who were you living with 13 sleep on and I began to field many phone calls
14 at the time, or who lived with you at the 14 that were coming in at that point.
15 time? 15 So because of that experience and
16 A. The same people I live with today. 16 the necessity of having somebody there to
17 My two children, my daughter Sophie and my son 17 answer calls and to relay information to
18 Alex, who are almost 11 and 14 now. 18 Council members, because Council and
19 Q. Okay. And when Hurricane Katrina 19 administration are two very separate entities,
20 was coming and it was the Friday before the 20 legislative versus administrative.
21 storm, what did you do with your son and your 21 Q. Administrative, you mean --
22 daughter while you were tending to Parish 22 A. The Parish President's office.
23 business? 23 Q. -- Mr. Rodriguez's office?
24 A. Going to plenty meetings. It was a 24 A. Yes. Versus the Council office.
25 naturally occurring weekend for them to be 25 Q. And the Councils office.
Page 38 Page 40
1 with their dad, and I had to make some phone 1 A. So that Friday, sitting in one of
2 calls to kind of speed up the exchange process 2 the meetings, I looked at a few of the Council
3 with them and get them -- go pick them up 3 members that were there and I said "I know
4 quickly, get them to his wife so that they 4 what happened during Cindy. Aren't we going
5 could take them on for the weekend and I could 5 to expect the same kind of response for the
6 get back to the next meeting that was being 6 hurricane that's coming?" And so at that
7 called that evening. So they didn't go -- 7 point I was named mandator- -- essential
8 They did not leave with believing that 8 personnel, meaning that I was going to stay
9 anything was going to happen. They left like 9 through the event. The first time ever.
10 a regular weekend, which meant very little 10 Clerk of Council had never stayed, never been
11 things went with them, very few things. 11 considered essential personnel prior to that.
12 Q. Where does their dad live? Where 12 But I was -- I was made essential personnel
13 did he live at the time? 13 then. And so Saturday was more meetings and
14 A. At the time he lived in Morgan City, 14 kind of back and forth to the house.
15 in Berwick. 15 Q. And with the meetings, who
16 Q. And tell us what you did and what 16 participated in the meetings on Saturday?
17 actions you took beginning on Friday before 17 A. Several department heads, Public
18 the storm. 18 Works Director, Roads, the OEP Director, Fire
19 A. Not very much personally, but 19 -- the Fire Chief, Ambulance, School Board,
20 attending the meetings as they were called, 20 Police -- Police Department. Somebody was
21 gearing up the office, my office for myself to 21 there always from the port. There were --
22 be the only one as a staff member. I believe 22 Q. And the port would be the Port of
23 it was during the meeting Friday -- Hurricane 23 St. Bernard facility. Is that right?
24 -- not Hurricane -- Tropical Storm Cindy had 24 A. Yes. Yes. Yes. That Port
25 occurred a month prior to Hurricane Katrina 25 authority.
Page 39 Page 41
11 (Pages 38 to 41)
JOHNS, PENDLETON & ASSOCIATES 800 562-1285
POLLY BOUDREAUX 3/5/2008
1 the large scale of things, it is very narrow 1 Council side. Who in the presidential side of
2 compared to the Gulf of Mexico itself. 2 the government was essential personnel?
3 Q. Okay. Now go back to -- Sorry for 3 A. That's all those department
4 that -- 4 directors.
5 A. That's okay. 5 Q. Okay.
6 Q. -- deviation. Go back to the 6 A. That's all administrative. The only
7 telling us about the meetings on Saturday. 7 -- The only Council staffing that they named
8 Who else was essential personnel besides 8 was myself, new. The TV studio director is
9 yourself? 9 kind of a position that teeters between
10 A. Standard essential personnel for 10 administration and Council and he is also --
11 administrative side of government would your 11 was also considered, our TV studio director
12 Water and Sewer Director, your Public Works 12 was concerned an essential personnel. At this
13 Director, your Transportation Director, Roads 13 point he belonged to the Council. So we would
14 Supervisor, Purchasing Agent, who would be 14 have been the only two kind of official
15 responsible for, you know, preparing supplies 15 positions named.
16 or making -- you know, making things happen 16 Q. And what was the sentiment on
17 financially in a quick turnaround. A few 17 Saturday before the storm at the Council -- I
18 secretarial positions from administrative side 18 mean at the Council with all -- in all the
19 who would man phones during -- you know, 19 meetings?
20 during the night or morning hours as an event 20 A. There was growing concern, and the
21 is taking place for folks to call in to. 21 later it got on Saturday, the more the concern
22 Finance Director was considered essential 22 grew that it was indeed going to be a large
23 personnel at that point. 23 catastrophic event. We would watch the models
24 Q. What about the Councilmen? 24 as the conference calls would come in. There
25 A. They -- 25 were modeling maps that would occur that would
Page 43 Page 45
12 (Pages 42 to 45)
JOHNS, PENDLETON & ASSOCIATES 800 562-1285
POLLY BOUDREAUX 3/5/2008
1 be shown in our -- in the room right off the 1 had to testify on behalf of the St. Rita's
2 OEP office and -- 2 Nursing Home trial. So I have copies of those
3 Q. Who was providing you the models? 3 notes. But the originals are in -- should
4 Any of those water models? 4 still be in my office, Council office.
5 A. Let me think if we had -- We had a 5 Q. I understand that you had a camera
6 number of models, but they were through our -- 6 with you. Do you know of anybody else that
7 through the service there, the Internet 7 was there that had a camera with them also?
8 service that we had there at government. So 8 A. Our TV studio director was filming
9 it would have been National Weather Service 9 the entire time. Picture-wise, or camera-wise
10 and I don't know how many different news media 10 I am sure there were a few others. But Ken
11 -- different folks they used. 11 definitely had his and I had mine until the
12 Q. But were the models of the storm 12 battery died and we had no more electricity so
13 track or were they models of -- 13 that was the end of picture taking.
14 A. A lot -- And lot of it was storm 14 Q. Besides Ken and yourself, do you
15 track. 15 remember anybody that may have had a video
16 Q. -- what would happen when the storm 16 camera or a picture camera?
17 -- Okay. 17 A. I really don't. I would assume that
18 A. Right. A lot of it was storm 18 there may have been some firemen who did. Our
19 track. I remember conversations in the 19 Council chambers -- Our Council chambers, the
20 conference calls about what do you -- what do 20 back of it faced Judge Perez Drive; all
21 you think we're going to experience 21 windows, very large windows. So it was, at
22 water-wise? What do you think we're going to 22 the time the hurricane was hitting, it was an
23 have surge -- You know, what's the surge model 23 unbelievable show to watch until it became
24 look like? But I don't recall that we saw 24 catastrophic and nobody could watch, but it
25 that over and over. I remember the track over 25 provided a great kind of ampitheater for the
Page 46 Page 48
1 and over, and you could never see St. Bernard 1 events of the hurricane as the wind was
2 Parish. Every time you would see the track, 2 blowing. And I'm -- I have never seen them,
3 it completely covered St. Bernard. 3 but there could have been some fire personnel
4 Q. And at the time who was present? 4 who had originally camped out in that area for
5 Was it the essential personnel you talked 5 the night that may have photographs.
6 about, the Council members -- 6 Q. When did the storm's effect begin to
7 A. Yes. 7 be felt at the St. Bernard Parish Council
8 Q. -- or Mr. Rodriguez? 8 chambers? Or I should say the Council
9 A. He -- He wouldn't have come in until 9 building.
10 Saturday evening. He had just experienced 10 A. Right. The Government Complex
11 major surgery and a major setback from the 11 building is what we call it. I slept the last
12 surgery and had not even been officially back 12 night in my house Saturday night, and by
13 to work in a full time -- you know, in a daily 13 Sunday, Sunday noonish we were loading buses,
14 capacity, but he came in that evening, 14 the last of buses, the last of people we could
15 Saturday evening. And maybe not even Saturday 15 gather off the streets to get out of St.
16 evening. It may have been Sunday evening that 16 Bernard, and the wind was -- was blowing
17 he finally came in, he and his family. And I 17 rather nicely at that point. You definitely
18 have notes about that. 18 knew something was coming. I recall taking a
19 Q. And when you have notes about that, 19 drive with Mr. DiFatta and Miss Hoffmeister,
20 do you have written notes about that? 20 and maybe Mr. Madary. I actually have picture
21 A. Uh-huh (affirmatively). Uh-huh 21 of this as well. We went across the green
22 (affirmatively). 22 bridge and went on -- Is that Chef Highway?
23 Q. And where are those written notes 23 Q. Yes.
24 today? 24 A. To where the locks are to see if the
25 A. I have a copy of those, because I've 25 water was coming up there. And I have a
Page 47 Page 49
13 (Pages 46 to 49)
JOHNS, PENDLETON & ASSOCIATES 800 562-1285
POLLY BOUDREAUX 3/5/2008
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,
Page 51 Page 53
14 (Pages 50 to 53)
JOHNS, PENDLETON & ASSOCIATES 800 562-1285
POLLY BOUDREAUX 3/5/2008
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 --
Page 55 Page 57
15 (Pages 54 to 57)
JOHNS, PENDLETON & ASSOCIATES 800 562-1285
POLLY BOUDREAUX 3/5/2008
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:
Page 59 Page 61
16 (Pages 58 to 61)
JOHNS, PENDLETON & ASSOCIATES 800 562-1285
POLLY BOUDREAUX 3/5/2008
1 Yeah, minus a Xerox copy of what 1 President's office. So it was rather large
2 originally was there. You know, what 2 and had a little bit more furniture in it than
3 should still be there. 3 other offices. But it would have been in the
4 EXAMINATION BY MR. ANDRY: 4 corner -- corner of the first floor building.
5 Q. Okay. What happened on Sunday 5 The way the building is fashioned,
6 night? 6 or it was constructed, they're very high
7 A. Sunday night we had the last -- the 7 walls. The windows that you have are
8 last meeting fairly, fairly late that 8 significantly above eye level. So you really
9 evening. I say 9:00 o'clock, 10:00 maybe, and 9 can't see outside. It's windows so you get
10 -- and the news -- the news or the projection 10 light, but you can't see -- you can't see
11 of the hurricane had by that time grown very 11 trees, you can't see anything else. They're
12 severe for St. Bernard and so we -- we went to 12 very high ceilings on the first floor
13 the different areas of the building. Council 13 offices. And that's where I stayed, because
14 went back to Council offices where we were 14 he had a private bathroom in his office and
15 going to spend the night. Several Council 15 had a couch, so there was something to sleep
16 members had put cots in there, in their 16 on without having to get a cot. That's where
17 offices to accommodate a spouse or, you know, 17 I stayed.
18 had their animals with them, whatever. And we 18 There were other Council members
19 at some point, you know, lights out, the 19 in other places. And we -- Miss Hoffmeister
20 wind's blowing the whole time. I remember 20 had asked me to make sure that she was awake
21 that, because that's my last night of sleep, 21 by 6:30, 7:00 o'clock in the morning because
22 was Saturday night. I didn't sleep well at 22 her daughter was calling from Florida and they
23 all Sunday evening because the wind was 23 wanted to do a live radio interview with her,
24 howling very loudly and I remember -- I 24 because we would be in the midst of Hurricane
25 remember going to -- There was a bathroom in 25 Katrina at that point.
Page 62 Page 64
1 Mr. Dean's office, which is why I stayed there 1 Q. And her daughter is a news reporter
2 rather than mine, and he also had a large 2 in Florida? Is that correct?
3 couch and I didn't have one in my office. 3 A. She works with -- She worked then
4 Q. Let me ask you this, for those who 4 with Innis Broadcast, I believe. She doesn't
5 have never been in the building, and that 5 do radio, but she works in the offices of N
6 would be the people reading the deposition and 6 Broadcasting.
7 watching the deposition. 7 Q. And did Miss Hoffmeister participate
8 A. Uh-huh (affirmatively). 8 in the interview on -- that would be Monday
9 Q. As best you can, could you describe 9 morning?
10 where those rooms are within the Council -- 10 A. I went to make sure she was awake,
11 within the government building -- 11 and she was awake. She and her husband and
12 A. Okay. 12 the dog were already awake. And I don't know
13 Q. -- so that we understand where Mr. 13 that anybody slept really well that night,
14 Dean's office is and -- 14 because it was very loud. It was not a
15 A. Okay. 15 soothing noise. A howling wind through the
16 Q. -- how that relates to the exterior 16 night. And I believe she -- she was able to
17 of the building, first floor, second floor? 17 speak to them by phone. It was a phone
18 A. Okay. The Council offices are 18 interview, a cell phone. I think she was on
19 located on the -- were located on the first 19 cell phone at that time. But we were
20 floor of the Government Complex building. As 20 scheduled to have a meeting, a conference call
21 you enter the main lobby, Council assumed the 21 the morning of Katrina's impact and at the
22 left wing of the building. Toward the back 22 point we went up to begin that meeting is loss
23 corner. 23 of electricity and then the events that
24 Mr. Dean's office at the time was 24 unfold.
25 what had formerly been the police jury 25 Q. Let's go back and do it slowly.
Page 63 Page 65
17 (Pages 62 to 65)
JOHNS, PENDLETON & ASSOCIATES 800 562-1285
POLLY BOUDREAUX 3/5/2008
1 Other than the wind and the howling noise, 1 word from somebody who -- whose windows had
2 were there any significant events, to your 2 just blown out of their car, and I, ridiculous
3 recollection, breaking glass or anything like 3 as it may sound, said, "Kenny, I wonder if my
4 that on Sunday night? 4 windows blew out. I'm parked under the
5 A. No. Not in -- Not in that 5 awning, too." And this is obviously before
6 building. Not at that point. No. To my 6 any water, before, you know, anything of that
7 knowledge, there were none. But we are 7 nature has occurred. So Mr. Henderson and I,
8 talking about large -- mostly wall and then 8 who are probably the two smallest people on
9 window at the top which is over, you know, -- 9 the Council, in the Council entourage, decided
10 is under an overhang at the second floor. So 10 to go out of the side door. The door was just
11 while it's exposed to the outside, it's still 11 sucked away from us as soon as we pushed it,
12 very much like a fortress, you know, being in 12 you know, pushed to have it open and he and I
13 that building. 13 had to fight to try to close it. Couldn't see
14 Q. And when you awoke on Sunday morning 14 my car because there was another car blocking
15 after you woke up Miss Hoffmeister, what did 15 it, and at that point realized we're not going
16 you do? 16 outside. I mean, he and I would have been --
17 A. Went upstairs -- Well, I was going 17 would have been blown away God knows where
18 to tell you about having to go to the bathroom 18 because the wind was so strong. So we had to
19 in Mr. Dean's office and I had heard this -- 19 physically pull that door back, pull it
20 the wind all night long and, I don't know, not 20 closed.
21 meaning to be more descriptive than I need to 21 Q. And when you went outside, could you
22 be, but the toilet seat was completely wet and 22 tell which direction the wind was blowing
23 I had this, "Oh, my gosh, how in the world is 23 from?
24 water getting on the toilet seat? Is there 24 A. No. I couldn't. I mean, I know
25 water coming up, you know, already through the 25 that it blew the door completely back against
Page 66 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.
Page 67 Page 69
18 (Pages 66 to 69)
JOHNS, PENDLETON & ASSOCIATES 800 562-1285
POLLY BOUDREAUX 3/5/2008
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.
Page 71 Page 73
19 (Pages 70 to 73)
JOHNS, PENDLETON & ASSOCIATES 800 562-1285
POLLY BOUDREAUX 3/5/2008
1 Q. Do you remember their names? 1 Guardsmen, who knew that his grandfather was
2 A. There are quite a number of them. 2 in Arabi and there was no water, and no water
3 Some of the Public Works fellows, I have 3 coming up, but he and this National Guardsman
4 pictures of them and I don't remember -- I 4 got up Judge Perez going towards New Orleans
5 don't remember their names. But Donna Nye, 5 in a Humm V, I think. They were in an a
6 who was secretary to the CAO was there, and 6 military vehicle. And obviously I didn't go
7 she is one of the ones that called me to go 7 with them, so this is the stories that he has
8 take a look at the parking lot. There were 8 shared. He got up toward Arabi and the water
9 quite a few people. 9 just poured in at an alarming rate, so quickly
10 Q. Was Robert Turner there? 10 that they didn't make it to the destination of
11 A. Yes, Bob Turner was there. He was 11 the grandfather's house. They -- The Humm V
12 guesstimating at what point the water was 12 started floating. They ended up under
13 going to stop once the water, you know, 13 awnings; had to pull themselves up on
14 started coming in and rising significantly. 14 buildings, and kind of go from building to
15 He was using a big mural in the bottom -- on 15 building for safety. Which would have been
16 the bottom floor of the Government Complex and 16 the time, you know, shortly after that we
17 saying, "It's going to get to this step and 17 started seeing the water here in the parking
18 then it's going to stop" or "It's going to get 18 lot.
19 to this step, this window, you know, in the 19 Q. Looking outside through that
20 mural." So I do remember him there. 20 photograph -- Can I take the photograph out?
21 Q. And at that time when you looked 21 A. This is Judge Perez. Uh-huh
22 out, do you know what direction the water was 22 (affirmatively). This is the Judge Perez side
23 coming from? 23 of the lobby. And I have another picture that
24 A. At this point coming from the New 24 would have been the Torres Park side. This is
25 Orleans direction. From the Ninth Ward area. 25 the Torres Park side (indicating). And I
Page 74 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?
Page 75 Page 77
20 (Pages 74 to 77)
JOHNS, PENDLETON & ASSOCIATES 800 562-1285
POLLY BOUDREAUX 3/5/2008
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
Page 79 Page 81
21 (Pages 78 to 81)
JOHNS, PENDLETON & ASSOCIATES 800 562-1285
POLLY BOUDREAUX 3/5/2008
1 a few up on the balcony area, "You got to see, 1 -- they're not the same level kind of
2 the water's coming in, how much water is 2 pictures. The water was rolling in very
3 coming in" and then I turned to look at the 3 quickly and I can tell you how I know that
4 back where the parking lot is to establish how 4 beyond seeing it with my eyes out in the
5 much water there was in that area. 5 parking lot that the water level is, you know,
6 Q. Would it have been five minutes, ten 6 on a steady rise up and a very quick rise up,
7 minutes, half an hour? 7 was noting the level here on the doors,
8 A. Not more than five or ten minutes, 8 realization that I had passed my office and
9 no. 9 while the day before I had trustees take out
10 Q. And the photographs -- Excuse me, 10 filing cabinets with all the Council records
11 the cars, it looks like in photograph Exhibit 11 from years and years and years past, which is
12 Number 2 there's a white car and then a black 12 why the MRGO records are still around, they
13 SUV type of vehicle. In that photograph, it 13 brought them up to the second floor. I had
14 doesn't look like the water is up to the top 14 actually not cleared anything off of my desk,
15 of the tires. 15 which would have been current legislation,
16 A. No. Probably halfway up the tires 16 current, you know, current action by the
17 there. And these are cars, though, that are 17 Council. And so at this point, the
18 parked -- That's not a typical place for cars 18 realization is this water is coming up,
19 to be parked. Those were folks who had parked 19 seriously coming up very quickly, the doors
20 the cars to keep them up on higher ground. So 20 are not going to continue to hold the water,
21 these would have been cars parked up under the 21 we're going to have water in the building and
22 awning kind of the second -- of the second 22 I have all of these files all over my desk
23 floor. So they're parked up close to the 23 that are much more current than everything I
24 lobby -- the Judge Perez lobby entrance to the 24 brought up, you know, the day before. And so
25 Government Complex. Typically you would not 25 at that point I went in my office, grabbed a
Page 82 Page 84
1 see any vehicles there. You would only see 1 load of whatever I could grab off the desk,
2 them in the back. 2 went upstairs, I had some National Guards
3 Q. Well, let me ask you, if you could 3 folks to come down with me, and at that point
4 determine by looking at the photographs, 4 we made three to four trips down the steps
5 Exhibit 2 and Exhibit 3, how much the water 5 into my office, grabbing, running back up the
6 actually rose as it relates to the ground 6 steps, depositing, and coming back down; and
7 between the time you took the -- or in the 7 each time we would come back down, I had on a
8 time you took these two photographs. 8 pair of my daughter's shorts, which I am not
9 A. I would say, Jon, that it's maybe a 9 sure how I ended up with those, but I'm glad I
10 little deceptive to know. And I will give you 10 did, it was -- it was ankle deep, then came up
11 this as a for instance. My recollection is 11 on my calves, then up to knees; the last trip
12 that the water level on the foyer doors would 12 I went down, second-to-last and last trip were
13 have been similar to one another, front of the 13 to get things out of Council members' offices,
14 building to back of the building. But here 14 I realized their college diplomas are hanging
15 you have cars parked up on the cement that 15 on their walls, too. I had saved mine at one
16 surrounds the Government Complex, and here you 16 of the trips with National Guards. We go in
17 have cars parked down in the parking lot. 17 theirs grabbing things off the wall. The last
18 Q. When you say "here", could you tell 18 trip down, I'm in rushing, and when I tell you
19 about which picture you're -- 19 rushing water, very, very powerful water,
20 A. Yes. The Exhibit 3 picture would 20 right to the edge of those -- of those shorts
21 have been the actual -- the true parking lot 21 to go into Mark Madary's office, because
22 for the Government Complex building. And when 22 that's where a very large historical painting
23 you exited the Government Complex building, 23 of Andrew Jackson was and I realized that on
24 you walked down -- down a sloped kind of ramp 24 the way up, "Oh, my gosh, Andrew Jackson's in
25 to get into the parking lot. So these are not 25 Mark's office" and it's -- it had been taken
Page 83 Page 85
22 (Pages 82 to 85)
JOHNS, PENDLETON & ASSOCIATES 800 562-1285
POLLY BOUDREAUX 3/5/2008
1 down because Council chambers were leaking and 1 I mean, nothing like some rainstorms that we
2 we didn't want to destroy the picture. But 2 have certainly experienced since then where
3 now I've got water up to mid thigh and realize 3 you can't see -- where you can't see very far.
4 that Andrew Jackson is now floating in water 4 Q. But based on your experience in the
5 or his -- so I went down with two of the 5 storm or in the events of that day, is it your
6 National Guardsmen to get that -- that 6 belief that the storm came and then the water
7 painting, which takes six men to move it in 7 followed?
8 normal times, two of them and me, and I have 8 A. Yes. Yes. I would say that. There
9 to literally hold the door back to keep it 9 were fringes of the storm, but the water was
10 open because water is rushing, let them go 10 -- I think a lot of people thought, okay, we
11 through, then get around them to go to the 11 made it, you know, and then all of a sudden
12 stairway doors to hold a door back so that 12 here comes -- here comes this rushing water.
13 they can get the painting out the -- up the 13 And rushing water. Not, you know, glug, glug,
14 stairwell. So I know it was moving very 14 glug, glug, glug like you're filling up a
15 quickly because I was in it. I felt it moving 15 bathtub.
16 and felt things rushing against my legs. 16 Q. Was it like a wave?
17 Q. How deep did the water get 17 A. I didn't see any crested, you know,
18 eventually? 18 big wave. I think we all would like to see
19 A. It was into the stairwell on the 19 pictures like that because I think that's what
20 second -- the second landing, and there are 20 helped damage my house significantly. But I
21 different numbers that I have heard. 18 to 22 21 have never seen any pictures that indicate
22 feet. I think 22 feet would have been closer 22 that -- that look. And maybe they're there.
23 to the 40 Arpent. Where we were was probably 23 I have seen video footage from a fellow who
24 about 18, 18 feet. We watched at that point 24 stayed in Lexington about halfway up the
25 from the second floor lobby, we watched in the 25 subdivision. I was all the way in the back
Page 86 Page 88
1 hole of the, you know, the lobby. We all 1 and I have seen his footage, and it really is
2 stood around there watching -- watching the 2 this kind of -- It's almost like the water's
3 water come up. At this point we were not -- 3 -- just all of a sudden it's there and then
4 we weren't dodging wind. You know, it wasn't 4 it's just rising as quick as you can think.
5 wind sounds. It was this rising water that 5 Q. What is his name?
6 took full center stage. 6 A. Fabian Garro.
7 Q. Did the storm, as best you know, get 7 Q. And is that the footage that's on
8 to y'all at that point in time? 8 the St. Bernard disk, that St. Bernard -- the
9 A. I think the storm had gotten to us 9 Garro family footage that you're talking
10 at this point. There was -- You know, it was 10 about?
11 still not beautiful weather, but the worst of 11 A. Yes. It should be. I have a copy
12 the wind blowing was more Sunday night, Monday 12 of it at home. He is a Parish worker. He was
13 morning, and then the -- the water coming up 13 one of our coastal inspectors staying in his
14 seemed, in my mind, that had a complete life 14 or his wife's sister's home. They had a home
15 of its own. That was -- didn't seem to be 15 down the road, but, yes, where you see
16 surrounded or encased in this high wind, you 16 Lexington, you see the shot all the way out
17 know, or accompanied by necessarily high winds 17 the end of Lexington and it's water as far as
18 at that point. I think we had -- I think we 18 your eye can see.
19 had experienced the passing of the, you know, 19 Q. Well, tell me about the photograph
20 the major parts. 20 that I have marked Exhibit 4. Just kind of
21 Q. And did you have significant rain on 21 hold it up so the camera can see it. And then
22 Monday associated with the storm? 22 tell me what is depicted in that photograph.
23 A. Through the night and Monday 23 A. This -- This was a shot that I took
24 morning, yes, but at this point I think you 24 the next morning. This would be the 30th of
25 can see there's not -- there's some rain, but, 25 -- Once we went up on the roof of the
Page 87 Page 89
23 (Pages 86 to 89)
JOHNS, PENDLETON & ASSOCIATES 800 562-1285
POLLY BOUDREAUX 3/5/2008
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
Page 91 Page 93
24 (Pages 90 to 93)
JOHNS, PENDLETON & ASSOCIATES 800 562-1285
POLLY BOUDREAUX 3/5/2008
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
25 (Pages 94 to 97)
JOHNS, PENDLETON & ASSOCIATES 800 562-1285
POLLY BOUDREAUX 3/5/2008
1 bizarre. One piece of furniture in the 1 know, they will go their own ways. Lots --
2 backyard. Nothing else got out of the house. 2 Lots of changes that guarantee that St.
3 And the piece had to float perfectly out of 3 Bernard Parish will never, ever be the same.
4 the kitchen door to get into the backyard. 4 We lost community that day, and it's not to
5 Very, very bizarre. Looked like somebody had 5 say that, you know, we can't build the sense
6 put a blender inside the house and just 6 of community. We're in the middle of
7 churned and churned and churned it all up. 7 preparing to rebuild the community playground,
8 And then the furniture was all jammed to the 8 the one that I showed in the picture, and
9 back of the house, which would have been the 9 while it's going to feel good, it's going to
10 direction the water came. It was all in the 10 make us all feel good to do it, the
11 hallway so you couldn't get to my son's and my 11 realization every single day is you don't live
12 daughter's rooms except from outside the house 12 in the same place.
13 through the window. 13 I am one of three people on my
14 Q. Did you lose a lot of stuff in the 14 street. Three. And that'll probably be it
15 storm? 15 for a long time. There are less than 40
16 A. I did. Yes. Salvaged some dishes 16 percent returned in -- in probably one of the
17 that I still use today. We actually use them 17 most established subdivisions in St. Bernard
18 every day. We eat on China every day now. I 18 Parish. Lexington had just over 700 homes and
19 learned a new lessen about that. But we lost 19 we have recently done a poll of our own. I am
20 a considerable amount. I think many of us 20 the block captain of Florida Avenue, which is
21 have realized today, having begun to put our 21 no grand task with three people living on the
22 lives back together, that we lost more than we 22 street. I can keep up with what's going on on
23 thought we lost. It's difficult to value 23 the street very easily. But we were each
24 things when you just don't even realize how 24 asked to survey how many folks are living in
25 much you have and why you have it. But we 25 homes, how many are for sale, all these
Page 98 Page 100
1 kind of learn that every day. You go to look 1 figures, and the bottom line is two and a
2 for something, "Well, why isn't it in that 2 half, almost three years later we have -- we
3 drawer? Where is the -- where is this holder, 3 have less than 40 percent return. He have no
4 and pot holder?" That was before the 4 guarantee for all the homes that sit empty
5 hurricane. That's not now. And a lot of 5 that should be demolished because there's no
6 realizations now about how much we -- how much 6 market for them and then all the homes that
7 we lost. 7 sit with for sale signs around our total life
8 Q. Do you think it'll ever be the same? 8 investment, our home. And so can St. Bernard
9 A. I do not. No. I am absolutely 9 ever be the same? No way. No way.
10 convinced that it can never be the same. It 10 Q. Do you think the Mississippi River
11 has already structurally, physically changed. 11 Gulf Outlet still poses a danger to the people
12 He have -- We have lost -- We have lost 12 who live currently in St. Bernard Parish?
13 community members that -- You know, I think 13 A. I do. There's not been anything
14 about kids that my children went to school 14 that would change -- change what it can do,
15 with that they will never see again. Not 15 what it -- the conduit it provides for water,
16 because they died, but because they have had 16 for rushing water. It alone was responsible
17 to reestablish their lives somewhere else and 17 for a great deal of coastal erosion on our
18 people that, you know, before -- I'm sorry -- 18 living side, you know, our marsh side, our
19 before the hurricane you took for granted. 19 buffer zone, and it's not to say that we
20 You know, you had next door neighbors. I 20 haven't lost a great deal of coast line
21 don't have next door neighbors now. I have a 21 because of the storm and because of years of,
22 slab. We had -- Thank you -- children that my 22 you know, I think neglect. But to
23 kids played with that are now growing up in 23 purposefully build something that creates more
24 another parish and they won't play with them 24 damage makes absolutely no sense to an already
25 again. They're all getting older and, you 25 receding coast line.
Page 99 Page 101
26 (Pages 98 to 101)
JOHNS, PENDLETON & ASSOCIATES 800 562-1285
POLLY BOUDREAUX 3/5/2008
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
Page 103 Page 105
1 can see the direction just as I saw the next 1 things, and I am sure you know that, a lot of
2 morning, you could see the water flow back 2 things that take place much prior to whatever
3 toward the city. You could see the direction, 3 you see publicly in government and, you know,
4 you know, the direction of the water outside 4 in politics. A lot of things that go on. So
5 the -- I can't tell you that I watched as the 5 we would have no knowledge of what all and who
6 water came down the street for the first 6 all had been in the formation of that letter
7 time. It was already there when I looked at 7 and that position.
8 it. But you could see the direction, the 8 Q. Do you remember about the time
9 direction of the flow. And whatever, you know 9 period about when this is happening?
10 -- I know that water -- water changes its 10 A. It would have been fairly early on,
11 direction based on what it runs into and so, 11 because I remember we were meeting in the
12 you know, I am scientifically -- You would 12 Council chamber. Again, I have to go by bench
13 have to confirm that in other ways. But that 13 marks of -- But the letter is on file in the
14 was my observation as, you know, being there. 14 office. It is definitely something that was
15 Q. Okay. You also testified about a 15 submitted at a Council meeting so it is record
16 proposed resolution or legislation that, I 16 of that meeting.
17 think, that Mr. Rodriguez and the rest of the 17 Q. And when you say early on, you mean
18 Council members disagreed on? 18 early on in your time as the Clerk? Is that
19 A. Yes. 19 what you mean?
20 Q. Tell me what was that proposed 20 A. Early on in my -- This is -- I am
21 resolution again? 21 picturing the -- I have to picture the
22 A. It was a -- one side offering a 22 building and picture what condition we were in
23 resolution of support in regards to the MRGO 23 when we met in the Government Complex building
24 and the Port of New Orleans to preserve their 24 to remember him coming in. And I, without the
25 financial -- their financial interest in 25 documentation, my forte is not -- That's why I
Page 106 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:
Page 107 Page 109
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. 1 was always an issue to those who had financial
2 Q. Well, what about the one that Mr. 2 interests along the MRGO, and that would have
3 Rodriguez -- 3 been folks in the port, folks along the GIWW,
4 A. That was a letter of support and it 4 anybody who had businesses there who would be
5 never -- it never culminated in any 5 adversely affected by an inability to use the
6 resolution, because the Parish President 6 MRGO. They had consistently lobbied against
7 cannot -- he can't enact a resolution. The 7 any closure.
8 Council has to do that. So without their 8 Q. They did lobby the Council, and you
9 support, he could only offer a suggestion or 9 were the Clerk?
10 proposal, you know, an agreement with the 10 A. They lobbied the -- I never
11 Port. And the letter would, you know, would 11 witnessed them openly lobbying Council
12 give you that information. It would speak to 12 members. I think that would have been a -- I
13 that directly. 13 don't know. I did not witness that. I
14 Q. Do you remember Mr. Rodriguez having 14 witnessed several interchanges when we went to
15 a position before Katrina involving not 15 Corps meetings post-Katrina where the folks
16 closing MRGO? 16 who had apparently been at meetings
17 A. He had for many years been -- been 17 pre-Katrina appeared to give their same
18 speaking against the MRGO. I think the gray 18 arguments about leaving it open and very
19 area is in -- And I didn't understand this 19 heated exchanges in those meetings from Mr.
20 until after sitting through long discussions, 20 Rodriguez, who at this point has dropped the
21 that closure of the MRGO has a lot of 21 Port alliance and returned to his closure
22 options. You know, a lot of different 22 position, and some very -- very heated barbs
23 concepts. And until people begin to speak 23 between them about "You all have been lobbying
24 about it openly or publicly you don't even 24 this for years. It's just your own financial
25 really know. You assume, you know, we're -- 25 interest. It has nothing to do with the
Page 111 Page 113
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 A. No, towards St. Bernard. 1 the other end of the foyer, which is what we
2 Q. Looking sort of downriver? 2 might call the Lake Borgne, or the back side
3 A. Down -- Downriver, yes. 3 of the building or the Lake Borgne side?
4 Q. Okay. Now, the photographs that you 4 A. Uh-huh (affirmatively).
5 showed us, it looks like the first one, the 5 Q. It looks like -- It looks to me like
6 first photo which I think is Exhibit 2, you're 6 you've got more waves there and the wind is
7 looking out toward St. Bernard, towards Judge 7 kind of blowing towards that side. Is that
8 Perez Drive? 8 fair to say?
9 A. Yes. 9 A. That it's flowing --
10 Q. Is that sort of what you might call 10 Q. Kind of towards that side.
11 the -- In sailing, we have a windward side and 11 A. I don't -- I mean, I -- It -- Again,
12 a leeward side. The wind hits on one side and 12 I am going to say because of the building,
13 the wind goes away on the other side. Are you 13 because of the things around it, that I don't
14 looking at sort of the leeward side where the 14 know that you're getting a true sense of what
15 wind is blowing away from you at that point? 15 the water -- what the water is doing beyond
16 Towards the river, if you will? 16 unaltered, you know, unhindered.
17 A. I am not going to claim any 17 Q. Yes.
18 expertise at that. I really am not. I 18 A. I don't think you can say that.
19 remember looking in the Council chambers where 19 Because there were several -- There was a big
20 we would -- we would have had a view of Judge 20 TV news truck here and so I would expect you
21 Perez and watching the trees blow, you know, 21 to have water -- you have water that swirls
22 being blown very heavily downriver. 22 regardless of which direction it's coming
23 Q. Downriver. And the Council chamber 23 from. It's not science.
24 windows would be looking in the same direction 24 Q. Okay. I was just trying to figure
25 as -- 25 out, you know, you have a side from which the
Page 119 Page 121
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,
Page 123 Page 125
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
Page 127 Page 129
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
Page 131 Page 133
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?
Page 135 Page 137
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
Page 139 Page 141
1 tropical storm. It was a very frightening 1 as you had described, where exactly were you?
2 experience. I can only imagine anybody going 2 In what direction were you looking?
3 through the Katrina sounds, because they were 3 A. I would have been in the Council
4 significantly higher winds. But my -- my 4 chambers looking toward the Mississippi River.
5 judgment is very, you know, very different 5 Q. And which direction were the trees
6 because of the kind of building that I was 6 bending from that vantage point?
7 in. 7 A. My memory is first bending downriver
8 Q. And what sort of damage did you have 8 and then as the wind direction changed -- at
9 to your house after Cindy? 9 -- at some point there was a significant wind
10 A. I had water that came in through 10 change, wind pattern change, and at that point
11 several windows and wet the sheetrock. Water 11 the glass began shattering. And, in fact, the
12 that came in through the door. It broke the 12 glasses there did shortly after. I was not in
13 -- It broke the gate of my backyard, 13 the room when they did, but everyone came
14 literally just laid it -- laid it flat. It's 14 flying out of that room because the -- those
15 the last picture that I have of my home before 15 windows were shattering with wind.
16 Katrina. I took a picture on the way out just 16 Q. And was that before you saw standing
17 in case, because the wind was still blowing 17 water outside?
18 when I left to go to the government building. 18 A. That would be my best guess, yes.
19 So I have one picture of this -- at mine. So 19 That there was glass damage to that area, not
20 it was water and then you had fence damage to 20 in our lobby. Those glasses didn't -- we
21 the gate. 21 didn't actually have shattered glass there. I
22 Q. And were you in that house during 22 think it broke the door, the doors in, to come
23 any other storms beyond Tropical Storm Cindy? 23 into the building.
24 A. No. No. It was never my pattern to 24 Q. Okay. And you described on Monday
25 stay close. Especially if they called it a 25 morning when you were in -- was it Mr. Dean's
Page 142 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
Page 143 Page 145
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
Page 147 Page 149
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
Page 151 Page 153
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.
Page 155 Page 157
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
Page 159
35:7 boxes 32:21 33:2 72:10 73:7,9 call 14:2 37:20 card 60:17,18
blow 118:10,11 33:15,18 34:3 75:2,3 76:14 37:22 43:21 career 17:5
119:21 boyfriend 76:15 77:8 49:11 65:20 carefully 26:20
blowing 49:2,16 135:12 78:23 81:9,10 79:19 119:10 CARMELITE
62:20 67:4,22 brave 75:17 81:11 83:14,14 121:2 130:17 2:20
68:22 70:20 bravely 67:18 83:22,23 84:21 134:4 138:25 Carondelet 2:22
87:12 119:15 breached 26:11 90:1,25 92:10 149:17 carpeting 67:14
121:7 142:17 136:10 146:9 92:14 93:4,23 called 17:20 21:7 cars 67:23 73:20
146:4 146:13 94:7,9,11,16 39:7,20 40:7 82:11,17,18,20
blown 67:6,12 BREACHES 1:7 94:16,20 44:11,16,17 82:21 83:15,17
67:13 68:2,17 break 72:6 102:7 108:22,23 55:10 74:7 118:5
96:13 109:19 breaking 66:3 118:3,15 121:3 78:24 110:25 case 7:14 54:11
119:22 140:24 bridge 14:1,3 121:12 123:1 129:12 142:25 142:17 154:6
148:9,17 36:12 49:22 124:10,21 143:11 147:13 155:14
blows 151:7 50:1 127:16,17 126:19 131:23 calling 64:22 casings 141:4
board 10:4 127:18 130:20 132:13,18,23 calls 39:2 40:13 catastrophic
22:18 41:19 130:22 150:23 135:2,6 136:3 40:17 45:24 45:23 48:24
boards 148:9 bring 31:20 136:25 138:8 46:20 93:13 category 44:14
boat 14:21 24:8 33:13 138:15 141:19 calves 85:11 44:15,17
26:1 27:2 bringing 25:17 142:6,18 143:5 camera 48:5,7 caught 137:21
59:13 94:5 104:19 135:13 143:15 144:23 48:16,16 52:19 cause 16:10
132:9,24 133:1 broad 112:3 145:22 146:7,9 52:22,23 53:1 17:10 18:14
133:6,11 135:1 Broadcast 65:4 146:22 149:19 53:2 89:21 caused 23:11
boats 27:1 94:7 Broadcasting 150:1 156:19 91:6,7,8,13,14 107:11
Bob 74:11 65:6 157:5 91:20 92:3,3 cc'd 29:20
126:22 broke 142:12,13 buildings 76:14 134:21 135:24 CD 53:13,15
body 13:23,24 144:22 118:23 134:9 136:13 149:6,9 ceased 126:18
21:12 28:14 brought 24:23 built 11:6 124:11 155:4 ceiling 127:11
bolted 143:15 25:18,19 26:1 124:17 125:10 camera-wise ceilings 64:12
Bombay 97:21 31:16 84:13,24 151:14 48:9 125:20,22
Borgne 81:1,12 93:8 94:1,5 bulging 31:3 CAMPBELL 127:5
118:13,21 Brussels 9:14 bulwarks 26:11 1:21 7:6 159:4 cell 65:18,19
121:2,3 122:8 Buccaneer 92:17 bunch 24:4 camped 49:4 70:16,16 93:13
122:13,15 92:17,17,19,20 BURGLASS camps 129:22 117:16
134:3,5 146:23 92:22,23 3:13 canal 1:7 24:16 cement 83:15
146:24 buffer 101:19 burned 60:20 25:8,10 36:14 center 3:23 4:7
born 9:7,8,10 build 15:23,24 buses 49:13,14 131:3 136:6,8 71:21 87:6
bottom 67:8 100:5 101:23 90:6,7,9 137:1,3 152:5 132:6
74:15,16 101:1 102:12 124:11 business 28:9 canals 25:4 central 10:2
123:2 132:20 builder 125:10 38:23 56:14 CAO 74:6 cert 122:3
Boudreaux 1:21 building 33:4 businesses 113:4 capacity 20:15 certain 153:12
7:6,11 61:9 49:9,11 62:13 busy 21:24 42:13 47:14 certainly 25:21
105:7 116:22 63:5,11,17,20 captain 100:20 30:19 35:19
159:4 63:22 64:4,5 C car 40:9 51:1 88:2 136:19
Boulevard 2:13 66:6,13 67:24 C 2:12 68:2,14,14 CERTIFICATE
130:1 69:3,4,6,7,8 cabinet 22:16 82:12 117:10 159:2 160:2
box 3:6 33:20 70:15 71:13,22 cabinets 84:10 118:9 certification
69:19 Denver 9:10 died 48:12 91:21 53:12 54:4 97:16,22 98:4
dead 61:1 department 3:3 99:16 149:16 155:2 99:20,21
deal 22:9,22 41:17,20 45:3 DiFatta 12:9 directors 45:4 117:23 118:12
23:8 33:10 depicted 55:22 49:19 50:23 disagreed 122:10,18
101:17,20 78:20 89:22 58:13 59:9 106:18 123:3 141:1
112:14 114:7 depiction 54:14 79:19 Discovery 154:7 142:12 144:22
dealing 30:3 depicts 81:6 difference 96:5 discussion 12:22 doors 73:9 75:5
114:22 DEPONENT different 44:16 18:4 61:23 83:12 84:7,19
dealings 12:19 159:15 46:10,11 62:13 112:15 134:17 86:12 144:22
16:21 20:16 deposed 7:20 73:24 86:21 discussions 146:8,13,15
deals 7:16 155:14 111:22 141:14 111:20 112:5 doorsteps 14:24
Dean 12:9 depositing 85:6 142:5 146:9,18 dishes 98:16 Downman
Dean's 55:1 63:1 deposition 1:20 differently disk 31:13 54:5 129:25
63:14,24 66:19 5:5,16 7:12,24 104:11 60:20 78:12 downriver 90:22
133:16 144:25 60:4,8 61:5,18 difficult 27:23 89:8 119:2,3,22,23
debates 17:21 63:6,7 77:23 51:20 72:18 Disney 91:17 134:10,16
debating 36:10 157:25 80:20 98:23 distance 133:8 144:7
debris 90:17,24 depositions 125:1 133:10 downstairs 33:3
96:12,13 155:18 digital 53:1,2 distinguished 73:2 145:18
136:17 152:24 depths 16:6,8,8 134:21 42:1 Dr 42:17
deceptive 83:10 describe 10:12 diplomas 85:14 distorted 143:21 drawer 99:3
decided 68:9 63:9 78:19 direct 28:5 District 1:1,2 dredged 16:6
decision 38:3 81:5 145:19 directed 29:8 4:11 75:23 dripping 140:25
94:14 147:23 direction 19:3 districts 12:10 drive 3:15 48:20
decisions 38:1 described 34:2 42:21 68:22 division 153:16 49:19 51:11
deems 44:13 57:23 58:11 69:12 74:22,25 documentation 119:8 150:20
deep 85:10 86:17 117:3 141:10 79:23 80:21 22:8 107:9 151:19
defense 44:10 141:12 143:4 90:17 93:16 108:25 driving 141:3
define 112:6 144:1,24 145:4 98:10 105:19 documents 150:5 152:11
definite 22:15 147:8 150:4 105:21 106:1,3 30:21,23 32:11 drop 104:24
152:4 description 57:2 106:4,8,9,11 32:17 33:23 dropped 113:20
definitely 33:18 57:16 118:20 119:24 73:11 drove 40:11
36:25 42:18,22 descriptive 121:22 122:16 dodging 87:4 50:12 59:5
48:11 49:17 66:21 124:5 128:8 dog 65:12 150:23
51:13 59:18 desk 84:14,22 137:13 144:2,5 135:13 dry 94:13 96:2
60:19 95:23 85:1 144:8 145:20 doing 25:22 117:7 118:1
97:6 104:10 destination 146:2,5,10,19 34:23 38:4 138:8,15
108:14 132:16 76:10 146:23 160:11 117:12 121:15 156:13,17
152:5 destroy 86:2 direction-wise 135:22,23 due 11:10
definition 112:6 destroyed 96:8 81:13 146:7 147:5 152:15 153:12
152:8,8 109:14,17 directly 30:9 Don 15:8 duly 7:8 160:7
degree 8:25 9:2 destruction 92:13 111:13 Donna 74:5 Duplantier 15:8
9:5,23 18:19 122:13 door 14:24 38:9 dusk 59:19
delegation 29:17 determine 37:3 director 20:22 59:23,24 68:10 duties 30:22
demand 32:10 83:4 153:18 20:23 41:18,18 68:10,19,25 56:16
demolished deviation 43:6 43:12,13,13,22 69:2,10 70:8 duty 152:22
101:5 die 149:9 45:8,11 48:8 86:9,12 92:14 DUVAL 1:12
farther 52:1 filled 152:6 fizzles 21:25 93:12 94:2 forwarded 28:16
fashioned 22:10 filling 88:14 flash 51:21 100:24 103:22 28:25 29:7
23:4 64:5 146:1 flat 142:14 107:19 113:3,3 found 33:12
father 9:12 film 155:2 fleshed 20:7 113:15 123:5 97:18 154:13
feature 154:7 filming 48:8 flip 23:2 137:6 147:18 four 31:2 85:4
features 148:9 final 153:23 float 98:3 135:9 147:21 155:6 96:9
February 91:18 finally 47:17 floating 76:12 followed 88:7 fours 148:16
Federal 5:7 7:16 126:18,23 86:4 following 58:4 foyer 71:14 73:6
116:7 Finance 43:22 flood 18:13,17 154:8 78:21 79:11,12
feel 67:2 93:19 financial 23:9 94:20 153:3,10 follows 7:9 80:25 83:12
100:9,10 106:25,25 153:10 follow-up 121:1 123:13
feeling 104:5 113:1,24 flooded 152:10 139:21 156:9 127:4 146:14
133:14 financially 23:25 flooding 35:17 foot 125:11,20 157:4
feels 22:16 43:17 35:23 94:18 125:21,22 foyers 118:15
feet 86:22,22,24 find 16:20 31:5,8 140:13,20 footage 88:23 frame 70:10
123:1 126:4,5 93:15 97:23 151:12,17 89:1,7,9 Franklin 3:7
126:12 157:11 130:17 138:4 153:12,19,21 FORBES 3:22 French 9:3
fell 97:9,10 fine 78:2,10 floods 92:21 6:19,21 77:6 frequency 27:20
fellow 15:9 97:18 floor 32:22 34:3 77:12 102:6 frequently 37:23
35:10 36:1 finished 157:19 63:17,17,20 115:8,12 fresh 91:23
88:23 102:20 fire 41:18,19 64:4,12 66:10 116:21 117:2 Friday 37:23,24
136:11 49:3 133:3,4 71:24 72:6,10 130:5 134:19 37:24 38:20
fellows 74:3 firefighters 74:16 75:12,15 139:7,15 39:17,23 41:1
fellow's 138:5 75:19 82:23 84:13 155:23 156:8 friend 24:25
felt 14:12 37:18 firemen 48:18 86:25 94:21 157:12,22 frightening 40:4
49:7 86:15,16 93:24 97:10,11 123:8 force 21:11,15 142:1
93:21 131:11 firm 1:23 2:4 123:11,17 21:20 32:23 fringes 88:9
141:21,22 18:24 125:15 127:7 40:3 front 38:9 77:8
FEMA 152:20 first 14:10 24:15 127:11 132:21 form 5:14 13:1 83:13 97:16
152:25 153:15 27:2 41:9 143:5,9,9,19 23:16 32:8 103:6 122:10
fence 142:20 44:10 63:17,19 143:25 145:24 107:1 136:5
fencing 148:10 64:4,12 71:8 157:4 formal 30:3 frontier 16:15
field 25:18,20 72:23 78:25 Florida 1:22 7:7 formalities 5:9 full 13:5,23
40:13 79:2 92:10 64:22 65:2 5:11 22:14 47:13
fight 68:13 94:21 95:13,15 100:20 139:24 format 31:14 87:6
figure 121:24 96:1 105:12 flow 80:22 90:17 57:10 funding 44:8
figures 101:1 106:6 119:5,6 106:2,9 151:8 formation 108:6 114:7,9,11,14
file 30:14 108:13 123:11,22 flowing 90:19,22 formerly 63:25 114:14
114:21 147:24 127:11 128:7,8 90:23 121:9 124:12 funnel 42:14,14
filed 115:18 137:14 143:8 flying 144:14 Fort 52:3 128:20 furniture 64:2
files 13:3 16:18 143:25 144:7 folders 13:5 150:10,10,12 97:24 98:1,8
30:16 31:3,8 145:17,22 folks 14:5 34:20 150:15 136:20
31:17 32:12,21 149:15 160:7 43:21 46:11 forte 108:25 further 36:14
33:19,20 84:22 fishing 17:24 52:14 56:9 forth 41:14 52:2 131:9
filing 5:12 22:16 five 12:10 82:6,8 72:1 73:20,22 104:18 156:23 136:25
84:10 122:9 73:25 79:7,16 160:8
fill 11:11 18:1,3 fix 149:21 82:19 85:3 fortress 66:12 G
Garro 89:6,9 50:11,18 51:22 121:12 122:4 grabbing 85:5 grows 44:18
gate 142:13,21 52:3 53:25 124:5 126:23 85:17 guarantee 100:2
gather 34:24 58:22 65:25 126:24,24 graduated 9:22 101:4 103:14
37:19 49:15 66:18 67:17,19 127:21 129:15 25:3 103:14,18
gauge 125:25 68:10 73:2 132:17,18,20 grand 100:21 Guards 85:2,16
geared 18:17 74:7 75:4,11 133:11 138:4 grandfather Guardsman
gearing 39:21 75:12 76:6,14 142:2 145:18 76:1 138:5 76:3 137:20
generally 152:16 85:16,21 86:10 145:21,23 grandfather's Guardsmen
gentleman 86:11 92:2 151:17 76:11 75:20 76:1
147:12 97:23 99:1 good 11:1 33:10 grandparents 86:6
gentleman's 100:1 102:12 42:6 78:18 104:16 guess 19:20 20:7
34:21 102:13 103:5 100:9,10 granted 25:25 20:23 21:22
getting 61:4 103:10 104:15 104:13 99:19 24:9 26:12
66:24 94:6,7 104:23,24 goods 15:20 gravel 71:17,18 35:5 36:14
99:25 121:14 108:4,12 gosh 66:23 85:24 gray 111:18 67:7 73:19
131:11 123:25 127:12 gotten 87:9 great 13:3 15:25 107:2 120:17
Gilmore 34:18 128:16,17 government 18:18 19:22 120:18 126:22
34:18 35:25 132:9 133:2,6 7:17 10:16 48:25 72:4 127:10,14,22
give 7:12 8:15 133:7,12 11:15 13:2 101:17,20 132:16 137:14
50:7 60:19 136:25 142:18 17:4 23:19 112:14 117:12 144:18 151:7
80:16 83:10 143:1 150:15 26:21 32:9 greater 40:2 152:2
111:12 113:17 God 68:17 33:4 38:5 67:22 guessing 120:20
123:6 146:15 goes 71:19 43:11 45:2 greatly 143:20 126:12 157:10
given 10:20 28:4 119:13 128:15 46:8 49:10 green 14:1,2,2 guesstimate
95:16 116:14 143:14 52:16 56:18,19 36:12 49:21 148:21
154:21 going 14:4,12,20 63:11,20 67:24 50:1 127:16 guesstimating
giving 126:22 16:14 19:22,24 69:3 73:24 130:21 74:12
GIWW 36:19 20:1,3,21 74:16 78:22 GREG 4:6 Gulf 7:18 12:20
113:3 24:10 27:9,9 80:25 81:8,10 grew 13:14 25:3 12:23 13:12
glad 60:18 85:9 31:21 32:25 82:25 83:16,22 45:22 15:3,6 16:13
glass 66:3 72:3 36:24 38:2,24 83:23 90:2 ground 82:20 16:15,22 17:1
73:8 102:10 39:9 41:4,8 91:24 92:15 83:6 94:13 17:7,17 18:12
141:20 143:12 42:12 45:22 94:15,15 95:7 125:11,14 21:10,20 22:5
143:15,16 46:21,22 55:5 104:19 108:3 151:15 22:12 24:6,8
144:11,19,21 59:8 62:15,25 108:23 112:18 grounded 15:18 26:6 27:18
glasses 35:9 66:17 68:15 123:1,20 group 2:24 29:19 30:4,25
144:12,20 69:5,24 72:3 124:14,20 33:22 36:1 31:1 32:18
glory 26:15 74:13,17,18,18 126:19 131:23 139:20 35:23 36:16,17
glug 88:13,13,14 76:4 77:5 132:5,12,23 groups 19:8 42:15 43:2
88:14,14 78:11 84:20,21 134:7 135:1,6 112:17,17,18 59:4 101:11
go 9:15 11:4 90:22 91:24 136:24 138:15 112:18,23 gutted 97:7
15:2 22:13,17 95:16 100:9,9 142:18 143:5 grow 16:5 104:8 guy 35:7,9
25:6 27:10 100:22 103:10 152:18,20 growing 45:20 guys 14:19
28:7,22 29:22 104:17,18,20 155:1,4 156:19 55:4 59:19
31:15,17 32:3 104:24,24 157:5 99:23 H
38:6 39:3,7 110:7 112:5,7 grab 85:1 grown 25:23 hair 35:8,8,9
42:24 43:3,6 119:17 120:19 grabbed 84:25 62:11 half 10:2,3 82:7
101:2 104:25 heated 23:18 historical 85:22 124:25 125:12 immediate 17:20
halfway 73:19 110:8,11 historically 125:17 131:17 110:25
82:16 88:24 113:19,22 30:24 120:19 131:18,19 immediately
141:1 147:15 Heath 77:2 history 32:17 136:4,5,20,21 140:4
hallway 98:11 heavily 11:7 hit 11:14 40:2 140:23 141:22 impact 13:23
hand 19:25 103:24 119:22 hits 119:12 141:23,23 65:21 136:22
handkerchief 141:18 hitting 48:22 142:9,22 150:7 important 33:13
139:13 heavy 140:14 Hoffmeister 150:9,19 151:2 impose 17:16
handle 104:22 153:4 12:8 49:19 houses 51:23 impression
handles 153:16 Hebert 16:13 58:13 64:19 96:7,14 125:2 24:24 79:12
hands 73:11 height 114:15,16 65:7 66:15 148:19 145:20
handwritten 123:7,18 hold 8:25 77:10 howling 55:1 inability 113:5
58:7,8 heights 36:6 84:20 86:9,12 62:24 65:15 Incajolia 20:24
hanging 85:14 122:25 124:20 89:21 66:1 include 60:23
happen 19:1,17 held 10:24 13:7 holder 99:3,4 huge 25:11 included 12:22
19:18 20:1,3 61:23 126:20 holding 132:13 Humm 76:5,11 33:7
29:22 39:9 134:17 hole 87:1 143:22 hurricane 11:14 incorrect 91:14
43:16 46:16 help 147:14 home 40:5 48:2 12:14 18:22 increase 15:22
71:3 125:3 helped 88:20 50:13,19 59:21 19:2,4,12,14 15:25
happened 21:19 helpful 33:12 89:12,14,14 19:15 20:17,18 incredible 67:11
21:21 41:4 Henderson 12:8 91:24 97:12,13 21:6 24:18 indicate 60:10
54:11 57:1,8 67:18 68:7 101:8 104:14 26:10,18 27:7 88:21 153:14
62:5 69:21 70:7 117:9 104:14 140:1 27:15 30:6,8 indicated 153:11
71:7 116:13 hereinabove 141:15,15,17 31:7,19 32:7 indicates 91:3
139:1 148:8 160:8 142:15 147:24 35:15 37:11,12 136:13
happening 57:25 hereto 5:4 154:6,11,11,12 38:19 39:23,24 indicating 76:25
108:9 160:14 155:14 39:25 41:6 78:16 79:20
happens 91:17 high 10:1 13:22 homes 15:1 42:16 44:5 118:21,22
happy 20:10 25:3,17 50:12 100:18,25 48:22 49:1 122:15,16
138:2 51:5 52:13 101:4,6 151:14 53:20 54:22 134:2,7
hard 117:23 58:21 64:6,12 honest 36:3 62:11 64:24 indication
harm 67:25 67:5 87:16,17 horizontally 69:18 71:11 137:15 146:2
hate 126:13 94:22 127:5 140:25 94:4 99:5,19 individual 117:8
Haynes 129:25 131:25 132:3 hot 93:11 109:5,11 individually
head 138:20 140:22 145:10 hour 82:7 140:16 141:10 35:22
headed 122:22 145:11 157:3 120:14 143:1 154:1 industrial 16:14
129:18 130:25 higher 51:15 hours 18:3,3 156:10,16,22 36:14
heads 41:17 52:10 82:20 43:20 104:20 157:8 information 8:3
hear 16:12 21:9 125:12 142:4 154:5 husband 65:11 13:6 40:17
42:14 71:25 highest 90:11,14 house 41:14 42:9 55:18
141:17 126:2 49:12 76:11 I 56:4 57:3,17
heard 13:18 14:5 highrise 131:2 88:20 95:15,17 ice 135:8 111:12 154:24
15:16 42:17 Highway 49:22 95:18,21 97:4 idea 107:15 inherited 13:4
66:19 86:21 128:11,15 97:10,23 98:2 146:15 initial 24:24
118:8,10 129:20 130:16 98:6,9,12 II 2:13 125:25 159:15
137:25 133:6 103:9,10 images 53:23 Innis 65:4
hearing 10:20 Hilton 93:7 104:16,23 imagine 142:2 inquisitive 19:20
inside 93:3,11 105:1 113:1 judgment 142:5 30:13 32:9 54:11 56:1,3,5
98:6 132:12 issues 11:10 13:8 Judy 12:7 39:2 41:5,14 57:1,1,1,18
146:7 148:18 19:21,21 20:5 Junior 12:2,3 45:9,14 48:25 59:9 60:13,16
149:19 44:12 55:12 14:15 22:21,23 51:21 52:5,5,8 60:25 62:2,17
inspectors 89:13 114:8,9,11 jury 63:25 56:2,5 70:13 62:19 65:12
instance 83:11 it'll 99:8 JUSTICE 3:3 71:19 72:16 66:9,12,20,25
insulation 97:10 justify 23:25 76:14 80:16,17 67:1,2,10,14
insurance J 37:6 82:22 83:24 67:25 68:6,12
147:25 148:8 Jack 50:13 84:1 89:2,20 68:24 69:13
153:10,17 131:16 K 90:19 93:14 70:11,14 71:2
interchanges Jackson 80:2 K 1:10 96:1 99:1 72:3,21 73:16
113:14 85:23 86:4 Katrina 1:7 10:7 107:20 110:15 74:13,19,22
interest 14:8 Jackson's 85:24 12:14 18:22 114:4 120:7 75:14,18 76:16
23:9 29:13 jammed 98:8 22:15 26:18,24 121:7,10 78:15 79:6
30:1 106:25 January 91:19 27:16 29:19 122:19 123:16 80:13,14,22
113:25 Jeff 35:5 34:11,15 35:15 125:1 127:24 81:18 83:10
interested JEFFERSON 37:11 38:19 134:9 136:2 84:3,5,16,24
160:15 3:17 39:25 42:16 142:6 146:1,11 86:14 87:1,4,7
interesting JESSICA 3:5 64:25 111:15 kitchen 97:21 87:10,17,19
97:19 job 10:12,13,23 114:22 141:10 98:4 88:11,13,17
interests 103:16 10:24 12:19 141:17 142:3 Kleenex 139:12 90:12,20 91:16
113:2 15:21 30:22 142:16 154:1,5 knees 85:11 91:21,23 93:9
INTERNATI... 57:2,15 114:8 155:15,18 knew 13:18 93:25 94:3,4
2:25 jobs 15:22,25 157:8 37:24 49:18 95:9,17,22
Internet 8:11 16:4 Katrina's 65:21 76:1 79:22 97:17,20 99:13
46:7 Joey 12:9 52:8 Katrina-related 90:4 137:6 99:18,20 100:1
interpret 8:19 129:19 130:17 153:21 138:1 100:5 101:18
interview 64:23 JOHNS 4:20 Kattengell 11:9 know 7:13 14:4 101:22 102:22
65:8,18 5:21 160:4,20 KEA 3:14 15:11,18,23 102:25 103:2
interviewed joined 36:15 keep 82:20 86:9 18:5,18,20 103:11,15,17
153:24 154:9 Jon 71:5 83:9 100:22 116:24 19:3,8,17 21:3 103:22,24
interviews 154:3 109:7 155:24 126:13 152:14 21:13,15,19,21 104:8,9,13
154:17 Jonathan 2:5 152:18 21:25 23:24 106:4,9,10,12
Intracoastal 7:12 keeping 38:4 24:19 25:4,7 106:14 107:2
36:16 127:19 JOSEPH 4:15 107:1 25:12,14 26:15 107:16,19,23
127:24 JR 2:12 Keith 3:4 105:8 27:8,24 28:5,6 108:1,3 109:7
investment Judge 1:12 Ken 48:10,14 28:16 29:6 110:10,13
101:8 103:17 48:20 51:25 60:20 30:11,19 31:24 111:10,11,22
involved 154:4 69:5,8 71:12 Kenny 12:8 68:3 33:16 34:6,25 111:25,25
involving 111:15 76:4,21,22 kept 19:16 33:6 36:3,21 37:4 112:4 113:13
in-between 78:22 82:24 55:20 153:6 37:20 38:4 114:1,4,14,15
132:22 96:17,18,19 kids 14:5 25:18 40:5 41:3 115:25 116:9
Irish 130:6 119:7,20 120:4 40:9,12 99:14 42:10 43:15,16 119:21 121:14
island 93:21 130:25 131:1,8 99:23 103:24 43:19 44:12,15 121:16,25
issue 17:5 27:22 133:3 136:12 kind 11:14 17:10 46:10,23 47:13 123:6,19,22
29:13 30:10 137:19 147:16 21:25 25:8 48:6 50:11 124:10,18,25
33:17 44:8 150:22,24 27:7 29:13 51:14 54:1,7 125:1,2,4,25
38:10,10 41:2 84:5 88:10 maker 38:3 6:20 139:17,19 Mellerine 12:9
53:14,25 59:13 90:4 96:13 making 10:18 150:18 155:20 member 39:22
74:21 75:8 97:17 98:14 38:1 43:16,16 mean 9:20 18:1 42:9 75:22
97:15 98:5 99:5 105:13 man 43:19 25:3,9 40:21 112:11 115:23
106:7 117:6,6 107:25 108:1,4management 45:18 51:10 117:9
117:22 118:12 111:21,22 10:14 68:16,24 75:8 members 12:1,6
120:9 151:25 116:15 117:25 mandator 41:7 88:1 108:17,19 12:12 18:4
looking 11:11 122:11,12 map 19:23 81:14 112:4,10 22:6 23:6,13
32:6 54:3 138:7 141:16 152:2 117:21 121:11 40:18 41:3
70:14 75:1 147:23 150:16 maps 45:25 128:4 131:12 42:7 47:6 57:3
76:19 80:12,18 154:15 March 1:25 7:3 134:13 62:16 64:18
80:18 81:25 Lots 40:5 100:1 159:20 meaning 41:8 85:13 95:7
83:4 117:10 100:2 margin 127:14 66:21 115:24 99:13 106:18
118:3,4,20,22 loud 65:14 70:18marina 24:24 means 15:21 113:12 137:18
119:2,7,14,19 71:25 mark 12:7 75:22 112:11 115:25 147:14 149:14
119:24 120:23 loudly 62:24 85:21 90:11 meant 17:22 154:8
120:24,25 Louisiana 1:2,22 91:3 139:5 25:25 39:10 memory 19:9
122:7,18 128:3 1:24 2:7,14,23marked 89:20 107:4 112:15 27:11 32:5
134:9,16 143:6 3:16,24 4:10 123:19 124:1,7 media 46:10 52:6 53:5,8
143:22 144:2,4 4:22 5:22 7:7 marker 132:17 153:25 154:3 54:12 60:17,18
146:3,14,19,21 9:2 25:19 market 101:6 154:22 109:4 144:7
146:23 151:20 29:17 160:22 marking 123:6 medical 11:10 154:19
looks 72:17 lower 94:23 marks 108:13 meeting 27:21 men 86:7
82:11 119:5 150:24 Mark's 85:25 31:22,22 32:1 mentally 103:23
121:5,5 123:12 LSU 18:23 19:12 marsh 16:11,11 39:6,23 50:9 Menteur 58:17
134:22 lull 138:3 18:19 38:11 55:7,10,25 128:15 129:18
lose 30:15 98:14 Lynn 12:9 101:18 124:12 57:5 58:4,22 129:20
loss 65:22 133:15 124:13,18 58:23 62:8 mentioned 15:4
154:19 marshy 124:17 65:20,22 122:25 127:16
losses 154:16 M Mary 29:11 102:14 108:11 137:17 140:16
lost 34:7 70:13 Madary 12:7 Mashriki's 108:15,16 145:18 147:8
77:3 91:20 49:20 58:13 42:17 109:16 110:8 149:6 150:5
98:19,22,23 75:22 Mashriky 20:13 meetings 10:22 151:20 155:13
99:7,12,12 Madary's 85:21 20:14 12:22 13:7 Meraux 1:22 7:7
100:4 101:20 MAG 1:14 massive 22:16 14:13 21:15 met 108:23
114:2 118:9 main 63:21 25:9 28:8 24:1 31:21 110:1
136:1 71:13 103:20 35:11 37:14,15 metadata 60:9
lot 23:18 33:5 maintain 30:23 Master's 8:25 37:17 38:24 92:5
37:14 40:6 maintained 9:5 39:20 41:2,13 Metairie 3:16
46:14,14,18 32:19 math 11:4 41:15,16 42:5 Mexico 43:2
56:24 60:25 major 16:9 22:5 matter 160:16 42:10 43:7 Microphone
70:17,17,18 23:12,12 47:11 matters 16:24 45:19 50:10 117:1
71:15 73:2,3 47:11 87:20 maximum 61:11 107:20 mid 86:3
73:10 74:8 107:17 123:18 109:23 112:8 middle 26:2
76:18 80:24 majority 96:7 MCCALL 3:21 113:15,16,19 100:6 104:21
81:7,24 82:4 Makeover McComb 128:20 114:5 149:16 124:12
83:17,21,25 154:12 McPeak 2:21 meets 127:23 midst 64:24
midway 136:11 months 19:15 N 5:1 6:1 65:5 99:21 147:10 noonish 49:13
miles 131:5 104:18 name 19:10,11 NEUNER 4:5 normal 73:7
military 76:6 Morgan 2:14 21:5,6 32:22 never 16:3 19:23 86:8 102:16
mind 22:13,14 39:14 42:21 44:9 25:19 41:10,10 Norman 7:13,15
87:14 morning 40:8 89:5 139:19 47:1 49:2 north 3:25 81:17
mine 26:19 43:20 64:21 named 41:7 44:3 53:13 56:18 92:17,18,22,23
44:23 48:11 65:9,21 66:14 44:22 45:7,15 63:5 72:4 127:21
63:2 85:15 67:16,19,21 names 15:7,11 88:21 99:10,15 northeast 81:15
142:19 69:15 70:9 34:17,22 74:1 100:3 111:5,5 81:16
Minolta 52:25 87:13,24 89:24 74:5 113:10 142:24 north-northeast
minus 62:1 90:8 92:11 narrow 42:25 143:1 147:16 81:18
125:6 106:2 134:23 43:1 new 1:24 2:7,23 note 58:3 75:7
minute 24:7 134:24 144:25 National 46:9 3:24 12:1 19:1 127:15
102:8 145:2,16 149:7 56:8 75:20,25 19:22 20:2 noted 29:12
minutes 33:7 move 36:13 86:7 76:3 85:2,16 22:10 26:8,14 notes 38:4 47:18
82:6,7,8 112:8 94:14,14 86:6 137:20 45:8 74:24 47:19,20,23
122:9 141:22 naturalist 15:9 76:4 90:2,18 48:3 50:9
miserably 93:11 moved 9:10 10:2 naturally 38:25 90:23 98:19 55:12,20,22,25
Mississippi 7:18 movement nature 29:4 68:7 102:21 104:22 56:4,6,6,11,12
12:20,23 13:12 145:25 72:22 105:18 106:24 56:13 57:9,11
15:3,6 21:10 moving 79:5 near 80:2 152:10 107:7 131:8,8 57:21,22,23
21:20 22:5,12 86:14,15 necessarily 23:5 news 46:10 58:2,3,5,6 59:1
26:5 27:18 MRGO 13:6,9 87:17 117:18 62:10,10 65:1 61:10 109:1,3
29:18 30:25 13:18 14:4,10 necessary 44:13 77:2 121:20 120:21,22
31:1 32:18 15:19 17:13,21 necessity 40:16 nice 23:18 127:14
35:22 36:17 17:23 18:1,7 neck 35:19 nicely 49:17 notice 72:23,25
42:15 59:4 23:7,16 25:1 need 9:6 26:22 night 43:20 49:5 104:2,3
101:10 128:25 25:20 28:19 27:12 56:25 49:12,12 50:6 noticed 73:16
144:4 146:20 30:16 31:15 57:9,17 66:21 54:25 55:8 78:25
Mitsubishi 32:10 33:17 73:2 141:13 58:23 62:6,7 notices 10:20
51:14 35:16 36:15,19 needed 14:12,13 62:15,21,22 noting 84:7
mock 18:23 38:12 50:1 16:9 23:23 65:13,16 66:4 November 20:20
model 46:23 58:16 59:25 34:25 40:9,10 66:20 67:12 number 6:5,9
modeled 42:19 84:12 106:23 57:7 87:12,23 93:1 11:2,2 12:21
modeling 20:6 107:15 111:1 needs 28:7 77:11 93:2,4,5 13:3,5 15:12
45:25 111:16,18,21 negatively 53:24 104:21 128:5 15:25 17:21
models 19:16,17 112:1,19,21 70:3 141:8 133:14 150:4 42:6 46:6 74:2
37:2 45:23 113:2,6 114:9 neglect 101:22 151:10,19,25 78:13,15 82:12
46:3,4,6,12,13 127:23 129:15 negligence 7:17 nine 125:21,22 115:1,5 120:24
Monday 54:24 151:20,25 negotiation 126:7 123:4 155:9
65:8 87:12,22 152:10 107:25 Ninth 74:25 numbers 86:21
87:23 144:24 mud 97:23 neighbor 147:8 137:12 140:9 nursing 48:2
145:2 muddy 95:19 neighborhood Nobody's 28:4 154:6 155:14
Montero 51:13 mural 74:15,20 136:4,12 147:7 116:12 Nye 74:5
51:14 Myra 11:8 147:10,20 nods 138:20
month 9:8 39:25 156:12,14 noise 65:15 66:1 O
monthly 34:19 N neighbors 99:20 70:18 O 5:1
68:15 70:6,13 13:13 14:7,11 40:22 64:1 106:20 110:18 98:6,21 107:23
70:22,24 71:3 15:13 21:13 pretty 52:21 protect 23:8 putting 10:21
73:13 74:12,24 26:21 45:9 69:18 125:13 143:16 31:11,11
75:5,6 84:17 108:7 111:15 130:16 protected 103:1 141:23
84:25 85:3 113:22 114:12 previously 103:16
86:24 87:3,8 positions 12:11 153:19 protection 36:24 Q
87:10,18,24 43:18 45:15 pre-hurricane 72:11 151:16 question 5:14
90:13,16 91:19 possessed 13:11 72:21 protective 16:11 8:3,16,20
96:17 105:25 possession 16:19 pre-Katrina prove 91:18 19:25 57:20
107:8 113:20 possible 21:5 110:23 112:16 provide 8:23 70:1 104:3
117:20,25 post 3:6 26:18 113:17 55:15 57:3,17 questioned 56:9
118:2 119:15 posted 10:18 print 16:17 60:8 60:4 61:5,15 questions 7:24
120:5,22 post-hurricane prior 12:25 61:18 102:3 105:5
126:14 134:21 34:11 13:16 15:12 provided 16:1,3 116:23 139:8
136:1 143:4,18 post-Katrina 18:5,21,21 33:24 48:25 139:18,21
143:19 144:6,9 110:20,24 26:24,24 27:6 154:25 147:6 149:4
144:10 145:13 113:15 29:19 30:8 providers 55:17 153:24 156:10
146:17 151:18 post-traumatic 31:7,19 32:6 provides 101:15 157:18
152:9 157:2 104:5 39:25 41:11 providing 46:3 quick 43:17 56:3
pointed 122:12 pot 99:4 42:16 44:4 78:9 84:6 89:4
pointing 122:17 potential 37:25 54:21 79:10,13 proximity 15:1 quickly 39:4
police 41:20,20 poured 76:9 79:20 91:10,10 public 10:20 55:9 76:9 79:5
63:25 pouring 73:9 108:2 140:5 23:21 26:3 79:8 84:3,19
political 27:3 power 91:20 149:2 41:17 43:12 86:15
37:6 114:18 136:1 private 64:14 55:18 74:3 quiet 71:1
politicians 24:20 150:1,2 privy 107:20 110:11 137:8 quite 13:4 36:4
politics 108:4 powerful 85:19 probably 35:25 155:6 72:20 74:2,9
poll 100:19 practice 31:10 40:8 68:8 publicly 108:3 92:21 95:24
POLLY 1:21 7:6 preceding 159:5 81:18 82:16 111:24 107:12 155:9
159:4 preparing 37:19 86:23 100:14 pull 12:24 31:18
Ponstein 11:25 43:15 100:7 100:16 126:14 68:19,19 76:13 R
population present 2:16 problem 77:24 pulled 32:7 raced 50:11
103:20 4:14 42:11 78:5 33:10 radio 64:23 65:5
port 22:10,17 47:4 56:2 57:4 Procedure 5:7 pulling 52:8 139:1 149:18
23:9 41:21,22 presentation process 39:2 Purchasing railroad 130:14
41:22,24 42:1 19:9 42:18 Proctor 50:16 43:14 rain 67:13 70:20
42:3 106:24 presented 150:10 purpose 155:5 87:21,25
107:7,18 107:22 Proctor's 50:17 purposefully 140:14 152:15
111:11 113:3 preserve 106:24 52:4 101:23 153:4
113:21 president 11:22 professional purposes 5:8 rainfall 153:13
portion 58:19 12:2,4 15:13 13:17 57:21 77:22 rainstorms 88:1
152:17 22:11 23:13 professor 19:12 purse 52:25 raised 19:25
portions 148:15 44:13 107:17 20:13 purview 153:9 104:12,13
poses 101:11 111:6 112:13 projection 62:10 pushed 68:11,12 114:16
position 9:13 presidential property 148:13 put 37:8 40:9 ramp 52:9 83:24
10:6,16 11:8 45:1 proposal 111:10 53:15 54:4 ran 134:20
11:12 13:1,4,9 President's proposed 106:16 62:16 72:11,14 rate 76:9
RDR 5:21 160:4
127:22 130:9 107:22 111:3 45:17,21 47:10 63:17 66:10 seeing 76:17
130:14 134:12 111:14 113:20 47:15,15 49:12 71:24 72:6,10 84:4 143:6
138:22 143:21 Rodriguez's 62:22 78:3 82:22,22 145:19 146:3
152:2 155:11 40:23 Saudi 9:13 84:13 86:20,20 seen 36:23 49:2
157:13,21 ROGER 4:20 save 5:13 33:8 86:25 123:8,21 88:21,23 89:1
rise 84:6,6 151:6 5:21 160:4,20 53:4,7 123:21 127:7 103:19 118:11
151:9 role 35:16,22 saved 85:15 143:5,9,18,19 137:5,13
rising 74:14 87:5 roll 59:10 Savoye 15:9 second-to-last 145:25 155:9
89:4 126:18 rolled 79:7 saw 31:18 34:22 85:12 seeping 145:23
145:13 rolling 84:2 46:24 57:14 secretarial 43:18 146:11,11
Rita 156:10,16 roof 71:17 89:25 70:5,11 78:23 secretary 74:6 Senator 29:23
156:22 90:2 92:25 79:2 105:12 secure 103:17 29:24 30:7
Rita's 48:1 93:2,5,10,14 106:1 134:23 securely 72:14 send 27:24 28:4
rivaled 157:8 94:9 141:23 137:11,15 see 14:12,21,22 28:6,9 29:7,8
river 7:18 12:20 148:10,16,17 138:12 139:5 17:3 26:14,15 29:16
12:23 13:12 149:15,16,22 143:25 144:16 27:9 28:23 sending 28:3
15:3,6 21:10 room 46:1 145:17 147:5 31:16 34:21 sense 97:19
21:20 22:12 144:13,14 151:11 156:25 35:4 47:1,2 100:5 101:24
25:11 26:5 rooms 63:10 saying 29:11 49:24 50:8,9 103:11 121:14
27:18 29:18 98:12 74:17 79:16 51:20 55:7 126:17 141:13
30:25 31:1 rose 83:6 says 14:19 57:14,15 58:17 sent 28:11,11
32:18 35:23 rough 138:24 scale 43:1 58:19 59:17 sentiment 45:16
36:17 42:15 route 127:18 scary 103:22 64:9,10,10,11 separate 40:19
59:4 94:13,23 129:23 130:21 scathing 27:24 68:13 71:8 separation 127:8
101:10 118:16 131:25 28:25 72:18 73:1,3 September
118:18,20 Rules 5:7 scatter 72:1 75:11 77:1 95:11,12
119:16 144:4 run 26:13 96:16 scheduled 65:20 78:24 80:9,9 109:10 156:11
146:20 96:17 schedules 10:22 80:13,15,20 seriously 84:19
RMR 4:20 160:4 running 85:5 school 10:1,4,9 82:1 83:1,1 serve 10:15
road 4:8 50:20 runs 106:11 13:22 25:4,17 87:25 88:3,3 12:13
89:15 103:12 rushing 85:18,19 41:19 50:13 88:17,18 89:15 served 10:8
127:18 128:11 86:10,16 88:12 52:13,17 58:21 89:16,18,21 56:21
128:12 129:25 88:13 101:16 99:14 103:19 90:24 93:17 service 46:7,8,9
130:21 131:14 141:20 132:1,3 95:17,19,21 56:9 93:14
131:18 133:3,5 science 19:19,21 96:4 99:15 97:21
137:9 150:20 S 90:21 121:23 104:10 105:24 serving 10:7
roads 41:18 S 5:1 scientifically 105:25 106:1,2 155:5,6
43:13 152:10 safe 67:25 77:5 106:12 106:3,8 108:3 set 17:8 60:8
roadway 133:8 safety 23:10 scope 56:14 124:15 126:3 91:7,10 95:4
Robert 74:10 76:15 114:1 57:12 129:7 131:12 160:8
Robinson 1:12 sailing 119:11 scraping 133:7 131:17,17 setback 47:11
7:14,15 sale 100:25 sea 125:3 135:14 139:2 settled 90:12
rode 55:3 94:3 101:7 searchable 140:13,20 seven 10:14
Rodriguez 12:2 Salvaged 98:16 31:14 143:9,23 145:8 12:10
15:12 22:25 sanity 10:10 seat 66:22,24 148:14 151:1,8 severe 20:5
24:18 47:8 Saturday 33:10 94:15 145:5 151:24 152:1,3 62:12
106:17 107:5 41:13,16 43:7 second 61:22 152:3 sewer 43:12
134:13 135:23 14:24 16:16 time 5:16 9:13 116:12 136:9 tried 67:18
136:6,6,21 20:18 24:16 10:7,19 11:23 157:1,9 148:6
137:2 138:5,6 25:6,10,23 12:6,14,17 TOM 3:22 trip 14:10 24:5
139:1 141:14 27:6 31:18 13:15 27:4,14 Tommy 20:25 25:20 26:23
147:4 155:7,11 37:15 46:5,21 29:24 33:11 top 50:1 66:9 27:8 37:6
156:25 157:10 46:22 51:8 34:9 37:1 38:7 67:7 71:23 50:10 52:19
telling 43:7 52:21 53:1 38:14,15 39:13 82:14 92:9 55:3,9 58:11
ten 82:6,8 122:9 60:1 65:18 39:14 41:9 136:7 58:16 59:2
tending 38:22 70:25 71:14,16 42:16 47:2,4 Torres 69:10 85:11,12,18
tennis 73:15 76:5 77:1,2 47:13 48:9,22 76:24,25 81:11 133:12 150:23
tent 24:2 78:11 81:15,17 50:8,9 51:13 81:11 92:13 trips 25:19 26:5
tenure 18:9,11 86:22 87:9,18 53:19,25 55:2 118:13 134:3 26:17 37:5
22:4 87:18,24 88:10 55:7,7 56:1,20 tort 7:16 85:4,16 133:1
term 21:10 88:18,19 89:4 56:21 59:15 total 101:7 tropical 39:24
42:14,19 112:3 91:13 97:14 62:11,20 63:24 tough 102:19 40:3 140:17,18
terms 138:24 98:20 99:8,13 65:19 69:13 track 46:13,15 141:12 142:1
testified 105:11 101:10,22 70:10,12,22 46:19,25 47:2 142:23
105:15 106:15 104:8,10 71:4 74:21 133:4 truck 51:2,4,6
testify 7:8 48:1 105:15 106:17 76:16 79:6,10 tracks 130:14 121:20
160:7,8 111:18 112:11 79:14 81:19,19 traditionally trucks 133:3
testimony 159:5 112:14 113:12 81:21,24 83:7 153:3 trudging 73:17
159:7 160:9 116:17 117:3 83:8 85:7 87:8 traffic 17:23,24 true 23:7 83:21
Thank 29:5,12 119:6 121:18 95:13,15 104:22 121:14 159:6
30:11,12 61:3 124:21 125:8 100:15 105:12 transcribe 58:6 160:11
99:22 102:3,5 129:12 132:15 106:7 108:8,18 transcribed trustees 84:9
116:17 139:12 136:21 139:8 117:4,7,11,17 160:10 truth 160:8
155:21 157:14 144:22 148:5 122:12 126:13 transcript try 11:5 68:13
157:23 149:19 153:14 132:11 133:2 160:12 116:24
thanks 7:11 30:1 153:15 154:7 133:12 137:24 transcription trying 7:25 8:2
139:9 154:10,17,18 138:6 139:9 159:7 27:5 34:23
theirs 85:17 156:11 157:13 145:9 transition 56:20 75:11 93:13
thereof 5:16 thinking 21:7 times 24:17,20 Transportation 120:15 121:24
thick 127:8 25:15 27:4 31:16 43:13 Tuesday 94:10
141:20 thinks 112:12,13 32:7 54:1 73:7 trauma 141:16 94:10 132:6,6
thigh 86:3 third 32:22 34:3 86:8 109:2 traveling 50:22 turn 16:14 51:21
thing 18:1 25:9 75:12,15 110:1 156:23 52:3,3,11
103:22 114:12 thought 77:5,10 tires 73:19 82:15 tree 40:6 123:22 124:1,4
141:2 88:10 98:23 82:16 trees 40:5 52:7 129:3 131:6
things 27:3,12 120:7 138:3 today 9:21 38:16 64:11 70:19 turnaround
33:12 39:11,11 three 15:10,10 47:24 51:11 71:12 119:21 43:17
43:1,16 56:25 31:2 85:4 90:6 53:22 98:17,21 120:6 124:15 turned 82:3
85:13,17 86:16 90:6 96:8 102:20 124:2 143:7,25 144:5 115:24 123:24
97:19 98:24 100:13,14,21 toilet 66:22,24 152:24 129:4 132:2
108:1,2,4 101:2 157:11 67:1,9 145:5 tremendously Turner 74:10,11
120:20 121:13 157:11 told 24:6 40:8 13:15 126:22
135:8 Thursday 37:15 58:14 102:20 trial 48:2 turning 81:1
think 8:11 10:5 tied 21:24 105:16,22 trick 7:25 116:4