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KTR00130

KTR00130

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Published by: KatrinaDocs on Apr 17, 2009
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GRIESHABER, Ph.D., JOHN6/27/2008Johns Pendleton Court Reporters800 562-1285Page 1UNITED STATES DISTRICT COURTEASTERN DISTRICT OF LOUISIANAIN RE: KATRINA CANAL BREACHES CIVIL ACTIONCONSOLIDATED LITIGATION NO. 05-4182 K2JUDGE DUVALPERTAINS TO: MRGO AND ROBINSON(No. 06-2268)Rule 30(b)(6) deposition of THE UNITEDSTATES OF AMERICA, BY AND THROUGH THE UNITEDSTATES ARMY CORPS OF ENGINEERS' DESIGNEE JOHNGRIESHABER, Ph.D., P.E., given at the U.S. ArmyCorps of Engineers New Orleans Districtoffices, 7400 Leake Avenue, New Orleans,Louisiana 70118-3651, on June 27th, 2008.REPORTED BY:JOSEPH A. FAIRBANKS, JR., CCR, RPRCERTIFIED COURT REPORTER #75005
 
GRIESHABER, Ph.D., JOHN6/27/2008Johns Pendleton Court Reporters800 562-12852 (Pages 2 to 5)
Page 2
1
APPEARANCES:
2
REPRESENTING THE PLAINTIFFS:
3
BRUNO & BRUNO
4
(BY: JOSEPH M. BRUNO, ESQUIRE)
5
(BY: SCOTT JOANEN, ESQUIRE)
6
(BY: FLORIAN BUCHLER, ESQUIRE)
7
855 Baronne Street
8
New Orleans, Louisiana 70113
9
504-525-1335
1011
REPRESENTING THE UNITED STATES OF AMERICA:
12
UNITED STATES DEPARTMENT OF JUSTICE,
13
TORTS BRANCH, CIVIL DIVISION
14
(BY: RICHARD STONE, ESQUIRE)
15
(BY: DAN BAEZA, ESQUIRE)
16
P.O. Box 888
17
Benjamin Franklin Station
18
Washington, D.C. 20044
19
202-616-4289
202122232425
Page 3
1
REPRESENTING THE U.S. ARMY CORPS OF ENGINEERS.
2
CORPS OF ENGINEERS, OFFICE OF COUNSEL
3
(BY: JENNIFER LABOURDETTE, ESQUIRE)
4
7400 Leake Avenue
5
New Orleans, Louisiana 70118-3651
6
504-862-2843
78
ALSO PRESENT:
9
ROBERT FISHER, ESQ.
10
WILLIAM D. TREEBY, ESQ.
11
CHARLES SUTTON, ESQ.
12
R. SCOTT HOGAN, ESQ.
13
JOSEPH E. BEARDEN, III, ESQ.
14
CHRISTOPHER ALFIERI, ESQ.
15
RICHARD PAVLICK, ESQ.
1617
PRESENT VIA I-DEP:
18
ERIC GOLDBERG, ESQ.
19
RONALD KITTO, ESQ.
20
CHRISTOPHER ALFIERI, ESQ.
2122
VIDEOGRAPHER:
23
TODD MEAUX (DEPO-VUE)
2425
Page 4
1
E X A M I N A T I O N I N D E X
23
EXAMINATION BY: PAGE
45
MR. BRUNO .................................6
6
E X H I B I T I N D E X
78
EXHIBIT NO. PAGE
9
Exhibit 1 ................................11
10
Exhibit 2 ................................11
11
Exhibit 3 ................................11
12
Exhibit 4 ................................47
13
Exhibit 5 ................................94
14
Exhibit 6 ...............................109
15
Exhibit 7 ...............................110
16
Exhibit 8 ...............................115
17
Exhibit 9 ...............................115
18
Exhibit 10 ...............................133
19
Exhibit 11 ...............................148
20
Exhibit 12 ...............................151
21
Exhibit 13 ...............................197
22
Exhibit 14 ...............................198
23
Exhibit 15 ...............................218
24
Exhibit 17 ...............................234
25
Page 5
1
S T I P U L A T I O N
2
IT IS STIPULATED AND AGREED by and
3
among counsel for the parties hereto that the
4
deposition of the aforementioned witness may be
5
taken for all purposes permitted within the
6
Federal Rules of Civil Procedure, in accordance
7
with law, pursuant to notice;
8
That all formalities, save reading
9
and signing of the original transcript by the
10
deponent, are hereby specifically waived;
11
That all objections, save those as to
12
the form of the question and the responsiveness
13
of the answer, are reserved until such time as
14
this deposition, or any part thereof, is used
15
or sought to be used in evidence.
161718
* * *
19202122
JOSEPH A. FAIRBANKS, JR., CCR, RPR,
23
Certified Court Reporter in and for the State
24
of Louisiana, officiated in administering the
25
oath to the witness.
 
GRIESHABER, Ph.D., JOHN6/27/2008Johns Pendleton Court Reporters800 562-12853 (Pages 6 to 9)
Page 6
1
MR. BRUNO:
2
This is a Notice of Deposition
3
taken pursuant to Rule 30(b)(6) of the
4
Federal Rules.
5
Counsel, would you be so kind as
6
to identify the person who the
7
government has appointed today to
8
appear in response to this notice and
9
the particular paragraphs to which he
10
will be speaking?
11
MR. STONE:
12
It's Mr. John Grieshaber,
13
G-R-I-E-S-H-A-B-E-R. And the topics
14
are 27, 28, 31, 34 to 37.
15
MR. BRUNO:
16
Great. Thank you.
17
With that, would you swear the
18
witness?
19
JOHN GRIESHABER, PH.D., P.E.
20
USACE HPO, NOD, 7400 Leake Avenue, New Orleans,
21
Louisiana 70118, a witness named in the above
22
stipulation, having been first duly sworn, was
23
examined and testified on his oath as follows:
24
EXAMINATION BY MR. BRUNO:
25
Q. Good morning, sir. My name is Joseph
Page 7
1
Bruno.
2
First, have you ever given a
3
deposition before?
4
A. Yes, I have.
5
Q. So you're you generally know the rules
6
of the game.
7
A. (Nods affirmatively.)
8
Q. Let me just share with you just once
9
again what you may encounter this morning.
10
From time to time counsel for the government
11
may object, which is their right; however, we
12
are reserving a ruling on the objection until
13
the deposition is sought to be used at trial.
14
So unless your counsel instructs you not to
15
answer, you should answer the question. Okay?
16
Is that fair?
17
A. I understand.
18
Q. All right. As between you and I, my
19
rules are real simple. You're the boss of 
20
breaks. If you need to get a cup of coffee or
21
you need a personal break, you just hold up
22
your hand, we'll stop immediately. Okay?
23
With regard to my questions, if you
24
don't understand them or they don't make any
25
sense to you, just holler, just tell me, and I
Page 8
1
will do what I can to rephrase the question so
2
that you and I can be on the same page.
3
A. I understand.
4
Q. There it is.
5
All right. When is the first time
6
that you were made aware that the government
7
was going to appoint you to represent it in the
8
context of this deposition?
9
A. I guess about two weeks ago.
10
Q. Okay. How many times did you meet
11
with counsel for the government in preparation
12
for the deposition?
13
A. Twice.
14
Q. Okay. And for how long did you meet
15
with them on each of those occasions?
16
A. I guess a half hour the first time,
17
two plus hours the second time.
18
Q. Okay. Now, do you know how it was
19
that you were selected to speak on behalf of 
20
the government for the particular paragraphs?
21
A. Um -- I really don't know the definite
22
way it happened. I just was told it was
23
happening.
24
Q. It's you.
25
A. Got it.
Page 9
1
Q. All right. That's fine.
2
Did you review any documents in
3
preparation for this deposition?
4
A. I was shown some documents, and I went
5
and reviewed the page in the DM, the P&S that
6
showed the pile lengths, tip elevations and top
7
of wall.
8
Q. Okay. Let me get you to explain for
9
the record, DM means?
10
A. That's a design manual. The, um --
11
the P&S are the plans by which the wall was
12
built.
13
Q. All right. The wall is which wall?
14
A. Is the wall -- the IHNC floodwall that
15
we're speaking of.
16
Q. Okay.
17
MR. BRUNO:
18
Richard, can you just give me the
19
Bates number on that?
20
MR. STONE:
21
I don't have a Bates number.
22
MR. BRUNO:
23
Why don't we just produce it,
24
then, if you don't mind.
25
MR. STONE:

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