Trial Transcript 2009-04-29 PM

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1 UNITED STATES DISTRICT COURT

2 EASTERN DISTRICT OF LOUISIANA
3
4
5 NORMAN ROBINSON, ET AL * DOCKET 06-CV-2268-K
*
6 VERSUS * NEW ORLEANS, LOUISIANA
*
7 UNITED STATES OF AMERICA, ET AL * APRIL 29, 2009
* * * * * * * * * * * * * * * * *
8
9
10 VOLUME 8 - AFTERNOON SESSION
TRIAL PROCEEDINGS BEFORE THE
11 HONORABLE STANWOOD R. DUVAL JR.
UNITED STATES DISTRICT JUDGE
12
13
APPEARANCES:
14
15 FOR THE PLAINTIFFS: O'DONNELL & ASSOCIATES, PC
BY: PIERCE O'DONNELL, ESQ.
16 550 SOUTH HOPE STREET, SUITE 1000
LOS ANGELES, CALIFORNIA 90071
17
18 FOR THE PLAINTIFFS: LAW OFFICES OF JOSEPH M. BRUNO, A PLC
BY: JOSEPH M. BRUNO, ESQ.
19 L. SCOTT JOANEN, ESQ.
855 BARONNE STREET
20 NEW ORLEANS, LOUISIANA 70113
21
FOR THE PLAINTIFFS: THE ANDRY LAW FIRM, LLC
22 BY: JONATHAN B. ANDRY, ESQ.
KEA SHERMAN, ESQ.
23 610 BARONNE STREET
NEW ORLEANS, LOUISIANA 70113
24
25
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1 APPEARANCES (CONTINUED):
2
FOR THE PLAINTIFFS: BARON & BUDD, PC
3 BY: THOMAS SIMS, ESQ.
3102 OAK LAWN AVENUE, SUITE 1100
4 DALLAS, TEXAS 75219
5
FOR THE PLAINTIFFS: DOMENGEAUX WRIGHT ROY & EDWARDS,LLC
6 BY: JAMES P. ROY, ESQ.
556 JEFFERSON STREET, SUITE 500
7 POST OFFICE BOX 3668
LAFAYETTE, LOUISIANA 70502
8
9 FOR THE PLAINTIFFS: THE DUDENHEFER LAW FIRM, LLC
BY: FRANK C. DUDENHEFER JR., ESQ.
10 601 POYDRAS STREET, SUITE 2655
NEW ORLEANS, LOUISIANA 70130
11
12 FOR THE PLAINTIFFS: DUMAS & ASSOCIATES LAW FIRM, LLC
BY: WALTER C. DUMAS, ESQ.
13 LAWYER'S COMPLEX
1261 GOVERNMENT STREET
14 POST OFFICE BOX 1366
BATON ROUGE, LOUISIANA 70821
15
16 FOR THE PLAINTIFFS: FAYARD & HONEYCUTT
BY: CALVIN C. FAYARD JR., ESQ.
17 519 FLORIDA AVENUE S.W.
DENHAM SPRINGS, LOUISIANA 70726
18
19 FOR THE PLAINTIFFS: MICHAEL C. PALMINTIER, A PLC
BY: MICHAEL C. PALMINTIER, ESQ.
20 JOSHUA M. PALMINTIER, ESQ.
618 MAIN STREET
21 BATON ROUGE, LOUISIANA 70801
22
FOR THE PLAINTIFFS: LAW OFFICE OF ELWOOD C. STEVENS JR.,
23 A PLC
BY: ELWOOD C. STEVENS JR., ESQ.
24 1205 VICTOR II BOULEVARD
POST OFFICE BOX 2626
25 MORGAN CITY, LOUISIANA 70381
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1 APPEARANCES (CONTINUED):
2
FOR SUBROGATED INSURERS: THE GILBERT FIRM
3 BY: ELISA T. GILBERT, ESQ.
BRENDAN R. O'BRIEN, ESQ.
4 325 EAST 57TH STREET
NEW YORK, NEW YORK 10022
5
6 ALSO PRESENT FOR J. ROBERT WARREN II, ESQ.
PLAINTIFFS: ASHLEY E. PHILEN, ESQ.
7 MRGO LITIGATION GROUP
600 CARONDELET STREET, SUITE 604
9
FOR THE DEFENDANT: U.S. DEPARTMENT OF JUSTICE
10 TORTS BRANCH, CIVIL DIVISION
BY: DANIEL M. BAEZA JR., ESQ.
11 JEFFREY PAUL EHRLICH, ESQ.
TAHEERAH KALIMAH EL-AMIN, ESQ.
12 MICHELE S. GREIF, ESQ.
CONOR KELLS, ESQ.
13 PAUL MARC LEVINE, ESQ.
JAMES F. MCCONNON JR., ESQ.
14 KARA K. MILLER, ESQ.
RUPERT MITSCH, ESQ.
15 PETER G. MYER, ESQ.
ROBIN D. SMITH, ESQ.
16 SARAH K. SOJA, ESQ.
RICHARD R. STONE SR., ESQ.
17 JOHN WOODCOCK, ESQ.
BENJAMIN FRANKLIN STATION
18 P.O. BOX 888
WASHINGTON, DC 20044
19
20 OFFICIAL COURT REPORTER: TONI DOYLE TUSA, CCR, FCRR
500 POYDRAS STREET, ROOM HB-406
(504) 589-7778
22
23
24
PROCEEDINGS RECORDED BY MECHANICAL STENOGRAPHY, TRANSCRIPT
25 PRODUCED BY COMPUTER.
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1 I N D E X
2 PAGE
3 G. PAUL KEMP
4 VOIR DIRE 1727
5 DIRECT EXAMINATION 1735
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12:51 1 AFTERNOON SESSION

12:51 2 (APRIL 29, 2009)
12:51 3 THE DEPUTY CLERK: ALL RISE.
12:51 4 COURT IS IN SESSION. PLEASE BE SEATED.
12:59 5 THE COURT: OKAY. ARE THE PLAINTIFFS READY TO
13:09 6 PROCEED WITH THE NEXT WITNESS?
13:09 7 MR. ROY: WE ARE, YOUR HONOR. THE PLAINTIFFS WILL
13:09 8 CALL DR. PAUL KEMP.
13:09 9 THE COURT: YES, SIR.
13:09 10 MR. LEVINE: PAUL LEVINE FOR THE UNITED STATES.
13:09 11 (WHEREUPON G. PAUL KEMP, HAVING BEEN DULY SWORN,
13:09 12 TESTIFIED AS FOLLOWS.)
13:09 13 THE DEPUTY CLERK: PLEASE STATE YOUR FULL NAME AND
13:09 14 CORRECT SPELLING FOR THE RECORD.
13:10 15 THE WITNESS: MY NAME IS GEORGE PAUL KEMP. WHAT ELSE
13:10 16 DID YOU ASK FOR?
13:10 17 THE DEPUTY CLERK: SPELL IT.
13:10 18 THE WITNESS: G-E-O-R-G-E, P-A-U-L, K-E-M-P.
13:10 19 VOIR DIRE
13:10 20 BY MR. ROY:
13:10 21 Q. DR. KEMP, WHAT IS YOUR AREA OF EXPERTISE?
13:10 22 A. MY AREA IS COASTAL GEOLOGY AND OCEANOGRAPHY.
13:10 23 Q. THAT INCLUDES MARINE SCIENCES, COASTAL STUDIES,
13:10 24 SEDIMENTOLOGY, AND HYDROLOGY WITHIN THAT GROUPING; RIGHT?
13:10 25 A. THAT'S CORRECT.
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13:10 1 MR. ROY: YOUR HONOR, FOR YOUR REFERENCE, HIS

13:10 2 JULY 2008 REPORT, WHICH IS IN THE RECORD AS PX-91, PAGES 225 TO
13:10 3 22, ENCOMPASSES MANY OF HIS QUALIFICATIONS. I'LL JUST TOUCH ON
13:11 4 SOME.
13:11 5 BY MR. ROY:
13:11 6 Q. WHAT DOES YOUR WORK AS A GEOLOGIST AND OCEANOGRAPHER
13:11 7 ENTAIL?
13:11 8 A. I MOSTLY AM WORKING IN MODERN ENVIRONMENTS, RIVERS, WATER
13:11 9 MOVING UNDER THE INFLUENCE OF TIDES AND WINDS AND CURRENTS
13:11 10 DEVELOPED IN OTHER WAYS.
13:11 11 Q. WELL, WOULD IT BE FAIR TO SAY GEOLOGY IS THE STUDY OF
13:11 12 SOLID AND LIQUID MATTER THAT CONSTITUTES THE EARTH?
13:11 14 Q. OCEANOGRAPHY IS A BRANCH OF EARTH SCIENCES THAT STUDIES
13:11 15 THE OCEAN, INCLUDING ECOSYSTEM DYNAMICS AND MOVEMENT OF WATER
13:11 16 UNDER THE INFLUENCE OF WIND, TIDES, WAVES, AND ACROSS DIFFERING
13:11 17 TERRAIN, AND THE GEOLOGY OF WATER BODY FORCE?
13:11 19 Q. NOW, DO YOU WORK WITH MODELS, HYDRODYNAMIC AND ECOLOGICAL
13:11 20 MODELS?
13:11 21 A. I HAVE FOR THE PAST 20 YEARS.
13:11 22 Q. DO YOU WORK WITH ENGINEERS THAT DO MODELS UNDER YOUR
13:12 23 DIRECTION OR AT YOUR REQUEST?
13:12 24 A. IT IS MY PRIVILEGE TO WORK WITH MANY ENGINEERS.
13:12 25 Q. IS THIS PART OF YOUR PROFESSION THAT YOU DO THIS?
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13:12 2 Q. DO YOU DO IT FREQUENTLY?
13:12 3 A. THAT HAS BEEN MY NORMAL OPERATIONS, TO WORK WITH
13:12 4 ENGINEERS, WITH ENGINEERING MODELS IN AN OCEANOGRAPHY CONTEXT.
13:12 5 Q. NOW, YOU'RE CURRENTLY VICE PRESIDENT OF THE GULF COAST
13:12 6 INITIATIVE OF THE NATIONAL AUDUBON SOCIETY SINCE FEBRUARY OF
13:12 7 2007. BETWEEN 1992 AND 2007, WHAT WAS YOUR OCCUPATION?
13:12 8 A. I WAS AN ASSOCIATE RESEARCH PROFESSOR IN THE SCHOOL OF THE
13:12 9 COAST AND ENVIRONMENT AT LSU.
13:12 10 Q. WAS THAT LSU IN BATON ROUGE?
13:12 11 A. YES, SIR.
13:12 12 Q. THERE, YOU DIRECTED THE NATURAL SYSTEMS MODELING GROUP AT
13:12 13 LSU IN THE SCHOOL OF COASTAL ENVIRONMENT?
13:12 14 A. THE SCHOOL OF THE COAST AND ENVIRONMENT, THAT'S CORRECT.
13:12 15 Q. YOU'VE LIVED IN LOUISIANA SINCE 1975?
13:12 16 A. YES. I CAME TO LOUISIANA AS A GRADUATE STUDENT.
13:13 17 Q. DR. KEMP, YOU'RE A SCIENTIST; RIGHT?
13:13 18 A. THAT'S RIGHT.
13:13 19 Q. WHAT ELSE DO YOU CONSIDER YOURSELF TO BE IN TERMS OF NOT
13:13 20 JUST A SCIENTIST?
13:13 21 A. WELL, I'M ALSO INTEREST -- I'M A CONSERVATIONIST. I'M
13:13 22 INTERESTED IN RESTORING THE COAST, AND I'VE WORKED AT THAT FOR
13:13 23 ALMOST 30 YEARS.
13:13 24 Q. WELL, SPECIFICALLY, YOU CONSIDER YOURSELF TO BE A FIELD
13:13 25 SCIENTIST; CORRECT?
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13:13 1 A. THAT HAS BEEN MY NORMAL OPERATION, IS THAT I SPEND A LOT

13:13 2 OF TIME COLLECTING MEASUREMENTS IN THE FIELD, AND THEN I USE
13:13 3 MODELS AND OTHER TECHNIQUES TO TRY AND EXPLAIN WHAT I'M SEEING
13:13 4 OUT THERE.
13:13 5 Q. STATED DIFFERENTLY, SOME SCIENTISTS, EVEN IN YOUR
13:13 6 OCCUPATION, AROUND THE COUNTRY OR EVEN ADJACENT STATES MAY
13:13 7 CONSIDER THEMSELVES SCIENTISTS AND READ ABOUT THE LOUISIANA
13:13 8 MARSHES AND WETLANDS AND EVEN LOOK AT PICTURES OF THEM. YOU'VE
13:13 9 SPENT THE BETTER PART OF 25 YEARS ACTUALLY WALKING THEM AND
13:13 10 RIDING THROUGH THEM; RIGHT?
13:13 11 A. THAT'S RIGHT. THAT'S WHY I CAME TO LOUISIANA, WAS TO HAVE
13:13 12 THAT OPPORTUNITY.
13:14 13 Q. YOUR BS FROM CORNELL; YOUR MS, LSU; AND YOUR PH.D. IN 1986
13:14 14 FROM LSU, THE DEPARTMENT OF MARINE SCIENCES, NOW THE DEPARTMENT
13:14 15 OF OCEANOGRAPHY AND COASTAL SCIENCE; CORRECT?
13:14 17 Q. YOU'VE DONE RESEARCH. THAT'S WHY YOU WENT TO LSU AND WHY
13:14 18 YOU STAYED AT LSU, TO DO RESEARCH ON THE VERY SORTS OF DYNAMICS
13:14 19 WE'RE TALKING ABOUT IN THIS CASE THAT YOU'VE BEEN CALLED UPON
13:14 20 TO DO RESEARCH AND GIVE EXPERT OPINIONS; CORRECT?
13:14 22 Q. COASTAL ECOLOGY, THAT'S COASTAL ZONE MANAGEMENT, YOU
13:14 23 FREQUENTLY HAVE LECTURED IN THAT; RIGHT?
13:14 24 A. YES. AND IN OCEANOGRAPHY AND SEDIMENTOLOGY AS WELL.
13:14 25 Q. LET'S TALK ABOUT SOME OF THE PROJECTS. ONCE AGAIN, YOUR
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13:14 1 RÉSUMÉ COVERS THEM IN EXQUISITE DETAIL, BUT I WANT TO HIGHLIGHT

13:14 2 A COUPLE. THE FIRST ONE I WANT TO TALK ABOUT IS YOU'VE
13:14 3 ACTUALLY EVALUATED A CORPS NAVIGATION PROJECT BEFORE, HAVEN'T
13:14 4 YOU?
13:14 5 A. THAT'S RIGHT. BACK IN THE EARLY 1990S, THE CORPS HAD PUT
13:15 6 A DAM-LIKE STRUCTURE ACROSS ONE OF THE BRANCHES OF THE
13:15 7 ATCHAFALAYA RIVER.
13:15 8 Q. THAT'S THE WAX LAKE WEIR YOU'RE TALKING ABOUT?
13:15 9 A. THAT'S RIGHT, THE WAX LAKE WEIR. THEY PUT IT THERE IN
13:15 10 1987. I WAS CONTACTED IN 1993, WHEN THE PEOPLE OF MORGAN CITY,
13:15 11 REALLY THEIR CHAMBER OF COMMERCE, WAS CONCERNED THAT THEY WERE
13:15 12 SEEING HIGHER WATER THAN THE CORPS HAD TOLD THEM TO EXPECT.
13:15 13 THEY HAD TOLD THEM THAT THIS WEIR WOULD HAVE NO EFFECT ON
13:15 14 FLOODING. IT TURNED OUT THAT IT DID HAVE AN EFFECT ON
13:15 15 FLOODING. WE DID A FIELD INVESTIGATION AND A MODELING STUDY
13:15 16 AND CONFIRMED THAT EFFECT. IN 1994, THE WEIR WAS REMOVED.
13:15 17 Q. WHO REMOVED IT?
13:15 18 A. THE CORPS OF ENGINEERS.
13:15 19 Q. DID THEY REMOVE IT BECAUSE OF THE EXPERT OPINIONS, AMONG
13:15 20 OTHER THINGS, YOU RENDERED?
13:15 22 Q. AMONG THOSE EXPERT OPINIONS IN YOUR STUDY -- EXCUSE ME.
13:16 23 AT THAT TIME, AMONG YOUR OPINIONS REACHED IN YOUR
13:16 24 ANALYSIS OF THAT SITUATION OF THE NAVIGATION PROJECT DESIGNED
13:16 25 AND BUILT BY THE CORPS AND OVER THE ENSUING YEARS, IN YOUR
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13:16 1 EXPERT OPINION, CAUSED LOCAL FLOODING, DID YOU FIND THAT ONE OF
13:16 2 THE REASONS WAS IT CAUSED AN ACCELERATED BUILDUP OF SEDIMENT
13:16 3 THAT RAISED THE BOTTOM OF THE BODY OF WATER, THAT THEN RAISED
13:16 4 THE WATER ITSELF IN FLOOD TIDES?
13:16 5 A. THAT'S CORRECT. IT WAS DONE TO SCOUR SEDIMENT OUT OF THE
13:16 6 NAVIGATION CANAL, BUT IT ACTUALLY RESULTED IN MORE
13:16 7 SEDIMENTATION IN THAT CHANNEL THAN HAD OCCURRED PREVIOUSLY.
13:16 8 Q. YOU, IN FACT, HAVE WORKED ON AN ASSIGNMENT TO THE U.S.
13:16 9 ARMY CORPS OF ENGINEERS TO REVIEW APPLICATION OF 1D AND 2D
13:16 10 MODELS ADDRESSING THE NEED TO RAISE GUIDE LEVEES IN THE
13:17 11 ATCHAFALAYA IN THE PAST, HAVE YOU NOT?
13:17 12 A. THAT'S CORRECT, YES.
13:17 13 Q. YOU'VE SPENT A COUPLE YEARS AS A TECHNICAL ON COASTAL
13:17 14 RESTORATION FOR THE LOUISIANA GOVERNOR'S OFFICE?
13:17 15 A. YES. I WAS INVOLVED IN GETTING THE COASTAL RESTORATION
13:17 16 PROGRAM STARTED IN LOUISIANA, BOTH AT THE FEDERAL AND STATE
13:17 17 LEVEL.
13:17 18 Q. LET'S TALK SPECIFICALLY MODELING. SOME OF THE LAST WORK
13:17 19 AT LSU THAT YOU ACTUALLY COORDINATED AND DIRECTED WAS IN YOUR
13:17 20 CAPACITY AS DIRECTOR OF THE NATURAL SYSTEMS MODELING GROUP
13:17 21 UNDER CONTRACT TO THE LSU HURRICANE CENTER TO ADAPT THE 2D
13:17 22 ADCIRC MODEL TO PROVIDE RELIABLE REALTIME FORECASTING OF
13:17 23 HURRICANE SURGE; IS THAT RIGHT?
13:17 24 A. THAT'S CORRECT. WITH MY COLLEAGUE, HASSAN MASHRIQUI, WE
13:17 25 DEVELOPED THE PROTOCOL TO ACTUALLY USE THE MODEL IN A
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13:17 1 FORECASTING MODE TO ALERT PUBLIC SAFETY AND -- IN A PUBLIC

13:17 2 SAFETY ROLE, WHERE WE WOULD FORECAST SURGE WITHIN THE SIX-HOUR
13:17 3 WINDOW THAT THE NOAA WEATHER SERVICE PROVIDED UPDATES.
13:18 4 Q. YOU, IN FACT, USED THAT MODELING WITH YOUR TEAM IN THE
13:18 5 HURRICANE PAM EXERCISES PRIOR TO KATRINA?
13:18 6 A. THAT'S RIGHT. WE MODELED THE HYPOTHETICAL HURRICANE THAT
13:18 7 THE FEDERAL EMERGENCY MANAGEMENT AGENCY HAD DEVELOPED WITH THE
13:18 8 WEATHER SERVICE, AND THAT WAS QUITE AN EYE OPENER.
13:18 9 Q. AS DIRECTOR OF THE NATURAL SYSTEMS MODELING GROUP, THE
13:18 10 NSMG, YOU CARRIED OUT APPLIED RESEARCH IN YOUR FIELD TO ADAPT
13:18 11 STANDARD ENGINEERING METHODS AND MODELS TO THE EMERGING FIELD
13:18 12 OF WETLAND RESTORATION AS WE KNOW IT TODAY?
13:18 13 A. THAT'S CORRECT. ONE ASSIGNMENT THAT I HAD THAT CAME TO
13:18 14 MIND JUST VERY RECENTLY WAS -- I'M NOT A MEMBER OF THE NATIONAL
13:18 15 ACADEMY OF ENGINEERING, BUT I DID ACTUALLY SERVE ON A NATIONAL
13:19 16 RESEARCH COUNCIL STUDY FOR PIPELINE SAFETY, WHERE CHANNELS HAD
13:19 17 EXPANDED. THERE WAS A LOT OF FORENSICS WORK INVOLVED BECAUSE
13:19 18 FISHING BOATS WERE HITTING THESE EXPOSED PIPES AND BLOWING UP,
13:19 19 AND IT WAS RELATED TO THE CHANGING ENVIRONMENT IN LOUISIANA,
13:19 20 VERY SIMILAR TO THE CONDITION THAT WE SEE IN THE MRGO.
13:19 21 Q. SO WITHIN THE APPLICATION OF YOUR FIELD OF EXPERTISE,
13:19 22 YOU'RE NO STRANGER IN GOING OUT IN THE FIELD, WHETHER IT'S
13:19 23 WETLANDS, NAVIGATION PROJECTS, SO-CALLED IMPROVEMENT, OR
13:19 24 WHATEVER, AND DETERMINING IN THE FIELD WHAT'S REALLY HAPPENING,
13:19 25 WHY IT'S HAPPENING, AND HOW TO FIX IT?
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13:19 1 A. THAT'S RIGHT. MOST OF THE INSPIRATION COMES FROM SEEING

13:19 2 THE PROCESSES IN THE FIELD AND THEN GOING BACK INTO THE
13:19 3 LABORATORY AND TRYING TO REPRODUCE THOSE WITH STANDARD MODELS.
13:19 4 Q. YOUR PUBLICATIONS ARE LARGELY LISTED IN YOUR RÉSUMÉ, BUT I
13:19 5 WANT TO TOUCH UPON ONE. YOU WERE THE LEAD AUTHOR HAVING BEEN
13:19 6 HIRED BY THE STATE OF LOUISIANA TO LEAD THE TEAM LOUISIANA
13:19 7 REPORT AFTER HURRICANE KATRINA; IS THAT RIGHT?
13:20 8 A. NOT EXACTLY. I WAS NOT THE LEAD AUTHOR. I WAS THE
13:20 9 PRIMARY SCRIBE, LET'S SAY. I WORKED VERY CLOSELY WITH
13:20 10 DR. VAN HEERDEN, WHO WAS THE LEAD AUTHOR.
13:20 11 Q. I APOLOGIZE FOR THE MISCHARACTERIZATION. SHALL WE SAY YOU
13:20 12 WERE INTEGRALLY INVOLVED WITH DR. VAN HEERDEN COORDINATING AND
13:20 13 PUTTING TOGETHER, WITH THE WHOLE TEAM, THE TEAM LOUISIANA
13:20 14 REPORT?
13:20 16 MR. ROY: YOUR HONOR, THAT IS IN EVIDENCE AS PX-4 IN
13:20 17 ITS ENTIRETY.
13:20 18 THE COURT: THANK YOU.
13:20 19 BY MR. ROY:
13:20 20 Q. NOW, YOU RENDERED A NUMBER OF REPORTS IN THIS CASE. THE
13:20 21 PRIMARY ONE, WHICH WE WILL BE REFERRING TO MOSTLY TODAY AS THE
13:20 22 KEMP REPORT, IS THE ONE THAT WE'VE LABELED AND IS IN THE RECORD
13:20 23 AS PX-91; IS THAT CORRECT?
13:20 25 Q. YOU'VE REVIEWED OTHER INVESTIGATIONS AND STUDIES OF WHAT
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13:20 1 HAPPENED, SOME SAID, AT KATRINA FROM THE PERSPECTIVE OF OTHERS,

13:20 2 INCLUDING IPET AND ILIT, AND YOU DELINEATE THESE IN YOUR
13:21 3 REPORT; CORRECT?
13:21 5 MR. ROY: YOUR HONOR, AT THIS TIME WE'D LIKE TO ASK
13:21 6 THE COURT TO ACCEPT DR. PAUL KEMP AS AN EXPERT IN THE AREAS OF
13:21 7 COASTAL GEOLOGY, OCEANOGRAPHY, INCLUDING HYDRODYNAMIC MODELING
13:21 8 OF WAVES AND SURGE AND WETLAND EFFECTS ON WAVE AND SURGE,
13:21 9 MARINE SCIENCES, INCLUDING HYDROLOGY, AND COASTAL STUDIES,
13:21 10 INCLUDING SEDIMENTOLOGY.
13:21 11 MR. LEVINE: NO OBJECTION.
13:21 12 THE COURT: THANK YOU, COUNSEL. THE COURT ACCEPTS
13:21 13 THE WITNESS AS TENDERED.
13:21 14 MR. ROY: THANK YOU, YOUR HONOR.
13:21 15 THANK YOU, COUNSEL.
13:21 16 DIRECT EXAMINATION
13:21 17 BY MR. ROY:
13:21 18 Q. DR. KEMP, YOU WERE FIRST HIRED BY THE ROBINSON/MRGO TRIAL
13:21 19 TEAM, IF YOU WILL, BACK IN 2007; IS THAT CORRECT?
13:21 20 A. THAT'S RIGHT. AS SOON AS I FINISHED THE TEAM LOUISIANA
13:21 21 REPORT, I STILL HAD A LOT OF QUESTIONS ABOUT WHAT HAD HAPPENED
13:21 22 AND I SOUGHT AN OPPORTUNITY TO FIND OUT.
13:21 23 Q. PRIOR TO BEING RETAINED BY THE PLAINTIFF LAWYERS IN THIS
13:21 24 COURTROOM, GIVE THE COURT AN IDEA OF HOW MANY HOURS YOU HAD
13:22 25 SPENT ANALYZING, RECONSTRUCTING, TRYING TO FIGURE OUT WHY
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13:22 1 KATRINA DID WHAT IT DID TO THE METROPOLITAN AREA OF

13:22 2 NEW ORLEANS.
13:22 3 A. I RECENTLY ESTIMATED SOMETHING IN EXCESS OF 2,300 HOURS.
13:22 4 OF COURSE, MY INVOLVEMENT BEGAN BEFORE THE STORM HIT, WHEN WE
13:22 5 WERE PROVIDING THE FORECASTS. I THINK THE EXPERIENCE OF
13:22 6 ACTUALLY SEEING OVERTOPPING SIMULATED ON THE COMPUTER SCREEN
13:22 7 GALVANIZED ME AND I FELT I REALLY, REALLY NEEDED TO UNDERSTAND
13:22 8 WHAT WAS GOING ON. SO AS SOON AS I COULD, I GOT BACK INTO
13:22 9 NEW ORLEANS, INITIALLY WITH MILITARY ESCORTS, TO STUDY THE --
13:23 10 TO MAP THE SURGE HIGH WATER MARKS.
13:23 11 Q. DR. KEMP, SPECIFICALLY, BEFORE EVER BEING HIRED BY THIS
13:23 12 GROUP OF PLAINTIFF ATTORNEYS IN THIS CASE, IN THE MRGO DIVISION
13:23 13 LITIGATION OF THE UMBRELLA, THE SHORT ANSWER IS YOU PUT OVER 23
13:23 14 HOURS, BY YOUR OWN ESTIMATE, NEVER COMPENSATED --
13:23 15 THE COURT: 2,300.
13:23 16 THE WITNESS: I WISH I COULD HAVE DONE IT IN 23
13:23 17 HOURS.
13:23 18 THE COURT: YOU SAID 23. YOU MEANT 2,300.
13:23 19 MR. ROY: I MEANT 2,300, YOUR HONOR.
13:23 20 BY MR. ROY:
13:23 21 Q. IS THAT CORRECT, DR. KEMP?
13:23 23 Q. SINCE BEING RETAINED BY THE MRGO/ROBINSON TRIAL TEAM, CAN
13:23 24 YOU ESTIMATE HOW MANY HOURS THAT YOU HAVE PUT IN THAT HAVE BEEN
13:23 25 ON OUR NICKEL, IF YOU WILL.
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13:23 1 A. I'M LOOKING AT THE TICKER, AND I THINK IT'S AROUND 800.
13:23 2 Q. WHEN OUR LITIGATION TEAM RETAINED YOU ON BEHALF OF THE
13:24 3 ROBINSON PLAINTIFFS, YOUR SPECIFIC ASSIGNMENT -- OR I SHOULD
13:24 4 SAY YOUR GENERAL ASSIGNMENT WAS TO WORK OUT AN ANALYTICAL PLAN
13:24 5 WHEREBY DIFFERENT EXPERT GROUPS WOULD RUN DIFFERENT EXPERT
13:24 6 MODELS IN LOGICAL SEQUENCES THAT WOULD ULTIMATELY ANSWER THE
13:24 7 QUESTION OF HOW MUCH, IF ANY, DID THE MRGO CONTRIBUTE TO THE
13:24 8 FLOODING IN THE ROBINSON PLAINTIFF CASES?
13:24 9 A. THAT'S CORRECT. I HAVE TO TAKE SOME RESPONSIBILITY FOR
13:24 10 WHATEVER CONFUSION THIS COURT FEELS ABOUT ALL THOSE MODEL RUNS
13:24 11 THAT WERE DONE. THEY WERE A MEANS TO AN END. ULTIMATELY, WE
13:24 12 WANTED TO KNOW HOW MUCH OF THE WATER IN NORMAN ROBINSON'S HOUSE
13:24 13 AND MS. FRANZ'S HOUSE WAS ACTUALLY ATTRIBUTABLE TO THE MRGO.
13:24 14 Q. WE'RE GOING TO GET INTO THAT IN EXQUISITE DETAIL LATER,
13:24 15 DR. KEMP.
13:24 16 YOU'VE INVESTIGATED THE HISTORICAL DESIGN EVOLUTION
13:24 17 OF THE MRGO, BOTH REACH 1 AND REACH 2, AND ON A SIMULTANEOUS
13:25 18 COURSE THE HISTORIES, IF YOU WILL, OF THE GULF INTRACOASTAL
13:25 19 WATERWAY AND THE IHNC?
13:25 21 Q. YOU WERE, IN EFFECT, THE PLAINTIFFS' EXPERT
13:25 22 MANAGER/COORDINATOR UP TO THE POINT YOU HAND OFF YOUR DATA TO
13:25 23 DR. BEA; CORRECT?
13:25 24 A. YES, YES. I WOULD SAY THAT DR. BEA AND I BOTH WERE ON THE
13:25 25 SAME LEVEL. OF COURSE, HE'S A MEMBER OF THE NATIONAL ACADEMY
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13:25 1 OF ENGINEERING. BUT FOR PURPOSES OF THIS LITIGATION, I WOULD

13:25 2 HAND MY RESULTS TO HIM.
13:25 3 Q. AS A FIELD SCIENTIST, YOU USE MODELS AS TOOLS TO
13:25 4 UNDERSTAND WHAT YOU ACTUALLY ARE OBSERVING IN THE FIELD, THE
13:25 5 REALITY THAT YOU OBSERVE?
13:25 6 A. THAT'S CORRECT. MANY PEOPLE WILL RECALL THAT IN THE
13:25 7 AFTERMATH OF KATRINA, THERE WERE MANY REPORTS COMING FROM
13:25 8 DIFFERENT QUARTERS, SOME OFFICIAL QUARTERS, ABOUT WHAT HAD
13:26 9 HAPPENED. MOST OF THEM TURNED OUT TO BE INCORRECT OR
13:26 10 INACCURATE. I FOUND THE ONLY WAY TO FIND OUT WAS TO ACTUALLY
13:26 11 GO LOOK.
13:26 12 Q. FOUR DAYS AFTER KATRINA, ON SEPTEMBER 2, 2005, YOU FLEW
13:26 13 OVER THE ENTIRETY OF NEW ORLEANS AND SOUTH LOUISIANA AND
13:26 14 SOUTHERN MISSISSIPPI ON AN AIR RECON MISSION DOING GENERAL
13:26 15 OBSERVATIONS; CORRECT?
13:26 16 A. THAT'S RIGHT. WE WERE TRYING TO PLAN OUR FIELD CAMPAIGN,
13:26 17 AND THAT WAS THE BEST WAY TO GET AN OVERVIEW.
13:26 18 Q. FIVE DAYS LATER, YOU WERE BOOTS ON THE GROUND HERE IN
13:26 19 NEW ORLEANS AND ST. BERNARD; CORRECT?
13:26 20 A. WELL, BOOTS IN THE BOAT.
13:26 21 Q. TRUE STORY. I'M SORRY. BOOTS IN THE BOAT.
13:26 22 A. RIGHT. AGAIN, OF COURSE, AT THAT TIME THERE WAS STILL A
13:26 23 LOT OF RESCUES GOING ON AND SO ON, BUT WE WERE ABLE TO GET OUT
13:26 24 TO THE PERIMETER AND BEGIN TO FIGURE OUT HOW COULD WE -- AS
13:26 25 QUICKLY AS POSSIBLE BECAUSE THE HIGH WATER MARKS THAT WE WERE
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13:26 1 LOOKING FOR WERE VERY PERISHABLE AND ALSO BEING DISRUPTED BY
13:27 2 REPAIR ACTIVITIES -- HOW COULD WE QUICKLY MAP THE SURGE ON THE
13:27 3 PERIMETER.
13:27 4 Q. YOU SYSTEMATICALLY MAPPED THAT, CORRECT, WITH YOUR TEAM?
13:27 5 A. I DID. I DID. IT WAS KIND OF LIKE PAINTING TOM SAWYER'S
13:27 6 FENCE. EVERY TIME I WOULD GO, THERE WOULD BE MORE PEOPLE WITH
13:27 7 ME, USUALLY FROM THE CORPS OF ENGINEERS OR FROM FEMA OR VARIOUS
13:27 8 AGENCIES. THE GOOD NEWS WAS THAT BECAUSE EVERYBODY WAS THERE
13:27 9 TOGETHER, WE ALL CAME TO THE SAME CONCLUSIONS ABOUT WHAT HIGH
13:27 10 WATER MARKS WERE GOOD. AND THEN WE HAD A TEAM OF SURVEYORS
13:27 11 FOLLOWING AFTERWARDS, YOU KNOW, TO MAP THE ELEVATIONS.
13:27 12 Q. DR. KEMP, YOU AND YOUR TEAM WERE SEEKING TO VALIDATE YOUR
13:27 13 MODEL RESULTS AND ESTABLISH THE SURGE SEQUENCING AND ITS
13:27 14 EFFECTS ON BREACHING; IS THAT CORRECT?
13:27 15 A. THAT'S CORRECT. BECAUSE WE HAD THE ONLY SURGE MODEL THAT
13:27 16 HAD BEEN RUN AT THAT TIME AND BECAUSE OUR RESULTS SEEMED TO BE
13:28 17 SO ACCURATE, WE WERE THEN PRETTY CONFIDENT THAT WE UNDERSTOOD
13:28 18 THE SEQUENCE, BUT WE WANTED TO VERIFY THAT.
13:28 19 Q. A LOT OF THIS MODELING IS DONE WITH THE ADCIRC SO8;
13:28 20 CORRECT?
13:28 21 A. ALL OF THE SURGE MODELING WAS DONE WITH THE SO8 VERSION OF
13:28 22 ADCIRC CREATED BY JOANNES WESTERINK AND MODIFIED WITH OUR HELP
13:28 23 AT THE LSU HURRICANE CENTER.
13:28 24 THE COURT: WOULD YOU MIND, MR. ROY, DELINEATING THE
13:28 25 ACRONYM FOR THE COURT REPORTER.
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13:28 1 MR. ROY: YES, SIR.

13:28 2 BY MR. ROY:
13:28 3 Q. WILL YOU TELL THE COURT WHAT THE ACRONYM, ALL CAPS, ADCIRC
13:28 4 SO8 STANDS FOR.
13:28 5 A. ADVANCED CIRCULATION. I THINK THE ORIGINATOR OF THE MODEL
13:28 6 IS IN THE COURTROOM. I'M NOT SURE.
13:28 7 Q. IT'S KNOWN AS ADCIRC IN THE COMMUNITY?
13:28 8 A. ADCIRC.
13:29 9 THE COURT: THAT WAS WHAT I WAS MAINLY CONCERNED
13:29 10 WITH, ADCIRC, NOT NECESSARILY THE FULL TITLE. GO AHEAD.
13:29 11 BY MR. ROY:
13:29 12 Q. THE DETAILS OF WHAT YOU SAW AND THE DATA COLLECTED ARE,
13:29 13 ONCE AGAIN, EXQUISITELY DETAILED IN YOUR REPORTS; CORRECT?
13:29 15 Q. THE EXPERT REPORTS THAT YOU'VE PREPARED, YOU AND I HAVE
13:29 16 GONE THROUGH THESE LISTINGS BEFORE.
13:29 17 MR. ROY: SO FOR THE BENEFIT OF THE RECORD, I'LL GIVE
13:29 18 THE ACTUAL RECORD NUMBERS, YOUR HONOR, OF THE ACTUAL REPORTS OF
13:29 19 DR. KEMP THAT ARE IN THE RECORD AND THE DATES AS WE UNDERSTAND
13:29 20 THEM TO BE SO THAT IF YOU HAVE LOOKED AT A REPORT IN THE RECORD
13:29 21 AND ALL IT'S GOT IS A DATE, IT CAN NOW BE MATCHED WITH AN
13:29 22 EXHIBIT NUMBER.
13:29 23 THE PRIMARY REPORT IS, OF COURSE, THE JULY 11,
13:29 24 2008 REPORT, PX-91. THE JULY 28, 2007 REPORT IS JX-194.
13:29 25 APPENDIX B TO THE JULY 14, '08 REPORT IS PX-92. THE
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13:30 1 OCTOBER 19, 2008 DECLARATION IS PX-93. THE JANUARY 14, '09
13:30 2 DECLARATION IS PX-2152. I BELIEVE THAT HAD TO BE ADDED.
13:30 3 THAT'S A NEW NUMBER BECAUSE IT HAD SOMEHOW BEEN LEFT OFF.
13:30 4 WE TOLD Y'ALL ABOUT IT. IT HAD TO BE ADDED. IT
13:30 5 WASN'T IN THE ORIGINAL FILING AT THE BEGINNING OF TRIAL.
13:30 6 MR. LEVINE: I'M LOOKING. FOR THE RECORD, I DIDN'T
13:30 7 THINK WE HAD ATTACHED IT AS AN EXHIBIT, SO NO PROBLEM.
13:30 8 BY MR. ROY:
13:30 9 Q. THERE ARE OTHER REPORTS, I THINK PX-94, WHICH IS SEPTEMBER
13:30 10 16, 2007, YOUR SO-CALLED 702C DECLARATION. ALL THAT'S CORRECT,
13:30 11 DR. KEMP, AS WE TALKED ABOUT?
13:30 12 A. I BELIEVE THERE WAS ONE OTHER REPORT THAT'S A MAY 1
13:30 13 REPORT, BUT IT WAS A DRAFT THAT WAS SUPERSEDED BY THE JULY 11
13:30 14 REPORT.
13:30 15 MR. ROY: FAIR ENOUGH. TO MY KNOWLEDGE THAT DRAFT IS
13:30 16 NOT IN THE RECORD, YOUR HONOR, SINCE IT WAS JUST A DRAFT.
13:31 17 BY MR. ROY:
13:31 18 Q. LET'S TURN TO YOUR PRIMARY CONCLUSIONS.
13:31 19 MR. ROY: YOUR HONOR, WITH YOUR PERMISSION, I'D LIKE
13:31 20 TO TOUCH UPON THEM TO FRAME HIS TESTIMONY, AND THEN WE'LL GO
13:31 21 BACK AND GET THE BASES FOR EACH OF THEM BRIEFLY WITHOUT
13:31 22 REGURGITATING THE WHOLE REPORT.
13:31 23 THE COURT: I GENERALLY LIKE THAT APPROACH, YES, SIR.
13:31 24 MR. ROY: COULD WE PULL UP PAGE 2 OF THE POWERPOINT.
25
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1742
13:31 1 BY MR. ROY:

13:31 2 Q. DR. KEMP, WHAT IS YOUR FIRST OPINION?
13:31 3 A. MY FIRST OPINION IS THAT THE MRGO NAVIGATION PROJECT
13:31 4 CREATED A FUNNEL, THE DANGEROUS CONVERGENCE OF CHANNELS AND
13:31 5 SPOIL DISPOSAL AREAS, LATER AUGMENTED BY ADDITION OF THE LAKE
13:31 6 PONTCHARTRAIN AND VICINITY (LPV) BERMS EAST OF NEW ORLEANS AND
13:31 7 BY THE SUBTRACTION OF BUFFERING WETLANDS THAT FORESEEABLY
13:31 8 AMPLIFIED THE THREAT POSED BY HURRICANE SURGE TO THE GREATER
13:31 9 NEW ORLEANS AREA.
13:32 10 Q. YOU DISCUSSED THE FUNNEL EXQUISITELY IN PX-91. HAS ANY
13:32 11 DEFENSE EXPERT IN ANY REPORT OPINED THAT THERE WAS NOT A FUNNEL
13:32 12 EFFECT?
13:32 13 A. I HAVE FOUND IT ONLY IN U.S. ARMY DISTRICT DOCUMENTS, BUT
13:32 14 I HAVE NOT FOUND IT BY ANYBODY THAT UNDERSTOOD THE
13:32 15 OCEANOGRAPHY.
13:32 16 Q. IN THIS LITIGATION HAVE ANY OF THE ARMY CORPS OF
13:32 17 ENGINEERS' EXPERTS, TO YOUR KNOWLEDGE, OPINED THERE WAS NO
13:32 18 FUNNEL EFFECT?
13:32 19 A. NO, SIR.
13:32 20 Q. JUST TO OFFER THREE VISUAL PERSPECTIVES INVOLVING THE
13:32 21 FUNNEL, LET'S PULL UP, IF WE CAN, PAGE 3 OF THE POWERPOINT.
13:32 22 DR. KEMP, YOU HAVE A LASER POINTER THERE IF YOU NEED TO USE IT.
13:32 23 A. I DO.
13:32 24 Q. FEEL FREE TO. WOULD YOU JUST ORIENT US WITH THIS ONE.
13:32 25 THE COURT: EXCUSE ME.
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1743
13:33 1 THE WITNESS: THE JUDGE HAS IT NOW, BUT YOU-ALL

13:33 2 DON'T. I CAN PUT THE LASER POINTER ON THERE.
13:34 3 MR. ROY: YOUR HONOR, I THINK I CAN PROCEED WITH A
13:34 4 SUBSTANTIAL PORTION OF THIS. I'LL STOP WHEN I NEED TO GO INTO
13:34 5 AN EXHIBIT. IF WE CAN TURN THE ELMO ON, PERHAPS I COULD GET
13:34 6 ONE OF MY COLLEAGUES TO PUT ON THE PRECISE PAGES, AND WE'LL GET
13:35 7 THE SAME RESULT IF YOU LIKE.
13:35 8 THE COURT: STEVE, WE THINK WE'VE GOT IT RECTIFIED,
13:35 9 BUT YOU MIGHT LET SHEENA TELL YOU.
13:37 10 BY MR. ROY:
13:37 11 Q. DR. KEMP, IN CONNECTION WITH YOUR FIRST OPINION, THE
13:37 12 POWERPOINT PAGE IS UP NOW, WHICH IS REFLECTING THREE SEPARATE
13:37 13 IMAGES: PX-91 AT PAGE 10; PX-91 AT PAGE 14; AND PX-91 AT
13:37 14 PAGE 20. WOULD YOU DESCRIBE TO THE COURT WHAT WE HAVE UP HERE.
13:37 15 A. THESE ARE THREE VIEWS OF WHAT WE EQUAL THE FUNNEL, AND
13:37 16 THAT IS BASICALLY THE CONVERGING CHANNELS HERE FLANKED NOW BY
13:37 17 THE LPV LEVEES. THERE'S ALSO A THROAT TO THE FUNNEL, WHICH IS
13:37 18 THE MRGO REACH 1, AND THEN IHNC IS THE BENT TO
13:37 19 LAKE PONTCHARTRAIN.
13:37 20 HERE'S AN OBLIQUE VIEW. YOU CAN SEE THIS IS LOOKING
13:37 21 OVER THE PARIS ROAD BRIDGE. THE GIWW IS GOING OFF TO THE LEFT,
13:38 22 WHICH WOULD BE TO THE NORTH. THEN THE MRGO SHIP CHANNEL IS
13:38 23 GOING OFF TO THE RIGHT. THESE ARE THE LEVEE ALIGNMENTS THAT
13:38 24 FOLLOW THOSE CHANNELS.
13:38 25 THEN THIS IS A PLAN VIEW JUST AT THE JUNCTION OF THE
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1744
13:38 1 GIWW AND THE MRGO. IT'S A LITTLE DARK, BUT THIS SHOWS SOME OF
13:38 2 THE ENLARGEMENT OF THE CHANNEL. THIS IS THE LPV STRUCTURE HERE
13:38 3 AND ALONG HERE. THIS AREA, I GUESS, WOULD BE CALLED THE GOLDEN
13:38 4 TRIANGLE AREA.
13:38 5 Q. WE'RE GOING TO BE COMING BACK TO IT AND TALK ABOUT IT AT
13:38 6 GREAT LENGTH LATER, BUT WHILE YOU HAVE THIS IMAGE UP, IN THE
13:38 7 LOWER RIGHT-HAND CORNER, PX-91 AT PAGE 14, IN FACT, A VERY
13:38 8 WIDE, DEEP SECTION OF THE REACH 2 MRGO IS RIGHT THERE IN THAT
13:38 9 MILE OR TWO OR THREE BEFORE IT INTERSECTS WITH THE REACH 1;
13:38 10 CORRECT?
13:39 12 Q. IS THAT SIGNIFICANT? WE'RE GOING TO COME BACK AND TALK
13:39 13 ABOUT IT.
13:39 14 A. WELL, I THINK THE WIDENING OF REACH 2 -- THAT'S JUST A
13:39 15 REPRESENTATIVE AREA -- IS CHARACTERISTIC ALL ALONG THAT IN
13:39 16 FRONT OF THE LPV STRUCTURES.
13:39 17 Q. LET'S PULL UP PAGE 4 OF THE POWERPOINT, YOUR SECOND
13:39 18 OPINION. PAGE 4 OF THE POWERPOINT, WILL YOU TELL THE COURT
13:39 19 WHAT YOUR SECOND EXPERT OPINION IS.
13:39 20 A. IT IS MY OPINION THAT THE MRGO NAVIGATION PROJECT GREATLY
13:39 21 ENLARGED THE ORIGINAL GULF INTRACOASTAL WATERWAY CONNECTION
13:39 22 BETWEEN THE THROAT OF THE FUNNEL AND THE INNER HARBOR
13:39 23 NAVIGATION CANAL, AND THAT SECTION OF THE GIWW IS ALSO CALLED
13:39 24 THE MRGO REACH 1. THAT FORESEEABLY INCREASED SURGE
13:39 25 TRANSMISSION INTO THE CITY EARLIER, ADDING TO THE HEIGHT AND
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1745
13:39 1 DURATION OF SURGE EXPERIENCED IN THE IHNC DURING KATRINA AND

13:39 2 CONTRIBUTING TO THE EARLY FAILURE OF FLOOD WALLS AND LEVEES
13:40 3 ADJACENT TO THE IHNC.
13:40 4 Q. REACH 1 WIDENING -- LET'S PULL UP PAGE 50 OF THE
13:40 5 POWERPOINT. THIS ILLUSTRATES DIRECTLY THE CONCEPT OF HOW MUCH
13:40 6 REACH 1 WAS REALLY WIDENED IN ITS ORIGINAL DESIGN CONSTRUCTION
13:40 7 AND, IN FACT, BY LATER EXPANSION DUE TO DREDGING AND EROSION;
13:40 8 CORRECT?
13:40 9 A. THAT'S RIGHT. THIS IS NOT A SURVEYOR'S MAP, BUT IT DOES
13:40 10 SHOW THE RELATIVE SIZES OF THE ORIGINAL AUTHORIZED GIWW HERE
13:40 11 THAT EXISTED BEFORE THE PROJECT AND THEN THE AUTHORIZED
13:40 12 TEMPLATE OF THE CHANNEL AND THEN THE ACTUAL OUTLINES OF THE
13:40 13 CHANNEL AS IT EXISTED BEFORE HURRICANE KATRINA STRUCK ON
13:40 14 AUGUST 29, 2005.
13:40 15 Q. SO IN SUM AND SUBSTANCE, YOU'VE SHOWN THE ORIGINAL THE WAY
13:40 16 IT WAS BEFORE MRGO REACH 1 WAS ENLARGED IN THE MID '60S, EARLY
13:41 17 '70S, AND THEN YOU'VE SHOWN ADDITIONALLY -- SCHEMATICALLY, AT
13:41 18 LEAST -- THE ADDITIONAL WIDTH AND DEPTH SINCE THAT TIME?
13:41 19 A. THAT'S CORRECT, BUT THIS IS MUCH LESS WIDENING THAN WE
13:41 20 WOULD SEE FURTHER DOWN THE CHANNEL IN REACH 2. THIS IS IN THE
13:41 21 REACH 1 SECTION, WHICH IS THE THROAT OF THE FUNNEL. THE
13:41 22 INCREASE HERE IS ON THE ORDER OF 12 TIMES IN TERMS OF GOING
13:41 23 FROM THE GIWW TO THE NAVIGATION PROJECT.
13:41 24 Q. LET'S TURN TO PAGE 6 OF THE POWERPOINT AND GIVE ME YOUR
13:41 25 THIRD PRIMARY OPINION. GIVE THE COURT YOUR THIRD PRIMARY
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1746
13:41 1 OPINION.
13:41 2 A. IT IS MY OPINION THAT THE MRGO NAVIGATION PROJECT CREATED
13:41 3 A REACH 2 CHANNEL WITH UNSTABLE SIDE SLOPES THAT CAUSED IT TO
13:41 4 PREDICTABLY EXPAND OVER TIME, REDUCING THE NATURAL MARSH BUFFER
13:41 5 THAT PREVIOUSLY SEPARATED IT FROM LAKE BORGNE ON ONE SIDE AND
13:41 6 FROM THE ADJACENT LPV BERMS ON THE OTHER, THEREBY COMPROMISING
13:42 7 FORESHORE PROTECTION FOR THE MAN-MADE LPV SURGE PROTECTION
13:42 8 ELEMENTS AND HASTENING THE ONSET OF DAMAGING WAVE ACTION ON
13:42 9 THESE DELICATE STRUCTURES SO THAT THEY BREACHED EARLIER IN THE
13:42 10 STORM SEQUENCE.
13:42 11 Q. YOUR FOURTH OPINION, LET'S PULL UP PAGE 9 OF THE
13:42 12 POWERPOINT.
13:42 13 A. IT IS MY OPINION THAT THE MRGO NAVIGATION PROJECT CREATED
13:42 14 A CHANNEL IN REACH 2 THAT PREDICTABLY EXPOSED FRESHWATER SWAMPS
13:42 15 AND MARSHES WITHIN THE LAKE BORGNE FUNNEL TO INCREASED
13:42 16 SALINITY, ACCELERATING THEIR CONVERSION TO OPEN WATER, AND
13:42 17 THEREBY REDUCING THE WETLAND SURGE AND WAVE BUFFER BETWEEN
13:42 18 LAKE BORGNE AND POPULATED AREAS.
13:42 19 Q. PAGE 11, YOUR FIFTH OPINION, IF YOU COULD TELL THE COURT.
13:42 20 A. IT IS MY OPINION THAT THE MRGO NAVIGATION PROJECT WAS A
13:42 21 SUBSTANTIAL CONTRIBUTING FACTOR TO THE CATASTROPHIC FLOODING OF
13:43 22 THE ROBINSON PLAINTIFFS' HOMES AND COMMUNITIES.
13:43 23 Q. NOW, IS IT CORRECT, SIR, THAT ONLY BY UNDERSTANDING THE
13:43 24 MRGO'S ROLE IN HASTENING THE FLOODING ONSET CAN WE EXPLAIN A
13:43 25 NUMBER OF THINGS IMPORTANT TO UNDERSTANDING YOUR OPINION?
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1747

13:43 2 Q. LET'S PULL UP PAGE 12.
13:43 3 A. OKAY. TO ME, WHEN I WAS WRITING THE TEAM LOUISIANA, THIS
13:43 4 IS WHAT REALLY MOTIVATED ME TO LOOK FURTHER. I NOTICED THAT
13:43 5 ST. BERNARD -- WHICH THE AREA THAT FLOODED IN ST. BERNARD IS
13:43 6 ACTUALLY, ON AVERAGE, ABOVE SEA LEVEL TWO-AND-A-HALF FEET, AND
13:43 7 YET IT FLOODED TO THE GREATEST DEPTH. THE MAXIMUM ELEVATION
13:43 8 THERE WAS AROUND 11 FEET ABOVE SEA LEVEL.
13:43 9 OTHER AREAS WHICH ALSO FLOODED HAD MUCH LOWER LAND
13:43 10 ELEVATIONS, BUT THEY DIDN'T FLOOD AS DEEPLY. THE ONLY WAY TO
13:44 11 UNDERSTAND THIS IS IF YOU REALLY UNDERSTAND THE DYNAMICS OF THE
13:44 12 FLOODING, THE BREACHING EVENTS THAT LED TO THAT, AND WHEN THEY
13:44 13 OCCURRED: EARLY IN THE SURGE SEQUENCE AS OPPOSED TO LATER ON.
13:44 14 Q. NOW, YOU HAVE A SIXTH OPINION THAT'S REFLECTED IN YOUR
13:44 15 REPORT, PX-91, CHAPTER 10. THERE'S A TYPO. IT'S REALLY THE
13:44 16 SECOND CHAPTER 9, BETWEEN PAGES 185 AND 195. AND THAT IS THAT
13:44 17 THE CORPS WAS AWARE BY AT LEAST 1966 THAT THE MRGO PROJECT
13:44 18 ENHANCED CATASTROPHIC SURGE RUSH; CORRECT?
13:44 19 A. YES. THAT WAS BASED ON MY ANALYSIS OF WHAT KNOWLEDGE THE
13:44 20 CORPS HAD WHEN IN TERMS OF THE ADDITIONAL RISKS POSED BY THE
13:44 21 STRUCTURE THEY HAD BUILT. IT'S MY OPINION THAT THEY WERE AWARE
13:44 22 AT LEAST BY 1966 THAT THE MRGO PROJECT ENHANCED CATASTROPHIC
13:45 23 STORM SURGE RISK, I WILL SAY, TO THE CITY OF NEW ORLEANS BUT
13:45 24 NEVER UNDERTOOK TO WARN CONGRESS ABOUT THIS POSSIBILITY AND
13:45 25 NEVER SOUGHT FUNDING FOR REMEDIAL MEASURES, THOUGH SUCH
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1748
13:45 1 MEASURES HAD BEEN PROPOSED AND WERE WELL UNDERSTOOD AT THAT
13:45 2 TIME.
13:45 3 Q. IN REVIEWING THE VAST BODY OF INFORMATION THAT YOU DID,
13:45 4 INCLUDING THE HISTORICAL INFORMATION, PRIOR REPORTS, AND SO
13:45 5 FORTH, THAT ARE DELINEATED IN YOUR REPORTS, WHEN'S THE FIRST
13:45 6 TIME, IN YOUR PROFESSIONAL OPINION, THAT YOU SAW THE CORPS
13:45 7 APPLY GENERALLY ACCEPTED AND KNOWN OCEANOGRAPHIC INFORMATION
13:45 8 AND TECHNIQUES TO THIS SURGE THAT THEY HAVE CREATED AND
13:45 9 AGGRAVATED THROUGH THE FUNNEL CREATED BY THE JOINING OF REACH 2
13:45 10 AND THE GIWW?
13:45 11 A. THE FIRST SERIOUS TREATMENT THAT I SAW OF THAT ACTUALLY
13:45 12 CAME AFTER HURRICANE BETSY IN 1966, WHEN THE CORPS ENGAGED
13:46 13 BRETSCHNEIDER AND COLLINS, TWO OF THE LEADING OCEANOGRAPHIC
13:46 14 HYDRAULIC ENGINEERS OF THE TIME, TO STUDY THE EFFECT. THIS WAS
13:46 15 IN THE CONTEXT OF LITIGATION, LIKE WHAT WE HAVE TODAY, AFTER
13:46 16 HURRICANE BETSY.
13:46 17 Q. WHAT KIND OF A STUDY WAS IT?
13:46 18 A. WELL, IT WAS AN ARMCHAIR STUDY; THAT IS, IT DIDN'T INVOLVE
13:46 19 A FIELD INVESTIGATION. IT WAS CONDUCTED BASED ON INFORMATION
13:46 20 THAT THE CORPS PROVIDED TO THE PARTICIPANTS, BUT IT WAS
13:46 21 ACTUALLY VERY PROGRESSIVE IN MANY WAYS. CERTAINLY, IF ONE READ
13:46 22 IT CAREFULLY, THERE WAS AN AWFUL LOT TO BE CONCERNED ABOUT IN
13:46 23 THAT STUDY.
13:46 24 Q. NOW, THE B&C STUDY IS IN EVIDENCE AT PX-68, CLEARLY
13:47 25 REFERRED TO IN YOUR REPORT.
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1749
13:47 1 MR. ROY: I WANT YOU TO PULL UP, PLEASE, CARL

13:47 2 POWERPOINT 5, PAGE 5.
13:47 3 THE WITNESS: YES. THESE ARE TWO FIGURES FROM THAT
13:47 4 STUDY.
13:47 5 BY MR. ROY:
13:47 6 Q. PAGES 40 AND 48 FROM PX-68; CORRECT?
13:47 7 A. THEY'RE A LITTLE COMPLICATED, SO IF YOU'LL ALLOW ME TO
13:47 8 EXPLAIN IT SOME. ON THE LEFT, WHAT WE'RE SEEING IS THE
13:47 9 GEOMETRY OF TWO DIFFERENT TESTS THAT THEY RAN. THIS WAS IN
13:47 10 1966, SO THE MRGO NAVIGATION PROJECT WAS COMPLETE, OR NEARLY
13:47 11 COMPLETE, BUT THE LPV HURRICANE PROTECTION SYSTEM WAS STILL IN
13:47 12 A PROPOSED STATE. SO THEY TESTED -- ONE REASON THAT THIS IS
13:47 13 MOST INTERESTING IS BECAUSE THEY TESTED FOUR CONDITIONS TO SEE
13:47 14 THE EFFECT ON SURGE.
13:47 15 NO. 1, YOU SEE HERE EXISTING LEVEES; THAT IS, THERE
13:48 16 WAS SOME LEVEES ALONG THE 40 ARPENT, THERE WAS A LEVEE ALONG
13:48 17 THE NORTH SIDE OF THE GIWW, BUT THERE WAS NO NARROW THROAT LIKE
13:48 18 SHOWN IN THE BOTTOM.
13:48 19 AND THEN THERE WAS -- THEY TESTED ALSO, OKAY, LET'S
13:48 20 SAY IF WE JUST PUT THE -- THIS WAS ACTUALLY THE CONDITION
13:48 21 DURING BETSY, THE EXISTING LEVEES WITH THE MRGO PROJECT.
13:48 22 THAT'S NO. 2.
13:48 23 AND THEN NO. 3 IS THE PROPOSED LEVEE WITH MRGO.
13:48 24 THAT'S REALLY THE CONDITION WE HAVE TODAY, OR I SHOULD SAY AS
13:48 25 OF MAYBE LAST WEEK BECAUSE THE MRGO PROJECT'S NOW DEAUTHORIZED,
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1750
13:48 1 BUT THE PROPOSED LEVEES WITH NO MRGO.

13:48 2 SO THEY WERE LOOKING AT A LOT OF THE SAME THINGS WE
13:48 3 DID WITH OUR TESTING PROGRAM. I GUESS THE POINT HERE IS IF WE
13:48 4 LOOK AT THE CONDITION THAT EXISTED AT THE TIME OF -- OKAY.
13:49 5 THESE ARE TIME-OF-ONSET CURVES FOR A HYPOTHETICAL SURGE. WHAT
13:49 6 IT SHOWS IS THE -- OH, I SEE. I DIDN'T KNOW I COULD DO THAT.
13:49 7 THE SURGE, THE WORST CONDITION THAT IS THE EARLIEST
13:49 8 ONSET IS ACTUALLY CASE 3. THAT'S THE CASE THAT ACTUALLY IS IN
13:49 9 EXISTENCE DURING KATRINA, SO THAT'S THIS LINE HERE. I COULD
13:49 10 PUT THAT DOCUMENT. THAT'S THAT ONE.
13:49 11 THE SECOND WORST SITUATION IS CASE 2, WHICH IS THE
13:49 12 EXISTING LEVEES. SO ANYTHING WITH THE CHANNEL IN IT IS GOING
13:49 13 TO HAVE AN EARLIER ONSET. THEN THESE LAST TWO CASES HERE ON
13:50 14 THE END ARE ONLY THE EFFECT OF ADDING THE FUNNELING EFFECT OF
13:50 15 THE LEVEE.
13:50 16 SO HERE WHAT WE SEE IS THAT THERE IS AN ENHANCEMENT
13:50 17 OR A HASTENING OF THE SURGE ONSET CAUSED BY THE ADDITION OF THE
13:50 18 VERY LARGE CHANNEL, AND THERE IS A HASTENING CAUSED BY THE
13:50 19 ADDITION OF THE LEVEES ALONG THE CHANNELS. THEN IF YOU PUT
13:50 20 THEM TOGETHER, YOU GET AN ADDITIVE EFFECT. WHAT BRETSCHNEIDER
13:50 21 AND COLLINS DID WAS THEY WERE ABLE TO SEPARATE OUT THESE
13:50 22 EFFECTS, AND THAT WAS A VERY INTERESTING APPROACH THAT THEY
13:50 23 TOOK.
13:50 24 SO NOW, IN THIS CASE, THERE WAS NO -- THIS IS FOR A
13:50 25 SLOW-MOVING STORM. THERE WAS NO POSSIBILITY OF CHANGING THE
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1751
13:50 1 MAXIMUM ELEVATION UP HERE BECAUSE THAT WAS PART OF THEIR INPUT
13:50 2 CONDITION. THEY COULDN'T GO ANY HIGHER THAN THAT. BUT WHAT
13:50 3 DID CHANGE WAS THE DURATION. THIS IS TRUE OF ALL STORMS. THE
13:51 4 TIME WHEN THE STORM LEAVES THE REGION IS ALWAYS SET BY ITS
13:51 5 TRANSLATION, THE SPEED AT WHICH IT'S MOVING, IN THIS CASE, THE
13:51 6 CASE OF KATRINA, TOWARDS THE MISSISSIPPI COAST.
13:51 7 SO THE STORM IS GOING TO TRANSIT THE AREA, ALL CURVES
13:51 8 ARE GOING TO DROP AT THE SAME TIME, BUT WHAT CHANGES IS HOW
13:51 9 QUICKLY THAT SURGE COMES INTO THE INNER HARBOR NAVIGATION
13:51 10 CANAL.
13:51 11 Q. LET'S GET THIS CLEAR. I'M NO SCIENTIST. I WANT TO BE
13:51 12 SURE I'VE GOT IT. WHAT I'M POINTING TO RIGHT NOW IN THIS AREA
13:51 13 IS WITH NO REACH 2 AND NO --
13:51 14 A. THAT'S THE NEW LPV LEVEES BUT NO MRGO CHANNEL IN PLACE, NO
13:51 15 PROJECT.
13:51 16 Q. THE IMPORTANT POINT HERE FROM YOUR STANDPOINT, YOUR AREAS
13:51 17 OF EXPERTISE, IS THAT THE LPV SYSTEM AS PROPOSED IS NOT -- IS
13:52 18 NOT -- THE CAUSE OF THE ADDED NUMBER OF HOURS OF SURGE. IT IS
13:52 19 THE CHANNEL WIDENING AND DEEPENING BACK THEN, RECOGNIZED BY
13:52 20 THESE EXPERTS IN 1966, THAT INCREASES THE VOLUME OF WATER, THE
13:52 21 VELOCITY OF WATER, THUS NOT THE HEIGHT OF THE SURGE BUT THE
13:52 22 DURATION OF THE SURGE OVERTOPPING LEVEES; GENERALLY CORRECT?
13:52 23 A. THAT'S RIGHT. THE MAJOR EFFECT IS THE ADDITION OF THE
13:52 24 CHANNEL. THERE IS A MINOR EFFECT ASSOCIATED WITH THE GEOMETRY
13:52 25 OF THE PROPOSED LEVEE SYSTEM. BOTH OF THEM TOGETHER WORKED TO
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1752
13:52 1 EXACERBATE THE CONDITIONS.

13:52 2 IF I WAS THE CORPS OF ENGINEERS LOOKING AT THIS
13:52 3 PROJECT, I WOULD SAY, "GOSH, I DON'T KNOW IF WE REALLY
13:52 4 CONCEIVED OF IT PROPERLY IF ALL THE ADDITIONS THAT WE'RE
13:52 5 MAKING, ALL THE IMPROVEMENTS WE'RE MAKING ACTUALLY HASTEN THE
13:52 6 ONSET OF SURGE INTO THE CITY."
13:53 7 Q. BUT I'M MERELY SETTING THE STAGE FOR WHERE WE'RE GOING TO
13:53 8 GO MAYBE AN HOUR FROM NOW. THE BOTTOM LINE IS: THE
13:53 9 FUNDAMENTAL HYDRAULIC SCIENCE WITHIN YOUR PROFESSION, YOUR
13:53 10 EXPERTISE, IS LAID OUT FOR ALL TO SEE IF THEY WERE COMPETENT,
13:53 11 MINIMALLY, TO UNDERSTAND?
13:53 12 A. 1966.
13:53 13 Q. LET'S PULL UP PAGE 5 OF THE POWERPOINT. THAT IS PAGE 5 OF
13:53 14 THE POWERPOINT.
13:53 15 A. IT'S RIGHT THERE.
13:53 16 Q. IT'S A DEAD HORSE.
13:53 17 MR. ROY: FOR THE COURT, YOU CAN RECOGNIZE A DEAD
13:53 18 HORSE, TOO, YOUR HONOR.
13:53 19 BY MR. ROY:
13:53 20 Q. DID THE CORPS HEED THAT WARNING IN 1966?
13:53 21 A. I COULD FIND NO EVIDENCE THAT THEY HEEDED ANY WARNING AT
13:53 22 ANY TIME. THEY TOOK THIS STUDY AS CONFIRMATION OF THEIR
13:54 23 INITIAL ASSUMPTION. THE ASSUMPTION REALLY WAS THAT THIS MRGO
13:54 24 CHANNEL COULD HAVE BEEN BUILT IN FLORIDA. IT WAS JUST A BENIGN
13:54 25 PIECE OF LANDSCAPE THAT HAD NO HYDRAULIC EFFECT AT ALL. THAT
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13:54 1 WOULD MEAN THEY DIDN'T GET VERY FAR INTO BRETSCHNEIDER AND
13:54 2 COLLINS' REPORT.
13:54 3 Q. IN ESSENCE, ABOUT A YEAR OR SO AFTER THE STORM, THIS
13:54 4 STUDY, B&C, SCIENTIFICALLY PROVES THAT WITHOUT LPV STRUCTURES
13:54 5 THE MRGO ITSELF, REACH 1/REACH 2, THE WAY IT WAS BUILT, HAS
13:54 6 MAJOR HYDRODYNAMIC INFLUENCES UPON SURGE-RUSH VELOCITY AND
13:54 7 OVERTOPPING DURATION?
13:54 8 A. THAT'S CORRECT, BUT IT'S ALSO OCEANOGRAPHY 101 WOULD TELL
13:55 9 YOU THAT. AND, OF COURSE, WE MODELED THIS CONDITION AS WELL.
13:55 10 Q. WHY IS IT OCEANOGRAPHY 101, DR. KEMP, IF THE CORPS DID NOT
13:55 11 RECOGNIZE AND SAY, "AHA, I'VE A MAGIC MOMENT, PUBLIC. IT IS A
13:55 12 FUNNEL EFFECT CAUSED BY THE MRGO"? WHY IS IT OCEANOGRAPHY 101?
13:55 13 WHY IS IT THAT FUNDAMENTALLY SIMPLE THAT YOU GOT IT, B&C GOT
13:55 14 IT, BUT THE CORPS DIDN'T GET?
13:55 15 A. YOU KNOW, IT'S VERY DIFFICULT FOR ME TO PUT MYSELF IN THE
13:55 16 PLACE OF THE OFFICIALS READING THIS. I DON'T THINK THAT THAT
13:55 17 WAS THE MESSAGE THEY WERE LOOKING FOR. MY EXPERIENCE -- OF
13:55 18 COURSE, I'VE REVIEWED SUBSEQUENT -- AND REALLY DR. GAGLIANO AND
13:55 19 DR. HSU IN 1973 TOLD THEM EXACTLY THE SAME THING. HERE'S
13:55 20 DR. GAGLIANO, PROBABLY ONE OF THE LEADING DELTAIC GEOLOGISTS IN
13:55 21 THE COUNTRY; DR. HSU, THE LEADING OCEANOGRAPHIC METEOROLOGIST
13:56 22 IN THE COUNTRY, TELLING THEM THESE THINGS. IT DIDN'T MAKE A
13:56 23 DIFFERENCE.
13:56 24 Q. WHEN MR. CROSBY IN THE EARLY '70S -- LATE '60S. EXCUSE
13:56 25 ME. YOU REFERENCE THAT AT PAGE 91 OF YOUR REPORT. LET'S PULL
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13:56 1 UP PAGE 14.

13:56 2 DOES THIS ILLUSTRATE ANOTHER WARNING TO THE CORPS?
13:56 3 A. THIS IS ACTUALLY A COMPOSITE OF TWO IMAGES: ONE IS FROM
13:56 4 PX-91 AT 24; THE OTHER IS FROM PX-91 AT 37. IT'S CONTRASTING A
13:56 5 PLAN CALLED THE CROSBY PLAN THAT AT LEAST GOT TO THE STAGE OF
13:56 6 BEING PUT ON A MAP BY THE CORPS.
13:56 7 IT APPEARED IN THE 1967 CITRUS BACK LEVEE GENERAL
13:57 8 DESIGN MEMORANDUM, AND IT WAS CONSIDERED AN ALTERNATIVE. IT'S
13:57 9 ACTUALLY VERY SIMILAR TO THE 100-YEAR PLAN THAT'S NOW BEING
13:57 10 IMPLEMENTED IN THIS AREA SINCE KATRINA, BUT IT SHOWS A BARRIER
13:57 11 STRUCTURE ACROSS THE THROAT OF THE FUNNEL AND A FLOATING GATE
13:57 12 ACROSS THE MRGO CHANNEL.
13:57 13 Q. NOW, ALL THIS WAS DISMISSED OUT OF HAND, AND YOU DISCUSS
13:57 14 THAT DISMISSAL BY THE CORPS AT PAGES 23 AND 24 OF YOUR REPORT,
13:57 15 DO YOU NOT?
13:57 16 A. I DO.
13:57 17 Q. HAD THIS MITIGATION MEASURE BEEN IMPLEMENTED THEN, WOULD
13:57 18 IT HAVE MITIGATED SIGNIFICANTLY, SUBSTANTIALLY, THE FUNNEL
13:57 19 EFFECT INDUCED BY THE MRGO REACH 1/REACH 2 CONVERSION FOR GIWW
13:58 20 DURING KATRINA?
13:58 22 Q. NOW, THERE ARE MANY OTHER EXAMPLES OF CORPS INACTION AND,
13:58 23 ONCE AGAIN, YOU DELINEATE A NUMBER OF THEM. JUST TO TOUCH A
13:58 24 FEW, IN 1973, MR. BECNEL WITH THE CORPS, WHO WAS THE
13:58 25 NEW ORLEANS DIVISION CHIEF OF HYDRAULICS, WAS RESPONDING TO
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13:58 1 DR. GAGLIANO AND DR. HSU'S VERY INSTRUCTIVE SUGGESTIONS, ISSUES
13:58 2 WHAT YOU HAVE DESCRIBED IN YOUR REPORT AS THE UNITIVE STATEMENT
13:58 3 ON THE POSITION FOR THE NEW ORLEANS DISTRICT; CORRECT?
13:58 4 A. ACTUALLY, THAT'S WHAT MR. BECNEL DESCRIBED AS THE UNITIVE
13:58 5 STATEMENT. THIS WAS IN THE CONTEXT OF THAT 1973 -- THE CORPS
13:58 6 WAS GOING OUT TO THE PUBLIC TO GET COMMENTS ON THE CONCEPT OF
13:58 7 WIDENING AND DEEPENING THE CHANNEL. THERE WERE SOME PEOPLE
13:59 8 WHO, FOR WHATEVER REASON, WERE WORRIED ABOUT THAT. I THINK
13:59 9 MR. BECNEL THOUGHT THAT THAT CONCERN MIGHT PUT A DAMPER ON SOME
13:59 10 OF THOSE PLANS.
13:59 11 Q. LET'S PULL UP, IF WE CAN, PX-91 AT PAGE 25. THESE ARE THE
13:59 12 EXACT WORDS YOU DESCRIBE IN PAGE 25 OF YOUR REPORT. WOULD YOU
13:59 13 READ THEM.
13:59 14 A. THIS IS FROM MR. BECNEL'S MEMO. IT SAYS:
13:59 15 "THE PURPOSE OF THIS MEMORANDUM IS TO PROVIDE A
13:59 16 UNITIVE STATEMENT ON THE POSITION OF THE NEW ORLEANS DISTRICT
13:59 17 CONCERNING THE ACCUSATION BY DR. SHERWOOD M. GAGLIANO OR ANYONE
13:59 18 ELSE THAT THE ALIGNMENT OF THE PROTECTION LEVEES CREATES A
13:59 19 FUNNEL EFFECT IN THE VICINITY OF PARIS ROAD AT LAKE BORGNE. AT
13:59 20 THESE MEETINGS, DR. GAGLIANO, ET AL, PRESENTED THREE REPORTS,
13:59 21 WHICH ARE A MATTER OF RECORD OF THE PUBLIC HEARINGS."
14:00 22 I GUESS BECAUSE IT WAS A MATTER OF RECORD, HE FELT
14:00 23 LIKE THAT HE NEEDED TO TAKE SOME POSITION.
14:00 24 Q. NOW, THIS UNITIVE STATEMENT WAS NOT PUBLISHED OUTSIDE OF
14:00 25 THE CORPS; IS THAT CORRECT, TO YOUR KNOWLEDGE?
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14:00 1 A. THE ONLY PLACE I HAVE FOUND IT IS IN AN INTERNAL

14:00 2 MEMORANDUM.
14:00 3 Q. IS IT YOUR APPRECIATION THE CORPS WANTED TO ENLARGE THE
14:00 4 CHANNEL AND WANTED A UNITIVE STATEMENT FOR EVERYBODY TALKING ON
14:00 5 BEHALF OF THE CORPS HOW TO RESPOND AND THE RESPONSE WAS "NO
14:00 6 FUNNEL"?
14:00 7 A. I THINK THAT'S A REASONABLE -- THAT WAS MY INTERPRETATION.
14:00 8 AND, REMEMBER, THIS IS A QUASI-MILITARY ORGANIZATION, SO WHAT
14:00 9 FOLKS SAY AT THE TOP IS SUPPOSED TO HAVE AN EFFECT ON EVERYONE
14:00 10 ELSE.
14:00 11 THE COURT: JUST A BRIEF INTERRUPTION. DR. KEMP, DO
14:00 12 YOU KNOW AT THAT TIME WHAT THE BASIS BEHIND THE CORPS' POSITION
14:01 13 WAS? DID THEY GIVE ANY INTELLECTUAL, SCIENTIFIC, OR OTHER
14:01 14 RATIONALE FOR THE STATEMENT?
14:01 15 THE WITNESS: ACTUALLY, THEY GAVE SOMETHING, BUT IT
14:01 16 WASN'T RATIONAL, IN MY OPINION. I DON'T THINK IT WAS BASED ON
14:01 17 GOOD SCIENTIFIC PRINCIPLES. I DID READ WHAT THEY SAID, BUT --
14:01 18 THE COURT: WHAT WAS IT? DO YOU RECALL?
14:01 19 THE WITNESS: IT SOMETHING LIKE: WELL, THE WATER AT
14:01 20 PARIS ROAD GOT TO 10 FEET DURING BETSY, AND THEN IT GOT TO 10
14:01 21 FEET DURING CAMILLE IN 1969, SO I GUESS THAT SETTLES IT.
14:01 22 THE COURT: SO BASED ON WATER HEIGHTS FROM PREVIOUS
14:01 23 STORMS, THE DEDUCTION WAS MADE THAT IT WAS NOT EXACERBATED BY
14:01 24 THE CHANNEL?
14:01 25 THE WITNESS: YEAH, BUT I COULDN'T FIGURE OUT THE
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14:01 1 LOGIC OF THAT. IT WASN'T ANY SCIENTIFIC APPROACH.

14:01 3 BY MR. ROY:
14:01 4 Q. LET ME ASK YOU THIS, DR. KEMP, SO NOBODY'S SPECULATING
14:01 5 HERE, OR BEING ACCUSED OF SPECULATING. ALL RIGHT? WOULD A
14:02 6 PRUDENT -- PRUDENT -- SCIENTIST WITHIN YOUR PROFESSION HAVE
14:02 7 REALIZED AT THAT TIME THAT, IN FACT, MR. BECNEL WAS WRONG?
14:02 8 A. I THINK, AGAIN, THIS IS OCEANOGRAPHY 101. HE HAD JUST
14:02 9 READ A REPORT FROM DR. HSU, WHICH POINTED OUT THE PROBLEMS OF
14:02 10 TRYING TO STATISTICALLY EXTRAPOLATE FROM ONE STORM TO THE
14:02 11 UNIVERSE OF STORMS. THIS WAS JUST -- I JUST CAN'T EXPLAIN IT.
14:02 12 Q. THE REFUSAL OF THE CORPS AT THAT TIME TO EVEN CONTEMPLATE
14:02 13 THE POSSIBILITY THAT THEY COULD BE WRONG AND THERE MIGHT BE A
14:02 14 FUNNEL, LIKE B AND C PROVED, HYDRAULICALLY, AS A REASONABLY
14:03 15 PRUDENT OCEANOGRAPHER, DOES THAT VIOLATE THE MOST BASIC OF YOUR
14:03 16 PROFESSION'S PRINCIPLES ON SCIENTIFIC INQUIRY?
14:03 17 A. ABSOLUTELY. WHEN THEY SAY THE ACCUSATIONS OF DR. GAGLIANO
14:03 18 OR ANYONE ELSE, IT PRESUMES THAT ABSOLUTELY NO EVIDENCE COULD
14:03 19 BE PRESENTED THAT WOULD BE PERSUASIVE TO THEM THAT THEY MIGHT
14:03 20 HAVE IT WRONG.
14:03 21 Q. THEN THERE WAS THE 1988 BANK RECONNAISSANCE REPORT. IT
14:03 22 INTRODUCES EFFECTS OF WAVES IN CAUSING WIDENING OF THE MRGO;
14:03 23 CORRECT?
14:03 25 Q. THAT'S IN PX-9 AND ALSO PX-91. THIS REPORT, IN YOUR
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14:03 1 OPINION, DEMONSTRATES THE CORPS WAS FULLY AWARE OF THE CHANNEL
14:03 2 WIDENING AT THAT TIME DUE TO BANK EROSION FROM WAVES AND THE
14:03 3 NEED TO TAKE DECISIVE REMEDIAL ACTION; IS THAT CORRECT?
14:03 5 Q. IN FACT, AT THAT TIME THE CORPS ACKNOWLEDGES ANNUAL SHORE
14:04 6 EROSION OF AT LEAST 15 TO 32 FEET PER YEAR; IS THAT CORRECT?
14:04 8 Q. SOMETHING IN THAT NEIGHBORHOOD?
14:04 9 A. YEAH. I THINK THE AVERAGE WAS AROUND 15, BUT IT RANGED IN
14:04 10 THAT --
14:04 11 Q. AND DESCRIBED A STAGGERING LOSS OF WETLANDS ALONG REACH 2;
14:04 12 IS THAT RIGHT?
14:04 13 A. ALONG REACH 2 AND ALSO MORE GENERALLY IN THE ENTIRE FUNNEL
14:04 14 AREA.
14:04 15 Q. THE CORPS' DIVISION LEVEL REVIEWERS OF THE '88 REPORT ALSO
14:04 16 WARN ABOUT THE POSSIBILITY OF CATASTROPHIC FLOODING CAUSED BY
14:04 17 THE MRGO; CORRECT?
14:04 19 Q. DID THE CORPS HEED THOSE WARNINGS?
14:04 20 A. THE CORPS ADDRESSED SOME OF THOSE COMMENTS, AND THAT WAS
14:04 21 ONE COMMENT THEY CHOSE NOT ADDRESS. THAT'S PART OF THE RECORD
14:04 22 OF THAT REPORT.
14:04 23 Q. AS A PRUDENT OCEANOGRAPHER AND EXPERT IN YOUR FIELD, IN
14:04 24 1988, LOOKING AT THE BODY OF KNOWLEDGE AVAILABLE TO THE CORPS
14:04 25 AT THAT TIME, WOULD A MINIMALLY COMPETENT EXPERT IN YOUR FIELD
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1759
14:05 1 HAVE RECOGNIZED THAT THE HYDROLOGIC AND ECOLOGIC EVENTS

14:05 2 OCCURRING AS THE MRGO REACH 1 AND REACH 2 EVOLVED WERE POSING
14:05 3 GREAT SIGNIFICANT, POTENTIALLY CATASTROPHIC RISKS TO LIFE AND
14:05 4 PROPERTY IN METROPOLITAN ORLEANS AREA?
14:05 5 A. THAT'S CORRECT. I THINK THAT'S WHAT DR. BEA TALKED ABOUT
14:05 6 IN TERMS OF THE NEED TO GO BACK IN AN OBSERVATIONAL METHOD AND
14:05 7 REASSESS FROM TIME TO TIME. THEY WOULD GET PIECES OF THE
14:05 8 PICTURE, BUT THEY NEVER PUT THEM TOGETHER.
14:05 9 Q. WOULD ARMORING OF THE CHANNEL BANKS IN THE 1988 TIME
14:05 10 FRAME, IN YOUR OPINION, HAVE SIGNIFICANTLY PREVENTED ADDITIONAL
14:05 11 WIDENING AND DEEPENING OF THE REACH 2 IN THE ABSENCE OF
14:05 12 EXCESSIVE DREDGING?
14:05 13 A. THE MEANS TO STOP BANK EROSION WERE WELL KNOWN AT THE
14:05 14 TIME. THEY HAD BEEN STUDIED. EVENTUALLY, IN THE EARLY 1990S,
14:06 15 THEY ACTUALLY PUT BANK PROTECTION ALONG, I GUESS, WHAT WE'D
14:06 16 CALL THE WEST BANK AND IT WORKED. UNTIL RECENTLY, THEY NEVER
14:06 17 PUT ANYTHING ON THE NORTH SIDE, THOUGH -- NO. THIS IS
14:06 18 NEW ORLEANS CONVENTION, SO THE EAST BANK.
14:06 19 THE COURT: YOU MIGHT WANT TO POINT THAT OUT.
14:06 20 THE WITNESS: THANK YOU VERY MUCH. SO THEY PUT ROCKS
14:06 21 OUT IN FRONT OF THIS LPV SECTION, BUT THEN THERE WAS THE OTHER
14:06 22 BANK ON THE OTHER SIDE THAT FACED LAKE BORGNE THAT THEY DID NOT
14:06 23 ARMOR, AND THAT CONTINUED TO WIDEN AND ENLARGE.
24 BY MR. ROY:
14:06 25 Q. DR. KEMP, THE CONCEPT OF ARMORING NAVIGABLE WATERWAY BANKS
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1760
14:06 1 BACK IN 1988 WAS NOT ALIEN TO THE CORPS; IN FACT, AN HOUR AND A
14:06 2 HALF FROM HERE AT ST. FRANCISVILLE, ON THE VERY
14:06 3 MISSISSIPPI RIVER THAT FLOWS THROUGH NEW ORLEANS, IS A HUGE --
14:07 4 AND WAS THEN -- HUGE WHAT? CONCRETE-ARTICULATED MAT FACILITY
14:07 5 FOR THE PURPOSE OF ARMORING SHORELINES; RIGHT?
14:07 6 A. THAT'S CORRECT. ONE WOULD BE HARD PRESSED IN THE LOWER
14:07 7 MISSISSIPPI RIVER TO FIND 1,000 FEET OF THE BANK THAT DOESN'T
14:07 8 HAVE A MAT LIKE THAT ON IT.
14:07 9 THE COURT: DR. KEMP, JUST SO I UNDERSTAND SOMETHING,
14:07 10 WHEN YOU SAY THE CORPS PUT -- WE'LL JUST CALL IT ROCKS FOR LACK
14:07 11 OF A BETTER WORD, RIPRAP, OR WHATEVER IT IS, THE EXTENT OF
14:07 12 THAT -- WE'LL CALL IT ARMORING OF THE BANKS. WAS THAT ALONG
14:07 13 THE ENTIRETY OF REACH 2? I'M NOT QUITE SURE WHAT YOU TESTIFIED
14:07 14 TO.
14:07 15 THE WITNESS: NO, YOUR HONOR. THEY PUT IT, FOR SOME
14:07 16 REASON, DIRECTLY IN FRONT OF THE LPV STRUCTURES AND NO FURTHER.
14:08 17 THE COURT: THAT WOULD BE IN FRONT OF THE LPV
14:08 18 STRUCTURES, MEANING --
14:08 19 THE WITNESS: WELL, I'M SAYING THE MRGO REACH 2
14:08 20 CHANNEL IS EXPANDING TOWARDS THE STRUCTURES AT AN ALARMING
14:08 21 RATE. THE FIRST PLACE THEY PUT THE ROCKS IS ALONG THE MRGO
14:08 22 BANK BETWEEN THE ENLARGED CHANNEL AND THE TOE OF THE
14:08 23 STRUCTURES.
14:08 24 THE COURT: RIGHT. I UNDERSTAND THAT. WAS THAT
14:08 25 ALONG THE ENTIRETY OF REACH 2? DO YOU KNOW?
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1761
14:08 1 THE WITNESS: NO. REACH 2 EXTENDS ALL THE WAY OUT TO
14:08 2 THE EDGE OF THE MARSH, SO IT'S JUST THAT 12 MILES THAT FRONTS
14:08 3 THE STRUCTURES.
14:08 4 THE COURT: OKAY. THAT WAS DONE WHEN?
14:08 5 THE WITNESS: I BELIEVE IT WAS DONE ABOUT '94, '95,
14:08 6 MAYBE '93. WE CAN CERTAINLY FIND OUT EXACTLY IN A MINUTE.
14:08 7 MR. ROY: NOW, FOR MORE GRAPHIC CONTEXT, LET'S GO TO
14:08 8 PX-193, CARL. PX-193. WOULD YOU PULL THAT UP.
14:09 9 BY MR. ROY:
14:09 10 Q. THESE ARE THINGS REFERENCED IN YOUR VARIOUS WRITINGS,
14:09 11 DR. KEMP. THIS IS THE MAY 24, 1988 MEMO FROM CECIL W.
14:09 12 SOUILEAU, CHIEF, HYDRAULICS AND HYDROLOGIC BRANCH, WITH THE
14:09 13 CORPS; CORRECT?
14:09 14 THE COURT: IS THAT ALSO CONTAINED IN DR. KEMP'S
14:09 15 REPORT?
14:09 16 MR. ROY: I BELIEVE IT IS REFERRED TO, JUDGE, EITHER
14:09 17 IN APPENDIX B OR ELSEWHERE IN THE REPORT.
14:09 18 THE COURT: IT'S NOT THERE IN TOTO?
14:09 19 MR. ROY: NO, SIR. THAT'S THE ONLY REASON I'M
14:09 20 CALLING YOUR ATTENTION TO IT.
14:09 21 THE COURT: I APPRECIATE IT.
14:09 22 MR. ROY: CARL, WOULD YOU HIGHLIGHT STARTING WITH THE
14:09 23 FIFTH LINE, FIRST SENTENCE, PARAGRAPH 3, "WE COMPARED 1969
14:09 24 QUADRANGLES...." HIGHLIGHT THAT SENTENCE.
25
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1762
13:31 1 BY MR. ROY:

14:09 2 Q. NOW, DR. KEMP, IN THIS DOCUMENT, MR. SOUILEAU WRITES:
14:09 3 "WE COMPARED 1969 QUADRANGLES AND 85 AERIAL
14:10 4 PHOTOGRAPHS TO DERIVE AN ANNUAL EROSION RATE ALONG THE NORTH
14:10 5 BANK AND SOUTH BANK OF 15 FEET PER YEAR. THIS IS EQUIVALENT TO
14:10 6 30 FEET PER YEAR FOR BOTH BANKS."
14:10 7 THIS IS ONE OF THE SOURCES OF YOUR INFORMATION;
14:10 8 CORRECT?
14:10 9 A. THAT'S CORRECT. THAT'S REPEATED IN THE 1988 REPORT.
14:10 10 MR. ROY: THE NEXT PAGE, PLEASE, CARL, PARAGRAPH 5,
14:10 11 APPROXIMATELY 10 LINES DOWN, "THE MRGO WILL BE EXPOSED...."
14:10 12 HIGHLIGHT THAT PLEASE, SIR.
14:10 13 BY MR. ROY:
14:10 14 Q. MR. SOUILEAU FURTHER WRITES: "THE MRGO WILL BE EXPOSED ON
14:10 15 THE NORTH SIDE" -- WHICH IN THIS CASE IS THE LAKE BORGNE SIDE;
14:10 16 RIGHT?
14:10 18 Q. -- "TO A LARGE BODY OF OPEN WATER SIMILAR TO THE SITUATION
14:10 19 THAT NOW EXISTS ALONG THE OFFSHORE REACHES OF THE MRGO IN
14:10 20 BRETON SOUND, PARTICULARLY IN THE SINGLE JETTY REACH FROM MILE
14:10 21 20 TO 15."
14:10 22 CORRECT?
14:10 23 A. YES. I THINK IT'S CONFUSING, THOUGH, TO TALK ABOUT -- I
14:10 24 MEAN, THEY ALSO HAD A TREMENDOUS PROBLEM TRYING TO MAINTAIN
14:11 25 DEPTHS IN THE OPEN WATER PART OF THE MRGO, WHICH IS OUT THERE
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14:11 1 IN MILE 20 TO 15. BUT WHAT HE'S SAYING IS THAT THE INSHORE
14:11 2 PART WILL BECOME LIKE THAT OFFSHORE PART WHEN LAKE BORGNE
14:11 3 BREACHES INTO THE MRGO, WHICH, OF COURSE, OCCURRED, OH, AROUND
14:11 4 1980.
14:11 5 Q. NOW, LET'S GO TO THE NEXT PAGE, PARAGRAPH 7, COMMENT 2.
14:11 6 THE VERY FIRST SENTENCE STARTING WITH SALTWATER INTRUSION, WILL
14:11 7 YOU HIGHLIGHT THAT IN THE SECOND SENTENCE. MR. SOUILEAU
14:11 8 ACKNOWLEDGES:
14:11 9 "SALTWATER INTRUSION MAY BE REDUCED DURING NORMAL
14:11 10 CONDITIONS BY BLOCKING OF THE DEEP-DRAFT CHANNEL. HOWEVER,
14:11 11 CLOSING OF THE MRGO NAVIGATION CHANNEL WILL HAVE NO IMPACT ON
14:11 12 HURRICANE SURGE."
14:11 13 A. MY COMMENT IS IT DEPENDS ON WHERE YOU DO IT. THE WAY IT'S
14:11 14 BEING HANDLED RIGHT NOW IS THAT THERE IS A SALINITY BARRIER
14:11 15 BEING PLACED AT THE BAYOU LA LOUTRE RIDGE, WHICH IS THE
14:11 16 APPROPRIATE PLACE FOR THAT, AND THEN A SURGE BARRIER IS BEING
14:12 17 PLACED IN THE THROAT OF THE FUNNEL SIMILAR TO THE CROSBY PLAN.
14:12 18 YOU NEED BOTH THOSE THINGS.
14:12 19 MR. ROY: LET'S GO FORWARD FOUR MORE PAGES, CARL, TO
14:12 20 PARAGRAPH 11, TOP OF THE PAGE, COMMENT 4(C), THE LAST SENTENCE,
14:12 21 STARTING WITH "SPARTINA."
14:12 22 BY MR. ROY:
14:12 23 Q. DR. KEMP, CAN YOU READ WHAT THAT SENTENCE SAYS.
14:12 24 A. YES. I CAN EVEN PRONOUNCE THE WORD SPARTINA ALTERNIFLORA.
14:12 25 Q. READ THE SENTENCE.
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1764
14:12 1 A. "SPARTINA ALTERNIFLORA MAY BE PLANTED ON THE LAKE BORGNE

14:12 2 SIDE TO ENCOURAGE DEPOSITION AND STABILIZATION OF THE EXPOSED
14:12 3 SHORELINE IF DEEMED NECESSARY AFTER FURTHER STUDY."
14:12 4 Q. NOW, IN THE CONTEXT WE'RE LOOKING AT IT, CLEARLY, AS YOU
14:12 5 HAVE DESCRIBED, THE CORPS IS AWARE THAT THEY CAN PLANT THINGS,
14:13 6 THEY CAN ARMOR BANKS, AND IT'S ACKNOWLEDGED THERE, AT
14:13 7 LEAST FROM YOUR STANDPOINT; RIGHT?
14:13 8 A. OH, DEFINITELY. THIS IS A SALT MARSH GRASS THAT GROWS
14:13 9 VERY READILY AS LONG AS THE ELEVATION IS RIGHT.
14:13 10 MR. ROY: LET'S GO TO PX-09, CARL, PAGE 1.
14:13 11 BY MR. ROY:
14:14 12 Q. HERE, I BELIEVE IT'S THE SAME MR. SOUILEAU WRITING FOR THE
14:14 13 CORPS, IS IT NOT, OR DO YOU KNOW?
14:14 14 A. I BELIEVE THAT IT'S NOT MR. SOUILEAU. THESE ARE COMMENTS
14:14 15 FROM THE LOWER MISSISSIPPI VALLEY DIVISION. DR. SOUILEAU WAS
14:14 16 AN EMPLOYEE OF THE NEW ORLEANS DIVISION. SO IT'S ALMOST
14:14 17 CERTAINLY NOT MR. SOUILEAU.
14:14 18 Q. ONCE AGAIN, A CORPS-INTERNAL DOCUMENT, THE FIRST SENTENCE:
14:14 19 "THE ALTERNATIVE TO COMPLETELY CLOSE THE MRGO WATERWAY SHOULD
14:14 20 BE EVALUATED AND A DISCUSSION OF THE EVALUATION SHOULD BE
14:14 21 INCLUDED IN THE REPORT."
14:14 22 IS THAT WHAT IT SAYS?
14:14 23 A. THAT'S CORRECT. I'M SURE THAT WAS BASED ON THE ECONOMICS
14:14 24 OF THE CHANNEL. IT WAS COSTING A LOT MORE THAN -- FOR WHATEVER
14:14 25 ECONOMIC DEVELOPMENT WAS --
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1765
14:14 1 Q. THE SECOND SENTENCE THAT'S HIGHLIGHTED: "IN ADDITION TO

14:14 2 SOLVING THE AFOREMENTIONED PROBLEMS" -- THAT'S CLOSURE -- IT
14:15 3 READS -- YOU READ IT.
14:15 4 A. WELL, THIS SAYS:
14:15 5 "CLOSURE WILL ALSO REDUCE THE POSSIBILITY OF
14:15 6 CATASTROPHIC DAMAGE TO URBAN AREAS BY A HURRICANE SURGE COMING
14:15 7 UP THIS WATERWAY AND ALSO GREATLY REDUCE THE NEED TO OPERATE
14:15 8 AND COULD POSSIBLY ELIMINATE THE CONTROL STRUCTURES AT BAYOUS
14:15 9 DUPRE AND BIENVENUE. FURTHERMORE, THE SALINITY LEVEL IN LAKE
14:15 10 PONTCHARTRAIN WILL BE REDUCED, WHICH, ACCORDING TO SOME
14:15 11 PARTIES, WILL BE OF GREAT BENEFIT."
14:15 12 THE COURT: LET'S GET IT IN CONTEXT. I UNDERSTAND
14:15 13 IT'S OUT OF THE REPORT OF FEBRUARY 1988. IS THIS A RESPONSE BY
14:15 14 THE CORPS TO COMMENTS MADE BY THE PUBLIC?
14:15 15 THE WITNESS: NO, IT'S NOT. IT'S AN INTERNAL -- IT'S
14:15 16 A RESPONSE TO -- THE DISTRICT WILL DEVELOP THE REPORT. THEY
14:15 17 SEND IT UP TO VICKSBURG, WHERE THE DIVISION OFFICE IS. THEN
14:15 18 THE DIVISION STAFF HAS A CHANCE TO MAKE COMMENTS ON THE REPORT.
14:16 19 THESE REPRESENT --
14:16 20 THE COURT: FINE.
14:16 21 THE WITNESS: OKAY.
14:16 22 THE COURT: GO AHEAD AND FINISH IT.
14:16 23 THE WITNESS: THESE ARE COMMENTS MADE BY ENGINEERS
14:16 24 AND EXPERTS AT THE DIVISION OFFICE BACK TO NEW ORLEANS. THEN
14:16 25 NEW ORLEANS HAS A CHANCE TO RESPOND TO THESE. THE ENTIRE
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14:16 1 RECORD IS INCLUDED IN THE FRONT OF THE REPORT.

14:16 2 THE COURT: THE RECONNAISSANCE REPORT, WHICH I READ A
14:16 3 MONTH OR SO AGO, IS AN INTERNAL CORPS DOCUMENT, PRIMARILY?
14:16 4 THE WITNESS: I WOULD SAY IT'S A PUBLIC DOCUMENT.
14:16 5 THE COURT: BUT IT'S ALL CORPS GENERATED? THERE'S NO
14:16 6 PUBLIC COMMENT AND THEN A BACK-AND-FORTH?
14:16 7 THE WITNESS: I DIDN'T SEE IT IN THIS. IT'S NOT LIKE
14:16 8 AN EIS, BUT THERE IS AT LEAST THIS REVIEW AT A HIGHER LEVEL.
14:16 9 THE COURT: THAT'S WHAT I UNDERSTAND. THANK YOU.
23:59 10 BY MR. ROY:
14:17 11 Q. THE BOTTOM LINE IS THE CORPS DIVISION LEVEL REVIEWERS
14:17 12 COMMENTED AT THAT TIME IN '88 AND WARNED ABOUT THE POSSIBILITY
14:17 13 OF CATASTROPHIC FLOODING IN THE NEW ORLEANS AREA; CORRECT?
14:17 14 A. THEY DO. I SHOULD POINT OUT THAT THIS IS ONE COMMENT THAT
14:17 15 DOESN'T SEEM TO BE ADDRESSED IN THE DISTRICT RESPONSE.
14:17 16 Q. LET'S GO TO '91. THAT'S GOING TO BE THE SECOND TO LAST OF
14:17 17 THE HISTORICAL EVENTS. IN 1991, THE STATE OF LOUISIANA
14:17 18 COMPLAINED ABOUT THE CORPS' FAILURE TO TAKE RECOMMENDED
14:17 19 MEDIATION MEASURES ALONG REACH 2 OF THE MRGO; IS THAT CORRECT?
14:17 20 A. THAT'S RIGHT. THIS WAS AN ONGOING SOURCE OF RANCOR
14:17 21 BETWEEN THE STATE AND THE CORPS.
14:17 22 Q. THE STATE INVOKED THE FEDERAL COASTAL ZONE MANAGEMENT ACT
14:17 23 AND THREATENED TO TRY TO STOP ALL DREDGING BECAUSE OF BANK
14:17 24 EROSION AND FAILURE TO FOLLOW STATE GUIDELINES FOR PROTECTION
14:17 25 OF WETLANDS IN 1991; CORRECT?
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14:18 1 A. YES. I ACTUALLY REMEMBER THAT. I WAS ONE OF THE PEOPLE

14:18 2 WHO SUGGESTED THIS BECAUSE WE HAD JUST STARTED OUR COASTAL
14:18 3 RESTORATION PROGRAM. WE WERE TRYING TO RESTORE WETLANDS, AND
14:18 4 HERE WE HAD THIS HUGE PROJECT THAT HAD ESSENTIALLY A HOLE IN
14:18 5 THE BUCKET. SO IF WE RESTORED WETLANDS AND THEN THEY WERE LOST
14:18 6 BECAUSE OF THE MRGO, WE WERE IN A FUTILE FIGHT.
14:18 7 ALSO, THE COASTAL ZONE MANAGEMENT PROGRAM, WHICH IS A
14:18 8 FEDERAL PROGRAM, FEDERAL LAW THAT IS IMPLEMENTED AT THE STATE
14:18 9 LEVEL, ACTUALLY HAS SOME PRETTY STRONG LEVERAGE, GIVES SOME
14:18 10 PRETTY STRONG LEVERAGE FOR STATES THAT DEVELOP COASTAL ZONE
14:18 11 PLANS. ONE OF THEM WAS THAT ALL DREDGED MATERIAL THAT WOULD BE
14:18 12 USED FROM A NAVIGATION CHANNEL WOULD BE USED BENEFICIALLY TO
14:19 13 RESTORE WETLANDS.
14:19 14 Q. AT LEAST THE STATE WAS ACCUSING THE CORPS OF NOT DOING
14:19 15 THAT; RIGHT?
14:19 17 Q. LET'S CUT TO THE CHASE. THE STATE OF LOUISIANA DEPARTMENT
14:19 18 OF NATURAL RESOURCES HAD WROTE A LETTER TO THE NEW ORLEANS
14:19 19 DIVISION OF THE CORPS ON MAY 5, '91, PUTTING THE FEDS ON
14:19 20 NOTICE, THE CORPS ON NOTICE THAT THEY BELIEVED THE MRGO
14:19 21 DREDGING OPERATION AND WIDENING WAS INCONSISTENT WITH FEDERAL
14:19 22 GUIDELINES. THE NEW ORLEANS DISTRICT ISSUED AN INTERNAL-ONLY
14:19 23 BRIEFING MEMO DATED MAY 30, '91 -- YOU POINT THIS OUT AT
14:19 24 PAGE 28 OF YOUR REPORT -- WHICH WAS A SERIES OF JUSTIFICATIONS
14:19 25 FOR INACTION, INCLUDING THE ADMISSION BY THE CORPS THAT IT HAD
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1768
14:19 1 BEEN LONG-STANDING ARMY CORPS POLICY THAT BANK STABILIZATION

14:19 2 PROJECTS HAVE LOW FUNDING PRIORITY, "EFFECTIVELY ZERO FUNDING";
14:19 3 IS THAT CORRECT?
14:19 4 A. THAT'S WHAT I READ.
14:20 5 Q. LET'S PULL THE DOCUMENT UP ITSELF SO WE HAVE NO
14:20 6 MISUNDERSTANDINGS HERE.
14:20 7 MR. ROY: PULL UP PX-2082, PLEASE, CARL. NOW, CARL,
14:20 8 I'D LIKE YOU TO GO TO THE LAST TWO LINES, SECTION D AND D(1).
14:20 9 HIGHLIGHT THOSE.
14:20 10 BY MR. ROY:
14:20 11 Q. READ THAT, DR. KEMP.
14:20 12 A. "ISSUE IS NOT 'GOODNESS' OF BANK STABILIZATION ON MRGO.
14:20 13 WHY STABILIZE BANKS?"
14:20 14 NOW, THIS IS A RHETORICAL QUESTION.
14:20 15 MR. ROY: LET'S GO TO PAGE 2, CARL, AND START WITH
14:20 16 THE FIRST REASON IN THIS INTERNAL MEMO OF THE CORPS. IT SAYS:
14:20 17 "WHY STABILIZE BANKS?"
14:20 18 THAT'S OF THE MRGO, YOUR HONOR, REACH 2.
14:20 19 BY MR. ROY:
14:20 20 Q. READ THAT, DR. KEMP.
14:20 21 A. "RESTORE ERODED MARSH; REPAIR ENVIRONMENT DAMAGE."
14:20 22 Q. SO IT'S ONE OF THE RECOMMENDATIONS THAT DR. GAGLIANO HAD
14:20 23 BEEN MAKING FOR, AT THAT POINT IN TIME, MANY, MANY YEARS?
14:21 25 MR. ROY: HIGHLIGHT B, PLEASE.
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1769
14:21 1 THE COURT: WHAT'S THE DATE OF THIS?

14:21 2 MR. ROY: 1991, YOUR HONOR. MAY 5, 1991.
14:21 3 HIGHLIGHT B.
14:21 4 BY MR. ROY:
14:21 5 Q. READ THAT, PLEASE, DR. KEMP, THE SECOND REASON THAT THE
14:21 6 CORPS INTERNALLY GIVES, "WHY STABILIZE BANKS?"
14:21 7 A. YES. THIS IS TO PROTECT THE HABITAT. IT MAY BE A SUBTLE
14:21 8 THING, BUT IN THE RESTORATION BUSINESS, WE WANT TO DO TWO
14:21 9 THINGS: WE WANT TO KEEP MARSH THAT'S HEALTHY FROM BEING LOST;
14:21 10 THAT IS, PROTECT HABITAT. THEN WE ALSO WANT TO RESTORE MARSH
14:21 11 INTO AREAS THAT IT'S ALREADY BEEN LOST. SO THEIR BIOLOGISTS
14:21 12 WOULD HAVE UNDERSTOOD THAT DIFFERENTIATION.
14:21 13 Q. THE EXACT WORDS UP THERE ARE: "PROTECT HABITAT (BRACKISH
14:21 14 MARSH)"?
14:22 16 Q. THIS IS REFERRING TO THE MARSHES THAT WOULD BE ON THE
14:22 17 LAKE BORGNE SIDE, PRIMARILY, OF THE MRGO REACH 2 AND THE
14:22 18 CENTRAL WETLANDS; CORRECT?
14:22 19 A. PROBABLY, SINCE THIS DEALS SPECIFICALLY WITH BANK
14:22 20 STABILIZATION, IT'S -- AND THIS IS PRIOR TO ANY PLACEMENT OF
14:22 21 ANY ROCK ALONG THERE. IT WOULD HAVE BEEN ON BOTH SIDES, BUT
14:22 22 MOSTLY BETWEEN THE EXPANDED CHANNEL AND THE TOE OF THE LPV
14:22 23 LEVEE, AND THEN ON THE OTHER SIDE BETWEEN THE EXPANDED CHANNEL
14:22 24 AND LAKE BORGNE.
14:22 25 MR. ROY: YOUR HONOR, THE CORRECTED DATE OF THIS
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1770
14:22 1 DOCUMENT I'VE CORRECTED IS MAY 30, 1991.

14:22 2 THE COURT: THANK YOU, SIR.
14:22 3 BY MR. ROY:
14:22 4 Q. LET'S HIGHLIGHT D SINCE C DEALS WITH OYSTER LEASES. READ
14:22 5 D.
14:22 6 A. IT JUST SAYS: "PREVENT FURTHER EROSION OF PRIVATE LANDS
14:22 7 BEYOND PROJECT RIGHT-OF-WAY."
14:22 8 MR. ROY: HIGHLIGHT E, CARL.
14:22 9 THE WITNESS: "NEW ORLEANS DISTRICT RECON REPORT
14:22 10 IDENTIFIED THREE 'CRITICAL' REACHES; I.E., CORPS RECOGNIZES
14:23 11 EROSION IS AN ENVIRONMENTAL PROBLEM."
14:23 12 SO THEY IDENTIFIED SOME AREAS THAT WERE
14:23 13 PARTICULARLY CRITICAL.
14:23 14 MR. ROY: CARL, WOULD YOU HIGHLIGHT F.
14:23 15 THE WITNESS: "STABILIZED BANKS WOULD ENCOURAGE
14:23 16 LONG-TERM ACCEPTANCE OF MRGO AND POSSIBLY PAVE WAY FOR DEEPER
14:23 17 CHANNEL.
14:23 18 BY MR. ROY:
14:23 19 Q. SO IN 1991 THE CORPS, OF ALL THINGS, STILL WANTS TO DEEPEN
14:23 20 AND WIDEN THE CHANNEL, EVEN THOUGH DEEPENING AND WIDENING OF
14:23 21 THE CHANNEL HAS ALREADY CAUSED A MYRIAD OF ENVIRONMENTAL
14:23 22 DEVASTATION TO THAT POINT SINCE CONSTRUCTION; IS THAT RIGHT?
14:23 23 A. THAT'S THE ONLY IMPRESSION I CAN DRAW FROM THAT.
14:23 24 Q. LET'S SEE. THE CORPS SAYS AT PARAGRAPH 2, THAT SAME PAGE:
14:23 25 "WHY NOT STABILIZE THE BANKS?" THIS IS WHERE IT GETS
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1771
14:23 1 INTERESTING.
14:23 2 MR. ROY: LET'S HIGHLIGHT B, CARL.
14:23 3 BY MR. ROY:
14:23 4 Q. WHAT DOES THAT SAY?
14:23 5 A. YOU MENTIONED THAT EARLIER. THAT'S THE CORPS'
14:23 6 LONG-STANDING POLICY AGAINST REPAIRING BANK EROSION. THIS IS
14:24 7 SOMETHING THEY CONSTITUTIONALLY DISLIKE DOING.
14:24 8 Q. SUBPARAGRAPH E, READ THAT.
14:24 9 A. "LONG-TERM VIABILITY OF MRGO IN QUESTION, DUE TO
14:24 10 CONSIDERABLE PUBLIC OPPOSITION TO PAST AND CONTINUING
14:24 11 (PERCEIVED AND REAL) ENVIRONMENTAL DAMAGES AND TO MARGINAL
14:24 12 COMPETITIVENESS OF 36-FOOT CHANNEL."
14:24 13 MR. ROY: YOUR HONOR, IN ORDER TO SAVE TIME AND MOVE
14:24 14 THIS ALONG, I'D LIKE TO POINT OUT, OBSERVATIONALLY, A COUPLE OF
14:24 15 OTHER HIGHLIGHTED AREAS OF THIS EXHIBIT. I BELIEVE WE'VE
14:24 16 ESTABLISHED RELEVANCE.
14:24 17 THE COURT: ALL RIGHT.
14:24 18 MR. ROY: THE NEXT LINE IS: "NOT POLICY QUESTION
14:24 19 (CAN BE RESOLVED BY SPONSOR)."
14:24 20 IN THE CONTEXT OF THE DOCUMENT, YOUR HONOR,
14:25 21 "SPONSOR" IS LOCAL GOVERNMENT.
14:25 22 THE NEXT PAGE, D: "SECTION 1135 PROVIDES
14:25 23 AUTHORITY ONLY. FUNDS MUST COME FROM OPERATION AND MAINTENANCE
14:25 24 (O&M) OR OTHER BUDGET."
14:25 25 GOING DOWN TO F, "PRECEDENT" -- AND THESE ARE
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1772
14:25 1 ALL THE REASONS WHY NOT TO STABILIZE THE BANKS, AN IMPASSE, NOT
14:25 2 POLICY.
14:25 3 "PRECEDENT: IF CORPS FIXES MILE 50 TO 56 AS
14:25 4 CONDITION OF DREDGED MATERIAL PLACEMENT, EXPECT CONTINUED
14:25 5 DEMANDS THROUGHOUT LOUISIANA COASTAL ZONE."
14:25 6 THE NEXT PAGE, CARL, PAGE 4 -- ACTUALLY, THAT'S IT.
14:25 7 THE COURT: THANK YOU, COUNSEL.
14:25 8 JUST TO LET YOU KNOW, WE'LL PROBABLY TAKE A
14:25 9 BREAK IN ABOUT SIX OR SEVEN MINUTES IF THAT HELPS YOU
14:25 10 CALIBRATE.
14:26 12 BY MR. ROY:
14:26 13 Q. YOU TESTIFIED THE CORPS WAS AWARE BY AT LEAST 1966 AND
14:26 14 INCREASINGLY AT THE BENCHMARK DATES WE'VE TALKED ABOUT, AND
14:26 15 DR. GAGLIANO AND OTHERS TALKED ABOUT, TO CLARIFY: CLEARLY, IN
14:26 16 1966, WITH RESPECT TO THE FUNNEL, AND BY AT THE LATEST 1988, AS
14:26 17 TO WAVES AND EROSION ON REACH 2, THE CORPS HAD BEEN WARNED, AS
14:26 18 FAR AS YOU'RE CONCERNED, THROUGH THE LENS AND THE VIEWPOINT OF
14:26 19 A MINIMALLY COMPETENT OCEANOGRAPHER UNDERSTANDING WHAT'S GOING
14:26 20 ON OUT THERE?
14:26 21 A. YES, SIR.
14:26 22 Q. THERE WAS AMPLE TIME, IF THE CORPS HAD CHOSEN TO, TO
14:26 23 FORMALLY ALERT CONGRESS TO THE REMEDIAL MEASURES KNOWN BY THE
14:26 24 CORPS THAT COULD HAVE FIXED THESE PROBLEMS, BUT TO YOUR
14:26 25 KNOWLEDGE IT WAS NEVER DONE IN THAT TIME FRAME; CORRECT?
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1773

14:26 2 Q. FROM THE TIME OF CONSTRUCTION TO THE TIME OF KATRINA, TO
14:27 3 YOUR KNOWLEDGE HAS THE UNITED STATES ARMY CORPS OF ENGINEERS
14:27 4 EVER ADMITTED THAT THERE WAS A FUNNEL EFFECT AT THE CONVERGENCE
14:27 5 OF THE GIWW IN REACH 2?
14:27 6 A. IF THEY HAVE, I HAVEN'T SEEN IT.
14:27 7 Q. YOUR PROFESSION, LIKE MANY OTHERS, HAS A WORD FOR THAT,
14:27 8 DON'T THEY: MYOPIC?
14:27 9 A. OKAY.
14:27 10 THE COURT: COUNSEL, YOU'RE TESTIFYING.
14:27 11 MR. ROY: IT'S A GOOD BREAKING POINT, YOUR HONOR.
14:27 12 THE COURT: THE COURT IS AWARE WHEN THE RHETORIC OF
14:27 13 COUNSEL IS MAYBE EMBELLISHING THE REPORT OF THE WITNESS. DON'T
14:27 14 WORRY. I'M CALIBRATING THAT.
14:27 15 MR. LEVINE: I WAS JUST WAITING FOR FOLLOW-UP
14:27 16 QUESTIONING.
14:27 17 THE COURT: WE WILL TAKE A RECESS FOR 10 MINUTES.
14:39 19 (WHEREUPON THE COURT TOOK A BRIEF RECESS.)
14:49 22 THE COURT: A LITTLE CAFFEINE AND I THINK I'M GOING
14:49 23 TO GET THROUGH YOUR EXAMINATION A LITTLE MORE ALERT, SIR.
14:49 24 YOU'VE BEEN VERY ANIMATED, THOUGH. IT'S HELPED. THANK YOU.
14:49 25 MR. ROY: IN THE ABSENCE OF CAFFEINE, I HAVE NO
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1774
14:49 1 CHOICE.
14:49 2 THE COURT: I'M SURE YOU HAD A RATHER SHORT NIGHT
14:49 3 YOURSELF. GO AHEAD, SIR.
14:49 4 MR. ROY: YOUR HONOR, LET ME BE SURE THAT WHEN I
14:49 5 DESCRIBED THE JULY 28, 2007 REPORT THAT I SAID IT'S JX-194. I
14:50 6 MAY HAVE MISDATED IT.
14:50 7 THE COURT: I HAVE A COMPENDIUM OF THE REPORT, WHICH
14:50 8 I SYNOPSIZED. ARE ALL OF THOSE REPORTS IN THE BOOK THAT I WAS
14:50 9 GIVEN? I'M TRYING TO REMEMBER.
14:50 10 MR. ROY: THE ONLY ONE, YOUR HONOR, THAT MAY NOT HAVE
14:50 11 BEEN GIVEN IS THE -- WELL, THERE ARE TWO, I BELIEVE. I THINK
14:50 12 2152 IS MAYBE THE ONLY ONE WE MAY HAVE TO BACKFILL TO YOU.
14:50 13 THE COURT: 2152 MAY BE THE ONLY ONE.
14:50 14 MR. ROY: YOU HAD IT, ANYWAY, BECAUSE IT WAS THE 702C
14:50 15 DECLARATION.
14:50 16 THE COURT: RIGHT.
14:50 17 MR. ROY: MAY WE PROCEED?
14:50 18 THE COURT: YES, YOU MAY.
14:50 19 BY MR. ROY:
14:50 20 Q. DR. KEMP, YOUR OCEANOGRAPHIC METHODS AND ANALYSIS -- LET'S
14:50 21 GO TO PAGE 15. TELL THE COURT AS CONCISELY AS YOU CAN WHAT
14:50 22 THOSE ARE, GENERALLY.
14:51 23 A. ACTUALLY, WE ARE DOING A LOT OF THE SAME THINGS THAT
14:51 24 BRETSCHNEIDER AND COLLINS DID BUT WITH SOME MORE MODERN TOOLS.
14:51 25 WE SIMULATE THE KATRINA SCENARIO WITHOUT THE LEVEE AND FLOOD
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1775
14:51 1 WALL BREACHES. WE USE MODERN NUMERICAL MODELING TECHNIQUES TO

14:51 2 TEST THE EFFECTS, THE HYDRAULIC OCEANOGRAPHIC EFFECTS OF THE
14:51 3 MRGO PROJECT, BOTH AS IT WAS DESIGNED AND AS IT WAS MAINTAINED,
14:51 4 ON SURGE-INDUCED DISCHARGE AND OVERTOPPING OF THE STRUCTURES TO
14:51 5 DETERMINE THE MRGO NEUTRAL CONDITION.
14:51 6 THEN WE USE MODERN WAVE-MODELING TO DETERMINE THE
14:51 7 AMPLIFICATION OF WAVES BY THE CHANNEL, MRGO CHANNEL, FOR INPUT
14:51 8 TO THE LPV BREACHING ANALYSIS AND THAT TIME LINE. THAT'S WHERE
14:51 9 I HAND OFF TO DR. BEA.
14:52 10 WE USED MODERN FLOOD SIMULATION TECHNIQUES TO
14:52 11 DETERMINE THE INCREMENT OF FLOODING ONCE WE KNEW THE BREACHING
14:52 12 TIME LINE: WHERE THE BREACHES WERE, HOW BIG THEY ARE, WHEN
14:52 13 THEY STARTED. THEN WE ARE ABLE TO FLOOD THE DEVELOPED AREAS TO
14:52 14 DETERMINE HOW MUCH OF THAT FLOODING IS ACTUALLY ATTRIBUTABLE TO
14:52 15 THE NAVIGATION PROJECT.
14:52 16 Q. WHY DID YOU USE DR. VRIJLING AND HIS DELFT UNIVERSITY
14:52 17 GROUP?
14:52 18 A. WELL, THERE WERE A LOT OF REASONS, BUT I BECAME FAMILIAR
14:52 19 WITH THEIR CAPABILITIES -- DELFT UNIVERSITY OF TECHNOLOGY IS
14:52 20 PROBABLY THE EPICENTER OF OCEANOGRAPHIC AND HYDRAULIC
14:52 21 ENGINEERING IN THE WORLD. THE UNIVERSITY SITS IN A MILIEU OF
14:52 22 PROBABLY DOZENS OF ENGINEERING COMPANIES THAT TAKE THE RESEARCH
14:53 23 PRODUCTS, THE MODELS THAT ARE DEVELOPED AT DELFT UNIVERSITY OF
14:53 24 TECHNOLOGY, AND THEN COMMERCIALIZES THEM.
14:53 25 ALSO, THERE'S A LOT OF CONNECTION BETWEEN DELFT
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1776
14:53 1 UNIVERSITY OF TECHNOLOGY AND THE MINISTRY OF WATER IN THE

14:53 2 NETHERLANDS, THE RIJKSWATERSTAAT. IT'S A VERY, VERY -- A VERY
14:53 3 APPLIED BUT ALSO VERY, VERY CAPABLE MIX OF ENGINEERS AND
14:53 4 SCIENTISTS THERE. SO I KNEW THAT WHATEVER WAS NECESSARY, IN
14:53 5 THE COURSE OF THIS WORK, WE WERE GOING TO BE ABLE TO FIND THAT
14:53 6 CAPABILITY AT DELFT.
14:53 7 Q. THE FOUR PRIMARY PROGRAMS, YOU DESCRIBED ADCIRC. THAT WAS
14:53 8 USED PRIMARILY FOR WIND AND SURGE ON A LARGE SCALE; CORRECT?
14:53 10 Q. THEN YOU MOVED INTO USING FINEL, WHICH IS FOR THE MODELING
14:53 11 OF WINDS AND SURGE ON A SMALLER SCALE; CORRECT?
14:54 13 Q. THEN YOU MOVED INTO SWAN, WHICH WAS TO MODEL THE
14:54 14 NEAR-SHORE WAVES; CORRECT?
14:54 16 Q. THEN ONCE ALL THAT INFORMATION IS TURNED OVER TO DR. BEA,
14:54 17 HIS INPUTS COME BACK, YOU'RE THEN ABLE TO APPLY SOBEK, WHICH IS
14:54 18 THE POLDER MODELING PROGRAM BASED ON VARYING ASSUMPTIONS;
14:54 19 CORRECT?
14:54 20 A. THAT'S RIGHT, AND THESE ARE ALL WELL TESTED, WIDELY USED
14:54 21 IN THE ENGINEERING PRACTICE.
14:54 22 Q. FINEL, SWAN, AND SOBEK WERE DEVELOPED BY DELFT AND
14:54 23 AFFILIATES; CORRECT?
14:54 24 A. THAT'S RIGHT. USUALLY, THEY START OFF IN THE UNIVERSITY
14:54 25 AND THEN THEY MOVE OUT INTO THE COMMERCIAL.
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1777
14:54 1 Q. THEY ARE INTERNATIONALLY RECOGNIZED AS RELIABLE AND

14:54 2 SCIENTIFICALLY PROVEN MODELING PROGRAMS FOR THE PURPOSES YOU
14:54 3 HAVE USED THEM; CORRECT?
14:54 5 Q. NOW, AS AN EXPERT IN OCEANOGRAPHY, YOU USE AND INTERPRET
14:54 6 ADCIRC MODELING; CORRECT?
14:55 7 A. SINCE 2003, THAT WAS WHEN I FIRST BECAME INVOLVED WITH
14:55 8 ADCIRC.
14:55 9 Q. IT'S REALLY A SYSTEM OF COMPUTER PROGRAMS DESIGNED TO
14:55 10 SOLVE TIME-DEPENDENT FREE-SURFACE CIRCULATION. AND YOU APPLY
14:55 11 THIS, USING THAT, BASED UPON INPUTS THAT ARE MOST EFFECTIVE IF
14:55 12 THEY ARE BASED ON REALITY; RIGHT?
14:55 13 A. THAT'S RIGHT. WHEN WE ARE DOING SURGE SIMULATION, WE ARE
14:55 14 TAKING INPUTS FROM THE NATIONAL WEATHER SERVICE, AND WE
14:55 15 GENERATE THE WIND STRESSES. THOSE WIND STRESSES THEN MOVE THE
14:55 16 WATER SURFACE UP AND DOWN AND CIRCULATION.
14:55 17 Q. ADCIRC SO8 IS LIKE THE PROVEN RACEHORSE. IT'S USED ALL
14:55 18 OVER; RIGHT?
14:55 19 A. WELL, ADCIRC SO8 WAS THE MODEL THAT WE DEVELOPED WITH
14:55 20 DR. WESTERINK AT THE LSU HURRICANE CENTER THAT TURNED OUT TO BE
14:56 21 EXTREMELY ACCURATE FOR HURRICANE KATRINA.
14:56 22 Q. YOUR PRIMARY USE OF FINEL WAS TO TEST THE FUNNEL THEORIES
14:56 23 FIRST ESPOUSED BY B&C; CORRECT?
14:56 24 A. THAT'S RIGHT. WE NEEDED TO -- AS GOOD AS ADCIRC WAS FOR A
14:56 25 REALTIME SURGE SIMULATOR, WE NEEDED TO LOOK AT THINGS IN MORE
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1778
14:56 1 DETAIL. AND THAT WAS BETTER DONE USING THE FINEL MODEL, WHERE
14:56 2 WE COULD PUT IN MORE PRECISE GEOMETRY, AND IT WAS WELL SET UP
14:56 3 TO USE TO HANDLE THE WETLAND EFFECTS ON MODERN FRICTION AND SO
14:56 4 ON.
14:56 5 Q. TO YOUR SATISFACTION, IT'S YOUR OPINION THAT FINEL SHOWED
14:56 6 THAT THE MRGO AS ORIGINALLY BUILT, BUT MADE SIGNIFICANTLY WORSE
14:57 7 BECAUSE OF ITS WIDENING AND DEEPENING SINCE ORIGINAL
14:57 8 CONSTRUCTION, THAT CHANGE, THAT THIS HAD A SIGNIFICANT EFFECT
14:57 9 ON SURGE AMPLIFICATION AND VOLUME AND TIMING AT REACH 1 AND 2;
14:57 10 CORRECT?
14:57 12 Q. ESPECIALLY REACH 2 IN THE CASE OF THE DESTRUCTION OF THE
14:57 13 WETLANDS AND THE WATER COMING IN AND AMPLIFYING INTO THAT
14:57 14 NARROWER FUNNEL AND THEN INTO NEW ORLEANS EAST?
14:57 15 A. YES. IN TERMS OF SURGE HEIGHT OUT IN THE JAWS OF THE
14:57 16 FUNNEL THAT I'M POINTING HERE TO, TO THIS AREA, THIS REACH 2
14:57 17 HERE. SO WE HAD A LOT OF EFFECT ON CIRCULATION IN THE GAPE OF
14:57 18 THE FUNNEL, SHALL WE SAY, BUT IN THAT AREA THE WATER CAN ONLY
14:57 19 GET SO HIGH. SO THE MAXIMUM ELEVATION OF THE WATER IN THAT
14:58 20 AREA IS DETERMINED NOT SO MUCH BY THE AMOUNT OF WATER COMING IN
14:58 21 BUT BY THE HEIGHT OF THE PROTECTIVE STRUCTURES THERE.
14:58 22 SO THIS IS A BATHTUB IN WHICH WE ARE EMPTYING THE
14:58 23 FIREHOSE. THE WATER DOESN'T GO UP TO THE CEILING. IT STOPS AT
14:58 24 THE EDGE OF THE BATHTUB. I MEAN, IT DOESN'T STOP, BUT IT
14:58 25 DOESN'T GO ANY HIGHER THAN THE EDGE OF THE BATHTUB, AND THEN
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1779
14:58 1 THE NEIGHBORS DOWNSTAIRS GET WET.

14:58 2 Q. TO BE CLEAR, YOUR TESTING SCIENTIFICALLY PROVED WHAT B&C
14:58 3 ALERTED THE CORPS TO --
14:58 4 A. OH, ABSOLUTELY.
14:58 5 Q. -- WHICH IS THE CONVERGENCE OF JUST THE CHANNELS BY ITSELF
14:58 6 SIGNIFICANTLY AMPLIFIES SURGE TIMING AND INTENSITY?
14:58 8 Q. ADDITIONALLY, THE ENLARGEMENT OF REACH 1 AND REACH 2
14:58 9 FURTHER SIGNIFICANTLY AMPLIFIED THE KATRINA SURGE AND
14:59 10 OVERTOPPING AT THE CITRUS BACK LEVEE OF NEW ORLEANS EAST?
14:59 11 A. NO QUESTION ABOUT THAT.
14:59 12 Q. AND THAT A SIGNIFICANT PORTION OF THE INUNDATION OF
14:59 13 NEW ORLEANS EAST WAS THROUGH OVERTOPPING OF THE CITRUS BACK
14:59 14 LEVEE CAUSED BY THIS FUNNEL EITHER AS ORIGINALLY DESIGNED BUT
14:59 15 MADE SIGNIFICANTLY WORSE, AS WE'LL TALK ABOUT LATER, BY THE
14:59 16 FURTHER EROSION THAT WAS UNMITIGATED?
14:59 17 A. THAT'S RIGHT. AND I DISCUSSED THAT EXTENSIVELY IN MY
14:59 18 REPORT.
14:59 19 Q. TO BE CLEAR, THAT UNMITIGATED REACH 1 AND REACH 2 COMBINED
14:59 20 AND CAUSED AN AMPLIFIED SURGE HEIGHT, VOLUME, AND TIMING IN
14:59 21 REACH 1 AND THE IHNC TO BE DRAMATICALLY INCREASED AND
14:59 22 OVERTOPPED THE CITRUS BACK LEVEE, CAUSING THE OVERWHELMING
14:59 23 MAJORITY OF FLOODING IN NEW ORLEANS EAST WHERE THE ROBINSONS
14:59 24 LIVED?
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1780
14:59 1 Q. NOW, YOU AND YOUR EXPERT TEAM, WITH THE DUTCH USING FINEL,
15:00 2 REPORTED AND USED INFORMATION GENERATED AT CERTAIN SPECIFIC
15:00 3 POINTS SHOWN AT PAGE 20 OF THE POWERPOINT; CORRECT?
15:00 4 A. THAT'S RIGHT. THIS SHOWS THE LOCATIONS, SORT OF OUR
15:00 5 REFERENCE LOCATIONS.
15:00 6 Q. THE PURPOSE HERE IS, AMONG OTHER THINGS, TO ESTABLISH FLOW
15:00 7 AND FLOW VELOCITIES; CORRECT?
15:00 8 A. WE ARE ESTABLISHING CONDITIONS AT THESE POINTS. WE ALSO
15:00 9 SIMULATE FLOW VELOCITY IN THE CHANNELS AND OUTSIDE THE
15:00 10 CHANNELS.
15:00 11 Q. IN AN IDEAL WORLD, THERE'S A LITTLE MACHINE OR A HUMAN
15:00 12 PROTECTED FROM ALL OF THE WILD ELEMENTS OF A HURRICANE AT EVERY
15:00 13 ONE OF THESE POINTS THAT RECORDS EXACTLY WHAT IT REALLY WAS
15:00 14 DURING THE STORM; RIGHT?
15:00 15 A. IDEALLY, BUT THAT'S NOT THE WORLD THAT WE LIVE IN.
15:00 16 Q. SO YOU AND YOUR TEAM HAVE TO CALIBRATE OR VALIDATE THE
15:01 17 FINEL SIMULATION BY LOOKING FOR WHAT IS REALITY THAT YOU CAN
15:01 18 FIND TO VALIDATE UPON; RIGHT?
15:01 20 Q. YOU DON'T JUST ADJUST DATA BECAUSE IT DOESN'T SEEM TO FIT
15:01 21 YOUR MODEL; YOU GO OUT AND YOU FIND THE REALITY TO BASE YOUR
15:01 22 MODEL ON. RIGHT?
15:01 23 A. THAT'S THE PRINCIPLE OF SCIENTIFIC INQUIRY.
15:01 24 Q. IS THAT SOUND SCIENCE?
15:01 25 A. IT IS.
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15:01 1 Q. WELL, WHAT WAS THE PEAK SURGE? WE KNOW THE PEAK SURGE OF
15:01 2 KATRINA, DON'T WE? WE KNOW IT BASED ON REALITY?
15:01 3 A. WE KNOW IT AT A FEW PLACES.
15:01 4 Q. ALL RIGHT. WELL, LET'S PULL UP PAGE 25 OF THE POWERPOINT
15:01 5 AND TELL THE COURT ONE PLACE WE KNOW IT WITH ABSOLUTE
15:01 6 CERTAINTY.
15:01 7 A. OKAY. THIS IS PROBABLY THE ONLY PLACE -- WELL, IT IS THE
15:01 8 ONLY PLACE WHERE WE ACTUALLY HAVE A COMPLETE RECORD OF THE
15:01 9 SURGE, AND THAT IS FROM THE LOCK MASTER ACTUALLY HOURLY
15:01 10 GLANCING OUT OF HIS LITTLE GUARDHOUSE THERE ON THE IHNC LOCK
15:02 11 AND WRITING DOWN THE GAUGE READINGS EVERY HOUR. THAT IS SHOWN
15:02 12 IN THE BOTTOM DIAGRAM HERE. THIS IS FROM THE IPET REPORT.
15:02 13 THEN I PUT ON THE TOP OF THIS OUR FINEL SIMULATION,
15:02 14 AND I TRIED MY SPECIAL EFFECTS HERE -- NOT THAT GREAT, BUT I
15:02 15 TRIED TO MATCH THE TIME LINE. THE FACT IS THAT WE MATCHED THE
15:02 16 TIMING OF THE PEAK AT THIS POINT VERY, VERY CAREFULLY. WE
15:02 17 DIDN'T MATCH THE PEAK ELEVATION. WE ARE AT 17 FEET HERE. THE
15:02 18 PEAK ELEVATION IS A LITTLE ABOVE 14, BUT THERE'S A LOT OF GOOD
15:02 19 REASON FOR THAT.
15:02 20 Q. WELL, TELL THE COURT.
15:02 21 A. WELL, WHENEVER I RUN OR DR. VRIJLING RUNS THE FINEL MODEL
15:03 22 OR OUR GROUP AT LSU IS RUNNING ADCIRC OR DR. WESTERINK IS
15:03 23 RUNNING ADCIRC AT NOTRE DAME, WE NEVER IN OUR SURGE MODEL PUT
15:03 24 BREACHES INTO THAT SYSTEM.
15:03 25 SO WE DON'T MODEL THE SYSTEM AS IT ACTUALLY HAPPENED
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15:03 1 DURING KATRINA; WE MODEL IT AS IF THE LEVEES WERE PERFECTLY

15:03 2 MAINTAINED. WE PUT THEM AT THE RIGHT ELEVATIONS, BUT WE DON'T
15:03 3 ALLOW THEM TO BREACH, BECAUSE THAT INTRODUCES ANOTHER VARIABLE
15:03 4 INTO THE ANALYSIS. LATER, ONCE WE KNOW THE -- WHEN THE
15:03 5 BREACHES OPEN UP AND BEGIN FLOWING, THEN WE CAN PUT THAT IN
15:03 6 ANOTHER MODEL. BUT FOR THE SURGE MODEL, WE DON'T HAVE BREACHES
15:03 7 IN IT. SO WE KNOW THAT, IF OUR FINEL MODEL IS WORKING WELL, IT
15:03 8 SHOULD PREDICT HIGHER SURGE ELEVATION AT THIS POINT THAN WHAT
15:03 9 WAS ACTUALLY OBSERVED.
15:04 10 Q. IN OTHER WORDS, IT -- WELL, LET'S BACK UP. WHAT DID THE
15:04 11 LOCK MASTER OBSERVE AS THE HIGH POINT OF THE SURGE, THE TIME?
15:04 12 A. THE LOCK MASTER OBSERVED 14.2 FEET. ACTUALLY, I THINK
15:04 13 THAT THE GAUGE WAS LATER ADJUSTED, BUT 14.2 FEET OF SURGE RIGHT
15:04 14 AT THE NORTH END OF THE LOCK. THAT'S VERY CLOSE TO THE VERY
15:04 15 LARGE BREACH ON THE SOUTH INTO THE LOWER NINTH WARD.
15:04 16 Q. AT WHAT TIME, DR. KEMP?
15:04 17 A. LET'S SEE. THE HIGH POINT ON THIS CHART IS RIGHT AT 9:00.
15:04 18 Q. NOW, EARLIER IN THIS TRIAL, AN EXHIBIT WAS INTRODUCED
15:04 19 WITHOUT OBJECTION THAT SHOWED A TELEVISION CAMERA SHOWING SURGE
15:04 20 OVERTOPPING THE 40 ARPENT LEVEE. DO YOU RECALL THAT?
15:04 21 A. YES. IT WAS CLOSE TO THE 40 ARPENT LEVEE, AND IT SHOWS
15:05 22 THE WATER COMING UP VERY QUICKLY.
15:05 23 Q. IT SHOWED, ACCORDING TO THE CAMERA, ON THAT FILM
15:05 24 APPROXIMATELY 8:30, 8:35, IN THE MORNING; IS THAT CORRECT?
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15:05 1 Q. IS THAT CONSISTENT WITH THE OBSERVED HIGH WATER MARK BY

15:05 2 THE LOCK MASTER, HIGH SURGE POINT BY THE LOCK MASTER?
15:05 3 A. WELL, THE TIMING IS --
15:05 4 Q. THAT'S WHAT I MEAN, THE TIMING.
15:05 5 A. -- CONSISTENT, YES.
15:05 6 Q. THE TIMING IS CONSISTENT.
15:05 7 A. SO WHAT IT MEANS IS, AT THE TIME OF PEAK SURGE IN THE
15:05 8 IHNC, THE WATER WAS ALREADY COMING OVER THE 40 ARPENT LEVEE
15:05 9 INTO THE DEVELOPED AREA OF ST. BERNARD.
15:05 10 Q. NOW, BEFORE WATER CAN COME OVER THE 40 ARPENT LEVEE, THE
15:05 11 CENTRAL WETLANDS UNIT HAS TO FILL UP; CORRECT?
15:05 12 A. RIGHT. THAT'S A VERY LARGE AREA, ABOUT 32,000 ACRES, AND
15:05 13 SO IT DOESN'T FILL UP INSTANTANEOUSLY EVEN WITH VERY LARGE
15:05 14 BREACHES GOING INTO IT. WE ESTIMATE IT TAKES ABOUT TWO HOURS
15:05 15 TO FILL UP.
15:05 16 Q. YOU FURTHER VALIDATED FINEL BY GETTING THE TIMING RIGHT
15:06 17 BASED ON THESE TWO BITS OF REALITY?
15:06 18 A. THAT'S RIGHT. IF WE DON'T GET THIS RIGHT, THEN EVERYTHING
15:06 19 WE DO AFTER THAT IS WRONG.
15:06 20 Q. YOU DIDN'T DO IT BY ADJUSTING REALITY; YOU DID IT BY USING
15:06 21 REALITY. CORRECT?
15:06 23 Q. TIMING IS EVERYTHING IN GETTING BREACHING TIME ACCURATELY
15:06 24 ESTABLISHED, IS IT NOT?
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15:06 1 Q. NOW, YOUR FINEL TESTING, DR. VRIJLING'S FINEL TESTING, IN

15:06 2 YOUR OPINION NAILED THE PEAK SURGE TIME RECORDED BY THE LOCK
15:06 3 MASTER ON THE MONEY; IS THAT RIGHT?
15:06 5 THE COURT: THE DIFFERENCE IN HEIGHT IS ATTRIBUTABLE
15:06 6 TO THE FACT THAT BREACHES ARE NOT REGARDED AT THIS POINT IN THE
15:06 7 MODEL?
15:06 8 THE WITNESS: THAT'S RIGHT. REMEMBER, WE HAVE
15:06 9 BREACHES NOT ONLY IN THE IHNC BUT ALL ALONG THE REACH 2. SO IF
15:06 10 WE GOT IT RIGHT ON THE NUMBER, WE WOULD HAVE TO GO BACK AND SEE
15:06 11 WHAT WAS WRONG WITH OUR MODEL.
15:06 12 THE COURT: I UNDERSTAND. BECAUSE, OBVIOUSLY, THE
15:06 13 BREACHES WOULD HAVE REDUCED THE VOLUME TO SOME DEGREE, THE
15:07 14 SURGE VOLUME.
15:07 15 THE WITNESS: ABSOLUTELY, JUDGE.
15:07 16 BY MR. ROY:
15:07 17 Q. NOW, NOT TO DIGRESS TOO MUCH HERE, BUT THE CORPS OF
15:07 18 ENGINEERS' EXPERT, DR. WESTERINK, WHAT IS HIS TIMING ON PEAK
15:07 19 SURGE IN COMPARISON TO WHERE THESE REALITIES ARE, THESE TWO
15:07 20 BENCHMARKS THAT ARE REAL?
15:07 21 A. HIS PEAK SURGE COMES A COUPLE OF HOURS EARLIER.
15:07 22 Q. A COUPLE OF HOURS EARLIER THAN WHAT?
15:07 23 A. THAN WHAT THE LOCK MASTER SAW.
15:07 24 Q. WHEN YOU SAY A COUPLE HOURS EARLIER, YOU MEAN A COUPLE OF
15:07 25 HOURS TOO EARLY IN ORDER TO HAVE THE CWU FILL UP AND OVERFLOW
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15:07 1 BY THE TIME IT, IN FACT, DID AROUND 8:30?

15:07 2 A. THAT'S RIGHT. I BELIEVE HIS PEAK AT -- AND I THINK WE
15:07 3 HAVE A FIGURE THAT SHOWS THAT, BUT HIS PEAK WAS AROUND 6:40, I
15:08 4 BELIEVE, IN THE IHNC.
15:08 5 NOW, THE PEAK, THE SURGE PEAK, DOES NOT HAPPEN AT
15:08 6 EXACTLY THE SAME TIME EVERYWHERE IN THE FUNNEL, BUT IT DOES
15:08 7 HAPPEN WITHIN ABOUT 20 MINUTES. IT'S A LITTLE EARLIER OUT IN
15:08 8 THE REACH 2 LEVEES.
15:08 9 Q. WHAT WOULD YOU HAVE EXPECTED FROM A SCIENTIFICALLY VALID
15:08 10 ANALYSIS, WITHIN YOUR EXPERTISE, TO HAVE THE REALITY BE AT THE
15:08 11 LOCK AND AT THE TV TOWER CAMERA IF DR. WESTERINK'S TIMING WAS
15:08 12 CORRECT? WOULD YOU HAVE EXPECTED TO SEE THAT SURGE COME IN
15:08 13 EARLIER?
15:08 14 A. YES, SIR.
15:08 15 Q. MUCH EARLIER?
15:08 16 A. PROBABLY ABOUT TWO HOURS EARLIER.
15:08 17 Q. BUT THAT'S NOT REALITY, IS IT?
15:08 18 A. THAT'S NOT REALITY.
15:08 19 Q. NOW, DR. RESIO AND MR. EBERSOLE REALLY USE DR. WESTERINK'S
15:08 20 ADCIRC PEAK SURGE TIMES AND ADJUST IT A BIT, DO THEY NOT? OR
15:09 21 DO THEY?
15:09 22 A. WELL, I READ IN DR. EBERSOLE'S REPORT, AND I BELIEVE IN
15:09 23 DR. RESIO'S REPORT, THEY SAY THE PEAK SURGE IS AT 7:30. THAT'S
15:09 24 WHAT THIS DIAGRAM SHOWS, AND THIS WAS TAKEN OFF OF THEIR
15:09 25 EXHIBITS.
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15:09 1 THE COURT: MAY I ASK -- WE JUST NEED TO GET THIS --

15:09 2 WHERE CAN THE COURT FIND THIS EXHIBIT?
15:09 3 MR. ROY: THIS IS POWERPOINT 163, YOUR HONOR.
15:09 4 COUNSEL FOR THE CORPS AND I HAVE AGREED THAT, AT THE CONCLUSION
15:09 5 OF THIS, WE ARE GOING TO TURN THIS WHOLE POWERPOINT IN AS
15:09 6 DEMONSTRATIVES FOR THE REFERENCE OF THE COURT.
15:09 7 THE COURT: ALL RIGHT. POWERPOINT 163, DO WE HAVE
15:09 8 THAT --
15:09 9 MR. ROY: IT'S NOT IN YOUR POSSESSION RIGHT NOW, BUT
15:09 10 ROB HAS A COPY. I HAVE A COPY.
15:09 11 BY MR. ROY:
15:10 12 Q. SO IF THOSE EXPERTS HAVE, IN FACT, ADJUSTED THE PEAK SURGE
15:10 13 FROM WHAT FITZGERALD HAD AND ARRIVE AT AROUND 7:30, THEN WHEN
15:10 14 WOULD YOU HAVE EXPECTED THE SURGE TO BE AT PEAK WHERE THE
15:10 15 REALITY POINT IS, THE LOCK AND THE TV TOWER?
15:10 16 A. I'M SORRY. I KIND OF LOST YOU THERE. YOU MENTIONED STEVE
15:10 17 FITZGERALD. HE WAS THEIR POLDER MODELING EXPERT. IS THAT --
15:10 18 Q. RIGHT. I WAS UNDER THE IMPRESSION THAT YOU WERE TELLING
15:10 19 US HOW DR. RESIO AND FITZGERALD AND OTHERS OF THEIR EXPERTS HAD
15:11 20 ADJUSTED DR. WESTERINK'S DATA SUCH AS TO SHIFT THE PEAK SURGE
15:11 21 TIME TO AROUND 7:30. PERHAPS I MISUNDERSTOOD.
15:11 22 A. THAT'S WHAT IT APPEARS TO ME. BECAUSE DR. EBERSOLE DID
15:11 23 NOT ACTUALLY RUN A SURGE MODEL, SO HIS SURGE INFORMATION IS
15:11 24 DERIVED FROM DR. WESTERINK. BUT SINCE DR. WESTERINK'S MODEL
15:11 25 OUTPUT IS ADVANCED TWO HOURS AHEAD OF REALITY, HE AND DR. RESIO
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1787
15:11 1 HAVE CHOSEN TO SHIFT IT AN HOUR LATER, SO TO 7:30. THAT STILL

15:11 2 DOESN'T COMPORT WITH REALITY, BUT IT'S AN HOUR CLOSER.
15:11 3 Q. WELL, USING THE REALITY OF TWO HOURS TO FILL THE CWU, IF
15:12 4 THE PEAK SURGE WAS AT 7:30, WHEN WOULD YOU HAVE EXPECTED TO SEE
15:12 5 THAT SURGE COME ROLLING OVER THE TOP OF THE 40 ARPENT LEVEE --
15:12 6 A. IT WOULD BE --
15:12 7 Q. -- IF IT WASN'T 8:35 LIKE THE TV CAMERA SHOWED?
15:12 8 A. IT WOULD BE AT 9:30.
15:12 9 Q. BUT THAT'S NOT REALITY.
15:12 10 A. WAIT. I'M SORRY. I'M CONFUSED HERE. THE ACTUAL SURGE IS
15:12 11 COMING ACROSS THE 40 ARPENT LEVEE --
15:12 12 THE COURT: AT 7:30.
15:12 13 THE WITNESS: NO, AT 8:30. AT 8:30.
15:12 14 THE COURT: I KNOW, BUT HE IS SAYING IF THE PEAK
15:12 15 SURGE WERE AT 7:30 --
15:12 16 THE WITNESS: IT WOULD COME AT 7:30.
15:12 17 THE COURT: -- IT WOULD THEN START TO, YOU SAY, FILL
15:12 18 UP? WHAT WAS YOUR QUESTION?
15:12 19 MR. ROY: THAT'S IT, YOUR HONOR. THAT'S IT.
15:12 20 BY MR. ROY:
15:12 21 Q. DR. KEMP, LISTEN. IF THE PEAK SURGE IS, IN FACT, AT 7:30,
15:12 22 IF THAT WERE IT, WHEN WOULD YOU HAVE EXPECTED TO SEE THE WATER
15:13 23 STARTING TO COME OVER THE 40 ARPENT LEVEE?
15:13 24 A. THE ANSWER IS 7:30 BECAUSE IT WOULD BE SYNCHRONOUS WITH
15:13 25 THE PEAK SURGE.
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15:13 1 THE COURT: LET ME ASK YOU A QUESTION. WE ARE USING

15:13 2 WHAT YOU HAVE STATED ARE REALITY POINTS TO SEE HOW WELL YOUR
15:13 3 MODEL COMPORTED WITH REALITY AND OTHERS. THERE'S A TWO-HOUR
15:13 4 DIFFERENTIAL, I UNDERSTAND, BETWEEN YOUR TEAM'S OPINION
15:13 5 AND DR. WESTERINK; IS THAT CORRECT?
15:13 6 THE WITNESS: WELL, THERE IS A TWO-HOUR DIFFERENCE
15:13 7 BETWEEN WHAT THE LOCK MASTER SAW AND WHAT DR. WESTERINK
15:13 8 PREDICTED.
15:13 9 THE COURT: I GUESS I WILL ASK YOU: WHAT IS YOUR
15:13 10 MODEL? DOES YOUR MODEL COINCIDE WITH WHAT THE LOCK MASTER
15:13 11 SAID?
15:13 12 THE WITNESS: IT DOES, WITHIN ABOUT TEN MINUTES.
15:13 13 THE COURT: MY QUESTION IS WOULD THAT BE THE CASE --
15:13 14 ALTHOUGH THE PEAK SURGE DID NOT REACH ALL POINTS INVOLVED IN
15:14 15 THIS LAWSUIT AT THE SAME TIME, IF WE ACCEPT THIS PREMISE AS
15:14 16 TRUE, IT WOULD BE A TWO-HOUR DIFFERENTIAL AT ALL POINTS?
15:14 17 THE WITNESS: THAT'S CORRECT.
15:14 18 THE COURT: JUST TO GET IT ON THE RECORD.
15:14 19 BY MR. ROY:
15:14 20 Q. NOW, WHAT'S THE SIGNIFICANCE, DR. KEMP? IS THE
15:14 21 SIGNIFICANCE BECAUSE THEIR THEORY OF WHAT HAPPENED TO THE
15:14 22 REACH 2 LEVEES CAN ONLY HAPPEN, ACCORDING TO THEIR THEORY, NEAR
15:14 23 PEAK SURGE THROUGH OVERTOPPING?
15:14 24 A. MY READING IS THAT THEY NEED AN EARLIER PEAK BECAUSE, FOR
15:14 25 THEM, OVERTOPPING IS THE PRIMARY MECHANISM; WHEREAS, FOR US, WE
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15:14 1 CAN DESTROY THE LEVEES BEFORE WE GET TO PEAK BECAUSE WE

15:14 2 CONTEMPLATE THE IDEA OF FRONT-SIDE WAVE EROSION AS A MAJOR
15:15 3 DESTRUCTIVE FORCE, AND YOU HAVE HEARD A LOT ABOUT THAT FROM
15:15 4 DR. BEA.
15:15 5 Q. USING PAGE 163 OF THE POWERPOINT, YOU HAVE TAKEN THE
15:15 6 REPORTED WESTERINK, RESIO, EBERSOLE, LOCK MASTER, AND OUR FINEL
15:15 7 PEAK SURGE AND CORRELATED WHERE THEY ARE TIME-WISE AND
15:15 8 HEIGHT-WISE; IS THAT RIGHT?
15:15 9 A. THESE ARE TAKEN EXACTLY FROM -- FIRST OF ALL, THE DOTTED
15:15 10 BLACK LINE IS THE FINEL SCENARIO 1 TRACE. THIS IS TIME ALONG
15:15 11 THE BOTTOM HERE. THIS IS HEIGHT, NAVD88.
15:15 12 THE SECOND LINE YOU SEE HERE, THE THICK RED LINE IS
15:15 13 ACTUALLY THAT. THAT IS WHAT THE LOCK MASTER SAW. OKAY. WE
15:15 14 HAVE CHANGED THE SCALE SOMEWHAT.
15:15 15 Q. BUT THE DIFFERENCE BETWEEN WHAT THE LOCK MASTER SAW AT
15:16 16 THAT PRECISE TIME, 8:50, AND WHAT YOUR TESTING REVEALED IS THE
15:16 17 EFFECT OF THE BREACHING?
15:16 18 A. THAT'S CORRECT. NOW, DR. WESTERINK'S PREDICTION IS THIS
15:16 19 BLUE LINE, AND HE SHOWS A PEAK OF 13.6 FEET AT 6:35 A.M.
15:16 20 CENTRAL TIME. DR. EBERSOLE REPORTS THAT THE PEAK HAS ACTUALLY
15:16 21 RISEN TO 14.2 FEET, WHICH HAPPENS TO CORRESPOND WITH WHAT THE
15:16 22 LOCK MASTER RECORDED, AND THE PEAK TIME IS AT 7:40. SO IT'S
15:16 23 ALMOST EXACTLY AN HOUR LATER THAN WHAT THE UNDERLYING MODEL
15:16 24 RESULT WAS. SO I CALL THAT THE EBERSOLE TIME ADJUSTMENT.
15:16 25 Q. FROM WHAT YOU CAN TELL FROM THE EBERSOLE REPORTS, DID
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15:17 1 MR. EBERSOLE DO ANY ACTUAL TESTING/MODELING HIMSELF?

15:17 2 A. MY UNDERSTANDING IS THAT ALL OF HIS MODELING RESULTS ARE
15:17 3 DERIVED FROM DR. WESTERINK.
15:17 4 Q. HE JUST ADJUSTED THEM?
15:17 5 A. APPARENTLY.
15:17 6 Q. NOW, DR. VRIJLING, IN HIS REPORTS AND TESTIMONY, SHOWED
15:17 7 THE COURT, AS YOU DID IN YOUR REPORT -- ESPECIALLY CHAPTER 5,
15:17 8 PX-91 -- VARIOUS MODEL RUNS: SCENARIO 1, 2C, 3, AND OTHERS;
15:17 9 CORRECT?
15:17 11 Q. FOR THE GOVERNMENT'S THEORY TO WORK -- THAT IS,
15:17 12 OVERTOPPING ON REACH 2 ERODED THE BACK SIDE OF THE LEVEES,
15:17 13 THERE WAS NO COLLAPSE AND BREACH OF THE LEVEES FROM FRONT-SIDE
15:18 14 ATTACK AS DR. BEA SAYS -- FOR THE GOVERNMENT THEORY TO WORK,
15:18 15 THE COURT WOULD HAVE TO ACCEPT THAT PEAK SURGE WAS AT OR BEFORE
15:18 16 7:30 A.M. INSTEAD OF 8:50. IS THAT RIGHT?
15:18 17 A. THAT IS CORRECT.
15:18 18 Q. WHY?
15:18 19 A. WELL, THEY DON'T REALLY HAVE AVAILABLE TO THEM THE
15:18 20 FRONT-SIDE EROSION MECHANISM. IT'S JUST THEY -- WE HAVE TWO
15:18 21 MECHANISMS; THAT IS, FRONT-SIDE EROSION AND OVERTOPPING. THEY
15:18 22 HAVE ONLY ONE.
15:18 23 Q. WELL, LET'S TALK ABOUT WAVES BECAUSE YOU KEEP --
15:18 24 THE COURT: BEFORE YOU GET TO WAVES, DO THE VARIOUS
15:18 25 EXPERTS AGREE -- THERE'S DISAGREEMENT AS TO WHEN THE SURGE
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15:18 1 PEAKED. IS THERE AGREEMENT AMONG THE EXPERTS IN GENERAL --

15:19 2 PLEASE TELL ME IF THERE ISN'T -- AS TO THE DURATION OF THE
15:19 3 SURGE?
15:19 4 THE WITNESS: WHEN WE TALK ABOUT DURATION ABOVE A
15:19 5 CERTAIN EXCEEDANCE LEVEL, WE HAVE DIFFERENT UNDERSTANDINGS OF
15:19 6 THAT. OF COURSE, THE DEFENDANT'S EXPERTS ALSO DON'T AGREE ON
15:19 7 THE HEIGHT OF THE SURGE EITHER, BUT --
15:19 8 THE COURT: THERE ARE DIFFERENCES RELATED TO HOW LONG
15:19 9 THE SURGE MAINTAINED A CERTAIN LEVEL?
15:19 10 THE WITNESS: THAT'S RIGHT. YOU CAN SEE WE DIDN'T
15:19 11 PLOT THE WHOLE CURVE HERE, BUT YOU CAN SEE THAT THERE ARE
15:19 12 DIFFERENCES HERE. WE'RE COMING UP AND -- ACTUALLY, THEY SEEM
15:19 13 TO COME TOGETHER FAIRLY WELL, BUT DR. WESTERINK ALSO HAD A
15:19 14 SECONDARY SURGE THAT OCCURRED ABOUT THREE OR FOUR HOURS AFTER
15:20 15 THE MAIN SURGE.
15:20 16 THE COURT: IF YOU DON'T FEEL COMFORTABLE ANSWERING A
15:20 17 QUESTION, YOU CAN CERTAINLY TELL ME SO. DOES THE TIME OF THE
15:20 18 SURGE -- PRETERMITTING THE FRONT-SIDE EROSION, BACK-SIDE
15:20 19 EROSION, TENSION -- HAVE AN EFFECT ON WHETHER THERE WAS
15:20 20 SUFFICIENT TIME, SUFFICIENT OVERTOPPING, SO THAT ULTIMATELY THE
15:20 21 40 ARPENT WAS OVERTOPPED?
15:20 22 THE WITNESS: VERY DEFINITELY.
15:20 23 THE COURT: WELL, COULD YOU ELABORATE ON THAT A
15:20 24 LITTLE BIT.
15:20 25 THE WITNESS: I GUESS I WOULD HAVE TO TALK ABOUT
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15:20 1 ANOTHER MODEL, WHICH IS THE POLDER FLOODING MODEL.

15:20 2 THE COURT: YOU MAY BE GETTING INTO THAT, MR. ROY. I
15:20 3 DON'T KNOW IF YOU ARE OR NOT.
15:20 4 MR. ROY: I THINK WE DO GET THERE, YOUR HONOR.
15:20 5 THE COURT: WELL, I'LL WAIT UNTIL YOU GET THERE.
15:20 6 BY MR. ROY:
15:20 7 Q. LET'S TURN TO WAVES, DR. KEMP. IPET GOT THE WAVE PERIODS
15:21 8 AND HEIGHTS WRONG, AND ILIT RELIED ON IPET FOR THAT; RIGHT?
15:21 9 A. UNTIL DR. VRIJLING AND HIS TEAM RAN SWAN AS PART OF THIS
15:21 10 INVESTIGATION, THE WAVE CLIMATE IN LAKE BORGNE WAS COMPLETELY
15:21 11 MISUNDERSTOOD, AND THE RESULTS THAT WERE -- OR THE INFORMATION
15:21 12 REPORTED IN IPET WAS COMPLETELY WRONG.
15:21 13 Q. THE IPET REPORT, OF COURSE, INCLUDED MANY OF THE SAME
15:21 14 CORPS EXPERTS THAT ARE GOING TO TESTIFY DURING THE DEFENSE
15:21 15 PORTION OF THE CASE; CORRECT?
15:21 17 Q. THE MAGNITUDE OF THE WAVES REFLECTED IN IPET WAS HALF OF
15:21 18 WHAT IT SHOULD BE AS TO THE PERIOD. THEY SAID THE WAVES WERE
15:21 19 THREE TIMES WHAT THEY REALLY WERE, 15-, 16-SECOND WAVE PERIODS;
15:21 20 RIGHT?
15:21 21 A. THAT'S RIGHT. THEY SAID THAT THE WAVES IN LAKE BORGNE
15:22 22 WERE ESSENTIALLY SWELL WAVES COMING FROM OFFSHORE. SWELL WAVES
15:22 23 HAVE PERIODS IN EXCESS OF 10 SECONDS. WHAT WE ENDED UP FINDING
15:22 24 OUT WAS THAT THE WAVES IN THE SOUTHERN PART OF LAKE BORGNE
15:22 25 ACTUALLY GENERATED IN LAKE BORGNE AND WERE LOCALLY GENERATED
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15:22 1 SEAS.
15:22 2 Q. THE BOTTOM LINE IS IPET AND ILIT FOUND LONGER AND SHORTER,
15:22 3 LESS-ENERGIZED WAVES THAN KATRINA REALITY PROVEN BY YOUR
15:22 4 TESTING?
15:22 5 A. OKAY. THAT'S A HARD -- I WOULD PUT IT DIFFERENTLY.
15:22 6 Q. PUT IT HOWEVER IT SHOULD -- I'M SORRY.
15:22 7 THE WITNESS: JUDGE, DID YOU HAVE A QUESTION?
15:22 8 THE COURT: I JUST DIDN'T UNDERSTAND THE LONGER,
15:22 9 SHORTER, ENERGIZED WAVES.
15:22 10 THE WITNESS: WELL, I HAD A LITTLE DIFFICULTY WITH
15:22 11 THAT TOO.
15:22 12 BY MR. ROY:
15:22 13 Q. LONGER IN WAVELENGTH?
15:22 14 A. OKAY. LONGER IN WAVELENGTH, CORRECT.
15:22 15 Q. LONGER WAVE --
15:22 16 A. OBVIOUSLY, 15 SECONDS -- REMEMBER, WE ARE TALKING ABOUT
15:22 17 THE TIME THAT IT TAKES A WAVE CREST TO GO PAST A POST, LET'S
15:22 18 SAY, ON THE BEACH OR HOW OFTEN THE WAVES ARE BREAKING ON THE
15:23 19 BEACH. THAT'S EVERY 15 SECONDS. WE ARE TALKING ABOUT WAVES
15:23 20 THAT WERE GENERATED ACTUALLY WELL OFFSHORE THAT HAVE TRAVELED
15:23 21 INTO THE AREA.
15:23 22 WHEN THE SQUALL COMES UP AND THE THUNDERSTORM COMES
15:23 23 THROUGH, WHAT YOU SEE ARE WAVES THAT ARE 3, 4 SECONDS. THOSE
15:23 24 ARE LOCALLY GENERATED SEAS. MAYBE I'M MISSING SOMETHING.
15:23 25 Q. WELL, LET ME TRY AGAIN.
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15:23 1 THE COURT: ARE YOU SAYING -- I NEED TO UNDERSTAND

15:23 2 IT. ARE YOU SAYING THAT THERE'S A DIFFERENCE IN THE HEIGHT OF
15:23 3 THE WAVE -- I DON'T KNOW IF YOU WANT TO USE THE TERM
15:23 4 SIGNIFICANT WAVE OR NOT -- AND THE INTERVAL BETWEEN THE WAVES?
15:23 5 THE WITNESS: BOTH THOSE THINGS ARE VERY DIFFERENT
15:23 6 FROM THE IPET REPORT TO ANY STUDY THAT'S BEEN DONE IN THIS
15:23 7 REPORT.
15:23 8 NOW, THAT'S NOT RELEVANT, NECESSARILY, TO ME
15:23 9 BECAUSE THE GOVERNMENT'S EXPERTS HAVE AGREED WITH US ON THAT AT
15:24 10 THIS POINT. BUT WHAT I'M SAYING IS THAT WE, WHEN WE WERE DOING
15:24 11 TEAM LOUISIANA -- I SHOULD SAY I, WHEN I WAS DOING TEAM
15:24 12 LOUISIANA, WE WERE MISLED BY THE BELIEF THAT THERE WERE
15:24 13 15-SECOND WAVES IN THIS AREA, WHICH WOULD HAVE CHANGED VERY
15:24 14 MUCH OUR PERCEPTION OF ERODIBILITY ON THE LEVEES.
15:24 15 THE COURT: THE LESS THE TIME INTERVAL BETWEEN THE
15:24 16 WAVES, THE MORE EROSION?
15:24 17 THE WITNESS: THE LESS THE TIME INTERVAL, THE MORE
15:24 18 THE CYCLES, WHICH IN DR. BEA'S FATIGUE MODELS ARE VERY
15:24 19 IMPORTANT. SO IT'S THE NUMBER OF HAMMER HITS EVERY MINUTE.
15:24 20 THE COURT: SO WAS I CORRECT IN SAYING --
15:24 21 THE WITNESS: YOU WERE CORRECT.
15:24 22 THE COURT: AND IT'S DUE TO THE CYCLES?
15:24 23 THE WITNESS: THE NUMBER OF CYCLES.
15:24 24 BY MR. ROY:
15:24 25 Q. WHAT IPET AND ILIT DESCRIBED AS THE LAKE BORGNE WAVES
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1795
15:25 1 COMING INTO, EFFECTIVELY, THE REACH 2 AREA WERE BASICALLY LONG,
15:25 2 ROLLING WAVES THAT HAVE LESS ENERGY AND IMPACT THAN 4- AND
15:25 3 5-SECOND WAVES THAT HIT QUICKLY WITH FAR HIGHER ENERGY?
15:25 4 A. THAT'S CORRECT. THESE ARE DYING WAVES, ESSENTIALLY, AS
15:25 5 OPPOSED TO BUILDING WAVES.
15:25 6 Q. THE SHORT WAVES ARE WHAT?
15:25 7 A. THEY ARE LOCALLY GENERATED. THEY ARE BUILDING UNDER THAT
15:25 8 90-MILE-AN-HOUR WINDS.
15:25 9 Q. HIGH-ENERGY WAVES?
15:25 10 A. OH, YES.
15:25 11 Q. ALL RIGHT. THE WAVE HEIGHT REPORTED THEN WAS ONE-THIRD OF
15:25 12 WHAT YOU AND THE DUTCH FOUND THEM TO BE?
15:25 13 A. ACTUALLY, THE WAVE HEIGHT THAT I SAW IN IPET WAS 5 FEET,
15:25 14 AND WE ARE REPORTING 9-FOOT WAVES IN THE SAME AREA --
15:25 15 Q. I STAND CORRECTED.
15:25 16 A. -- SO NOT QUITE.
15:25 17 Q. LET'S PULL UP PAGE 27 OF THE POWERPOINT. LET'S QUICKLY GO
15:26 18 THROUGH THE CONCEPTS OF THE WAVE MODELING, WHAT YOU DID. THEN
15:26 19 WE ARE GOING TO GO TO THE ACTUAL GRID AND SHOW HOW YOU WENT TWO
15:26 20 STEPS FURTHER WITH THE DUTCH THAN THE GOVERNMENT TEAMS DID.
15:26 21 A. THAT'S RIGHT. UNLIKE THE CIRCULATION MODELS THAT WE USED,
15:26 22 LIKE ADCIRC AND FINEL, WHICH HAVE THE ABILITY -- YOU CAN PUT A
15:26 23 LOT OF INTENSITY IN AREAS YOU ARE INTERESTED IN. IN WAVE
15:26 24 MODELING YOU HAVE TO USE A REGULAR GRID, LIKE A PIECE OF GRAPH
15:26 25 PAPER. SO YOU ARE ACTUALLY LOOKING AT WAVES ON A GRIDDED
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1796
15:26 1 SURFACE, AND THE GRID HAS TO BE THE SAME SIZE EVERYWHERE INSIDE
15:26 2 THE DOMAIN OF THE PALM.
15:26 3 THE ONLY WAY WE CAN CAPTURE WHAT'S HAPPENING WITH
15:26 4 WAVES AT A HIGH RESOLUTION IS TO PROGRESSIVELY NEST GRIDS
15:26 5 INSIDE EACH OTHER UNTIL WE COME DOWN TO THE RESOLUTION THAT IS
15:26 6 NECESSARY TO ANSWER THE QUESTIONS THAT WE NEED TO ANSWER. SO
15:27 7 THE WAY THIS STARTS IS WE USE THE SURGE SURFACE GENERATED BY
15:27 8 THE -- IN THE CASE OF THE DEFENDANTS, THEY USED AN
15:27 9 ADCIRC-GENERATED SURFACE. WE USED A FINEL-GENERATED SURFACE.
15:27 10 THEN WE RUN THE WINDS OVER THAT, AND WE DEVELOP A SPECTRAL
15:27 11 CHARACTERIZATION OF THE WAVES THAT ARE IN THAT AREA.
15:27 12 Q. DR. KEMP, LET'S CUT TO THE CHASE. GO TO PAGE 28 AND
15:27 13 EXPLAIN FOR THE JUDGE THIS CONCEPT OF NESTED GRIDS IN LANGUAGE
15:27 14 WE CAN UNDERSTAND.
15:27 15 A. OKAY. I'LL TRY. HERE WE SEE A SERIES OF BOXES INSIDE
15:27 16 EACH OTHER. MAYBE YOU CAN BLOW THAT UP SOME. OKAY.
15:27 17 SO THIS IS WHERE WE TAKE WAVES FROM -- WE START THE
15:27 18 SAME PLACE THAT THE DEFENDANTS DO. WE TAKE BOUNDARY CONDITIONS
15:28 19 FROM ANOTHER MODEL, WHICH EVERYBODY USES, THE OFFSHORE MODEL.
15:28 20 THEN WE USE THIS GRID FIRST. THE NEXT TIME, WE USE THIS ONE.
15:28 21 IT'S KIND OF LIKE IF I WANTED TO READ WHATEVER THE
15:28 22 LEAD ATTORNEY ON THE DEFENDANT'S SIDE IS WRITING ON HIS TABLET,
15:28 23 I CAN'T SEE IT FROM HERE, SO I HAVE TO TAKE PROGRESSIVELY
15:28 24 SMALLER -- I HAVE TO GET CLOSER OVER TIME.
15:28 25 THIS BIG GRID MIGHT BE THE WHOLE COURTROOM HERE.
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1797
15:28 1 THIS SMALLER GRID MIGHT INCLUDE THE ATTORNEYS' TABLE AND MAYBE
15:28 2 OUT TO WHERE YOU ARE, JUDGE. THEN THE NEXT GRID -- THAT'S THE
15:29 3 M GRID -- MIGHT REPRESENT TOP OF THEIR TABLE. THEN THE F AND
15:29 4 THE G GRIDS HERE WOULD ALLOW ME TO NOT ONLY SEE THAT THEY HAVE
15:29 5 A PAD OF PAPER IN FRONT OF THEM BUT ALSO WHAT THEY SAYS ON IT.
15:29 6 THE COURT: THIS MAY NOT BE AN APPROPRIATE ANALOGY,
15:29 7 BUT IS IT, IN A VERY SIMPLISTIC WAY, LIKE GETTING BETTER
15:29 8 RESOLUTION ON A CAMERA? IS IT A QUESTION OF ACHIEVING BETTER
15:29 9 FOCUS BY FINE-TUNING THE GRID?
15:29 10 THE WITNESS: YOU'RE JUST MORE ELOQUENT THAN I AM
15:29 11 ABOUT THIS. IT'S HARD FOR ME TO EXPLAIN IT, BUT I THINK YOU
15:29 12 GRASP IT PERFECTLY.
15:29 13 IF YOU LOOK AT THE BOTTOM OF THAT PAGE, WE
15:29 14 ACTUALLY QUANTIFY THAT. WHAT YOU SEE, THE LARGEST GRID, IF YOU
15:29 15 LOOK AT THE AREA -- OR, I'M SORRY, THE RESOLUTION HERE, YOU
15:29 16 WILL SEE THAT IT HAS A -- THE LENGTH ON EACH SIDE OF THAT GRID
15:30 17 IS 1,640 FEET, SO ABOUT A THIRD OF A MILE. THEN THE NEXT ONE
15:30 18 IS 656 BY 656.
15:30 19 NOW, I CAN TELL YOU BECAUSE I HAVE DONE THE
15:30 20 CALCULATION THAT THE SMALLEST CELL SIDE IN THE A GRID IS ABOUT
15:30 21 70 ACRES. IF I GO DOWN TO 656, THE SMALLEST CELL SIZE IS ABOUT
15:30 22 10 ACRES. THEN THE NEXT STEP DOWN, THAT'S 3 ACRES. OUR
15:30 23 FINEST-RESOLUTION GRID HAS A RESOLUTION OF A TENTH OF AN ACRE.
15:30 24 SO WE CAN SEE THINGS THAT ARE HAPPENING IN A GRID THAT IS
15:30 25 66 FEET ON EACH SIDE.
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1798
15:30 1 THE COURT: WOULD THAT TECHNOLOGY BE AVAILABLE TO THE

15:30 2 DEFENDANT EXPERTS AS WELL?
15:30 3 THE WITNESS: THIS IS AVAILABLE TO ANYONE DOING WAVE
15:30 4 MODELING.
15:30 5 THE COURT: IS THERE ANY REASON WHY ONE WOULD USE --
15:31 6 I'M GOING TO USE SIMPLISTIC TERMS -- A LOW-RESOLUTION WAVE
15:31 7 MODEL RATHER THAN A HIGH-RESOLUTION WAVE MODEL?
15:31 8 THE WITNESS: I CAN'T THINK OF ANY.
15:31 9 THE COURT: OTHER THAN IT TAKES A LONGER TIME TO DO,
15:31 10 I'M CERTAIN -- BECAUSE YOU HAVE TO GO THROUGH MORE STEPS -- THE
15:31 11 HIGHER RESOLUTION?
15:31 12 THE WITNESS: THAT'S CORRECT, YOUR HONOR.
15:31 13 THE COURT: YOU WOULD HAVE TO HAVE MORE RUNS, ETC.
15:31 14 THE WITNESS: AGAIN, IN THIS CASE, WE WERE INTERESTED
15:31 15 IN LOOKING SPECIFICALLY AT THE MRGO. OKAY. THE MRGO IS A
15:31 16 CHANNEL THAT HAD AN AUTHORIZED TOP WIDTH OF 650 FEET. SO IF
15:31 17 OUR FINEST-RESOLUTION GRID HAS 656 FEET ON THE SIDE, WE ARE
15:31 18 GOING TO HAVE TO BE VERY LUCKY TO FIT ONE IN THAT FOOTPRINT.
15:31 19 SO WE DON'T WANT TO TAKE THAT CHANCE, BUT WE CAN PUT 10 OF OUR
15:31 20 SMALLER CELLS ACROSS THERE AND WE REALLY SEE WHAT'S HAPPENING.
15:32 21 BECAUSE WHEN YOU HAVE THESE LARGER CELLS, THEN
15:32 22 THE WAVE CHARACTERISTICS APPEAR TO JUMP FROM ONE TO THE NEXT
15:32 23 CELL, AND YOU DON'T ACTUALLY GET A SMOOTH SENSE OF WHAT'S GOING
15:32 24 ON. HERE WE WERE PARTICULARLY INTERESTED IN LOOKING AT WAVE
15:32 25 REGENERATION IN THIS CHANNEL, SO WE HAD TO GET DOWN TO THAT
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1799
15:32 1 KIND OF RESOLUTION.

15:32 2 BY MR. ROY:
15:32 3 Q. SO, DR. KEMP, I WANT TO MOVE OFF OF HERE, BUT BEFORE WE DO
15:32 4 THAT, I WANT TO GET ONE COMPARISON VERY CLEARLY MADE. THE
15:32 5 GOVERNMENT, USING THE BIG BLACK LINE, YOUR BIG GRID -- IS THAT
15:32 6 YOUR A GRID?
15:32 7 A. THE GRID THAT THEY USED WOULD CORRESPOND WITH THIS GREEN
15:32 8 LINE. THAT'S THE C GRID FOR US. THAT'S THE ONE THAT IS 656
15:32 9 FEET BY 656 FEET ON THE SIDE.
15:32 10 Q. SO WHEN DEALING WITH RESIO REPORT 1, WHEN I TALKED TO HIM
15:33 11 ABOUT HIS STWAVE MODELING THAT HE USED AND WHATNOT, THE BASIC
15:33 12 COMPARISON IS THE GREEN BOX UP THERE? I MEAN, NOT EXACTLY, BUT
15:33 13 CLOSE?
15:33 14 A. IT'S QUITE CLOSE.
15:33 15 Q. THEN THEY GO INTO ONE ELEVATION LOWER; IS THAT CORRECT?
15:33 16 A. NO. THAT IS THEIR MOST -- THAT'S THEIR HIGHEST. THEY DO
15:33 17 THE FIRST TWO STEPS; THAT IS, THE BLACK BOX AND THE GREEN BOX.
15:33 18 THEY DON'T DO WHAT WE CALL THIS M GRID HERE, AND THE --
15:33 19 THE COURT: I UNDERSTOOD YOUR QUESTION, SIR. ONE
15:33 20 RESOLUTION LOWER THAN THE A GRID; IS THAT CORRECT?
15:33 22 BY MR. ROY:
15:33 23 Q. SO THE BOTTOM LINE IS THE GOVERNMENT'S EXPERTS, WHEN THEY
15:33 24 ARE LOOKING AT WHAT'S HAPPENING OVER MRGO, ARE USING GRIDS THAT
15:34 25 ARE OVER 600 FEET ON THE SIDE AS REPORTED IN THEIR REPORTS; IS
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1800
15:34 1 THAT CORRECT?

15:34 3 Q. THE RESULT IS YOU HAVE LOSS OF RESOLUTION, LOSS OF
15:34 4 DEFINITION OF THE MRGO AND, IN FACT, CANNOT ARTICULATE AND
15:34 5 IDENTIFY IT LIKE YOU DO AND THE DUTCH DO. WE JUMP DOWN TO
15:34 6 THESE NEXT TWO LEVELS EXAMINING RIGHT ON IT OR, LIKE YOU SAID,
15:34 7 STANDING ON MR. SMITH'S SHOULDER, EFFECTIVELY, AND READING HIS
15:34 8 TABLET. THAT'S THE MRGO?
15:34 10 Q. ALL RIGHT. IS SMALLER BETTER WHEN YOU ARE TALKING ABOUT
15:34 11 GRIDS?
15:34 12 A. NO, MR. ROY, SMALLER IS NOT BETTER IN WAVE MODELING IN
15:34 13 GRIDS, NO.
15:34 14 WAIT. I'M SORRY. ASK THE QUESTION AGAIN, PLEASE,
15:34 15 SIR.
15:34 16 Q. SMALLER GRIDS ARE BETTER THAN BIGGER GRIDS?
15:34 17 A. ABSOLUTELY.
15:34 18 THE COURT: I'VE GOT THE PICTURE.
15:34 19 THE WITNESS: I THINK I MISSED IT.
15:34 20 THE COURT: IT'S IN FINE RESOLUTION.
15:34 21 BY MR. ROY:
15:34 22 Q. LET'S GO TO PAGE 29 FOR THE POWERPOINT. THIS IS THE
15:35 23 FINEST RESOLUTION OF YOUR FINEL. YOU ARE DOWN TO -- GO AHEAD.
15:35 24 A. ACTUALLY, THIS IS OUR FINE-RESOLUTION SWAN GRID, THE F AND
15:35 25 THE G GRIDS, DESIGNED TO LOOK SPECIFICALLY AT WAVE
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1801
15:35 1 TRANSFORMATION IN THE MRGO AND GIWW CHANNELS.

15:35 2 Q. THE GRID SIZE IN THESE IS WHAT?
15:35 3 A. A TENTH OF AN ACRE, 66 FEET BY 66 FEET.
15:35 4 Q. NOW, IN THE SLIDE NUMBERED 6 AND THE SLIDE NUMBERED 2 --
15:35 5 MR. ROY: BY THE WAY, YOUR HONOR, THE POWERPOINT
15:35 6 IDENTIFIES ON THE RIGHT WHAT PAGE -- ALMOST ALL OF THESE ARE
15:35 7 CROSS-REFERENCED TO THE ACTUAL EXHIBITS -- I MEAN, ACTUAL
15:35 8 REPORT DATES AND PAGE NUMBERS AND FIGURE NUMBERS.
15:35 9 BY MR. ROY:
15:35 10 Q. SO WHAT ARE WE LOOKING AT THERE?
15:35 11 A. FIRST OF ALL, WHAT YOU'RE LOOKING AT IS THE UNDERLYING
15:35 12 BATHYMETRY. SO THE REDDER, THE BROWNER COLORS ARE HIGHER, AND
15:36 13 THE BLUE COLOR IN THE CHANNEL IS LOWER.
15:36 14 OKAY. WHAT YOU WILL SEE ON EACH OF THESE CASES --
15:36 15 AND DR. VRIJLING DID THIS AT OUR REQUEST. HE PUT A TRANSECT OF
15:36 16 POINTS ACROSS THE CHANNEL TO ALLOW US TO UNDERSTAND WHAT WAS
15:36 17 HAPPENING AS THE WAVES CAME OUT OF LAKE BORGNE, CROSSED THE
15:36 18 MARSH, AND THEN MOVED INTO THE CHANNEL.
15:36 19 THIS POINT AT THE MIDPOINT OF THE CHANNEL IS ACTUALLY
15:36 20 WHERE MY JOB IS DONE. I HAND THE WAVE AND SURGE INFORMATION TO
15:36 21 DR. BEA AT THAT POINT, AND THEN HE RUNS HIS NONLINEAR MODELS UP
15:36 22 ON THE LEVEE AND THE FORESHORE THERE.
15:36 23 WAVES ARE WELL CHARACTERIZED OUT IN THIS AREA, BUT
15:37 24 WHEN WE GET INTO -- BY SWAN, BUT WHEN WE GET INTO THIS VERY
15:37 25 STEEPLY SLOPING ENVIRONMENT ON THE FORESHORE AND FACE OF THE
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1802
15:37 1 LEVEE, THEN THE WAVE ACTUALLY MOVES FROM A WAVE OF TRANSLATION,
15:37 2 WHERE THE FORM MOVES BUT THE WATER DOESN'T, TO A WAVE THAT'S
15:37 3 ACTUALLY TRANSPORTING WATER.
15:37 4 SO THAT'S SOMETHING THAT I WAS INTERESTED IN BECAUSE
15:37 5 I STUDIED IT FOR MY DISSERTATION, BUT IT MAY BE OF LESS
15:37 6 INTEREST TO OTHERS.
15:37 7 Q. SO BEFORE WE GO TO THE NEXT SLIDE, THE ACTUAL COMPARISON
15:37 8 OF A 60-BY-60 GRID LIKE YOU USED, THAT'S 3,600 SQUARE FEET;
15:37 9 COMPARED TO WHAT THE GOVERNMENT USED, WHICH IS A GRID OF
15:37 10 430,000 SQUARE FEET. RIGHT?
15:38 12 Q. THE DIFFERENCE OF YOUR GRID OF ONE-TENTH OF AN ACRE; THEIR
15:38 13 GRID OF 10 ACRES?
15:38 14 A. YES. A HUNDRED --
15:38 15 Q. LET'S LOOK AT PAGE 136.
15:38 16 THE COURT: WHAT WAS THAT YOU WANTED TO SAY?
15:38 17 THE WITNESS: I'M JUST SAYING .1 TO TENTHS, WE ARE
15:38 18 MOVING THE DECIMAL PLACE TO A HUNDRED TIMES.
15:38 19 THE COURT: YES. HE WANTED TO FINISH HIS ANSWER. GO
15:38 20 AHEAD.
15:38 21 BY MR. ROY:
15:38 22 Q. PAGE 136, CAN YOU EXPLAIN TO THE COURT WHAT WE ARE LOOKING
15:38 23 AT HERE.
15:38 24 A. OKAY.
15:38 25 Q. THIS IS DR. RESIO'S AND MR. EBERSOLE'S STUFF, IS IT NOT?
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1803
15:38 1 A. YES. THIS IS ACTUALLY THEIR -- AGAIN, IT'S

15:38 2 656-BY-656-FOOT RESOLUTION. BUT, ACTUALLY, IT'S REASSURING TO
15:38 3 US BECAUSE IT REALLY SHOWS, IN GENERAL, THEY'RE SEEING NOW
15:38 4 WAVES THAT ARE QUITE DIFFERENT THAN WHAT IPET REPORTED.
15:39 5 THEY ARE NOW IN THE TOP PANEL. THIS IS SIGNIFICANT
15:39 6 WAVE HEIGHT, THE AVERAGE OF THE HIGHEST ONE-THIRD WAVES.
15:39 7 THAT'S A STANDARD OUTPUT FOR A WAVE MODEL LIKE STWAVE OR SWAN.
15:39 8 THEY ARE ACTUALLY SEEING -- THE LARGEST WAVES IN THIS SOUTHERN,
15:39 9 SOUTHWESTERN LOBE OF LAKE BORGNE ARE NOW ABOUT 8 FEET.
15:39 10 IN TERMS OF THE PERIOD ON THE BOTTOM HERE, WE ARE NOW
15:39 11 SEEING 6 TO 7 SECONDS IN THIS AREA, AND THIS IS ESSENTIALLY
15:39 12 WHAT -- WE FOUND CLOSE TO THAT, SO WE ARE PRETTY HAPPY WITH
15:39 13 THAT.
15:39 14 Q. WASN'T YOURS ACTUALLY BETWEEN 5 AND 6? I DON'T RECALL.
15:39 15 A. WELL, IT'S HARD TO TELL -- BECAUSE THE RESOLUTION IS SO
15:39 16 POOR -- EXACTLY WHERE WE MAKE THE COMPARISONS. BUT THESE TWO
15:40 17 WAVE MODELS, STWAVE AND SWAN, ARE NOW REPORTING ESSENTIALLY THE
15:40 18 SAME KIND OF INFORMATION.
15:40 19 Q. LET'S GO TO THE BLOWUP, PAGE 137 OF DR. RESIO AND
15:40 20 MR. EBERSOLE'S REPORT. IS THE BLACK LINE BASICALLY THE EDGE
15:40 21 WHERE THE MRGO IS AND TO THE LEFT -- OR THE TOP LEFT OF THIS
15:40 22 SLIDE BEING WHERE LAKE BORGNE IS?
15:40 23 A. YES. THIS IS ACTUALLY LAKE BORGNE, THE SOUTHERN LOBE OF
15:40 24 LAKE BORGNE. THIS IS A PROCTOR POINT OUT HERE.
15:40 25 THE COURT: IF YOU COULD JUST BE A LITTLE SLOWER
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1804
15:40 1 THERE, SIR, PLEASE, TO ORIENT HER.

15:40 2 THE WITNESS: THE DARK -- THE RED COLORS, WHICH ARE
15:40 3 LARGER WAVES, OCCUR IN THE WATER BODIES. THE POINT OF THIS
15:40 4 SLIDE -- THERE ARE TWO LOBES OF LAKE BORGNE THAT ACTUALLY COME
15:41 5 CLOSE TO THE MRGO, WHICH IS RUNNING HERE WHERE I'M SHOWING.
15:41 6 YOU'LL NOTICE, IN THE MARSH, WAVE HEIGHTS ARE MUCH LOWER, AND
15:41 7 THAT'S TO BE EXPECTED.
15:41 8 BUT ALONG THE RIGHT-OF-WAY OF THE MRGO CHANNEL,
15:41 9 WHAT WE ENCOUNTER IS WHAT I HAVE CALLED IN MY REPORT "BEADS,"
15:41 10 AND I'M TALKING ABOUT MY JANUARY 15 REPORT. THESE ARE PLACES
15:41 11 WHERE IT LOOKS LIKE THE WAVE HEIGHT IS GOING UP AND DOWN. THIS
15:41 12 IS REALLY JUST AN ARTIFACT OF TRYING TO PUT A DIAGONAL CHANNEL
15:41 13 INTO A SQUARE GRID WHERE THE CELLS ARE ABOUT THE SIZE OF THE
15:41 14 CHANNEL. SO YOU GET A MORAIS (PHONETIC) EFFECT THERE.
15:41 15 THE COURT: I DID READ THAT IN ONE OF YOUR REPORTS,
15:41 16 AND SEEING THE PICTURE HELPS ME UNDERSTAND IT A LITTLE BETTER.
15:42 17 BY MR. ROY:
15:42 18 Q. SO, DR. KEMP, TO BE CLEAR HERE, WHERE I'M POINTING, THESE
15:42 19 RED DOTS THAT OCCUR, THESE ARE RED DOTS REFLECTED IN THE
15:42 20 GOVERNMENT'S STWAVE THAT REFLECT WAVE HEIGHTS OF HOW HIGH ON
15:42 21 THE MRGO IN THAT TEST?
15:42 22 A. I BELIEVE IT'S AROUND 8 FEET. YOU KNOW, WE WOULD HAVE TO
15:42 23 LOOK AT THE -- THE MAXIMUM IS AROUND 8 FEET. OBVIOUSLY, THEY
15:42 24 ALSO REPORT 6 FEET AND 5 FEET BECAUSE IT'S GOING UP AND DOWN.
15:42 25 IF I WERE TRYING TO USE THIS FOR PASSING ALONG
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1805
15:42 1 INFORMATION TO THE LEVEE-FACE MODEL, I WOULD USE THE HIGHEST

15:42 2 NUMBERS THAT COME OUT OF THIS AS MY STARTUP WAVES BECAUSE
15:43 3 THEY'RE PROBABLY THE ONES THAT HAVE MORE OF THE CHANNEL IN
15:43 4 THEM. THE CELLS HAVE MORE OF THE CHANNEL IN THEM.
15:43 5 Q. NOW, YOUR WAVE FIGURES CALCULATED WITH SWAN AND THE
15:43 6 HIGH-RESOLUTION SWAN, HOW HIGH DID YOU TELL US THEY WERE?
15:43 7 A. BETWEEN 8 AND 9 FEET.
15:43 8 Q. NOW, HOW DO YOU KNOW YOUR WAVE FIGURES ARE RIGHT --
15:43 9 THE COURT: JUST TO GET A LOCATION, BETWEEN 8 AND
15:43 10 9 FEET WHERE, SIR?
15:43 11 THE WITNESS: THIS IS IN THE MRGO CHANNEL.
15:43 12 THE COURT: THIS WOULD BE, AS I WOULD CHARACTERIZE IT
15:43 13 HAVING TO DO WITH HIS TESTIMONY, AS THERE WAS T, D, AND L.
15:43 14 THIS WOULD BE D? DO YOU KNOW WHAT I'M TALKING ABOUT? YOU MAY
15:43 15 NOT HAVE SEEN THOSE EXHIBITS. THIS WOULD BE, BASICALLY, IN THE
15:43 16 MID LEVEL OF THE CHANNEL?
15:43 17 THE WITNESS: YES. I ONLY LOOK AT THE WAVE IN THE
15:43 18 MID LEVEL BECAUSE THAT'S REALLY WHAT WE PASS ALONG TO THE
15:43 19 NEXT --
15:43 20 THE COURT: RIGHT. I UNDERSTAND. I MAY HAVE
15:43 21 SOMETHING WRONG, MR. ROY, BUT THAT WOULD BE WHAT I WOULD
15:44 22 CONSIDER TO BE D, WHAT WE HAVE BEEN TALKING ABOUT IN THE
15:44 23 DIAGRAM --
15:44 24 MR. ROY: IT'S THE MID LEVEL OF THE CHANNEL WIDTH BUT
15:44 25 ALL ALONG REACH 2.
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1806
15:44 1 THE COURT: OH, I UNDERSTAND THAT.

15:44 2 BY MR. ROY:
15:44 3 Q. THAT'S CORRECT, DR. KEMP?
15:44 4 A. THE "D" IS ACTUALLY FOR "DEEP."
15:44 5 THE COURT: THAT'S WHAT I FIGURED.
15:44 6 BY MR. ROY:
15:44 7 Q. WELL, HOW DO YOU KNOW YOUR WAVE FIGURES PREDICTED AND
15:44 8 MODELED BY YOUR HIGH-RESOLUTION SWAN, ADDITIONAL TESTS AND
15:44 9 GRIDS THE GOVERNMENT DID NOT DO -- HOW DO YOU KNOW YOU AND THE
15:44 10 DUTCH ARE RIGHT AND THE GOVERNMENT IS WRONG?
15:44 11 A. WELL, I THINK, ACTUALLY, WE AND THE GOVERNMENT ARE NOT --
15:44 12 WE DON'T DIFFER TOO MUCH ON THIS, BUT I WILL SAY THAT BOTH --
15:44 13 DURING KATRINA, THERE WERE NO WAVE MEASUREMENTS IN LAKE BORGNE,
15:44 14 BUT THERE WERE WAVE MEASUREMENTS IN LAKE PONTCHARTRAIN, WHICH
15:44 15 IS RIGHT NEXT-DOOR.
15:44 16 Q. ALL RIGHT. WHAT YOU'RE TELLING US IS YOU VALIDATED YOUR
15:45 17 TESTING ONCE AGAIN BASED UPON ACTUAL REALITY IN ANOTHER
15:45 18 GEOGRAPHIC LOCATION WHERE THERE WAS REAL, HARD DATA AND YOU
15:45 19 SAID, "THIS IS WHAT WE ACTUALLY SAW, AND SO WE OUGHT TO SEE
15:45 20 SOMETHING SIMILAR TO THAT ALONG REACH 2." SO YOU LOOKED TO THE
15:45 21 LAKE PONTCHARTRAIN SOUTH SHORE REPORTED DATA DURING KATRINA.
15:45 22 RIGHT?
15:45 24 Q. LET'S PULL UP PAGE 30 AND 31 OF THE POWERPOINT, 30 FIRST.
15:45 25 IS THIS THE PAGE THAT CAN HELP YOU EXPLAIN THAT TO THE JUDGE?
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1807
15:45 1 A. SO THIS IS OUT OF THE IPET REPORT. THEY ACTUALLY -- AND

15:45 2 THIS IS -- BECAUSE WE HAVE SO LITTLE GOOD OBSERVATIONAL DATA
15:45 3 FROM KATRINA, IT WAS WONDERFUL THAT THEY DEPLOYED TWO SMALL
15:45 4 WAVE-RIDING BUOYS THAT WOULD ACTUALLY ALLOW YOU TO MEASURE
15:46 5 WAVES ALONG THE SOUTH SHORE OF LAKE PONTCHARTRAIN.
15:46 6 WHAT WE ARE SEEING ON THE TOP PANEL HERE IS THE WAVE
15:46 7 HEIGHT -- AND THIS IS TIME ALONG THE BOTTOM -- MEASURED BY TWO
15:46 8 BUOYS. THEY ARE GOING UP AND DOWN, AND THE BUOY -- AND THE
15:46 9 ACCELERATIONS ARE THEN CONVERTED INTO WAVE HEIGHT. ON THIS
15:46 10 RIGHT GRAPH, WE SEE THE PERIOD. SO THE PEAK WAVE HEIGHT HERE
15:46 11 IS AROUND 9 FEET, AND THE PEAK WAVE PERIOD HERE IS AROUND 6 1/2
15:46 12 TO 7.
15:46 13 SO WE ARE LOOKING FOR -- SINCE LAKE PONTCHARTRAIN IS
15:46 14 A SHALLOW LAKE, SIMILAR TO LAKE BORGNE, AND WE KNOW THE WAVES
15:46 15 ARE GENERATED INSIDE THE LAKE, WE WOULD EXPECT TO SEE SIMILAR
15:46 16 WAVES ALONG THE SOUTH SHORE OF LAKE BORGNE. EVEN THOUGH IT'S A
15:47 17 LITTLE CLOSER TO THE EYE, YOU MIGHT HAVE SOME HIGHER WINDS, BUT
15:47 18 THESE WAVES ARE ALL LIMITED BY DEPTH. SO WITH SIMILAR DEPTHS,
15:47 19 WE SHOULD SEE SIMILAR WAVES.
15:47 20 Q. LET'S PULL UP 32 OF OUR POWERPOINT, WHICH IS PX-91 AT
15:47 21 PAGE 97.
15:47 22 A. THIS IS ALSO FROM THE IPET REPORT. I'M SORRY. WE NEED TO
15:47 23 GO BACK ONE MORE.
15:47 24 THIS JUST SHOWS THAT WHEN THE CORPS RAN THEIR STWAVE
15:47 25 PROPERLY -- THAT IS, WITH A FULL PLANE, THAT IS, TO SEE
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1808
15:47 1 360 DEGREES -- THEY ACTUALLY WERE ABLE TO REPRODUCE THE -- THE
15:47 2 WAVE BUOYS WERE DOWN IN THIS AREA, AND WE ARE SEEING THE MODEL
15:47 3 PREDICTS 8-FOOT SEAS IN THIS AREA WITH A PERIOD OF 6 TO 7
15:47 4 SECONDS.
15:47 5 Q. ACTUALLY, THAT'S 8-FOOT OR BETTER WAVES, ISN'T IT?
15:47 6 A. THAT'S RIGHT, 8-FOOT OR HIGHER. BUT THE CONTOUR THAT'S
15:48 7 SHOWN THERE, I BELIEVE, IS 8-FOOT.
15:48 8 THE COURT: SO WHEN YOU SAY A FULL PLANE -- I'VE
15:48 9 NOTICED THAT IN THE REPORTS -- YOU MIGHT DESCRIBE FOR THE
15:48 10 RECORD WHAT A FULL PLANE IS. P-L-A-N-E.
15:48 11 THE WITNESS: YES. P-L-A-N-E. WHAT WE ARE TALKING
15:48 12 ABOUT THERE IS, IF WE DON'T KNOW THE DIRECTION THAT THE WAVES
15:48 13 ARE GOING TO COME FROM, THEN WE HAVE TO DO A MORE COMPREHENSIVE
15:48 14 ANALYSIS IN WHICH WE -- WHEN WE RUN THE WINDS OVER THE DOMAIN,
15:48 15 WE ALLOW WAVES TO BE GENERATED IN ALL DIRECTIONS. OKAY. SO WE
15:48 16 ARE NOT ASSUMING THAT WE ARE ONLY GOING TO LOOK AT WAVES COMING
15:48 17 FROM A CERTAIN DIRECTION.
15:48 18 IF WE HAVE ENOUGH INFORMATION ABOUT THE SYSTEM
15:48 19 THAT WE KNOW, FOR EXAMPLE, THAT -- LET'S SAY WE WERE MODELING
15:48 20 BEHIND AN INLET, AND WE KNEW THAT THE ONLY WAY THAT LARGE WAVES
15:48 21 COULD COME IN WAS THROUGH THE INLET, WE WOULD KNOW THE
15:48 22 DIRECTION THEY WERE COMING FROM, AND WE WOULD NOT HAVE TO
15:49 23 BOTHER WITH LOOKING AT WAVES GENERATED FROM ALL DIRECTIONS.
15:49 24 SO THIS IS THE WAY THEY DID IT HERE BECAUSE, IN
15:49 25 A HURRICANE WITH 90 MILE-AN-HOUR WINDS FLOWING AND CONSTANT
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1809
15:49 1 SHIFTING IN DIRECTION, WE CAN EXPECT TO SEE A VERY CONFUSED

15:49 2 SEA. THAT MEANS IT'S COMPUTATIONALLY MUCH MORE DIFFICULT, AND
15:49 3 THE MODEL RUNS TAKE LONGER. AGAIN, IT'S A MORE COMPREHENSIVE
15:49 4 APPROACH.
15:49 5 THE COURT: TO YOUR KNOWLEDGE, HAS A FULL-PLANE MODEL
15:49 6 BEEN DONE ON THE MRGO BY THE GOVERNMENT --
15:49 7 THE WITNESS: THE ANSWER IS YES, THEY MAY HAVE NOW.
15:49 8 THEY HAD NOT DONE IT, TO MY KNOWLEDGE, DURING IPET. THEY MADE
15:49 9 A HALF-PLANE MODEL DURING IPET.
15:49 10 THE COURT: DO YOUR FIGURES GENERALLY AGREE, THEN,
15:49 11 WHEN THEY USE A FULL-PLANE MODEL?
15:50 12 THE WITNESS: THAT'S CORRECT. SO WE ARE PRETTY MUCH
15:50 13 IN AGREEMENT NOW, NOW THAT THEY HAVE RUN IT IN THE FULL-PLANE
15:50 14 MODE.
15:50 15 THE COURT: SO WHERE ARE THE DIFFERENCES FOR THE
15:50 16 COURT? WHERE ARE THE DIFFERENCES VIS-À-VIS THE SWAN MODEL AND
15:50 17 WHATEVER MODEL THEY USED NOW, TO YOUR UNDERSTANDING, AS TO THE
15:50 18 WAVE FEATURES IMPACTING THE MRGO AND THE LEVEES ALONG THE MRGO?
15:50 19 THE WITNESS: WE ALREADY TALKED ABOUT THE RESOLUTION.
15:50 20 OKAY. WE HAVE MUCH BETTER RESOLUTION, SO WE CAN SAY --
15:50 21 THE COURT: THERE'S NO NEW RESOLUTION, JUST FULL
15:50 22 PLANE. I UNDERSTAND THAT.
15:50 23 THE WITNESS: RIGHT. NOW, THE OTHER FEATURE THAT WE
15:50 24 CAPTURE IS THAT WE ACTUALLY RAN THE SWAN OVERTOP OUR FINEL
15:50 25 SURFACE, WHICH WAS A LITTLE HIGHER THAN THEIR ADCIRC SURFACE.
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1810
15:50 1 THE COURT: ALL RIGHT. THEREFORE, BECAUSE OF THOSE

15:50 2 DIFFERENCES, DO YOU HAVE DIFFERENCES IN WAVE HEIGHT AND WAVE
15:51 3 FREQUENCY?
15:51 4 THE WITNESS: WE HAVE A DIFFERENCE IN WAVE HEIGHT OF
15:51 5 PERHAPS A FOOT, SIGNIFICANT WAVE HEIGHT AT THE PEAK.
15:51 6 THE COURT: YES.
15:51 7 THE WITNESS: WE HAVE VIRTUALLY NO DIFFERENCES IN
15:51 8 TERMS OF PERIOD. WE ARE SEEING PERIODS VERY SIMILAR TO WHAT
15:51 9 THEY ARE.
15:51 10 THE COURT: SO IS THERE ANY OTHER DISAGREEMENT THAT
15:51 11 WOULD BE RELEVANT TO THE ULTIMATE DETERMINATION AS TO HOW THOSE
15:51 12 WAVES AFFECTED THE LEVEES?
15:51 13 THE WITNESS: I WOULD SAY THE RESOLUTION THING IS NOT
15:51 14 TO BE OVERLOOKED BECAUSE WAVES ARE TRANSFORMING AS THEY COME
15:51 15 OUT OF LAKE BORGNE AND GO ACROSS THE MARSH AND THEN REBUILD.
15:51 16 WHEN THEY FIRST HIT THE AREA, IT MAY BE VERY SHALLOW, BUT
15:51 17 THERE'S NO VEGETATION. THEY START TO BUILD IMMEDIATELY THERE.
15:51 18 THEN, AS SOON AS THE BOTTOM DROPS OUT AND THEY BECOME DEEPWATER
15:52 19 WAVES, THEY VERY QUICKLY RISE IN HEIGHT. SO GETTING THAT
15:52 20 GEOMETRY RIGHT IS VERY IMPORTANT.
15:52 21 MR. ROY: YOUR HONOR, THAT'S EXACTLY WHAT THE NEXT
15:52 22 TOPIC IS. WE HAVE A FUNDAMENTAL DIFFERENCE WITH THE
15:52 23 GOVERNMENT'S EXPERTS ON THE NATURE AND EXTENT OF WAVE
15:52 24 REGENERATION OVER THE MRGO. WE SAY IT'S SUBSTANTIAL, AN AMOUNT
15:52 25 OF A NUMBER OF FEET; THEY SAY IT'S DIMINIMUS. SO THAT'S WHERE
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1811
15:52 1 WE ARE GOING NOW.

15:52 2 MR. ROY: COULD WE PULL UP PAGE 32 OF THE POWERPOINT,
15:52 3 PLEASE.
15:52 4 BY MR. ROY:
15:52 5 Q. NOW, DR. KEMP, THIS IS ANOTHER EXAMPLE OF THREE GRIDS OF
15:52 6 THE SWAN; IS THAT RIGHT?
15:52 7 A. THAT'S RIGHT. WE HAVE PIECES HERE OF THE M GRID AND THE
15:52 8 MORE DETAILED F AND G GRIDS. THEY'RE MERGED TOGETHER TO SHOW
15:53 9 THE EFFECT ALONG MRGO.
15:53 10 Q. USING THE SCALING ON THE RIGHT, CONFIRMED 7- TO 8-FOOT
15:53 11 WAVES, WITH A 4- TO 5-SECOND RANGE ON MRGO -- IS THAT RIGHT?
15:53 12 A. OKAY. LET ME FIRST -- THESE ARE AT DIFFERENT TIMES,
15:53 13 SEPARATED BY AN HOUR. SO IT'S 6:00, 7:00, 8:00, 9:00.
15:53 14 Q. FOR THE PURPOSE OF THE RECORD, DR. KEMP, LET'S START OVER
15:53 15 AGAIN. THE TOP LEFT IS WHAT TIME?
15:53 16 A. IT'S AT 6:00 ON AUGUST 29.
15:53 17 Q. WHICH ONE IS THE NEXT ONE YOU WANT TO GO TO, THE TOP
15:53 18 RIGHT?
15:53 19 A. THE TOP RIGHT.
15:53 20 Q. THE TOP RIGHT IS WHAT TIME?
15:53 21 A. IT'S AT 7:00.
15:53 22 Q. IN THE MORNING?
15:53 24 Q. THE NEXT ONE YOU WANT TO GO TO, BOTTOM LEFT?
15:53 25 A. THE BOTTOM LEFT IS VERY CLOSE TO PEAK, AND THAT'S AT 8:00.
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1812
15:53 1 Q. AND THE BOTTOM RIGHT?

15:53 2 A. IS AT 9:00.
15:53 3 Q. A.M. ON THE MORNING KATRINA HIT?
15:53 4 A. RIGHT. WHAT YOU SEE HERE IS YOU SEE ARROWS. THAT'S
15:53 5 DESIGNATING THE WIND DIRECTIONS. THEN YOU SEE DIFFERENT SHADES
15:54 6 THAT ARE DENOTED ON THIS SCALE. IN EACH CASE THE SCALE IS THE
15:54 7 SAME, EXTENDING UP TO IN EXCESS OF 9 FEET. THE BROWN IS
15:54 8 9 FEET; THE REDDISH COLOR -- THE RED COLOR IS BETWEEN 8 AND
15:54 9 9 FEET; AND THEN ORANGE IS BETWEEN 6 AND 7.
15:54 10 Q. LOOKING AT THE TOP LEFT, 6:00 A.M., APPROXIMATELY, THE DAY
15:54 11 HURRICANE KATRINA IMPACTED THIS AREA -- LOOKING AT THE TOP LEFT
15:54 12 OF THE SWAN MODEL, WHAT DOES IT SHOW AT 6:00 A.M. THE WAVE
15:54 13 HEIGHTS TO BE IN LAKE BORGNE?
15:54 14 A. I THINK WE CAN BLOW THAT UP THERE.
15:54 15 Q. IS THAT 8, 9 FEET IN PLACES?
15:54 16 A. IN LAKE BORGNE, WE ARE UP TO JUST UNDER 9 FEET IN HERE.
15:54 17 BUT IN THE MRGO CHANNEL, YOU CAN SEE THAT THE WETLANDS HERE ARE
15:55 18 KNOCKING THE WAVES DOWN, AND THEY'RE DOWN IN THE RANGE OF 4 TO
15:55 19 5 FEET HERE.
15:55 20 BUT UNDER THE EFFECTS OF THESE, IN THIS CASE,
15:55 21 PROBABLY ABOUT 70-MILE-AN-HOUR WINDS, YOU CAN SEE AS THE WAVES
15:55 22 CROSS INTO -- LEAVE THE WETLANDS AND GET INTO DEEPER WATER,
15:55 23 THEN THEY GROW AGAIN. IN THIS CASE THE TANNISH COLOR IS
15:55 24 BETWEEN 6 AND 7 FEET, AND THEN WE SEE PLACES IN HERE WHERE IT
15:55 25 HAS GOTTEN MORE RED. THAT'S BETWEEN 7 AND 8 FEET. SO BY
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1813
15:55 1 6:00 -- THAT'S ABOUT 2 1/2 HOURS BEFORE THE PEAK SURGE -- WE
15:55 2 HAVE 6- TO 7-FOOT WAVES IN THE MRGO CHANNEL, VERY SIMILAR TO
15:55 3 WHAT WE HAVE IN THE SOUTHERN PART OF LAKE BORGNE.
15:55 4 Q. SO WHAT WE ARE OBSERVING HERE AT 6:00 IN THE MORNING IS A
15:55 5 PHENOMENON THAT'S VERY SIMILAR TO WHAT WE SEE OFF THE BEACH,
15:56 6 AND THAT IS WHERE THERE'S A SANDBAR -- A DIFFERENT-PERIOD WAVE
15:56 7 PERHAPS, BUT THE WAVE IS COMING IN FROM OFFSHORE. IT GETS OVER
15:56 8 THE SANDBAR THAT'S MAYBE A FEW FEET DEEP, THE WAVE DROPS, AND
15:56 9 THEN IT COMES IN. OVER THE REMAINING FEW HUNDRED FEET TO
15:56 10 SHORE, IT POPS BACK UP WITH THE INTENSITY THAT IT HITS THE
15:56 11 SHORE. IS THAT THE REGENERATION CONCEPT YOU'RE TALKING ABOUT?
15:56 12 A. YES. THE ONLY THING THAT I WOULD ADD IS THAT THAT WILL
15:56 13 ONLY OCCUR IF THERE'S A STIFF WIND BLOWING BECAUSE THE
15:56 14 REGENERATING AGENT IS REALLY THE STRESS ASSOCIATED WITH THE
15:56 15 WIND.
15:56 16 Q. WELL, PUTTING IT DIFFERENTLY, BECAUSE THESE WAVES COMING
15:56 17 OFF OF LAKE BORGNE AT THAT TIME WERE LOCALLY GENERATED,
15:56 18 HIGH-ENERGY, LOW-PERIOD WAVES, THEY WOULD COME OVER THE
15:56 19 MARSH -- WHICH IS ANALOGOUS TO THAT SANDBAR?
15:56 20 A. IT IS.
15:56 21 Q. THEY WOULD DROP DOWN FROM THE 8- TO 9-FOOT RANGE DOWN INTO
15:56 22 THE 4-FOOT RANGE OR SO. THEN WHEN THEY HIT THE MRGO, BECAUSE
15:57 23 OF THE ENERGY, THE KINETIC ENERGY, THEY SPRING BACK UP --
15:57 25 Q. -- AND THEN RACE ACROSS THE CHANNEL AND HIT THE LEVEES.
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1814
15:57 1 RIGHT?
15:57 2 A. YEAH. I WOULD PUT IT A LITTLE DIFFERENTLY IF YOU WILL
15:57 3 INDULGE ME.
15:57 4 Q. ABSOLUTELY.
15:57 5 A. WHAT I SAY IS ALL ACROSS HERE WE HAVE, YOU KNOW, 70 TO
15:57 6 80-MILE-AN-HOUR WINDS. SO THERE'S A LOT OF ENERGY BEING PUT
15:57 7 INTO THE WATER ALL THROUGH HERE. WHAT CHANGES IS THE AMOUNT OF
15:57 8 RESISTANCE THAT THE WAVES FEEL ON THE BOTTOM. OKAY.
15:57 9 THE MARSH HAS A TREMENDOUS ENERGY DISSIPATION EFFECT;
15:57 10 WHICH, AS THE WAVE MOVES IN AWAY FROM THE MARSH ONTO,
15:57 11 ESSENTIALLY, A MUD FLAT -- OF COURSE, I'M SPEAKING A LITTLE BIT
15:57 12 FIGURATIVELY BECAUSE WE STILL HAVE PROBABLY 15 FEET OF WATER
15:57 13 OVER THE MARSH IN THIS CASE -- THE ENERGY DISSIPATION DROPS
15:58 14 OFF. THEN WHEN IT GETS INTO THE CHANNEL, ESSENTIALLY, IT'S A
15:58 15 FRICTIONLESS ENVIRONMENT, AND THE WAVE ENERGY -- IT BEGINS TO
15:58 16 JUST SUCK WAVE ENERGY OUT OF THE WIND AND REBUILD.
15:58 17 Q. THE BOTTOM LINE IS YOU'VE GOT WAVES AT 6:00 IN THE MORNING
15:58 18 IN THE MRGO REGENERATING UP TO THE 8-FOOT-OR-SO LEVEL IN MANY
15:58 19 PLACES SHOWN ON HERE, WHICH THEN ARE TRAVERSING AND GOING INTO
15:58 20 THE LEVEE?
15:58 21 A. THAT'S RIGHT. AT THAT POINT WE HAND THEM TO DR. BEA.
15:58 22 Q. NOW, LET'S GO TO THE 7:00 A.M., WHICH IS THE TOP RIGHT.
15:58 23 AT 7:00 WHAT DOES YOUR DETAILED SWAN SHOW TO BE -- LET ME MAKE
15:58 24 IT SIMPLE. IT SHOWS, BASICALLY, THE ENTIRE LENGTH OF THE MRGO
15:58 25 WITH 8-FOOT AND BIGGER WAVES; IS THAT RIGHT?
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1815

15:59 2 Q. DIRECTLY IMPACTING THE LEVEES ON REACH 2; IS THAT RIGHT?
15:59 3 A. THAT'S RIGHT. I SHOULD SAY, ALSO, WE HAVE PRETTY GOOD
15:59 4 SIZE WAVES IN THE GIWW, AS WELL, BETWEEN 6 AND 7 FEET.
15:59 5 Q. EVEN THEN, WITH THAT HIGH SURGE, WE ARE STILL SHOWING THE
15:59 6 WAVES COMING OVER LAKE BORGNE, FOLLOWING THE ARROWS OF THE
15:59 7 WIND, AND DROPPING DOWN TO THAT 5 1/2-FOOT RANGE, WHERE THE
15:59 8 YELLOW IS, TO THEN HIT THE MRGO AND SPRING BACK UP AND GO AT
15:59 9 THE LEVEES?
15:59 10 A. YEAH, THAT'S WHAT'S HAPPENING.
15:59 11 Q. IS THAT YOUR EXPERT OPINION?
15:59 12 A. THAT'S MY EXPERT OPINION, YES.
15:59 13 Q. THE SWAN HIGH-RESOLUTION TESTING CLEARLY PROVES
15:59 14 SIGNIFICANT WAVE REGENERATION OVER REACH 2 AT 6:00 A.M. LIKE
15:59 15 YOU TOLD US AND 7:00 A.M. LIKE YOU TOLD US; RIGHT?
16:00 16 A. IT'S BUILDING THAT WHOLE TIME.
16:00 17 Q. NOW, WE WILL SKIP THE THIRD -- WELL, THE THIRD, IT'S
16:00 18 VIRTUALLY ALL, ONCE AGAIN, 8- AND 9-FOOT WAVES; IS THAT
16:00 19 CORRECT?
16:00 20 A. YEAH. BUT I ALSO POINT OUT THAT IT'S HIGH IN THE GIWW
16:00 21 TOO.
16:00 22 Q. GOT YOU.
16:00 23 THE COURT: COUNSEL, NOT TO INTERRUPT YOU, BUT JUST
16:00 24 TO MAKE SURE WE GET ALL OUR COLORS RIGHT, I SEE ALL THE COLORS
16:00 25 CODED ON THE RIGHT EXCEPT WHITE, AND I DO SEE SOME WHITE; NOT
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1816
16:00 1 OFF TO THE SIDE, BUT I SEE WHITE BEHIND THE MRGO, ETC.
16:00 2 THE WITNESS: I CAN ADDRESS THAT IF YOU WOULD LIKE.
16:00 3 THE COURT: YES, SIR. IF YOU WOULD, PLEASE.
16:00 4 THE WITNESS: THE ONLY PLACE THERE AREN'T WAVES IS
16:00 5 WHERE THERE ISN'T WATER. FOR THE MOST PART, WE DON'T HAVE A
16:00 6 LOT OF WATER GOING OVER THE TOPS OF THESE LEVEES RIGHT NOW.
16:00 7 THE COURT: THIS IS AT --
16:00 8 THE WITNESS: THIS IS AT 8:00.
16:01 9 THE COURT: 8:00. THANK YOU.
16:01 10 BY MR. ROY:
16:01 11 Q. NOW, IN ESSENCE, THIS IS WHERE YOU HAND THIS INFORMATION
16:01 12 OFF TO DR. BEA, AND DR. BEA IS THEN ABLE TO EXPLAIN, WHEN YOU
16:01 13 HAVE THE REALITY OF THE PEAK SURGE SHOWN AT THE LOCK, WHY THAT
16:01 14 SLIDE IS STILL NOT SHOWING OVERTOPPING. THE ANSWER IS EARLIER
16:01 15 BREACHING; RIGHT?
16:01 16 A. THAT'S CORRECT, YES.
16:01 17 Q. THAT'S THE ONLY SCIENTIFIC ANSWER YOU'VE BEEN ABLE TO COME
16:01 18 UP WITH, WORKING WITH YOUR TEAM; RIGHT?
16:01 19 A. THAT'S WHAT WE HAVE BEEN -- WE HAVE TESTED ALL THE OTHER
16:01 20 POSSIBILITIES, AND THAT'S WHAT WE HAVE ARRIVED AT.
16:01 21 Q. THE CONCEPT OF WAVE REGENERATION HAS BEEN KNOWN BY THE
16:01 22 CORPS AT LEAST SINCE THEIR 1966 SHORE PROTECTION MANUAL --
16:01 23 WHICH IS IN EVIDENCE AS PX-2152, YOUR HONOR -- IS THAT CORRECT,
16:01 24 DR. KEMP?
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1817
16:02 1 Q. IF YOU KNOW WIND SPEED, DEPTH, AND THE FETCH, YOU CAN
16:02 2 PREDICT WAVE REGENERATION?
16:02 3 A. THAT'S RIGHT. AND TIME ALSO.
16:02 4 Q. NOW, LET'S TALK ABOUT THE WIDENING OF THE MRGO AT REACH 2.
16:02 5 MR. ROY: CAN YOU PULL UP PAGE 7 OF THE POWERPOINT,
16:02 6 CARL.
16:02 7 BY MR. ROY:
16:02 8 Q. YOU HAVE ACTUALLY, USING THE DATA YOU HAVE GATHERED AND
16:02 9 APPLYING YOUR PROFESSIONAL OPINIONS, YOUR EXPERT OPINIONS, AND
16:02 10 THOSE OF YOUR TEAM, DONE WHAT ILLUSTRATING HERE?
16:02 11 A. HERE I JUST -- THIS WAS A VERY SIMPLE EXERCISE WITH A MAP
16:02 12 OR A SATELLITE PHOTOGRAPH. EVERY THOUSAND FEET, I MEASURED THE
16:02 13 WIDTH BETWEEN THE VEGETATION ALONG THE MRGO, AND WHAT YOU SEE
16:02 14 ON THIS -- THIS IS THE MILES ALONG MRGO. MRGO ENDS IN THE IHNC
16:03 15 AT MILE 66, OR CLOSE TO THAT, AND THEN OUR LEVEE SYSTEM ENDS
16:03 16 AROUND 46 HERE.
16:03 17 SO FOR THAT PART, THE AXIS ON THE Y SIDE IS SHOWING
16:03 18 THE WIDTH, TOP WIDTH, OF THE -- IT'S REALLY THE DISTANCE
16:03 19 BETWEEN THE VEGETATION. WE HAVE HERE THE DESIGN TOP WIDTH,
16:03 20 650 FEET. THEN WE CAN COMPARE THAT AT ANY OF THESE POINTS WITH
16:03 21 THE TOP WIDTH OR THE AREA BETWEEN THE VEGETATION.
16:03 22 Q. DR. KEMP, LET'S BE MORE SPECIFIC IN USING AN EXAMPLE SO US
16:03 23 LAYMEN CAN UNDERSTAND. JUST TAKE, FOR EXAMPLE, AT ABOUT MILE
16:03 24 MARKER 47.
16:03 25 A. OKAY. THAT WOULD BE --
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1818
16:03 1 Q. ALL RIGHT. WALK US FROM THE BOTTOM UP AND TELL US WHAT IT
16:04 2 SHOWS, HOW WE WOULD USE THIS GRAPH.
16:04 3 A. I'M NOT VERY STEADY WITH THIS THING, BUT THAT WOULD BE
16:04 4 ABOUT MILE 57 -- 47 THERE, WHICH IS -- IT'S KIND OF CLOSE TO
16:04 5 THE END OF THE LEVEE SYSTEM.
16:04 6 IF I WENT UP THERE, I WOULD FIND, OKAY, I'VE GOT THE
16:04 7 DISTANCE BETWEEN THE VEGETATION IS ABOUT A LITTLE OVER
16:04 8 2,000 FEET. SO I CAN CONCLUDE THAT THE CHANNEL, AT LEAST THE
16:04 9 PART THAT'S FREE OF VEGETATION, HAS INCREASED FROM 650 FEET TO
16:04 10 2,000 FEET.
16:04 11 Q. WHAT ABOUT THE DOT RIGHT THERE, A LITTLE BIT CLOSER TO 46?
16:04 12 WHAT WOULD THAT REFLECT?
16:04 13 THE COURT: REMEMBER WHAT IT WAS, 46. IS THIS SIMPLY
16:04 14 A DEMONSTRATIVE EXHIBIT?
16:04 15 MR. ROY: YES, SIR. THAT'S ALL IT IS.
16:04 16 THE WITNESS: I MEAN, I THINK MANY PEOPLE UNDERSTAND
16:04 17 THAT THE MRGO HAS EXPANDED, AND THIS IS JUST AN EFFORT TO PUT
16:05 18 IT ON ONE GRAPHIC, MY EFFORT.
16:05 19 BY MR. ROY:
16:05 20 Q. USING PRIMARILY THE DATA AND THE SURVEY INFORMATION
16:05 21 EXTRACTED FROM THE GIS?
16:05 22 A. ACTUALLY, I DID IT MORE SIMPLY THAN THAT. I JUST SCALED
16:05 23 IT OFF WITH THE CALIPERS.
16:05 24 THE COURT: ALL RIGHT. SO THIS SIMPLY SHOWS, AS I
16:05 25 UNDERSTAND IT, THE DESIGN TOP WIDTH, AND THEN AT POINTS ALONG
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1819
16:05 1 THAT WIDTH IT IS JUST WIDENED AND THE AMOUNT OF WIDENING AND
16:05 2 WHERE IT TAKES PLACE. IS THAT --
16:05 3 THE WITNESS: THAT'S CORRECT. IT'S A VERY SIMPLE
16:05 4 THING. I SAID I DID IT EVERY THOUSAND FEET. I DIDN'T. IT'S
16:05 5 OBVIOUS I DID IT EVERY MILE. SO IT'S NOT AS FREQUENT AS THAT.
16:05 6 BY MR. ROY:
16:05 7 Q. IS THIS PART OF THE FIELD SCIENCE THAT YOU APPLY ROUTINELY
16:05 8 IN YOUR PROFESSIONAL AREA OF EXPERTISE -- NOT THE GRAPHIC BUT
16:05 9 MAKING THE MEASUREMENTS AND CORRELATING THEM -- AS PART OF AN
16:06 10 ATTEMPT TO UNDERSTAND A COMPREHENSIVE PROBLEM AND A
16:06 11 COMPREHENSIVE SOLUTION?
16:06 12 A. YES. THIS IS TRYING -- IT'S A MEASURE OF ENVIRONMENTAL
16:06 13 CHANGE IS WHAT IT IS.
16:06 14 Q. ALL RIGHT. NOW, LET'S GO BACK TO THE WAVES REGENERATING
16:06 15 AFTER THEY PASS THE SANDBAR AND TALK ABOUT SOMETHING ELSE. IS
16:06 16 THAT THE SAME CONCEPT, FROM AN ANALOGY STANDPOINT, THAT WHAT
16:06 17 HAPPENED, IF WAVES WERE COMING ACROSS, SAY, A LARGELY INLAND
16:06 18 LAKE OR AN ENCLOSED AREA SUCH AS BORGNE OR SOMETHING, IF THERE
16:06 19 WERE A BIG BORROW PIT A FEW HUNDRED FEET OR A FEW HUNDRED YARDS
16:06 20 OFF THE SHORE, THAT SUDDENLY IT'S DEEPER, WHERE STUFF HAS BEEN
16:06 21 EXCAVATED, WOULD YOU EXPECT, THEN, TO SEE A REGENERATION OF THE
16:06 22 WAVES, AT LEAST OVER THAT PIT?
16:06 23 A. YOU WOULD, AND YOU WOULD ALSO SEE THE WAVE CRESTS BEND
16:06 24 AROUND THAT PIT. THERE WOULD BE DEFRACTION. THAT'S A PRETTY
16:07 25 STANDARD PROBLEM THAT WE GIVE THE STUDENTS.
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1820
16:07 1 Q. SO TO TIE THE ENDS TOGETHER, IT'S YOUR OPINION THAT

16:07 2 HIGH-INTENSITY, SHORT-PERIOD, 7- TO 8-FOOT WAVES DESTROYED THE
16:07 3 REACH 2 LEVEES AND WERE A SIGNIFICANT CAUSE OF FLOODING OF
16:07 4 ST. BERNARD AND THE LOWER NINTH WARD; IS THAT RIGHT?
16:07 6 Q. DR. BEA CAN TELL US PRECISELY WHERE AND THE PRECISE
16:07 7 MECHANISM OF FAILURE; BUT SPEAKING FROM YOUR FIELD OF
16:07 8 EXPERTISE, THAT IS YOUR CONCLUSION?
16:07 10 Q. IT'S A TALE OF TWO LEVEES, ISN'T IT, DR. KEMP?
16:07 11 A. IT IS, INDEED.
16:07 12 MR. ROY: LET'S PULL UP OUR POWERPOINT 104.
16:07 13 BY MR. ROY:
16:07 14 Q. CAN YOU SHOW US WHY IT'S A TALE OF TWO LEVEES.
16:08 15 A. WELL, THIS IS FROM MY JULY REPORT, I GUESS. HERE, I AM
16:08 16 CIRCLING THE LEVEES THAT ARE JUST SOUTH OF THE LAKE BORGNE
16:08 17 LOBE, AND THEN I HAVE ALSO CIRCLED THE LEVEES THAT ARE AT
16:08 18 ALMOST A RIGHT ANGLE TO THAT, WHAT WE WOULD CALL THE VERRETT
16:08 19 RETURN.
16:08 20 AND, OF COURSE, THESE LEVEES HERE ARE IN A PERFECT
16:08 21 ALIGNMENT TO GET DIRECT IMPACT OF WAVES. THIS LEVEE IS
16:08 22 ORIENTED ESSENTIALLY PARALLEL TO THE DIRECTION OF THE WAVES.
16:08 23 FURTHERMORE, IT IS FRONTED BY WETLANDS; WHEREAS THIS ONE IS
16:08 24 FRONTED BY THE MRGO CHANNEL.
16:08 25 SO WE KNOW THAT THIS WHOLE LEVEE REACH WAS BUILT WITH
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1821
16:08 1 THE SAME MATERIALS AND SO ON, SO THAT'S NOT A VARIABLE AND --
16:08 2 Q. JUST TO BE CLEAR THERE, YOU'RE TALKING ABOUT ONLY THE AREA
16:09 3 OF THE VERRETT LEVEE RIGHT THERE THAT I'M SHOWING; RIGHT?
16:09 4 A. YES.
16:09 5 Q. AND THE PORTION GENERALLY, THE YELLOW CIRCLES, IF YOU
16:09 6 WILL, ON REACH 2, WHEN YOU TALK ABOUT YOUR UNDERSTANDING IS
16:09 7 BUILT FROM THE SAME TYPE OF MATERIAL?
16:09 8 A. THAT'S RIGHT. IT'S NOT A CONSTRUCTION DIFFERENCE.
16:09 9 Q. ALL RIGHT. WELL, OBSERVATIONALLY AND SCIENTIFICALLY, WERE
16:09 10 THERE ANY BREACHES IN THE VERRETT SECTION OF THE LEVEE?
16:09 11 A. NO.
16:09 12 Q. BUT THERE, OF COURSE, WERE MANY ALONG REACH 2; RIGHT?
16:09 13 A. THAT'S RIGHT, AND THIS IS JUST A PIECE OF THE PUZZLE.
16:09 14 Q. WERE THERE ANY BREACHES OF ANY SIGNIFICANCE ON THE
16:09 15 SOUTH-SIDE LPVS ALONG REACH 1?
16:09 16 A. NO, THERE WEREN'T. OF COURSE, THEY DIDN'T HAVE THE
16:09 17 SIGNIFICANT WAVE ATTACK THERE.
16:09 18 Q. BUT THEY DID OVERTOP?
16:09 19 A. OH, YES, THEY OVERTOPPED. THOSE WERE LOWER LEVEES.
16:09 20 Q. THE NORTH SIDE OF REACH 2, THOSE LPVS, I KNOW THAT THERE
16:10 21 WERE A FEW SMALL BREACHES IN THAT GENERAL AREA, BUT THERE WERE
16:10 22 NO SIGNIFICANT BREACHES; RIGHT?
16:10 23 A. THE ONLY BREACHES WERE ASSOCIATED WITH SOME SHEET-PILE
16:10 24 SECTIONS.
16:10 25 Q. THE OVERTOPPING ITSELF, ALBEIT PROLONGED, DID NOT DESTROY
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1822
16:10 1 THOSE LEVEES --

16:10 2 A. NO. THOSE EARTHEN LEVEES FAIRED QUITE WELL.
16:10 3 Q. THE DIFFERENCE IS WAVES?
16:10 4 A. THE DIFFERENCE IS WAVES AND WAVE DIRECTION.
16:10 5 Q. YOU BELIEVE YOU AND DR. VRIJLING'S TEAM AND DR. BEA HAVE
16:10 6 PROVEN THAT SCIENTIFICALLY?
16:10 7 A. I FEEL VERY CONFIDENT ABOUT THAT.
16:10 8 Q. WHY DID IT HAVE TO BE THE WAVES, IN YOUR PROFESSIONAL
16:10 9 OPINION, THAT DESTROYED THE REACH 2 LEVEES LIKE DR. BEA SAYS?
16:10 10 MR. ROY: LET'S PULL UP PAGE 77 OF THE POWERPOINT.
16:10 11 THE WITNESS: LET ME SAY SOMETHING. DR. BEA TALKED
16:10 12 ABOUT 35 PERCENT OF THE REACH 2 LEVEE WAS DESTROYED PRIMARILY
16:11 13 BY FRONT-SIDE WAVE ATTACK. ABOUT 45 PERCENT WAS DESTROYED BY
16:11 14 WAVE-INDUCED OVERTOPPING. SO WE HAVE TWO MECHANISMS INVOLVED
16:11 15 WITH WAVES HERE. BUT OVERTOPPING CAUSED BY WAVES AND
16:11 16 FRONT-SIDE EROSION CAUSED BY WAVES, THOSE ARE BOTH WAVE
16:11 17 PHENOMENA DIFFERENT FROM STRICTLY SURGE. SO THERE'S A TIMING
16:11 18 PROBLEM FOR THE THEORY THAT ALL THE LPV STRUCTURES ALONG
16:11 19 REACH 2 WERE DESTROYED SOLELY BY OVERTOPPING SURGE BECAUSE --
16:11 20 BY MR. SMITH:
16:11 21 Q. IS THAT THE THEORY OF THE DEFENSE, AS YOU UNDERSTAND IT?
16:11 22 A. AS I UNDERSTAND IT, IT'S PRIMARILY SURGE, BUT IT'S ALSO
16:11 23 SOME OVERTOPPING ASSOCIATED WITH WAVES BEFORE THE SURGE GETS
16:11 24 THERE.
16:12 25 Q. I DIDN'T MEAN TO INTERRUPT YOU. GO AHEAD.
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1823
16:12 1 A. WE HAVE, OF COURSE, A MECHANISM TO DESTROY THE WAVES LONG

16:12 2 BEFORE THE SURGE GETS TO THE TOP.
16:12 3 THE COURT: THIS MAY BE SOMETHING YOU'RE TALKING
16:12 4 ABOUT LATER, AND I HAVE READ YOUR REPORTS, BUT JUST TO
16:12 5 HIGHLIGHT THIS: IF THERE WERE ONLY OVERTOPPING AND NOT
16:12 6 DESTRUCTION, IN YOUR EXPERT OPINION, WOULD CHALMETTE FLOOD?
16:12 7 THE WITNESS: NO.
16:12 8 THE COURT: WHY?
16:12 9 THE WITNESS: ACTUALLY, WE MODELED THAT SITUATION IN
16:12 10 SOME DETAIL. THE 32,000-ACRE CENTRAL WETLANDS UNIT HAS A LOT
16:12 11 OF STORAGE CAPACITY. WITH OVERTOPPING, EVEN CONSIDERABLE
16:12 12 OVERTOPPING, OUR MODELING RESULTS SHOW THAT THE STORM WOULD
16:12 13 HAVE PASSED BEFORE THE 40 ARPENT LEVEE OVERTOPPED.
16:12 14 THE COURT: I DO A LOT OF THIS: (1) FOR THE RECORD;
16:12 15 (2) TO HELP ENLIGHTEN ME; AND (3) WHEN THE DEFENDANT'S EXPERTS
16:13 16 TESTIFY, I WILL HAVE A GOOD CALIBRATION TO KNOW WHERE TO GO.
16:13 17 BY MR. ROY:
16:13 18 Q. DR. KEMP, ST. BERNARD, IN YOUR OPINION, WAS FLOODED
16:13 19 PRIMARILY BY WATER COMING THROUGH THE REACH 2 LPV BREACHES
16:13 20 CAUSED BY WAVES ON THE FRONT SIDE OR AS YOU JUST DESCRIBED.
16:13 21 BUT IF THE BREACHES DID NOT OCCUR EARLY IN THE SURGE SEQUENCE,
16:13 22 YOU FILL IN THE BLANK: IT WAS NOT POSSIBLE TO FILL THE
16:13 23 32,000-ACRE CENTRAL WETLANDS, IS IT?
16:13 24 A. THAT'S RIGHT, AND I BELIEVE -- AND DR. VRIJLING'S SOBEK
16:13 25 MODEL SHOWS THAT. THE BREACHES OPEN UP BETWEEN 6:00 AND 8:00,
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1824
16:13 1 AND THEY HIT THE MARKS IN TERMS OF MAXIMUM SURGE ELEVATION AND
16:13 2 TIMING.
16:13 3 THE INTERESTING THING IS THAT STEVE FITZGERALD'S
16:13 4 HEC-RAS MODEL THERE -- THAT'S THE DEFENDANT'S FLOODING MODEL --
16:14 5 SHOWS ALMOST THE SAME THING. SO THE DIFFERENCE IS IN THE
16:14 6 TIMING OF THE PEAK SURGE. WE GET TO THE SAME RESULT IN
16:14 7 FLOODING WHILE KEEPING THE PEAK SURGE WHERE IT ACTUALLY WAS.
16:14 8 THEY GET THAT ONLY BY MOVING THE SURGE AHEAD ONE HOUR.
16:14 9 BY MR. ROY:
16:14 10 Q. BUT THAT'S NOT REALITY?
16:14 11 A. THAT'S NOT REALITY.
16:14 12 THE COURT: SO IF THE DEFENDANT'S EXPERTS ARE
16:14 13 RIGHT -- I KNOW YOU ADAMANTLY DISAGREE WITH IT -- ABOUT THE
16:14 14 PEAK SURGE, THEN OVERTOPPING COULD HAVE FLOODED ST. BERNARD?
16:14 15 THE WITNESS: ABSOLUTELY.
16:14 16 THE COURT: WHY IS THAT, JUST TO MAKE IT CLEAR? I'M
16:14 17 SURE THE DEFENSE EXPERTS WILL, BUT JUST TO --
16:14 18 THE WITNESS: I AM MAYBE NOT THE BEST PERSON TO ARGUE
16:14 19 THEIR CASE, BUT THE --
16:14 20 THE COURT: I KNOW THEY WILL BE READY TO DO IT. GO
16:14 21 AHEAD.
16:14 22 THE WITNESS: BUT IT IS POSSIBLE AND WE DO NOT
16:14 23 DISPUTE THAT IT IS POSSIBLE TO BREACH A LEVEE BY OVERTOPPING OF
16:15 24 SIGNIFICANT FLOW AND --
16:15 25 THE COURT: IT'S THE WHOLE MECHANISM, THE MECHANISM
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1825
16:15 1 OF FAILURE, OF THE LEVEE?

16:15 2 THE WITNESS: RIGHT. IT'S JUST WE DIDN'T SEE LOT OF
16:15 3 LEVEES DESTROYED LIKE THAT UNLESS THERE WAS STRONG WAVE
16:15 4 INFLUENCE.
16:15 5 THE COURT: THANK YOU, SIR. CAN YOU HOLD ON ONE
16:15 6 SECOND, MR. ROY?
16:15 7 MR. ROY: SURE.
16:15 8 BY MR. ROY:
16:15 9 Q. IT'S YOUR OPINION THE MRGO PROJECT CREATED A MORPHED
16:15 10 CHANNEL, IF YOU WILL, IN REACH 2 THAT EXPOSED THE FRESHWATER
16:15 11 SWAMPS AND MARSHES TO INCREASED SALINITY, ACCELERATING THEIR
16:15 12 CONVERSION TO OPEN WATER, REDUCING WETLAND, AND REDUCING THE
16:15 13 AMOUNT OF THE WAVE BUFFER BETWEEN LAKE BORGNE AND POPULATED
16:15 14 AREAS; RIGHT?
16:15 15 A. YES. AND THERE I'M TALKING ABOUT A MORE REGIONAL EFFECT
16:16 16 BECAUSE THE MRGO HAD A VERY LARGE EFFECT ON SALINITY OVER A
16:16 17 LARGE AREA AND, IN FACT, ALL THROUGH THE LAKE PONTCHARTRAIN
16:16 18 SYSTEM. SO WHAT THAT MEANT WAS THAT WETLANDS DEGRADED
16:16 19 EVERYWHERE IN THE CENTRAL WETLANDS AREA IN THE GOLDEN TRIANGLE,
16:16 20 AND THIS AFFECTED THE ABILITY OF THOSE WETLANDS TO REALLY
16:16 21 ATTENUATE BOTH SURGE AND WAVES AND PARTICULARLY --
16:16 22 PARTICULARLY -- CAUSED THE DEATH OF CYPRESS SWAMPS, WHICH ARE
16:16 23 ABSOLUTELY THE BEST PROTECTION AGAINST WAVES AND SURGE.
16:16 24 Q. EARLIER IN THIS TRIAL, DAY ONE, DR. GAGLIANO TESTIFIED AND
16:16 25 TOLD US FIVE REMEDIATION MEASURES HE TOLD THE CORPS DECADES AGO
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1826
16:17 1 WOULD HELP PREVENT THE PROBLEM AT REACH 2. YOU AND OTHER
16:17 2 EXPERTS FOR THE PLAINTIFFS' TEAM HAVE DESCRIBED THE NEED FOR
16:17 3 REMEDIATION TO BE DONE BY THE CORPS YEARS BEFORE KATRINA THAT
16:17 4 WAS NOT DONE THAT COULD HAVE EFFECTIVELY, DRAMATICALLY CHANGED
16:17 5 THE OUTCOME. AMONG THESE THINGS, DO YOU AGREE WITH
16:17 6 DR. GAGLIANO THAT THE FIRST ONE AND PERHAPS THE MOST IMPORTANT
16:17 7 WAS TO PREVENT SALTWATER INTRUSION, AVERTING SEVERE WETLAND
16:17 8 LOSS?
16:17 9 A. THAT WAS THE BIGGEST REGIONAL EFFECT THAT THEY --
16:17 10 REMEDIATION.
16:17 11 Q. DO YOU AGREE WITH DR. GAGLIANO THAT THE CORPS SHOULD HAVE
16:17 12 ARMORED BOTH BANKS OF REACH 2 AND THE LAKE BORGNE SHORELINES?
16:17 13 A. NO QUESTION.
16:17 14 Q. DO YOU AGREE WITH DR. GAGLIANO THE BENEFICIAL DEPOSITING
16:17 15 OF DREDGED SPOIL ON THE EAST BANK -- THAT'S THE LAKE BORGNE
16:17 16 BANK OF REACH 2 -- SHOULD HAVE BEEN DONE BY THE CORPS DECADES
16:17 17 AGO TO RESTORE THE LAND BRIDGE BETWEEN LAKE BORGNE AND REACH 2?
16:18 18 A. YES. WE SAW THAT WAS AN AVENUE FOR SURGE TRANSMISSION
16:18 19 BOTH SURGE AND WAVE TRANSMISSION.
16:18 20 Q. DO YOU AGREE, DR. GAGLIANO, THAT PLANTING TREES, SHRUBS,
16:18 21 AND GRASS ALONG THE REACH 2 CHANNEL AND THE TOE OF THE LPV
16:18 22 STRUCTURE, PLANTING GRASS ON BOTH SIDES OF THE CROWN OF THE LPV
16:18 23 STRUCTURE, TOO, SHOULD HAVE BEEN DONE TO REMEDIATE THE EFFECTS
16:18 24 OF THE MRGO CHANNEL?
16:18 25 A. ABSOLUTELY. AND, OF COURSE, DR. BEA HAS REALLY EXPLORED
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1827
16:18 1 THAT IN DETAIL.

16:18 2 Q. FIFTH, DO YOU AGREE WITH DR. GAGLIANO THAT REVEGETATION OF
16:18 3 THE CENTRAL WETLANDS UNIT, ALONG WITH THE PREVIOUS FOUR THINGS,
16:18 4 WOULD HAVE SIGNIFICANTLY LESSENED THE IMPACT OF KATRINA UPON
16:18 5 THE ROBINSON PLAINTIFFS?
16:18 6 A. IT WOULD HAVE PREVENTED FLOODING.
16:18 7 Q. YOUR TEAM'S WAVE DATA FOR REACH 2 WAS GIVEN TO DR. BEA
16:18 8 PRIMARILY FOR HIM, IN HIS CAPACITY AS A COASTAL ENGINEER, TO
16:18 9 COMPUTE THE EFFECTS OF WAVES SURGE AND SO FORTH ON THE REACH 2
16:18 10 LPV STRUCTURES; CORRECT?
16:19 11 A. YES. DR. BEA IS PROBABLY THE LEADING EXPERT ON EFFECTS OF
16:19 12 WAVES ON STRUCTURES, AND MY SOLE PURPOSE WAS TO DELIVER TO HIM
16:19 13 WAVES THAT I BELIEVED WERE RELIABLY SIMULATED, AND I FEEL
16:19 14 THAT'S WHAT WE DID.
16:19 15 I SHOULD SAY THAT WE RAN MANY, MANY SENSITIVITY TESTS
16:19 16 ON WAVES AND DIFFERENT KINDS OF WETLANDS AND SO ON TRYING TO
16:19 17 MAKE SURE WE WERE GETTING THE BEST RESULTS POSSIBLE.
16:19 18 Q. THE FINAL TESTING THAT YOUR TEAM DID MODELING, IF YOU
16:19 19 WILL, WAS THE SOBEK, WHICH IS ALSO KNOWN INTERNATIONALLY AS THE
16:19 20 DELFT 1D/2D MODEL PROGRAM; RIGHT?
16:19 21 A. ALL OF THESE COMMERCIAL VERSIONS COME ORIGINALLY OUT OF
16:19 22 DELFT UNIVERSITY.
16:19 23 Q. WHY IS SOBEK MODELING SO IMPORTANT?
16:19 24 A. WELL, THIS IS THE ONLY TIME, AFTER ALL THESE MODELS ARE
16:19 25 DONE, IN WHICH WE ACTUALLY PUT THE BREACHES THAT KATRINA
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1828
16:20 1 CAUSED. THIS IS REALITY INTRUDING ONCE AGAIN. SO FAR WE HAVE

16:20 2 BEEN IN MODEL WORLD. NOW WE ARE IN REALITY. WE HAVE BREACHES.
16:20 3 WE KNOW WHAT THE SURGE ELEVATION IS OUTSIDE THE BREACHES, AND
16:20 4 SO THEN WE CAN CONVEY THE WATER INTO THE CENTRAL WETLANDS AREA,
16:20 5 INTO NEW ORLEANS EAST, AND THEN OVER THE 40 ARPENT AREA, INTO
16:20 6 THE HOMES OF THE PLAINTIFFS.
16:20 7 Q. BEFORE WE GET INTO THE VARIOUS SCENARIOS OF THE MODELING,
16:20 8 WHICH WILL BE SOME DETAIL, LET ME JUST LAY A FOUNDATION.
16:20 9 WOULD YOU AGREE, SIR, THAT EACH MODELING SCENARIO IS
16:20 10 JUST ONE PIECE OF THE PUZZLE FOR YOUR TEAM TO FIGURE OUT?
16:20 11 A. THAT'S RIGHT. THIS IS, AS MR. STEVENS SAID, WE ARE
16:20 12 SHOWING OUR WORK. MR. BOURGEOIS MADE ELWOOD DO IT AND DR. BEA
16:21 13 IS MAKING ME DO IT.
16:21 14 Q. THE LAST MODEL, THE POLDER FLOODING MODEL, SOBEK, TELLS
16:21 15 THE TALE OF THE INCREMENTAL CONTRIBUTION OF MRGO AND THE
16:21 16 WIDENED MRGO TO THE FLOODING FOR EACH OF THE PLAINTIFFS; IS
16:21 18 THE COURT: THERE'S BEEN AN OBJECTION, MR. ROY. YOU
16:21 19 CAN'T SEE IT, BUT I CAN.
16:21 20 MR. ROY: OH, I'M SORRY.
16:21 21 MR. LEVINE: THIS WITNESS DOESN'T DISCUSS THE SOBEK
16:21 22 REPORT AND ITS RESULTS IN HIS EXPERT REPORT, SO I THINK IT'S
16:21 23 OUTSIDE THE SCOPE OF HIS EXPERT REPORT.
16:21 24 THE COURT: RESPONSE, MR. ROY.
25
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1829
16:21 1 THE WITNESS: ACTUALLY, YOUR HONOR, IF YOU LOOK AT

16:21 2 THE TABLE THAT WE PUT UP, YOU CAN SEE THAT THE SOBEK MODEL IS
16:21 3 LISTED THERE.
16:21 4 THE COURT: GO AHEAD, COUNSEL.
16:21 5 MR. LEVINE: BUT THE PARTICULAR RESULTS AREN'T
16:21 6 LISTED. IT MENTIONS IT IN A TABLE, BUT HE DOESN'T GET INTO THE
16:21 7 RESULTS FOR THE MODEL.
16:21 8 THE COURT: SO THE OBJECTION IS THAT HE IS RENDERING
16:22 9 AN OPINION THAT GOES BEYOND THE SCOPE OF HIS REPORT.
16:22 10 WHAT OPINION ARE YOU TRYING TO ELICIT?
16:22 11 MR. ROY: YOUR HONOR, THIS DOVETAILS STRAIGHT INTO
16:22 12 THE FIVE PRIMARY OPINIONS THAT WE STARTED HIS TESTIMONY WITH
16:22 13 TODAY. MOST SIGNIFICANTLY, HE IS THE HEAD OF THE TEAM. HE IS
16:22 14 THE COORDINATOR. HE IS THE ONE THROUGH WHICH THESE THINGS ARE
16:22 15 GOING. AT THE END OF THE DAY, HE IS GUIDING THEM AS TO THE
16:22 16 TEMPLATE THAT SHOULD OR SHOULD NOT BE DONE AND, I BELIEVE,
16:22 17 DIRECTED THAT THE POLDER TESTING BE DONE.
16:22 18 IN HIS REPORT HE MAY CALL IT POLDER MODELING,
16:22 19 BUT IT IS, IN FACT, SOBEK. THAT'S A FACT STATEMENT, NOT AN
16:22 20 EXPERT OPINION, WITH ALL DUE RESPECT.
16:22 21 THE COURT: YOU NEED TO MAYBE ESTABLISH THAT SINCE
16:22 22 THE POLDER MODELING IS IN HIS REPORT, THAT HE UTILIZES THE
16:22 23 POLDER MODELING IN HIS REPORT --
16:22 24 MR. ROY: YES, SIR. I THOUGHT WE COVERED THAT.
16:22 25 THE COURT: -- THAT HE DIRECTED THAT IT BE -- ARE YOU
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1830
16:22 1 SAYING THAT WE ARE GETTING INTO THE SOBEK MODEL AS OPPOSED TO
16:23 2 SOMETHING ELSE?
16:23 3 MR. ROY: IT'S THE POLDER MODELING. I WAS MERELY
16:23 4 ESTABLISHING THAT'S WHAT THE DUTCH USED.
16:23 5 THE COURT: I FORGOT THE QUESTION. TO BE HONEST WITH
16:23 6 YOU, I FORGET THE QUESTION TO WHICH THERE WAS AN OBJECTION, AND
16:23 7 I APOLOGIZE.
16:24 8 MR. ROY: I'LL COVER IT A LITTLE DIFFERENTLY,
16:24 9 YOUR HONOR. THAT'S FINE.
16:24 10 BY MR. ROY:
16:24 11 Q. DR. KEMP, ANYWHERE IN YOUR REPORTS DO YOU DISCUSS VARIOUS
16:24 12 SCENARIOS OF FLOODING THAT YOUR TEAM, INCLUDING THE DUTCH, RAN?
16:24 13 A. THAT'S PRIMARILY IN MY FIRST REPORT, THE JULY 27, 2007,
16:24 14 REPORT.
16:24 15 THE COURT: LET ME ASK YOU A QUESTION WITHOUT PUTTING
16:24 16 YOU ON THE SPOT. WE ARE GOING TO TRY TO GO TO 5:30 TODAY. I'M
16:24 17 NOT SURE YOU CAN FINISH THIS WITNESS, BUT DO WE HAVE A SHOT?
16:24 18 NO PRESSURE ON YOU.
16:24 19 MR. ROY: IT'S GOING TO BE CLOSE, BUT WE MIGHT.
16:24 20 THE COURT: WE'LL TAKE A QUICK -- IT WILL BE OUR LAST
16:24 21 RECESS OF THE DAY UNTIL ADJOURNMENT. WE WILL BE BACK IN TEN
16:24 22 MINUTES.
16:25 24 (WHEREUPON THE COURT TOOK A BRIEF RECESS.)
16:37 25 THE DEPUTY CLERK: ALL RISE, PLEASE.
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1831

16:38 2 THE COURT: YES, SIR. YOU MIGHT WANT, FOR THE
16:38 3 RECORD, TO TELL US WHERE WE ARE MOVING TO NOW.
16:38 4 MR. ROY: WE ARE MOVING. WE ARE NOT SINKING; WE ARE
16:38 5 SWIMMING. THERE IS FORWARD PROGRESS.
16:38 6 YOUR HONOR, HOUSEKEEPING. EARLIER WHEN I
16:38 7 REFERRED TO THE SHORE PROTECTION MANUAL, I BELIEVE I SAID IT
16:38 8 WAS PX-2152. THAT, IN FACT, IS DR. KEMP'S REPORT OF
16:38 9 JANUARY 29, I BELIEVE OF '07. THE ACTUAL SHORE PROTECTION
16:38 10 MANUAL IS PX-65.
16:38 11 THE COURT: THE SHORE PROTECTION MANUAL IS 65 AND
16:38 12 2152 IS THE JANUARY '07--
16:38 13 MR. ROY: THAT'S THE REPORT, BUT 65 --
16:39 14 THE COURT: I UNDERSTAND. THE OTHER ONE IS THE
16:39 15 REPORT.
16:39 16 MR. ROY: ALSO, DURING THE BREAK, PAGE 71 OF PX-91 IS
16:39 17 A TABLE. WE HAVE GOT IT AS A POWERPOINT SLIDE THAT'S IN THIS
16:39 18 DEAL. IT SHOWS ALL OF THE DIFFERENT TESTING MODELS THAT
16:39 19 DR. KEMP USED, INVOLVED, COORDINATED. SOBEK IS CLEARLY LISTED
16:39 20 AS ONE OF THEM. ADDITIONALLY, ALL OF THE SCENARIOS ARE LAID
16:39 21 OUT -- I SAY ALL OF THEM -- A GREAT NUMBER OF THEM ARE LAID OUT
16:39 22 IN EXCRUCIATING DETAIL IN CHAPTER 6 OF PX-91, WHICH INCLUDE THE
16:39 23 POLDER MODEL.
16:39 24 MR. LEVINE: I GUESS THIS RELATES TO MY EARLIER
16:39 25 OBJECTION RELATING TO THE SOBEK. HE LISTS IT THERE AS A MODEL
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1832
16:39 1 THAT WAS USED, BUT HE DOESN'T REALLY EVER PRODUCE ANY RESULTS
16:39 2 FROM THE MODEL IN HIS EXPERT REPORT.
16:39 3 THE COURT: WELL, I DON'T KNOW IF HE DOES OR NOT.
16:39 4 MR. ROY: IT SOUNDS LIKE CROSS-EXAMINATION MATERIAL.
16:39 5 THE COURT: YOU CAN ASK HIM WHAT UTILIZATION HE MADE
16:40 6 OF SOBEK. I'LL ALLOW THAT AND WE'LL GO FROM THERE. FEEL FREE
16:40 7 TO OBJECT AGAIN.
16:40 8 BY MR. ROY:
16:40 9 Q. SO, DR. KEMP, YOU HAVE AN ENTIRE CHAPTER IN YOUR REPORT
16:40 10 ADDRESSING POLDER MODEL SCENARIOS, IF YOU WILL; RIGHT?
16:40 11 A. WE HAVE AN ANALYTICAL SCHEME IN WHICH WE HAVE CERTAIN
16:40 12 SCENARIOS LISTED. THOSE SCENARIOS ARE RUN IN A VARIETY OF
16:40 13 MODELS, INCLUDING THE POLDER MODEL. THE PLACE WHERE WE TALK
16:40 14 THE MOST ABOUT POLDER MODELING IS IN MY JULY 28, 2007 REPORT
16:40 15 THAT WAS VERY EARLY IN THIS EFFORT.
16:40 16 THE ANALYTICAL SCHEME CALLED FOR ME TO HAND THE WAVES
16:41 17 AND SURGE INFORMATION OFF TO BOB BEA AT THE MIDPOINT OF THE
16:41 18 MRGO CHANNEL, WHEREUPON HE WOULD THEN COME UP WITH THE TIMING
16:41 19 AND CAUSATION OF BREACHING. THEN HE WOULD HAND THAT
16:41 20 INFORMATION BACK TO ME, AND I WOULD TRANSMIT IT TO THE DUTCH.
16:41 21 DR. VRIJLING THEN RAN THE POLDER MODEL, AND I THINK HE HAS
16:41 22 DESCRIBED IT IN CONSIDERABLE DETAIL. IT IS THE FINAL PHASE IN
16:41 23 OUR ANALYTICAL APPROACH. ACTUALLY, IN MY JULY REPORT, MY MOST
16:41 24 RECENT ONE --
16:41 25 MR. ROY: PX-91.
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1833
16:41 1 THE COURT: 91.

16:41 2 THE WITNESS: -- I DO NOT HAVE A LOT OF DISCUSSION OF
16:41 3 THE RESULTS IN THE POLDER MODEL. THAT WAS MORE A PROBLEM OF
16:42 4 NOT HAVING ENOUGH TIME THAN ANYTHING ELSE.
16:42 5 BY MR. ROY:
16:42 6 Q. IT'S BEEN A SUBJECT OF DISCUSSION -- A THEME, AT LEAST --
16:42 7 IN YOUR REPORTS?
16:42 9 Q. IT'S CERTAINLY BEEN A THEME OF THE COORDINATION PROCESS
16:42 10 THAT YOU ARTICULATED AMONG THE EXPERTS?
16:42 12 Q. NOW, WITH THAT IN MIND, IN PX-91, CHAPTER 6, YOUR MOST
16:42 13 RECENT REPORT, DO YOU TALK ABOUT A SCENARIO 1?
16:42 14 A. YES, I DO.
16:42 15 Q. SCENARIO 1 IS THE HYDROLOGIC SITUATION AS IT WAS DURING
16:42 16 KATRINA AFTER, AT LEAST, 30 YEARS OF NONMITIGATION?
16:42 17 A. THAT'S RIGHT. WITH THE EXCEPTION THAT IT DOES NOT INCLUDE
16:42 18 BREACHING.
16:42 19 THE COURT: JUST ONE MINUTE, PLEASE.
16:42 20 NEVER MIND. GO AHEAD, SIR.
16:43 21 BY MR. ROY:
16:43 22 Q. WHY SCENARIO 2C?
16:43 23 A. WELL, AS FAR AS I CAN TELL, THE FUNDAMENTAL ASSUMPTION OF
16:43 24 THE CORPS THROUGHOUT THIS, FROM 19 -- WELL, REALLY FROM THE
16:43 25 TIME THAT THE MRGO WAS BUILT WAS THAT THIS CHANNEL WAS OF NO
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1834
16:43 1 HYDROLOGIC CONSEQUENCE WHATSOEVER WITH RESPECT TO THE FLOOD

16:43 2 PROTECTION SYSTEM, AND SO IT MIGHT AS WELL HAVE BEEN BUILT IN
16:43 3 ALABAMA OR FLORIDA OR SOMEPLACE LIKE THAT.
16:43 4 THE ONLY WAY THAT I KNOW TO SIMULATE THAT CONDITION
16:43 5 IS TO ACTUALLY TAKE THE -- RESTORE THE GEOMETRY TO A CONDITION
16:43 6 WHICH THE CHANNEL IS NOT PRESENT. NOW, THAT'S NOT THE SAME
16:43 7 THING -- I MEAN, THAT'S NOT THE SAME THING AS A REMEDIATED OR
16:43 8 MITIGATED MRGO FROM THE STANDPOINT OF ACTUALLY PUTTING THE
16:43 9 STRUCTURES IN AND WAVE BUFFERS AND THINGS LIKE THAT, BUT FROM A
16:44 10 NUMERICAL STANDPOINT, IT IS A GOOD STARTING POINT.
16:44 11 Q. WHY SCENARIO 3? AND WE'LL TIE THEM BACK TOGETHER.
16:44 12 A. SCENARIO 3 TAKES US BACK TO THE TIME WHEN THE MRGO WAS
16:44 13 BEING DREDGED. IT TESTS THE ORIGINAL ASSUMPTION OF THE CORPS,
16:44 14 THAT IS, THAT IT COULD HAVE BEEN IN FLORIDA OR ALABAMA. HERE
16:44 15 WE PUT IT IN AND WE SEE WHETHER IT HAS A HYDRAULIC EFFECT THAT
16:44 16 IS OF INTEREST OR WITH RESPECT TO THE FLOOD PROTECTION
16:44 17 STRUCTURES.
16:44 18 Q. SCENARIO 3 WAS YOUR PRIMARY CONFIRMATORY DEVICE OF THE
16:44 19 BRETSCHNEIDER AND COLLINS SCIENTIFIC WORK IN 1966?
16:44 20 A. THAT'S RIGHT. AS I SAID, WE WERE TRYING TO FOLLOW IN
16:44 21 THEIR FOOTSTEPS, ESSENTIALLY. THEY OUTLINED A GOOD THEORETICAL
16:45 22 APPROACH, AND WE REPLICATED THAT USING MODERN TECHNIQUES.
16:45 23 Q. LIKE BRETSCHNEIDER AND COLLINS DID IN THEIR DIFFERENT
16:45 24 SCENARIOS -- OR NOT "LIKE" -- IN ANALOGOUS FASHION, THE ONLY
16:45 25 WAY FOR YOU TO TEST THE CORPS' POSITION THROUGHOUT THE DECADES
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1835
16:45 1 THERE'S NO FUNNEL WAS TO REMOVE THE MRGO?

16:45 3 Q. HYDROLOGICALLY REMOVE IT?
16:45 4 A. THAT WAS OUR ANALYTICAL APPROACH.
16:45 5 Q. AND THEN COME BACK IN AND PUT IT BACK IN AND SHOW THE
16:45 6 HYDROLOGIC DIFFERENCE?
16:45 8 Q. AS TIME PROGRESSED AT EACH OF THE BENCHMARK DATES WE HAVE
16:45 9 DISCUSSED SINCE 1965, FROM AN OCEANOGRAPHER/COASTAL GEOLOGIST
16:46 10 STANDPOINT, CAN YOU THINK OF ANY -- ANY -- REASON THAT A
16:46 11 PRUDENT OCEANOGRAPHER/COASTAL GEOLOGIST SUCH AS YOURSELF WOULD
16:46 12 NOT HAVE WARNED THE CORPS -- WITHIN THE CORPS -- AND RECOGNIZED
16:46 13 THE ISSUE OF THE FUNNEL, ESPECIALLY AS ENHANCED AND AGGRAVATED
16:46 14 BY THE INCREASED DEPTH AND WIDTH AT REACH 2 AND EVEN REACH 1?
16:46 15 A. I CAN'T.
16:46 16 Q. TO FAIL TO ACT WOULD BE TO FAIL IN YOUR DUTY AS A PRUDENT
16:46 17 OCEANOGRAPHER/GEOLOGIST, UNDER THOSE CIRCUMSTANCES, IF YOU WERE
16:46 18 WITH THE CORPS?
16:46 19 A. THAT'S CORRECT. I THINK THE ONLY THING HOLDING ME BACK
16:46 20 WOULD BE LOOKING AT WHAT HAPPENED WHEN OTHER PEOPLE DID.
16:47 21 Q. NOW, TO REALLY GET INTO THE ULTIMATE EFFECT OF THE FUNNEL,
16:47 22 YOU HAVE TO LOOK AT REACH 1 AND THE IHNC, AND YOU ACTUALLY USED
16:47 23 FINEL TO CALCULATE THE REACH 1 DISCHARGE VELOCITY AND WATER
16:47 24 LEVEL FOR EACH OF THE KEY SCENARIOS; IS THAT RIGHT?
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1836
16:47 1 MR. ROY: COULD YOU PULL UP POWERPOINT PAGE 55,

16:47 2 PLEASE.
16:47 3 BY MR. ROY:
16:47 4 Q. THIS IS FROM YOUR REPORT IN PX-91, PAGE 111. NOW, USING
16:47 5 THAT LASER POINTER, I WOULD LIKE FOR YOU TO SHOW THE COURT WHAT
16:47 6 WE HAVE, IN TERMS OF CONTRIBUTION TO VOLUME AND VELOCITY,
16:47 7 COMING OUT OF THE REACH 2 AND THEN THE PARIS ROAD BRIDGE AND
16:47 8 THEN ON, AND FINALLY TALK ABOUT THE OUTFLOW.
16:48 9 A. YEAH. WHEN WE LOOK AT VELOCITY AS OPPOSED TO SURGE
16:48 10 HEIGHT -- AND THIS IS AT 8:00, AND YOU CAN SEE UP IN HERE THIS
16:48 11 IS CLOSE TO PEAK SURGE. THIS IS THE REACH 2 CHANNEL COMING IN.
16:48 12 REACH 1. THIS IS THE LOCK MASTER IS DOWN HERE. THEN YOU SEE,
16:48 13 GOING UP TOWARDS LAKE PONTCHARTRAIN, THE IHNC.
16:48 14 THE BOTTOM DIAGRAM HERE IS JUST A BLOW-UP OF THIS
16:48 15 SECTION OF THAT CHANNEL, SHOWING SOME OVERTOPPING OF LOWER
16:48 16 LEVEES. THESE LEVEES IN THE MODEL ARE VERY DURABLE LEVEES.
16:48 17 THEY STAY THERE, BUT THEY GET OVERTOPPED AT PEAK SURGE. SO
16:48 18 WHAT YOU SEE IS, REALLY, FROM HERE ON IS ONE RIVER FLOWING FROM
16:48 19 THE REACH 2, INTO REACH 1, AND THEN OUT THE IHNC.
16:49 20 ONE OF THE MAIN REASONS WE USE FINEL IS BECAUSE WE
16:49 21 WANTED TO GET THE GEOMETRY OF THIS VERY NARROW AND CONSTRICTED
16:49 22 NORTH END OF THE IHNC. THAT'S GOT ALL THESE BRIDGES ACROSS IT
16:49 23 AND RAILROAD BRIDGES, SO IT'S GOT A MYRIAD OF OBSTRUCTIONS IN
16:49 24 IT. IT'S NOT ALL THAT CLEAR ON THE OVERHEAD, BUT IF YOU LOOK
16:49 25 CLOSELY, YOU CAN SEE THE VELOCITIES IN THAT NORTHERN REACH OF
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1837
16:49 1 THE IHNC ARE IN EXCESS OF 11, 12 FEET PER SECOND, SO --

16:49 2 THE COURT: THAT WOULD BE THE RED NEAR THE CENTER;
16:49 3 CORRECT?
16:49 5 THE COURT: I CAN SEE IT BETTER ON MINE.
16:49 6 THE WITNESS: SO WHAT WE HAVE GOT IS A SITUATION
16:49 7 WHERE WE ARE PUTTING A FIREHOSE INTO A VERY NARROW SYSTEM, AND
16:49 8 THE MOST CONSTRICTED SPOT IS GOING UP TOWARDS
16:49 9 LAKE PONTCHARTRAIN, WHICH, OF COURSE, IS LOWER AT THIS TIME.
16:50 10 SO THE WATER IS HAVING SOME TROUBLE GETTING OUT
16:50 11 OF THE -- SO IT'S COMING IN VERY FAST, AND WITH THAT
16:50 12 CONTRIBUTION IS LARGELY -- A LOT OF THAT WATER IS COMING RIGHT
16:50 13 OUT OF THE REACH 2 CHANNEL, AND WE SEE SOME VERY HIGH
16:50 14 VELOCITIES AROUND THE PARIS ROAD BRIDGE. THOSE ARE ON THE
16:50 15 ORDER OF 7 TO 8 FEET PER SECOND.
16:50 16 BY MR. ROY:
16:50 17 Q. DISCHARGE THROUGH REACH 1 IS SIGNIFICANTLY AFFECTED AND
16:50 18 VERY SENSITIVE TO DIFFERENCES IN THE DEPTH AND WIDTH OF
16:50 19 REACH 1; IS THAT NOT RIGHT?
16:50 20 A. IT CERTAINLY IS.
16:50 21 MR. ROY: LET'S GO TO PAGE 7 OF THE POWERPOINT.
16:50 22 BY MR. ROY:
16:50 23 Q. NOW, AT THE POINT RIGHT IN THAT AREA, THAT'S THE PARIS
16:50 24 BRIDGE, RIGHT HERE?
16:50 25 A. THAT'S RIGHT. WE PUT A CROSS-SECTION RIGHT THERE.
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1838
16:50 1 Q. NOW, IS THAT WHERE YOU ACTUALLY MODELED, USING FINEL, THE
16:51 2 FLOW RATE AND VOLUME?
16:51 3 A. THAT'S CORRECT. THAT'S ONE OF THE ADVANTAGES OF HAVING A
16:51 4 FULL-CIRCULATION MODEL. WE CAN LOOK AT NOT JUST STAGE HEIGHT,
16:51 5 WE CAN ALSO LOOK AT DISCHARGE IN THE CHANNELS, ALSO DISCHARGE
16:51 6 OVER THE LOW-LYING LEVEES ON EITHER SIDE.
16:51 7 Q. WHICH FULL-CIRCULATION MODEL DID THE GOVERNMENT USE?
16:51 8 A. ADCIRC MODEL IS QUITE CAPABLE OF DOING THE SAME THINGS.
16:51 9 Q. ALL RIGHT. SO, LOOKING AT THIS, FOR EXAMPLE, SURGE
16:51 10 ELEVATION, IN YOUR OPINION, WHEN YOU CROWD WATER INTO A NARROW,
16:51 11 RESTRICTED CHANNEL, SURGE ELEVATION IS NOT A SENSITIVE
16:51 12 INDICATOR. VOLUME IS FAR MORE IMPORTANT THAN SURGE HEIGHT. IS
16:52 13 THAT RIGHT?
16:52 14 A. WELL, IN THIS PARTICULAR CASE --
16:52 15 Q. REACH 1?
16:52 16 A. YES, THAT'S RIGHT. AND THAT IS BECAUSE, REMEMBER, THE
16:52 17 WALLS OF THIS BATHTUB ARE NOT CHANGING AS THE WATER COMES UP.
16:52 18 SO IF ALL YOU'RE LOOKING AT IS THE PEAK WATER LEVEL, YOU'LL
16:52 19 FIND OUT THAT AFTER A WHILE IT GIVES YOU A VERY GOOD READING ON
16:52 20 WHAT THE AVERAGE ELEVATION OF THE LEVEES IS. IF YOU LOOK AT
16:52 21 THE DISCHARGE, YOU WILL FIND THAT THAT'S VERY SENSITIVE.
16:52 22 THIS IS A LITTLE BIT COMPLICATED, BUT WE HAVE TIME
16:52 23 HERE IN THE FIRST COLUMN AT HOURLY INTERVALS, STARTING AT
16:52 24 4:00 IN THE MORNING AND GOING TO 9:00. I'VE HIGHLIGHTED THE
16:52 25 8:00 PERIOD.
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1839
16:52 1 THE FIRST THREE COLUMNS HERE ARE DISCHARGE AT THAT

16:52 2 CROSS-SECTION, PARIS ROAD CROSS-SECTION, IN CUBIC FEET PER
16:52 3 SECOND. WHAT WE SEE IS, FOR THE SCENARIO 1 SITUATION, WE HAVE
16:53 4 430,000 CUBIC FEET PER SECOND. THAT'S PRETTY MUCH EQUIVALENT
16:53 5 TO THE BASE FLOW OF THE MISSISSIPPI RIVER.
16:53 6 Q. GOING THROUGH REACH 1?
16:53 7 A. GOING THROUGH REACH 1.
16:53 8 THEN IF THAT CHANNEL IS PUT BACK TO WHAT ITS
16:53 9 AUTHORIZED DIMENSIONS ARE, THAT IS, THE REACH 1 CHANNEL IS
16:53 10 RETURNED TO ITS AUTHORIZED DIMENSIONS, WE HAVE A DISCHARGE THAT
16:53 11 IS ABOUT 80,000 CUBIC FEET PER SECOND LESS AT THAT TIME AND --
16:53 12 Q. THAT'S SCENARIO 3?
16:53 13 A. THAT'S SCENARIO 3, YES.
16:53 14 Q. SO THAT'S 354,000; RIGHT?
16:53 15 A. VERY GOOD. VERY GOOD.
16:53 16 Q. LET ME BACK UP. SCENARIO 2C, IF THE CORPS HAD COME IN AND
16:53 17 FULLY REMEDIATED AND PUT THE CHANNEL TO THE SIZE, WITH A
16:53 18 NEUTRAL HYDROLOGIC EFFECT, THEN IT'S GOING TO DROP IT TO
16:54 19 157,000; RIGHT?
16:54 20 A. THAT'S WHAT THIS NUMBER HERE -- IT'S A THIRD OF THE
16:54 21 DISCHARGE OF THE SCENARIO 1.
16:54 22 THE COURT: NOW, ARE YOU SAYING 2C PUT THE CHANNEL IN
16:54 23 WITH A NEUTRAL HYDROLOGIC -- DID I UNDERSTAND YOU RIGHT?
16:54 24 BY MR. ROY:
16:54 25 Q. 2C, DR. KEMP -- CORRECT ME IF I'M WRONG. I KNOW YOU
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1840
16:54 1 WILL -- 2C IS A HYDROLOGICALLY NEUTRAL MRGO; IS THAT RIGHT?

16:54 2 A. YES.
16:54 3 THE COURT: WELL, MY UNDERSTANDING IS IT WAS SO
16:54 4 NEUTRAL IT WASN'T IN THE SCENARIO.
16:54 5 THE WITNESS: OKAY. THIS WOULD BE A SITUATION IN
16:54 6 WHICH THERE WAS OBVIOUSLY SOME KIND OF SURGE GATE --
16:54 7 THE COURT: THAT'S MY UNDERSTANDING.
16:54 8 THE WITNESS: YEAH.
16:54 9 THE COURT: WE ARE TALKING ABOUT SCENARIO 2C BEING --
16:54 10 THE SURGE GATE NEUTRALIZES THE MRGO AS IF IT WEREN'T THERE
16:54 11 VIS-À-VIS REACH 1. I UNDERSTAND.
16:55 12 MR. ROY: THAT'S CORRECT.
16:55 13 THE WITNESS: THAT'S EXACTLY IT. I DIDN'T SPECIFY
16:55 14 WHETHER IT HAS A SURGE GATE OR NOT, BUT SOME WAY WE GET TO THAT
16:55 15 POINT.
16:55 16 BY MR. ROY:
16:55 17 Q. BUT UNDER SCENARIO 3, EVEN, NO BREACHING OCCURS ANYWHERE
16:55 18 AROUND NEW ORLEANS EAST LPV, AND OVERTOPPING IS OVER THE CITRUS
16:55 19 BACK LEVEE AT A REDUCED RATE, REDUCED BY ABOUT 30 PERCENT UNDER
16:55 20 SCENARIO 3?
16:55 22 Q. IS THAT SIGNIFICANT, IN YOUR PROFESSIONAL OPINION?
16:55 23 A. WELL, IT IS SIGNIFICANT BECAUSE, ALSO, THE BREACHING THAT
16:55 24 OCCURRED OUT ON THE NEW ORLEANS EAST BACK LEVEE DOES NOT OCCUR
16:55 25 EITHER. SO WE HAVE A REDUCTION IN VOLUME INTRODUCED, PROBABLY
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1841
16:55 1 50 PERCENT, SOMETHING LIKE THAT.

16:55 2 Q. SO IF THE JUDGE FOR WHATEVER REASON, UNDER THE LAW AND HIS
16:55 3 DISCRETION, WERE TO SAY, "I'M GOING TO COMPARE 1 AND 3," IS IT
16:56 4 YOUR TESTIMONY THAT EVEN UNDER 3 THERE IS -- DESIGN SIZE AS
16:56 5 OPPOSED TO ENLARGED SIZE, THERE IS SIGNIFICANTLY LESS FLOODING
16:56 6 OF THE NEW ORLEANS EAST POLDER BY OVERTOPPING?
16:56 8 Q. AND THERE IS NO BREACHING OF ANY SUBSTANCE UNDER
16:56 9 SCENARIO 3?
16:56 11 THE COURT: HOW MUCH LESS FLOODING?
16:56 12 THE WITNESS: IT'S ABOUT 30 PERCENT OVER THIS CITRUS
16:56 13 BACK LEVEE.
16:56 14 THE COURT: SO IF THERE WERE 9 FEET, IT WOULD BE --
16:56 15 THE WITNESS: IT WOULD BE ABOUT 6.
16:56 16 THE COURT: 6.
16:56 17 THE WITNESS: NOW, I SAID 30 PERCENT OVER THIS LEVEE.
16:56 18 THERE'S ALSO THIS BREACHING OUT HERE. THAT CONTRIBUTES ANOTHER
16:56 19 30 PERCENT THAT WOULDN'T BE THERE. SO I WOULD SAY 50 PERCENT
16:56 20 WOULD BE MORE THE CUMULATIVE EFFECT.
16:56 21 THE COURT: OKAY.
16:56 22 BY MR. ROY:
16:56 23 Q. SO THE ROBINSONS, FOR EXAMPLE, IN NEW ORLEANS EAST --
16:56 24 THE COURT: THIS IS ASSUMING THAT NO SURGE -- WE ARE
16:56 25 IN SCENARIO 3, NO SURGE GATE AND THE MRGO STAYED PRISTINE?
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1842
16:57 1 THE WITNESS: YES, SIR.

16:57 2 BY MR. ROY:
16:57 3 Q. COMPARING 1 TO 3 --
16:57 4 THE COURT: AND ITS ENVIRONS. GO AHEAD.
16:57 5 BY MR. ROY:
16:57 6 Q. COMPARING 1 TO 3, THE ROBINSONS GET 50 PERCENT NET LESS
16:57 7 WATER THAN THEY GOT DURING KATRINA?
16:57 8 A. THAT'S MY INTERPRETATION, YES.
16:57 9 Q. THAT'S YOUR EXPERT OPINION?
16:57 10 A. THAT'S MY EXPERT OPINION.
16:57 11 Q. BACKED BY THE SCIENTIFIC PROCESSES AND APPLICATIONS AND
16:57 12 MODELING THAT YOU DIRECTED AND OVERSAW?
16:57 14 Q. NOW, THE KEY TO UNDERSTANDING THIS FOR ALL OF US IS WHAT
16:57 15 YOU CALL THE BATHTUB EFFECT; CORRECT?
16:57 17 MR. ROY: CAN WE PULL UP PAGE 71.
16:57 18 BY MR. ROY:
16:57 19 Q. THE BATHTUB EFFECT IS THE ANALOGY YOU CAN DRAW THAT
16:57 20 BASICALLY IS WHY YOU SAID, IF IT OVERTOPS LONG ENOUGH, YOU CAN
16:57 21 MAKE A PRETTY GOOD GUESS WHAT THE LEVEE HEIGHT IS; RIGHT?
16:57 23 Q. EXPLAIN IT.
16:57 24 A. OKAY. WELL, UNLIKE A NATURAL COASTAL INDENTATION IN WHICH
16:58 25 YOU HAVE THE MOUNTAINS ARE SLOPING DOWN TO THE EDGE OF THE
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1843
16:58 1 SEASHORE AND, AS THE SURGE WOULD COME UP, IT WOULD JUST GET
16:58 2 HIGHER AND HIGHER GOING UP INTO -- AS THE FUNNEL NARROWS, YOU
16:58 3 CAN'T DO THAT IN THIS ARTIFICIAL FUNNEL BECAUSE IT'S BOUNDED BY
16:58 4 THESE ARTIFICIAL LEVEES RATHER THAN A NATURAL SEASHORE.
16:58 5 SO THE SURGE WOULD LIKE TO DO THE SAME THING. IT
16:58 6 WOULD LIKE TO RISE AS YOU MOVE INTO THE FUNNEL, BUT INSTEAD,
16:58 7 WHAT IT DOES IS THE WATER JUST OVERFLOWS INTO THE ADJACENT
16:58 8 AREAS. SO THIS WAS ONE OF THE THINGS WE SAW IN THE IPET
16:58 9 SIMULATIONS WAS THAT ALTHOUGH -- AND THERE THEY ONLY TOOK OUT
16:58 10 THE REACH 2. THEY DIDN'T DO ANYTHING ABOUT REACH 1.
16:58 11 BUT WHAT WE SAW WAS, WHEN THEY DID TAKE THE REACH 2
16:58 12 CHANNEL OUT, IT REDUCED FLOODING IN THE DEVELOPED AREAS. SO
16:59 13 THAT GAVE US, I GUESS, THE GERM OF THAT IDEA ABOUT THE BATHTUB.
16:59 14 SO THE PRESENCE OF THE LARGE MRGO CHANNEL GREATLY INCREASES
16:59 15 CONVEYANCE OF SURGE FROM REACH 1 TO REACH 2 AND INTO THE IHNC.
16:59 16 THE CREST ELEVATION OF THE LPV LEVEES PROVIDES A MAXIMUM LIMIT
16:59 17 ON HOW HIGH SURGE GETS, ESSENTIALLY, EAST OF THE
16:59 18 REACH 1/REACH 2 JUNCTION.
16:59 19 NOW, INSIDE THAT CHANNEL SYSTEM, THE SURGE CAN
16:59 20 ACTUALLY GET HIGHER THAN THE LEVEE HEIGHT BECAUSE YOU HAVE THIS
16:59 21 HUGE AMOUNT OF WATER CONVERGING INTO THAT AREA. THE MRGO
16:59 22 CHANNEL IS A HUGE SPIGOT INTO THE BATHTUB, BASICALLY, WHICH HAS
16:59 23 A LIMITED ABILITY TO DRAIN, BUT THE SURGE IS NOT GOING TO -- IF
16:59 24 ALL YOU LOOK AT IS SURGE ELEVATION, YOU WILL MISS ALL THE
16:59 25 DYNAMICS.
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1844
17:00 1 THE COURT: HOLD ON FOR ONE SECOND, SIR.

17:01 2 OKAY. I THINK WE GOT IT CLEARED UP. THANK YOU.
17:01 3 BY MR. ROY:
17:01 4 Q. HAD YOU FINISHED?
17:01 5 A. I WAS JUST GOING TO READ THE LAST POINT THERE. BUT INSIDE
17:01 6 REACH 1 AND THE IHNC, THE BATHTUB EFFECT IS LESS -- I MEAN, YOU
17:01 7 CAN GET WATER ABOVE THE LEVEES BECAUSE YOU HAVE SUCH A HUGE
17:01 8 DRIVING FORCE COMING FROM THE FUNNEL.
17:01 9 Q. THE PRIMARY FACTOR OR A SIGNIFICANT FACTOR OF THAT DRIVING
17:01 10 FORCE IS THE DRAMATICALLY ENLARGED MRGO AS IT GREW IN WIDTH AND
17:01 11 DEPTH SINCE CONSTRUCTION IN THE MID '60S?
17:01 12 A. NO QUESTION ABOUT IT.
17:01 13 Q. THAT'S WHAT YOUR FINEL FLOW-MODELING CATEGORICALLY PROVED,
17:01 14 IN YOUR OPINION; RIGHT?
17:01 16 Q. REALIZING MY ILLUSTRATIVE EXAMPLE I'M GOING TO GIVE YOU
17:02 17 NOW MAY BE OFF IN TERMS OF EXACT MEASUREMENTS, I JUST WANT TO
17:02 18 TRY TO GET A CONCEPT OUT THERE.
17:02 19 IF WE HAVE A TROUGH ROUGHLY ONE INCH SQUARE, OPEN AT
17:02 20 THE TOP, FLOWING WATER, AND WE HAVE ANOTHER ONE-INCH TROUGH,
17:02 21 FLOWING WATER, AND THEY CONVERGE TOGETHER, LET'S SAY, AT ABOUT
17:02 22 A 45- OR A 90-DEGREE; AND THEY CONVERGE INTO A TROUGH THAT'S
17:02 23 2 INCHES BY 2 INCHES, OR WHATEVER IT TAKES TO CARRY THAT LOAD
17:02 24 FROM GULF INTRACOASTAL TROUGH AND THE MRGO REACH 2 TROUGH AND
17:02 25 IT CARRIES IT THROUGH; IF THE MRGO TROUGH ON THE BOTTOM TRIPLES
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1845
17:02 1 IN SIZE OR QUADRUPLES IN SIZE AND EVEN GETS DEEPER, THEN IT'S
17:02 2 LIKE CONVERTING A 1-INCH BY 1-INCH, LIKE YOU SAID, TO A
17:02 3 FIREHOSE AIMED STRAIGHT AT THE CONVERGENCE POINT. RIGHT?
17:02 4 A. THAT'S WHAT THE FINEL MODEL SHOWS, YES.
17:03 5 Q. SO WE'RE VERY, VERY CLEAR HERE, WHILE THE FUNNEL EXISTED,
17:03 6 AND THE CORPS SHOULD HAVE KNOWN IT, IN YOUR OPINION, WHEN THEY
17:03 7 BUILT THE MRGO, THE PRIMARY DRIVING FACTOR FROM A STANDPOINT OF
17:03 8 DRIVING THE VELOCITY AND VOLUME OF THE SURGE UNDER THE PARIS
17:03 9 ROAD BRIDGE IN REACH 1 WAS THE ENLARGEMENT OF THE MRGO OVER THE
17:03 10 DECADES IN WIDTH AND DEPTH, AND EVEN THEN THE ENLARGEMENT OF
17:03 11 THE REACH 1 A LITTLE BIT IN DEPTH AND REACH?
17:03 13 Q. WITHOUT THAT, THERE WOULD HAVE BEEN SIGNIFICANTLY LESS
17:03 14 FLOODING OF NEW ORLEANS EAST -- THE ROBINSONS WOULD HAVE HAD
17:03 15 HALF THE FLOODING -- WITH NO REMEDIATION OTHER THAN JUST HAVING
17:03 16 IT THE WAY IT WAS BUILT ORIGINALLY. RIGHT?
17:03 18 Q. YOU HAVE PROVED THESE THINGS WITH YOUR MODEL; IS THAT
17:03 19 RIGHT?
17:03 20 A. YES. A LOT OF IT IS IN THE SAME WAY THAT BRETSCHNEIDER
17:04 21 AND COLLINS SHOWED. WHAT IT DOES IS IT CHANGES THE DURATION OF
17:04 22 THE FLOODING. YOU MAY NOT SEE A BIG CHANGE IN THE MAXIMUM, BUT
17:04 23 YOU SEE A BIG CHANGE IN THE DURATION OF THE PERIOD OF TIME THAT
17:04 24 IT'S ABOVE THE LEVEE HEIGHT.
17:04 25 Q. IN YOUR PROFESSIONAL OPINION, DO YOU AGREE THAT THE KEY TO
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1846
17:04 1 WHEN NEW ORLEANS EAST FLOODED AS MUCH AS IT DID DURING KATRINA
17:04 2 IS THE OVERTOPPING OF THE REACH 1 NORTH LEVEE -- THAT'S THE
17:04 3 CITRUS BACK LEVEE -- BEING THE PRIMARY SOURCE OF EXCESS
17:04 4 VELOCITY, EXCESS SURGE VOLUME, SHOVED DOWN REACH 1 AT THE PARIS
17:04 5 BRIDGE AREA AND THROUGH REACH 1 BY THAT AGGRAVATED MRGO
17:04 6 REACH 2?
17:04 8 Q. SINCE DESIGN AND CONSTRUCTION?
17:04 9 A. YEAH. I CAN DEMONSTRATE THAT WITH A HYDROGRAPH OR
17:05 10 SOMETHING, BUT --
17:05 11 Q. IF YOU WOULD LIKE.
17:05 12 A. OKAY. THIS IS ACTUALLY AN OVERTOPPING HYDROGRAPH. SO
17:05 13 WHAT WE SEE ON THE TOP HERE IS THAT CITRUS BACK LEVEE, AND WHAT
17:05 14 WE HAVE ON THE SIDE IS THE OVERTOPPING RATE, WHICH IS GIVEN IN
17:05 15 CUBIC FEET PER SECOND PER LINEAR FOOT AT THE TOP.
17:05 16 THE COURT: FOR THE RECORD, YOU'RE REFERRING TO YOUR
17:05 17 EXPERT REPORT, PAGE 135?
17:05 18 MR. ROY: YES, SIR. PX-91.
17:05 19 THE COURT: PX-91.
17:05 20 THE WITNESS: THEN WE HAVE TIME ALONG THE BOTTOM
17:05 21 AXIS, AND THE THREE CURVES THAT ARE OF INTEREST HERE IS THE --
17:05 22 I'M SORRY, I'M POINTING AT THE THING ON MY SCREEN -- BLUE LINE,
17:05 23 WHICH IS THE KATRINA AS IS. THE DOTTED RED LINE IS THE
17:05 24 SITUATION WITH THE SCENARIO 3, THAT IS THE CONDITION WHEN
17:06 25 THE --
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1847
17:06 1 THE COURT: WHEN YOU SAY "DOTTED RED," MY COLOR

17:06 2 CODING IS POOR. IS THAT WHAT LOOKS LIKE ORANGE TO ME?
17:06 3 THE WITNESS: ACTUALLY, WHEN I LOOK AT IT DOWN HERE,
17:06 4 IT LOOKS ORANGE.
17:06 5 THE COURT: OKAY.
17:06 6 THE WITNESS: THIS IS THE SCENARIO 2C, WHICH IS THE
17:06 7 DASHED GRAY. I CALL YOUR ATTENTION TO THIS LEGEND, AND MAYBE
17:06 8 WE COULD BLOW THAT UP.
17:06 9 OKAY. SO WHAT WE HAVE ACTUALLY DONE HERE IS PUT
17:06 10 THE -- WE HAVE INTEGRATED UNDER THAT CURVE. SO WE HAVE THE
17:06 11 TOTAL VOLUME FOR THE EVENT, THAT IS, FOR THE SURGE EVENT. FOR
17:06 12 SCENARIO 1 IT'S 118,000 CUBIC FEET PER FOOT. THAT'S ADDING IT
17:06 13 UP OVER ALL THE TIME THAT IT'S ABOVE THE LEVEE.
17:06 14 THEN FOR SCENARIO 3 IT'S ABOUT 30 PERCENT LESS,
17:07 15 25, 30 PERCENT LESS; 86,000, 87,000 CUBIC FEET PER FOOT.
17:07 16 FOR THE 2C CONDITION, IT'S ABOUT 80 PERCENT
17:07 17 REDUCED; 17,600 CUBIC FEET PER FOOT.
17:07 18 SO THAT GIVES YOU -- SINCE FLOODING OVER THIS
17:07 19 LEVEE WAS THE PRIMARY SOURCE OF FLOODING TO NEW ORLEANS EAST,
17:07 20 THIS GIVES YOU AN IDEA OF THE SENSITIVITY OF OVERTOPPING TO THE
17:07 21 CHANNEL GEOMETRY.
17:07 22 THE COURT: SO UNDER 2C WOULD THERE BE ANY FLOODING
17:07 23 IN THE INHABITED PORTION OF NEW ORLEANS EAST?
17:07 24 THE WITNESS: THERE MIGHT HAVE BEEN SOME STREET
17:07 25 FLOODING. NOW, WE DID HAVE SOME FLOODING --
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1848
17:07 1 THE COURT: CAUSED FROM OVERTOPPING, I SHOULD SAY.

17:07 2 THE WITNESS: YEAH, FROM OVERTOPPING. NOW, THERE WAS
17:07 3 SOME BREACHING WAY OUT IN THE EASTERN PART THAT CONTRIBUTED
17:07 4 SOME WATER, BUT A MINORITY OF THE WATER, PROBABLY 30 PERCENT.
17:07 5 MR. ROY: YOUR HONOR, I THINK THE TABLE AT
17:08 6 POWERPOINT 66 MAY BE THE ONE THAT WILL FACILITATE DIRECT
17:08 7 ANSWERS TO YOUR QUESTIONS, THE SCIENTIFICALLY CREATED TESTING
17:08 8 CHART.
17:08 9 BY MR. ROY:
17:08 10 Q. WHAT IS THIS, DR. KEMP?
17:08 11 A. IT'S A VERY BUSY TABLE. I'VE LISTED --
17:08 12 Q. THIS IS FROM PAGE 142 OF YOUR REPORT, PX-91; CORRECT?
17:08 13 A. THAT'S RIGHT. THIS IS ALL FINEL RESULTS. THERE ARE A
17:08 14 SERIES OF LOCATIONS ON THE LEFT. THESE WOULD CORRESPOND TO THE
17:08 15 LEVEE NAMES THAT ARE SHOWN IN THE NEXT COLUMN. THEN WE HAVE
17:08 16 ATTACHED EACH LEVEE TO A PARTICULAR POLDER. OKAY.
17:08 17 SO THE CITRUS BACK LEVEE WOULD FLOOD INTO -- ANY
17:08 18 OVERTOPPING WOULD GO INTO THE NEW ORLEANS EAST POLDER. THEN WE
17:08 19 HAVE TAKEN THAT INFORMATION THAT YOU SAW, CUBIC FEET PER FOOT,
17:08 20 THE TOTAL VOLUME, AND PUT THAT IN SCENARIO 1, SCENARIO 2C OVER
17:09 21 HERE, AND SCENARIO 3.
17:09 22 SO WE HAVE DONE THAT FOR EACH OF THESE POINTS AND
17:09 23 ASSIGNED THEM TO POLDERS, AND THEN WE HAVE KIND OF LUMPED THAT
17:09 24 INFORMATION TOGETHER TO SAY -- BECAUSE THESE ARE REPRESENTATIVE
17:09 25 LEVEE DEPICTIONS. WE SAY FOR THE NEW ORLEANS EAST POLDER, FOR
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1849
17:09 1 EXAMPLE, IF WE HAD THE 2C -- 100 PERCENT IS WHAT YOU GET UNDER
17:09 2 SCENARIO 1. IF YOU HAVE 2C, THEN YOU ONLY GET 18 PERCENT OF
17:09 3 THE FLOODING. IF YOU HAVE 3, YOU GET 75 PERCENT IN NEW ORLEANS
17:09 4 EAST. OKAY. AND THEN FOR -- I'M SORRY.
17:09 5 Q. I WAS GOING TO SAY, CAN YOU MOVE A LITTLE BIT SLOWER SO WE
17:09 6 CAN ASSIMILATE THIS. IT'S A TOUGH CHART FOR LAYMEN TO LOOK AT.
17:09 7 A. YOU CAN LOOK AT EACH INDIVIDUAL LEVEE SEGMENT IF YOU WOULD
17:09 8 LIKE, BUT --
17:09 9 THE COURT: LET'S GO FOR THE NEW ORLEANS EAST POLDER.
17:10 10 WE KNOW UNDER SCENARIO 1, OBVIOUSLY, THAT'S WHAT REALLY
17:10 11 HAPPENED. THAT'S THE FLOODING THAT ACTUALLY OCCURRED.
17:10 12 THE WITNESS: THAT'S RIGHT.
17:10 13 THE COURT: I'M GOING TO GO RIGHT TO 2C, WHICH IS THE
17:10 14 NEUTRAL MRGO, OR THE MITIGATED MRGO, WHATEVER WE WANT TO CALL
17:10 15 IT. ONLY 18 PERCENT OF THE FLOODING WOULD HAVE OCCURRED, AND
17:10 16 IS THAT WITHIN THE ENTIRE POLDER?
17:10 17 THE WITNESS: THAT'S 18 PERCENT OF THE FLOW OVER THAT
17:10 18 LEVEE. NOW, THAT FLOW OVER THAT LEVEE IS THE MAIN SOURCE OF
17:10 19 OVERTOPPING INTO THAT POLDER, YES.
17:10 20 THE COURT: WHEN YOU'RE TALKING ABOUT THE POLDER,
17:10 21 THERE'S A PART OF THE NEW ORLEANS POLDER THAT'S NOT INHABITED?
17:10 22 THE WITNESS: YEAH. I'M TALKING ABOUT THE INHABITED
17:10 23 AREAS.
17:10 24 THE COURT: SO IF THERE WAS NO MRGO OR NEUTRAL MRGO,
17:10 25 WHATEVER, THEN IF THE FLOODING -- AND I'M GOING TO DO THIS
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1850
17:10 1 SIMPLY. IT'S NOT PERFECT MATHEMATICALLY. IF THERE WERE 10

17:10 2 FEET OF WATER, YOU WOULD HAVE HAD 2 FEET, THE WAY I'M LOOKING
17:10 3 AT THIS -- AND PLEASE TELL ME IF I'M WRONG -- AND UNDER
17:11 4 SCENARIO 3, IF THERE WERE, LET'S SAY -- I WOULD LIKE TO DO IT.
17:11 5 SINCE IT'S 75 PERCENT, IF THERE WERE 12 FEET OF WATER, THERE
17:11 6 WOULD BE 9 FEET UNDER 3. THAT'S WHAT IT LOOKS LIKE TO ME, AND
17:11 7 PLEASE CORRECT ME ON THOSE.
17:11 8 THE WITNESS: NO. THAT MAKES A LOT OF SENSE TO ME.
17:11 9 THE ONLY OTHER THING I WOULD SAY IS THAT THIS IS WHERE THE
17:11 10 MAJORITY OF WATER COMES IN, BUT THERE IS STILL SOME WATER THAT
17:11 11 COMES IN FROM THE -- FARTHER OUT TO THE EAST WHERE THERE IS
17:11 12 SOME LEVEE BREACHING. ABOUT 30 PERCENT OF THE WATER FLOODING
17:11 13 NEW ORLEANS EAST COMES FROM THE BREACHES. SO 70 PERCENT FROM
17:11 14 OVERTOPPING PRIMARILY ACROSS THE CITRUS EAST LEVEE, AND
17:11 15 30 PERCENT COMING FROM BREACHES, YOU KNOW, WAY OUT ON THE EAST
17:11 16 END.
17:11 17 THE COURT: I UNDERSTAND WHAT YOU'RE SAYING. OF
17:11 18 COURSE, THE LOWER THE WATER IS, THEN THE MORE DRAMATIC THE
17:11 19 EFFECT. THIS LOOKS LIKE 75 PERCENT RATHER THAN 50 PERCENT, AND
17:12 20 WE HAVE BEEN TALKING ABOUT 50 PERCENT, SO THE COURT IS A LITTLE
17:12 21 BEFUDDLED.
17:12 22 THE WITNESS: OKAY. YEAH. I WAS FACTORING IN THE
17:12 23 BREACHING THAT WOULD NOT OCCUR IN THE NEW ORLEANS EAST AREA.
17:12 24 BY MR. ROY:
17:12 25 Q. UNDER WHAT SCENARIO, DR. KEMP?
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1851
17:12 1 A. THAT WAS BEFORE 2C OR 3.

17:12 2 THE COURT: SO YOU'RE SAYING THAT THE BREACHING WOULD
17:12 3 NOT OCCUR UNDER 3?
17:12 4 THE WITNESS: THAT'S RIGHT. EITHER 2C OR 3. THAT'S
17:12 5 WHAT DR. BEA WAS --
17:12 6 THE COURT: SO THAT'S HOW WE GET DOWN TO 50 PERCENT.
17:12 7 THE WITNESS: THAT'S RIGHT.
17:12 8 THE COURT: I GOT YOU. OKAY.
17:12 9 BY MR. ROY:
17:12 10 Q. SO JUST GOING UP TO THE TOP, LOCATION 1, CITRUS BACK
17:12 11 LEVEE, NEW ORLEANS EAST POLDER, YOU COMPARE UNDER SCENARIO 1,
17:12 12 118,300 CUBIC FEET PER LINEAR FOOT; UNDER 2C, DOWN TO 17,600;
17:12 13 UNDER SCENARIO 3, IT'S 86,000.
17:13 14 2C, FOR THE PEOPLE AROUND CITRUS BACK LEVEE, IT'S
17:13 15 WATER IN THE STREET?
17:13 17 Q. IF THE COMPARISON IS STRICTLY 3, THEN LIKE YOU
17:13 18 EXTRAPOLATED, ULTIMATELY, WHEN YOU TAKE OUT THE THREE
17:13 19 BREACHINGS ON THE NEW ORLEANS EAST BACK LEVEE, THEN THE
17:13 20 ROBINSONS GET HALF THE WATER IN NET THAT THEY WOULD HAVE --
17:13 21 A. THAT'S A ROUGH ESTIMATE, YES.
17:13 22 Q. WELL, IT'S ONE THAT YOU HAVE DERIVED FROM INTERPRETING
17:13 23 YOUR FINEL MODELING; IS THAT CORRECT?
17:13 25 Q. IT'S NOT A WILD GUESS AND IT'S CERTAINLY NOT SPECULATION,
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1852
17:13 1 IS IT?
17:13 2 A. NO.
17:13 3 Q. NOW, THIS CHART IS IN EVIDENCE, SO WE WON'T BEAT THAT
17:13 4 HORSE INTO THE GROUND.
17:14 5 THE COURT: I UNDERSTAND WHAT IT MEANS, AND WE HAVE
17:14 6 ILLUSTRATED HOW TO RIDE THE HORSE ANYWAY.
17:14 8 THE COURT: I'M SURE WE WILL BE SEEING IT TOMORROW AS
17:14 9 WELL.
17:14 10 MR. ROY: I BET WE WILL.
17:14 11 BY MR. ROY:
17:14 12 Q. SO YOU BELIEVE THAT THE MRGO REACH 1 AND REACH 2, AS THEY
17:14 13 BOTH ENLARGED IN DEPTH AND WIDTH SINCE ORIGINAL DESIGN AND
17:14 14 CONSTRUCTION, SIGNIFICANTLY CONTRIBUTED TO THE VOLUME AND
17:14 15 DURATION OF THE SURGE IN REACH 1 THAT OVERTOPPED THE CITRUS
17:14 16 BACK LEVEE AND CONTRIBUTED TO THE ROBINSONS' FLOODING; IS THAT
17:14 17 RIGHT?
17:14 18 A. NO QUESTION ABOUT THAT.
17:14 19 Q. IN FACT, IF IT HAD NOT ENLARGED, ALL RIGHT, IF I
17:14 20 UNDERSTOOD YOU CORRECTLY, STRICTLY WITH THAT, WITHOUT ANY OTHER
17:14 21 REMEDIATION WHATSOEVER, IT'S HALF THE FLOODING?
17:14 22 A. THAT'S MY OPINION.
17:14 23 Q. THE FULLY MITIGATED MRGO FLOW COMPARISONS AT PEAK SURGE,
17:14 24 8:00 A.M., OVERTOPPING IS REDUCED, BOTTOM LINE, 82 PERCENT IN
17:15 25 NEW ORLEANS EAST; IS THAT RIGHT?
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1853

17:15 2 Q. LOWER NINTH WARD AND ST. BERNARD PARISH, WHAT'S THE
17:15 3 RESULT?
17:15 4 A. PERHAPS WE CAN GET THE CHART BACK UP. OKAY. SO THE LOWER
17:15 5 NINTH WARD -- NOW, WHAT WE HAVE DONE HERE IS WE DON'T HAVE --
17:15 6 WE HAVE COMBINED ST. BERNARD AND THE LOWER NINTH WARD, BUT
17:15 7 REALLY, WHAT WE ARE LOOKING AT THERE, AND WHEN WE SAY -- THIS
17:15 8 IS THE SECOND LINE. THIS IS REALLY THE LOWER NINTH WARD
17:15 9 BECAUSE, REMEMBER, UNDER SCENARIO 1, IF THERE IS NO BREACHING,
17:15 10 THEN WE DON'T GET WATER IN ST. BERNARD.
17:15 11 THE COURT: RIGHT. WE HAVE GOT THAT.
17:15 12 THE WITNESS: RIGHT. SO THIS WOULD BE MOSTLY
17:15 13 OVERFLOW OF THE FLOOD WALLS IN THE IHNC. THERE WE ARE SHOWING
17:15 14 WE WOULD HAVE ONLY 15 PERCENT OF THAT OVERFLOW FOR SCENARIO 2C
17:16 15 AND WE HAVE ABOUT 79, 80 PERCENT FOR 3. SO THERE IS A
17:16 16 REDUCTION, BUT IT'S NOT -- FOR 3, BUT IT'S ONLY ABOUT
17:16 17 20 PERCENT OF THE OVERFLOW. BUT, OF COURSE, THAT WAS A VERY
17:16 18 SMALL CONTRIBUTOR TO THE ACTUAL FLOODING.
17:16 19 THE COURT: BREACHING WAS --
17:16 20 THE WITNESS: BREACHING WAS --
17:16 21 THE COURT: -- PRIMARY, OTHER THAN WHAT OCCURRED FROM
17:16 22 REACH 2 BECAUSE, AS I UNDERSTAND SOME OF THE TESTIMONY, SOME OF
17:16 23 THAT AREA WAS FLOODED BY VIRTUE OF THE FAILURE OF REACH 2
17:16 24 LEVEES.
17:16 25 THE WITNESS: I THINK 90 PERCENT OF THE WATER CAME
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1854
17:16 1 FROM THE FAILURE OF REACH 2; ABOUT 10 PERCENT FROM THE FAILURE
17:16 2 OF FLOOD WALLS.
17:16 3 THE COURT: IN THE LOWER NINTH?
17:16 6 BY MR. ROY:
17:16 7 Q. DID YOU OR YOUR TEAM EVER DETERMINE IF THERE WAS A SECOND
17:17 8 SURGE, LIKE DR. WESTERINK OPINED AND LIKE THE JUDGE REFERRED TO
17:17 9 EARLIER TODAY?
17:17 10 A. THE ONLY THING I COULD LOOK AT WAS -- THE ONLY RECORD THAT
17:17 11 WAS ACTUALLY CONTEMPORANEOUS, WHICH IS THE LOCK MASTER'S
17:17 12 RECORD, IT DOES NOT SHOW THAT SECOND SURGE. BUT WE SHOW A
17:17 13 SMALL HUMP ON SOME OF OUR FINEL RESULTS THAT COULD BE ANALOGOUS
17:17 14 TO THE LARGE HUMP THAT DR. WESTERINK SHOWS. IT DOESN'T SEEM TO
17:17 15 SHOW UP IN THE ONLY RECORD THAT WE ACTUALLY HAVE.
17:17 16 Q. NOTHING YOU HAVE SHOWS THIS DRAMATIC SECOND SURGE THAT
17:17 17 COMES BACK AND SITS THERE FOR A WHILE BEFORE GRADUALLY COMING
17:17 18 BACK DOWN; RIGHT?
17:17 19 A. NO. UNTIL I SAW DR. WESTERINK'S CHRISTMAS REPORT, I HAD
17:17 20 NEVER SEEN ANY DEPICTION OF SURGE, CERTAINLY NOT IN IPET.
17:18 21 Q. IS THAT USING THAT NEW ADCIRC, THAT SL15?
17:18 22 A. I THINK YOU WILL HAVE TO ASK DR. WESTERINK ABOUT THAT.
17:18 23 Q. IN YOUR OBSERVATION AND YOUR EXPERTISE THAT YOU HAVE BEEN
17:18 24 TENDERED TODAY, WAS KATRINA THE MOTHER OF ALL STORMS TO HIT
17:18 25 ST. BERNARD AND ORLEANS PARISH IN THE LAST 100 YEARS?
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17:18 1 A. WELL, IT REALLY DIDN'T HIT NEW ORLEANS. IT KIND OF WAS A

17:18 2 NEAR MISS. IT WAS A VERY SEVERE STORM, BUT IT WAS CERTAINLY
17:18 3 NOT THE WORST-CASE SCENARIO FOR NEW ORLEANS.
17:18 4 Q. IT WAS A CATEGORY 3 STORM THAT MISSED NEW ORLEANS?
17:18 5 A. CATEGORY 3 STORM, YEAH. WE WERE ON THE BEST SIDE OF IT.
17:18 6 CERTAINLY, THE POOR PEOPLE IN MISSISSIPPI GOT THE WORST OF IT.
17:19 7 WHEN WE MODELED THE HURRICANE PAM SIMULATION -- THAT
17:19 8 WAS A MYTHICAL STORM -- THE WIND SPEEDS WERE NOT ANY HIGHER
17:19 9 THAN IN KATRINA, BUT IT WAS ON A WORST TRACK, AND SO OUR
17:19 10 MODELING SHOWED IT WOULD HAVE FLOODED BOTH BANKS OF
17:19 11 NEW ORLEANS. KATRINA ONLY FLOODED ONE BANK, THANK GOODNESS.
17:19 12 Q. EVEN IF THE FUNNEL WAS A RESULT OF THE ORIGINAL DESIGN OF
17:19 13 THE MRGO REACH 1 AND REACH 2, FROM AN OCEANOGRAPHER'S
17:19 14 STANDPOINT, THE PROBABILITY FOR RESULTING HARM TO PEOPLE AND
17:19 15 PROPERTY, IN YOUR OPINION, SHOULD HAVE BEEN SEEN, RECOGNIZED,
17:19 16 AND CORRECTED BY REMEDIATION AS EARLY AS '66 AND NO LATER THAN
17:19 17 '91; IS THAT A FAIR STATEMENT?
17:19 18 A. THAT'S A FAIR STATEMENT.
17:19 19 Q. IS THAT YOUR OPINION?
17:19 20 A. THAT'S MY OPINION.
17:19 21 Q. IS THAT BASED ON THE SCIENCE AND THE MODELING, YOUR
17:20 22 EDUCATION, AND YOUR EXPERIENCE?
17:20 23 A. YES, SIR.
17:20 24 Q. NO LATER THAN 1966 OR, AT THE LATEST, 1973, IN YOUR
17:20 25 PROFESSIONAL OPINION, SHOULD A MINIMALLY COMPETENT
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1856
17:20 1 OCEANOGRAPHER HAVE RECOGNIZED THE FUNNEL AND ITS PROBABLE CAUSE
17:20 2 OF DESTRUCTION OF LIFE AND PROPERTY UNDER HURRICANE SURGE
17:20 3 CONDITIONS AND THEREAFTER? DO YOU AGREE WITH THAT?
17:20 4 A. I DO.
17:20 5 Q. THE FUNNEL, AS REACH 1 AND REACH 2 GREW WIDER AND DEEPER
17:20 6 WITH DREDGING AND EROSION, WAS EVEN MORE DANGEROUS, AND ANY
17:20 7 MINIMALLY COMPETENT OCEANOGRAPHER WITH THE CORPS SHOULD HAVE
17:20 8 KNOWN THAT BY NO LATER THAN THE LATE '80S, AND THE CORPS SHOULD
17:20 9 HAVE ADVISED CONGRESS TO TAKE REMEDIAL ACTION? DO YOU BELIEVE
17:20 10 THAT TO BE TRUE?
17:20 12 Q. FAILURE TO MITIGATE BOTH THE REACH 1 AND REACH 2 AS
17:20 13 DESIGNED BY, AT THE LATEST, 1988 WAS A SIGNIFICANT CAUSE OF THE
17:20 14 FLOODING PLAINTIFFS SUSTAINED DURING KATRINA, THE PLAINTIFFS IN
17:20 15 THIS CASE; IS THAT TRUE?
17:20 16 A. CAN YOU REPEAT THAT AGAIN. I COULDN'T QUITE --
17:21 17 Q. FAILURE TO MITIGATE BOTH THE MRGO REACH 1 AND REACH 2 AS
17:21 18 DESIGNED BY, AT THE LATEST, BY 1988 WAS A SIGNIFICANT CAUSE OF
17:21 19 THE FLOODING THE PLAINTIFFS SUSTAINED IN KATRINA?
17:21 20 A. OKAY. I'M GOING TO INTERPRET THAT AS MEANING AS IT WAS IN
17:21 21 1980S, NOT AS DESIGNED.
17:21 22 Q. NO. I'M TIRED. I APOLOGIZE. YOU'RE RIGHT. AS IT HAD
17:21 23 MORPHED --
17:21 24 A. OKAY. YES, YES.
17:21 25 Q. -- SINCE DESIGN AND CONSTRUCTION.
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1857
17:21 1 A. RIGHT. BECAUSE THEN THE WAVE EFFECTS BEGAN TO COME IN.
17:21 2 Q. THE FAILURE TO MITIGATE THE POSTDESIGN AND CONSTRUCTION
17:21 3 REACH 1 AND REACH 2 MORPHING DUE TO DREDGING AND EROSION WAS A
17:21 4 SIGNIFICANT CAUSE OF THE PLAINTIFFS' FLOODING IN KATRINA; IS
17:21 6 A. NO QUESTION.
17:21 7 Q. KENT LATTIMORE'S HOME IN ST. BERNARD --
17:21 8 MR. ROY: LET'S GO TO PAGE 161 OF THE POWERPOINT.
17:22 9 BY MR. ROY:
17:22 10 Q. -- YOUR PROFESSIONAL OPINION IS THAT HIS HOUSE WOULD
17:22 11 SUFFER DURING HURRICANE KATRINA SUBSTANTIALLY LESS WITH A
17:22 12 NEUTRAL MRGO; IS THAT RIGHT?
17:22 13 THE COURT: THANK YOU FOR NOT ANSWERING.
17:22 14 YES, SIR, COUNSEL. I'M SORRY.
17:22 15 MR. LEVINE: I'M GOING TO OBJECT. THESE ARE
17:22 16 HYDROGRAPH RESULTS DERIVED FROM THE SOBEK REPORT THAT I DON'T
17:22 17 BELIEVE WERE INCLUDED IN DR. KEMP'S REPORT ANYWHERE.
17:22 18 THE COURT: I UNDERSTAND THAT. I NOTE YOUR
17:22 19 OBJECTION. SINCE THEY HAVE ALREADY BEEN INTRODUCED INTO
17:22 20 EVIDENCE, I AM GOING TO ALLOW HIM SIMPLY FROM AN ILLUSTRATIVE
17:22 21 STANDPOINT TO CONFIRM AN OPINION HE HAS REALLY ALREADY GIVEN.
17:22 22 THE OBJECTION IS NOTED. HE MAY ANSWER THE QUESTION.
17:22 23 BY MR. ROY:
17:22 24 Q. DR. KEMP, HOW MUCH FLOODING DID MR. LATTIMORE'S HOME
17:22 25 SUFFER DURING HURRICANE KATRINA?
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1858
17:22 1 A. THE GROUND ELEVATION HERE IS 4 FEET AND THE PEAK ELEVATION
17:23 2 OF THE SURGE AT THIS LOCATION IS 10 FEET, SO IT SUFFERED A
17:23 3 TOTAL OF 5 FEET.
17:23 4 Q. IN YOUR EXPERT OPINION, WITH A FULLY NEUTRAL MRGO PROJECT,
17:23 5 HOW MUCH FLOODING WOULD HAVE OCCURRED IN HIS HOME?
17:23 6 A. IT LOOKS LIKE ABOUT A FOOT.
17:23 7 Q. SAME WITH SCENARIO 3?
17:23 8 A. I'M SORRY. I HAVE TO READ THIS BECAUSE THIS IS
17:23 9 DR. VRIJLING'S. IT WOULD HAVE BEEN ABOUT A FOOT IF THE
17:23 10 INDUSTRIAL CANAL BREACHES OCCURRED, WHICH I BELIEVE DR. BEA
17:23 11 SAYS THEY DO. IF THEY DIDN'T OCCUR, THEN THERE WOULD BE NO
17:23 12 FLOODING. SO ASSUMING THAT THE INDUSTRIAL CANAL BREACHES
17:23 13 OCCUR, IT'S ABOUT A FOOT.
17:23 14 Q. THE SAME WITH SCENARIO 3?
17:23 15 A. THAT'S RIGHT, BECAUSE THERE'S -- WE ARE TALKING HERE ABOUT
17:23 16 BREACHING, AND DR. BEA SAYS 2C AND 3 PRODUCED NO BREACHING.
17:24 17 Q. WHEN YOU SAY 1 FOOT, THAT'S 1 FOOT ON THE PROPERTY?
17:24 18 A. YEAH. I WAS LOOKING HERE AT THE --
17:24 19 THE COURT: THAT NEEDED TO BE CLARIFIED. NOT 1 FOOT
17:24 20 INTO THE HOME, BUT 1 FOOT ONTO THE PROPERTY?
17:24 21 THE WITNESS: THAT'S RIGHT. THIS WOULD BE MORE
17:24 22 STREET FLOODING.
17:24 23 BY MR. ROY:
17:24 24 Q. YOUR ANSWERS WOULD BE THE SAME IF I REPEATED THE SAME
17:24 25 QUESTIONS FOR LATTIMORE & ASSOCIATES' OFFICE IN ST. BERNARD; IS
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1859
17:24 1 THAT TRUE?

17:24 2 A. MY UNDERSTANDING IS THEY ARE VERY CLOSE TOGETHER IN
17:24 3 LOCATION.
17:24 4 Q. TANYA SMITH'S HOME?
17:24 5 A. YEAH.
17:24 6 Q. PX-1771, AT PAGE 3, POWERPOINT PAGE 162, HOW MUCH FLOODING
17:24 7 DID HER HOUSE SUFFER DURING KATRINA?
17:24 8 A. IT SUFFERED ABOUT 11 FEET.
17:24 9 Q. GROUND ELEVATION WAS 1 FOOT; RIGHT?
17:24 10 A. IT SAYS HERE -- YEAH, ABOUT 1 FOOT. THE TOTAL
17:24 11 ELEVATION -- IT SAYS "WATER DEPTH" OVER HERE, BUT I THINK THEY
17:24 12 REALLY MEAN THE TOTAL ELEVATION OF THE WATER. SO IF I SUBTRACT
17:24 13 1 FOOT FROM 11 FEET, I GET 10 FEET OF FLOODING IN THE HOUSE.
17:25 14 THE BLUE LINE OVER HERE SHOWS THE SITUATION IF THE
17:25 15 ONLY FLOODING WAS COMING FROM THE INDUSTRIAL CANAL BREACH. SO
17:25 16 WE WOULD HAVE GOTTEN 2 1/2 FEET THERE INSTEAD OF -- WELL, IT
17:25 17 WOULD HAVE BEEN 1 1/2 FEET, REALLY.
17:25 18 Q. IN YOUR EXPERT OPINION, WITH A FULLY NEUTRAL MRGO PROJECT,
17:25 19 HOW MUCH FLOODING WOULD HAVE OCCURRED IN THAT HOME?
17:25 20 A. I THINK THIS WOULD HAVE BEEN MORE WET CARPETS AND MAYBE
17:25 21 SOME, YOU KNOW, FLOORS THAT HAD TO BE REPLACED.
17:25 22 Q. SCENARIO 3, SAME RESULT; RIGHT?
17:25 23 A. RIGHT.
17:25 24 Q. ANTHONY AND LUCILLE FRANZ'S HOME IN THE LOWER NINTH WARD,
17:25 25 POWERPOINT PAGE 160, PX-1771, AT PAGE, 4. HOW MUCH FLOODING
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1860
17:25 1 DID THEIR PROPERTY SUFFER DURING HURRICANE KATRINA? THE GROUND
17:25 2 IS AT 1 1/2-FEET ELEVATION; RIGHT?
17:26 3 A. THAT'S RIGHT. BUT THE SURGE GOT UP TO CLOSE TO 11 FEET,
17:26 4 SO THEY SUFFERED 9 1/2 FEET OF FLOODING. BECAUSE THEY WERE
17:26 5 VERY CLOSE TO THE INDUSTRIAL CANAL BREACH, THEY WOULD STILL GET
17:26 6 ABOUT 5 FEET OF FLOODING.
17:26 7 Q. IN YOUR EXPERT OPINION, UNDER A FULLY NEUTRAL MRGO, HOW
17:26 8 MUCH FLOODING WOULD HAVE OCCURRED AT THEIR SITE?
17:26 9 A. I'M STILL ASSUMING THE INDUSTRIAL CANAL BREACH OCCURS. I
17:26 10 HAVE TO REMEMBER WHAT DR. BEA SAID ABOUT IT, BUT THEY WOULD
17:26 11 STILL GET ABOUT 5 FEET OF FLOODING.
17:26 12 Q. IF NO INDUSTRIAL CANAL BREACH?
17:26 13 A. WELL, THEY WOULDN'T GET ANY FLOODING.
17:26 14 Q. NORMAN AND MONICA ROBINSON'S HOME IN NEW ORLEANS EAST --
17:26 15 LET'S GO TO POWERPOINT PAGE 159, WHICH IS DERIVED FROM PX-1771
17:26 16 AT PAGE 1 -- HOW MUCH FLOODING DID THEIR PROPERTY SUFFER DURING
17:26 17 HURRICANE KATRINA?
17:26 18 A. THIS ONE I HAVE A HARD TIME INTERPRETING BECAUSE I THINK
17:26 19 IT REALLY IS DEPTH, NOT ELEVATION.
17:27 20 Q. IS THAT ABOUT 13 FEET?
17:27 21 A. YEAH.
17:27 22 Q. IN YOUR EXPERT OPINION, UNDER FULLY MITIGATED MRGO
17:27 23 CIRCUMSTANCES, HOW MUCH FLOODING WOULD HAVE OCCURRED IN THEIR
17:27 24 HOME?
17:27 25 A. IN THIS CASE, FULLY MITIGATED, THAT MEANS?
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1861
17:27 1 THE COURT: 2C.

17:27 2 THE WITNESS: 2C. IT WOULD HAVE BEEN LESS THAN
17:27 3 2 FEET.
17:27 4 BY MR. ROY:
17:27 5 Q. IF THE JUDGE FOR WHATEVER REASON, DESPITE OUR PROTESTS,
17:27 6 DECIDES TO ONLY USE A COMPARISON BETWEEN SCENARIO 1 AND 3 FOR
17:27 7 THE ROBINSONS IN NEW ORLEANS EAST, THEN IS IT YOUR EXPERT
17:27 8 OPINION THAT, COMPARING THOSE TWO, THE DIFFERENCE WOULD HAVE
17:27 9 BEEN THAT THE ROBINSONS WOULD ONLY HAVE ABOUT 6, 6 1/2, FEET ON
17:27 10 THEIR PROPERTY?
17:27 11 A. THAT'S CORRECT. YES, WE DISCUSSED THAT EARLIER.
17:27 12 Q. WOULD STANDING WATER POSTSURGE BE NOT GREATER THAN WHAT?
17:28 13 A. YOU KNOW, IT'S GOING TO BE -- IF IT'S 7 FEET IN THE HOUSE,
17:28 14 AND THE HOUSE IS AT A -7.1, IT MIGHT BE CLOSE TO SEA LEVEL. I
17:28 15 MEAN, IN THIS AREA YOU HAD A LOT OF FLOODING EVEN WHEN THE
17:28 16 WATER WAS JUST 1 OR 2 FEET ABOVE SEA LEVEL, YOU KNOW.
17:28 17 Q. WELL, GO BACK --
17:28 18 A. ABOUT HALF THE FLOODING YOU WOULD HAVE HAD OTHERWISE.
17:28 19 Q. ABOUT 36 INCHES? ABOUT 3 FEET?
17:28 20 A. SOMETHING LIKE THAT.
17:28 21 Q. ALL RIGHT. WAS THE AMOUNT OF FLOODING OF THE PLAINTIFFS
17:28 22 PREVENTIBLE, IN YOUR EXPERT OPINION?
17:28 24 Q. WAS THE FLOODING OF THE PLAINTIFFS FROM THE UNMITIGATED
17:28 25 MRGO A SUBSTANTIAL FACTOR IN WHATEVER WATER CAUSED DAMAGE AT
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1862
17:28 1 THEIR PROPERTIES?

17:28 2 A. I THINK WE HAVE WALKED THROUGH THAT AND SHOWN THAT IT
17:28 3 CONTRIBUTED TO MOST OF THE DAMAGE.
17:28 4 Q. HAVE ALL OF YOUR OPINIONS THAT YOU HAVE GIVEN IN YOUR
17:28 5 REPORTS AND IN YOUR TESTIMONY HERE IN THIS COURT BEEN BASED ON
17:28 6 YOUR EXPERTISE AND EXPERIENCE AND OFFERED BASED UPON REASONABLE
17:29 7 SCIENTIFIC CERTAINTY AS YOU KNOW THAT WITHIN YOUR PROFESSION?
17:29 9 MR. ROY: YOUR HONOR, GIVE ME JUST A MOMENT IF YOU
17:29 10 WOULD.
17:29 11 THE COURT: I'LL ASK HIM ONE QUESTION JUST TO GET
17:29 12 SOMETHING CLEAR IN MY MIND. IF -- AND IT'S A BIG "IF." BUT IF
17:29 13 FOR SOME REASON THERE WAS A SURGE BARRIER PLACED AT AN
17:29 14 APPROPRIATE LOCATION NEAR THE IHNC AND MRGO IN 1966, TO YOUR
17:29 15 KNOWLEDGE -- ONLY IF YOU KNOW -- WOULD THE BREACHES HAVE
17:29 16 OCCURRED -- WOULD THERE HAVE BEEN ANY IMPACT ON -- WOULD THE
17:29 17 BREACHES THAT OCCURRED AT THE IHNC HAVE OCCURRED? IF YOU DON'T
17:30 18 KNOW, THAT'S FINE.
17:30 19 THE WITNESS: THE WATER LEVEL WOULD HAVE BEEN
17:30 20 CONTROLLED BY THE LEVEL IN LAKE PONTCHARTRAIN, WHICH REACHED
17:30 21 ABOUT 12 FEET. SO I WOULD ASSUME THAT YOU WOULD HAVE 12 FEET
17:30 22 OF WATER IN THERE. I THINK AT LEAST THE SMALL NORTH BREACH MAY
17:30 23 HAVE OCCURRED ANYWAY.
17:30 24 THE COURT: OKAY. THAT'S JUST IN THE EVENT -- AND I
17:30 25 HAVE TO THINK ABOUT EVERY POSSIBLE SCENARIO. SO IF WE'RE
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1863
17:30 1 CALCULATING -- IF, IF, IF -- AND, AGAIN, BIG "IF'S." THE COURT
17:30 2 HAS NO IDEA WHAT IT'S GOING TO DO. IF THE COURT WOULD SOMEHOW
17:30 3 FIND LIABILITY ALLOCATING DAMAGES -- AND I'M EXPECTING A LITTLE
17:30 4 BRIEFING ON THAT SHORTLY, AND I'VE BEEN THINKING ABOUT THIS FOR
17:30 5 THE COURT OF APPEAL. THIS IS JUST AN ASIDE. HOW YOU ARE GOING
17:30 6 TO BRIEF THIS, WITH THE PAGE NUMBER REQUIREMENT IN THE COURT OF
17:30 7 APPEALS, IS GOING TO BE SOMETHING ELSE. I'M AFRAID YOU ARE
17:30 8 GOING TO HAVE TO GET AN EXTENSION.
17:31 9 MR. ROY: BY THE GRACE OF GOD, THOUGH, YOUR HONOR IS
17:31 10 NOT LIMITED TO SUCH A PAGE LIMIT.
17:31 11 THE COURT: NO, I'M NOT. I WANT YOU TO BE THINKING
17:31 12 ABOUT THAT. I'M THINKING ABOUT IT. SO IF IT'S TOO LONG, IT
17:31 13 WON'T BE TAILORED ENOUGH. LET'S ALL BE THINKING ABOUT THAT. I
17:31 14 THINK WE CAN DISTILL A LOT OF THE ISSUES, BUT I'LL GIVE YOU
17:31 15 SOME HINTS AT THE END OF THE TRIAL.
17:31 16 MR. ROY: THANK YOU, YOUR HONOR. WE TENDER THE
17:31 17 WITNESS.
17:31 18 THE COURT: THANK YOU, MR. ROY, FOR YOUR EXAMINATION.
17:31 19 SIR, I'M ASSUMING YOU ARE GOING TO DEFER UNTIL
17:31 20 TOMORROW?
17:31 21 MR. LEVINE: YES, SIR.
17:31 22 THE COURT: SIR, YOU MAY STEP DOWN, AND YOU WILL BE
17:31 23 UP TOMORROW.
17:31 24 MR. STEVENS: YOUR HONOR, IT'S KIND OF BECOME MY TASK
17:31 25 THESE DAYS TO SUMMARIZE THINGS AND MAKE LISTS. TO AVOID
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1864
17:31 1 CONFUSION IN THE RECORD AND HOPEFULLY STRAIGHTEN IT OUT, WE

17:31 2 SORT OF SCURRIED LAST NIGHT TO PULL ALL THE DEPOSITIONS THAT
17:31 3 KEA SHERMAN HAD BEEN INVOLVED IN.
17:31 4 IN CONNECTION WITH TODAY'S HEARING ON THE MOTION
17:31 5 TO DISQUALIFY COUNSEL, WE WOULD JUST REOFFER AS EXHIBIT 9 TO
17:31 6 OUR OPPOSITION -- BECAUSE THERE WERE EIGHT ATTACHMENTS.
17:31 7 EXHIBIT 9 IS AN ACCUMULATION. IT'S SOME BEFORE AND AFTER, BUT
17:32 8 BASICALLY SEVEN DEPOSITIONS THAT MS. SHERMAN ATTENDED WHILE
17:32 9 EMPLOYED WITH BURGLASS BEFORE HER CHANGE IN EMPLOYMENT AND
17:32 10 EIGHT DEPOSITIONS AFTER HER CHANGE IN EMPLOYMENT ON MAY 1,
17:32 11 2008, WHEN SHE WENT TO WORK FOR THE ANDRY FIRM.
17:32 12 IT LISTS ALL THOSE DEPOSITIONS AND ATTACHES TO
17:32 13 IT THE COVER SHEET AND THE APPEARANCE PAGES FOR EACH ONE OF
17:32 14 THOSE. IT'S HIGHLIGHTED AS TO WHICH ATTORNEYS WERE THERE FOR
17:32 15 THE UNITED STATES. IT'S ALL EXPLANATORY ON THE COVER NOTE FOR
17:32 16 EXHIBIT 9. I WON'T TAKE ANY MORE OF YOUR TIME.
17:32 17 THE COURT: THE GOVERNMENT DOESN'T HAVE AN OBJECTION
17:32 18 TO THAT, OR DO YOU? I DON'T THINK YOU DO.
17:32 19 MR. SMITH: NO, YOUR HONOR.
17:32 20 THE COURT: I THINK YOU HAD ALREADY SAID THAT. I
17:32 21 WANTED TO MAKE SURE.
17:32 22 MR. STEVENS: I ALSO HAVE EXTRA COPIES. I'LL FILE
17:32 23 THE ORIGINAL IN THE MORNING IF YOU WANT.
17:32 24 THE COURT: NO NEED TO. WE HAVE ENOUGH PAPER.
17:32 25 MR. ANDRY: YOUR HONOR, IF I MAY, I TALKED ABOUT AN
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1865
17:33 1 E-MAIL EARLIER. ON SEPTEMBER 23, 2008, AT 12:09 P.M., I

17:33 2 RECEIVED AN E-MAIL FROM ROBIN SMITH. IN THE E-MAIL, MR. SMITH
17:33 3 SAID:
17:33 4 "JON, I'VE BEEN INFORMED THAT AN ATTORNEY FROM
17:33 5 YOUR FIRM HAS BEEN CALLING THE CORPS SEEKING INFORMATION
17:33 6 RELEVANT TO THE KATRINA LITIGATION (ASKING ABOUT THE MRGO
17:33 7 CLOSURE PLAN). ATTACHED IS A VOICE MESSAGE FROM SOMEONE
17:33 8 IDENTIFYING HERSELF AS KEA SHERMAN. IF THIS IS FROM ONE OF
17:33 9 YOUR ATTORNEYS, WILL YOU PLEASE ENSURE THAT THIS DOES NOT
17:33 10 CONTINUE. ALL LITIGATION-RELATED INQUIRIES SHOULD BE MADE TO
17:33 11 DEPARTMENT OF JUSTICE ATTORNEYS, WHO ARE CORPS' LITIGATION
17:33 12 COUNSEL.
17:33 13 "THANKS FOR YOUR COOPERATION. IF YOU HAVE ANY
17:33 14 QUESTION ABOUT THIS OR WISH TO DISCUSS IT, PLEASE DO NOT
17:33 15 HESITATE TO CONTACT ME. ROBIN."
17:33 16 I AM SURE, YOUR HONOR, THAT I RESPONDED TO THAT
17:33 17 E-MAIL. I HAVE DILIGENTLY SEARCHED AND PUT ALL THE PEOPLE IN
17:33 18 MY OFFICE -- I HAVE EVEN OFFERED THEM A BONUS IF THEY WERE ABLE
17:33 19 TO FIND THE E-MAIL THAT I RESPONDED. DUE TO MY INEPTNESS OR
17:33 20 THE COMPUTER PROBLEMS WE HAD, WE WERE UNABLE TO FIND IT.
17:34 21 I CAN REPRESENT TO YOUR HONOR, AS AN OFFICER OF
17:34 22 THE COURT, THAT I DID ADDRESS THIS WITH MR. SMITH AND AT THAT
17:34 23 TIME, UNEQUIVOCABLY, HE KNEW THAT MS. SHERMAN WAS AN ATTORNEY
17:34 24 IN MY OFFICE WELL BEFORE THE TRIAL OF THIS MATTER, PARTICULARLY
17:34 25 YESTERDAY. THIS WAS IN SEPTEMBER OF 2008.
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1866
17:34 1 I WILL PROVIDE THE COURT WITH THE E-MAILS.

17:34 2 UNDERSTANDING THE COURT'S RULING EARLIER, WE WILL JUST PROVIDE
17:34 3 THIS FOR THE PURPOSES OF THE RECORD. THANK YOU, YOUR HONOR.
17:34 5 MR. ROY: I'M NOT SURE WHAT I DID FIVE HOURS AGO MUCH
17:34 6 LESS A YEAR AGO, BUT I DO WANT TO MAKE SURE, IN CONNECTION WITH
17:34 7 THE DIRECT OF DR. KEMP, THAT THE POWERPOINTS THAT WERE REFERRED
17:34 8 TO AND THE PX-S THAT WERE REFERRED TO ARE OFFERED IN CONNECTION
17:34 9 WITH HIS TESTIMONY THAT HAS BEEN GIVEN TODAY.
17:34 10 THE COURT: ANY OBJECTION FROM THE GOVERNMENT? I
17:34 11 KNOW YOU OBJECTED TO -- GO AHEAD, MR. LEVINE.
17:34 12 MR. LEVINE: I HAVE NO OBJECTION EXCEPT FOR THE FACT
17:34 13 THAT THE POWERPOINTS ARE JUST ADMITTED AS DEMONSTRATIVE
17:34 14 EXHIBITS.
17:34 15 MR. ROY: IF THE POWERPOINTS ARE NOT DERIVED FROM THE
17:35 16 PX NUMBER, THEY'RE JUST POWERPOINTS. THEY'RE JUST ILLUSTRATIVE
17:35 17 THINGS. WE HAVE AGREED THAT, SO WHEN WE TALK, IT MAKES SENSE.
17:35 18 THEY'RE ALL IN DEMONSTRATIVELY. I JUST WANTED TO MAKE SURE --
17:35 19 I THINK THERE WAS ONE EXHIBIT WE HAD TO ADD.
17:35 20 THE COURT: LET ME MAKE SURE, FOR THE
17:35 21 RECORD STANDPOINT, ARE YOU OFFERING THEM TO GO INTO THE RECORD?
17:35 22 I JUST WANT TO MAKE SURE.
17:35 23 MR. ROY: I THINK WE AGREED DEMONSTRATIVES GO IN THE
17:35 24 RECORD BUT NOT AS EXHIBITS. THEY GO IN JUST AS DEMONSTRATIVES.
17:35 25 MR. LEVINE: RIGHT. WE'LL BE REFERRING TO THE
FINAL DAILY COPY

1867
17:35 1 POWERPOINT EXHIBITS THROUGHOUT THE --

17:35 2 MR. ROY: YOUR HONOR, WE HAD OFFERED THE POWERPOINTS
17:35 3 REFERRED TO TODAY AS PLAINTIFF DEMONSTRATIVES IN CONNECTION
17:35 4 WITH THIS AND, TO THE EXTENT THEY INCORPORATE ACTUAL PX'S,
17:35 5 OFFER THE PX'S.
17:35 6 MR. LEVINE: I'M CORRECTING MR. SMITH. WE ARE GOING
17:35 7 TO BE TALKING ABOUT THE POWERPOINTS TOMORROW, REFERENCING THEM
17:35 8 BY NUMBER. THEREFORE, SO THAT THE COURT, COURT OF APPEALS, OR
17:36 9 ANYBODY ELSE WHO WANTS TO BE ABLE TO REFERENCE IT --
17:36 10 THE COURT: THAT'S A PRACTICAL WAY OF DOING IT,
17:36 11 UNDERSTANDING THAT THEY ARE LABELED DEMONSTRATIVES, BUT BECAUSE
17:36 12 WE ARE TALKING ABOUT THEM SO MUCH, THOSE THAT DON'T HAVE A PX
17:36 13 NUMBER ASSOCIATED -- BECAUSE WE ARE TALKING ABOUT THEM SO MUCH,
17:36 14 AT LEAST IF SOMEONE IS INCLINED TO LOOK AT THEM, THEY MAY;
17:36 15 UNDERSTANDING THAT UNLESS THEY ARE TIED TO A SPECIFIC ALREADY
17:36 16 INTRODUCED PLAINTIFF EXHIBIT OR DEFENDANT EXHIBIT, THEY ARE
17:36 17 DEMONSTRATIVE.
17:36 18 MR. LEVINE: YES, YOUR HONOR.
17:36 19 THE COURT: THANK YOU VERY MUCH, COUNSEL. WE ARE
17:36 20 ADJOURNED UNTIL TOMORROW AT 9:00 A.M.
17:36 22 (WHEREUPON THE COURT WAS IN RECESS FOR THE EVENING.)
17:36 23 * * *
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FINAL DAILY COPY

1868
1 CERTIFICATE
2 I, TONI DOYLE TUSA, CCR, FCRR, OFFICIAL COURT
3 REPORTER FOR THE UNITED STATES DISTRICT COURT, EASTERN DISTRICT
4 OF LOUISIANA, DO HEREBY CERTIFY THAT THE FOREGOING IS A TRUE
5 AND CORRECT TRANSCRIPT, TO THE BEST OF MY ABILITY AND
6 UNDERSTANDING, FROM THE RECORD OF THE PROCEEDINGS IN THE
7 ABOVE-ENTITLED AND NUMBERED MATTER.
8
9
10 S/ TONI DOYLE TUSA
TONI DOYLE TUSA, CCR, FCRR
11 OFFICIAL COURT REPORTER
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FINAL DAILY COPY

15 [9] 1758/6 1758/9 1762/21 1763/1 23 [5] 1736/13 1736/16 1736/18 1754/14
' 1774/21 1792/19 1793/16 1793/19 1865/1
'07 [2] 1831/9 1831/12 1804/10 24 [3] 1754/4 1754/14 1761/11
'08 [1] 1740/25 15 FEET [2] 1762/5 1814/12 25 [5] 1730/9 1755/11 1755/12 1781/4
'09 [1] 1741/1 15 PERCENT [1] 1853/14 1847/15
'60S [3] 1745/16 1753/24 1844/11 15-SECOND [1] 1794/13 2626 [1] 1724/24
'66 [1] 1855/16 157,000 [1] 1839/19 2655 [1] 1724/10
'70S [2] 1745/17 1753/24 159 [1] 1860/15 27 [2] 1795/17 1830/13
'80S [1] 1856/8 16 [1] 1741/10 28 [5] 1740/24 1767/24 1774/5 1796/12
'88 [2] 1758/15 1766/12 16-SECOND [1] 1792/19 1832/14
'91 [4] 1766/16 1767/19 1767/23 160 [1] 1859/25 29 [6] 1723/7 1727/2 1745/14 1800/22
1855/17 161 [1] 1857/8 1811/16 1831/9
'93 [1] 1761/6 162 [1] 1859/6 2C [22] 1790/8 1833/22 1839/16
'94 [1] 1761/5 163 [3] 1786/3 1786/7 1789/5 1839/22 1839/25 1840/1 1840/9 1847/6
'95 [1] 1761/5 17 FEET [1] 1781/17 1847/16 1847/22 1848/20 1849/1 1849/2
'CRITICAL' [1] 1770/10 17,600 [1] 1851/12 1849/13 1851/1 1851/4 1851/12 1851/14
'GOODNESS' [1] 1768/12 17,600 CUBIC [1] 1847/17 1853/14 1858/16 1861/1 1861/2
1771 [3] 1859/6 1859/25 1860/15 2D [3] 1732/9 1732/21 1827/20
- 18 PERCENT [3] 1849/2 1849/15
-7.1 [1] 1861/14 1849/17 3
185 [1] 1747/16 3 FEET [1] 1861/19
. 19 [2] 1741/1 1833/24 3,600 [1] 1802/8
.1 [1] 1802/17 193 [2] 1761/8 1761/8 30 [6] 1729/23 1767/23 1770/1 1806/24
0 194 [2] 1740/24 1774/5 1806/24 1833/16
195 [1] 1747/16 30 FEET [1] 1762/6
06-CV-2268-K [1] 1723/5 1965 [1] 1835/9 30 PERCENT [9] 1840/19 1841/12
09 [1] 1764/10 1966 [13] 1747/17 1747/22 1748/12 1841/17 1841/19 1847/14 1847/15
1 1749/10 1751/20 1752/12 1752/20 1848/4 1850/12 1850/15
1772/13 1772/16 1816/22 1834/19 31 [1] 1806/24
1,000 [1] 1760/7 1855/24 1862/14 3102 [1] 1724/3
1,640 FEET [1] 1797/17 1967 [1] 1754/7 32 [2] 1807/20 1811/2
1-INCH [2] 1845/2 1845/2 1969 [3] 1756/21 1761/23 1762/3 32 FEET [1] 1758/6
1/2 [6] 1807/11 1813/1 1859/16 1859/17 1973 [4] 1753/19 1754/24 1755/5 32,000 ACRES [1] 1783/12
1860/4 1861/9 1855/24 32,000-ACRE [2] 1823/10 1823/23
1/2-FEET [1] 1860/2 1975 [1] 1729/15 325 [1] 1725/4
1/2-FOOT [1] 1815/7 1980 [1] 1763/4 35 PERCENT [1] 1822/12
10 [12] 1743/13 1747/15 1756/20 1980S [1] 1856/21 354,000 [1] 1839/14
1756/20 1762/11 1773/17 1792/23 1986 [1] 1730/13 36 INCHES [1] 1861/19
1797/22 1798/19 1802/13 1850/1 1987 [1] 1731/10 36-FOOT [1] 1771/12
1859/13 1988 [10] 1757/21 1758/24 1759/9 360 DEGREES [1] 1808/1
10 FEET [1] 1858/2 1760/1 1761/11 1762/9 1765/13 1772/16 3668 [1] 1724/7
10 PERCENT [1] 1854/1 1856/13 1856/18 37 [1] 1754/4
100 [2] 1849/1 1854/25 1990S [2] 1731/5 1759/14
100-YEAR [1] 1754/9 1991 [6] 1766/17 1766/25 1769/2 1769/2
4
1000 [1] 1723/16 1770/1 1770/19 4 FEET [1] 1858/1
10022 [1] 1725/4 1992 [1] 1729/7 4-FOOT [1] 1813/22
101 [4] 1753/8 1753/10 1753/12 1757/8 1993 [1] 1731/10 40 [12] 1749/6 1749/16 1782/20 1782/21
104 [1] 1820/12 1994 [1] 1731/16 1783/8 1783/10 1787/5 1787/11 1787/23
11 [5] 1740/23 1741/13 1746/19 1763/20 1D [1] 1732/9 1791/21 1823/13 1828/5
1837/1 1D/2D [1] 1827/20 406 [1] 1725/20
11 FEET [4] 1747/8 1859/8 1859/13 430,000 [1] 1802/10
1860/3 2 430,000 CUBIC [1] 1839/4
1100 [1] 1724/3 2 FEET [2] 1861/3 1861/16 45 [1] 1844/22
111 [1] 1836/4 2 INCHES [1] 1844/23 45 PERCENT [1] 1822/13
1135 [1] 1771/22 2,000 FEET [2] 1818/8 1818/10 46 [3] 1817/16 1818/11 1818/13
118,000 CUBIC [1] 1847/12 2,300 [4] 1736/3 1736/15 1736/18 47 [2] 1817/24 1818/4
118,300 [1] 1851/12 1736/19 48 [1] 1749/6
12 [2] 1745/22 1747/2 20 [6] 1728/21 1743/14 1762/21 1763/1 4:00 IN [1] 1838/24
12 FEET [4] 1837/1 1850/5 1862/21 1780/3 1785/7
1862/21 20 PERCENT [1] 1853/17
5
12 MILES [1] 1761/2 2003 [1] 1777/7 5 FEET [4] 1804/24 1812/19 1860/6
1205 [1] 1724/24 20044 [1] 1725/18 1860/11
1261 [1] 1724/13 2005 [2] 1738/12 1745/14 5-SECOND [2] 1795/3 1811/11
12:09 P.M [1] 1865/1 2007 [8] 1729/7 1729/7 1735/19 1740/24 50 [2] 1745/4 1772/3
13 FEET [1] 1860/20 1741/10 1774/5 1830/13 1832/14 50 PERCENT [6] 1841/1 1841/19 1842/6
13.6 FEET [1] 1789/19 2008 [6] 1728/2 1740/24 1741/1 1864/11 1850/19 1850/20 1851/6
135 [1] 1846/17 1865/1 1865/25 500 [2] 1724/6 1725/20
136 [2] 1802/15 1802/22 2009 [2] 1723/7 1727/2 504 [1] 1725/21
1366 [1] 1724/14 2082 [1] 1768/7 519 [1] 1724/17
137 [1] 1803/19 2152 [6] 1741/2 1774/12 1774/13 55 [1] 1836/1
14 [6] 1740/25 1741/1 1743/13 1744/7 1816/23 1831/8 1831/12 550 [1] 1723/16
1754/1 1781/18 22 [1] 1728/3 556 [1] 1724/6
14.2 FEET [3] 1782/12 1782/13 1789/21 225 [1] 1728/2 56 [1] 1772/3
142 [1] 1848/12 57 [1] 1818/4
855 [1] 1723/19 1863/13 1864/25 1865/6 1865/14 1867/7
5 86,000 [2] 1847/15 1851/13 1867/12 1867/13
57TH [1] 1725/4 87,000 CUBIC [1] 1847/15 ABOVE [9] 1747/6 1747/8 1781/18
589-7778 [1] 1725/21 888 [1] 1725/18 1791/4 1844/7 1845/24 1847/13 1861/16
5:30 [1] 1830/16 8:00 [6] 1811/13 1811/25 1816/8 1816/9 1868/7
1823/25 1836/10 ABOVE-ENTITLED [1] 1868/7
6 8:00 A.M [1] 1852/24 ABSENCE [2] 1759/11 1773/25
6 FEET [1] 1804/24 8:00 PERIOD [1] 1838/25 ABSOLUTE [1] 1781/5
60 [1] 1802/8 8:30 [4] 1782/24 1785/1 1787/13 ABSOLUTELY [12] 1757/17 1757/18
60-BY-60 [1] 1802/8 1787/13 1779/4 1784/15 1800/17 1814/4 1824/15
600 [1] 1725/7 8:35 [2] 1782/24 1787/7 1825/23 1826/25 1841/7 1856/11
600 FEET [1] 1799/25 8:50 [2] 1789/16 1790/16 1861/23
601 [1] 1724/10 ACADEMY [2] 1733/15 1737/25
604 [1] 1725/7 9 ACCELERATED [1] 1732/2
610 [1] 1723/23 9 FEET [10] 1805/7 1805/10 1807/11 ACCELERATING [2] 1746/16 1825/11
618 [1] 1724/20 1812/7 1812/8 1812/9 1812/15 1812/16 ACCELERATIONS [1] 1807/9
65 [3] 1831/10 1831/11 1831/13 1841/14 1850/6 ACCEPT [3] 1735/6 1788/15 1790/15
650 FEET [3] 1798/16 1817/20 1818/9 9-FOOT [3] 1795/14 1813/21 1815/18 ACCEPTANCE [1] 1770/16
656 [4] 1797/18 1797/18 1797/21 1799/8 90 [1] 1808/25 ACCEPTED [1] 1748/7
656 FEET [2] 1798/17 1799/9 90 PERCENT [1] 1853/25 ACCEPTS [1] 1735/12
656-BY-656-FOOT [1] 1803/2 90-DEGREE [1] 1844/22 ACCORDING [3] 1765/10 1782/23
66 [2] 1817/15 1848/6 90-MILE-AN-HOUR [1] 1795/8 1788/22
66 FEET [3] 1797/25 1801/3 1801/3 90071 [1] 1723/16 ACCUMULATION [1] 1864/7
68 [2] 1748/24 1749/6 91 [25] 1728/2 1734/23 1740/24 1742/10 ACCURATE [2] 1739/17 1777/21
6:00 [2] 1811/13 1813/1 1743/13 1743/13 1743/13 1744/7 ACCURATELY [1] 1783/23
6:00 A.M [3] 1812/10 1812/12 1815/14 1747/15 1753/25 1754/4 1754/4 1755/11 ACCUSATION [1] 1755/17
6:00 AND [1] 1823/25 1757/25 1790/8 1807/20 1831/16 ACCUSATIONS [1] 1757/17
6:00 IN [2] 1813/4 1814/17 1831/22 1832/25 1833/1 1833/12 1836/4 ACCUSED [1] 1757/5
6:00 ON [1] 1811/16 1846/18 1846/19 1848/12 ACCUSING [1] 1767/14
6:35 A.M [1] 1789/19 92 [1] 1740/25 ACHIEVING [1] 1797/8
6:40 [1] 1785/3 93 [1] 1741/1 ACKNOWLEDGED [1] 1764/6
94 [1] 1741/9 ACKNOWLEDGES [2] 1758/5 1763/8
7 97 [1] 1807/21 ACRE [5] 1797/23 1801/3 1802/12
7 FEET [3] 1812/24 1815/4 1861/13 9:00 [4] 1782/17 1811/13 1812/2 1823/10 1823/23
7-FOOT [1] 1813/2 1838/24 ACRES [5] 1783/12 1797/21 1797/22
7.1 [1] 1861/14 9:00 A.M [1] 1867/20 1797/22 1802/13
70 [1] 1814/5 9:30 [1] 1787/8 ACRONYM [2] 1739/25 1740/3
70 ACRES [1] 1797/21 ACROSS [13] 1728/16 1731/6 1754/11
70 PERCENT [1] 1850/13 A 1754/12 1787/11 1798/20 1801/16
70-MILE-AN-HOUR [1] 1812/21 A.M [10] 1789/19 1790/16 1812/3 1810/15 1813/25 1814/5 1819/17
70113 [2] 1723/20 1723/23 1812/10 1812/12 1814/22 1815/14 1836/22 1850/14
70130 [3] 1724/10 1725/8 1725/21 1815/15 1852/24 1867/20 ACT [2] 1766/22 1835/16
702C [2] 1741/10 1774/14 ABILITY [4] 1795/22 1825/20 1843/23 ACTION [3] 1746/8 1758/3 1856/9
70381 [1] 1724/25 1868/5 ACTIVITIES [1] 1739/2
70502 [1] 1724/7 ABLE [10] 1738/23 1750/21 1775/13 ACTUAL [13] 1740/18 1740/18 1745/12
70726 [1] 1724/17 1776/5 1776/17 1808/1 1816/12 1816/17 1787/10 1790/1 1795/19 1801/7 1801/7
70801 [1] 1724/21 1865/18 1867/9 1802/7 1806/17 1831/9 1853/18 1867/4
70821 [1] 1724/14 ABOUT [120] 1730/7 1730/19 1730/25 ACTUALLY [78] 1730/9 1731/3 1732/6
71 [2] 1831/16 1842/17 1731/2 1731/8 1735/21 1737/10 1738/8 1732/19 1732/25 1733/15 1736/6
75 PERCENT [3] 1849/3 1850/5 1850/19 1739/9 1741/4 1741/11 1744/5 1744/13 1737/13 1738/4 1738/10 1747/6 1748/11
75219 [1] 1724/4 1747/24 1748/22 1753/3 1755/8 1758/16 1748/21 1749/20 1750/8 1750/8 1752/5
77 [1] 1822/10 1759/5 1761/5 1762/23 1766/12 1766/18 1754/3 1754/9 1755/4 1756/15 1759/15
7778 [1] 1725/21 1772/9 1772/14 1772/15 1779/11 1767/1 1767/9 1772/6 1774/23 1775/14
79 [1] 1853/15 1779/15 1783/12 1783/14 1785/7 1781/8 1781/9 1781/25 1782/9 1782/12
7:00 [3] 1811/13 1811/21 1815/15 1785/16 1788/12 1789/3 1790/23 1791/4 1786/23 1789/13 1789/20 1791/12
7:00 A.M [1] 1814/22 1791/14 1791/25 1793/16 1793/19 1792/25 1793/20 1795/13 1795/25
7:00 WHAT [1] 1814/23 1797/11 1797/17 1797/20 1797/21 1797/14 1798/23 1800/24 1801/19
7:30 [10] 1785/23 1786/13 1786/21 1799/11 1800/10 1803/9 1804/10 1802/1 1802/3 1803/1 1803/2 1803/8
1787/1 1787/4 1787/12 1787/15 1787/16 1804/13 1805/14 1805/22 1808/12 1803/14 1803/23 1804/4 1806/4 1806/11
1787/21 1787/24 1808/18 1809/19 1812/21 1813/1 1806/19 1807/1 1807/4 1808/1 1808/5
7:30 A.M [1] 1790/16 1813/11 1817/4 1817/23 1818/4 1818/7 1809/24 1817/8 1818/22 1823/9 1824/7
7:40 [1] 1789/22 1818/11 1819/15 1821/2 1821/6 1822/7 1827/25 1829/1 1832/23 1834/5 1834/8
1822/12 1822/13 1823/4 1824/13 1835/22 1838/1 1843/20 1846/12 1847/3
8 1825/15 1832/14 1833/13 1836/8 1847/9 1849/11 1854/11 1854/15
8 FEET [2] 1804/23 1812/25 1839/11 1840/9 1840/19 1841/12 ADAMANTLY [1] 1824/13
8-FOOT [7] 1808/3 1808/5 1808/6 1841/15 1843/10 1843/13 1844/12 ADAPT [2] 1732/21 1733/10
1808/7 1811/10 1814/25 1820/2 1844/21 1847/14 1847/16 1849/20 ADCIRC [21] 1732/22 1739/19 1739/22
8-FOOT-OR-SO [1] 1814/18 1849/22 1850/12 1850/20 1852/18 1740/3 1740/7 1740/8 1740/10 1776/7
80 PERCENT [2] 1847/16 1853/15 1853/15 1853/16 1854/1 1854/22 1858/6 1777/6 1777/8 1777/17 1777/19 1777/24
80,000 CUBIC [1] 1839/11 1858/9 1858/13 1858/15 1859/8 1859/10 1781/22 1781/23 1785/20 1795/22
80-MILE-AN-HOUR [1] 1814/6 1860/6 1860/10 1860/11 1860/20 1861/9 1796/9 1809/25 1838/8 1854/21
800 [1] 1737/1 1861/18 1861/19 1861/19 1862/21 ADCIRC-GENERATED [1] 1796/9
82 PERCENT [1] 1852/24 1862/25 1863/4 1863/12 1863/12 ADD [2] 1813/12 1866/19
85 [1] 1762/3
ALERTED [1] 1779/3 1775/8 1782/4 1785/10 1808/14
A ALIEN [1] 1760/1 ANALYTICAL [5] 1737/4 1832/11
ADDED [3] 1741/2 1741/4 1751/18 ALIGNMENT [2] 1755/18 1820/21 1832/16 1832/23 1835/4
ADDING [3] 1744/25 1750/14 1847/12 ALIGNMENTS [1] 1743/23 ANALYZING [1] 1735/25
ADDITION [5] 1742/5 1750/17 1750/19 ALL [90] 1727/3 1737/10 1739/9 1739/21 AND DR. WESTERINK [1] 1788/5
1751/23 1765/1 1740/3 1740/21 1741/10 1743/1 1744/15 ANDRY [3] 1723/21 1723/22 1864/11
ADDITIONAL [4] 1745/18 1747/20 1751/3 1751/7 1752/4 1752/5 1752/10 ANGELES [1] 1723/16
1759/10 1806/8 1752/25 1754/13 1757/5 1761/1 1766/5 ANGLE [1] 1820/18
ADDITIONALLY [3] 1745/17 1779/8 1766/23 1767/11 1770/19 1771/17 ANIMATED [1] 1773/24
1831/20 1772/1 1773/18 1773/20 1774/8 1776/16 ANNUAL [2] 1758/5 1762/4
ADDITIONS [1] 1752/4 1776/20 1777/17 1780/12 1781/4 1784/9 ANOTHER [9] 1754/2 1782/3 1782/6
ADDITIVE [1] 1750/20 1786/7 1788/14 1788/16 1789/9 1790/2 1792/1 1796/19 1806/17 1811/5 1841/18
ADDRESS [3] 1758/21 1816/2 1865/22 1795/11 1800/10 1801/6 1801/11 1844/20
ADDRESSED [2] 1758/20 1766/15 1805/25 1806/16 1807/18 1808/15 ANSWER [10] 1736/13 1737/6 1787/24
ADDRESSING [2] 1732/10 1832/10 1808/23 1810/1 1814/5 1814/7 1815/18 1796/6 1796/6 1802/19 1809/7 1816/14
ADJACENT [4] 1730/6 1745/3 1746/6 1815/24 1815/24 1816/19 1818/1 1816/17 1857/22
1843/7 1818/15 1818/24 1819/14 1821/9 ANSWERING [2] 1791/16 1857/13
ADJOURNED [1] 1867/20 1822/18 1825/17 1827/21 1827/24 ANSWERS [2] 1848/7 1858/24
ADJOURNMENT [1] 1830/21 1829/20 1830/23 1830/25 1831/18 ANTHONY [1] 1859/24
ADJUST [2] 1780/20 1785/20 1831/20 1831/21 1836/22 1836/24 ANY [36] 1737/7 1742/10 1742/11
ADJUSTED [4] 1782/13 1786/12 1838/9 1838/18 1842/14 1843/24 1742/16 1751/2 1752/21 1752/22
1786/20 1790/4 1843/24 1847/13 1848/13 1852/19 1756/13 1757/1 1769/20 1769/21
ADJUSTING [1] 1783/20 1854/24 1861/21 1862/4 1863/13 1864/2 1778/25 1790/1 1794/6 1798/5 1798/8
ADJUSTMENT [1] 1789/24 1864/12 1864/15 1865/10 1865/17 1810/10 1817/20 1821/10 1821/14
ADMISSION [1] 1767/25 1866/18 1867/21 1821/14 1832/1 1835/10 1835/10 1841/8
ADMITTED [2] 1773/4 1866/13 ALLOCATING [1] 1863/3 1847/22 1848/17 1852/20 1854/20
ADVANCED [2] 1740/5 1786/25 ALLOW [8] 1749/7 1782/3 1797/4 1855/8 1856/6 1860/13 1862/16 1864/16
ADVANTAGES [1] 1838/3 1801/16 1807/4 1808/15 1832/6 1857/20 1865/13 1866/10
ADVISED [1] 1856/9 ALMOST [6] 1729/23 1764/16 1789/23 ANYBODY [2] 1742/14 1867/9
AERIAL [1] 1762/3 1801/6 1820/18 1824/5 ANYONE [3] 1755/17 1757/18 1798/3
AFFECTED [3] 1810/12 1825/20 ALONG [37] 1744/3 1744/15 1749/16 ANYTHING [4] 1750/12 1759/17 1833/4
1837/17 1749/16 1750/19 1758/11 1758/13 1843/10
AFFILIATES [1] 1776/23 1759/15 1760/12 1760/21 1760/25 ANYWAY [3] 1774/14 1852/6 1862/23
AFOREMENTIONED [1] 1765/2 1762/4 1762/19 1766/19 1769/21 ANYWHERE [3] 1830/11 1840/17
AFRAID [1] 1863/7 1771/14 1784/9 1789/10 1804/8 1804/25 1857/17
AFTER [14] 1734/7 1738/12 1748/12 1805/18 1805/25 1806/20 1807/5 1807/7 APOLOGIZE [3] 1734/11 1830/7
1748/15 1753/3 1764/3 1783/19 1791/14 1807/16 1809/18 1811/9 1817/13 1856/22
1819/15 1827/24 1833/16 1838/19 1817/14 1818/25 1821/12 1821/15 APPARENTLY [1] 1790/5
1864/7 1864/10 1822/18 1826/21 1827/3 1846/20 APPEAL [1] 1863/5
AFTERMATH [1] 1738/7 ALREADY [8] 1769/11 1770/21 1783/8 APPEALS [2] 1863/7 1867/8
AFTERNOON [2] 1723/10 1727/1 1809/19 1857/19 1857/21 1864/20 APPEAR [1] 1798/22
AFTERWARDS [1] 1739/11 1867/15 APPEARANCE [1] 1864/13
AGAIN [19] 1730/25 1738/22 1740/13 ALSO [38] 1725/6 1729/21 1739/1 APPEARANCES [3] 1723/13 1724/1
1754/23 1757/8 1764/18 1793/25 1743/17 1744/23 1747/9 1749/19 1753/8 1725/1
1798/14 1800/14 1803/1 1806/17 1809/3 1757/25 1758/13 1758/15 1761/14 APPEARED [1] 1754/7
1811/15 1812/23 1815/18 1828/1 1832/7 1762/24 1765/5 1765/7 1767/7 1769/10 APPEARS [1] 1786/22
1856/16 1863/1 1775/25 1776/3 1780/8 1791/6 1791/13 APPENDIX [2] 1740/25 1761/17
AGAINST [2] 1771/6 1825/23 1797/5 1804/24 1807/22 1815/3 1815/20 APPLICATION [2] 1732/9 1733/21
AGENCIES [1] 1739/8 1817/3 1819/23 1820/17 1822/22 APPLICATIONS [1] 1842/11
AGENCY [1] 1733/7 1827/19 1831/16 1838/5 1838/5 1840/23 APPLIED [2] 1733/10 1776/3
AGENT [1] 1813/14 1841/18 1864/22 APPLY [4] 1748/7 1776/17 1777/10
AGGRAVATED [3] 1748/9 1835/13 ALTERNATIVE [2] 1754/8 1764/19 1819/7
1846/5 ALTERNIFLORA [2] 1763/24 1764/1 APPLYING [1] 1817/9
AGO [5] 1766/3 1825/25 1826/17 1866/5 ALTHOUGH [2] 1788/14 1843/9 APPRECIATE [1] 1761/21
1866/6 ALWAYS [1] 1751/4 APPRECIATION [1] 1756/3
AGREE [11] 1790/25 1791/6 1809/10 AM [6] 1728/8 1797/10 1820/15 1824/18 APPROACH [7] 1741/23 1750/22 1757/1
1826/5 1826/11 1826/14 1826/20 1827/2 1857/20 1865/16 1809/4 1832/23 1834/22 1835/4
1828/9 1845/25 1856/3 AMERICA [1] 1723/7 APPROPRIATE [3] 1763/16 1797/6
AGREED [4] 1786/4 1794/9 1866/17 AMIN [1] 1725/11 1862/14
1866/23 AMONG [7] 1731/19 1731/22 1731/23 APPROXIMATELY [3] 1762/11 1782/24
AGREEMENT [2] 1791/1 1809/13 1780/6 1791/1 1826/5 1833/10 1812/10
AHA [1] 1753/11 AMOUNT [7] 1778/20 1810/24 1814/7 APRIL [2] 1723/7 1727/2
AHEAD [13] 1740/10 1765/22 1774/3 1819/1 1825/13 1843/21 1861/21 ARE [182]
1786/25 1800/23 1802/20 1822/25 AMPLE [1] 1772/22 AREA [46] 1727/21 1727/22 1736/1
1824/8 1824/21 1829/4 1833/20 1842/4 AMPLIFICATION [2] 1775/7 1778/9 1742/9 1744/3 1744/4 1744/15 1747/5
1866/11 AMPLIFIED [3] 1742/8 1779/9 1779/20 1751/7 1751/12 1754/10 1758/14 1759/4
AIMED [1] 1845/3 AMPLIFIES [1] 1779/6 1766/13 1778/16 1778/18 1778/20
AIR [1] 1738/14 AMPLIFYING [1] 1778/13 1783/9 1783/12 1793/21 1794/13 1795/1
AL [3] 1723/5 1723/7 1755/20 AN INTERNAL [1] 1765/15 1795/14 1796/11 1797/15 1801/23
ALABAMA [2] 1834/3 1834/14 ANALOGOUS [3] 1813/19 1834/24 1803/11 1808/2 1808/3 1810/16 1812/11
ALARMING [1] 1760/20 1854/13 1817/21 1819/8 1819/18 1821/2 1821/21
ALBEIT [1] 1821/25 ANALOGY [3] 1797/6 1819/16 1842/19 1825/17 1825/19 1828/4 1828/5 1837/23
ALERT [3] 1733/1 1772/23 1773/23 ANALYSIS [7] 1731/24 1747/19 1774/20 1843/21 1846/5 1850/23 1853/23
ASSOCIATE [1] 1729/8 1770/15 1770/25 1772/1 1826/12
A ASSOCIATED [5] 1751/24 1813/14 1855/10
AREA... [1] 1861/15 1821/23 1822/23 1867/13 BARON [1] 1724/2
AREAS [15] 1735/6 1742/5 1746/18 ASSOCIATES [2] 1723/15 1724/12 BARONNE [2] 1723/19 1723/23
1747/9 1751/16 1765/6 1769/11 1770/12 ASSOCIATES' [1] 1858/25 BARRIER [4] 1754/10 1763/14 1763/16
1771/15 1775/13 1795/23 1825/14 ASSUME [1] 1862/21 1862/13
1843/8 1843/12 1849/23 ASSUMING [5] 1808/16 1841/24 BASE [2] 1780/21 1839/5
AREN'T [2] 1816/4 1829/5 1858/12 1860/9 1863/19 BASED [14] 1747/19 1748/19 1756/16
ARGUE [1] 1824/18 ASSUMPTION [4] 1752/23 1752/23 1756/22 1764/23 1776/18 1777/11
ARMCHAIR [1] 1748/18 1833/23 1834/13 1777/12 1781/2 1783/17 1806/17
ARMOR [2] 1759/23 1764/6 ASSUMPTIONS [1] 1776/18 1855/21 1862/5 1862/6
ARMORED [1] 1826/12 AT [230] BASES [1] 1741/21
ARMORING [4] 1759/9 1759/25 1760/5 ATCHAFALAYA [2] 1731/7 1732/11 BASIC [2] 1757/15 1799/11
1760/12 ATTACHED [3] 1741/7 1848/16 1865/7 BASICALLY [8] 1743/16 1795/1 1803/20
ARMY [5] 1732/9 1742/13 1742/16 ATTACHES [1] 1864/12 1805/15 1814/24 1842/20 1843/22
1768/1 1773/3 ATTACHMENTS [1] 1864/6 1864/8
AROUND [18] 1730/6 1737/1 1747/8 ATTACK [3] 1790/14 1821/17 1822/13 BASIS [1] 1756/12
1758/9 1763/3 1785/1 1785/3 1786/13 ATTEMPT [1] 1819/10 BATHTUB [9] 1778/22 1778/24 1778/25
1786/21 1804/22 1804/23 1807/11 ATTENDED [1] 1864/8 1838/17 1842/15 1842/19 1843/13
1807/11 1817/16 1819/24 1837/14 ATTENTION [2] 1761/20 1847/7 1843/22 1844/6
1840/18 1851/14 ATTENUATE [1] 1825/21 BATHYMETRY [1] 1801/12
ARPENT [11] 1749/16 1782/20 1782/21 ATTORNEY [3] 1796/22 1865/4 1865/23 BATON [3] 1724/14 1724/21 1729/10
1783/8 1783/10 1787/5 1787/11 1787/23 ATTORNEYS [4] 1736/12 1864/14 BATON ROUGE [1] 1729/10
1791/21 1823/13 1828/5 1865/9 1865/11 BAYOU [1] 1763/15
ARRIVE [1] 1786/13 ATTORNEYS' [1] 1797/1 BAYOU LA LOUTRE [1] 1763/15
ARRIVED [1] 1816/20 ATTRIBUTABLE [3] 1737/13 1775/14 BAYOUS [1] 1765/8
ARROWS [2] 1812/4 1815/6 1784/5 BE [127] 1727/4 1728/11 1729/19
ARTICULATE [1] 1800/4 AUDUBON [1] 1729/6 1729/24 1734/21 1738/9 1739/6 1739/16
ARTICULATED [2] 1760/4 1833/10 AUGMENTED [1] 1742/5 1740/20 1740/21 1741/2 1741/4 1743/22
ARTIFACT [1] 1804/12 AUGUST [2] 1745/14 1811/16 1744/3 1744/5 1748/22 1751/11 1757/13
ARTIFICIAL [2] 1843/3 1843/4 AUGUST 29 [2] 1745/14 1811/16 1757/13 1757/19 1757/19 1760/6
AS [144] 1727/12 1728/2 1728/6 AUTHOR [3] 1734/5 1734/8 1734/10 1760/17 1762/11 1762/14 1763/9 1764/1
1729/16 1730/24 1732/13 1732/20 AUTHORITY [1] 1771/23 1764/20 1764/20 1765/10 1765/11
1733/9 1733/12 1734/16 1734/21 AUTHORIZED [5] 1745/10 1745/11 1766/15 1766/16 1767/11 1767/12
1734/23 1735/6 1735/13 1735/20 1798/16 1839/9 1839/10 1769/7 1769/16 1771/19 1773/21 1774/4
1735/20 1736/8 1736/8 1738/3 1738/3 AVAILABLE [4] 1758/24 1790/19 1798/1 1774/13 1776/5 1777/20 1779/2 1779/19
1738/24 1738/25 1740/7 1740/19 1741/7 1798/3 1779/21 1785/10 1786/14 1787/6 1787/8
1741/11 1745/13 1747/10 1747/13 AVENUE [3] 1724/3 1724/17 1826/18 1787/24 1788/13 1788/16 1792/2
1749/24 1751/17 1752/22 1753/9 1755/2 AVERAGE [4] 1747/6 1758/9 1803/6 1792/18 1795/12 1796/1 1796/25 1797/6
1755/4 1757/14 1758/23 1759/2 1764/4 1838/20 1798/1 1798/18 1802/5 1803/25 1804/7
1764/9 1764/9 1772/3 1772/16 1772/17 AVERTING [1] 1826/7 1804/18 1805/12 1805/14 1805/15
1772/18 1774/21 1774/21 1775/3 1775/3 AVOID [1] 1863/25 1805/21 1805/22 1808/15 1810/11
1777/1 1777/5 1777/24 1777/24 1778/6 AWARE [6] 1747/17 1747/21 1758/1 1810/14 1810/16 1812/13 1814/23
1779/14 1779/15 1781/25 1782/1 1764/5 1772/13 1773/12 1817/22 1817/25 1818/3 1819/24 1821/2
1782/11 1786/5 1786/20 1788/15 1789/2 AWAY [1] 1814/10 1822/8 1823/3 1824/20 1826/3 1828/8
1790/7 1790/14 1790/25 1791/2 1792/9 AWFUL [1] 1748/22 1829/16 1829/17 1829/25 1830/5
1792/18 1794/25 1795/4 1798/2 1799/25 AXIS [2] 1817/17 1846/21 1830/19 1830/20 1830/21 1831/1
1801/17 1805/2 1805/12 1805/13 1835/16 1835/20 1837/2 1840/5 1841/14
1809/17 1810/11 1810/14 1810/18 B 1841/15 1841/19 1841/20 1844/17
1810/18 1812/21 1814/10 1815/4 BACK [49] 1731/5 1734/2 1735/19 1847/22 1848/6 1850/6 1852/8 1853/12
1816/23 1818/24 1819/5 1819/5 1819/9 1736/8 1741/21 1744/5 1744/12 1751/19 1854/13 1856/10 1858/11 1858/19
1819/18 1822/21 1822/22 1823/20 1754/7 1759/6 1760/1 1765/24 1766/6 1858/21 1858/24 1859/21 1861/12
1827/8 1827/19 1828/11 1829/15 1830/1 1776/17 1779/10 1779/13 1779/22 1861/13 1861/14 1863/7 1863/11
1831/17 1831/20 1831/25 1833/15 1782/10 1784/10 1790/12 1791/18 1863/13 1863/13 1863/22 1865/10
1833/23 1833/23 1834/2 1834/7 1834/20 1807/23 1813/10 1813/23 1815/8 1866/25 1867/7 1867/9
1835/8 1835/11 1835/13 1835/16 1836/9 1819/14 1830/21 1832/20 1834/11 BEA [24] 1737/23 1737/24 1759/5
1838/17 1840/10 1841/4 1843/1 1843/2 1834/12 1835/5 1835/5 1835/19 1839/8 1775/9 1776/16 1789/4 1790/14 1801/21
1843/6 1844/10 1846/1 1846/1 1846/23 1839/16 1840/19 1840/24 1841/13 1814/21 1816/12 1816/12 1820/6 1822/5
1852/8 1852/12 1853/22 1855/16 1846/3 1846/13 1848/17 1851/10 1822/9 1822/11 1826/25 1827/7 1827/11
1855/16 1856/5 1856/12 1856/17 1851/14 1851/19 1852/16 1853/4 1828/12 1832/17 1851/5 1858/10
1856/20 1856/20 1856/21 1856/22 1854/17 1854/18 1861/17 1858/16 1860/10
1862/7 1864/5 1864/14 1865/8 1865/21 BACK-AND-FORTH [1] 1766/6 BEA'S [1] 1794/18
1866/13 1866/24 1866/24 1867/3 BACK-SIDE [1] 1791/18 BEACH [3] 1793/18 1793/19 1813/5
ASHLEY [1] 1725/6 BACKED [1] 1842/11 BEADS [1] 1804/9
ASIDE [1] 1863/5 BACKFILL [1] 1774/12 BEAT [1] 1852/3
ASK [11] 1727/16 1735/5 1757/4 1786/1 BAEZA [1] 1725/10 BECAME [2] 1775/18 1777/7
1788/1 1788/9 1800/14 1830/15 1832/5 BANK [19] 1757/21 1758/2 1759/13 BECAUSE [62] 1731/19 1733/17
1854/22 1862/11 1759/15 1759/16 1759/18 1759/22 1738/25 1739/8 1739/15 1739/16 1741/3
ASKING [1] 1865/6 1760/7 1760/22 1762/5 1762/5 1766/23 1749/13 1749/25 1751/1 1755/22
ASSIGNED [1] 1848/23 1768/1 1768/12 1769/19 1771/6 1826/15 1766/23 1767/2 1767/6 1774/14 1778/7
ASSIGNMENT [4] 1732/8 1733/13 1826/16 1855/11 1780/20 1782/3 1784/12 1786/22
1737/3 1737/4 BANKS [13] 1759/9 1759/25 1760/12 1787/24 1788/21 1788/24 1789/1
ASSIMILATE [1] 1849/6 1762/6 1764/6 1768/13 1768/17 1769/6 1790/23 1794/9 1797/19 1798/10
1769/23 1775/25 1788/4 1788/7 1789/15 1781/24 1782/5 1782/6 1783/14 1784/6
B 1794/4 1794/15 1803/14 1805/7 1805/9 1784/9 1784/13 1821/10 1821/14
BECAUSE... [34] 1798/21 1802/4 1803/3 1812/8 1812/9 1812/24 1812/25 1815/4 1821/21 1821/22 1821/23 1823/19
1803/15 1804/24 1805/2 1805/18 1807/2 1817/13 1817/19 1817/21 1818/7 1823/21 1823/25 1827/25 1828/2 1828/3
1808/24 1810/1 1810/14 1813/13 1823/25 1825/13 1826/17 1861/6 1850/13 1850/15 1858/10 1858/12
1813/16 1813/22 1814/12 1822/19 BEYOND [2] 1770/7 1829/9 1862/15 1862/17
1825/16 1836/20 1838/16 1840/23 BIENVENUE [1] 1765/9 BREACHING [22] 1739/14 1747/12
1843/3 1843/20 1844/7 1848/24 1853/9 BIG [9] 1775/12 1796/25 1799/5 1799/5 1775/8 1775/11 1783/23 1789/17
1853/22 1857/1 1858/8 1858/15 1860/4 1819/19 1845/22 1845/23 1862/12 1816/15 1832/19 1833/18 1840/17
1860/18 1864/6 1867/11 1867/13 1863/1 1840/23 1841/8 1841/18 1848/3 1850/12
BECNEL [4] 1754/24 1755/4 1755/9 BIGGER [2] 1800/16 1814/25 1850/23 1851/2 1853/9 1853/19 1853/20
1757/7 BIGGEST [1] 1826/9 1858/16 1858/16
BECNEL'S [1] 1755/14 BIOLOGISTS [1] 1769/11 BREACHINGS [1] 1851/19
BECOME [3] 1763/2 1810/18 1863/24 BIT [7] 1785/20 1791/24 1814/11 BREAK [2] 1772/9 1831/16
BEEN [53] 1727/11 1729/3 1730/1 1818/11 1838/22 1845/11 1849/5 BREAKING [2] 1773/11 1793/18
1730/19 1734/5 1736/24 1739/16 1741/3 BITS [1] 1783/17 BRENDAN [1] 1725/3
1748/1 1752/24 1754/17 1759/14 1768/1 BLACK [4] 1789/10 1799/5 1799/17 BRETON [1] 1762/20
1768/23 1769/11 1769/21 1772/17 1803/20 BRETSCHNEIDER [7] 1748/13 1750/20
1773/24 1774/11 1794/6 1805/22 1809/6 BLANK [1] 1823/22 1753/1 1774/24 1834/19 1834/23
1816/17 1816/19 1816/21 1819/20 BLOCKING [1] 1763/10 1845/20
1826/16 1826/23 1828/2 1828/18 1833/6 BLOW [4] 1796/16 1812/14 1836/14 BRIDGE [7] 1743/21 1826/17 1836/7
1833/9 1834/2 1834/14 1845/13 1847/24 1847/8 1837/14 1837/24 1845/9 1846/5
1850/20 1854/23 1855/15 1857/19 BLOW-UP [1] 1836/14 BRIDGES [2] 1836/22 1836/23
1858/9 1859/17 1859/20 1861/2 1861/9 BLOWING [2] 1733/18 1813/13 BRIEF [4] 1756/11 1773/19 1830/24
1862/5 1862/16 1862/19 1863/4 1864/3 BLOWUP [1] 1803/19 1863/6
1865/4 1865/5 1866/9 BLUE [4] 1789/19 1801/13 1846/22 BRIEFING [2] 1767/23 1863/4
BEFORE [26] 1723/10 1731/3 1736/4 1859/14 BRIEFLY [1] 1741/21
1736/11 1740/16 1744/9 1745/11 BOAT [2] 1738/20 1738/21 BROWN [1] 1812/7
1745/13 1745/16 1783/10 1789/1 BOATS [1] 1733/18 BROWNER [1] 1801/12
1790/15 1790/24 1799/3 1802/7 1813/1 BOB [1] 1832/17 BRUNO [2] 1723/18 1723/18
1822/23 1823/2 1823/13 1826/3 1828/7 BODIES [1] 1804/3 BS [1] 1730/13
1851/1 1854/17 1864/7 1864/9 1865/24 BODY [5] 1728/17 1732/3 1748/3 BUCKET [1] 1767/5
BEFUDDLED [1] 1850/21 1758/24 1762/18 BUDD [1] 1724/2
BEGAN [2] 1736/4 1857/1 BONUS [1] 1865/18 BUDGET [1] 1771/24
BEGIN [2] 1738/24 1782/5 BOOK [1] 1774/8 BUFFER [3] 1746/4 1746/17 1825/13
BEGINNING [1] 1741/5 BOOTS [3] 1738/18 1738/20 1738/21 BUFFERING [1] 1742/7
BEGINS [1] 1814/15 BORGNE [36] 1746/5 1746/15 1746/18 BUFFERS [1] 1834/9
BEHALF [2] 1737/2 1756/5 1755/19 1759/22 1762/15 1763/2 1764/1 BUILD [1] 1810/17
BEHIND [3] 1756/12 1808/20 1816/1 1769/17 1769/24 1792/10 1792/21 BUILDING [3] 1795/5 1795/7 1815/16
BEING [16] 1735/23 1736/11 1736/23 1792/24 1792/25 1794/25 1801/17 BUILDUP [1] 1732/2
1739/1 1754/6 1754/9 1757/5 1763/14 1803/9 1803/22 1803/23 1803/24 1804/4 BUILT [11] 1731/25 1747/21 1752/24
1763/15 1763/16 1769/9 1803/22 1814/6 1806/13 1807/14 1807/16 1810/15 1753/5 1778/6 1820/25 1821/7 1833/25
1834/13 1840/9 1846/3 1812/13 1812/16 1813/3 1813/17 1815/6 1834/2 1845/7 1845/16
BELIEF [1] 1794/12 1819/18 1820/16 1825/13 1826/12 BUOY [1] 1807/8
BELIEVE [22] 1741/2 1741/12 1761/5 1826/15 1826/17 BUOYS [3] 1807/4 1807/8 1808/2
1761/16 1764/12 1764/14 1771/15 BORROW [1] 1819/19 BURGLASS [1] 1864/9
1774/11 1785/2 1785/4 1785/22 1804/22 BOTH [19] 1732/16 1737/17 1737/24 BUSINESS [1] 1769/8
1808/7 1822/5 1823/24 1829/16 1831/7 1751/25 1762/6 1763/18 1769/21 1775/3 BUSY [1] 1848/11
1831/9 1852/12 1856/9 1857/17 1858/10 1794/5 1806/12 1822/16 1825/21 BUT [150]
BELIEVED [2] 1767/20 1827/13 1826/12 1826/19 1826/22 1852/13
BENCHMARK [2] 1772/14 1835/8 1855/10 1856/12 1856/17 C
BENCHMARKS [1] 1784/20 BOTHER [1] 1808/23 CAFFEINE [2] 1773/22 1773/25
BEND [1] 1819/23 BOTTOM [22] 1732/3 1749/18 1752/8 CALCULATE [1] 1835/23
BENEFICIAL [1] 1826/14 1766/11 1781/12 1789/11 1793/2 CALCULATED [1] 1805/5
BENEFICIALLY [1] 1767/12 1797/13 1799/23 1803/10 1807/7 CALCULATING [1] 1863/1
BENEFIT [2] 1740/17 1765/11 1810/18 1811/24 1811/25 1812/1 1814/8 CALCULATION [1] 1797/20
BENIGN [1] 1752/24 1814/17 1818/1 1836/14 1844/25 CALIBRATE [2] 1772/10 1780/16
BENJAMIN [1] 1725/17 1846/20 1852/24 CALIBRATING [1] 1773/14
BENT [1] 1743/18 BOULEVARD [1] 1724/24 CALIBRATION [1] 1823/16
BERMS [2] 1742/6 1746/6 BOUNDARY [1] 1796/18 CALIFORNIA [1] 1723/16
BERNARD [13] 1738/19 1747/5 1747/5 BOUNDED [1] 1843/3 CALIPERS [1] 1818/23
1783/9 1820/4 1823/18 1824/14 1853/2 BOURGEOIS [1] 1828/12 CALL [11] 1727/8 1759/16 1760/10
1853/6 1853/10 1854/25 1857/7 1858/25 BOX [7] 1724/7 1724/14 1724/24 1760/12 1789/24 1799/18 1820/18
BEST [6] 1738/17 1824/18 1825/23 1725/18 1799/12 1799/17 1799/17 1829/18 1842/15 1847/7 1849/14
1827/17 1855/5 1868/5 BOXES [1] 1796/15 CALLED [8] 1730/19 1733/23 1741/10
BET [1] 1852/10 BRACKISH [1] 1769/13 1744/3 1744/23 1754/5 1804/9 1832/16
BETSY [4] 1748/12 1748/16 1749/21 BRANCH [3] 1725/10 1728/14 1761/12 CALLING [2] 1761/20 1865/5
1756/20 BRANCHES [1] 1731/6 CALVIN [1] 1724/16
BETTER [12] 1730/9 1760/11 1778/1 BREACH [9] 1782/3 1782/15 1790/13 CAME [7] 1729/16 1730/11 1733/13
1797/7 1797/8 1800/10 1800/12 1800/16 1824/23 1859/15 1860/5 1860/9 1860/12 1739/9 1748/12 1801/17 1853/25
1804/16 1808/5 1809/20 1837/5 1862/22 CAMERA [5] 1782/19 1782/23 1785/11
BETWEEN [30] 1729/7 1744/22 1746/17 BREACHED [1] 1746/9 1787/7 1797/8
1747/16 1760/22 1766/21 1769/22 BREACHES [27] 1763/3 1775/1 1775/12 CAMILLE [1] 1756/21
CERTAIN [6] 1780/2 1791/5 1791/9 1799/4 1815/13 1831/19
C 1798/10 1808/17 1832/11 CLIMATE [1] 1792/10
CAMPAIGN [1] 1738/16 CERTAINLY [10] 1748/21 1761/6 CLOSE [16] 1764/19 1782/14 1782/21
CAN [77] 1736/23 1740/21 1742/21 1764/17 1791/17 1833/9 1837/20 1799/13 1799/14 1803/12 1804/5
1743/2 1743/3 1743/5 1743/20 1746/24 1851/25 1854/20 1855/2 1855/6 1811/25 1817/15 1818/4 1830/19
1752/17 1755/11 1761/6 1763/23 CERTAINTY [2] 1781/6 1862/7 1836/11 1859/2 1860/3 1860/5 1861/14
1763/24 1764/5 1764/6 1770/23 1771/19 CERTIFICATE [1] 1868/1 CLOSELY [2] 1734/9 1836/25
1774/21 1778/18 1780/17 1782/5 CERTIFY [1] 1868/4 CLOSER [4] 1787/2 1796/24 1807/17
1783/10 1786/2 1788/22 1789/1 1789/25 CHALMETTE [1] 1823/6 1818/11
1791/10 1791/11 1791/17 1795/22 CHAMBER [1] 1731/11 CLOSING [1] 1763/11
1796/3 1796/14 1796/16 1797/19 CHANCE [3] 1765/18 1765/25 1798/19 CLOSURE [3] 1765/2 1765/5 1865/7
1797/24 1798/19 1802/22 1806/25 CHANGE [7] 1751/3 1778/8 1819/13 COAST [5] 1729/5 1729/9 1729/14
1809/1 1809/20 1812/14 1812/17 1845/22 1845/23 1864/9 1864/10 1729/22 1751/6
1812/21 1816/2 1817/1 1817/5 1817/20 CHANGED [3] 1789/14 1794/13 1826/4 COASTAL [19] 1727/22 1727/23
1817/23 1818/8 1820/6 1820/14 1825/5 CHANGES [3] 1751/8 1814/7 1845/21 1729/13 1730/15 1730/22 1730/22
1828/4 1828/19 1829/2 1830/17 1832/5 CHANGING [3] 1733/19 1750/25 1732/13 1732/15 1735/7 1735/9 1766/22
1833/23 1835/10 1836/10 1836/25 1838/17 1767/2 1767/7 1767/10 1772/5 1827/8
1837/5 1838/4 1838/5 1842/17 1842/19 CHANNEL [73] 1732/7 1743/22 1744/2 1835/9 1835/11 1842/24
1842/20 1843/19 1844/7 1846/9 1849/5 1745/12 1745/13 1745/20 1746/3 CODED [1] 1815/25
1849/6 1849/7 1853/4 1856/16 1863/14 1746/14 1750/12 1750/18 1751/14 CODING [1] 1847/2
1865/21 1751/19 1751/24 1752/24 1754/12 COINCIDE [1] 1788/10
CAN'T [6] 1757/11 1796/23 1798/8 1755/7 1756/4 1756/24 1758/1 1759/9 COLLAPSE [1] 1790/13
1828/19 1835/15 1843/3 1760/20 1760/22 1763/10 1763/11 COLLEAGUE [1] 1732/24
CANAL [9] 1732/6 1744/23 1751/10 1764/24 1767/12 1769/22 1769/23 COLLEAGUES [1] 1743/6
1858/10 1858/12 1859/15 1860/5 1860/9 1770/17 1770/20 1770/21 1771/12 COLLECTED [1] 1740/12
1860/12 1775/7 1775/7 1798/16 1798/25 1801/13 COLLECTING [1] 1730/2
CANNOT [1] 1800/4 1801/16 1801/18 1801/19 1804/8 COLLINS [6] 1748/13 1750/21 1774/24
CAPABILITIES [1] 1775/19 1804/12 1804/14 1805/3 1805/4 1805/11 1834/19 1834/23 1845/21
CAPABILITY [1] 1776/6 1805/16 1805/24 1812/17 1813/2 COLLINS' [1] 1753/2
CAPABLE [2] 1776/3 1838/8 1813/25 1814/14 1818/8 1820/24 COLOR [5] 1801/13 1812/8 1812/8
CAPACITY [3] 1732/20 1823/11 1827/8 1825/10 1826/21 1826/24 1832/18 1812/23 1847/1
CAPS [1] 1740/3 1833/25 1834/6 1836/11 1836/15 COLORS [4] 1801/12 1804/2 1815/24
CAPTURE [2] 1796/3 1809/24 1837/13 1838/11 1839/8 1839/9 1839/17 1815/24
CAREFULLY [2] 1748/22 1781/16 1839/22 1843/12 1843/14 1843/19 COLUMN [2] 1838/23 1848/15
CARL [14] 1749/1 1761/8 1761/22 1843/22 1847/21 COLUMNS [1] 1839/1
1762/10 1763/19 1764/10 1768/7 1768/7 CHANNELS [10] 1733/16 1742/4 COMBINED [2] 1779/19 1853/6
1768/15 1770/8 1770/14 1771/2 1772/6 1743/16 1743/24 1750/19 1779/5 1780/9 COME [23] 1744/12 1771/23 1776/17
1817/6 1780/10 1801/1 1838/5 1783/10 1785/12 1787/5 1787/16
CARONDELET [1] 1725/7 CHAPTER [6] 1747/15 1747/16 1790/7 1787/23 1791/13 1796/5 1804/4 1805/2
CARPETS [1] 1859/20 1831/22 1832/9 1833/12 1808/13 1808/21 1810/14 1813/18
CARRIED [1] 1733/10 CHARACTERISTIC [1] 1744/15 1816/17 1827/21 1832/18 1835/5
CARRIES [1] 1844/25 CHARACTERISTICS [1] 1798/22 1839/16 1843/1 1857/1
CARRY [1] 1844/23 CHARACTERIZATION [1] 1796/11 COMES [11] 1734/1 1751/9 1784/21
CASE [24] 1730/19 1734/20 1736/12 CHARACTERIZE [1] 1805/12 1793/22 1793/22 1813/9 1838/17
1750/8 1750/8 1750/11 1750/24 1751/5 CHARACTERIZED [1] 1801/23 1850/10 1850/11 1850/13 1854/17
1751/6 1762/15 1778/12 1788/13 CHART [5] 1782/17 1848/8 1849/6 COMFORTABLE [1] 1791/16
1792/15 1796/8 1798/14 1812/6 1812/20 1852/3 1853/4 COMING [26] 1738/7 1744/5 1765/6
1812/23 1814/13 1824/19 1838/14 CHASE [2] 1767/17 1796/12 1778/13 1778/20 1782/22 1783/8
1855/3 1856/15 1860/25 CHIEF [2] 1754/25 1761/12 1787/11 1791/12 1792/22 1795/1
CASES [3] 1737/8 1750/13 1801/14 CHOICE [1] 1774/1 1808/16 1808/22 1813/7 1813/16 1815/6
CATASTROPHIC [7] 1746/21 1747/18 CHOSE [1] 1758/21 1819/17 1823/19 1836/7 1836/11
1747/22 1758/16 1759/3 1765/6 1766/13 CHOSEN [2] 1772/22 1787/1 1837/11 1837/12 1844/8 1850/15
CATEGORICALLY [1] 1844/13 CHRISTMAS [1] 1854/19 1854/17 1859/15
CATEGORY [2] 1855/4 1855/5 CIRCLED [1] 1820/17 COMMENT [6] 1758/21 1763/5 1763/13
CAUSATION [1] 1832/19 CIRCLES [1] 1821/5 1763/20 1766/6 1766/14
CAUSE [6] 1751/18 1820/3 1856/1 CIRCLING [1] 1820/16 COMMENTED [1] 1766/12
1856/13 1856/18 1857/4 CIRCULATION [7] 1740/5 1777/10 COMMENTS [6] 1755/6 1758/20
CAUSED [17] 1732/1 1732/2 1746/3 1777/16 1778/17 1795/21 1838/4 1838/7 1764/14 1765/14 1765/18 1765/23
1750/17 1750/18 1753/12 1758/16 CIRCUMSTANCES [2] 1835/17 1860/23 COMMERCE [1] 1731/11
1770/21 1779/14 1779/20 1822/15 CITRUS [13] 1754/7 1779/10 1779/13 COMMERCIAL [2] 1776/25 1827/21
1822/16 1823/20 1825/22 1828/1 1848/1 1779/22 1840/18 1841/12 1846/3 COMMERCIALIZES [1] 1775/24
1861/25 1846/13 1848/17 1850/14 1851/10 COMMUNITIES [1] 1746/22
CAUSING [2] 1757/22 1779/22 1851/14 1852/15 COMMUNITY [1] 1740/7
CCR [3] 1725/20 1868/2 1868/10 CITY [5] 1724/25 1731/10 1744/25 COMPANIES [1] 1775/22
CECIL [1] 1761/11 1747/23 1752/6 COMPARE [3] 1817/20 1841/3 1851/11
CEILING [1] 1778/23 CIVIL [1] 1725/10 COMPARED [3] 1761/23 1762/3 1802/9
CELL [3] 1797/20 1797/21 1798/23 CLARIFIED [1] 1858/19 COMPARING [3] 1842/3 1842/6 1861/8
CELLS [4] 1798/20 1798/21 1804/13 CLARIFY [1] 1772/15 COMPARISON [6] 1784/19 1799/4
1805/4 CLEAR [9] 1751/11 1779/2 1779/19 1799/12 1802/7 1851/17 1861/6
CENTER [4] 1732/21 1739/23 1777/20 1804/18 1821/2 1824/16 1836/24 1845/5 COMPARISONS [2] 1803/16 1852/23
1837/2 1862/12 COMPENDIUM [1] 1774/7
CENTRAL [8] 1769/18 1783/11 1789/20 CLEARED [1] 1844/2 COMPENSATED [1] 1736/14
1823/10 1823/23 1825/19 1827/3 1828/4 CLEARLY [6] 1748/24 1764/4 1772/15 COMPETENT [5] 1752/10 1758/25
CONTAINED [1] 1761/14 COULD [27] 1736/8 1736/16 1738/24
C CONTEMPLATE [2] 1757/12 1789/2 1739/2 1741/24 1743/5 1746/19 1750/6
COMPETENT... [3] 1772/19 1855/25 CONTEMPORANEOUS [1] 1854/11 1750/9 1752/21 1752/24 1757/13
1856/7 CONTEXT [7] 1729/4 1748/15 1755/5 1757/18 1765/8 1772/24 1778/2 1791/23
COMPETITIVENESS [1] 1771/12 1761/7 1764/4 1765/12 1771/20 1803/25 1808/21 1811/2 1824/14 1826/4
COMPLAINED [1] 1766/18 CONTINUE [1] 1865/10 1834/14 1836/1 1847/8 1854/10 1854/13
COMPLETE [3] 1749/10 1749/11 1781/8 CONTINUED [4] 1724/1 1725/1 1759/23 COULDN'T [3] 1751/2 1756/25 1856/16
COMPLETELY [3] 1764/19 1792/10 1772/4 COUNCIL [1] 1733/16
1792/12 CONTINUING [1] 1771/10 COUNSEL [12] 1735/12 1735/15 1772/7
COMPLEX [1] 1724/13 CONTOUR [1] 1808/6 1773/10 1773/13 1786/4 1815/23 1829/4
COMPLICATED [2] 1749/7 1838/22 CONTRACT [1] 1732/21 1857/14 1864/5 1865/12 1867/19
COMPORT [1] 1787/2 CONTRASTING [1] 1754/4 COUNTRY [3] 1730/6 1753/21 1753/22
COMPORTED [1] 1788/3 CONTRIBUTE [1] 1737/7 COUPLE [7] 1731/2 1732/13 1771/14
COMPOSITE [1] 1754/3 CONTRIBUTED [4] 1848/3 1852/14 1784/21 1784/22 1784/24 1784/24
COMPREHENSIVE [4] 1808/13 1809/3 1852/16 1862/3 COURSE [20] 1736/4 1737/18 1737/25
1819/10 1819/11 CONTRIBUTES [1] 1841/18 1738/22 1740/23 1753/9 1753/18 1763/3
COMPROMISING [1] 1746/6 CONTRIBUTING [2] 1745/2 1746/21 1776/5 1791/6 1792/13 1814/11 1820/20
COMPUTATIONALLY [1] 1809/2 CONTRIBUTION [3] 1828/15 1836/6 1821/12 1821/16 1823/1 1826/25 1837/9
COMPUTE [1] 1827/9 1837/12 1850/18 1853/17
COMPUTER [4] 1725/25 1736/6 1777/9 CONTRIBUTOR [1] 1853/18 COURT [43] 1723/1 1725/20 1727/4
1865/20 CONTROL [1] 1765/8 1735/6 1735/12 1735/24 1737/10
CONCEIVED [1] 1752/4 CONTROLLED [1] 1862/20 1739/25 1740/3 1743/14 1744/18
CONCEPT [8] 1745/5 1755/6 1759/25 CONVENTION [1] 1759/18 1745/25 1746/19 1752/17 1773/12
1796/13 1813/11 1816/21 1819/16 CONVERGE [2] 1844/21 1844/22 1773/19 1773/21 1774/21 1781/5
1844/18 CONVERGENCE [4] 1742/4 1773/4 1781/20 1786/2 1786/6 1790/7 1790/15
CONCEPTS [1] 1795/18 1779/5 1845/3 1802/22 1809/16 1830/24 1831/1 1836/5
CONCERN [1] 1755/9 CONVERGING [2] 1743/16 1843/21 1850/20 1862/5 1863/1 1863/2 1863/5
CONCERNED [4] 1731/11 1740/9 CONVERSION [3] 1746/16 1754/19 1863/6 1865/22 1866/1 1867/8 1867/8
1748/22 1772/18 1825/12 1867/22 1868/2 1868/3 1868/11
CONCERNING [1] 1755/17 CONVERTED [1] 1807/9 COURT'S [1] 1866/2
CONCISELY [1] 1774/21 CONVERTING [1] 1845/2 COURTROOM [3] 1735/24 1740/6
CONCLUDE [1] 1818/8 CONVEY [1] 1828/4 1796/25
CONCLUSION [2] 1786/4 1820/8 CONVEYANCE [1] 1843/15 COVER [3] 1830/8 1864/13 1864/15
CONCLUSIONS [2] 1739/9 1741/18 COOPERATION [1] 1865/13 COVERED [1] 1829/24
CONCRETE [1] 1760/4 COORDINATED [2] 1732/19 1831/19 COVERS [1] 1731/1
CONCRETE-ARTICULATED [1] 1760/4 COORDINATING [1] 1734/12 CREATED [8] 1739/22 1742/4 1746/2
CONDITION [13] 1733/20 1749/20 COORDINATION [1] 1833/9 1746/13 1748/8 1748/9 1825/9 1848/7
1749/24 1750/4 1750/7 1751/2 1753/9 COORDINATOR [2] 1737/22 1829/14 CREATES [1] 1755/18
1772/4 1775/5 1834/4 1834/5 1846/24 COPIES [1] 1864/22 CREST [2] 1793/17 1843/16
1847/16 COPY [2] 1786/10 1786/10 CRESTS [1] 1819/23
CONDITIONS [6] 1749/13 1752/1 CORNELL [1] 1730/13 CRITICAL [1] 1770/13
1763/10 1780/8 1796/18 1856/3 CORNER [1] 1744/7 CROSBY [3] 1753/24 1754/5 1763/17
CONDUCTED [1] 1748/19 CORPS [79] 1731/3 1731/5 1731/12 CROSS [6] 1801/7 1812/22 1832/4
CONFIDENT [2] 1739/17 1822/7 1731/18 1731/25 1732/9 1739/7 1742/16 1837/25 1839/2 1839/2
CONFIRM [1] 1857/21 1747/17 1747/20 1748/6 1748/12 CROSS-EXAMINATION [1] 1832/4
CONFIRMATION [1] 1752/22 1748/20 1752/2 1752/20 1753/10 CROSS-REFERENCED [1] 1801/7
CONFIRMATORY [1] 1834/18 1753/14 1754/2 1754/6 1754/14 1754/22 CROSS-SECTION [3] 1837/25 1839/2
CONFIRMED [2] 1731/16 1811/10 1754/24 1755/5 1755/25 1756/3 1756/5 1839/2
CONFUSED [2] 1787/10 1809/1 1757/12 1758/1 1758/5 1758/19 1758/20 CROSSED [1] 1801/17
CONFUSING [1] 1762/23 1758/24 1760/1 1760/10 1761/13 1764/5 CROWD [1] 1838/10
CONFUSION [2] 1737/10 1864/1 1764/13 1764/18 1765/14 1766/3 1766/5 CROWN [1] 1826/22
CONGRESS [3] 1747/24 1772/23 1766/11 1766/21 1767/14 1767/19 CUBIC [9] 1839/2 1839/4 1839/11
1856/9 1767/20 1767/25 1768/1 1768/16 1769/6 1846/15 1847/12 1847/15 1847/17
CONNECTION [7] 1743/11 1744/21 1770/10 1770/19 1770/24 1772/3 1848/19 1851/12
1775/25 1864/4 1866/6 1866/8 1867/3 1772/13 1772/17 1772/22 1772/24 CUMULATIVE [1] 1841/20
CONOR [1] 1725/12 1773/3 1779/3 1784/17 1786/4 1792/14 CURRENTLY [1] 1729/5
CONSEQUENCE [1] 1834/1 1807/24 1816/22 1825/25 1826/3 CURRENTS [1] 1728/9
CONSERVATIONIST [1] 1729/21 1826/11 1826/16 1833/24 1834/13 CURVE [2] 1791/11 1847/10
CONSIDER [4] 1729/19 1729/24 1730/7 1835/12 1835/12 1835/18 1839/16 CURVES [3] 1750/5 1751/7 1846/21
1805/22 1845/6 1856/7 1856/8 1865/5 CUT [2] 1767/17 1796/12
CONSIDERABLE [3] 1771/10 1823/11 CORPS' [6] 1756/12 1758/15 1766/18 CV [1] 1723/5
1832/22 1771/5 1834/25 1865/11 CWU [2] 1784/25 1787/3
CONSIDERED [1] 1754/8 CORPS-INTERNAL [1] 1764/18 CYCLES [3] 1794/18 1794/22 1794/23
CONSISTENT [3] 1783/1 1783/5 1783/6 CORRECT [148] CYPRESS [1] 1825/22
CONSTANT [1] 1808/25 CORRECTED [4] 1769/25 1770/1
CONSTITUTES [1] 1728/12 1795/15 1855/16 D
CONSTITUTIONALLY [1] 1771/7 CORRECTING [1] 1867/6 DALLAS [1] 1724/4
CONSTRICTED [2] 1836/21 1837/8 CORRECTLY [1] 1852/20 DAM [1] 1731/6
CONSTRUCTION [10] 1745/6 1770/22 CORRELATED [1] 1789/7 DAM-LIKE [1] 1731/6
1773/2 1778/8 1821/8 1844/11 1846/8 CORRELATING [1] 1819/9 DAMAGE [4] 1765/6 1768/21 1861/25
1852/14 1856/25 1857/2 CORRESPOND [3] 1789/21 1799/7 1862/3
CONTACT [1] 1865/15 1848/14 DAMAGES [2] 1771/11 1863/3
CONTACTED [1] 1731/10 COSTING [1] 1764/24 DAMAGING [1] 1746/8
DENHAM [1] 1724/17 1750/6 1753/1 1753/14 1753/22 1766/7
D DENOTED [1] 1812/6 1781/17 1783/20 1791/10 1793/8 1819/4
DAME [1] 1781/23 DEPARTMENT [5] 1725/9 1730/14 1821/16 1822/25 1825/2 1840/13
DAMPER [1] 1755/9 1730/14 1767/17 1865/11 1843/10 1855/1 1858/11
DANGEROUS [2] 1742/4 1856/6 DEPENDENT [1] 1777/10 DIFFER [1] 1806/12
DANIEL [1] 1725/10 DEPENDS [1] 1763/13 DIFFERENCE [14] 1753/23 1784/5
DARK [2] 1744/1 1804/2 DEPICTION [1] 1854/20 1788/6 1789/15 1794/2 1802/12 1810/4
DASHED [1] 1847/7 DEPICTIONS [1] 1848/25 1810/22 1821/8 1822/3 1822/4 1824/5
DATA [10] 1737/22 1740/12 1780/20 DEPLOYED [1] 1807/3 1835/6 1861/8
1786/20 1806/18 1806/21 1807/2 1817/8 DEPOSITING [1] 1826/14 DIFFERENCES [8] 1791/8 1791/12
1818/20 1827/7 DEPOSITION [1] 1764/2 1809/15 1809/16 1810/2 1810/2 1810/7
DATE [3] 1740/21 1769/1 1769/25 DEPOSITIONS [4] 1864/2 1864/8 1837/18
DATED [1] 1767/23 1864/10 1864/12 DIFFERENT [14] 1737/5 1737/5 1738/8
DATES [4] 1740/19 1772/14 1801/8 DEPTH [12] 1745/18 1747/7 1807/18 1749/9 1791/5 1794/5 1803/4 1811/12
1835/8 1817/1 1835/14 1837/18 1844/11 1812/5 1813/6 1822/17 1827/16 1831/18
DAY [4] 1812/10 1825/24 1829/15 1845/10 1845/11 1852/13 1859/11 1834/23
1830/21 1860/19 DIFFERENT-PERIOD [1] 1813/6
DAYS [3] 1738/12 1738/18 1863/25 DEPTHS [2] 1762/25 1807/18 DIFFERENTIAL [2] 1788/4 1788/16
DC [1] 1725/18 DERIVE [1] 1762/4 DIFFERENTIATION [1] 1769/12
DEAD [2] 1752/16 1752/17 DERIVED [6] 1786/24 1790/3 1851/22 DIFFERENTLY [5] 1730/5 1793/5
DEAL [1] 1831/18 1857/16 1860/15 1866/15 1813/16 1814/2 1830/8
DEALING [1] 1799/10 DESCRIBE [3] 1743/14 1755/12 1808/9 DIFFERING [1] 1728/16
DEALS [2] 1769/19 1770/4 DESCRIBED [10] 1755/2 1755/4 DIFFICULT [2] 1753/15 1809/2
DEATH [1] 1825/22 1758/11 1764/5 1774/5 1776/7 1794/25 DIFFICULTY [1] 1793/10
DEAUTHORIZED [1] 1749/25 1823/20 1826/2 1832/22 DIGRESS [1] 1784/17
DECADES [4] 1825/25 1826/16 1834/25 DESIGN [10] 1737/16 1745/6 1754/8 DILIGENTLY [1] 1865/17
1845/10 1817/19 1818/25 1841/4 1846/8 1852/13 DIMENSIONS [2] 1839/9 1839/10
DECIDES [1] 1861/6 1855/12 1856/25 DIMINIMUS [1] 1810/25
DECIMAL [1] 1802/18 DESIGNATING [1] 1812/5 DIRE [1] 1727/19
DECISIVE [1] 1758/3 DESIGNED [8] 1731/24 1775/3 1777/9 DIRECT [4] 1735/16 1820/21 1848/6
DECLARATION [4] 1741/1 1741/2 1779/14 1800/25 1856/13 1856/18 1866/7
1741/10 1774/15 1856/21 DIRECTED [5] 1729/12 1732/19 1829/17
DEDUCTION [1] 1756/23 DESPITE [1] 1861/5 1829/25 1842/12
DEEMED [1] 1764/3 DESTROY [3] 1789/1 1821/25 1823/1 DIRECTION [7] 1728/23 1808/12
DEEP [4] 1744/8 1763/10 1806/4 1813/8 DESTROYED [6] 1820/2 1822/9 1822/12 1808/17 1808/22 1809/1 1820/22 1822/4
DEEP-DRAFT [1] 1763/10 1822/13 1822/19 1825/3 DIRECTIONS [3] 1808/15 1808/23
DEEPEN [1] 1770/19 DESTRUCTION [3] 1778/12 1823/6 1812/5
DEEPENING [5] 1751/19 1755/7 1856/2 DIRECTLY [3] 1745/5 1760/16 1815/2
1759/11 1770/20 1778/7 DESTRUCTIVE [1] 1789/3 DIRECTOR [2] 1732/20 1733/9
DEEPER [5] 1770/16 1812/22 1819/20 DETAIL [8] 1731/1 1737/14 1778/1 DISAGREE [1] 1824/13
1845/1 1856/5 1823/10 1827/1 1828/8 1831/22 1832/22 DISAGREEMENT [2] 1790/25 1810/10
DEEPLY [1] 1747/10 DETAILED [3] 1740/13 1811/8 1814/23 DISCHARGE [9] 1775/4 1835/23
DEEPWATER [1] 1810/18 DETAILS [1] 1740/12 1837/17 1838/5 1838/5 1838/21 1839/1
DEFENDANT [3] 1725/9 1798/2 1867/16 DETERMINATION [1] 1810/11 1839/10 1839/21
DEFENDANT'S [5] 1791/6 1796/22 DETERMINE [5] 1775/5 1775/6 1775/11 DISCRETION [1] 1841/3
1823/15 1824/4 1824/12 1775/14 1854/7 DISCUSS [4] 1754/13 1828/21 1830/11
DEFENDANTS [2] 1796/8 1796/18 DETERMINED [1] 1778/20 1865/14
DEFENSE [4] 1742/11 1792/14 1822/21 DETERMINING [1] 1733/24 DISCUSSED [4] 1742/10 1779/17
1824/17 DEVASTATION [1] 1770/22 1835/9 1861/11
DEFER [1] 1863/19 DEVELOP [3] 1765/16 1767/10 1796/10 DISCUSSION [3] 1764/20 1833/2 1833/6
DEFINITELY [2] 1764/8 1791/22 DEVELOPED [9] 1728/10 1732/25 DISLIKE [1] 1771/7
DEFINITION [1] 1800/4 1733/7 1775/13 1775/23 1776/22 DISMISSAL [1] 1754/14
DEFRACTION [1] 1819/24 1777/19 1783/9 1843/12 DISMISSED [1] 1754/13
DEGRADED [1] 1825/18 DEVELOPMENT [1] 1764/25 DISPOSAL [1] 1742/5
DEGREE [2] 1784/13 1844/22 DEVICE [1] 1834/18 DISPUTE [1] 1824/23
DEGREES [1] 1808/1 DIAGONAL [1] 1804/12 DISQUALIFY [1] 1864/5
DELFT [8] 1775/16 1775/19 1775/23 DIAGRAM [4] 1781/12 1785/24 1805/23 DISRUPTED [1] 1739/1
1775/25 1776/6 1776/22 1827/20 1836/14 DISSERTATION [1] 1802/5
1827/22 DID [61] 1727/16 1731/14 1731/15 DISSIPATION [2] 1814/9 1814/13
DELICATE [1] 1746/9 1731/19 1732/1 1733/15 1736/1 1736/1 DISTANCE [2] 1817/18 1818/7
DELINEATE [2] 1735/2 1754/23 1737/7 1739/5 1739/5 1748/3 1750/3 DISTILL [1] 1863/14
DELINEATED [1] 1748/5 1750/21 1751/3 1752/20 1753/10 DISTRICT [12] 1723/1 1723/2 1723/11
DELINEATING [1] 1739/24 1756/13 1756/17 1758/19 1759/22 1742/13 1755/3 1755/16 1765/16
DELIVER [1] 1827/12 1774/24 1775/16 1782/10 1783/20 1766/15 1767/22 1770/9 1868/3 1868/3
DELTAIC [1] 1753/20 1785/1 1786/22 1788/14 1789/25 1790/7 DIVISION [11] 1725/10 1736/12 1754/25
DEMANDS [1] 1772/5 1793/7 1795/18 1795/20 1801/15 1758/15 1764/15 1764/16 1765/17
DEMONSTRATE [1] 1846/9 1804/15 1805/6 1806/9 1808/24 1818/22 1765/18 1765/24 1766/11 1767/19
DEMONSTRATES [1] 1758/1 1819/4 1819/5 1821/18 1821/25 1822/8 DO [77] 1728/19 1728/22 1728/22
DEMONSTRATIVE [3] 1818/14 1866/13 1823/21 1827/14 1827/18 1834/23 1728/25 1729/2 1729/2 1729/19 1730/18
1867/17 1835/20 1838/7 1839/23 1843/11 1846/1 1730/20 1742/23 1750/6 1754/15
DEMONSTRATIVELY [1] 1866/18 1847/25 1854/7 1857/24 1859/7 1860/1 1754/16 1756/11 1756/18 1760/25
DEMONSTRATIVES [5] 1786/6 1866/23 1860/16 1865/22 1866/5 1763/13 1764/13 1766/14 1769/8
1866/24 1867/3 1867/11 DIDN'T [20] 1741/6 1747/10 1748/18 1782/20 1783/19 1783/20 1785/20
1768/11 1768/20 1768/22 1769/5 1767/21 1856/6 1857/3
D 1772/15 1774/20 1775/9 1775/16 DRIVING [4] 1844/8 1844/9 1845/7
DO... [53] 1785/21 1786/7 1790/1 1776/16 1777/20 1781/21 1781/22 1845/8
1790/24 1792/4 1796/18 1798/9 1799/3 1782/16 1784/1 1784/18 1785/11 DROP [3] 1751/8 1813/21 1839/18
1799/16 1799/18 1800/5 1800/5 1805/8 1785/19 1785/19 1785/22 1785/23 DROPPING [1] 1815/7
1805/13 1805/14 1806/7 1806/9 1806/9 1786/19 1786/20 1786/22 1786/24 DROPS [3] 1810/18 1813/8 1814/13
1808/13 1809/10 1810/2 1815/25 1786/24 1786/25 1787/21 1788/5 1788/7 DUDENHEFER [2] 1724/9 1724/9
1823/14 1824/20 1824/22 1826/5 1788/20 1789/4 1789/18 1789/20 1790/3 DUE [7] 1745/7 1758/2 1771/9 1794/22
1826/11 1826/14 1826/20 1827/2 1790/6 1790/14 1791/13 1792/7 1792/9 1829/20 1857/3 1865/19
1828/12 1828/13 1830/11 1830/17 1794/18 1796/12 1799/3 1801/15 DULY [1] 1727/11
1833/2 1833/13 1833/14 1843/3 1843/5 1801/21 1802/25 1803/19 1804/18 DUMAS [2] 1724/12 1724/12
1843/10 1845/25 1849/25 1850/4 1856/3 1811/5 1811/14 1814/21 1816/12 DUPRE [1] 1765/9
1856/4 1856/9 1858/11 1863/2 1864/18 1816/12 1816/24 1820/6 1820/10 1822/5 DURABLE [1] 1836/16
1864/18 1865/14 1866/6 1868/4 1822/5 1822/9 1822/11 1823/18 1823/24 DURATION [9] 1745/1 1751/3 1751/22
DOCKET [1] 1723/5 1825/24 1826/6 1826/11 1826/14 1753/7 1791/2 1791/4 1845/21 1845/23
DOCUMENT [8] 1750/10 1762/2 1826/25 1827/2 1827/7 1827/11 1828/12 1852/15
1764/18 1766/3 1766/4 1768/5 1770/1 1830/11 1831/8 1831/19 1832/9 1832/21 DURING [24] 1745/1 1749/21 1750/9
1771/20 1839/25 1848/10 1851/5 1854/8 1854/14 1754/20 1756/20 1756/21 1763/9
DOCUMENTS [1] 1742/13 1854/19 1854/22 1857/17 1857/24 1780/14 1782/1 1792/14 1806/13
DOES [19] 1728/6 1745/9 1754/2 1858/9 1858/10 1858/16 1860/10 1866/7 1806/21 1809/8 1809/9 1831/16 1833/15
1757/15 1771/4 1785/5 1785/6 1788/10 DR. BEA [23] 1737/23 1737/24 1759/5 1842/7 1846/1 1856/14 1857/11 1857/25
1788/12 1791/17 1812/12 1814/23 1775/9 1776/16 1789/4 1790/14 1801/21 1859/7 1860/1 1860/16
1832/3 1833/17 1840/24 1843/7 1845/21 1814/21 1816/12 1816/12 1820/6 1822/5 DUTCH [8] 1780/1 1795/12 1795/20
1854/12 1865/9 1822/9 1822/11 1826/25 1827/7 1827/11 1800/5 1806/10 1830/4 1830/12 1832/20
DOESN'T [14] 1760/7 1766/15 1778/23 1828/12 1851/5 1858/10 1858/16 DUTY [1] 1835/16
1778/24 1778/25 1780/20 1783/13 1860/10 DUVAL [1] 1723/11
1787/2 1802/2 1828/21 1829/6 1832/1 DR. BEA'S [1] 1794/18 DYING [1] 1795/4
1854/14 1864/17 DR. EBERSOLE [2] 1786/22 1789/20 DYNAMICS [4] 1728/15 1730/18
DOING [10] 1738/14 1767/14 1771/7 DR. EBERSOLE'S [1] 1785/22 1747/11 1843/25
1774/23 1777/13 1794/10 1794/11 DR. GAGLIANO [12] 1753/18 1753/20
1798/3 1838/8 1867/10 1755/1 1755/20 1757/17 1768/22 E
DOMAIN [2] 1796/2 1808/14 1772/15 1825/24 1826/6 1826/11 E-MAIL [5] 1865/1 1865/2 1865/2
DOMENGEAUX [1] 1724/5 1826/14 1827/2 1865/17 1865/19
DON'T [31] 1743/2 1752/3 1753/16 DR. HSU [2] 1753/19 1753/21 E-MAILS [1] 1866/1
1756/16 1773/8 1773/13 1780/20 1781/2 DR. KEMP [43] 1727/21 1729/17 EACH [15] 1741/21 1796/5 1796/16
1781/25 1782/2 1782/6 1783/18 1790/19 1735/18 1736/11 1736/21 1737/15 1797/16 1797/25 1801/14 1812/6 1828/9
1791/6 1791/16 1792/3 1794/3 1798/19 1739/12 1740/19 1741/11 1742/2 1828/16 1835/8 1835/24 1848/16
1798/23 1799/18 1803/14 1806/12 1742/22 1743/11 1753/10 1756/11 1848/22 1849/7 1864/13
1808/12 1816/5 1832/3 1853/5 1853/10 1757/4 1759/25 1760/9 1761/11 1762/2 EARLIER [21] 1744/25 1746/9 1750/13
1857/16 1862/17 1864/18 1867/12 1763/23 1768/11 1768/20 1769/5 1771/5 1782/18 1784/21 1784/22
DONE [26] 1730/17 1732/5 1736/16 1774/20 1782/16 1787/21 1788/20 1784/24 1785/7 1785/13 1785/15
1737/11 1739/19 1739/21 1761/4 1761/5 1792/7 1796/12 1799/3 1804/18 1811/5 1785/16 1788/24 1816/14 1825/24
1772/25 1778/1 1794/6 1797/19 1801/20 1811/14 1816/24 1820/10 1823/18 1831/6 1831/24 1854/9 1861/11 1865/1
1809/6 1809/8 1817/10 1826/3 1826/4 1830/11 1831/19 1832/9 1839/25 1866/2
1826/16 1826/23 1827/25 1829/16 1848/10 1857/24 1866/7 EARLIEST [1] 1750/7
1829/17 1847/9 1848/22 1853/5 DR. KEMP'S [3] 1761/14 1831/8 1857/17 EARLY [10] 1731/5 1745/2 1745/16
DOOR [1] 1806/15 DR. PAUL [2] 1727/8 1735/6 1747/13 1753/24 1759/14 1784/25
DOT [1] 1818/11 DR. RESIO [4] 1785/19 1786/19 1786/25 1823/21 1832/15 1855/16
DOTS [2] 1804/19 1804/19 1803/19 EARTH [2] 1728/12 1728/14
DOTTED [3] 1789/9 1846/23 1847/1 DR. RESIO'S [2] 1785/23 1802/25 EARTHEN [1] 1822/2
DOVETAILS [1] 1829/11 DR. SHERWOOD [1] 1755/17 EAST [32] 1725/4 1742/6 1759/18
DOWN [28] 1745/20 1762/11 1771/25 DR. SOUILEAU [1] 1764/15 1778/14 1779/10 1779/13 1779/23
1777/16 1781/11 1796/5 1797/21 DR. VAN HEERDEN [2] 1734/10 1826/15 1828/5 1840/18 1840/24 1841/6
1797/22 1798/25 1800/5 1800/23 1734/12 1841/23 1843/17 1845/14 1846/1
1804/11 1804/24 1807/8 1808/2 1812/18 DR. VRIJLING [6] 1775/16 1781/21 1847/19 1847/23 1848/18 1848/25
1812/18 1813/21 1813/21 1815/7 1790/6 1792/9 1801/15 1832/21 1849/4 1849/9 1850/11 1850/13 1850/14
1836/12 1842/25 1846/4 1847/3 1851/6 DR. VRIJLING'S [4] 1784/1 1822/5 1850/15 1850/23 1851/11 1851/19
1851/12 1854/18 1863/22 1823/24 1858/9 1852/25 1860/14 1861/7
DOWNSTAIRS [1] 1779/1 DR. WESTERINK [10] 1777/20 1781/22 EASTERN [3] 1723/2 1848/3 1868/3
DOYLE [4] 1725/20 1868/2 1868/10 1784/18 1786/24 1788/7 1790/3 1791/13 EBERSOLE [7] 1785/19 1786/22 1789/6
1868/10 1854/8 1854/14 1854/22 1789/20 1789/24 1789/25 1790/1
DOZENS [1] 1775/22 DR. WESTERINK'S [6] 1785/11 1785/19 EBERSOLE'S [3] 1785/22 1802/25
DR [6] 1755/1 1757/9 1806/3 1817/22 1786/20 1786/24 1789/18 1854/19 1803/20
1826/20 1850/25 DRAFT [4] 1741/13 1741/15 1741/16 ECOLOGIC [1] 1759/1
DR. [126] 1727/8 1727/21 1729/17 1763/10 ECOLOGICAL [1] 1728/19
1734/10 1734/12 1735/6 1735/18 DRAIN [1] 1843/23 ECOLOGY [1] 1730/22
1736/11 1736/21 1737/15 1737/23 DRAMATIC [2] 1850/18 1854/16 ECONOMIC [1] 1764/25
1737/24 1739/12 1740/19 1741/11 DRAMATICALLY [3] 1779/21 1826/4 ECONOMICS [1] 1764/23
1742/2 1742/22 1743/11 1753/10 1844/10 ECOSYSTEM [1] 1728/15
1753/18 1753/19 1753/20 1753/21 DRAW [2] 1770/23 1842/19 EDGE [5] 1761/2 1778/24 1778/25
1755/1 1755/17 1755/20 1756/11 1757/4 DREDGED [4] 1767/11 1772/4 1826/15 1803/20 1842/25
1757/17 1759/5 1759/25 1760/9 1761/11 1834/13 EDUCATION [1] 1855/22
1761/14 1762/2 1763/23 1764/15 DREDGING [6] 1745/7 1759/12 1766/23 EDWARDS,LLC [1] 1724/5
ENGINEERS' [2] 1742/17 1784/18 EVENTUALLY [1] 1759/14
E ENHANCED [3] 1747/18 1747/22 EVER [4] 1736/11 1773/4 1832/1 1854/7
EFFECT [37] 1731/13 1731/14 1731/16 1835/13 EVERY [9] 1739/6 1780/12 1781/11
1737/21 1742/12 1742/18 1748/14 ENHANCEMENT [1] 1750/16 1793/19 1794/19 1817/12 1819/4 1819/5
1749/14 1750/14 1750/14 1750/20 ENLARGE [2] 1756/3 1759/23 1862/25
1751/23 1751/24 1752/25 1753/12 ENLARGED [7] 1744/21 1745/16 EVERYBODY [3] 1739/8 1756/4 1796/19
1754/19 1755/19 1756/9 1773/4 1778/8 1760/22 1841/5 1844/10 1852/13 EVERYONE [1] 1756/9
1778/17 1789/17 1791/19 1804/14 1852/19 EVERYTHING [2] 1783/18 1783/23
1811/9 1814/9 1825/15 1825/16 1826/9 ENLARGEMENT [4] 1744/2 1779/8 EVERYWHERE [3] 1785/6 1796/1
1834/15 1835/21 1839/18 1841/20 1845/9 1845/10 1825/19
1842/15 1842/19 1844/6 1850/19 ENLIGHTEN [1] 1823/15 EVIDENCE [7] 1734/16 1748/24 1752/21
EFFECTIVE [1] 1777/11 ENOUGH [6] 1741/15 1808/18 1833/4 1757/18 1816/23 1852/3 1857/20
EFFECTIVELY [4] 1768/2 1795/1 1800/7 1842/20 1863/13 1864/24 EVOLUTION [1] 1737/16
1826/4 ENSUING [1] 1731/25 EVOLVED [1] 1759/2
EFFECTS [13] 1735/8 1739/14 1750/22 ENSURE [1] 1865/9 EXACERBATE [1] 1752/1
1757/22 1775/2 1775/2 1778/3 1781/14 ENTAIL [1] 1728/7 EXACERBATED [1] 1756/23
1812/20 1826/23 1827/9 1827/11 1857/1 ENTIRE [5] 1758/13 1765/25 1814/24 EXACT [3] 1755/12 1769/13 1844/17
EFFORT [3] 1818/17 1818/18 1832/15 1832/9 1849/16 EXACTLY [11] 1734/8 1753/19 1761/6
EHRLICH [1] 1725/11 ENTIRETY [4] 1734/17 1738/13 1760/13 1780/13 1785/6 1789/9 1789/23 1799/12
EIGHT [2] 1864/6 1864/10 1760/25 1803/16 1810/21 1840/13
EIGHT ATTACHMENTS [1] 1864/6 ENTITLED [1] 1868/7 EXAMINATION [4] 1735/16 1773/23
EIS [1] 1766/8 ENVIRONMENT [7] 1729/9 1729/13 1832/4 1863/18
EITHER [6] 1761/16 1779/14 1791/7 1729/14 1733/19 1768/21 1801/25 EXAMINING [1] 1800/6
1838/6 1840/25 1851/4 1814/15 EXAMPLE [8] 1808/19 1811/5 1817/22
EL [1] 1725/11 ENVIRONMENTAL [4] 1770/11 1770/21 1817/23 1838/9 1841/23 1844/16 1849/1
EL-AMIN [1] 1725/11 1771/11 1819/12 EXAMPLES [1] 1754/22
ELABORATE [1] 1791/23 ENVIRONMENTS [1] 1728/8 EXCAVATED [1] 1819/21
ELEMENTS [2] 1746/8 1780/12 ENVIRONS [1] 1842/4 EXCEEDANCE [1] 1791/5
ELEVATION [22] 1747/7 1751/1 1764/9 EPICENTER [1] 1775/20 EXCEPT [2] 1815/25 1866/12
1778/19 1781/17 1781/18 1782/8 EQUAL [1] 1743/15 EXCEPTION [1] 1833/17
1799/15 1824/1 1828/3 1838/10 1838/11 EQUIVALENT [2] 1762/5 1839/4 EXCESS [6] 1736/3 1792/23 1812/7
1838/20 1843/16 1843/24 1858/1 1858/1 ERODED [2] 1768/21 1790/12 1837/1 1846/3 1846/4
1859/9 1859/11 1859/12 1860/2 1860/19 ERODIBILITY [1] 1794/14 EXCESSIVE [1] 1759/12
ELEVATIONS [3] 1739/11 1747/10 EROSION [20] 1745/7 1758/2 1758/6 EXCRUCIATING [1] 1831/22
1782/2 1759/13 1762/4 1766/24 1770/6 1770/11 EXCUSE [3] 1731/22 1742/25 1753/24
ELICIT [1] 1829/10 1771/6 1772/17 1779/16 1789/2 1790/20 EXERCISE [1] 1817/11
ELIMINATE [1] 1765/8 1790/21 1791/18 1791/19 1794/16 EXERCISES [1] 1733/5
ELISA [1] 1725/3 1822/16 1856/6 1857/3 EXHIBIT [13] 1740/22 1741/7 1743/5
ELMO [1] 1743/5 ESCORTS [1] 1736/9 1771/15 1782/18 1786/2 1818/14 1864/5
ELOQUENT [1] 1797/10 ESPECIALLY [3] 1778/12 1790/7 1864/7 1864/16 1866/19 1867/16
ELSE [10] 1727/15 1729/19 1755/18 1835/13 1867/16
1756/10 1757/18 1819/15 1830/2 1833/4 ESPOUSED [1] 1777/23 EXHIBIT 9 [2] 1864/5 1864/16
1863/7 1867/9 ESQ [31] 1723/15 1723/18 1723/19 EXHIBITS [6] 1785/25 1801/7 1805/15
ELSEWHERE [1] 1761/17 1723/22 1723/22 1724/3 1724/6 1724/9 1866/14 1866/24 1867/1
ELWOOD [3] 1724/22 1724/23 1828/12 1724/12 1724/16 1724/19 1724/20 EXISTED [4] 1745/11 1745/13 1750/4
EMBELLISHING [1] 1773/13 1724/23 1725/3 1725/3 1725/6 1725/6 1845/5
EMERGENCY [1] 1733/7 1725/10 1725/11 1725/11 1725/12 EXISTENCE [1] 1750/9
EMERGING [1] 1733/11 1725/12 1725/13 1725/13 1725/14 EXISTING [3] 1749/15 1749/21 1750/12
EMPLOYED [1] 1864/9 1725/14 1725/15 1725/15 1725/16 EXISTS [1] 1762/19
EMPLOYEE [1] 1764/16 1725/16 1725/17 EXPAND [1] 1746/4
EMPLOYMENT [2] 1864/9 1864/10 ESSENCE [2] 1753/3 1816/11 EXPANDED [4] 1733/17 1769/22
EMPTYING [1] 1778/22 ESSENTIALLY [10] 1767/4 1792/22 1769/23 1818/17
ENCLOSED [1] 1819/18 1795/4 1803/11 1803/17 1814/11 EXPANDING [1] 1760/20
ENCOMPASSES [1] 1728/3 1814/14 1820/22 1834/21 1843/17 EXPANSION [1] 1745/7
ENCOUNTER [1] 1804/9 ESTABLISH [3] 1739/13 1780/6 1829/21 EXPECT [5] 1731/12 1772/4 1807/15
ENCOURAGE [2] 1764/2 1770/15 ESTABLISHED [2] 1771/16 1783/24 1809/1 1819/21
END [8] 1737/11 1750/14 1782/14 ESTABLISHING [2] 1780/8 1830/4 EXPECTED [6] 1785/9 1785/12 1786/14
1818/5 1829/15 1836/22 1850/16 ESTIMATE [4] 1736/14 1736/24 1783/14 1787/4 1787/22 1804/7
1863/15 1851/21 EXPECTING [1] 1863/3
ENDED [1] 1792/23 ESTIMATED [1] 1736/3 EXPERIENCE [4] 1736/5 1753/17
ENDS [3] 1817/14 1817/15 1820/1 ET [3] 1723/5 1723/7 1755/20 1855/22 1862/6
ENERGIZED [2] 1793/3 1793/9 ET AL [1] 1755/20 EXPERIENCED [1] 1745/1
ENERGY [11] 1795/2 1795/3 1795/9 ETC [2] 1798/13 1816/1 EXPERT [35] 1730/20 1731/19 1731/22
1813/18 1813/23 1813/23 1814/6 1814/9 EVALUATED [2] 1731/3 1764/20 1732/1 1735/6 1737/5 1737/5 1737/21
1814/13 1814/15 1814/16 EVALUATION [1] 1764/20 1740/15 1742/11 1744/19 1758/23
ENGAGED [1] 1748/12 EVEN [19] 1730/5 1730/6 1730/8 1758/25 1777/5 1780/1 1784/18 1786/17
ENGINEER [1] 1827/8 1757/12 1763/24 1770/20 1783/13 1815/11 1815/12 1817/9 1823/6 1827/11
ENGINEERING [7] 1729/4 1733/11 1807/16 1815/5 1823/11 1835/14 1828/22 1828/23 1829/20 1832/2 1842/9
1733/15 1738/1 1775/21 1775/22 1840/17 1841/4 1845/1 1845/10 1855/12 1842/10 1846/17 1858/4 1859/18 1860/7
1776/21 1856/6 1861/15 1865/18 1860/22 1861/7 1861/22
ENGINEERS [11] 1728/22 1728/24 EVENING [1] 1867/22 EXPERTISE [9] 1727/21 1733/21
1729/4 1731/18 1732/9 1739/7 1748/14 EVENT [3] 1847/11 1847/11 1862/24 1751/17 1752/10 1785/10 1819/8 1820/8
1752/2 1765/23 1773/3 1776/3 EVENTS [3] 1747/12 1759/1 1766/17 1854/23 1862/6
1801/3 1801/3 1802/8 1802/10 1803/9 FIT [2] 1780/20 1798/18
E 1804/22 1804/23 1804/24 1804/24 FITZGERALD [3] 1786/13 1786/17
EXPERTS [18] 1742/17 1751/20 1805/7 1805/10 1807/11 1810/25 1812/7 1786/19
1765/24 1786/12 1786/19 1790/25 1812/8 1812/9 1812/15 1812/16 1812/19 FITZGERALD'S [1] 1824/3
1791/1 1791/6 1792/14 1794/9 1798/2 1812/24 1812/25 1813/8 1813/9 1814/12 FIVE [4] 1738/18 1825/25 1829/12
1799/23 1810/23 1823/15 1824/12 1815/4 1817/12 1817/20 1818/8 1818/9 1866/5
1824/17 1826/2 1833/10 1818/10 1819/4 1819/19 1837/1 1837/15 FIX [1] 1733/25
EXPLAIN [10] 1730/3 1746/24 1749/8 1839/2 1839/4 1839/11 1841/14 1846/15 FIXED [1] 1772/24
1757/11 1796/13 1797/11 1802/22 1847/12 1847/15 1847/17 1848/19 FIXES [1] 1772/3
1806/25 1816/12 1842/23 1850/2 1850/2 1850/5 1850/6 1851/12 FLANKED [1] 1743/16
EXPLANATORY [1] 1864/15 1858/1 1858/2 1858/3 1859/8 1859/13 FLAT [1] 1814/11
EXPLORED [1] 1826/25 1859/13 1859/16 1859/17 1860/2 1860/3 FLEW [1] 1738/12
EXPOSED [6] 1733/18 1746/14 1762/11 1860/4 1860/6 1860/11 1860/20 1861/3 FLOATING [1] 1754/11
1762/14 1764/2 1825/10 1861/9 1861/13 1861/16 1861/19 FLOOD [12] 1732/4 1745/2 1747/10
EXQUISITE [2] 1731/1 1737/14 1862/21 1862/21 1774/25 1775/10 1775/13 1823/6 1834/1
EXQUISITELY [2] 1740/13 1742/10 FELT [2] 1736/7 1755/22 1834/16 1848/17 1853/13 1854/2
EXTENDING [1] 1812/7 FEMA [1] 1739/7 FLOODED [9] 1747/5 1747/7 1747/9
EXTENDS [1] 1761/1 FENCE [1] 1739/6 1823/18 1824/14 1846/1 1853/23
EXTENSION [1] 1863/8 FETCH [1] 1817/1 1855/10 1855/11
EXTENSIVELY [1] 1779/17 FEW [7] 1754/24 1781/3 1813/8 1813/9 FLOODING [62] 1731/14 1731/15
EXTENT [3] 1760/11 1810/23 1867/4 1819/19 1819/19 1821/21 1732/1 1737/8 1746/21 1746/24 1747/12
EXTRA [1] 1864/22 FIELD [17] 1729/24 1730/2 1731/15 1758/16 1766/13 1775/11 1775/14
EXTRACTED [1] 1818/21 1733/10 1733/11 1733/21 1733/22 1779/23 1792/1 1820/3 1824/4 1824/7
EXTRAPOLATE [1] 1757/10 1733/24 1734/2 1738/3 1738/4 1738/16 1827/6 1828/14 1828/16 1830/12 1841/5
EXTRAPOLATED [1] 1851/18 1748/19 1758/23 1758/25 1819/7 1820/7 1841/11 1843/12 1845/14 1845/15
EXTREMELY [1] 1777/21 FIFTH [3] 1746/19 1761/23 1827/2 1845/22 1847/18 1847/19 1847/22
EYE [2] 1733/8 1807/17 FIGHT [1] 1767/6 1847/25 1847/25 1849/3 1849/11
FIGURATIVELY [1] 1814/12 1849/15 1849/25 1850/12 1852/16
F FIGURE [6] 1735/25 1738/24 1756/25 1852/21 1853/18 1856/14 1856/19
FACE [2] 1801/25 1805/1 1785/3 1801/8 1828/10 1857/4 1857/24 1858/5 1858/12 1858/22
FACED [1] 1759/22 FIGURED [1] 1806/5 1859/6 1859/13 1859/15 1859/19
FACILITATE [1] 1848/6 FIGURES [5] 1749/3 1805/5 1805/8 1859/25 1860/4 1860/6 1860/8 1860/11
FACILITY [1] 1760/4 1806/7 1809/10 1860/13 1860/16 1860/23 1861/15
FACT [19] 1732/8 1733/4 1744/7 1745/7 FILE [1] 1864/22 1861/18 1861/21 1861/24
1757/7 1758/5 1760/1 1781/15 1784/6 FILING [1] 1741/5 FLOORS [1] 1859/21
1785/1 1786/12 1787/21 1800/4 1825/17 FILL [8] 1783/11 1783/13 1783/15 FLORIDA [4] 1724/17 1752/24 1834/3
1829/19 1829/19 1831/8 1852/19 1784/25 1787/3 1787/17 1823/22 1834/14
1866/12 1823/22 FLOW [10] 1780/6 1780/7 1780/9
FACTOR [5] 1746/21 1844/9 1844/9 FILM [1] 1782/23 1824/24 1838/2 1839/5 1844/13 1849/17
1845/7 1861/25 FINAL [2] 1827/18 1832/22 1849/18 1852/23
FACTORING [1] 1850/22 FINALLY [1] 1836/8 FLOW-MODELING [1] 1844/13
FAIL [2] 1835/16 1835/16 FIND [16] 1732/1 1735/22 1738/10 FLOWING [5] 1782/5 1808/25 1836/18
FAILURE [11] 1745/2 1766/18 1766/24 1752/21 1760/7 1761/6 1776/5 1780/18 1844/20 1844/21
1820/7 1825/1 1853/23 1854/1 1854/1 1780/21 1786/2 1818/6 1838/19 1838/21 FLOWS [1] 1760/3
1856/12 1856/17 1857/2 1863/3 1865/19 1865/20 FOCUS [1] 1797/9
FAIR [4] 1728/11 1741/15 1855/17 FINDING [1] 1792/23 FOLKS [1] 1756/9
1855/18 FINE [6] 1765/20 1797/9 1800/20 FOLLOW [4] 1743/24 1766/24 1773/15
FAIRED [1] 1822/2 1800/24 1830/9 1862/18 1834/20
FAIRLY [1] 1791/13 FINE-RESOLUTION [1] 1800/24 FOLLOW-UP [1] 1773/15
FAMILIAR [1] 1775/18 FINE-TUNING [1] 1797/9 FOLLOWING [2] 1739/11 1815/6
FAR [6] 1753/1 1772/18 1795/3 1828/1 FINEL [27] 1776/10 1776/22 1777/22 FOLLOWS [1] 1727/12
1833/23 1838/12 1778/1 1778/5 1780/1 1780/17 1781/13 FOOT [33] 1771/12 1795/14 1803/2
FARTHER [1] 1850/11 1781/21 1782/7 1783/16 1784/1 1784/1 1808/3 1808/5 1808/6 1808/7 1810/5
FASHION [1] 1834/24 1789/6 1789/10 1795/22 1796/9 1800/23 1811/10 1813/2 1813/21 1813/22
FAST [1] 1837/11 1809/24 1835/23 1836/20 1838/1 1814/18 1814/25 1815/7 1815/18 1820/2
FATIGUE [1] 1794/18 1844/13 1845/4 1848/13 1851/23 1846/15 1847/12 1847/15 1847/17
FAYARD [2] 1724/16 1724/16 1854/13 1848/19 1851/12 1858/6 1858/9 1858/13
FCRR [3] 1725/20 1868/2 1868/10 FINEL-GENERATED [1] 1796/9 1858/17 1858/17 1858/19 1858/20
FEATURE [1] 1809/23 FINEST [3] 1797/23 1798/17 1800/23 1859/9 1859/10 1859/13
FEATURES [1] 1809/18 FINEST-RESOLUTION [2] 1797/23 FOOTPRINT [1] 1798/18
FEBRUARY [2] 1729/6 1765/13 1798/17 FOOTSTEPS [1] 1834/21
FEBRUARY 1988 [1] 1765/13 FINISH [3] 1765/22 1802/19 1830/17 FORCE [4] 1728/17 1789/3 1844/8
FEDERAL [6] 1732/16 1733/7 1766/22 FINISHED [2] 1735/20 1844/4 1844/10
1767/8 1767/8 1767/21 FIREHOSE [3] 1778/23 1837/7 1845/3 FORECAST [1] 1733/2
FEDS [1] 1767/19 FIRM [6] 1723/21 1724/9 1724/12 FORECASTING [2] 1732/22 1733/1
FEEL [6] 1742/24 1791/16 1814/8 1725/2 1864/11 1865/5 FORECASTS [1] 1736/5
1822/7 1827/13 1832/6 FIRST [25] 1731/2 1735/18 1742/2 FOREGOING [1] 1868/4
FEELS [1] 1737/10 1742/3 1743/11 1748/5 1748/11 1760/21 FORENSICS [1] 1733/17
FEET [90] 1747/6 1747/8 1756/20 1761/23 1763/6 1764/18 1768/16 1777/7 FORESEEABLY [2] 1742/7 1744/24
1756/21 1758/6 1760/7 1762/5 1762/6 1777/23 1789/9 1796/20 1799/17 FORESHORE [3] 1746/7 1801/22
1781/17 1782/12 1782/13 1789/19 1801/11 1806/24 1810/16 1811/12 1801/25
1789/21 1795/13 1797/17 1797/25 1826/6 1830/13 1838/23 1839/1 FORGET [1] 1830/6
1798/16 1798/17 1799/9 1799/9 1799/25 FISHING [1] 1733/18 FORGOT [1] 1830/5
1840/14 1841/25 1744/5 1744/12 1745/22 1750/12 1751/7
F GATHERED [1] 1817/8 1751/8 1752/7 1755/6 1766/16 1771/25
FORM [1] 1802/2 GAUGE [2] 1781/11 1782/13 1772/19 1773/22 1776/5 1783/14 1786/5
FORMALLY [1] 1772/23 GAVE [2] 1756/15 1843/13 1792/14 1795/19 1798/6 1798/18
FORTH [3] 1748/5 1766/6 1827/9 GENERAL [6] 1737/4 1738/14 1754/7 1798/23 1804/11 1804/24 1807/8
FORWARD [2] 1763/19 1831/5 1791/1 1803/3 1821/21 1808/13 1808/16 1811/1 1814/19 1816/6
FOUND [7] 1738/10 1742/13 1742/14 GENERALLY [7] 1741/23 1748/7 1829/15 1830/16 1830/19 1836/13
1756/1 1793/2 1795/12 1803/12 1751/22 1758/13 1774/22 1809/10 1837/8 1838/24 1839/6 1839/7 1839/18
FOUNDATION [1] 1828/8 1821/5 1841/3 1843/2 1843/23 1844/5 1844/16
FOUR [6] 1738/12 1749/13 1763/19 GENERATE [1] 1777/15 1849/5 1849/13 1849/25 1851/10
1776/7 1791/14 1827/3 GENERATED [14] 1766/5 1780/2 1856/20 1857/15 1857/20 1861/13
FOURTH [1] 1746/11 1792/25 1792/25 1793/20 1793/24 1863/2 1863/5 1863/7 1863/8 1863/19
FRAME [3] 1741/20 1759/10 1772/25 1795/7 1796/7 1796/9 1796/9 1807/15 1867/6
FRANCISVILLE [1] 1760/2 1808/15 1808/23 1813/17 GOLDEN [2] 1744/3 1825/19
FRANK [1] 1724/9 GEOGRAPHIC [1] 1806/18 GONE [1] 1740/16
FRANKLIN [1] 1725/17 GEOLOGIST [4] 1728/6 1835/9 1835/11 GOOD [15] 1739/8 1739/10 1756/17
FRANZ'S [2] 1737/13 1859/24 1835/17 1773/11 1777/24 1781/18 1807/2 1815/3
FREE [4] 1742/24 1777/10 1818/9 GEOLOGISTS [1] 1753/20 1823/16 1834/10 1834/21 1838/19
1832/6 GEOLOGY [4] 1727/22 1728/11 1728/17 1839/15 1839/15 1842/21
FREE-SURFACE [1] 1777/10 1735/7 GOODNESS [1] 1855/11
FREQUENCY [1] 1810/3 GEOMETRY [7] 1749/9 1751/24 1778/2 GOSH [1] 1752/3
FREQUENT [1] 1819/5 1810/20 1834/5 1836/21 1847/21 GOT [25] 1736/8 1740/21 1743/8
FREQUENTLY [2] 1729/2 1730/23 GEORGE [1] 1727/15 1751/12 1753/13 1753/13 1754/5
FRESHWATER [2] 1746/14 1825/10 GERM [1] 1843/13 1756/20 1756/20 1784/10 1792/7
FRICTION [1] 1778/3 GET [60] 1737/14 1738/17 1738/23 1800/18 1814/17 1815/22 1818/6
FRICTIONLESS [1] 1814/15 1741/21 1743/5 1743/6 1750/20 1751/11 1831/17 1836/22 1836/23 1837/6 1842/7
FRONT [14] 1744/16 1759/21 1760/16 1753/1 1753/14 1755/6 1759/7 1765/12 1844/2 1851/8 1853/11 1855/6 1860/3
1760/17 1766/1 1789/2 1790/13 1790/20 1773/23 1778/19 1779/1 1783/18 1786/1 GOTTEN [2] 1812/25 1859/16
1790/21 1791/18 1797/5 1822/13 1788/18 1789/1 1790/24 1792/4 1792/5 GOVERNMENT [13] 1724/13 1771/21
1822/16 1823/20 1796/24 1798/23 1798/25 1799/4 1790/14 1795/20 1799/5 1802/9 1806/9
FRONT-SIDE [7] 1789/2 1790/13 1801/24 1801/24 1804/14 1805/9 1806/10 1806/11 1809/6 1838/7 1864/17
1790/20 1790/21 1791/18 1822/13 1812/22 1815/24 1820/21 1824/6 1824/8 1866/10
1822/16 1828/7 1829/6 1835/21 1836/17 1836/21 GOVERNMENT'S [5] 1790/11 1794/9
FRONTED [2] 1820/23 1820/24 1840/14 1842/6 1843/1 1843/20 1844/7 1799/23 1804/20 1810/23
FRONTS [1] 1761/2 1844/18 1849/1 1849/2 1849/3 1851/6 GOVERNOR'S [1] 1732/14
FULL [11] 1727/13 1740/10 1807/25 1851/20 1853/4 1853/10 1859/13 1860/5 GRACE [1] 1863/9
1808/8 1808/10 1809/5 1809/11 1809/13 1860/11 1860/13 1862/11 1863/8 GRADUALLY [1] 1854/17
1809/21 1838/4 1838/7 GETS [7] 1770/25 1813/7 1814/14 GRADUATE [1] 1729/16
FULL-CIRCULATION [2] 1838/4 1838/7 1822/23 1823/2 1843/17 1845/1 GRAPH [3] 1795/24 1807/10 1818/2
FULL-PLANE [3] 1809/5 1809/11 GETTING [9] 1732/15 1783/16 1783/23 GRAPHIC [3] 1761/7 1818/18 1819/8
1809/13 1792/2 1797/7 1810/19 1827/17 1830/1 GRASP [1] 1797/12
FULLY [8] 1758/1 1839/17 1852/23 1837/10 GRASS [3] 1764/8 1826/21 1826/22
1858/4 1859/18 1860/7 1860/22 1860/25 GILBERT [2] 1725/2 1725/3 GRAY [1] 1847/7
FUNDAMENTAL [3] 1752/9 1810/22 GIS [1] 1818/21 GREAT [5] 1744/6 1759/3 1765/11
1833/23 GIVE [10] 1730/20 1735/24 1740/17 1781/14 1831/21
FUNDAMENTALLY [1] 1753/13 1745/24 1745/25 1756/13 1819/25 GREATER [2] 1742/8 1861/12
FUNDING [3] 1747/25 1768/2 1768/2 1844/16 1862/9 1863/14 GREATEST [1] 1747/7
FUNDS [1] 1771/23 GIVEN [7] 1774/9 1774/11 1827/7 GREATLY [3] 1744/20 1765/7 1843/14
FUNNEL [38] 1742/4 1742/10 1742/11 1846/14 1857/21 1862/4 1866/9 GREEN [3] 1799/7 1799/12 1799/17
1742/18 1742/21 1743/15 1743/17 GIVES [5] 1767/9 1769/6 1838/19 GREIF [1] 1725/12
1744/22 1745/21 1746/15 1748/9 1847/18 1847/20 GREW [2] 1844/10 1856/5
1753/12 1754/11 1754/18 1755/19 GIWW [12] 1743/21 1744/1 1744/23 GRID [29] 1795/19 1795/24 1796/1
1756/6 1757/14 1758/13 1763/17 1745/10 1745/23 1748/10 1749/17 1796/20 1796/25 1797/1 1797/2 1797/3
1772/16 1773/4 1777/22 1778/14 1754/19 1773/5 1801/1 1815/4 1815/20 1797/9 1797/14 1797/16 1797/20
1778/16 1778/18 1779/14 1785/6 1835/1 GLANCING [1] 1781/10 1797/23 1797/24 1798/17 1799/5 1799/6
1835/13 1835/21 1843/2 1843/3 1843/6 GO [60] 1738/11 1739/6 1740/10 1799/7 1799/8 1799/18 1799/20 1800/24
1844/8 1845/5 1855/12 1856/1 1856/5 1741/20 1743/4 1751/2 1752/8 1759/6 1801/2 1802/8 1802/9 1802/12 1802/13
FUNNELING [1] 1750/14 1761/7 1763/5 1763/19 1764/10 1765/22 1804/13 1811/7
FURTHER [10] 1745/20 1747/4 1760/16 1766/16 1768/8 1768/15 1774/3 1774/21 GRIDDED [1] 1795/25
1762/14 1764/3 1770/6 1779/9 1779/16 1778/23 1778/25 1780/21 1784/10 GRIDS [12] 1796/4 1796/13 1797/4
1783/16 1795/20 1793/17 1795/17 1795/19 1796/12 1799/24 1800/11 1800/13 1800/16
FURTHERMORE [2] 1765/9 1820/23 1797/21 1798/10 1799/15 1800/22 1800/16 1800/25 1806/9 1811/5 1811/8
FUTILE [1] 1767/6 1800/23 1802/7 1802/19 1803/19 GROUND [5] 1738/18 1852/4 1858/1
1807/23 1810/15 1811/17 1811/24 1859/9 1860/1
G 1814/22 1815/8 1819/14 1822/25 GROUP [7] 1725/7 1729/12 1732/20
G-E-O-R-G-E [1] 1727/18 1823/16 1824/20 1829/4 1830/16 1832/6 1733/9 1736/12 1775/17 1781/22
GAGLIANO [14] 1753/18 1753/20 1833/20 1837/21 1842/4 1848/18 1849/9 GROUPING [1] 1727/24
1755/1 1755/17 1755/20 1757/17 1849/13 1857/8 1860/15 1861/17 GROUPS [1] 1737/5
1768/22 1772/15 1825/24 1826/6 1866/11 1866/21 1866/23 1866/24 GROW [1] 1812/23
1826/11 1826/14 1826/20 1827/2 GOD [1] 1863/9 GROWS [1] 1764/8
GALVANIZED [1] 1736/7 GOES [1] 1829/9 GUARDHOUSE [1] 1781/10
GAPE [1] 1778/17 GOING [63] 1733/22 1734/2 1736/8 GUESS [12] 1744/3 1750/3 1755/22
GATE [5] 1754/11 1840/6 1840/10 1737/14 1738/23 1743/21 1743/23 1756/21 1759/15 1788/9 1791/25
1832/5 1832/18 1832/19 1832/21 HIM [7] 1738/2 1799/10 1827/8 1827/12
G 1857/21 1857/22 1865/23 1832/5 1857/20 1862/11
GUESS... [5] 1820/15 1831/24 1842/21 HE'S [2] 1737/25 1763/1 HIMSELF [1] 1790/1
1843/13 1851/25 HEAD [1] 1829/13 HINTS [1] 1863/15
GUIDE [1] 1732/10 HEALTHY [1] 1769/9 HIRED [3] 1734/6 1735/18 1736/11
GUIDELINES [2] 1766/24 1767/22 HEARD [1] 1789/3 HIS [33] 1728/1 1728/3 1741/20 1775/16
GUIDING [1] 1829/15 HEARING [1] 1864/4 1776/17 1781/10 1784/18 1784/21
GULF [4] 1729/5 1737/18 1744/21 HEARINGS [1] 1755/21 1785/2 1785/3 1786/23 1790/2 1790/6
1844/24 HEC [1] 1824/4 1792/9 1796/22 1799/11 1800/7 1801/21
HEC-RAS [1] 1824/4 1802/19 1805/13 1827/8 1828/22
H HEED [2] 1752/20 1758/19 1828/23 1829/9 1829/12 1829/18
HABITAT [3] 1769/7 1769/10 1769/13 HEEDED [1] 1752/21 1829/22 1829/23 1832/2 1841/2 1857/10
HAD [63] 1731/5 1731/12 1731/13 HEERDEN [2] 1734/10 1734/12 1858/5 1866/9
1732/7 1733/7 1733/13 1733/16 1735/21 HEIGHT [27] 1744/25 1751/21 1778/15 HISTORICAL [3] 1737/16 1748/4
1735/21 1735/24 1738/8 1739/10 1778/21 1779/20 1784/5 1789/8 1789/11 1766/17
1739/15 1739/16 1741/2 1741/3 1741/4 1791/7 1794/2 1795/11 1795/13 1803/6 HISTORIES [1] 1737/18
1741/7 1747/9 1747/20 1747/21 1748/1 1804/11 1807/7 1807/9 1807/10 1810/2 HIT [10] 1736/4 1795/3 1810/16 1812/3
1752/25 1754/17 1757/8 1759/14 1810/4 1810/5 1810/19 1836/10 1838/4 1813/22 1813/25 1815/8 1824/1 1854/24
1762/24 1767/2 1767/4 1767/4 1767/18 1838/12 1842/21 1843/20 1845/24 1855/1
1767/25 1768/22 1772/17 1772/22 HEIGHT-WISE [1] 1789/8 HITS [2] 1794/19 1813/10
1774/2 1774/14 1778/8 1778/17 1786/13 HEIGHTS [5] 1756/22 1792/8 1804/6 HITTING [1] 1733/18
1786/19 1791/13 1793/10 1798/16 1804/20 1812/13 HOLD [2] 1825/5 1844/1
1798/25 1809/8 1825/16 1839/16 1844/4 HELP [4] 1739/22 1806/25 1823/15 HOLDING [1] 1835/19
1845/14 1849/1 1850/2 1852/19 1854/19 1826/1 HOLE [1] 1767/4
1856/22 1859/21 1861/15 1861/18 HELPED [1] 1773/24 HOME [9] 1857/7 1857/24 1858/5
1864/3 1864/20 1865/20 1866/19 1867/2 HELPS [2] 1772/9 1804/16 1858/20 1859/4 1859/19 1859/24
HALF [8] 1747/6 1760/2 1792/17 1809/9 HER [4] 1804/1 1859/7 1864/9 1864/10 1860/14 1860/24
1845/15 1851/20 1852/21 1861/18 HERE [89] 1738/18 1743/14 1743/16 HOMES [2] 1746/22 1828/6
HALF-PLANE [1] 1809/9 1744/2 1744/3 1745/10 1745/22 1749/15 HONEST [1] 1830/5
HAMMER [1] 1794/19 1750/3 1750/9 1750/13 1750/16 1751/1 HONEYCUTT [1] 1724/16
HAND [10] 1737/22 1738/2 1744/7 1751/16 1757/5 1760/2 1764/12 1767/4 HONOR [43] 1727/7 1728/1 1734/16
1754/13 1775/9 1801/20 1814/21 1768/6 1778/16 1778/17 1780/6 1781/12 1735/5 1735/14 1736/19 1740/18
1816/11 1832/16 1832/19 1781/14 1781/17 1784/17 1787/10 1741/16 1741/19 1743/3 1752/18
HANDLE [1] 1778/3 1789/11 1789/12 1791/11 1791/12 1760/15 1768/18 1769/2 1769/25
HANDLED [1] 1763/14 1796/15 1796/23 1796/25 1797/4 1771/13 1771/20 1773/11 1774/4
HAPPEN [3] 1785/5 1785/7 1788/22 1797/15 1798/24 1799/3 1799/18 1774/10 1786/3 1787/19 1792/4 1798/12
HAPPENED [8] 1735/1 1735/21 1738/9 1802/23 1803/10 1803/24 1804/5 1801/5 1810/21 1816/23 1829/1 1829/11
1781/25 1788/21 1819/17 1835/20 1804/18 1807/6 1807/10 1807/11 1830/9 1831/6 1848/5 1862/9 1863/9
1849/11 1808/24 1811/7 1812/4 1812/16 1812/17 1863/16 1863/24 1864/19 1864/25
HAPPENING [8] 1733/24 1733/25 1812/19 1812/24 1813/4 1814/5 1814/7 1865/16 1865/21 1866/3 1867/2 1867/18
1796/3 1797/24 1798/20 1799/24 1814/19 1817/10 1817/11 1817/16 HONORABLE [1] 1723/11
1801/17 1815/10 1817/19 1820/15 1820/20 1822/15 HOPE [1] 1723/16
HAPPENS [1] 1789/21 1834/14 1836/10 1836/12 1836/14 HOPEFULLY [1] 1864/1
HAPPY [1] 1803/12 1836/18 1837/24 1838/23 1839/1 HORSE [4] 1752/16 1752/18 1852/4
HARBOR [2] 1744/22 1751/9 1839/20 1841/18 1845/5 1846/13 1852/6
HARD [6] 1760/6 1793/5 1797/11 1846/21 1847/3 1847/9 1848/21 1853/5 HOUR [16] 1733/2 1752/8 1760/1
1803/15 1806/18 1860/18 1858/1 1858/15 1858/18 1859/10 1781/11 1787/1 1787/2 1788/3 1788/6
HARM [1] 1855/14 1859/11 1859/14 1862/5 1788/16 1789/23 1795/8 1808/25
HAS [35] 1729/3 1730/1 1742/10 1743/1 HERE'S [2] 1743/20 1753/19 1811/13 1812/21 1814/6 1824/8
1753/5 1765/18 1765/25 1767/9 1770/21 HEREBY [1] 1868/4 HOURLY [2] 1781/9 1838/23
1773/3 1773/7 1783/11 1786/10 1789/20 HERSELF [1] 1865/8 HOURS [17] 1735/24 1736/3 1736/14
1796/1 1797/16 1797/23 1798/17 1809/5 HESITATE [1] 1865/15 1736/17 1736/24 1751/18 1783/14
1812/25 1814/9 1816/21 1818/9 1818/17 HIGH [22] 1736/10 1738/25 1739/9 1784/21 1784/22 1784/24 1784/25
1819/20 1823/10 1826/25 1832/21 1778/19 1782/11 1782/17 1783/1 1783/2 1785/16 1786/25 1787/3 1791/14 1813/1
1834/15 1840/14 1843/22 1857/21 1795/9 1796/4 1798/7 1804/20 1805/6 1866/5
1863/2 1865/5 1866/9 1805/6 1806/8 1813/18 1815/5 1815/13 HOUSE [7] 1737/12 1737/13 1857/10
HAS A [1] 1797/16 1815/20 1820/2 1837/13 1843/17 1859/7 1859/13 1861/13 1861/14
HASSAN [1] 1732/24 HIGH-ENERGY [2] 1795/9 1813/18 HOUSEKEEPING [1] 1831/6
HASTEN [1] 1752/5 HIGH-INTENSITY [1] 1820/2 HOW [37] 1733/25 1735/24 1736/24
HASTENING [4] 1746/8 1746/24 HIGH-RESOLUTION [4] 1798/7 1805/6 1737/7 1737/12 1738/24 1739/2 1745/5
1750/17 1750/18 1806/8 1815/13 1751/8 1756/5 1775/12 1775/14 1786/19
HAVE [244] HIGHER [15] 1731/12 1751/2 1766/8 1788/2 1791/8 1793/18 1795/19 1804/20
HAVEN'T [2] 1731/3 1773/6 1778/25 1782/8 1795/3 1798/11 1801/12 1805/6 1805/8 1806/7 1806/9 1810/11
HAVING [7] 1727/11 1734/5 1805/13 1807/17 1808/6 1809/25 1843/2 1843/2 1818/2 1841/11 1843/17 1851/6 1852/6
1833/4 1837/10 1838/3 1845/15 1843/20 1855/8 1857/24 1858/5 1859/6 1859/19 1859/25
HB [1] 1725/20 HIGHEST [3] 1799/16 1803/6 1805/1 1860/7 1860/16 1860/23 1863/5
HB-406 [1] 1725/20 HIGHLIGHT [13] 1731/1 1761/22 HOWEVER [2] 1763/10 1793/6
HE [32] 1755/22 1755/23 1757/8 1761/24 1762/12 1763/7 1768/9 1768/25 HSU [3] 1753/19 1753/21 1757/9
1786/17 1786/25 1787/14 1789/19 1769/3 1770/4 1770/8 1770/14 1771/2 HSU'S [1] 1755/1
1790/4 1799/11 1801/15 1801/21 1823/5 HUGE [6] 1760/3 1760/4 1767/4 1843/21
1802/19 1825/25 1829/6 1829/8 1829/13 HIGHLIGHT B [1] 1769/3 1843/22 1844/7
1829/13 1829/14 1829/15 1829/18 HIGHLIGHTED [4] 1765/1 1771/15 HUMAN [1] 1780/11
1829/22 1829/25 1831/25 1832/1 1832/3 1838/24 1864/14 HUMP [2] 1854/13 1854/14
1838/18 1838/20 1839/8 1839/16 INDUSTRIAL [6] 1858/10 1858/12
H 1839/25 1840/10 1841/2 1841/14 1859/15 1860/5 1860/9 1860/12
HUNDRED [5] 1802/14 1802/18 1813/9 1842/20 1843/23 1844/19 1844/25 INEPTNESS [1] 1865/19
1819/19 1819/19 1846/11 1849/1 1849/2 1849/3 1849/7 INFLUENCE [3] 1728/9 1728/16 1825/4
HURRICANE [24] 1732/21 1732/23 1849/24 1849/25 1850/1 1850/3 1850/4 INFLUENCES [1] 1753/6
1733/5 1733/6 1734/7 1739/23 1742/8 1850/5 1851/17 1852/19 1852/19 1853/9 INFORMATION [20] 1748/3 1748/4
1745/13 1748/12 1748/16 1749/11 1854/7 1855/12 1858/9 1858/11 1858/24 1748/7 1748/19 1762/7 1776/16 1780/2
1763/12 1765/6 1777/20 1777/21 1859/12 1859/14 1860/12 1861/5 1786/23 1792/11 1801/20 1803/18
1780/12 1808/25 1812/11 1855/7 1856/2 1861/13 1862/9 1862/12 1862/12 1805/1 1808/18 1816/11 1818/20
1857/11 1857/25 1860/1 1860/17 1862/12 1862/15 1862/17 1862/25 1832/17 1832/20 1848/19 1848/24
HYDRAULIC [6] 1748/14 1752/9 1863/1 1863/1 1863/1 1863/2 1863/12 1865/5
1752/25 1775/2 1775/20 1834/15 1864/23 1864/25 1865/8 1865/13 INFORMED [1] 1865/4
HYDRAULICALLY [1] 1757/14 1865/18 1866/15 1867/14 INHABITED [3] 1847/23 1849/21
HYDRAULICS [2] 1754/25 1761/12 IF'S [1] 1863/1 1849/22
HYDRODYNAMIC [3] 1728/19 1735/7 IHNC [20] 1737/19 1743/18 1745/1 INITIAL [1] 1752/23
1753/6 1745/3 1779/21 1781/10 1783/8 1784/9 INITIALLY [1] 1736/9
HYDROGRAPH [3] 1846/9 1846/12 1785/4 1817/14 1835/22 1836/13 INITIATIVE [1] 1729/6
1857/16 1836/19 1836/22 1837/1 1843/15 1844/6 INLAND [1] 1819/17
HYDROLOGIC [7] 1759/1 1761/12 1853/13 1862/14 1862/17 INLET [2] 1808/20 1808/21
1833/15 1834/1 1835/6 1839/18 1839/23 II [2] 1724/24 1725/6 INNER [2] 1744/22 1751/9
HYDROLOGICALLY [2] 1835/3 1840/1 ILIT [4] 1735/2 1792/8 1793/2 1794/25 INPUT [2] 1751/1 1775/7
HYDROLOGY [2] 1727/24 1735/9 ILLUSTRATE [1] 1754/2 INPUTS [3] 1776/17 1777/11 1777/14
HYPOTHETICAL [2] 1733/6 1750/5 ILLUSTRATED [1] 1852/6 INQUIRIES [1] 1865/10
ILLUSTRATES [1] 1745/5 INQUIRY [2] 1757/16 1780/23
I ILLUSTRATING [1] 1817/10 INSHORE [1] 1763/1
I'D [3] 1741/19 1768/8 1771/14 ILLUSTRATIVE [3] 1844/16 1857/20 INSIDE [6] 1796/1 1796/5 1796/15
I'LL [10] 1728/3 1740/17 1743/4 1792/5 1866/16 1807/15 1843/19 1844/5
1796/15 1830/8 1832/6 1862/11 1863/14 IMAGE [1] 1744/6 INSPIRATION [1] 1734/1
1864/22 IMAGES [2] 1743/13 1754/3 INSTANTANEOUSLY [1] 1783/13
I'M [69] 1729/21 1729/21 1729/21 IMMEDIATELY [1] 1810/17 INSTEAD [3] 1790/16 1843/6 1859/16
1730/3 1733/14 1737/1 1738/21 1740/6 IMPACT [5] 1763/11 1795/2 1820/21 INSTRUCTIVE [1] 1755/1
1741/6 1751/11 1751/12 1752/7 1760/13 1827/4 1862/16 INSURERS [1] 1725/2
1760/19 1761/19 1764/23 1773/14 IMPACTED [1] 1812/11 INTEGRALLY [1] 1734/12
1773/22 1774/2 1774/9 1778/16 1786/16 IMPACTING [2] 1809/18 1815/2 INTEGRATED [1] 1847/10
1787/10 1787/10 1793/6 1793/24 IMPASSE [1] 1772/1 INTELLECTUAL [1] 1756/13
1794/10 1797/15 1798/6 1798/10 IMPLEMENTED [3] 1754/10 1754/17 INTENSITY [4] 1779/6 1795/23 1813/10
1800/14 1802/17 1804/5 1804/10 1767/8 1820/2
1804/18 1805/14 1807/22 1814/11 IMPORTANT [7] 1746/25 1751/16 INTEREST [4] 1729/21 1802/6 1834/16
1818/3 1821/3 1824/16 1825/15 1828/20 1794/19 1810/20 1826/6 1827/23 1846/21
1830/16 1839/25 1841/3 1844/16 1838/12 INTERESTED [5] 1729/22 1795/23
1846/22 1846/22 1849/4 1849/13 IMPRESSION [2] 1770/23 1786/18 1798/14 1798/24 1802/4
1849/22 1849/25 1850/2 1850/3 1852/8 IMPROVEMENT [1] 1733/23 INTERESTING [4] 1749/13 1750/22
1856/20 1856/22 1857/14 1857/15 IMPROVEMENTS [1] 1752/5 1771/1 1824/3
1858/8 1860/9 1863/3 1863/7 1863/11 IN [546] INTERNAL [6] 1756/1 1764/18 1765/15
1863/12 1863/19 1866/5 1867/6 INACCURATE [1] 1738/10 1766/3 1767/22 1768/16
I'VE [12] 1729/22 1751/12 1753/11 INACTION [2] 1754/22 1767/25 INTERNAL-ONLY [1] 1767/22
1753/18 1770/1 1800/18 1808/8 1818/6 INCH [4] 1844/19 1844/20 1845/2 INTERNALLY [1] 1769/6
1838/24 1848/11 1863/4 1865/4 1845/2 INTERNATIONALLY [2] 1777/1 1827/19
I.E [1] 1770/10 INCHES [3] 1844/23 1844/23 1861/19 INTERPRET [2] 1777/5 1856/20
IDEA [5] 1735/24 1789/2 1843/13 INCLINED [1] 1867/14 INTERPRETATION [2] 1756/7 1842/8
1847/20 1863/2 INCLUDE [3] 1797/1 1831/22 1833/17 INTERPRETING [2] 1851/22 1860/18
IDEAL [1] 1780/11 INCLUDED [4] 1764/21 1766/1 1792/13 INTERRUPT [2] 1815/23 1822/25
IDEALLY [1] 1780/15 1857/17 INTERRUPTION [1] 1756/11
IDENTIFIED [2] 1770/10 1770/12 INCLUDES [1] 1727/23 INTERSECTS [1] 1744/9
IDENTIFIES [1] 1801/6 INCLUDING [9] 1728/15 1735/2 1735/7 INTERVAL [3] 1794/4 1794/15 1794/17
IDENTIFY [1] 1800/5 1735/9 1735/10 1748/4 1767/25 1830/12 INTERVALS [1] 1838/23
IDENTIFYING [1] 1865/8 1832/13 INTO [60] 1734/2 1736/8 1737/14
IF [129] 1735/19 1736/25 1737/7 INCONSISTENT [1] 1767/21 1743/4 1744/25 1751/9 1752/6 1753/1
1737/18 1740/20 1742/21 1742/22 INCORPORATE [1] 1867/4 1763/3 1769/11 1776/10 1776/13
1743/5 1743/7 1746/19 1747/11 1748/21 INCORRECT [1] 1738/9 1776/25 1778/13 1778/14 1781/24
1749/7 1749/20 1750/3 1750/19 1752/2 INCREASE [1] 1745/22 1782/4 1782/15 1783/9 1783/14 1792/2
1752/3 1752/4 1752/10 1753/10 1755/11 INCREASED [6] 1744/24 1746/15 1793/21 1795/1 1799/15 1801/18
1764/3 1767/5 1772/3 1772/9 1772/22 1779/21 1818/9 1825/11 1835/14 1801/24 1801/24 1804/13 1807/9
1773/6 1777/11 1782/1 1782/7 1783/18 INCREASES [2] 1751/20 1843/14 1812/22 1812/22 1813/21 1814/7
1784/9 1785/11 1786/12 1787/3 1787/7 INCREASINGLY [1] 1772/14 1814/14 1814/19 1828/4 1828/5 1828/5
1787/14 1787/21 1787/22 1788/15 INCREMENT [1] 1775/11 1828/7 1829/6 1829/11 1830/1 1835/21
1791/2 1791/16 1792/3 1794/3 1796/21 INCREMENTAL [1] 1828/15 1836/19 1837/7 1838/10 1843/2 1843/6
1797/13 1797/14 1797/21 1798/16 INDEED [1] 1820/11 1843/7 1843/15 1843/21 1843/22
1803/25 1804/25 1808/12 1808/18 INDENTATION [1] 1842/24 1844/22 1848/17 1848/18 1849/19
1813/13 1814/2 1816/2 1816/3 1817/1 INDICATOR [1] 1838/12 1852/4 1857/19 1858/20 1866/21
1818/6 1819/17 1819/18 1821/5 1823/5 INDIVIDUAL [1] 1849/7 INTRACOASTAL [3] 1737/18 1744/21
1823/21 1824/12 1825/10 1827/18 INDUCED [3] 1754/19 1775/4 1822/14 1844/24
1829/1 1832/3 1832/10 1835/17 1836/24 INDULGE [1] 1814/3 INTRODUCED [4] 1782/18 1840/25
JOANEN [1] 1723/19 1811/5 1811/14 1816/24 1817/22
I JOANNES [1] 1739/22 1820/10 1823/18 1830/11 1831/19
INTRODUCED... [2] 1857/19 1867/16 JOB [1] 1801/20 1832/9 1839/25 1848/10 1850/25
INTRODUCES [2] 1757/22 1782/3 JOHN [1] 1725/17 1857/24 1866/7
INTRUDING [1] 1828/1 JOINING [1] 1748/9 KEMP'S [3] 1761/14 1831/8 1857/17
INTRUSION [3] 1763/6 1763/9 1826/7 JON [1] 1865/4 KENT [1] 1857/7
INUNDATION [1] 1779/12 JONATHAN [1] 1723/22 KEY [3] 1835/24 1842/14 1845/25
INVESTIGATED [1] 1737/16 JOSEPH [2] 1723/18 1723/18 KIND [11] 1739/5 1748/17 1786/16
INVESTIGATION [3] 1731/15 1748/19 JOSHUA [1] 1724/20 1796/21 1799/1 1803/18 1818/4 1840/6
1792/10 JR [7] 1723/11 1724/9 1724/16 1724/22 1848/23 1855/1 1863/24
INVESTIGATIONS [1] 1734/25 1724/23 1725/10 1725/13 KINDS [1] 1827/16
INVOKED [1] 1766/22 JUDGE [11] 1723/11 1743/1 1761/16 KINETIC [1] 1813/23
INVOLVE [1] 1748/18 1784/15 1793/7 1796/13 1797/2 1806/25 KNEW [4] 1775/11 1776/4 1808/20
INVOLVED [8] 1732/15 1733/17 1734/12 1841/2 1854/8 1861/5 1865/23
1777/7 1788/14 1822/14 1831/19 1864/3 JULY [10] 1728/2 1740/23 1740/24 KNOCKING [1] 1812/18
INVOLVEMENT [1] 1736/4 1740/25 1741/13 1774/5 1820/15 KNOW [48] 1733/12 1737/12 1739/11
INVOLVING [1] 1742/20 1830/13 1832/14 1832/23 1750/6 1752/3 1753/15 1756/12 1760/25
IPET [18] 1735/2 1781/12 1792/7 1792/8 JULY 11 [2] 1740/23 1741/13 1764/13 1772/8 1781/1 1781/2 1781/3
1792/12 1792/13 1792/17 1793/2 1794/6 JULY 14 [1] 1740/25 1781/5 1782/4 1782/7 1787/14 1792/3
1794/25 1795/13 1803/4 1807/1 1807/22 JULY 2008 [1] 1728/2 1794/3 1804/22 1805/8 1805/14 1806/7
1809/8 1809/9 1843/8 1854/20 JULY 27 [1] 1830/13 1806/9 1807/14 1808/12 1808/19
IS [552] JULY 28 [3] 1740/24 1774/5 1832/14 1808/21 1814/5 1817/1 1820/25 1821/20
ISN'T [4] 1791/2 1808/5 1816/5 1820/10 JUMP [2] 1798/22 1800/5 1823/16 1824/13 1824/20 1828/3 1832/3
ISSUE [2] 1768/12 1835/13 JUNCTION [2] 1743/25 1843/18 1834/4 1839/25 1849/10 1850/15
ISSUED [1] 1767/22 JUST [76] 1728/3 1729/20 1733/14 1859/21 1861/13 1861/16 1862/7
ISSUES [2] 1755/1 1863/14 1741/16 1742/20 1742/24 1743/25 1862/15 1862/18 1866/11
IT [347] 1744/14 1749/20 1752/24 1754/23 KNOWLEDGE [10] 1741/15 1742/17
IT IS [1] 1760/11 1756/11 1757/8 1757/11 1757/11 1760/9 1747/19 1755/25 1758/24 1772/25
IT'S [125] 1733/22 1733/25 1737/1 1760/10 1761/2 1767/2 1770/6 1772/8 1773/3 1809/5 1809/8 1862/15
1740/7 1740/21 1744/1 1747/15 1747/21 1773/15 1779/5 1780/20 1786/1 1788/18 KNOWN [8] 1740/7 1748/7 1759/13
1751/5 1752/15 1752/16 1753/8 1753/15 1790/4 1790/20 1793/8 1797/10 1802/17 1772/23 1816/21 1827/19 1845/6 1856/8
1754/4 1754/8 1761/2 1761/18 1762/23 1803/25 1804/12 1805/9 1807/24
1763/13 1764/6 1764/12 1764/14 1809/21 1812/16 1814/16 1815/23 L
1764/16 1765/13 1765/15 1765/15 1817/11 1817/23 1818/17 1818/22 LA [1] 1763/15
1765/15 1766/4 1766/5 1766/7 1768/22 1819/1 1820/16 1821/2 1821/13 1823/4 LABELED [2] 1734/22 1867/11
1769/11 1769/20 1773/11 1773/24 1823/20 1824/16 1824/17 1825/2 1828/8LABORATORY [1] 1734/3
1774/5 1776/2 1777/9 1777/17 1778/5 1828/10 1833/19 1836/14 1838/4 1843/1LACK [1] 1760/10
1785/7 1786/9 1787/2 1789/22 1790/20 1843/7 1844/5 1844/17 1845/15 1851/10LAFAYETTE [1] 1724/7
1794/19 1794/22 1796/21 1797/11 1861/16 1862/9 1862/11 1862/24 1863/5LAID [3] 1752/10 1831/20 1831/21
1799/14 1800/20 1803/1 1803/2 1803/15 1864/5 1866/2 1866/13 1866/16 1866/16LAKE [51] 1731/8 1731/9 1742/5
1804/22 1804/24 1805/24 1807/16 1866/18 1866/22 1866/24 1743/19 1746/5 1746/15 1746/18
1809/2 1809/3 1810/24 1810/25 1811/13 JUSTICE [2] 1725/9 1865/11 1755/19 1759/22 1762/15 1763/2 1764/1
1811/16 1811/21 1814/14 1815/16 JUSTIFICATIONS [1] 1767/24 1765/9 1769/17 1769/24 1792/10
1815/17 1815/20 1817/18 1818/4 1819/3 JX [2] 1740/24 1774/5 1792/21 1792/24 1792/25 1794/25
1819/4 1819/5 1819/12 1819/20 1820/1 JX-194 [2] 1740/24 1774/5 1801/17 1803/9 1803/22 1803/23
1820/10 1820/14 1821/8 1822/22 1803/24 1804/4 1806/13 1806/14
1822/22 1824/25 1825/2 1825/9 1828/22 K 1806/21 1807/5 1807/13 1807/14
1830/3 1830/19 1833/6 1833/9 1836/23 K-E-M-P [1] 1727/18 1807/14 1807/15 1807/16 1810/15
1836/24 1837/11 1839/18 1839/20 KALIMAH [1] 1725/11 1812/13 1812/16 1813/3 1813/17 1815/6
1841/12 1843/3 1845/1 1845/24 1847/12 KARA [1] 1725/14 1819/18 1820/16 1825/13 1825/17
1847/13 1847/14 1847/16 1848/11 KATRINA [43] 1733/5 1734/7 1735/1 1826/12 1826/15 1826/17 1836/13
1849/6 1850/1 1850/5 1851/13 1851/14 1736/1 1738/7 1738/12 1745/1 1745/13 1837/9 1862/20
1851/22 1851/25 1851/25 1852/21 1750/9 1751/6 1754/10 1754/20 1773/2 LAKE BORGNE [34] 1746/5 1746/15
1853/16 1853/16 1858/13 1861/13 1774/25 1777/21 1779/9 1781/2 1782/1 1746/18 1755/19 1759/22 1762/15
1861/13 1862/12 1863/2 1863/12 1793/3 1806/13 1806/21 1807/3 1812/3 1763/2 1764/1 1769/17 1769/24 1792/10
1863/24 1864/7 1864/14 1864/15 1812/11 1826/3 1827/4 1827/25 1833/16 1792/21 1792/24 1792/25 1794/25
ITS [10] 1734/17 1739/13 1745/6 1751/4 1842/7 1846/1 1846/23 1854/24 1855/9 1801/17 1803/9 1803/22 1803/23
1778/7 1828/22 1839/8 1839/10 1842/4 1855/11 1856/14 1856/19 1857/4 1803/24 1804/4 1806/13 1807/14
1856/1 1857/11 1857/25 1859/7 1860/1 1860/17 1807/16 1810/15 1812/13 1812/16
ITSELF [5] 1732/4 1753/5 1768/5 1779/5 1865/6 1813/3 1813/17 1815/6 1820/16 1825/13
1821/25 KEA [3] 1723/22 1864/3 1865/8 1826/12 1826/17
KEEP [2] 1769/9 1790/23 LAKE PONTCHARTRAIN [9] 1743/19
J KEEPING [1] 1824/7 1806/14 1806/21 1807/5 1807/13
JAMES [2] 1724/6 1725/13 KELLS [1] 1725/12 1825/17 1836/13 1837/9 1862/20
JANUARY [4] 1741/1 1804/10 1831/9 KEMP [51] 1727/8 1727/11 1727/15 LAND [2] 1747/9 1826/17
1831/12 1727/21 1729/17 1734/22 1735/6 LANDS [1] 1770/6
JANUARY 14 [1] 1741/1 1735/18 1736/11 1736/21 1737/15 LANDSCAPE [1] 1752/25
JANUARY 15 [1] 1804/10 1739/12 1740/19 1741/11 1742/2 LANGUAGE [1] 1796/13
JANUARY 29 [1] 1831/9 1742/22 1743/11 1753/10 1756/11 LARGE [11] 1750/18 1762/18 1776/8
JAWS [1] 1778/15 1757/4 1759/25 1760/9 1761/11 1762/2 1782/15 1783/12 1783/13 1808/20
JEFFERSON [1] 1724/6 1763/23 1768/11 1768/20 1769/5 1825/16 1825/17 1843/14 1854/14
JEFFREY [1] 1725/11 1774/20 1782/16 1787/21 1788/20 LARGELY [3] 1734/4 1819/17 1837/12
JETTY [1] 1762/20 1792/7 1796/12 1799/3 1804/18 1806/3 LARGER [2] 1798/21 1804/3
1782/20 1782/21 1783/8 1783/10 1787/5 LLC [3] 1723/21 1724/9 1724/12
L 1787/11 1787/23 1801/22 1802/1 1805/1 LOAD [1] 1844/23
LARGEST [2] 1797/14 1803/8 1814/20 1817/15 1818/5 1820/21 LOBE [3] 1803/9 1803/23 1820/17
LASER [3] 1742/22 1743/2 1836/5 1820/25 1821/3 1821/10 1822/12 LOBES [1] 1804/4
LAST [11] 1732/18 1749/25 1750/13 1823/13 1824/23 1825/1 1840/19 LOCAL [2] 1732/1 1771/21
1763/20 1766/16 1768/8 1828/14 1840/24 1841/13 1841/17 1842/21 LOCALLY [4] 1792/25 1793/24 1795/7
1830/20 1844/5 1854/25 1864/2 1843/20 1845/24 1846/2 1846/3 1846/13 1813/17
LAST OF [1] 1766/16 1847/13 1847/19 1848/15 1848/16 LOCATION [6] 1805/9 1806/18 1851/10
LATE [2] 1753/24 1856/8 1848/17 1848/25 1849/7 1849/18 1858/2 1859/3 1862/14
LATER [15] 1737/14 1738/18 1742/5 1849/18 1850/12 1850/14 1851/11 LOCATIONS [3] 1780/4 1780/5 1848/14
1744/6 1745/7 1747/13 1779/15 1782/4 1851/14 1851/19 1852/16 LOCK [20] 1781/9 1781/10 1782/11
1782/13 1787/1 1789/23 1823/4 1855/16 LEVEE-FACE [1] 1805/1 1782/12 1782/14 1783/2 1783/2 1784/2
1855/24 1856/8 LEVEES [45] 1732/10 1743/17 1745/2 1784/23 1785/11 1786/15 1788/7
LATEST [4] 1772/16 1855/24 1856/13 1749/15 1749/16 1749/21 1750/1 1788/10 1789/6 1789/13 1789/15
1856/18 1750/12 1750/19 1751/14 1751/22 1789/22 1816/13 1836/12 1854/11
LATTIMORE [1] 1858/25 1755/18 1782/1 1785/8 1788/22 1789/1 LOGIC [1] 1757/1
LATTIMORE'S [2] 1857/7 1857/24 1790/12 1790/13 1794/14 1809/18 LOGICAL [1] 1737/6
LAW [7] 1723/18 1723/21 1724/9 1810/12 1813/25 1815/2 1815/9 1816/6 LONG [10] 1764/9 1768/1 1770/16
1724/12 1724/22 1767/8 1841/2 1820/3 1820/10 1820/14 1820/16 1771/6 1771/9 1791/8 1795/1 1823/1
LAWN [1] 1724/3 1820/17 1820/20 1821/19 1822/1 1822/2 1842/20 1863/12
LAWSUIT [1] 1788/15 1822/9 1825/3 1836/16 1836/16 1836/16 LONG-STANDING [2] 1768/1 1771/6
LAWYER'S [1] 1724/13 1838/6 1838/20 1843/4 1843/16 1844/7 LONG-TERM [2] 1770/16 1771/9
LAWYERS [1] 1735/23 1853/24 LONGER [7] 1793/2 1793/8 1793/13
LAY [1] 1828/8 LEVEL [21] 1732/17 1737/25 1747/6 1793/14 1793/15 1798/9 1809/3
LAYMEN [2] 1817/23 1849/6 1747/8 1758/15 1765/9 1766/8 1766/11 LOOK [25] 1730/8 1738/11 1747/4
LEAD [5] 1734/5 1734/6 1734/8 1734/10 1767/9 1791/5 1791/9 1805/16 1805/18 1750/4 1777/25 1797/13 1797/15
1796/22 1805/24 1814/18 1835/24 1838/18 1800/25 1802/15 1804/23 1805/17
LEADING [4] 1748/13 1753/20 1753/21 1861/14 1861/16 1862/19 1862/20 1808/16 1829/1 1835/22 1836/9 1836/24
1827/11 LEVELS [1] 1800/6 1838/4 1838/5 1838/20 1843/24 1847/3
LEASES [1] 1770/4 LEVERAGE [2] 1767/9 1767/10 1849/6 1849/7 1854/10 1867/14
LEAST [16] 1745/18 1747/17 1747/22 LEVINE [3] 1725/13 1727/10 1866/11 LOOKED [2] 1740/20 1806/20
1754/5 1758/6 1764/7 1766/8 1767/14 LIABILITY [1] 1863/3 LOOKING [27] 1737/1 1739/1 1741/6
1772/13 1816/22 1818/8 1819/22 1833/6 LIFE [2] 1759/3 1856/2 1743/20 1750/2 1752/2 1753/17 1758/24
1833/16 1862/22 1867/14 LIKE [55] 1731/6 1735/5 1739/5 1741/19 1764/4 1780/17 1795/25 1798/15
LEAST FROM [1] 1764/7 1741/23 1743/7 1748/15 1749/17 1798/24 1799/24 1801/10 1801/11
LEAVE [1] 1812/22 1755/23 1756/19 1757/14 1760/8 1763/2 1802/22 1807/13 1808/23 1812/10
LEAVES [1] 1751/4 1766/7 1768/8 1771/14 1773/7 1777/17 1812/11 1835/20 1838/9 1838/18 1850/2
LECTURED [1] 1730/23 1787/7 1795/22 1795/24 1796/21 1797/7 1853/7 1858/18
LED [1] 1747/12 1800/5 1800/6 1802/8 1803/7 1804/11 LOOKS [6] 1804/11 1847/2 1847/4
LEFT [11] 1741/3 1743/21 1749/8 1815/14 1815/15 1816/2 1822/9 1825/3 1850/6 1850/19 1858/6
1803/21 1803/21 1811/15 1811/24 1832/4 1834/3 1834/9 1834/23 1834/24 LOS [1] 1723/16
1811/25 1812/10 1812/11 1848/14 1836/5 1841/1 1843/5 1843/6 1845/2 LOSS [4] 1758/11 1800/3 1800/3 1826/8
LEGEND [1] 1847/7 1845/2 1846/11 1847/2 1849/8 1850/4 LOST [4] 1767/5 1769/9 1769/11
LENGTH [3] 1744/6 1797/16 1814/24 1850/6 1850/19 1851/17 1854/8 1854/8 1786/16
LENS [1] 1772/18 1858/6 1861/20 LOT [26] 1730/1 1733/17 1735/21
LESS [17] 1745/19 1793/3 1794/15 LIMIT [2] 1843/16 1863/10 1738/23 1739/19 1748/22 1750/2
1794/17 1795/2 1802/5 1839/11 1841/5 LIMITED [3] 1807/18 1843/23 1863/10 1764/24 1774/23 1775/18 1775/25
1841/11 1842/6 1844/6 1845/13 1847/14 LINE [23] 1750/9 1752/8 1761/23 1778/17 1781/18 1789/3 1795/23 1814/6
1847/15 1857/11 1861/2 1866/6 1766/11 1771/18 1775/8 1775/12 1816/6 1823/10 1823/14 1825/2 1833/2
LESS-ENERGIZED [1] 1793/3 1781/15 1789/10 1789/12 1789/12 1837/12 1845/20 1850/8 1861/15
LESSENED [1] 1827/4 1789/19 1793/2 1799/5 1799/8 1799/23 1863/14
LET [13] 1743/9 1757/4 1772/8 1774/4 1803/20 1814/17 1846/22 1846/23 LOUISIANA [31] 1723/2 1723/6 1723/20
1788/1 1793/25 1811/12 1814/23 1852/24 1853/8 1859/14 1723/23 1724/7 1724/10 1724/14
1822/11 1828/8 1830/15 1839/16 LINEAR [2] 1846/15 1851/12 1724/17 1724/21 1724/25 1725/8
1866/20 LINES [2] 1762/11 1768/8 1725/21 1729/15 1729/16 1730/7
LET'S [57] 1730/25 1732/18 1734/9 LIQUID [1] 1728/12 1730/11 1732/14 1732/16 1733/19
1741/18 1742/21 1744/17 1745/4 LISTED [6] 1734/4 1829/3 1829/6 1734/6 1734/6 1734/13 1735/20 1738/13
1745/24 1746/11 1747/2 1749/19 1831/19 1832/12 1848/11 1747/3 1766/17 1767/17 1772/5 1794/11
1751/11 1752/13 1753/25 1755/11 LISTEN [1] 1787/21 1794/12 1868/4
1761/7 1763/5 1763/19 1764/10 1765/12 LISTINGS [1] 1740/16 LOUTRE [1] 1763/15
1766/16 1767/17 1768/5 1768/15 1770/4 LISTS [3] 1831/25 1863/25 1864/12 LOW [4] 1768/2 1798/6 1813/18 1838/6
1770/24 1771/2 1774/20 1781/4 1782/10 LITIGATION [9] 1725/7 1736/13 1737/2 LOW-LYING [1] 1838/6
1782/17 1790/23 1792/7 1793/17 1738/1 1742/16 1748/15 1865/6 1865/10 LOW-PERIOD [1] 1813/18
1795/17 1795/17 1796/12 1800/22 1865/11 LOW-RESOLUTION [1] 1798/6
1802/15 1803/19 1806/24 1807/20 LITIGATION-RELATED [1] 1865/10 LOWER [20] 1744/7 1747/9 1760/6
1808/19 1811/14 1814/22 1817/4 LITTLE [25] 1744/1 1749/7 1773/22 1764/15 1782/15 1799/15 1799/20
1817/22 1819/14 1820/12 1822/10 1773/23 1780/11 1781/10 1781/18 1801/13 1804/6 1820/4 1821/19 1836/15
1837/21 1844/21 1849/9 1850/4 1857/8 1785/7 1791/24 1793/10 1803/25 1837/9 1850/18 1853/2 1853/4 1853/6
1860/15 1863/13 1804/16 1807/2 1807/17 1809/25 1814/2 1853/8 1854/3 1859/24
LETTER [1] 1767/18 1814/11 1818/7 1818/11 1830/8 1838/22 LPV [22] 1742/6 1743/17 1744/2
LEVEE [57] 1743/23 1749/16 1749/23 1845/11 1849/5 1850/20 1863/3 1744/16 1746/6 1746/7 1749/11 1751/14
1750/15 1751/25 1754/7 1769/23 LIVE [1] 1780/15 1751/17 1753/4 1759/21 1760/16
1774/25 1779/10 1779/14 1779/22 LIVED [2] 1729/15 1779/24 1760/17 1769/22 1775/8 1822/18
MASTER'S [1] 1854/11 MICHELE [1] 1725/12
L MAT [2] 1760/4 1760/8 MID [5] 1745/16 1805/16 1805/18
LPV... [6] 1823/19 1826/21 1826/22 MATCH [2] 1781/15 1781/17 1805/24 1844/11
1827/10 1840/18 1843/16 MATCHED [2] 1740/21 1781/15 MIDPOINT [2] 1801/19 1832/17
LPVS [2] 1821/15 1821/20 MATERIAL [4] 1767/11 1772/4 1821/7 MIGHT [15] 1743/9 1755/9 1757/13
LSU [12] 1729/9 1729/10 1729/13 1832/4 1757/19 1759/19 1796/25 1797/1 1797/3
1730/13 1730/14 1730/17 1730/18 MATERIALS [1] 1821/1 1807/17 1808/9 1830/19 1831/2 1834/2
1732/19 1732/21 1739/23 1777/20 MATHEMATICALLY [1] 1850/1 1847/24 1861/14
1781/22 MATTER [5] 1728/12 1755/21 1755/22 MILE [13] 1744/9 1762/20 1763/1 1772/3
LUCILLE [1] 1859/24 1865/24 1868/7 1795/8 1797/17 1808/25 1812/21 1814/6
LUCKY [1] 1798/18 MAXIMUM [7] 1747/7 1751/1 1778/19 1817/15 1817/23 1818/4 1819/5
LUMPED [1] 1848/23 1804/23 1824/1 1843/16 1845/22 MILE-AN-HOUR [1] 1808/25
LYING [1] 1838/6 MAY [35] 1730/6 1741/12 1761/11 MILES [2] 1761/2 1817/14
1763/9 1764/1 1767/19 1767/23 1769/2 MILIEU [1] 1775/21
M 1769/7 1770/1 1774/6 1774/10 1774/12 MILITARY [2] 1736/9 1756/8
MACHINE [1] 1780/11 1774/13 1774/17 1774/18 1786/1 1792/2 MILLER [1] 1725/14
MADE [11] 1746/7 1756/23 1765/14 1797/6 1802/5 1805/14 1805/20 1809/7 MIND [5] 1733/14 1739/24 1833/12
1765/23 1778/6 1779/15 1799/4 1809/8 1810/16 1823/3 1829/18 1844/17 1833/20 1862/12
1828/12 1832/5 1865/10 1845/22 1848/6 1857/22 1862/22 MINE [1] 1837/5
MAGIC [1] 1753/11 1863/22 1864/10 1864/25 1867/14 MINIMALLY [5] 1752/11 1758/25
MAGNITUDE [1] 1792/17 MAY 1 [2] 1741/12 1864/10 1772/19 1855/25 1856/7
MAIL [5] 1865/1 1865/2 1865/2 1865/17 MAY 24 [1] 1761/11 MINISTRY [1] 1776/1
1865/19 MAY 30 [2] 1767/23 1770/1 MINOR [1] 1751/24
MAILS [1] 1866/1 MAY 5 [2] 1767/19 1769/2 MINORITY [1] 1848/4
MAIN [4] 1724/20 1791/15 1836/20 MAYBE [13] 1749/25 1752/8 1761/6 MINUTE [3] 1761/6 1794/19 1833/19
1849/18 1773/13 1774/12 1793/24 1796/16 MINUTES [5] 1772/9 1773/17 1785/7
MAINLY [1] 1740/9 1797/1 1813/8 1824/18 1829/21 1847/7 1788/12 1830/22
MAINTAIN [1] 1762/24 1859/20 MISCHARACTERIZATION [1] 1734/11
MAINTAINED [3] 1775/3 1782/2 1791/9 MCCONNON [1] 1725/13 MISDATED [1] 1774/6
MAINTENANCE [1] 1771/23 ME [42] 1731/22 1736/7 1739/7 1742/25 MISLED [1] 1794/12
MAJOR [3] 1751/23 1753/6 1789/2 1745/24 1747/3 1747/4 1749/7 1753/15 MISS [2] 1843/24 1855/2
MAJORITY [2] 1779/23 1850/10 1753/25 1757/4 1774/4 1786/22 1788/1 MISSED [2] 1800/19 1855/4
MAKE [14] 1753/22 1765/18 1803/16 1791/2 1791/17 1793/25 1794/8 1797/4 MISSING [1] 1793/24
1814/23 1815/24 1824/16 1827/17 1797/11 1804/16 1811/12 1814/3 MISSION [1] 1738/14
1842/21 1863/25 1864/21 1866/6 1814/23 1822/11 1823/15 1828/8 MISSISSIPPI [7] 1738/14 1751/6 1760/3
1866/18 1866/20 1866/22 1828/13 1830/15 1832/16 1832/20 1760/7 1764/15 1839/5 1855/6
MAKES [2] 1850/8 1866/17 1835/19 1839/16 1839/25 1847/2 1850/3 MISSISSIPPI RIVER [2] 1760/3 1839/5
MAKING [5] 1752/5 1752/5 1768/23 1850/6 1850/7 1850/8 1862/9 1865/15 MISUNDERSTANDINGS [1] 1768/6
1819/9 1828/13 1866/20 MISUNDERSTOOD [2] 1786/21 1792/11
MAN [1] 1746/7 MEAN [13] 1753/1 1762/24 1778/24 MITIGATE [3] 1856/12 1856/17 1857/2
MAN-MADE [1] 1746/7 1783/4 1784/24 1799/12 1801/7 1818/16 MITIGATED [6] 1754/18 1834/8 1849/14
MANAGEMENT [4] 1730/22 1733/7 1822/25 1834/7 1844/6 1859/12 1861/15 1852/23 1860/22 1860/25
1766/22 1767/7 MEANING [2] 1760/18 1856/20 MITIGATION [1] 1754/17
MANAGER [1] 1737/22 MEANS [6] 1737/11 1759/13 1783/7 MITSCH [1] 1725/14
MANAGER/COORDINATOR [1] 1737/22 1809/2 1852/5 1860/25 MIX [1] 1776/3
MANUAL [4] 1816/22 1831/7 1831/10 MEANT [3] 1736/18 1736/19 1825/18 MODE [2] 1733/1 1809/14
1831/11 MEASURE [3] 1754/17 1807/4 1819/12 MODEL [66] 1732/22 1732/25 1737/10
MANY [17] 1728/3 1728/24 1735/24 MEASURED [2] 1807/7 1817/12 1739/13 1739/15 1740/5 1776/13
1736/24 1738/6 1738/7 1748/21 1754/22 MEASUREMENTS [5] 1730/2 1806/13 1777/19 1778/1 1780/21 1780/22
1768/23 1768/23 1773/7 1792/13 1806/14 1819/9 1844/17 1781/21 1781/23 1781/25 1782/1 1782/6
1814/18 1818/16 1821/12 1827/15 MEASURES [5] 1747/25 1748/1 1766/19 1782/6 1782/7 1784/7 1784/11 1786/23
1827/15 1772/23 1825/25 1786/24 1788/3 1788/10 1788/10
MAP [6] 1736/10 1739/2 1739/11 1745/9 MECHANICAL [1] 1725/24 1789/23 1790/8 1792/1 1792/1 1796/19
1754/6 1817/11 MECHANISM [6] 1788/25 1790/20 1796/19 1798/7 1798/7 1803/7 1805/1
MAPPED [1] 1739/4 1820/7 1823/1 1824/25 1824/25 1808/2 1809/3 1809/5 1809/9 1809/11
MARC [1] 1725/13 MECHANISMS [2] 1790/21 1822/14 1809/16 1809/17 1812/12 1823/25
MARGINAL [1] 1771/11 MEDIATION [1] 1766/19 1824/4 1824/4 1827/20 1828/2 1828/14
MARINE [3] 1727/23 1730/14 1735/9 MEETINGS [1] 1755/20 1828/14 1829/2 1829/7 1830/1 1831/23
MARK [1] 1783/1 MEMBER [2] 1733/14 1737/25 1831/25 1832/2 1832/10 1832/13
MARKER [1] 1817/24 MEMO [4] 1755/14 1761/11 1767/23 1832/21 1833/3 1836/16 1838/4 1838/7
MARKS [4] 1736/10 1738/25 1739/10 1768/16 1838/8 1845/4 1845/18
1824/1 MEMORANDUM [3] 1754/8 1755/15 MODELED [6] 1733/6 1753/9 1806/8
MARSH [14] 1746/4 1761/2 1764/8 1756/2 1823/9 1838/1 1855/7
1768/21 1769/9 1769/10 1769/14 MENTIONED [2] 1771/5 1786/16 MODELING [39] 1729/12 1731/15
1801/18 1804/6 1810/15 1813/19 1814/9 MENTIONS [1] 1829/6 1732/18 1732/20 1733/4 1733/9 1735/7
1814/10 1814/13 MERELY [2] 1752/7 1830/3 1739/19 1739/21 1775/1 1775/6 1776/10
MARSHES [4] 1730/8 1746/15 1769/16 MERGED [1] 1811/8 1776/18 1777/2 1777/6 1786/17 1790/1
1825/11 MESSAGE [2] 1753/17 1865/7 1790/2 1795/18 1795/24 1798/4 1799/11
MASHRIQUI [1] 1732/24 METEOROLOGIST [1] 1753/21 1800/12 1808/19 1823/12 1827/18
MASTER [14] 1781/9 1782/11 1782/12 METHOD [1] 1759/6 1827/23 1828/7 1828/9 1829/18 1829/22
1783/2 1783/2 1784/3 1784/23 1788/7 METHODS [2] 1733/11 1774/20 1829/23 1830/3 1832/14 1842/12
1788/10 1789/6 1789/13 1789/15 METROPOLITAN [2] 1736/1 1759/4 1844/13 1851/23 1855/10 1855/21
1789/22 1836/12 MICHAEL [2] 1724/19 1724/19 MODELS [18] 1728/19 1728/20 1728/22
1746/13 1746/20 1747/17 1747/22 NATURE [1] 1810/23
M 1749/10 1749/21 1749/23 1749/25 NAVD88 [1] 1789/11
MODELS... [15] 1729/4 1730/3 1732/10 1750/1 1751/14 1752/23 1753/5 1753/12 NAVIGABLE [1] 1759/25
1733/11 1734/3 1737/6 1738/3 1775/23 1754/12 1754/19 1757/22 1758/17 NAVIGATION [16] 1731/3 1731/24
1794/18 1795/21 1801/21 1803/17 1759/2 1760/19 1760/21 1762/11 1732/6 1733/23 1742/3 1744/20 1744/23
1827/24 1831/18 1832/13 1762/14 1762/19 1762/25 1763/3 1745/23 1746/2 1746/13 1746/20
MODERN [7] 1728/8 1774/24 1775/1 1763/11 1764/19 1766/19 1767/6 1749/10 1751/9 1763/11 1767/12
1775/6 1775/10 1778/3 1834/22 1767/20 1768/12 1768/18 1769/17 1775/15
MODIFIED [1] 1739/22 1770/16 1771/9 1775/3 1775/5 1775/7 NEAR [5] 1776/14 1788/22 1837/2
MOMENT [2] 1753/11 1862/9 1778/6 1798/15 1798/15 1799/24 1800/4 1855/2 1862/14
MONEY [1] 1784/3 1800/8 1801/1 1803/21 1804/5 1804/8 NEAR-SHORE [1] 1776/14
MONICA [1] 1860/14 1804/21 1805/11 1809/6 1809/18 NEARLY [1] 1749/10
MONTH [1] 1766/3 1809/18 1810/24 1811/9 1811/11 NECESSARILY [2] 1740/10 1794/8
MORAIS [1] 1804/14 1812/17 1813/2 1813/22 1814/18 NECESSARY [3] 1764/3 1776/4 1796/6
MORE [34] 1732/6 1739/6 1758/13 1814/24 1815/8 1816/1 1817/4 1817/13 NEED [15] 1732/10 1742/22 1743/4
1761/7 1763/19 1764/24 1773/23 1817/14 1817/14 1818/17 1820/24 1758/3 1759/6 1763/18 1765/7 1786/1
1774/24 1777/25 1778/2 1794/16 1825/9 1825/16 1826/24 1828/15 1788/24 1794/1 1796/6 1807/22 1826/2
1794/17 1797/10 1798/10 1798/13 1828/16 1832/18 1833/25 1834/8 1829/21 1864/24
1805/3 1805/4 1807/23 1808/13 1809/2 1834/12 1835/1 1840/1 1840/10 1841/25 NEEDED [5] 1736/7 1755/23 1777/24
1809/3 1811/8 1812/25 1817/22 1818/22 1843/14 1843/21 1844/10 1844/24 1777/25 1858/19
1825/15 1833/3 1838/12 1841/20 1844/25 1845/7 1845/9 1846/5 1849/14 NEIGHBORHOOD [1] 1758/8
1850/18 1856/6 1858/21 1859/20 1849/14 1849/24 1849/24 1852/12 NEIGHBORS [1] 1779/1
1864/16 1852/23 1855/13 1856/17 1857/12 NEST [1] 1796/4
MORGAN [2] 1724/25 1731/10 1858/4 1859/18 1860/7 1860/22 1861/25 NESTED [1] 1796/13
MORGAN CITY [1] 1731/10 1862/14 1865/6 NET [2] 1842/6 1851/20
MORNING [7] 1782/24 1811/22 1812/3 MRGO'S [1] 1746/24 NETHERLANDS [1] 1776/2
1813/4 1814/17 1838/24 1864/23 MRGO/ROBINSON [1] 1736/23 NEUTRAL [11] 1775/5 1839/18 1839/23
MORPHED [2] 1825/9 1856/23 MS [1] 1730/13 1840/1 1840/4 1849/14 1849/24 1857/12
MORPHING [1] 1857/3 MS. [3] 1737/13 1864/8 1865/23 1858/4 1859/18 1860/7
MOST [14] 1734/1 1738/9 1749/13 MS. FRANZ'S [1] 1737/13 NEUTRALIZES [1] 1840/10
1757/15 1777/11 1799/16 1816/5 1826/6 MS. SHERMAN [2] 1864/8 1865/23 NEVER [9] 1736/14 1747/24 1747/25
1829/13 1832/14 1832/23 1833/12 MUCH [31] 1737/7 1737/12 1745/5 1759/8 1759/16 1772/25 1781/23
1837/8 1862/3 1745/19 1747/9 1759/20 1775/14 1833/20 1854/20
MOSTLY [4] 1728/8 1734/21 1769/22 1778/20 1784/17 1785/15 1794/14 NEW [60] 1723/6 1723/20 1723/23
1853/12 1804/6 1806/12 1809/2 1809/12 1809/20 1724/10 1725/4 1725/4 1725/8 1725/21
MOTHER [1] 1854/24 1839/4 1841/11 1846/1 1857/24 1858/5 1736/2 1736/9 1738/13 1738/19 1741/3
MOTION [1] 1864/4 1859/6 1859/19 1859/25 1860/8 1860/16 1742/6 1742/9 1747/23 1751/14 1754/25
MOTIVATED [1] 1747/4 1860/23 1866/5 1867/12 1867/13 1755/3 1755/16 1759/18 1760/3 1764/16
MOUNTAINS [1] 1842/25 1867/19 1765/24 1765/25 1766/13 1767/18
MOVE [6] 1771/13 1776/25 1777/15 MUD [1] 1814/11 1767/22 1770/9 1778/14 1779/10
1799/3 1843/6 1849/5 MUST [1] 1771/23 1779/13 1779/23 1809/21 1828/5
MOVED [3] 1776/10 1776/13 1801/18 MY [57] 1727/15 1727/22 1728/24 1840/18 1840/24 1841/6 1841/23
MOVEMENT [1] 1728/15 1729/3 1730/1 1732/24 1736/4 1738/2 1845/14 1846/1 1847/19 1847/23
MOVES [3] 1802/1 1802/2 1814/10 1741/15 1742/3 1743/6 1744/20 1746/2 1848/18 1848/25 1849/3 1849/9 1849/21
MOVING [7] 1728/9 1750/25 1751/5 1746/13 1746/20 1747/19 1747/21 1850/13 1850/23 1851/11 1851/19
1802/18 1824/8 1831/3 1831/4 1753/17 1756/7 1756/16 1763/13 1852/25 1854/21 1855/1 1855/3 1855/4
MR [6] 1739/24 1785/19 1828/18 1779/17 1781/14 1788/13 1788/24 1855/11 1860/14 1861/7
1865/22 1866/11 1867/6 1790/2 1801/20 1802/5 1804/9 1804/10 NEW ORLEANS [48] 1736/2 1736/9
MR. [26] 1753/24 1754/24 1755/4 1805/2 1809/8 1815/12 1818/18 1820/15 1738/13 1738/19 1742/6 1742/9 1747/23
1755/9 1755/14 1757/7 1762/2 1762/14 1827/12 1830/13 1831/24 1832/14 1754/25 1755/3 1755/16 1759/18 1760/3
1763/7 1764/12 1764/14 1764/17 1790/1 1832/23 1832/23 1840/3 1840/7 1842/8 1764/16 1765/24 1765/25 1766/13
1792/2 1800/7 1800/12 1802/25 1803/20 1842/10 1844/16 1846/22 1847/1 1767/18 1767/22 1770/9 1778/14
1805/21 1825/6 1828/11 1828/12 1852/22 1855/20 1859/2 1862/12 1779/10 1779/13 1779/23 1828/5
1828/24 1857/24 1863/18 1865/2 1863/24 1865/18 1865/19 1865/24 1840/18 1840/24 1841/6 1841/23
MR. BECNEL [4] 1754/24 1755/4 1755/9 1868/5 1845/14 1846/1 1847/19 1847/23
1757/7 MYER [1] 1725/15 1848/18 1848/25 1849/3 1849/9 1849/21
MR. BECNEL'S [1] 1755/14 MYOPIC [1] 1773/8 1850/13 1850/23 1851/11 1851/19
MR. BOURGEOIS [1] 1828/12 MYRIAD [2] 1770/21 1836/23 1852/25 1855/1 1855/3 1855/4 1855/11
MR. CROSBY [1] 1753/24 MYSELF [1] 1753/15 1860/14 1861/7
MR. EBERSOLE [1] 1790/1 MYTHICAL [1] 1855/8 NEWS [1] 1739/8
MR. EBERSOLE'S [2] 1802/25 1803/20 NEXT [19] 1727/6 1762/10 1763/5
MR. LATTIMORE'S [1] 1857/24 N 1771/18 1771/22 1772/6 1796/20 1797/2
MR. ROY [6] 1792/2 1800/12 1805/21 NAILED [1] 1784/2 1797/17 1797/22 1798/22 1800/6 1802/7
1825/6 1828/24 1863/18 NAME [2] 1727/13 1727/15 1805/19 1806/15 1810/21 1811/17
MR. SMITH [1] 1865/2 NAMES [1] 1848/15 1811/24 1848/15
MR. SMITH'S [1] 1800/7 NARROW [4] 1749/17 1836/21 1837/7 NEXT-DOOR [1] 1806/15
MR. SOUILEAU [6] 1762/2 1762/14 1838/10 NICKEL [1] 1736/25
1763/7 1764/12 1764/14 1764/17 NARROWER [1] 1778/14 NIGHT [2] 1774/2 1864/2
MR. STEVENS [1] 1828/11 NARROWS [1] 1843/2 NINTH [8] 1782/15 1820/4 1853/2
MRGO [123] 1725/7 1733/20 1735/18 NATIONAL [5] 1729/6 1733/14 1733/15 1853/5 1853/6 1853/8 1854/3 1859/24
1736/12 1736/23 1737/7 1737/13 1737/25 1777/14 NO [74] 1731/13 1733/22 1735/11
1737/17 1742/3 1743/18 1743/22 1744/1 NATURAL [7] 1729/12 1732/20 1733/9 1741/7 1742/17 1742/19 1749/15
1744/8 1744/20 1744/24 1745/16 1746/2 1746/4 1767/18 1842/24 1843/4 1749/17 1750/1 1750/24 1750/25
1768/14 1777/5 1780/1 1782/18 1783/10 1813/5 1813/17 1814/14 1816/1 1816/12
N 1784/1 1784/17 1785/5 1785/19 1786/9 1818/23 1819/20 1832/17 1844/17
NO... [63] 1751/11 1751/13 1751/13 1788/20 1789/18 1790/6 1794/8 1797/19 OFFER [2] 1742/20 1867/5
1751/14 1751/14 1752/21 1752/25 1801/4 1803/3 1803/5 1803/9 1803/10 OFFERED [4] 1862/6 1865/18 1866/8
1756/5 1757/18 1759/17 1760/15 1803/17 1805/5 1805/8 1809/7 1809/13 1867/2
1760/16 1761/1 1761/19 1763/11 1809/13 1809/17 1809/23 1811/1 1811/5 OFFERING [1] 1866/21
1765/15 1766/5 1768/5 1773/25 1779/11 1814/22 1815/17 1816/6 1816/11 1817/4 OFFICE [10] 1724/7 1724/14 1724/22
1787/13 1790/13 1799/16 1800/12 1819/14 1828/2 1831/3 1833/12 1834/6 1724/24 1732/14 1765/17 1765/24
1800/13 1806/13 1809/21 1810/7 1835/21 1836/4 1837/23 1838/1 1839/22 1858/25 1865/18 1865/24
1810/17 1821/11 1821/16 1821/22 1841/17 1842/14 1843/19 1844/17 OFFICER [1] 1865/21
1822/2 1823/7 1826/13 1830/18 1833/25 1847/25 1848/2 1849/18 1852/3 1853/5 OFFICES [1] 1723/18
1835/1 1840/17 1841/8 1841/24 1841/25 NSMG [1] 1733/10 OFFICIAL [4] 1725/20 1738/8 1868/2
1844/12 1845/15 1849/24 1850/8 1852/2 NUMBER [16] 1734/20 1740/22 1741/3 1868/11
1852/18 1853/9 1854/19 1855/16 1746/25 1751/18 1754/23 1784/10 OFFICIALS [1] 1753/16
1855/24 1856/8 1856/22 1857/6 1858/11 1794/19 1794/23 1810/25 1831/21 OFFSHORE [6] 1762/19 1763/2 1792/22
1858/16 1860/12 1863/2 1863/11 1839/20 1863/6 1866/16 1867/8 1867/13 1793/20 1796/19 1813/7
1864/19 1864/24 1866/12 NUMBERED [3] 1801/4 1801/4 1868/7 OFTEN [1] 1793/18
NO. [2] 1749/22 1749/23 NUMBERS [4] 1740/18 1801/8 1801/8 OH [8] 1750/6 1763/3 1764/8 1779/4
NO. 2 [1] 1749/22 1805/2 1795/10 1806/1 1821/19 1828/20
NO. 3 [1] 1749/23 NUMERICAL [2] 1775/1 1834/10 OKAY [37] 1727/5 1747/3 1749/19
NOAA [1] 1733/3 1750/4 1761/4 1765/21 1773/9 1781/7
NOBODY'S [1] 1757/4 O 1789/13 1793/5 1793/14 1796/15
NONLINEAR [1] 1801/21 O'BRIEN [1] 1725/3 1796/16 1798/15 1801/14 1802/24
NONMITIGATION [1] 1833/16 O'DONNELL [2] 1723/15 1723/15 1808/15 1809/20 1811/12 1814/8
NORMAL [3] 1729/3 1730/1 1763/9 OAK [1] 1724/3 1817/25 1818/6 1840/5 1841/21 1842/24
NORMAN [3] 1723/5 1737/12 1860/14 OBJECT [2] 1832/7 1857/15 1844/2 1846/12 1847/5 1847/9 1848/16
NORTH [10] 1743/22 1749/17 1759/17 OBJECTED [1] 1866/11 1849/4 1850/22 1851/8 1853/4 1856/20
1762/4 1762/15 1782/14 1821/20 OBJECTION [11] 1735/11 1782/19 1856/24 1862/24
1836/22 1846/2 1862/22 1828/18 1829/8 1830/6 1831/25 1857/19 ON [177]
NORTHERN [1] 1836/25 1857/22 1864/17 1866/10 1866/12 ONCE [10] 1730/25 1740/13 1754/23
NOT [129] 1729/19 1732/11 1733/14 OBLIQUE [1] 1743/20 1764/18 1775/11 1776/16 1782/4
1734/8 1734/8 1740/6 1740/10 1741/16 OBSERVATION [1] 1854/23 1806/17 1815/18 1828/1
1742/11 1742/14 1745/9 1751/17 OBSERVATIONAL [2] 1759/6 1807/2 ONE [74] 1731/2 1731/6 1732/1 1733/13
1751/18 1751/21 1753/10 1754/15 OBSERVATIONALLY [2] 1771/14 1734/5 1734/21 1734/22 1741/12
1755/24 1756/23 1758/21 1759/22 1821/9 1742/24 1743/6 1746/5 1748/21 1749/12
1760/1 1760/13 1761/18 1764/13 OBSERVATIONS [1] 1738/15 1750/10 1753/20 1754/3 1757/10
1764/14 1764/17 1765/15 1766/7 OBSERVE [2] 1738/5 1782/11 1758/21 1760/6 1762/7 1766/14 1767/1
1767/14 1768/12 1770/25 1771/18 OBSERVED [3] 1782/9 1782/12 1783/1 1767/11 1768/22 1774/10 1774/12
1772/1 1772/1 1774/10 1778/20 1780/15 OBSERVING [2] 1738/4 1813/4 1774/13 1780/13 1781/5 1790/22
1781/14 1783/24 1784/6 1784/9 1784/17 OBSTRUCTIONS [1] 1836/23 1795/11 1796/20 1797/17 1798/5
1785/5 1785/17 1785/18 1785/20 1786/9 OBVIOUS [1] 1819/5 1798/18 1798/22 1799/4 1799/8 1799/15
1786/23 1787/9 1788/14 1792/3 1794/4 OBVIOUSLY [5] 1784/12 1793/16 1799/19 1802/12 1803/6 1804/15
1794/8 1795/16 1797/4 1797/6 1799/12 1804/23 1840/6 1849/10 1807/23 1811/17 1811/17 1811/24
1800/12 1802/25 1805/15 1806/9 OCCUPATION [2] 1729/7 1730/6 1818/18 1820/23 1824/8 1825/5 1825/24
1806/11 1808/16 1808/22 1809/8 OCCUR [9] 1804/3 1804/19 1813/13 1826/6 1828/10 1829/14 1831/14
1810/13 1815/23 1815/25 1816/14 1823/21 1840/24 1850/23 1851/3 1831/20 1832/24 1833/19 1836/18
1818/3 1819/5 1819/8 1821/1 1821/8 1858/11 1858/13 1836/20 1838/3 1843/8 1844/1 1844/19
1821/25 1823/5 1823/21 1823/22 OCCURRED [17] 1732/7 1747/13 1844/20 1848/6 1851/22 1855/11
1824/10 1824/11 1824/18 1824/22 1763/3 1791/14 1840/24 1849/11 1860/18 1862/11 1864/13 1865/8
1826/4 1829/16 1829/19 1830/17 1831/4 1849/15 1853/21 1858/5 1858/10 1866/19
1832/3 1833/2 1833/4 1833/17 1834/6 1859/19 1860/8 1860/23 1862/16 ONE-INCH [1] 1844/20
1834/6 1834/7 1834/24 1835/12 1836/24 1862/17 1862/17 1862/23 ONE-TENTH [1] 1802/12
1837/19 1838/4 1838/11 1838/17 OCCURRING [1] 1759/2 ONE-THIRD [2] 1795/11 1803/6
1840/14 1840/24 1843/23 1845/22 OCCURS [2] 1840/17 1860/9 ONES [1] 1805/3
1849/21 1850/1 1850/23 1851/3 1851/25 OCEAN [1] 1728/15 ONGOING [1] 1766/20
1851/25 1852/19 1853/16 1854/12 OCEANOGRAPHER [9] 1728/6 1757/15 ONLY [51] 1738/10 1739/15 1742/13
1854/20 1855/3 1855/8 1856/21 1857/13 1758/23 1772/19 1835/9 1835/11 1746/23 1747/10 1750/14 1756/1
1858/19 1860/19 1861/12 1863/10 1835/17 1856/1 1856/7 1761/19 1767/22 1770/23 1771/23
1863/11 1865/9 1865/14 1866/5 1866/15 OCEANOGRAPHER'S [1] 1855/13 1774/10 1774/12 1774/13 1778/18
1866/24 OCEANOGRAPHER/COASTAL [2] 1781/7 1781/8 1784/9 1788/22 1790/22
NOTE [2] 1857/18 1864/15 1835/9 1835/11 1796/3 1797/4 1805/17 1808/16 1808/20
NOTED [1] 1857/22 OCEANOGRAPHER/GEOLOGIST [1] 1813/12 1813/13 1816/4 1816/17 1821/2
NOTHING [1] 1854/16 1835/17 1821/23 1823/5 1824/8 1827/24 1834/4
NOTICE [3] 1767/20 1767/20 1804/6 OCEANOGRAPHIC [6] 1748/7 1748/13 1834/24 1835/19 1843/9 1849/2 1849/15
NOTICED [2] 1747/4 1808/9 1753/21 1774/20 1775/2 1775/20 1850/9 1853/14 1853/16 1854/10
NOTRE [1] 1781/23 OCEANOGRAPHY [12] 1727/22 1854/10 1854/15 1855/11 1859/15
NOTRE DAME [1] 1781/23 1728/14 1729/4 1730/15 1730/24 1735/7 1861/6 1861/9 1862/15
NOW [80] 1728/19 1729/5 1730/14 1742/15 1753/8 1753/10 1753/12 1757/8 ONSET [7] 1746/8 1746/24 1750/5
1734/20 1740/21 1743/1 1743/12 1777/5 1750/8 1750/13 1750/17 1752/6
1743/16 1746/23 1747/14 1748/24 OCTOBER [1] 1741/1 ONTO [2] 1814/10 1858/20
1749/25 1750/24 1751/12 1752/8 1754/9 OCTOBER 19 [1] 1741/1 OPEN [7] 1746/16 1762/18 1762/25
1754/13 1754/22 1755/24 1761/7 1762/2 OFF [17] 1737/22 1741/3 1743/21 1782/5 1823/25 1825/12 1844/19
1762/19 1763/5 1763/14 1764/4 1768/7 1743/23 1775/9 1776/24 1785/24 1799/3 OPENER [1] 1733/8
1759/22 1769/23 1771/15 1771/24 OYSTER [1] 1770/4
O 1780/6 1782/10 1796/5 1796/16 1798/9
OPERATE [1] 1765/7 1809/23 1810/10 1816/19 1826/1 P
OPERATION [3] 1730/1 1767/21 1831/14 1835/20 1845/15 1850/9 P-A-U-L [1] 1727/18
1771/23 1852/20 1853/21 P-L-A-N-E [2] 1808/10 1808/11
OPERATIONS [1] 1729/3 OTHERS [7] 1735/1 1772/15 1773/7 P.M [1] 1865/1
OPINED [3] 1742/11 1742/17 1854/8 1786/19 1788/3 1790/8 1802/6 P.O [1] 1725/18
OPINION [54] 1732/1 1742/2 1742/3 OTHERWISE [1] 1861/18 PAD [1] 1797/5
1743/11 1744/18 1744/19 1744/20 OUGHT [1] 1806/19 PAGE [67] 1726/2 1741/24 1742/21
1745/25 1746/1 1746/2 1746/11 1746/13 OUR [34] 1736/25 1737/2 1738/16 1743/12 1743/13 1743/13 1743/14
1746/19 1746/20 1746/25 1747/14 1739/16 1739/22 1750/3 1767/2 1780/4 1744/7 1744/17 1744/18 1745/4 1745/24
1747/21 1748/6 1756/16 1758/1 1759/10 1781/13 1781/22 1781/23 1782/7 1746/11 1746/19 1747/2 1749/2 1752/13
1778/5 1784/2 1788/4 1815/11 1815/12 1784/11 1789/6 1794/14 1797/22 1752/13 1753/25 1754/1 1755/11
1820/1 1822/9 1823/6 1823/18 1825/9 1798/17 1798/19 1800/24 1801/15 1755/12 1762/10 1763/5 1763/20
1829/9 1829/10 1829/20 1838/10 1807/20 1809/24 1815/24 1817/15 1764/10 1767/24 1768/15 1770/24
1840/22 1842/9 1842/10 1844/14 1845/6 1820/12 1823/12 1828/12 1830/20 1771/22 1772/6 1772/6 1774/21 1780/3
1845/25 1852/22 1855/15 1855/19 1832/23 1835/4 1854/13 1855/9 1861/5 1781/4 1789/5 1795/17 1796/12 1797/13
1855/20 1855/25 1857/10 1857/21 1864/6 1800/22 1801/6 1801/8 1802/15 1802/22
1858/4 1859/18 1860/7 1860/22 1861/8 OUT [64] 1730/4 1731/14 1732/5 1803/19 1806/24 1806/25 1807/21
1861/22 1733/10 1733/22 1735/22 1735/25 1811/2 1817/5 1822/10 1831/16 1836/1
OPINIONS [8] 1730/20 1731/19 1731/22 1737/4 1738/9 1738/10 1738/23 1738/24 1836/4 1837/21 1842/17 1846/17
1731/23 1817/9 1817/9 1829/12 1862/4 1750/21 1752/10 1754/13 1755/6 1848/12 1857/8 1859/6 1859/6 1859/25
OPPORTUNITY [2] 1730/12 1735/22 1756/25 1757/9 1759/19 1759/21 1761/1 1859/25 1860/15 1860/16 1863/6
OPPOSED [5] 1747/13 1795/5 1830/1 1761/6 1762/25 1765/13 1766/14 1863/10
1836/9 1841/5 1767/23 1771/14 1772/20 1776/25 PAGE 20 [1] 1743/14
OPPOSITION [2] 1771/10 1864/6 1777/20 1778/15 1780/21 1781/10 PAGE 28 [1] 1767/24
OR [76] 1728/23 1730/6 1733/23 1737/3 1785/7 1792/24 1797/2 1801/17 1801/23 PAGE 97 [1] 1807/21
1738/9 1739/7 1739/7 1744/9 1744/9 1803/24 1805/2 1807/1 1810/15 1810/18 PAGES [7] 1728/2 1743/6 1747/16
1749/10 1749/24 1750/17 1753/3 1814/16 1815/20 1827/21 1828/10 1749/6 1754/14 1763/19 1864/13
1755/17 1756/13 1757/5 1757/18 1831/21 1831/21 1836/7 1836/19 PAINTING [1] 1739/5
1760/11 1761/17 1764/13 1766/3 1837/10 1837/13 1838/19 1840/24 PALM [1] 1796/2
1771/24 1772/9 1780/11 1780/16 1841/18 1843/9 1843/12 1844/18 1848/3 PALMINTIER [3] 1724/19 1724/19
1781/21 1781/22 1781/22 1785/20 1850/11 1850/15 1851/18 1864/1 1724/20
1790/15 1791/14 1792/3 1792/11 OUT ON [1] 1850/15 PAM [2] 1733/5 1855/7
1793/18 1794/4 1797/15 1800/6 1803/7 OUTCOME [1] 1826/5 PANEL [2] 1803/5 1807/6
1803/21 1808/5 1808/6 1813/22 1814/18 OUTFLOW [1] 1836/8 PAPER [3] 1795/25 1797/5 1864/24
1817/12 1817/15 1817/21 1819/18 OUTLINED [1] 1834/21 PARAGRAPH [5] 1761/23 1762/10
1819/18 1819/19 1823/20 1829/16 OUTLINES [1] 1745/12 1763/5 1763/20 1770/24
1832/3 1834/3 1834/3 1834/7 1834/14 OUTPUT [2] 1786/25 1803/7 PARALLEL [1] 1820/22
1834/16 1834/24 1840/14 1844/9 OUTSIDE [4] 1755/24 1780/9 1828/3 PARIS [9] 1743/21 1755/19 1756/20
1844/22 1844/23 1845/1 1846/9 1849/14 1828/23 1836/7 1837/14 1837/23 1839/2 1845/8
1849/24 1851/1 1851/4 1854/7 1855/24 OVER [41] 1731/25 1736/13 1738/13 1846/4
1861/16 1864/18 1865/14 1865/19 1743/21 1746/4 1776/16 1777/18 1783/8 PARISH [2] 1853/2 1854/25
1867/8 1867/16 1783/10 1787/5 1787/23 1796/10 PART [17] 1728/25 1730/9 1751/1
ORANGE [3] 1812/9 1847/2 1847/4 1796/24 1799/24 1799/25 1808/14 1758/21 1762/25 1763/2 1763/2 1792/9
ORDER [4] 1745/22 1771/13 1784/25 1810/24 1811/14 1813/7 1813/9 1813/18 1792/24 1813/3 1816/5 1817/17 1818/9
1837/15 1814/13 1815/6 1815/14 1816/6 1818/7 1819/7 1819/9 1848/3 1849/21
ORGANIZATION [1] 1756/8 1819/22 1825/16 1828/5 1838/6 1840/18 PARTICIPANTS [1] 1748/20
ORIENT [2] 1742/24 1804/1 1841/12 1841/17 1845/9 1847/13 PARTICULAR [3] 1829/5 1838/14
ORIENTED [1] 1820/22 1847/18 1848/20 1849/17 1849/18 1848/16
ORIGINAL [10] 1741/5 1744/21 1745/6 1859/11 1859/14 PARTICULARLY [6] 1762/20 1770/13
1745/10 1745/15 1778/7 1834/13 OVERFLOW [4] 1784/25 1853/13 1798/24 1825/21 1825/22 1865/24
1852/13 1855/12 1864/23 1853/14 1853/17 PARTIES [1] 1765/11
ORIGINALLY [4] 1778/6 1779/14 OVERFLOWS [1] 1843/7 PASS [2] 1805/18 1819/15
1827/21 1845/16 OVERHEAD [1] 1836/24 PASSED [1] 1823/13
ORIGINATOR [1] 1740/5 OVERLOOKED [1] 1810/14 PASSING [1] 1804/25
ORLEANS [56] 1723/6 1723/20 1723/23 OVERSAW [1] 1842/12 PAST [4] 1728/21 1732/11 1771/10
1724/10 1725/8 1725/21 1736/2 1736/9 OVERTOP [2] 1809/24 1821/18 1793/17
1738/13 1738/19 1742/6 1742/9 1747/23 OVERTOPPED [6] 1779/22 1791/21 PAUL [7] 1725/11 1725/13 1727/8
1754/25 1755/3 1755/16 1759/4 1759/18 1821/19 1823/13 1836/17 1852/15 1727/10 1727/11 1727/15 1735/6
1760/3 1764/16 1765/24 1765/25 OVERTOPPING [36] 1736/6 1751/22 PAVE [1] 1770/16
1766/13 1767/18 1767/22 1770/9 1753/7 1775/4 1779/10 1779/13 1782/20 PC [2] 1723/15 1724/2
1778/14 1779/10 1779/13 1779/23 1788/23 1788/25 1790/12 1790/21 PEAK [45] 1781/1 1781/1 1781/16
1828/5 1840/18 1840/24 1841/6 1841/23 1791/20 1816/14 1821/25 1822/14 1781/17 1781/18 1783/7 1784/2 1784/18
1845/14 1846/1 1847/19 1847/23 1822/15 1822/19 1822/23 1823/5 1784/21 1785/2 1785/3 1785/5 1785/5
1848/18 1848/25 1849/3 1849/9 1849/21 1823/11 1823/12 1824/14 1824/23 1785/20 1785/23 1786/12 1786/14
1850/13 1850/23 1851/11 1851/19 1836/15 1840/18 1841/6 1846/2 1846/12 1786/20 1787/4 1787/14 1787/21
1852/25 1854/25 1855/1 1855/3 1855/4 1846/14 1847/20 1848/1 1848/2 1848/18 1787/25 1788/14 1788/23 1788/24
1855/11 1860/14 1861/7 1849/19 1850/14 1852/24 1789/1 1789/7 1789/19 1789/20 1789/22
ORLEANS PARISH [1] 1854/25 OVERTOPS [1] 1842/20 1790/15 1807/10 1807/11 1810/5
OTHER [31] 1728/10 1730/3 1731/20 OVERVIEW [1] 1738/17 1811/25 1813/1 1816/13 1824/6 1824/7
1734/25 1741/9 1741/12 1746/6 1747/9 OVERWHELMING [1] 1779/22 1824/14 1836/11 1836/17 1838/18
1754/4 1754/22 1756/13 1759/21 OWN [1] 1736/14 1852/23 1858/1
PLAN [8] 1737/4 1738/16 1743/25 POWERPOINTS [6] 1866/7 1866/13
P 1754/5 1754/5 1754/9 1763/17 1865/7 1866/15 1866/16 1867/2 1867/7
PEAK AT [1] 1785/2 PLANE [8] 1807/25 1808/8 1808/10 POYDRAS [2] 1724/10 1725/20
PEAKED [1] 1791/1 1809/5 1809/9 1809/11 1809/13 1809/22 PRACTICAL [1] 1867/10
PEOPLE [11] 1731/10 1738/6 1739/6 PLANS [2] 1755/10 1767/11 PRACTICE [1] 1776/21
1755/7 1767/1 1818/16 1835/20 1851/14 PLANT [1] 1764/5 PRECEDENT [2] 1771/25 1772/3
1855/6 1855/14 1865/17 PLANTED [1] 1764/1 PRECISE [4] 1743/6 1778/2 1789/16
PER [15] 1758/6 1762/5 1762/6 1837/1 PLANTING [2] 1826/20 1826/22 1820/6
1837/15 1839/2 1839/4 1839/11 1846/15 PLC [3] 1723/18 1724/19 1724/23 PRECISELY [1] 1820/6
1846/15 1847/12 1847/15 1847/17 PLEASE [22] 1727/4 1727/13 1749/1 PREDICT [2] 1782/8 1817/2
1848/19 1851/12 1762/10 1762/12 1768/7 1768/25 1769/5 PREDICTABLY [2] 1746/4 1746/14
PERCEIVED [1] 1771/11 1773/21 1791/2 1800/14 1804/1 1811/3 PREDICTED [2] 1788/8 1806/7
PERCENT [32] 1822/12 1822/13 1816/3 1830/25 1831/1 1833/19 1836/2 PREDICTION [1] 1789/18
1840/19 1841/1 1841/12 1841/17 1850/3 1850/7 1865/9 1865/14 PREDICTS [1] 1808/3
1841/19 1841/19 1842/6 1847/14 PLOT [1] 1791/11 PREMISE [1] 1788/15
1847/15 1847/16 1848/4 1849/1 1849/2 POINT [29] 1737/22 1750/3 1751/16 PREPARED [1] 1740/15
1849/3 1849/15 1849/17 1850/5 1850/12 1759/19 1766/14 1767/23 1768/23 PRESENCE [1] 1843/14
1850/13 1850/15 1850/19 1850/19 1770/22 1771/14 1773/11 1781/16 PRESENT [2] 1725/6 1834/6
1850/20 1851/6 1852/24 1853/14 1782/8 1782/11 1782/17 1783/2 1784/6 PRESENTED [2] 1755/20 1757/19
1853/15 1853/17 1853/25 1854/1 1786/15 1794/10 1801/19 1801/21 PRESIDENT [1] 1729/5
PERCEPTION [1] 1794/14 1803/24 1804/3 1814/21 1815/20 PRESSED [1] 1760/6
PERFECT [2] 1820/20 1850/1 1834/10 1837/23 1840/15 1844/5 1845/3 PRESSURE [1] 1830/18
PERFECTLY [2] 1782/1 1797/12 POINTED [1] 1757/9 PRESUMES [1] 1757/18
PERHAPS [6] 1743/5 1786/21 1810/5 POINTER [3] 1742/22 1743/2 1836/5 PRETERMITTING [1] 1791/18
1813/7 1826/6 1853/4 POINTING [4] 1751/12 1778/16 1804/18 PRETTY [9] 1739/17 1767/9 1767/10
PERIMETER [2] 1738/24 1739/3 1846/22 1803/12 1809/12 1815/3 1819/24 1839/4
PERIOD [11] 1792/18 1803/10 1807/10 POINTS [10] 1780/3 1780/8 1780/13 1842/21
1807/11 1808/3 1810/8 1813/6 1813/18 1788/2 1788/14 1788/16 1801/16 PREVENT [3] 1770/6 1826/1 1826/7
1820/2 1838/25 1845/23 1817/20 1818/25 1848/22 PREVENTED [2] 1759/10 1827/6
PERIODS [4] 1792/7 1792/19 1792/23 POLDER [25] 1776/18 1786/17 1792/1 PREVENTIBLE [1] 1861/22
1810/8 1828/14 1829/17 1829/18 1829/22 PREVIOUS [2] 1756/22 1827/3
PERISHABLE [1] 1739/1 1829/23 1830/3 1831/23 1832/10 PREVIOUSLY [2] 1732/7 1746/5
PERMISSION [1] 1741/19 1832/13 1832/14 1832/21 1833/3 1841/6 PRIMARILY [10] 1766/3 1769/17 1776/8
PERSON [1] 1824/18 1848/16 1848/18 1848/25 1849/9 1818/20 1822/12 1822/22 1823/19
PERSPECTIVE [1] 1735/1 1849/16 1849/19 1849/20 1849/21 1827/8 1830/13 1850/14
PERSPECTIVES [1] 1742/20 1851/11 PRIMARY [16] 1734/9 1734/21 1740/23
PERSUASIVE [1] 1757/19 POLDERS [1] 1848/23 1741/18 1745/25 1745/25 1776/7
PETER [1] 1725/15 POLICY [4] 1768/1 1771/6 1771/18 1777/22 1788/25 1829/12 1834/18
PH.D [1] 1730/13 1772/2 1844/9 1845/7 1846/3 1847/19 1853/21
PHASE [1] 1832/22 PONTCHARTRAIN [11] 1742/6 1743/19 PRINCIPLE [1] 1780/23
PHENOMENA [1] 1822/17 1765/10 1806/14 1806/21 1807/5 PRINCIPLES [2] 1756/17 1757/16
PHENOMENON [1] 1813/5 1807/13 1825/17 1836/13 1837/9 PRIOR [4] 1733/5 1735/23 1748/4
PHILEN [1] 1725/6 1862/20 1769/20
PHONETIC [1] 1804/14 POOR [3] 1803/16 1847/2 1855/6 PRIORITY [1] 1768/2
PHOTOGRAPH [1] 1817/12 POPS [1] 1813/10 PRISTINE [1] 1841/25
PHOTOGRAPHS [1] 1762/4 POPULATED [2] 1746/18 1825/13 PRIVATE [1] 1770/6
PICTURE [3] 1759/8 1800/18 1804/16 PORTION [5] 1743/4 1779/12 1792/15 PRIVILEGE [1] 1728/24
PICTURES [1] 1730/8 1821/5 1847/23 PROBABILITY [1] 1855/14
PIECE [4] 1752/25 1795/24 1821/13 POSED [2] 1742/8 1747/20 PROBABLE [1] 1856/1
1828/10 POSING [1] 1759/2 PROBABLY [13] 1753/20 1769/19
PIECES [2] 1759/7 1811/7 POSITION [5] 1755/3 1755/16 1755/23 1772/8 1775/20 1775/22 1781/7 1785/16
PIERCE [1] 1723/15 1756/12 1834/25 1805/3 1812/21 1814/12 1827/11
PILE [1] 1821/23 POSSESSION [1] 1786/9 1840/25 1848/4
PIPELINE [1] 1733/16 POSSIBILITIES [1] 1816/20 PROBLEM [8] 1741/7 1762/24 1770/11
PIPES [1] 1733/18 POSSIBILITY [6] 1747/24 1750/25 1819/10 1819/25 1822/18 1826/1 1833/3
PIT [3] 1819/19 1819/22 1819/24 1757/13 1758/16 1765/5 1766/12 PROBLEMS [4] 1757/9 1765/2 1772/24
PLACE [13] 1751/14 1753/16 1756/1 POSSIBLE [6] 1738/25 1823/22 1824/22 1865/20
1760/21 1763/16 1781/5 1781/7 1781/8 1824/23 1827/17 1862/25 PROCEED [3] 1727/6 1743/3 1774/17
1796/18 1802/18 1816/4 1819/2 1832/13 POSSIBLY [2] 1765/8 1770/16 PROCEEDINGS [3] 1723/10 1725/24
PLACED [3] 1763/15 1763/17 1862/13 POST [4] 1724/7 1724/14 1724/24 1868/6
PLACEMENT [2] 1769/20 1772/4 1793/17 PROCESS [1] 1833/9
PLACES [5] 1781/3 1804/10 1812/15 POSTDESIGN [1] 1857/2 PROCESSES [2] 1734/2 1842/11
1812/24 1814/19 POSTSURGE [1] 1861/12 PROCTOR [1] 1803/24
PLAINTIFF [5] 1735/23 1736/12 1737/8 POTENTIALLY [1] 1759/3 PRODUCE [1] 1832/1
1867/3 1867/16 POWERPOINT [35] 1741/24 1742/21 PRODUCED [2] 1725/25 1858/16
PLAINTIFFS [22] 1723/15 1723/18 1743/12 1744/17 1744/18 1745/5 PRODUCTS [1] 1775/23
1723/21 1724/2 1724/5 1724/9 1724/12 1745/24 1746/12 1749/2 1752/13 PROFESSION [5] 1728/25 1752/9
1724/16 1724/19 1724/22 1725/6 1727/5 1752/14 1780/3 1781/4 1786/3 1786/5 1757/6 1773/7 1862/7
1727/7 1737/3 1827/5 1828/6 1828/16 1786/7 1789/5 1795/17 1800/22 1801/5 PROFESSION'S [1] 1757/16
1856/14 1856/14 1856/19 1861/21 1806/24 1807/20 1811/2 1817/5 1820/12 PROFESSIONAL [8] 1748/6 1817/9
1861/24 1822/10 1831/17 1836/1 1837/21 1848/6 1819/8 1822/8 1840/22 1845/25 1855/25
PLAINTIFFS' [4] 1737/21 1746/22 1857/8 1859/6 1859/25 1860/15 1867/1 1857/10
1826/2 1857/4 POWERPOINT 66 [1] 1848/6 PROFESSOR [1] 1729/8
PUZZLE [2] 1821/13 1828/10 RATIONAL [1] 1756/16
P PX [44] 1728/2 1734/16 1734/23 RATIONALE [1] 1756/14
PROGRAM [7] 1732/16 1750/3 1767/3 1740/24 1740/25 1741/1 1741/2 1741/9 REACH [122] 1737/17 1737/17 1743/18
1767/7 1767/8 1776/18 1827/20 1742/10 1743/13 1743/13 1743/13 1744/8 1744/9 1744/14 1744/24 1745/4
PROGRAMS [3] 1776/7 1777/2 1777/9 1744/7 1747/15 1748/24 1749/6 1754/4 1745/6 1745/16 1745/20 1745/21 1746/3
PROGRESS [1] 1831/5 1754/4 1755/11 1757/25 1757/25 1761/8 1746/14 1748/9 1751/13 1753/5 1753/5
PROGRESSED [1] 1835/8 1761/8 1764/10 1768/7 1790/8 1807/20 1754/19 1754/19 1758/11 1758/13
PROGRESSIVE [1] 1748/21 1816/23 1831/8 1831/10 1831/16 1759/2 1759/2 1759/11 1760/13 1760/19
PROGRESSIVELY [2] 1796/4 1796/23 1831/22 1832/25 1833/12 1836/4 1760/25 1761/1 1762/20 1766/19
PROJECT [22] 1731/3 1731/24 1742/3 1846/18 1846/19 1848/12 1859/6 1768/18 1769/17 1772/17 1773/5 1778/9
1744/20 1745/11 1745/23 1746/2 1859/25 1860/15 1866/8 1866/16 1778/12 1778/16 1779/8 1779/8 1779/19
1746/13 1746/20 1747/17 1747/22 1867/12 1779/19 1779/21 1784/9 1785/8 1788/14
1749/10 1749/21 1751/15 1752/3 1767/4 PX'S [2] 1867/4 1867/5 1788/22 1790/12 1795/1 1805/25
1770/7 1775/3 1775/15 1825/9 1858/4 PX-09 [1] 1764/10 1806/20 1815/2 1815/14 1817/4 1820/3
1859/18 PX-1771 [3] 1859/6 1859/25 1860/15 1820/25 1821/6 1821/12 1821/15
PROJECT'S [1] 1749/25 PX-193 [2] 1761/8 1761/8 1821/20 1822/9 1822/12 1822/19
PROJECTS [3] 1730/25 1733/23 1768/2 PX-2082 [1] 1768/7 1823/19 1825/10 1826/1 1826/12
PROLONGED [1] 1821/25 PX-2152 [3] 1741/2 1816/23 1831/8 1826/16 1826/17 1826/21 1827/7 1827/9
PRONOUNCE [1] 1763/24 PX-4 [1] 1734/16 1835/14 1835/14 1835/22 1835/23
PROPERLY [2] 1752/4 1807/25 PX-65 [1] 1831/10 1836/7 1836/11 1836/12 1836/19
PROPERTIES [1] 1862/1 PX-68 [2] 1748/24 1749/6 1836/19 1836/25 1837/13 1837/17
PROPERTY [8] 1759/4 1855/15 1856/2 PX-9 [1] 1757/25 1837/19 1838/15 1839/6 1839/7 1839/9
1858/17 1858/20 1860/1 1860/16 PX-91 [23] 1728/2 1734/23 1740/24 1840/11 1843/10 1843/10 1843/11
1861/10 1742/10 1743/13 1743/13 1743/13 1843/15 1843/15 1843/18 1843/18
PROPOSED [6] 1748/1 1749/12 1749/23 1744/7 1747/15 1754/4 1754/4 1755/11 1844/6 1844/24 1845/9 1845/11 1845/11
1750/1 1751/17 1751/25 1757/25 1790/8 1807/20 1831/16 1846/2 1846/4 1846/5 1846/6 1852/12
PROTECT [3] 1769/7 1769/10 1769/13 1831/22 1832/25 1833/12 1836/4 1852/12 1852/15 1853/22 1853/23
PROTECTED [1] 1780/12 1846/18 1846/19 1848/12 1854/1 1855/13 1855/13 1856/5 1856/5
PROTECTION [13] 1746/7 1746/7 PX-92 [1] 1740/25 1856/12 1856/12 1856/17 1856/17
1749/11 1755/18 1759/15 1766/24 PX-93 [1] 1741/1 1857/3 1857/3
1816/22 1825/23 1831/7 1831/9 1831/11 PX-94 [1] 1741/9 REACH 1 [40] 1737/17 1743/18 1744/9
1834/2 1834/16 PX-S [1] 1866/8 1744/24 1745/4 1745/6 1745/16 1745/21
PROTECTIVE [1] 1778/21 1759/2 1778/9 1779/8 1779/19 1779/21
PROTESTS [1] 1861/5 Q 1821/15 1835/14 1835/22 1835/23
PROTOCOL [1] 1732/25 QUADRANGLES [2] 1761/24 1762/3 1836/12 1836/19 1837/17 1837/19
PROVED [4] 1757/14 1779/2 1844/13 QUADRUPLES [1] 1845/1 1838/15 1839/7 1839/9 1840/11 1843/10
1845/18 QUALIFICATIONS [1] 1728/3 1843/15 1844/6 1845/9 1845/11 1846/2
PROVEN [4] 1777/2 1777/17 1793/3 QUANTIFY [1] 1797/14 1846/4 1846/5 1852/12 1852/15 1855/13
1822/6 QUARTERS [2] 1738/8 1738/8 1856/5 1856/12 1856/17 1857/3
PROVES [2] 1753/4 1815/13 QUASI [1] 1756/8 REACH 1/REACH 2 [3] 1753/5 1754/19
PROVIDE [4] 1732/22 1755/15 1866/1 QUASI-MILITARY [1] 1756/8 1843/18
1866/2 QUESTION [23] 1737/7 1768/14 1771/9 REACH 2 [66] 1737/17 1744/8 1744/14
PROVIDED [2] 1733/3 1748/20 1771/18 1779/11 1787/18 1788/1 1745/20 1746/3 1746/14 1748/9 1751/13
PROVIDES [2] 1771/22 1843/16 1788/13 1791/17 1793/7 1797/8 1799/19 1758/11 1758/13 1759/2 1759/11
PROVIDING [1] 1736/5 1800/14 1826/13 1830/5 1830/6 1830/15 1760/13 1760/19 1760/25 1761/1
PRUDENT [6] 1757/6 1757/6 1757/15 1844/12 1852/18 1857/6 1857/22 1766/19 1769/17 1772/17 1773/5
1758/23 1835/11 1835/16 1862/11 1865/14 1778/12 1778/16 1779/8 1779/19 1784/9
PUBLIC [9] 1733/1 1733/1 1753/11 QUESTIONING [1] 1773/16 1785/8 1788/22 1790/12 1795/1 1805/25
1755/6 1755/21 1765/14 1766/4 1766/6 QUESTIONS [4] 1735/21 1796/6 1848/7 1806/20 1815/2 1817/4 1820/3 1821/6
1771/10 1858/25 1821/12 1821/20 1822/9 1822/12
PUBLICATIONS [1] 1734/4 QUICK [1] 1830/20 1822/19 1825/10 1826/1 1826/12
PUBLISHED [1] 1755/24 QUICKLY [7] 1738/25 1739/2 1751/9 1826/17 1826/21 1827/7 1827/9 1835/14
PULL [24] 1741/24 1742/21 1744/17 1782/22 1795/3 1795/17 1810/19 1836/7 1836/11 1836/19 1837/13
1745/4 1746/11 1747/2 1749/1 1752/13 QUITE [8] 1733/8 1760/13 1795/16 1843/10 1843/11 1843/15 1844/24
1753/25 1755/11 1761/8 1768/5 1768/7 1799/14 1803/4 1822/2 1838/8 1856/16 1846/6 1852/12 1853/22 1853/23 1854/1
1781/4 1795/17 1806/24 1807/20 1811/2 1855/13 1856/5 1856/12 1856/17 1857/3
1817/5 1820/12 1822/10 1836/1 1842/17 R REACHED [2] 1731/23 1862/20
1864/2 RACE [1] 1813/25 REACHES [2] 1762/19 1770/10
PURPOSE [5] 1755/15 1760/5 1780/6 RACEHORSE [1] 1777/17 READ [21] 1730/7 1748/21 1755/13
1811/14 1827/12 RAILROAD [1] 1836/23 1756/17 1757/9 1763/23 1763/25 1765/3
PURPOSES [3] 1738/1 1777/2 1866/3 RAISE [1] 1732/10 1766/2 1768/4 1768/11 1768/20 1769/5
PUT [44] 1731/5 1731/9 1736/13 RAISED [2] 1732/3 1732/3 1770/4 1771/8 1785/22 1796/21 1804/15
1736/24 1743/2 1743/6 1749/20 1750/10 RAN [7] 1749/9 1792/9 1807/24 1809/24 1823/4 1844/5 1858/8
1750/19 1753/15 1754/6 1755/9 1759/8 1827/15 1830/12 1832/21 READILY [1] 1764/9
1759/15 1759/17 1759/20 1760/10 RANCOR [1] 1766/20 READING [4] 1753/16 1788/24 1800/7
1760/15 1760/21 1778/2 1781/13 RANGE [5] 1811/11 1812/18 1813/21 1838/19
1781/23 1782/2 1782/5 1793/5 1793/6 1813/22 1815/7 READINGS [1] 1781/11
1795/22 1798/19 1801/15 1804/12 RANGED [1] 1758/9 READS [1] 1765/3
1814/2 1814/6 1818/17 1827/25 1829/2 RAS [1] 1824/4 READY [2] 1727/5 1824/20
1834/15 1835/5 1837/25 1839/8 1839/17 RATE [5] 1760/21 1762/4 1838/2 REAL [3] 1771/11 1784/20 1806/18
1839/22 1847/9 1848/20 1865/17 1840/19 1846/14 REALITIES [1] 1784/19
PUTTING [6] 1734/13 1767/19 1813/16 RATHER [4] 1774/2 1798/7 1843/4 REALITY [25] 1738/5 1777/12 1780/17
1830/15 1834/8 1837/7 1850/19 1780/21 1781/2 1783/17 1783/20
REFERRED [7] 1748/25 1761/16 1831/7 REPORTING [2] 1795/14 1803/17
R 1854/8 1866/7 1866/8 1867/3 REPORTS [20] 1734/20 1738/7 1740/13
REALITY... [18] 1783/21 1785/10 REFERRING [4] 1734/21 1769/16 1740/15 1740/18 1741/9 1748/4 1748/5
1785/17 1785/18 1786/15 1786/25 1846/16 1866/25 1755/20 1774/8 1789/20 1789/25 1790/6
1787/2 1787/3 1787/9 1788/2 1788/3 REFLECT [2] 1804/20 1818/12 1799/25 1804/15 1808/9 1823/4 1830/11
1793/3 1806/17 1816/13 1824/10 REFLECTED [3] 1747/14 1792/17 1833/7 1862/5
1824/11 1828/1 1828/2 1804/19 REPRESENT [3] 1765/19 1797/3
REALIZED [1] 1757/7 REFLECTING [1] 1743/12 1865/21
REALIZING [1] 1844/16 REFUSAL [1] 1757/12 REPRESENTATIVE [2] 1744/15 1848/24
REALLY [37] 1731/11 1733/24 1736/7 REGARDED [1] 1784/6 REPRODUCE [2] 1734/3 1808/1
1736/7 1745/6 1747/4 1747/11 1747/15 REGENERATING [3] 1813/14 1814/18 REQUEST [2] 1728/23 1801/15
1749/24 1752/3 1752/23 1753/18 1777/9 1819/14 REQUIREMENT [1] 1863/6
1780/13 1785/19 1790/19 1792/19 REGENERATION [7] 1798/25 1810/24 RESCUES [1] 1738/23
1798/20 1803/3 1804/12 1805/18 1813/11 1815/14 1816/21 1817/2 RESEARCH [7] 1729/8 1730/17 1730/18
1813/14 1817/18 1825/20 1826/25 1819/21 1730/20 1733/10 1733/16 1775/22
1832/1 1833/24 1835/21 1836/18 REGION [1] 1751/4 RESIO [6] 1785/19 1786/19 1786/25
1849/10 1853/7 1853/8 1855/1 1857/21 REGIONAL [2] 1825/15 1826/9 1789/6 1799/10 1803/19
1859/12 1859/17 1860/19 REGULAR [1] 1795/24 RESIO'S [2] 1785/23 1802/25
REALTIME [2] 1732/22 1777/25 REGURGITATING [1] 1741/22 RESISTANCE [1] 1814/8
REASON [12] 1749/12 1755/8 1760/16 RELATED [3] 1733/19 1791/8 1865/10 RESOLUTION [25] 1796/4 1796/5
1761/19 1768/16 1769/5 1781/19 1798/5 RELATES [1] 1831/24 1797/8 1797/15 1797/23 1797/23 1798/6
1835/10 1841/2 1861/5 1862/13 RELATING [1] 1831/25 1798/7 1798/11 1798/17 1799/1 1799/20
REASONABLE [2] 1756/7 1862/6 RELATIVE [1] 1745/10 1800/3 1800/20 1800/23 1800/24 1803/2
REASONABLY [1] 1757/14 RELEVANCE [1] 1771/16 1803/15 1805/6 1806/8 1809/19 1809/20
REASONS [4] 1732/2 1772/1 1775/18 RELEVANT [3] 1794/8 1810/11 1865/6 1809/21 1810/13 1815/13
1836/20 RELIABLE [2] 1732/22 1777/1 RESOLVED [1] 1771/19
REASSESS [1] 1759/7 RELIABLY [1] 1827/13 RESOURCES [1] 1767/18
REASSURING [1] 1803/2 RELIED [1] 1792/8 RESPECT [4] 1772/16 1829/20 1834/1
REBUILD [2] 1810/15 1814/16 REMAINING [1] 1813/9 1834/16
RECALL [4] 1738/6 1756/18 1782/20 REMEDIAL [4] 1747/25 1758/3 1772/23 RESPOND [2] 1756/5 1765/25
1803/14 1856/9 RESPONDED [2] 1865/16 1865/19
RECEIVED [1] 1865/2 REMEDIATE [1] 1826/23 RESPONDING [1] 1754/25
RECENT [2] 1832/24 1833/13 REMEDIATED [2] 1834/7 1839/17 RESPONSE [5] 1756/5 1765/13 1765/16
RECENTLY [3] 1733/14 1736/3 1759/16 REMEDIATION [6] 1825/25 1826/3 1766/15 1828/24
RECESS [5] 1773/17 1773/19 1830/21 1826/10 1845/15 1852/21 1855/16 RESPONSIBILITY [1] 1737/9
1830/24 1867/22 REMEMBER [9] 1756/8 1767/1 1774/9 RESTORATION [5] 1732/14 1732/15
RECOGNIZE [2] 1752/17 1753/11 1784/8 1793/16 1818/13 1838/16 1853/9 1733/12 1767/3 1769/8
RECOGNIZED [6] 1751/19 1759/1 1860/10 RESTORE [6] 1767/3 1767/13 1768/21
1777/1 1835/12 1855/15 1856/1 REMOVE [3] 1731/19 1835/1 1835/3 1769/10 1826/17 1834/5
RECOGNIZES [1] 1770/10 REMOVED [2] 1731/16 1731/17 RESTORED [1] 1767/5
RECOMMENDATIONS [1] 1768/22 RENDERED [2] 1731/20 1734/20 RESTORING [1] 1729/22
RECOMMENDED [1] 1766/18 RENDERING [1] 1829/8 RESTRICTED [1] 1838/11
RECON [2] 1738/14 1770/9 REOFFER [1] 1864/5 RESULT [7] 1743/7 1789/24 1800/3
RECONNAISSANCE [2] 1757/21 1766/2 REPAIR [2] 1739/2 1768/21 1824/6 1853/3 1855/12 1859/22
RECONSTRUCTING [1] 1735/25 REPAIRING [1] 1771/6 RESULTED [1] 1732/6
RECORD [29] 1727/14 1728/2 1734/22 REPEAT [1] 1856/16 RESULTING [1] 1855/14
1740/17 1740/18 1740/19 1740/20 REPEATED [2] 1762/9 1858/24 RESULTS [15] 1738/2 1739/13 1739/16
1741/6 1741/16 1755/21 1755/22 REPLACED [1] 1859/21 1790/2 1792/11 1823/12 1827/17
1758/21 1766/1 1781/8 1788/18 1808/10 REPLICATED [1] 1834/22 1828/22 1829/5 1829/7 1832/1 1833/3
1811/14 1823/14 1831/3 1846/16 REPORT [82] 1728/2 1734/7 1734/14 1848/13 1854/13 1857/16
1854/10 1854/12 1854/15 1864/1 1866/3 1734/22 1735/3 1735/21 1740/20 RETAINED [3] 1735/23 1736/23 1737/2
1866/21 1866/21 1866/24 1868/6 1740/23 1740/24 1740/24 1740/25 RETURN [1] 1820/19
RECORD STANDPOINT [1] 1866/21 1741/12 1741/13 1741/14 1741/22 RETURNED [1] 1839/10
RECORDED [3] 1725/24 1784/2 1742/11 1747/15 1748/25 1753/2 REVEALED [1] 1789/16
1789/22 1753/25 1754/14 1755/2 1755/12 1757/9 REVEGETATION [1] 1827/2
RECORDS [1] 1780/13 1757/21 1757/25 1758/15 1758/22 REVIEW [2] 1732/9 1766/8
RECTIFIED [1] 1743/8 1761/15 1761/17 1762/9 1764/21 REVIEWED [2] 1734/25 1753/18
RED [9] 1789/12 1804/2 1804/19 1765/13 1765/16 1765/18 1766/1 1766/2 REVIEWERS [2] 1758/15 1766/11
1804/19 1812/8 1812/25 1837/2 1846/23 1767/24 1770/9 1773/13 1774/5 1774/7 REVIEWING [1] 1748/3
1847/1 1779/18 1781/12 1785/22 1785/23 RHETORIC [1] 1773/12
REDDER [1] 1801/12 1790/7 1792/13 1794/6 1794/7 1799/10 RHETORICAL [1] 1768/14
REDDISH [1] 1812/8 1801/8 1803/20 1804/9 1804/10 1804/24 RICHARD [1] 1725/16
REDUCE [2] 1765/5 1765/7 1807/1 1807/22 1820/15 1828/22 RIDE [1] 1852/6
REDUCED [8] 1763/9 1765/10 1784/13 1828/22 1828/23 1829/9 1829/18 RIDGE [1] 1763/15
1840/19 1840/19 1843/12 1847/17 1829/22 1829/23 1830/13 1830/14 RIDING [2] 1730/10 1807/4
1852/24 1831/8 1831/13 1831/15 1832/2 1832/9 RIGHT [193]
REDUCING [4] 1746/4 1746/17 1825/12 1832/14 1832/23 1833/13 1836/4 RIGHT-HAND [1] 1744/7
1825/12 1846/17 1848/12 1854/19 1857/16 RIGHT-OF-WAY [2] 1770/7 1804/8
REDUCTION [2] 1840/25 1853/16 1857/17 RIJKSWATERSTAAT [1] 1776/2
REFERENCE [5] 1728/1 1753/25 1780/5 REPORTED [7] 1780/2 1789/6 1792/12 RIPRAP [1] 1760/11
1786/6 1867/9 1795/11 1799/25 1803/4 1806/21 RISE [8] 1727/3 1773/18 1773/20
REFERENCED [2] 1761/10 1801/7 REPORTER [4] 1725/20 1739/25 1868/3 1810/19 1830/23 1830/25 1843/6
REFERENCING [1] 1867/7 1868/11 1867/21
SAWYER'S [1] 1739/5 SECTION [11] 1744/8 1744/23 1745/21
R SAY [47] 1728/11 1734/9 1734/11 1759/21 1768/8 1771/22 1821/10
RISEN [1] 1789/21 1737/4 1737/24 1747/23 1749/20 1836/15 1837/25 1839/2 1839/2
RISK [1] 1747/23 1749/24 1752/3 1753/11 1756/9 1757/17 SECTIONS [1] 1821/24
RISKS [2] 1747/20 1759/3 1760/10 1766/4 1771/4 1778/18 1784/24 SEDIMENT [2] 1732/2 1732/5
RIVER [5] 1731/7 1760/3 1760/7 1785/23 1787/17 1793/18 1794/11 SEDIMENTATION [1] 1732/7
1836/18 1839/5 1802/16 1806/12 1808/8 1808/19 SEDIMENTOLOGY [3] 1727/24 1730/24
RIVERS [1] 1728/8 1809/20 1810/13 1810/24 1810/25 1735/10
ROAD [7] 1743/21 1755/19 1756/20 1814/5 1815/3 1819/17 1822/11 1827/15 SEE [61] 1733/20 1743/20 1745/20
1836/7 1837/14 1839/2 1845/9 1831/21 1841/3 1841/19 1844/21 1847/1 1749/13 1749/15 1750/6 1750/16
ROB [1] 1786/10 1848/1 1848/24 1848/25 1849/5 1850/4 1752/10 1766/7 1770/24 1782/17
ROBERT [1] 1725/6 1850/9 1853/7 1858/17 1784/10 1785/12 1787/4 1787/22 1788/2
ROBIN [3] 1725/15 1865/2 1865/15 SAYING [12] 1760/19 1763/1 1787/14 1789/12 1791/10 1791/11 1793/23
ROBINSON [7] 1723/5 1735/18 1736/23 1794/1 1794/2 1794/10 1794/20 1802/17 1796/15 1796/23 1797/4 1797/14
1737/3 1737/8 1746/22 1827/5 1830/1 1839/22 1850/17 1851/2 1797/16 1797/24 1798/20 1801/14
ROBINSON'S [2] 1737/12 1860/14 SAYS [14] 1755/14 1763/23 1764/22 1806/19 1807/10 1807/15 1807/19
ROBINSON/MRGO [1] 1735/18 1765/4 1768/16 1770/6 1770/24 1790/14 1807/25 1809/1 1812/4 1812/4 1812/5
ROBINSONS [7] 1779/23 1841/23 1797/5 1822/9 1858/11 1858/16 1859/10 1812/17 1812/21 1812/24 1813/5
1842/6 1845/14 1851/20 1861/7 1861/9 1859/11 1815/24 1815/25 1816/1 1817/13
ROBINSONS' [1] 1852/16 SCALE [5] 1776/8 1776/11 1789/14 1819/21 1819/23 1825/2 1828/19 1829/2
ROCK [1] 1769/21 1812/6 1812/6 1834/15 1836/10 1836/12 1836/18
ROCKS [3] 1759/20 1760/10 1760/21 SCALED [1] 1818/22 1836/25 1837/5 1837/13 1839/3 1845/22
ROLE [2] 1733/2 1746/24 SCALING [1] 1811/10 1845/23 1846/13
ROLLING [2] 1787/5 1795/2 SCENARIO [42] 1774/25 1789/10 SEEING [13] 1730/3 1731/12 1734/1
ROOM [1] 1725/20 1790/8 1828/9 1833/13 1833/15 1833/22 1736/6 1749/8 1803/3 1803/8 1803/11
ROUGE [3] 1724/14 1724/21 1729/10 1834/11 1834/12 1834/18 1839/3 1804/16 1807/6 1808/2 1810/8 1852/8
ROUGH [1] 1851/21 1839/12 1839/13 1839/16 1839/21 SEEKING [2] 1739/12 1865/5
ROUGHLY [1] 1844/19 1840/4 1840/9 1840/17 1840/20 1841/9 SEEM [4] 1766/15 1780/20 1791/12
ROUTINELY [1] 1819/7 1841/25 1846/24 1847/6 1847/12 1854/14
ROY [10] 1724/5 1724/6 1739/24 1792/2 1847/14 1848/20 1848/20 1848/21 SEEMED [1] 1739/16
1800/12 1805/21 1825/6 1828/18 1849/2 1849/10 1850/4 1850/25 1851/11 SEEN [4] 1773/6 1805/15 1854/20
1828/24 1863/18 1851/13 1853/9 1853/14 1855/3 1858/7 1855/15
RULING [1] 1866/2 1858/14 1859/22 1861/6 1862/25 SEGMENT [1] 1849/7
RUN [8] 1737/5 1739/16 1781/21 SCENARIO 3 [1] 1841/9 SEND [1] 1765/17
1786/23 1796/10 1808/14 1809/13 SCENARIOS [8] 1828/7 1830/12 SENSE [3] 1798/23 1850/8 1866/17
1832/12 1831/20 1832/10 1832/12 1832/12 SENSITIVE [3] 1837/18 1838/11
RUNNING [3] 1781/22 1781/23 1804/5 1834/24 1835/24 1838/21
RUNS [6] 1737/10 1781/21 1790/8 SCHEMATICALLY [1] 1745/17 SENSITIVITY [2] 1827/15 1847/20
1798/13 1801/21 1809/3 SCHEME [2] 1832/11 1832/16 SENTENCE [9] 1761/23 1761/24 1763/6
RUPERT [1] 1725/14 SCHOOL [3] 1729/8 1729/13 1729/14 1763/7 1763/20 1763/23 1763/25
RUSH [2] 1747/18 1753/6 SCIENCE [5] 1730/15 1752/9 1780/24 1764/18 1765/1
RÉSUMÉ [2] 1731/1 1734/4 1819/7 1855/21 SEPARATE [2] 1743/12 1750/21
SCIENCES [4] 1727/23 1728/14 1730/14 SEPARATED [2] 1746/5 1811/13
S 1735/9 SEPTEMBER [4] 1738/12 1741/9 1865/1
S.W [1] 1724/17 SCIENTIFIC [9] 1756/13 1756/17 1757/1 1865/25
SAFETY [3] 1733/1 1733/2 1733/16 1757/16 1780/23 1816/17 1834/19 SEPTEMBER 2 [1] 1738/12
SAID [19] 1735/1 1736/18 1756/17 1842/11 1862/7 SEPTEMBER 23 [1] 1865/1
1774/5 1788/11 1792/18 1792/21 1800/6 SCIENTIFICALLY [7] 1753/4 1777/2 SEQUENCE [4] 1739/18 1746/10
1806/19 1819/4 1828/11 1831/7 1834/20 1779/2 1785/9 1821/9 1822/6 1848/7 1747/13 1823/21
1841/17 1842/20 1845/2 1860/10 SCIENTIST [6] 1729/17 1729/20 SEQUENCES [1] 1737/6
1864/20 1865/3 1729/25 1738/3 1751/11 1757/6 SEQUENCING [1] 1739/13
SALINITY [5] 1746/16 1763/14 1765/9 SCIENTISTS [3] 1730/5 1730/7 1776/4 SERIES [3] 1767/24 1796/15 1848/14
1825/11 1825/16 SCOPE [2] 1828/23 1829/9 SERIOUS [1] 1748/11
SALT [1] 1764/8 SCOTT [1] 1723/19 SERVE [1] 1733/15
SALTWATER [3] 1763/6 1763/9 1826/7 SCOUR [1] 1732/5 SERVICE [3] 1733/3 1733/8 1777/14
SAME [32] 1737/25 1739/9 1743/7 SCREEN [2] 1736/6 1846/22 SESSION [5] 1723/10 1727/1 1727/4
1750/2 1751/8 1753/19 1764/12 1770/24 SCRIBE [1] 1734/9 1773/21 1831/1
1774/23 1785/6 1788/15 1792/13 SCURRIED [1] 1864/2 SET [2] 1751/4 1778/2
1795/14 1796/1 1796/18 1803/18 1812/7 SEA [5] 1747/6 1747/8 1809/2 1861/14 SETTING [1] 1752/7
1819/16 1821/1 1821/7 1824/5 1824/6 1861/16 SETTLES [1] 1756/21
1834/6 1834/7 1838/8 1843/5 1845/20 SEARCHED [1] 1865/17 SEVEN [2] 1772/9 1864/8
1858/7 1858/14 1858/24 1858/24 SEAS [3] 1793/1 1793/24 1808/3 SEVERE [2] 1826/7 1855/2
1859/22 SEASHORE [2] 1843/1 1843/4 SHADES [1] 1812/5
SANDBAR [4] 1813/6 1813/8 1813/19 SEATED [3] 1727/4 1773/21 1831/1 SHALL [2] 1734/11 1778/18
1819/15 SECOND [25] 1744/17 1744/19 1747/16 SHALLOW [2] 1807/14 1810/16
SARAH [1] 1725/16 1750/11 1763/7 1765/1 1766/16 1769/5 SHE [1] 1864/11
SATELLITE [1] 1817/12 1789/12 1792/19 1794/13 1795/3 SHEENA [1] 1743/9
SATISFACTION [1] 1778/5 1811/11 1825/6 1837/1 1837/15 1839/3 SHEET [2] 1821/23 1864/13
SAVE [1] 1771/13 1839/4 1839/11 1844/1 1846/15 1853/8 SHEET-PILE [1] 1821/23
SAW [14] 1740/12 1748/6 1748/11 1854/7 1854/12 1854/16 SHERMAN [5] 1723/22 1864/3 1864/8
1784/23 1788/7 1789/13 1789/15 SECONDARY [1] 1791/14 1865/8 1865/23
1795/13 1806/19 1826/18 1843/8 SECONDS [6] 1792/23 1793/16 1793/19 SHERWOOD [1] 1755/17
1843/11 1848/19 1854/19 1793/23 1803/11 1808/4 SHIFT [2] 1786/20 1787/1
SIMULATIONS [1] 1843/9 1847/25 1848/3 1848/4 1850/10 1850/12
S SIMULATOR [1] 1777/25 1853/22 1853/22 1854/13 1859/21
SHIFTING [1] 1809/1 SIMULTANEOUS [1] 1737/17 1862/13 1863/15 1864/7
SHIP [1] 1743/22 SINCE [23] 1729/6 1729/15 1736/23 SOMEHOW [2] 1741/3 1863/2
SHORE [12] 1758/5 1776/14 1806/21 1741/16 1745/18 1754/10 1769/19 SOMEONE [2] 1865/7 1867/14
1807/5 1807/16 1813/10 1813/11 1770/4 1770/22 1777/7 1778/7 1786/24 SOMEPLACE [1] 1834/3
1816/22 1819/20 1831/7 1831/9 1831/11 1807/13 1816/22 1829/21 1835/9 SOMETHING [20] 1736/3 1756/15
SHORELINE [1] 1764/3 1844/11 1846/8 1847/18 1850/5 1852/13 1756/19 1758/8 1760/9 1771/7 1793/24
SHORELINES [2] 1760/5 1826/12 1856/25 1857/19 1802/4 1805/21 1806/20 1819/15
SHORT [4] 1736/13 1774/2 1795/6 SINGLE [1] 1762/20 1819/18 1822/11 1823/3 1830/2 1841/1
1820/2 SINKING [1] 1831/4 1846/10 1861/20 1862/12 1863/7
SHORT-PERIOD [1] 1820/2 SIR [35] 1727/9 1729/11 1740/1 1741/23 SOMEWHAT [1] 1789/14
SHORTER [2] 1793/2 1793/9 1742/19 1746/23 1761/19 1762/12 SOON [3] 1735/20 1736/8 1810/18
SHORTLY [1] 1863/4 1770/2 1772/11 1772/21 1773/23 1774/3 SORRY [12] 1738/21 1786/16 1787/10
SHOT [1] 1830/17 1785/14 1799/19 1799/21 1800/15 1793/6 1797/15 1800/14 1807/22
SHOULD [24] 1737/3 1749/24 1764/19 1804/1 1805/10 1816/3 1818/15 1825/5 1828/20 1846/22 1849/4 1857/14 1858/8
1764/20 1766/14 1782/8 1792/18 1793/6 1828/9 1829/24 1831/2 1833/20 1842/1 SORT [2] 1780/4 1864/2
1794/11 1807/19 1815/3 1826/11 1844/1 1846/18 1852/7 1855/23 1857/14 SORTS [1] 1730/18
1826/16 1826/23 1827/15 1829/16 1863/19 1863/21 1863/22 SOUGHT [2] 1735/22 1747/25
1829/16 1845/6 1848/1 1855/15 1855/25 SITE [1] 1860/8 SOUILEAU [8] 1761/12 1762/2 1762/14
1856/7 1856/8 1865/10 SITS [2] 1775/21 1854/17 1763/7 1764/12 1764/14 1764/15
SHOULDER [1] 1800/7 SITUATION [10] 1731/24 1750/11 1764/17
SHOVED [1] 1846/4 1762/18 1823/9 1833/15 1837/6 1839/3 SOUND [2] 1762/20 1780/24
SHOW [12] 1745/10 1795/19 1811/8 1840/5 1846/24 1859/14 SOUNDS [1] 1832/4
1812/12 1814/23 1820/14 1823/12 SIX [2] 1733/2 1772/9 SOURCE [4] 1766/20 1846/3 1847/19
1835/5 1836/5 1854/12 1854/12 1854/15 SIX-HOUR [1] 1733/2 1849/18
SHOWED [7] 1778/5 1782/19 1782/23 SIXTH [1] 1747/14 SOURCES [1] 1762/7
1787/7 1790/6 1845/21 1855/10 SIZE [10] 1796/1 1797/21 1801/2 SOUTH [9] 1723/16 1738/13 1762/5
SHOWING [9] 1782/19 1804/5 1815/5 1804/13 1815/4 1839/17 1841/4 1841/5 1782/15 1806/21 1807/5 1807/16
1816/14 1817/17 1821/3 1828/12 1845/1 1845/1 1820/16 1821/15
1836/15 1853/13 SIZES [1] 1745/10 SOUTH-SIDE [1] 1821/15
SHOWN [10] 1745/15 1745/17 1749/18 SKIP [1] 1815/17 SOUTHERN [5] 1738/14 1792/24 1803/8
1780/3 1781/11 1808/7 1814/19 1816/13 SL15 [1] 1854/21 1803/23 1813/3
1848/15 1862/2 SLIDE [7] 1801/4 1801/4 1802/7 1803/22 SOUTHWESTERN [1] 1803/9
SHOWS [20] 1744/1 1750/6 1754/10 1804/4 1816/14 1831/17 SPARTINA [3] 1763/21 1763/24 1764/1
1780/4 1782/21 1785/3 1785/24 1789/19 SLOPES [1] 1746/3 SPEAKING [2] 1814/11 1820/7
1803/3 1807/24 1814/24 1818/2 1818/24 SLOPING [2] 1801/25 1842/25 SPECIAL [1] 1781/14
1823/25 1824/5 1831/18 1845/4 1854/14 SLOW [1] 1750/25 SPECIFIC [4] 1737/3 1780/2 1817/22
1854/16 1859/14 SLOW-MOVING [1] 1750/25 1867/15
SHRUBS [1] 1826/20 SLOWER [2] 1803/25 1849/5 SPECIFICALLY [6] 1729/24 1732/18
SIDE [34] 1746/3 1746/5 1749/17 SMALL [5] 1807/3 1821/21 1853/18 1736/11 1769/19 1798/15 1800/25
1759/17 1759/22 1762/15 1762/15 1854/13 1862/22 SPECIFY [1] 1840/13
1764/2 1769/17 1769/23 1789/2 1790/12 SMALLER [7] 1776/11 1796/24 1797/1 SPECTRAL [1] 1796/10
1790/13 1790/20 1790/21 1791/18 1798/20 1800/10 1800/12 1800/16 SPECULATING [2] 1757/4 1757/5
1791/18 1796/22 1797/16 1797/20 SMALLEST [2] 1797/20 1797/21 SPECULATION [1] 1851/25
1797/25 1798/17 1799/9 1799/25 1816/1 SMITH [5] 1725/15 1865/2 1865/2 SPEED [2] 1751/5 1817/1
1817/17 1821/15 1821/20 1822/13 1865/22 1867/6 SPEEDS [1] 1855/8
1822/16 1823/20 1838/6 1846/14 1855/5 SMITH'S [2] 1800/7 1859/4 SPELL [1] 1727/17
SIDES [2] 1769/21 1826/22 SMOOTH [1] 1798/23 SPELLING [1] 1727/14
SIGNIFICANCE [3] 1788/20 1788/21 SO [178] SPEND [1] 1730/1
1821/14 SO-CALLED [2] 1733/23 1741/10 SPENT [3] 1730/9 1732/13 1735/25
SIGNIFICANT [18] 1744/12 1759/3 SO8 [5] 1739/19 1739/21 1740/4 SPIGOT [1] 1843/22
1778/8 1779/12 1794/4 1803/5 1810/5 1777/17 1777/19 SPOIL [2] 1742/5 1826/15
1815/14 1820/3 1821/17 1821/22 SOBEK [14] 1776/17 1776/22 1823/24 SPOIL ON [1] 1826/15
1824/24 1840/22 1840/23 1844/9 1827/19 1827/23 1828/14 1828/21 SPONSOR [2] 1771/19 1771/21
1856/13 1856/18 1857/4 1829/2 1829/19 1830/1 1831/19 1831/25 SPOT [2] 1830/16 1837/8
SIGNIFICANTLY [12] 1754/18 1759/10 1832/6 1857/16 SPRING [2] 1813/23 1815/8
1778/6 1779/6 1779/9 1779/15 1827/4 SOCIETY [1] 1729/6 SPRINGS [1] 1724/17
1829/13 1837/17 1841/5 1845/13 SOJA [1] 1725/16 SQUALL [1] 1793/22
1852/14 SOLE [1] 1827/12 SQUARE [4] 1802/8 1802/10 1804/13
SIMILAR [12] 1733/20 1754/9 1762/18 SOLELY [1] 1822/19 1844/19
1763/17 1806/20 1807/14 1807/15 SOLID [1] 1728/12 SR [1] 1725/16
1807/18 1807/19 1810/8 1813/2 1813/5 SOLUTION [1] 1819/11 ST [1] 1858/25
SIMPLE [4] 1753/13 1814/24 1817/11 SOLVE [1] 1777/10 ST. [13] 1738/19 1747/5 1747/5 1760/2
1819/3 SOLVING [1] 1765/2 1783/9 1820/4 1823/18 1824/14 1853/2
SIMPLISTIC [2] 1797/7 1798/6 SOME [46] 1728/4 1730/5 1730/25 1853/6 1853/10 1854/25 1857/7
SIMPLY [5] 1818/13 1818/22 1818/24 1732/18 1735/1 1737/9 1738/8 1744/1 ST. BERNARD [12] 1738/19 1747/5
1850/1 1857/20 1749/8 1749/16 1755/7 1755/9 1755/23 1747/5 1783/9 1820/4 1823/18 1824/14
SIMS [1] 1724/3 1758/20 1760/15 1765/10 1767/9 1767/9 1853/2 1853/6 1853/10 1854/25 1857/7
SIMULATE [3] 1774/25 1780/9 1834/4 1770/12 1774/24 1784/13 1796/16 ST. FRANCISVILLE [1] 1760/2
SIMULATED [2] 1736/6 1827/13 1807/17 1815/25 1821/23 1822/23 STABILIZATION [4] 1764/2 1768/1
SIMULATION [5] 1775/10 1777/13 1823/10 1828/8 1836/15 1837/10 1768/12 1769/20
1780/17 1781/13 1855/7 1837/13 1840/6 1840/14 1847/24 STABILIZE [5] 1768/13 1768/17 1769/6
STRUCK [1] 1745/13 1822/19 1822/22 1822/23 1823/2
S STRUCTURE [6] 1731/6 1744/2 1747/21 1823/21 1824/1 1824/6 1824/7 1824/8
STABILIZE... [2] 1770/25 1772/1 1754/11 1826/22 1826/23 1824/14 1825/21 1825/23 1826/18
STABILIZED [1] 1770/15 STRUCTURES [16] 1744/16 1746/9 1826/19 1827/9 1828/3 1832/17 1836/9
STAFF [1] 1765/18 1753/4 1760/16 1760/18 1760/20 1836/11 1836/17 1838/9 1838/11
STAGE [3] 1752/7 1754/5 1838/4 1760/23 1761/3 1765/8 1775/4 1778/21 1838/12 1840/6 1840/10 1840/14
STAGGERING [1] 1758/11 1822/18 1827/10 1827/12 1834/9 1841/24 1841/25 1843/1 1843/5 1843/15
STAND [1] 1795/15 1834/17 1843/17 1843/19 1843/23 1843/24
STANDARD [4] 1733/11 1734/3 1803/7 STUDENT [1] 1729/16 1845/8 1846/4 1847/11 1852/15 1852/23
1819/25 STUDENTS [1] 1819/25 1854/8 1854/12 1854/16 1854/20 1856/2
STANDING [4] 1768/1 1771/6 1800/7 STUDIED [2] 1759/14 1802/5 1858/2 1860/3 1862/13
1861/12 STUDIES [4] 1727/23 1728/14 1734/25 SURGE-INDUCED [1] 1775/4
STANDPOINT [10] 1751/16 1764/7 1735/9 SURGE-RUSH [1] 1753/6
1819/16 1834/8 1834/10 1835/10 1845/7 STUDY [15] 1728/11 1731/15 1731/22 SURVEY [1] 1818/20
1855/14 1857/21 1866/21 1733/16 1736/9 1748/14 1748/17 SURVEYOR'S [1] 1745/9
STANDS [1] 1740/4 1748/18 1748/23 1748/24 1749/4 SURVEYORS [1] 1739/10
STANWOOD [1] 1723/11 1752/22 1753/4 1764/3 1794/6 SUSTAINED [2] 1856/14 1856/19
START [6] 1768/15 1776/24 1787/17 STUFF [2] 1802/25 1819/20 SWAMPS [3] 1746/14 1825/11 1825/22
1796/17 1810/17 1811/14 STWAVE [5] 1799/11 1803/7 1803/17 SWAN [16] 1776/13 1776/22 1792/9
STARTED [4] 1732/16 1767/2 1775/13 1804/20 1807/24 1800/24 1801/24 1803/7 1803/17 1805/5
1829/12 SUBJECT [1] 1833/6 1805/6 1806/8 1809/16 1809/24 1811/6
STARTING [6] 1761/22 1763/6 1763/21 SUBPARAGRAPH [1] 1771/8 1812/12 1814/23 1815/13
1787/23 1834/10 1838/23 SUBROGATED [1] 1725/2 SWELL [2] 1792/22 1792/22
STARTS [1] 1796/7 SUBSEQUENT [1] 1753/18 SWIMMING [1] 1831/5
STARTUP [1] 1805/2 SUBSTANCE [2] 1745/15 1841/8 SWORN [1] 1727/11
STATE [11] 1727/13 1732/16 1734/6 SUBSTANTIAL [4] 1743/4 1746/21 SYNCHRONOUS [1] 1787/24
1749/12 1766/17 1766/21 1766/22 1810/24 1861/25 SYNOPSIZED [1] 1774/8
1766/24 1767/8 1767/14 1767/17 SUBSTANTIALLY [2] 1754/18 1857/11 SYSTEM [13] 1749/11 1751/17 1751/25
STATED [2] 1730/5 1788/2 SUBTLE [1] 1769/7 1777/9 1781/24 1781/25 1808/18
STATEMENT [9] 1755/2 1755/5 1755/16 SUBTRACT [1] 1859/12 1817/15 1818/5 1825/18 1834/2 1837/7
1755/24 1756/4 1756/14 1829/19 SUBTRACTION [1] 1742/7 1843/19
1855/17 1855/18 SUCH [6] 1747/25 1786/20 1819/18 SYSTEMATICALLY [1] 1739/4
STATES [9] 1723/1 1723/7 1723/11 1835/11 1844/7 1863/10 SYSTEMS [3] 1729/12 1732/20 1733/9
1727/10 1730/6 1767/10 1773/3 1864/15 SUCK [1] 1814/16
1868/3 SUDDENLY [1] 1819/20 T
STATION [1] 1725/17 SUFFER [5] 1857/11 1857/25 1859/7 TABLE [7] 1797/1 1797/3 1829/2 1829/6
STATISTICALLY [1] 1757/10 1860/1 1860/16 1831/17 1848/5 1848/11
STAY [1] 1836/17 SUFFERED [3] 1858/2 1859/8 1860/4 TABLET [2] 1796/22 1800/8
STAYED [2] 1730/18 1841/25 SUFFICIENT [2] 1791/20 1791/20 TAHEERAH [1] 1725/11
STEADY [1] 1818/3 SUGGESTED [1] 1767/2 TAILORED [1] 1863/13
STEEPLY [1] 1801/25 SUGGESTIONS [1] 1755/1 TAKE [19] 1737/9 1755/23 1758/3
STENOGRAPHY [1] 1725/24 SUITE [5] 1723/16 1724/3 1724/6 1766/18 1772/8 1773/17 1775/22
STEP [2] 1797/22 1863/22 1724/10 1725/7 1796/17 1796/18 1796/23 1798/19
STEPS [3] 1795/20 1798/10 1799/17 SUM [1] 1745/15 1809/3 1817/23 1830/20 1834/5 1843/11
STEVE [3] 1743/8 1786/16 1824/3 SUMMARIZE [1] 1863/25 1851/18 1856/9 1864/16
STEVENS [3] 1724/22 1724/23 1828/11 SUPERSEDED [1] 1741/13 TAKEN [4] 1785/24 1789/5 1789/9
STIFF [1] 1813/13 SUPPOSED [1] 1756/9 1848/19
STILL [12] 1735/21 1738/22 1749/11 SURE [19] 1740/6 1751/12 1760/13 TAKES [6] 1783/14 1793/17 1798/9
1770/19 1787/1 1814/12 1815/5 1816/14 1764/23 1774/2 1774/4 1815/24 1824/17 1819/2 1834/12 1844/23
1850/10 1860/5 1860/9 1860/11 1825/7 1827/17 1830/17 1852/8 1864/21 TAKING [1] 1777/14
STONE [1] 1725/16 1865/16 1866/5 1866/6 1866/18 1866/20 TALE [3] 1820/10 1820/14 1828/15
STOP [4] 1743/4 1759/13 1766/23 1866/22 TALK [17] 1730/25 1731/2 1732/18
1778/24 SURFACE [8] 1777/10 1777/16 1796/1 1744/5 1744/12 1762/23 1779/15
STOPS [1] 1778/23 1796/7 1796/9 1796/9 1809/25 1809/25 1790/23 1791/4 1791/25 1817/4 1819/15
STORAGE [1] 1823/11 SURGE [136] 1732/23 1733/2 1735/8 1821/6 1832/13 1833/13 1836/8 1866/17
STORM [14] 1736/4 1746/10 1747/23 1735/8 1736/10 1739/2 1739/13 1739/15 TALKED [8] 1741/11 1759/5 1772/14
1750/25 1751/4 1751/7 1753/3 1757/10 1739/21 1742/8 1744/24 1745/1 1746/7 1772/15 1799/10 1809/19 1822/11
1780/14 1823/12 1855/2 1855/4 1855/5 1746/17 1747/13 1747/18 1747/23 1864/25
1855/8 1748/8 1749/14 1750/5 1750/7 1750/17 TALKING [22] 1730/19 1731/8 1756/4
STORMS [4] 1751/3 1756/23 1757/11 1751/9 1751/18 1751/21 1751/22 1752/6 1793/16 1793/19 1800/10 1804/10
1854/24 1753/6 1763/12 1763/16 1765/6 1775/4 1805/14 1805/22 1808/11 1813/11
STORY [1] 1738/21 1776/8 1776/11 1777/13 1777/25 1778/9 1821/2 1823/3 1825/15 1840/9 1849/20
STRAIGHT [2] 1829/11 1845/3 1778/15 1779/6 1779/9 1779/20 1781/1 1849/22 1850/20 1858/15 1867/7
STRAIGHTEN [1] 1864/1 1781/1 1781/9 1781/23 1782/6 1782/8 1867/12 1867/13
STRANGER [1] 1733/22 1782/11 1782/13 1782/19 1783/2 1783/7 TANNISH [1] 1812/23
STREET [13] 1723/16 1723/19 1723/23 1784/2 1784/14 1784/19 1784/21 1785/5 TANYA [1] 1859/4
1724/6 1724/10 1724/13 1724/20 1725/4 1785/12 1785/20 1785/23 1786/12 TASK [1] 1863/24
1725/7 1725/20 1847/24 1851/15 1786/14 1786/20 1786/23 1786/23 TEAM [26] 1733/4 1734/6 1734/13
1858/22 1787/4 1787/5 1787/10 1787/15 1787/21 1734/13 1735/19 1735/20 1736/23
STRESS [1] 1813/14 1787/25 1788/14 1788/23 1789/7 1737/2 1739/4 1739/10 1739/12 1747/3
STRESSES [2] 1777/15 1777/15 1790/15 1790/25 1791/3 1791/7 1791/9 1780/1 1780/16 1792/9 1794/11 1794/11
STRICTLY [3] 1822/17 1851/17 1852/20 1791/14 1791/15 1791/18 1796/7 1816/18 1817/10 1822/5 1826/2 1827/18
STRONG [3] 1767/9 1767/10 1825/3 1801/20 1813/1 1815/5 1816/13 1822/17 1828/10 1829/13 1830/12 1854/7
1731/1 1731/12 1731/13 1738/9 1740/20 THERE'S [20] 1743/17 1747/15 1766/5
T 1741/20 1741/21 1750/20 1751/25 1775/25 1780/11 1781/18 1788/3
TEAM'S [2] 1788/4 1827/7 1753/19 1753/22 1754/23 1755/13 1790/25 1794/2 1809/21 1810/17 1813/6
TEAMS [1] 1795/20 1757/19 1759/8 1767/11 1775/24 1777/3 1813/13 1814/6 1822/17 1828/18 1835/1
TECHNICAL [1] 1732/13 1782/2 1782/3 1788/25 1790/4 1790/19 1841/18 1849/21 1858/15
TECHNIQUES [5] 1730/3 1748/8 1775/1 1795/12 1797/5 1805/4 1805/4 1814/21 THEREAFTER [1] 1856/3
1775/10 1834/22 1819/9 1829/15 1831/20 1831/21 THEREBY [2] 1746/6 1746/17
TECHNOLOGY [4] 1775/19 1775/24 1831/21 1834/11 1848/23 1865/18 THEREFORE [2] 1810/1 1867/8
1776/1 1798/1 1866/21 1867/7 1867/12 1867/13 THESE [58] 1733/18 1735/2 1740/16
TELEVISION [1] 1782/19 1867/14 1743/15 1743/23 1746/9 1749/3 1750/5
TELL [19] 1740/3 1743/9 1744/18 THEME [2] 1833/6 1833/9 1750/13 1750/21 1751/20 1753/22
1746/19 1753/8 1774/21 1781/5 1781/20 THEMSELVES [1] 1730/7 1755/11 1755/20 1761/10 1764/14
1789/25 1791/2 1791/17 1797/19 THEN [110] 1730/2 1732/3 1734/2 1765/19 1765/23 1765/25 1771/25
1803/15 1805/6 1818/1 1820/6 1831/3 1739/10 1739/17 1741/20 1743/18 1772/24 1776/20 1780/8 1780/13
1833/23 1850/3 1743/22 1743/25 1745/11 1745/12 1783/17 1784/19 1784/19 1789/9 1795/4
TELLING [3] 1753/22 1786/18 1806/16 1745/17 1749/19 1749/23 1750/13 1798/21 1800/6 1801/2 1801/6 1801/14
TELLS [1] 1828/14 1750/19 1751/19 1754/17 1756/20 1803/16 1804/10 1804/18 1804/19
TEMPLATE [2] 1745/12 1829/16 1757/21 1759/21 1760/4 1763/16 1807/18 1811/12 1812/20 1813/16
TEN [2] 1788/12 1830/21 1765/17 1765/24 1766/6 1767/5 1769/10 1816/6 1817/20 1820/20 1826/5 1827/21
TENDER [1] 1863/16 1769/23 1775/6 1775/13 1775/24 1827/24 1829/14 1836/16 1836/22
TENDERED [2] 1735/13 1854/24 1776/10 1776/13 1776/16 1776/17 1843/4 1845/18 1848/14 1848/22
TENSION [1] 1791/19 1776/25 1777/15 1778/14 1778/25 1848/24 1857/15 1863/25
TENTH [3] 1797/23 1801/3 1802/12 1781/13 1782/5 1783/18 1786/13 THEY [144] 1731/9 1731/11 1731/13
TENTHS [1] 1802/17 1787/17 1795/11 1795/18 1796/10 1731/19 1737/11 1746/9 1747/10
TERM [3] 1770/16 1771/9 1794/3 1796/20 1797/2 1797/3 1797/17 1797/22 1747/12 1747/21 1747/21 1748/8 1749/9
TERMS [11] 1729/19 1745/22 1747/20 1798/21 1799/15 1801/18 1801/21 1749/12 1749/13 1749/19 1750/2
1759/6 1778/15 1798/6 1803/10 1810/8 1802/1 1807/9 1808/13 1809/10 1810/15 1750/21 1750/22 1751/2 1752/10
1824/1 1836/6 1844/17 1810/18 1812/5 1812/9 1812/23 1812/24 1752/21 1752/22 1753/1 1753/17
TERRAIN [1] 1728/17 1813/9 1813/22 1813/25 1814/14 1756/13 1756/15 1756/17 1757/13
TEST [4] 1775/2 1777/22 1804/21 1814/19 1815/5 1815/8 1816/12 1817/15 1757/17 1757/19 1758/21 1759/7 1759/8
1834/25 1817/20 1818/25 1819/21 1820/17 1759/14 1759/15 1759/16 1759/20
TESTED [5] 1749/12 1749/13 1749/19 1824/14 1828/4 1828/5 1832/18 1832/19 1759/22 1760/15 1760/21 1762/24
1776/20 1816/19 1832/21 1835/5 1836/7 1836/8 1836/12 1764/5 1764/6 1765/16 1766/14 1767/5
TESTIFIED [4] 1727/12 1760/13 1772/13 1836/19 1839/8 1839/18 1845/1 1845/10 1767/20 1770/12 1771/7 1773/6 1773/8
1825/24 1846/20 1847/14 1848/15 1848/18 1775/12 1775/13 1776/24 1776/25
TESTIFY [2] 1792/14 1823/16 1848/23 1849/2 1849/4 1849/25 1850/18 1777/1 1777/12 1785/20 1785/21
TESTIFYING [1] 1773/10 1851/17 1851/19 1853/10 1857/1 1785/23 1788/24 1789/7 1790/19
TESTIMONY [8] 1741/20 1790/6 1858/11 1861/7 1790/20 1790/21 1791/12 1792/18
1805/13 1829/12 1841/4 1853/22 1862/5 THEORETICAL [1] 1834/21 1792/19 1792/21 1795/7 1795/7 1796/8
1866/9 THEORIES [1] 1777/22 1797/4 1797/5 1799/7 1799/15 1799/16
TESTING [13] 1750/3 1779/2 1784/1 THEORY [6] 1788/21 1788/22 1790/11 1799/18 1799/23 1803/5 1803/8 1804/23
1784/1 1789/16 1790/1 1793/4 1806/17 1790/14 1822/18 1822/21 1805/6 1807/1 1807/3 1807/8 1808/1
1815/13 1827/18 1829/17 1831/18 THERE [139] 1729/12 1730/4 1731/9 1808/22 1808/24 1809/7 1809/8 1809/8
1848/7 1733/17 1738/7 1738/22 1739/6 1739/8 1809/11 1809/13 1809/17 1810/9
TESTING/MODELING [1] 1790/1 1741/9 1741/12 1742/11 1742/17 1810/14 1810/16 1810/17 1810/18
TESTS [4] 1749/9 1806/8 1827/15 1742/22 1743/2 1744/8 1747/8 1748/22 1810/19 1810/25 1812/23 1813/18
1834/13 1749/15 1749/16 1749/17 1749/19 1813/21 1813/22 1813/23 1819/15
TEXAS [1] 1724/4 1750/16 1750/18 1750/24 1750/25 1821/16 1821/18 1821/19 1824/1 1824/8
THAN [35] 1731/12 1732/7 1745/19 1751/24 1752/15 1754/22 1755/7 1824/20 1826/9 1834/21 1836/17
1751/2 1764/24 1778/25 1782/8 1784/22 1757/13 1757/21 1759/21 1761/18 1836/17 1842/7 1843/9 1843/10 1843/11
1784/23 1789/23 1793/3 1795/2 1795/20 1762/25 1763/14 1764/6 1766/8 1769/13 1844/21 1844/22 1845/6 1851/20
1797/10 1798/7 1798/9 1799/20 1800/16 1769/21 1772/20 1772/22 1773/4 1852/12 1857/19 1858/11 1858/11
1803/4 1809/25 1818/22 1833/4 1838/12 1774/11 1775/18 1776/4 1778/21 1859/2 1859/11 1860/4 1860/4 1860/5
1842/7 1843/4 1843/20 1845/15 1850/19 1781/10 1786/16 1788/6 1790/13 1791/1 1860/10 1860/13 1865/18 1866/24
1853/21 1855/9 1855/16 1855/24 1856/8 1791/2 1791/8 1791/11 1791/19 1792/4 1867/4 1867/11 1867/14 1867/15
1861/2 1861/12 1792/5 1794/12 1798/5 1798/20 1799/12 1867/16
THANK [21] 1734/18 1735/12 1735/14 1801/10 1801/22 1804/1 1804/4 1804/14 THEY'RE [8] 1749/7 1803/3 1805/3
1735/15 1757/2 1759/20 1766/9 1770/2 1805/13 1806/13 1806/14 1806/18 1811/8 1812/18 1866/16 1866/16
1772/7 1773/24 1816/9 1825/5 1844/2 1808/7 1808/12 1810/10 1810/17 1866/18
1854/5 1855/11 1857/13 1863/16 1812/14 1816/4 1816/5 1818/4 1818/6 THICK [1] 1789/12
1863/18 1866/3 1866/4 1867/19 1818/11 1819/18 1819/24 1821/2 1821/3 THING [15] 1753/19 1769/8 1810/13
THANKS [1] 1865/13 1821/10 1821/12 1821/14 1821/16 1813/12 1818/3 1819/4 1824/3 1824/5
THAT [700] 1821/17 1821/20 1821/21 1822/24 1834/7 1834/7 1835/19 1843/5 1846/22
THAT'S [267] 1823/5 1824/4 1825/3 1825/15 1829/3 1850/9 1854/10
THEIR [30] 1731/11 1746/16 1751/1 1830/6 1831/5 1831/25 1832/6 1836/17 THINGS [23] 1731/20 1746/25 1750/2
1752/22 1769/11 1775/19 1785/24 1837/25 1840/6 1840/10 1841/4 1841/5 1753/22 1761/10 1763/18 1764/5 1769/9
1786/17 1786/19 1788/21 1788/22 1841/8 1841/14 1841/19 1843/9 1844/5 1770/19 1774/23 1777/25 1780/6 1794/5
1797/3 1799/16 1799/16 1799/25 1844/18 1845/13 1847/22 1847/24 1797/24 1826/5 1827/3 1829/14 1834/9
1802/12 1803/1 1807/24 1809/25 1848/2 1848/13 1849/24 1850/1 1850/4 1838/8 1843/8 1845/18 1863/25 1866/17
1816/22 1824/19 1825/11 1834/21 1850/5 1850/5 1850/10 1850/11 1853/7 THINK [46] 1736/5 1737/1 1740/5
1834/23 1860/1 1860/8 1860/16 1860/23 1853/9 1853/13 1853/15 1854/7 1854/17 1741/7 1741/9 1743/3 1743/8 1744/14
1861/10 1862/1 1858/11 1859/16 1862/13 1862/16 1753/16 1755/8 1756/7 1756/16 1757/8
THEM [44] 1730/8 1730/9 1730/10 1862/22 1864/6 1864/14 1866/19 1758/9 1759/5 1762/23 1773/22 1774/11
1781/16 1783/3 1783/4 1783/6 1783/16 TRUE [7] 1738/21 1751/3 1788/16
T 1783/23 1784/18 1785/11 1822/17 1856/10 1856/15 1859/1 1868/4
THINK... [28] 1782/12 1785/2 1792/4 1824/2 1824/6 1832/18 TRY [6] 1730/3 1766/23 1793/25
1797/11 1798/8 1800/19 1806/11 TIRED [1] 1856/22 1796/15 1830/16 1844/18
1812/14 1818/16 1828/22 1832/21 TITLE [1] 1740/10 TRYING [13] 1734/3 1735/25 1738/16
1835/10 1835/19 1844/2 1848/5 1853/25 TO 8 [1] 1837/15 1757/10 1762/24 1767/3 1774/9 1804/12
1854/22 1859/11 1859/20 1860/18 TODAY [10] 1733/12 1734/21 1748/15 1804/25 1819/12 1827/16 1829/10
1862/2 1862/22 1862/25 1863/14 1749/24 1829/13 1830/16 1854/9 1834/20
1864/18 1864/20 1866/19 1866/23 1854/24 1866/9 1867/3 TUNING [1] 1797/9
THINKING [4] 1863/4 1863/11 1863/12 TODAY'S [1] 1864/4 TURN [5] 1741/18 1743/5 1745/24
1863/13 TOE [3] 1760/22 1769/22 1826/21 1786/5 1792/7
THIRD [8] 1745/25 1745/25 1795/11 TOGETHER [12] 1734/13 1739/9 TURNED [4] 1731/14 1738/9 1776/16
1797/17 1803/6 1815/17 1815/17 1750/20 1751/25 1759/8 1791/13 1811/8 1777/20
1839/20 1820/1 1834/11 1844/21 1848/24 1859/2 TUSA [4] 1725/20 1868/2 1868/10
THIS [274] TOLD [8] 1731/12 1731/13 1741/4 1868/10
THOMAS [1] 1724/3 1753/19 1815/15 1815/15 1825/25 TV [3] 1785/11 1786/15 1787/7
THOSE [33] 1731/22 1734/3 1737/10 1825/25 TWO [31] 1744/9 1747/6 1748/13 1749/3
1743/24 1755/10 1758/19 1758/20 TOM [1] 1739/5 1749/9 1750/13 1754/3 1768/8 1769/8
1763/18 1768/9 1774/8 1774/22 1777/15 TOMORROW [5] 1852/8 1863/20 1774/11 1783/14 1783/17 1784/19
1786/12 1793/23 1794/5 1805/15 1810/1 1863/23 1867/7 1867/20 1785/16 1786/25 1787/3 1788/3 1788/6
1810/11 1817/10 1821/19 1821/20 TONI [4] 1725/20 1868/2 1868/10 1788/16 1790/20 1795/19 1799/17
1822/1 1822/2 1822/16 1825/20 1832/12 1868/10 1800/6 1803/16 1804/4 1807/3 1807/7
1835/17 1837/14 1850/7 1861/8 1864/12 TOO [8] 1752/18 1784/17 1784/25 1820/10 1820/14 1822/14 1861/8
1864/14 1867/12 1793/11 1806/12 1815/21 1826/23 TWO-AND-A-HALF [1] 1747/6
THOUGH [7] 1747/25 1759/17 1762/23 1863/12 TWO-HOUR [3] 1788/3 1788/6 1788/16
1770/20 1773/24 1807/16 1863/9 TOOK [5] 1750/23 1752/22 1773/19 TYPE [1] 1821/7
THOUGHT [2] 1755/9 1829/24 1830/24 1843/9 TYPO [1] 1747/15
THOUSAND [2] 1817/12 1819/4 TOOLS [2] 1738/3 1774/24
THREAT [1] 1742/8 TOP [25] 1756/9 1763/20 1781/13 U
THREATENED [1] 1766/23 1787/5 1797/3 1798/16 1803/5 1803/21 U.S [3] 1725/9 1732/8 1742/13
THREE [12] 1742/20 1743/12 1743/15 1807/6 1811/15 1811/17 1811/19 ULTIMATE [2] 1810/11 1835/21
1744/9 1755/20 1770/10 1791/14 1811/20 1812/10 1812/11 1814/22 ULTIMATELY [4] 1737/6 1737/11
1792/19 1811/5 1839/1 1846/21 1851/18 1817/18 1817/19 1817/21 1818/25 1791/20 1851/18
THROAT [6] 1743/17 1744/22 1745/21 1823/2 1844/20 1846/13 1846/15 UMBRELLA [1] 1736/13
1749/17 1754/11 1763/17 1851/10 UNABLE [1] 1865/20
THROUGH [22] 1730/10 1740/16 1748/9 TOPIC [1] 1810/22 UNDER [30] 1728/9 1728/16 1728/22
1760/3 1772/18 1773/23 1779/13 TOPS [1] 1816/6 1732/21 1786/18 1795/7 1812/16
1788/23 1793/23 1795/18 1798/10 TORTS [1] 1725/10 1812/20 1835/17 1840/17 1840/19
1808/21 1814/7 1823/19 1825/17 TOTAL [5] 1847/11 1848/20 1858/3 1841/2 1841/4 1841/8 1845/8 1847/10
1829/14 1837/17 1839/6 1839/7 1844/25 1859/10 1859/12 1847/22 1849/1 1849/10 1850/3 1850/6
1846/5 1862/2 TOTO [1] 1761/18 1850/25 1851/3 1851/11 1851/12
THROUGHOUT [4] 1772/5 1833/24 TOUCH [4] 1728/3 1734/5 1741/20 1851/13 1853/9 1856/2 1860/7 1860/22
1834/25 1867/1 1754/23 UNDERLYING [2] 1789/23 1801/11
THUNDERSTORM [1] 1793/22 TOUGH [1] 1849/6 UNDERSTAND [33] 1736/7 1738/4
THUS [1] 1751/21 TOWARDS [4] 1751/6 1760/20 1836/13 1740/19 1747/11 1747/11 1752/11
TICKER [1] 1737/1 1837/8 1760/9 1760/24 1765/12 1766/9 1784/12
TIDES [3] 1728/9 1728/16 1732/4 TOWER [2] 1785/11 1786/15 1788/4 1793/8 1794/1 1796/14 1801/16
TIE [2] 1820/1 1834/11 TRACE [1] 1789/10 1804/16 1805/20 1806/1 1809/22
TIED [1] 1867/15 TRACK [1] 1855/9 1817/23 1818/16 1818/25 1819/10
TIME [80] 1730/2 1731/23 1735/5 TRANSCRIPT [2] 1725/24 1868/5 1822/21 1822/22 1831/14 1839/23
1738/22 1739/6 1739/16 1745/18 1746/4 TRANSECT [1] 1801/15 1840/11 1850/17 1852/5 1853/22
1748/2 1748/6 1748/14 1750/4 1750/5 TRANSFORMATION [1] 1801/1 1857/18
1751/4 1751/8 1752/22 1756/12 1757/7 TRANSFORMING [1] 1810/14 UNDERSTANDING [14] 1746/23
1757/12 1758/2 1758/5 1758/25 1759/7 TRANSIT [1] 1751/7 1746/25 1772/19 1790/2 1809/17 1821/6
1759/7 1759/9 1759/14 1766/12 1768/23 TRANSLATION [2] 1751/5 1802/1 1840/3 1840/7 1842/14 1859/2 1866/2
1771/13 1772/22 1772/25 1773/2 1773/2 TRANSMISSION [3] 1744/25 1826/18 1867/11 1867/15 1868/6
1775/8 1775/12 1777/10 1781/15 1826/19 UNDERSTANDINGS [1] 1791/5
1782/11 1782/16 1783/7 1783/23 1784/2 TRANSMIT [1] 1832/20 UNDERSTOOD [6] 1739/17 1742/14
1785/1 1785/6 1786/21 1788/15 1789/7 TRANSPORTING [1] 1802/3 1748/1 1769/12 1799/19 1852/20
1789/10 1789/16 1789/20 1789/22 TRAVELED [1] 1793/20 UNDERTOOK [1] 1747/24
1789/24 1791/17 1791/20 1793/17 TRAVERSING [1] 1814/19 UNEQUIVOCABLY [1] 1865/23
1794/15 1794/17 1796/20 1796/24 TREATMENT [1] 1748/11 UNIT [3] 1783/11 1823/10 1827/3
1798/9 1807/7 1811/15 1811/20 1813/17 TREES [1] 1826/20 UNITED [7] 1723/1 1723/7 1723/11
1815/16 1817/3 1827/24 1833/4 1833/25 TREMENDOUS [2] 1762/24 1814/9 1727/10 1773/3 1864/15 1868/3
1834/12 1835/8 1837/9 1838/22 1839/11 TRIAL [8] 1723/10 1735/18 1736/23 UNITED STATES [3] 1727/10 1773/3
1845/23 1846/20 1847/13 1860/18 1741/5 1782/18 1825/24 1863/15 1864/15
1864/16 1865/23 1865/24 UNITIVE [5] 1755/2 1755/4 1755/16
TIME-DEPENDENT [1] 1777/10 TRIANGLE [2] 1744/4 1825/19 1755/24 1756/4
TIME-OF-ONSET [1] 1750/5 TRIED [2] 1781/14 1781/15 UNIVERSE [1] 1757/11
TIME-WISE [1] 1789/7 TRIPLES [1] 1844/25 UNIVERSITY [7] 1775/16 1775/19
TIMES [5] 1745/22 1785/20 1792/19 TROUBLE [1] 1837/10 1775/21 1775/23 1776/1 1776/24
1802/18 1811/12 TROUGH [6] 1844/19 1844/20 1844/22 1827/22
TIMING [15] 1778/9 1779/6 1779/20 1844/24 1844/24 1844/25 UNLESS [2] 1825/3 1867/15
VELOCITY [8] 1751/21 1753/6 1780/9 WARNING [3] 1752/20 1752/21 1754/2
U 1835/23 1836/6 1836/9 1845/8 1846/4 WARNINGS [1] 1758/19
UNLIKE [2] 1795/21 1842/24 VERIFY [1] 1739/18 WARREN [1] 1725/6
UNMITIGATED [3] 1779/16 1779/19 VERRETT [3] 1820/18 1821/3 1821/10 WAS [240]
1861/24 VERSION [1] 1739/21 WASHINGTON [1] 1725/18
UNSTABLE [1] 1746/3 VERSIONS [1] 1827/21 WASN'T [6] 1741/5 1756/16 1757/1
UNTIL [8] 1759/16 1792/5 1792/9 1796/5 VERSUS [1] 1723/6 1787/7 1803/14 1840/4
1830/21 1854/19 1863/19 1867/20 VERY [70] 1730/18 1733/14 1733/20 WATER [71] 1728/8 1728/15 1728/17
UP [82] 1733/18 1737/22 1741/24 1734/9 1739/1 1744/7 1748/21 1750/18 1731/12 1732/3 1732/4 1736/10 1737/12
1742/21 1743/12 1743/14 1744/6 1750/22 1753/1 1753/15 1754/9 1755/1 1738/25 1739/10 1746/16 1751/20
1744/17 1745/4 1746/11 1747/2 1749/1 1759/20 1760/2 1763/6 1764/9 1773/24 1751/21 1756/19 1756/22 1762/18
1751/1 1752/13 1754/1 1755/11 1761/8 1776/2 1776/2 1776/2 1776/3 1776/3 1762/25 1776/1 1777/16 1778/13
1765/7 1765/17 1768/5 1768/7 1769/13 1781/16 1781/16 1782/14 1782/14 1778/18 1778/19 1778/20 1778/23
1773/15 1777/16 1778/2 1778/23 1781/4 1782/22 1783/12 1783/13 1791/22 1782/22 1783/1 1783/8 1783/10 1787/22
1782/5 1782/10 1782/22 1783/11 1794/5 1794/13 1794/18 1797/7 1798/18 1802/2 1802/3 1804/3 1812/22 1814/7
1783/13 1783/15 1784/25 1787/18 1799/4 1801/24 1809/1 1810/8 1810/16 1814/12 1816/5 1816/6 1823/19 1825/12
1791/12 1792/23 1793/22 1795/17 1810/19 1810/20 1811/25 1813/2 1813/5 1828/4 1835/23 1837/10 1837/12
1796/16 1799/12 1801/21 1804/11 1817/11 1818/3 1819/3 1822/7 1825/16 1838/10 1838/17 1838/18 1842/7 1843/7
1804/24 1806/24 1807/8 1807/20 1811/2 1832/15 1836/16 1836/21 1837/7 1843/21 1844/7 1844/20 1844/21 1848/4
1812/7 1812/14 1812/16 1813/10 1837/11 1837/13 1837/18 1838/19 1848/4 1850/2 1850/5 1850/10 1850/10
1813/23 1814/18 1815/8 1816/18 1817/5 1838/21 1839/15 1839/15 1845/5 1845/5 1850/12 1850/18 1851/15 1851/20
1818/1 1818/6 1820/12 1822/10 1823/25 1848/11 1853/17 1855/2 1859/2 1860/5 1853/10 1853/25 1859/11 1859/12
1829/2 1832/18 1836/1 1836/10 1836/13 1867/19 1861/12 1861/16 1861/25 1862/19
1836/14 1837/8 1838/17 1839/16 VIABILITY [1] 1771/9 1862/22
1842/17 1843/1 1843/2 1844/2 1847/8 VICE [1] 1729/5 WATERWAY [5] 1737/19 1744/21
1847/13 1851/10 1853/4 1854/15 1860/3 VICINITY [2] 1742/6 1755/19 1759/25 1764/19 1765/7
1863/23 VICKSBURG [1] 1765/17 WAVE [73] 1735/8 1746/8 1746/17
UPDATES [1] 1733/3 VICTOR [1] 1724/24 1775/6 1789/2 1792/7 1792/10 1792/19
UPON [9] 1730/19 1734/5 1741/20 VIEW [2] 1743/20 1743/25 1793/15 1793/17 1794/3 1794/4 1795/11
1753/6 1777/11 1780/18 1806/17 1827/4 VIEWPOINT [1] 1772/18 1795/13 1795/18 1795/23 1798/3 1798/6
1862/6 VIEWS [1] 1743/15 1798/7 1798/22 1798/24 1800/12
URBAN [1] 1765/6 VIOLATE [1] 1757/15 1800/25 1801/20 1802/1 1802/1 1802/2
US [21] 1742/24 1786/19 1788/25 VIRTUALLY [2] 1810/7 1815/18 1803/6 1803/7 1803/17 1804/6 1804/11
1794/9 1799/8 1801/16 1803/3 1805/6 VIRTUE [1] 1853/23 1804/20 1805/5 1805/8 1805/17 1806/7
1806/16 1815/15 1815/15 1817/22 VIS [4] 1809/16 1809/16 1840/11 1806/13 1806/14 1807/4 1807/6 1807/9
1818/1 1818/1 1820/6 1820/14 1825/25 1840/11 1807/10 1807/11 1808/2 1809/18 1810/2
1831/3 1834/12 1842/14 1843/13 VIS-À-VIS [2] 1809/16 1840/11 1810/2 1810/4 1810/5 1810/23 1812/12
USE [25] 1730/2 1732/25 1738/3 VISUAL [1] 1742/20 1813/6 1813/7 1813/8 1814/10 1814/15
1742/22 1775/1 1775/6 1775/16 1777/5 VOICE [1] 1865/7 1814/16 1815/14 1816/21 1817/2
1777/22 1778/3 1785/19 1794/3 1795/24 VOIR [1] 1727/19 1819/23 1821/17 1822/4 1822/13
1796/7 1796/20 1796/20 1798/5 1798/6 VOLUME [15] 1723/10 1751/20 1778/9 1822/14 1822/16 1825/3 1825/13
1804/25 1805/1 1809/11 1818/2 1836/20 1779/20 1784/13 1784/14 1836/6 1838/2 1826/19 1827/7 1834/9 1857/1
1838/7 1861/6 1838/12 1840/25 1845/8 1846/4 1847/11 WAVE-INDUCED [1] 1822/14
USED [21] 1733/4 1767/12 1767/12 1848/20 1852/14 WAVE-MODELING [1] 1775/6
1775/10 1776/8 1776/20 1777/3 1777/17 VRIJLING [6] 1775/16 1781/21 1790/6 WAVE-RIDING [1] 1807/4
1780/2 1795/21 1796/8 1796/9 1799/7 1792/9 1801/15 1832/21 WAVELENGTH [2] 1793/13 1793/14
1799/11 1802/8 1802/9 1809/17 1830/4 VRIJLING'S [4] 1784/1 1822/5 1823/24 WAVES [92] 1728/16 1735/8 1757/22
1831/19 1832/1 1835/22 1858/9 1758/2 1772/17 1775/7 1776/14 1790/23
USES [1] 1796/19 1790/24 1792/7 1792/17 1792/18
USING [18] 1776/10 1777/11 1778/1 W 1792/21 1792/22 1792/22 1792/24
1780/1 1783/20 1787/3 1788/1 1789/5 WAIT [3] 1787/10 1792/5 1800/14 1793/3 1793/9 1793/18 1793/19 1793/23
1799/5 1799/24 1811/10 1817/8 1817/22WAITING [1] 1773/15 1794/4 1794/13 1794/16 1794/25 1795/2
1818/20 1834/22 1836/4 1838/1 1854/21WALK [1] 1818/1 1795/3 1795/4 1795/5 1795/6 1795/9
USUALLY [2] 1739/7 1776/24 WALKED [1] 1862/2 1795/14 1795/25 1796/4 1796/11
UTILIZATION [1] 1832/5 WALKING [1] 1730/9 1796/17 1801/17 1801/23 1803/4 1803/6
UTILIZES [1] 1829/22 WALL [1] 1775/1 1803/8 1804/3 1805/2 1807/5 1807/14
WALLS [4] 1745/2 1838/17 1853/13 1807/16 1807/18 1807/19 1808/5
V 1854/2 1808/12 1808/15 1808/16 1808/20
VALID [1] 1785/9 WALTER [1] 1724/12 1808/23 1810/12 1810/14 1810/19
VALIDATE [3] 1739/12 1780/16 1780/18 WANT [22] 1731/1 1731/2 1734/5 1811/11 1812/18 1812/21 1813/2
VALIDATED [2] 1783/16 1806/16 1749/1 1751/11 1759/19 1769/8 1769/9 1813/16 1813/18 1814/8 1814/17
VALLEY [1] 1764/15 1769/10 1794/3 1798/19 1799/3 1799/4 1814/25 1815/4 1815/6 1815/18 1816/4
VAN [2] 1734/10 1734/12 1811/17 1811/24 1831/2 1844/17 1819/14 1819/17 1819/22 1820/2
VARIABLE [2] 1782/3 1821/1 1849/14 1863/11 1864/23 1866/6 1820/21 1820/22 1822/3 1822/4 1822/8
VARIETY [1] 1832/12 1866/22 1822/15 1822/15 1822/16 1822/23
VARIOUS [6] 1739/7 1761/10 1790/8 WANTED [10] 1737/12 1739/18 1756/3 1823/1 1823/20 1825/21 1825/23 1827/9
1790/24 1828/7 1830/11 1756/4 1796/21 1802/16 1802/19 1827/12 1827/13 1827/16 1832/16
VARYING [1] 1776/18 1836/21 1864/21 1866/18 WAX [2] 1731/8 1731/9
VAST [1] 1748/3 WANTS [2] 1770/19 1867/9 WAY [25] 1738/10 1738/17 1745/15
VEGETATION [6] 1810/17 1817/13 WARD [7] 1782/15 1820/4 1853/2 1747/10 1753/5 1761/1 1763/13 1770/7
1817/19 1817/21 1818/7 1818/9 1853/5 1853/6 1853/8 1859/24 1770/16 1796/3 1796/7 1797/7 1801/5
VELOCITIES [3] 1780/7 1836/25 WARN [2] 1747/24 1758/16 1804/8 1808/20 1808/24 1834/4 1834/25
1837/14 WARNED [3] 1766/12 1772/17 1835/12 1840/14 1845/16 1845/20 1848/3 1850/2
1827/16 1828/4 1816/13 1820/14 1822/8 1823/8 1824/16
W WHAT [176] 1827/23 1833/22 1834/11 1842/20
WAY... [2] 1850/15 1867/10 WHAT'S [10] 1733/24 1769/1 1772/19 WIDE [1] 1744/8
WAYS [2] 1728/10 1748/21 1788/20 1796/3 1798/20 1798/23 WIDELY [1] 1776/20
WE [355] 1799/24 1815/10 1853/2 WIDEN [2] 1759/23 1770/20
WE'D [2] 1735/5 1759/15 WHATEVER [14] 1733/24 1737/10 WIDENED [3] 1745/6 1819/1 1828/16
WE'LL [10] 1741/20 1743/6 1760/10 1755/8 1760/11 1764/24 1776/4 1796/21 WIDENING [13] 1744/14 1745/4 1745/19
1760/12 1772/8 1779/15 1830/20 1832/6 1809/17 1841/2 1844/23 1849/14 1751/19 1755/7 1757/22 1758/2 1759/11
1834/11 1866/25 1849/25 1861/5 1861/25 1767/21 1770/20 1778/7 1817/4 1819/1
WE'RE [12] 1730/19 1737/14 1744/5 WHATNOT [1] 1799/11 WIDER [1] 1856/5
1744/12 1749/8 1752/4 1752/5 1752/7 WHATSOEVER [2] 1834/1 1852/21 WIDTH [15] 1745/18 1798/16 1805/24
1764/4 1791/12 1845/5 1862/25 WHEN [65] 1731/10 1736/4 1737/2 1817/13 1817/18 1817/18 1817/19
WE'VE [4] 1734/22 1743/8 1771/15 1743/4 1747/3 1747/12 1747/20 1748/12 1817/21 1818/25 1819/1 1835/14
1772/14 1751/4 1753/24 1757/17 1760/10 1761/4 1837/18 1844/10 1845/10 1852/13
WEATHER [3] 1733/3 1733/8 1777/14 1763/2 1773/12 1774/4 1775/12 1777/7 WILD [2] 1780/12 1851/25
WEEK [1] 1749/25 1777/13 1782/4 1784/24 1786/13 1787/4 WILL [47] 1727/7 1734/21 1735/19
WEIR [4] 1731/8 1731/9 1731/13 1787/22 1790/25 1791/4 1793/22 1736/25 1737/18 1738/6 1740/3 1744/18
1731/16 1794/10 1794/11 1798/21 1799/10 1747/23 1762/11 1762/14 1763/2 1763/6
WELL [65] 1728/11 1729/21 1729/24 1799/10 1799/23 1800/10 1801/24 1763/11 1765/5 1765/10 1765/11
1730/24 1738/20 1744/14 1748/1 1801/24 1807/24 1808/8 1808/14 1765/16 1773/17 1788/9 1797/16
1748/18 1753/9 1756/19 1759/13 1809/11 1810/16 1813/22 1814/14 1801/14 1806/12 1813/12 1814/2
1760/19 1765/4 1774/11 1775/18 1816/12 1821/6 1823/15 1831/6 1834/12 1815/17 1821/6 1823/16 1824/17
1776/20 1777/19 1778/2 1781/1 1781/4 1835/20 1836/9 1838/10 1843/11 1845/6 1824/20 1825/10 1827/19 1828/8
1781/7 1781/20 1781/21 1782/7 1782/10 1846/1 1846/24 1847/1 1847/3 1849/20 1830/20 1830/21 1832/10 1838/21
1783/3 1785/22 1787/3 1788/2 1788/6 1851/18 1853/7 1855/7 1858/17 1861/15 1840/1 1843/24 1848/6 1852/8 1852/10
1790/19 1790/23 1791/13 1791/23 1864/11 1866/17 1854/22 1863/22 1865/9 1866/1 1866/2
1792/5 1793/10 1793/20 1793/25 1798/2 WHEN'S [1] 1748/5 WIND [11] 1728/16 1776/8 1777/15
1801/23 1803/15 1806/7 1806/11 WHENEVER [1] 1781/21 1777/15 1812/5 1813/13 1813/15
1813/16 1815/4 1815/17 1820/15 1821/9 WHERE [47] 1733/2 1733/16 1752/7 1814/16 1815/7 1817/1 1855/8
1822/2 1827/24 1832/3 1833/23 1833/24 1763/13 1765/17 1770/25 1775/8 WINDOW [1] 1733/3
1834/2 1838/14 1840/3 1840/23 1842/24 1775/12 1778/1 1779/23 1781/8 1784/19 WINDS [9] 1728/9 1776/11 1795/8
1851/22 1852/9 1855/1 1859/16 1860/13 1786/2 1786/14 1789/7 1796/17 1797/2 1796/10 1807/17 1808/14 1808/25
1861/17 1865/24 1801/20 1802/2 1803/16 1803/21 1812/21 1814/6
WENT [4] 1730/17 1795/19 1818/6 1803/22 1804/5 1804/11 1804/13 WISE [2] 1789/7 1789/8
1864/11 1804/18 1805/10 1806/18 1809/15 WISH [2] 1736/16 1865/14
WERE [94] 1731/11 1733/18 1734/5 1809/16 1810/25 1812/24 1813/6 1815/7 WITHIN [12] 1727/24 1733/2 1733/21
1734/12 1735/18 1736/5 1737/11 1816/5 1816/11 1819/2 1819/20 1820/6 1746/15 1752/9 1757/6 1785/7 1785/10
1737/11 1737/21 1737/24 1738/7 1823/16 1824/7 1831/3 1832/13 1837/7 1788/12 1835/12 1849/16 1862/7
1738/16 1738/18 1738/23 1738/25 1838/1 1850/9 1850/11 WITHOUT [7] 1741/21 1753/4 1774/25
1739/1 1739/10 1739/12 1739/17 WHEREAS [2] 1788/25 1820/23 1782/19 1830/15 1845/13 1852/20
1747/21 1748/1 1750/2 1750/21 1752/10 WHEREBY [1] 1737/5 WITNESS [6] 1727/6 1735/13 1773/13
1753/17 1755/7 1755/8 1759/2 1759/13 WHEREUPON [5] 1727/11 1773/19 1828/21 1830/17 1863/17
1767/3 1767/5 1767/6 1770/12 1775/12 1830/24 1832/18 1867/22 WON'T [3] 1852/3 1863/13 1864/16
1775/18 1776/5 1776/22 1782/1 1786/18 WHETHER [4] 1733/22 1791/19 1834/15 WONDERFUL [1] 1807/3
1787/15 1787/22 1792/11 1792/18 1840/14 WOODCOCK [1] 1725/17
1792/19 1792/22 1792/25 1793/20 WHICH [70] 1728/2 1734/21 1741/9 WORD [3] 1760/11 1763/24 1773/7
1794/10 1794/12 1794/12 1794/21 1743/12 1743/17 1743/22 1745/21 WORDS [3] 1755/12 1769/13 1782/10
1795/1 1798/14 1798/24 1804/25 1805/6 1747/5 1747/9 1750/11 1751/5 1755/21 WORK [14] 1728/6 1728/19 1728/22
1806/13 1806/14 1808/1 1808/2 1808/19 1757/9 1762/15 1762/25 1763/3 1763/15 1728/24 1729/3 1732/18 1733/17 1737/4
1808/22 1813/17 1819/17 1819/19 1765/10 1766/2 1767/7 1767/24 1774/7 1776/5 1790/11 1790/14 1828/12
1820/3 1821/9 1821/12 1821/14 1821/19 1776/10 1776/13 1776/17 1778/22 1834/19 1864/11
1821/21 1821/21 1821/23 1822/19 1779/5 1789/21 1792/1 1794/13 1794/18 WORKED [5] 1729/22 1732/8 1734/9
1823/5 1827/13 1827/17 1834/20 1795/22 1796/19 1802/9 1804/2 1804/5 1751/25 1759/16
1835/17 1841/3 1841/14 1850/1 1850/4 1806/14 1807/20 1808/14 1809/25 WORKING [3] 1728/8 1782/7 1816/18
1850/5 1855/5 1855/8 1857/17 1860/4 1811/17 1813/19 1814/10 1814/19 WORLD [4] 1775/21 1780/11 1780/15
1864/6 1864/14 1865/18 1865/20 1866/7 1814/22 1816/23 1818/4 1825/22 1828/2
1866/8 1827/19 1827/25 1828/8 1829/14 1830/6 WORRIED [1] 1755/8
WEREN'T [2] 1821/16 1840/10 1831/22 1832/11 1834/6 1837/9 1838/7 WORRY [1] 1773/14
WEST [1] 1759/16 1840/6 1842/24 1843/22 1846/14 WORSE [2] 1778/6 1779/15
WESTERINK [13] 1739/22 1777/20 1846/23 1847/6 1849/13 1854/11 WORST [5] 1750/7 1750/11 1855/3
1781/22 1784/18 1786/24 1788/5 1788/7 1858/10 1860/15 1862/20 1864/14 1855/6 1855/9
1789/6 1790/3 1791/13 1854/8 1854/14 WHILE [6] 1744/6 1824/7 1838/19 WORST-CASE [1] 1855/3
1854/22 1845/5 1854/17 1864/8 WOULD [160]
WESTERINK'S [6] 1785/11 1785/19 WHITE [3] 1815/25 1815/25 1816/1 WOULDN'T [2] 1841/19 1860/13
1786/20 1786/24 1789/18 1854/19 WHO [7] 1731/17 1734/10 1754/24 WRIGHT [1] 1724/5
WET [2] 1779/1 1859/20 1755/8 1767/2 1865/11 1867/9 WRITES [2] 1762/2 1762/14
WETLAND [6] 1733/12 1735/8 1746/17 WHOLE [8] 1734/13 1741/22 1786/5 WRITING [4] 1747/3 1764/12 1781/11
1778/3 1825/12 1826/7 1791/11 1796/25 1815/16 1820/25 1796/22
WETLANDS [22] 1730/8 1733/23 1742/7 1824/25 WRITINGS [1] 1761/10
1758/11 1766/25 1767/3 1767/5 1767/13 WHY [25] 1730/11 1730/17 1730/17 WRONG [11] 1757/7 1757/13 1757/20
1769/18 1778/13 1783/11 1812/17 1733/25 1735/25 1753/10 1753/12 1783/19 1784/11 1792/8 1792/12
1812/22 1820/23 1823/10 1823/23 1753/13 1768/13 1768/17 1769/6 1805/21 1806/10 1839/25 1850/3
1825/18 1825/19 1825/20 1827/3 1770/25 1772/1 1775/16 1790/18 1798/5 WROTE [1] 1767/18
Y
Y'ALL [1] 1741/4
YARDS [1] 1819/19
YEAH [16] 1756/25 1758/9 1814/2
1815/10 1815/20 1836/9 1840/8 1846/9
1848/2 1849/22 1850/22 1855/5 1858/18
1859/5 1859/10 1860/21
YEAR [6] 1753/3 1754/9 1758/6 1762/5
1762/6 1866/6
YEARS [9] 1728/21 1729/23 1730/9
1731/25 1732/13 1768/23 1826/3
1833/16 1854/25
YELLOW [2] 1815/8 1821/5
YES [65] 1727/9 1729/11 1729/16
1730/24 1732/12 1732/15 1737/24
1737/24 1740/1 1741/23 1747/19 1749/3
1762/23 1763/24 1767/1 1769/7 1772/11
1772/21 1774/18 1778/15 1782/21
1783/5 1785/14 1795/10 1799/21
1802/14 1802/19 1803/1 1803/23
1805/17 1808/11 1809/7 1810/6 1813/12
1815/12 1816/3 1816/16 1818/15
1819/12 1821/4 1821/19 1825/15
1826/18 1827/11 1829/24 1831/2
1833/14 1838/16 1839/13 1840/2 1842/1
1842/8 1845/4 1845/20 1846/18 1849/19
1851/21 1852/7 1855/23 1856/24
1856/24 1857/14 1861/11 1863/21
1867/18
YESTERDAY [1] 1865/25
YET [1] 1747/7
YORK [2] 1725/4 1725/4
YOU [389]
YOU'LL [3] 1749/7 1804/6 1838/18
YOU'RE [19] 1729/5 1729/17 1731/8
1733/22 1772/18 1773/10 1776/17
1797/10 1801/11 1806/16 1813/11
1821/2 1823/3 1838/18 1846/16 1849/20
1850/17 1851/2 1856/22
YOU'VE [14] 1729/15 1730/8 1730/17
1730/19 1731/2 1732/13 1734/25
1737/16 1740/15 1745/15 1745/17
1773/24 1814/17 1816/17
YOU-ALL [1] 1743/1
YOUR [221]
YOUR HONOR [34] 1727/7 1728/1
1734/16 1735/14 1736/19 1740/18
1741/16 1741/19 1743/3 1752/18
1760/15 1769/2 1769/25 1771/13
1771/20 1773/11 1774/4 1774/10 1786/3
1792/4 1801/5 1810/21 1829/11 1830/9
1848/5 1862/9 1863/9 1863/16 1863/24
1864/19 1864/25 1865/16 1866/3
1867/18
YOURS [1] 1803/14
YOURSELF [4] 1729/19 1729/24 1774/3
1835/11
Z
ZERO [1] 1768/2
ZONE [5] 1730/22 1766/22 1767/7
1767/10 1772/5

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1723

1 UNITED STATES DISTRICT COURT

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12:51 1 AFTERNOON SESSION

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13:10 1 MR. ROY: YOUR HONOR, FOR YOUR REFERENCE, HIS

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13:12 1 A. THAT'S CORRECT.

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13:13 1 A. THAT HAS BEEN MY NORMAL OPERATION, IS THAT I SPEND A LOT

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13:14 1 RÉSUMÉ COVERS THEM IN EXQUISITE DETAIL, BUT I WANT TO HIGHLIGHT

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13:17 1 FORECASTING MODE TO ALERT PUBLIC SAFETY AND -- IN A PUBLIC

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13:19 1 A. THAT'S RIGHT. MOST OF THE INSPIRATION COMES FROM SEEING

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13:20 1 HAPPENED, SOME SAID, AT KATRINA FROM THE PERSPECTIVE OF OTHERS,

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13:22 1 KATRINA DID WHAT IT DID TO THE METROPOLITAN AREA OF

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13:25 1 OF ENGINEERING. BUT FOR PURPOSES OF THIS LITIGATION, I WOULD

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13:28 1 MR. ROY: YES, SIR.

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13:31 1 BY MR. ROY:

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13:33 1 THE WITNESS: THE JUDGE HAS IT NOW, BUT YOU-ALL

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13:39 1 DURATION OF SURGE EXPERIENCED IN THE IHNC DURING KATRINA AND

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13:43 1 A. THAT'S CORRECT.

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13:47 1 MR. ROY: I WANT YOU TO PULL UP, PLEASE, CARL

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13:48 1 BUT THE PROPOSED LEVEES WITH NO MRGO.

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13:52 1 EXACERBATE THE CONDITIONS.

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13:56 1 UP PAGE 14.

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14:00 1 A. THE ONLY PLACE I HAVE FOUND IT IS IN AN INTERNAL

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14:01 1 LOGIC OF THAT. IT WASN'T ANY SCIENTIFIC APPROACH.

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