THE WELCH COMPANY
440 Davis Court #1602
San Francisco, CA 94111-2496
415 781 5700
S U M M A R Y
DIARY: December 15, 89 09:01 AM .......;
Rod Welch
CSCJ deposition support re BBC damage expert, Rodger Hewitt.
1...Picked up documents for this deposition, 5 boxes and a large roll of
..............
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CONTACTS
0201 - O-0436 0204 Natkin & Weisbach 415 546 1292 fax 394 8752
020101 - Mr. Al Hirshen, Esquire
0202 - O-0338 0202 Arthur Young & Company 415 951 3023
020201 - Mr. Rodger Hewitt, Construction Industry Group
0203 - O-0320 0202 Pettit & Martin 408 295 3210 fax 982 4608
020301 - Mr. Bryant K. Zimmerman, Esquire, =415 954 1638
SUBJECTS
HPS, CSCJ Litigation
Depositions, Experts
Dawson-Edwards, J (BBC)
891211
0407 - Picked up documents for this deposition, 5 boxes and a large roll of
0408 - schedule diagrams and networks, left by Bill Boyd for HPS in the depo
0409 - room last night.
0410 -
0411 -
SUBJECTS
HPS, CSCJ Litigation
Depositions, Experts
Hewitt, Rodger (BBC,
EX) 891211
0506 - ..
0507 - Progress
0508 -
050801 - County's counsel asked questions for most of day. OKA counsel was
050802 - permitted approximately 1 hour to ask questions. DHP counsel was not
050803 - given the opportunity to ask any questions. BBC counsel initially
050804 - indicated he would not permit witness to return for further examina-
050805 - tion. County, OKA and DHP counsel objected and indicated at least 2
050806 - more days of examination were necessary. Witness was not examined on
050807 - all of his documents, particularly the computer spreadsheet data which
050808 - was not produced, but which was relied upon and cited in his
050809 - testimony.
050810 -
050811 - At the end of the deposition, BBC counsel said that if the lawyers
050812 - could agree on another day in December, BBC would permit one more day
050813 - of examination.
050814 -
050815 - This matter was left open.
050816 -
050817 - We requested the final cost report which was made exhibit 8.
050818 -
050819 -
050820 -
0509 -
SUBJECTS
HPS, CSCJ Litigation
Meetings with counsel
Law & Motion research
support, settlement, misc.
0607 - Met with Ken Natkin and Frank Hughes, counsel for Pioneer, re
0608 - settlement terms.
0609 -
0610 - Ken asked about OKA's contract obligation for scheduling. He asked if
0611 - OKA was required to prepare an independent schedule from that prepared
0612 - by BBC. I explained OKA was required to prepare and maintain a Master
0613 - schedule which incorporated the separate schedules submitted by AMV and
0614 - BBC.
0615 -
0616 - OKA was also required to approve BBC's schedule which it did even
0617 - though Noel McFarlane who was OKA's schedule consultant knew BBC's
0618 - schedule was incorrect. OKA was also required to evaluate long lead
0619 - procurement such the Detention HM products which ultimately became a
0620 - procurement problem which is at issue in this litigation.
0621 -
0622 -
0623 -
SUBJECTS
WMA, Marketing, Evaluation
Individuals, organizations
Sales Contacts
0806 - Summary
0807 -
080701 - Rodger said Bill Palmer gave the SDS material to him. He would like a
080702 - meeting to see a demonstration of how it works.
080703 -
080704 - Call Rodger after 1st of year to set appointment to evaluate SDS.
080705 -
080706 -
080707 -
080708 -
Distribution. . . . See "CONTACTS"