December 11, 2024 Planning Board Special Meeting Transcript - WEHI

5 of 38 sheets Page 17 to 20 of 100 01/08/2025 12:06:06 PM 17 there. And I guess the best I sign would be, he doesn't1 know, I don't think, know how this was done. I don't2 know if he does, I can't speak for him.3 Well, Mr. Anderson signed it, okay. You saw his4 Q. signature there, right?5 Engineers sign work other people do in their firm6 A. all the time.7 Did you ask Mr. Anderson --8 Q. I don't know.9 A. Did you ask Mr. Anderson for the tree study? The10 Q. actual documentation and notes underlining this11 document.12 This is what I was provided. This is what I13 A. reviewed.14 Now try answering the question given, please.15 Q. It's not that difficult. Did you ask --16 I did.17 A. Did you ask Mr. Anderson for the underlying18 Q. documentation?19 I did not ask for anything further than what I20 A. was provided.21 So you can declare that this study is invalid22 Q. statistically, invalid scientifically, invalid23 arboreally and you never even asked for any of the24 information underlying it, is that your testimony?25 18 "Yes" or "no", is that your testimony.1 I do not need to see the underlying report2 A. because enough information is given here to tell me just3 looking at these three plots you have not statistically,4 not you personally of course, it has not statistically5 covered sufficient land area to be accurate. It's that6 simple.7 Now, you said you have a tree report that8 Q. referred to the rolling mean, I think. Am I using the9 right terminology?10 There are methodologies that you utilize -- the11 A. tree study that I posted, to answer your question, you12 asked me to post it, I posted it.13 What day, was that the October 16, 2024 report?14 Q. No, I believe -- I'd have to look and see the15 A. filing.16 You haven't used that in your testimony, as far17 Q. as I know. Is that something before the board?18 I believe, correct me if I'm wrong, I was asked19 A. after one or -- I don't remember which hearing, to post20 the original tree study from 2019, my recollection, and21 I know I submitted that.22 MS. McGOVERN: It's on a November 6 report,23 I think. I see it starts with, "I have attached more24 documents. The original tree study conducted" is that25 19 what you're discussing?1 MR. AFRAN: I mean, Mr. DeFeo made a2 reference to what's in his tree report, yet he's never3 testified to it before. It's never been produced as an4 exhibit. I have no idea what

at you're discussing?1 MR. AFRAN: I mean, Mr. DeFeo made a2 reference to what's in his tree report, yet he's never3 testified to it before. It's never been produced as an4 exhibit. I have no idea what he's talking about.5 I believe it has been -- I'm almost positive it6 A. was submitted at your request.7 I don't have it. I've never seen it.8 Q. I answered that.9 A. Do you have it in front of you right now?10 Q. MS. McGOVERN: Tree report complete. File11 updated.12 THE WITNESS: No, there's the update and then13 I believe there was the original.14 Why -- okay. So we'll go back to that. Let me15 Q. ask you a question. Where, if you go back to your16 presentation, right.17 Yes.18 A. THE WITNESS: Is this working?19 Go to the page with the spot study20 Q. identification. No, the circles.21 That?22 A. Yes. Thank you.23 Q. Yeah.24 A. Now, what's the actual geographic area covered by25 Q. 20 each of your test areas?1 Test areas 100 -- they're 10 by 10.2 A. 10 by 10?3 Q. Roughly 100 square meters.4 A. I'm sorry, meters or feet?5 Q. 100 square feet. 10 by 10.6 A. Each ones 10 by 10 square feet?7 Q. Approximately.8 A. Okay.9 Q. And how many do you have?10 22.11 A. 22. And so 100 times 22 is 22,000. You're12 Q. saying you did a 22,000 square foot survey -- excuse me.13 I'm going to use my phone and do this, because I don't14 claim my math's great but --15 CHAIRMAN BAGOFF: Mr. Afran, 2,200?16 2,200 square feet.17 Q. Well, that's very interesting. You said that18 this survey was how many square feet?19 Each plot was 10,000.20 A. Square feet?21 Q. I'm sorry. 10,000, yeah.22 A. Well, that's a heck of a lot more than you did?23 Q. I'll explain again how this works.24 A. No, no, no, don't go explain anything. Answer25 Q.