December 10, 2025, Planning Board Special Meeting - WEHI Transcript

01/14/2026 10:36:25 AM Page 45 to 48 of 144 12 of 55 sheets 45 Langan, did you?1 No, because --2 A. "Yes" or "no"?3 Q. The subsequent discussion I think took place4 A. after that. After the report.5 Correct. But you never supplemented that report6 Q. to disclose those discussions, did you?7 No.8 A. Okay.9 Q. Now, before November 13 were there any other10 e-mail exchanges, texts exchanges, letter exchanges of11 any sort between yourself and your staff at CME?12 Yourself and anyone at Anderson and Langan.13 I'm sorry, can you repeat the question again.14 A. Certainly. Before November 13, that first e-mail15 Q. in Exhibit O-38, were there any other written16 communications of any kind, e-mail, text, letters, memo,17 etc., between CMEs staff, yourself and anyone at18 Anderson or Langan?19 We had -- I had no subsequent discussions with20 A. anybody at Langan or Anderson before I prepared the --21 between the time I visited the site and when I prepared22 the report.23 That's not an answer to my question. Before24 Q. November 13 do you have any other written communications25 46 of any kind?1 I don't recall.2 A. Well, how would we know?3 Q. I will have to check, I guess. Whatever, you4 A. know, I'm instructed to do I will do.5 I can't instruct you, I am saying as6 Q. cross-examiner I need to see that. So are you willing7 to produce it?8 If it exits I will produce it.9 A. Do you recall, sitting here today, whether10 Q. between the date of your report on October 2 and11 November 13, you had any written exchanges of any kind12 between Anderson and Langan and anyone at CME?13 I don't recall.14 A. Now, the same question I am going to ask you15 Q. concerning phone discussions or zoom discussions.16 Between the date of your report and the first November17 13 e-mail in Exhibit O-38, did you have any phone18 discussions, personal meetings or zoom meetings between19 yourself and anyone at Langan or did anyone at CME20 concerning this case?21 I can't recall.22 A. Now, if you did have those personal discussions23 Q. you would have memorialized them to your supervisor,24 correct?25 47 I am not 100 percent sure. I can't say that1 A. necessarily that I did.2 Will you make that search?3 Q. Yes.4 A. Now, prior to the date of your October 2 report,5 Q. not prior to its preparation but prior to the date of6 October 2, did you have any other written communications7 of any kind, again

h?3 Q. Yes.4 A. Now, prior to the date of your October 2 report,5 Q. not prior to its preparation but prior to the date of6 October 2, did you have any other written communications7 of any kind, again e-mail, text, letters, etc., from8 yourself and anyone at CME and anyone at Anderson and9 Langan?10 Maybe just to confirm the appointment. The time11 A. of the appointment at the site. We were referred to12 Anderson by the town engineer --13 I understand.14 Q. -- to arrange for a meeting. So I might have.15 A. Might have been one of those, are you available? When?16 Back and forth like that to me.17 Was that an e-mail, a phone call, how did the18 Q. engineer speak with you?19 Sorry.20 A. How did the engineer communicate with you, by21 Q. e-mail, phone call, any other kind of writing?22 I think the engineer e-mailed us that we would,23 A. that we would -- she referred us to Mr. Anderson. She24 may have made the appointment, I don't recall exactly.25 48 When you had that appointment made had you1 Q. consulted with anyone at the board, such as Ms.2 McGovern, about doing that meeting with the applicants3 engineer?4 Not with Ms. McGovern for that meeting. We5 A. contacted the town engineer and that was the arrangement6 that was made for us to get to the site.7 Perhaps you can help me. Is it December -- well,8 Q. let me go back.9 You testified on December 3, correct?10 Yes.11 A. Okay.12 Q. And when we left here on December 3 you also knew13 you would be coming back here to continue14 cross-examination?15 Yes.16 A. And on the December 5, just two days later, you17 Q. received a communication from Mr. Seel, again copied to18 the same general group, attaching summaries for the19 shallow slope stability cases you requested, assuming20 full saturation and slope parallel seepage and output21 files from ACS of their NJDEP-approved groundwater22 mounding analysis. And you then, there was then a23 discussion in substance by Mr. Seel of his view of what24 all this means. Do you recall that e-mail? It's in25