December 3, 2025 Regular Meeting - WEHI Transcript

13 of 17 sheets Page 49 to 52 of 68 01/05/2026 02:58:16 PM 49 core, did you see like a section you wished they had1 studied instead of?2 THE WITNESS: No, they have a photograph.3 MR. KLEIN: Of the whole core and whether4 they took this piece up here or went down six more5 inches and took that piece, it's pretty similar?6 THE WITNESS: Right.7 MR. KLEIN: All right.8 See Mr. Kleinberg, the problem is, me as a9 Q. lawyer, I assume what's put in a report is what is10 important or you wouldn't put it in the report. So I11 keep asking you questions about statements you made and12 then you keep saying, they're not important. I am13 trying to understand why you care about whether you14 could see this piece of rock?15 It would have been good to see which piece they16 A. took from it. It would, but it's, in the big picture of17 things, it's not that significant. But I did put it in18 the report.19 I am still trying to understand what would be the20 Q. value to seeing it. That's what I'm asking you. You21 couldn't see it, you don't know where it is, may have22 been devoid, what is the value at this point?23 When you look -- because there are a number of24 A. joints and fractures on the existing core and it would25 50 have been good to, it would, if I were -- when I was1 looking for the piece I would have wanted to see the2 piece that they took, they selected for the samples.3 How deep was that core?4 Q. That I think was at the top surface of the rock5 A. and it was, and I think the core is generally 5-feet and6 then they would stop and take the core sample out, put7 the barrel down and run another 5-feet.8 Thank you.9 Q. You also make a statement that you, referring to10 different compressive strength measures on Page 14.11 This is in the -- are you all right?12 Sorry.13 A. Thank you.14 Q. This is in the paragraph headed, Basalt Bedrock.15 Now you say, after addressing two compressive measures16 you say, "The results are a small fraction of the17 anticipated strength range for Basalt and roughly18 equivalent to that of a low to medium strength19 concrete."20 Correct.21 A. Now, what are you trying to say there?22 Q. Sorry.23 A. You're making a comparison, you're saying the24 Q. results of these compression tests are a small fraction25 51 of the anticipated strength range for Basalt. Now,1 let's deal with that first, what does that mean?2 That means that the, that means

24 Q. results of these compression tests are a small fraction25 51 of the anticipated strength range for Basalt. Now,1 let's deal with that first, what does that mean?2 That means that the, that means that the strength3 A. of the Basalt is typically, typically about 30,000 PSI4 and these were about 3,000 PSI. And each of the5 engineers involved observed the same point. Princeton6 Hydro went over it and Langan also went over it.7 And so you're saying that this particular Basalt8 Q. is not as strong as one normally would expect from9 Basalt, is that correct?10 The sample was not as strong, but we don't know11 A. what the rest of the rock is, if that's typical of the12 rest of the rock.13 But the part tested showed that it's much, much14 Q. weaker than Basalt normally is. Isn't that fair to say?15 Correct.16 A. Okay.17 Q. Now, then you said, and these results were18 "roughly equivalent to that of a low to medium strength19 concrete."20 Correct.21 A. Because concrete is not, doesn't have the22 Q. cohesion of Basalt or other forms of rock and so you're23 saying this Basalt is actually more akin to the24 strength, weight bearing strength to cement, is that25 52 what you're saying?1 I'm sorry, you said I didn't -- you said more2 A. than --3 I will rephrase it.4 Q. Yeah.5 A. You're saying here that this Basalt actually in6 Q. terms of its weight bearing strength is equivalent only7 to a low to medium strength concrete?8 Correct.9 A. Okay. Thank you.10 Q. What do you mean when you say Langan "attributed11 the unusually low strength to porosity, and crystalline12 grain size characteristics in the rock." I won't say13 the rest of the sentence. What does that mean,14 attributed this low strength, this unusually low15 strength to porosity and crystalline grain16 characteristics of the rock?17 That's what they said, and I was just quoting.18 A. Do you have any knowledge of that fact one way or19 Q. the other?20 No.21 A. Okay. Thank you.22 Q. So basically this rock is much weaker than rock23 normally would be in this class and it actual is24 equivalent in strength to a relatively low grade cement,25