December 3, 2025 Regular Meeting - WEHI Transcript

7 of 17 sheets Page 25 to 28 of 68 01/05/2026 02:58:16 PM 25 you evaluate it right now sitting here today?1 No, I can't.2 A. That's all I want to know.3 Q. Not sitting here, but I know that it can be4 A. evaluated if I was tasked to do that.5 I understand.6 Q. And it wouldn't be something I can do in a7 A. five-minute interchange here, but it can be done.8 Well, you don't have a blast plan, you couldn't9 Q. do one right now no matter what, fair to say?10 Right. That's correct.11 A. Okay.12 Q. This is a Planning Board application. It's13 A. not --14 Mr. Kleinberg, there's no crime under New Jersey15 Q. law to simply answer yes or no. If a question calls for16 that please just --17 Yeah, but the answer tends to distort the18 A. picture.19 Well, that's your view.20 Q. If you just say "yes" or "no" it doesn't tell the21 A. whole story.22 I want ask you, can you evaluate the level of23 Q. risk disturbance and weakening of slope based on what24 you have in front of you right now?25 26 No.1 A. Thank you.2 Q. No.3 A. Thank you.4 Q. At Page 9 of your report you make the statement,5 "The principal jointing pattern indicated jointing with6 dip favorably downward into the slope and steep, nearly7 vertical joints." Now, are those the joints you were8 referring to last week when you said, infiltration could9 take place and cause ultimate instability?10 Those are parts of the system of joints, yes.11 A. Now, it then says, "Some of the exposed rock12 Q. showed a series of tight vertical cracks spaced as close13 as 1 or 2 inches."14 That's what we observed. They're not serious,15 A. they're very fine cracks.16 It says, I was quoting you, it said -- it says,17 Q. "A series of tight vertical cracks."18 Right, but they're not -- it's not unusual.19 A. Nothing unusual about the observation.20 In other words, not unusual on a ridge line to21 Q. have that?22 Right. In any type of a rock formation.23 A. Those cracks, those joints are what you're24 Q. referring to at the last meeting when you said water25 27 infiltration could cause rock --1 No, there might be wider cracks but not evidenced2 A. at the surface. There's very little rock exposed at the3 surface.4 Okay.5 Q. So when you said last week, you don't know if the6 joints are there, you were referring to internally in7 the rock?8 It's just a precaution.9 A. When you said last week that we don't know if the10 Q. joints are

u said last week, you don't know if the6 joints are there, you were referring to internally in7 the rock?8 It's just a precaution.9 A. When you said last week that we don't know if the10 Q. joints are there, that's because you can't yet see11 inside the rock, is that correct?12 That's correct.13 A. Okay.14 Q. So the surface joints that you see were different15 from what you're referring to last week where you said16 you couldn't see them?17 Right. That's a remote possibility.18 A. Why do you say, that's remote, how do you know if19 Q. you can't see it?20 Well, it's just based on the, it's based on the21 A. observation of rock that have been made in other areas22 near the site. That's just the way you have to do it if23 you can't see.24 I'm not saying you have x-ray vision, I am just25 Q. 28 asking you, how do you know it's a remote chance if you1 can't see inside the rock?2 Because generally joints are tight and sometimes3 A. they're wider joints.4 And you could see wider joints on the surface but5 Q. you don't know if they're below?6 Correct.7 A. Okay.8 Q. Now --9 I don't know if they're there either.10 A. I just said, you don't know if they're there?11 Q. Right.12 A. Okay.13 Q. Now, if those joints are there and water14 infiltrates, ultimately that will destabilize the rock,15 is that correct?16 Not necessarily. We don't know, but it's a17 A. precaution you take. If you see them you fill them.18 If the joints are there and water infiltrates19 Q. that's the factor that causes destabilization20 ultimately, isn't that correct?21 Correct.22 A. Thank you.23 Q. Now, you also say at Page 9, you report to a24 fault line. And you say, "Tectonic jointing is reported25