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ft>qK>-Squish Condenselt George Jennrich <br />II <br />II <br />i 8 <br />II <br />li' <br />10 <br />1] <br />12 <br />13 <br />IE <br />IE <br />IS <br />6 <br />7 <br />18 <br />9 <br />IE <br />If <br />3 <br />24 <br />5 <br />1 <br />II3 <br />li <br />11: <br />10 <br />i <br />16 <br />T>9I <br />L25 <br />Page 53 <br />Q. So, three or four tunes a year the club would <br />have occasion to run a vehicle through the open barrier so <br />it could get to Long Lake '0 be serviced? <br />A. Yes. <br />MR. GREENE: I ani going to show you <br />another copy of 90. <br />MR. McCARTlri': Off the record. <br />(At this time a discussion was held off the <br />record.) <br />MR. MCCARTHY: It is Exhibit 153. <br />BY MR. GREENE: <br />Q. Earlier, you mentioned that there was a stretch <br />of road that you did not surface with aggregate as part of <br />regular maintenance. Can you circle the area of road that <br />you are referrirtg to or shade it in or in some way designate <br />it on this exhibit? <br />A. Is this western property line, is that where <br />the power lines run through? How accurate does this have to <br />be? <br />Q. This doesn't have to be accurate like a <br />surveyor, we are just trying to get the general area to <br />which you did not apply aggregate surfacing. <br />MR. MCCARTHY: On a regular basis. <br />A. On a regular basis. Yeah, we did throw some <br />materials in there. (Marking.) <br />Page 54 <br />Prior to what? There is a curve in the road. <br />Well, something like that. <br />MR. MCCARTHY: The witness asked about the <br />curve. There is a curve. This is a more detailed blowup, <br />the road continues after that point If you need a <br />different map to show a longer road, you could do that. <br />THEWTTNESS Well, ycah. <br />MR. MCCARTHY The witncss can take a look <br />at Exhibit I S3. <br />MR. GREENE: Or even 154 <br />MR. MCCARTHY: Right, or 154. <br />A. It went down to about where the curve was. <br />(Marking.) <br />BY MR. GREENE: <br />Q. So, the area that you have indicated on <br />Exhibit 153 with hash marks is an area that was rruuntained <br />differently from the other gravel or aggregate surfaced <br />roads within the club property; is that correct? <br />A. Yes. <br />MR. MCCARTHY: The record should reflect <br />that the witness has indicated that on Exhibit 155 that <br />point continued to about the curve south of the road, past <br />what is now shown as a new maintenance building; is rhat <br />correct? It wasn't there at the time. <br />THE WITNESS: YCS, it WCnt past. <br />1 <br />2 <br />3 <br />4 <br />5 <br />6 <br />7 <br />8 <br />9 <br />10 <br />11 <br />12 <br />13 <br />14 <br />15 <br />16 <br />17 <br />18 <br />19 <br />20 <br />21 <br />22 <br />23 <br />24 <br />25 <br />Page 55 <br />BY MR. GREENE. <br />Q. Let me ask this question. You may noi have <br />a recollection, but I am going to be very specific. <br />During the calendar year 1989. did you perform <br />or are you aware of having performed any mainteiuince on the <br />section of intenor oriveway that would have been west of <br />the site of the maintenance building? Again. I am just <br />asking if you have any recollection of having done so during <br />1989? <br />A. I am sure we did. yes. <br />Q. What is that recollection based upon? <br />A. I am sure we back bladed the road. <br />Q. Where would you back blade the road to? <br />A. Well, we would have done the whole thing <br />(indicating). <br />Q. Who typically did that at the club? <br />A. Oh. it could have been myself, it could have <br />been'one of my employees. Dean Peikey or Rick Rngman. or <br />whoever was a fuU*time employee. Dan Kavcm (phonetuj. <br />Q. My question was a very specific cne. Do you <br />have any specific recollection of that having been done in <br />1989? <br />A. No. but we did il on a yearly basis <br />Q. The back blading? <br />A. Right. <br />1 <br />2 <br />3 <br />4 <br />5 <br />6 <br />7 <br />8 <br />9 <br />10 <br />11 <br />12 <br />13 <br />14 <br />15 <br />16 <br />17 <br />18 <br />19 <br />20 <br />21 <br />22 <br />23 <br />24 <br />25 <br />Page 56 <br />0. What docs back blading mean'* <br />A. Well, you have a blade in back of a tractor <br />and you scrape the gravel, and it fills in the ruts and the <br />road, it smooths it off, you know If you don't do that on <br />a yearly basts or three or four times a year, the road would <br />become unusable. <br />MR. GREENE. Thank you. That is all I <br />have got <br />DIRECT EXAMINATION <br />BY MR. MCCARTHY: <br />Q. On this Exhibit 153, you marked in the back <br />hash marks to show where. I take it, in the I980's you <br />didn't do the same type of annual mainteruuioe that you did <br />on other portions of the internal roads; is that right? <br />A. Right. <br />Q. Now, the area that you have marked, tras that a <br />gravel rvi.al? <br />A Yes. <br />Q. During the 20 years that you were there would <br />you from time to time put fresh aggregate or gravel on <br />there? <br />A. Yes, we did. <br />Q. And the back blading is something that you did <br />annually?r;c 53 " age 56 Kirby A. Kennedy & Ataocintes (612) 922-I9SS