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-Squish Coadt^t” _________ Riclafd <br />>rt»w«prton«)7 <br />21 <br />about? <br />Q. Other than the maintenance you testified to? <br />A. Coma. Along the edges there were some <br />Boxelder saplings that were growing up, other than that, it <br />was general crabgrass growing in the path of the roadway. <br />Q. Was the roadway in the condition where cars <br />and trucks could use it to access the club from WoodhUl <br />Avenue without the need for roadway improvements, which <br />might include clearing off of vegetation and brush, grading <br />and resurfacing? <br />A. It is my belief you could get up and down that, <br />if you wanted to. <br />Q. What do you mean by that, "if you wanted to"? <br />A. If you wanted to take a vehicle up that road or <br />come down that road, you could have, if you removed the <br />chain. <br />Q. Would there have been any problems or <br />complications associated with doing so? <br />A. We didn't have any problems when wc took our <br />tractor down there. <br />Q. Suppose you are driving something other than <br />a tractor, are you encountering vegetauon and underbrush? <br />Page 70 <br />We have referred to that from time to tunc. Was that there? <br />A. You wouldn't be driving over brush. The center <br />pan of the roadway was clean still. We ined to maintain <br />that. But, the sides had the Boxelder saplings growing up <br />along the edges. <br />Q. How thick were the circumferences of the <br />Boxelder saplings? <br />A. One to throe inches. <br />Q. When you say, "the edges," were these growing <br />on the roadside, in other words, the area of the road that <br />would not be uaveied, or were they on the edges of the <br />traveled road area? <br />A. It would be on the edges of the traveled <br />road, so the center pan, you could still get a tractor or <br />a vehicle up and down the center. <br />Q. Can you provide me with a more detailed picture <br />of what the area you have shaded in pink looked like on <br />May 4, 1998, the day before improvements were do.ie? <br />A. There were Boxelder «apiing« growing along the <br />edge of the road and there were branches hanging from the <br />mature trees forming up a canopy, not a canopy across the <br />road, but a canopy to the edge of the road, to best describe <br />1 •It <br />24 Q. Would these trees obstnict the vision of <br />traffic or otherwise need to be pared back in order to <br />69-Page 72 " <br />I <br />—W /w ISaEKII <br />be desirable or would absolutely have to be done to be <br />navipied? <br />Ma.OReeNE: oesirabie. <br />SYMILCReeNE: <br />Q. 1 am trying to get a sense of bow me <br />bows related to the need to improve the roadway. <br />A. It would be desirable. <br />Q. Why is that? <br />A. If you ame going to pass two cars on the <br />roadwiy, you would hnve the ears pushii« up ogninstd* <br />branches, if we didn't trim !>■*— back. <br />Q. So kt OK see if I understand sort of the gist <br />of your testanony regarding mainienaaoe of U b ana wUcb <br />you have shaded in pink on Exhibit 88. <br />- From Oecamber of 1989 to May 4 of 1998, the <br />only mainioiance performed by the club in the vicmiiy of <br />the area shaded in pmk involved sook tnnuning or removal <br />of trees to faciliUK bicycle access lo the club? <br />A. And any of our vehicles, our tractors. <br />Q. Did you have to do nuuiienance to this arm <br />of the gravel road in conjunction with your desire to move <br />the tractor to the repair dmien in 1990 or 19977 <br />Page 72 <br />A. I can't answer that I don't know Our goal <br />was to keep the arm open so you could access it with a <br />tractor and access it with a bKycle. <br />Q. Had you read any depostuon iienscnpu in this <br />case? <br />A. 1 looked at Mr. AJbiecbi's. <br />Q. Did you rrad Mr. Albiechi's deposition? <br />A. I did. <br />Q. Is iboe any aspect of Mr. Albiecld's account <br />of events on May 4tb with which you disagree? <br />A. No <br />Q. Let me understand then in your own words, how <br />It was that you learned that the club wanMd to make mad <br />improvonenu that would enable pa ssag e to occur beivreen the <br />paved potuon of Woodhill Avenue and the country club. <br />A. 1 leceived a call from Mr. Albrecht asking <br />that we mem at L-OO on Monday with Mr. Dayton to V mA at <br />the road, and that's how I learned of it. <br />Q. What happohxl nea? <br />A. Wemesat 1:00 on Monday. U k 4th. 1 believe <br />it is. We walked the road. They asked me if I could do <br />this job. and 1 told than that the time constraint was my <br />staff, being that thoe was the opening pan of our golf <br />*eason. wc didn t have the staff to do it, but we would have <br />so mebo dy come in and help us. <br />A. Kennedy and Associates (612) 922- <br />% <br />) <br />)