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e e fs0227 i I CON F IDE N T I A L MEMORANDUM TO: Bob Hykan Gene Jencsok Ruth Yeager ~ March 5, 1986 FROM: DATE: SUBJECT: National Forest Reserved Rights Technical Studies: Questions to be asked of the consultants The following list of questions incorporates the concerns that we addressed at our meeting this morning. In addition, I have edited my list of technical questions to better fit the time constraints of the interviews. General Questions 1. Please describe the relevant litigation experience of your firm, both in terms of expert testimony and of preparation of exhibits and reports. 2. What type of work products do you recommend as most useful in litigation? 3. Are you or any members of your firm constrained in any way, as a result of previous work, from attacking the Forest Service method? 4. In a project of this magnitude, where the thrust of the study may be subject to change, there are likely to be some conflicts between your firm and the State as to the proper approach. What do you see as your role in determining the direction of this study? 5. The State will be hiring another firm to review the work being done and the general methodology in terms of its suitability for evidence in trial. Do you have any suggestions as to how the review process should be structured so as to make it as productive as possible? Critique of the Forest Service Methodology 1. The State is more concerned with obtaining a scientifically defensible study than in getting results most favorable to the State's position. Bearing this in mind, what would you say are the strong points of the Forest Service methodology? If the Forest Service hired you to defend their claims for channel maintenance flows, would you be able to do so? 2. Please comment on what you see as the relative importance of the critique of the Forest Service method and the development of alternative methods. 3. What information do you need to obtain from the U.S. through discovery, and how soon will you need it?