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WSPC12864
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Last modified
7/29/2009 1:47:11 PM
Creation date
4/15/2008 1:32:43 PM
Metadata
Fields
Template:
Water Supply Protection
File Number
8062
Description
Federal Water Rigjts, National Forest ISF Claims
State
CO
Author
CWCB/Varied
Title
Confidential Attorney Work Product - Master Outline of Trial Preparation Tasks
Water Supply Pro - Doc Type
Report/Study
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<br />j <br /> <br />,-~ <br /> <br />e <br /> <br />e <br /> <br />fs0306 <br /> <br />CONFIDENTIAL <br />MEMORANDUM <br /> <br />TO: <br /> <br />Bob Hykan <br />Gene Jencsok <br /> <br />Ruth Yeager ~ <br /> <br />March 7, 1986 <br /> <br />FROM: <br /> <br />DATE: <br /> <br />SUBJECT: <br /> <br />National Forests Reserved Rights Technical Studies: <br />Interview with Simons, Li & Associates <br /> <br />On March 7, 1986, we met with Ruh-Ming Li, Daryl Simons, Bob <br />Macarthur, Bob Musetter, and Brad Anderson of Simons, Li & Associates. <br />This interview was part of the selection process for hiring experts to <br />perform technical studies for the State of Colorado. <br /> <br />General <br />Both Simons & Li and Stanley Schumm (for KKBNA's team) are far <br />ahead of Bishop, Brogden & Rumph in terms of technical sophistication and <br />national reputation. Simons & Li came into the interview with two main <br />advantages over KKBNA: 1) all aspects of the study can be handled <br />in-house by a team with a proven track record for efficient and competent <br />work, and 2) their written proposal was far more detailed and thorough. <br />While the interview is important, our final selection needs to be based <br />on the written submissions as well. <br /> <br />Simons & Li gave a thorough and detailed presentation, and there is <br />no doubt about their ability to perform our study. If their presentation <br />is to be faulted, it is for a certain amount of heavy-handedness - at <br />times it sounded more like a sales pitch than a technical discussion. <br />Other factors that we discussed briefly after the interview were a <br />possible language problem in using Li as an expert witness, and how <br />amenable they might be to any changes suggested by us or by the other <br />expert we are planning to hire. <br /> <br />Suitability as Expert Witness <br />The firm as a whole has excellent credentials in courtroom <br />experience. Simons is lucid and eloquent, and his international <br />reputation is upheld by his authoratative demeanor. His testimony should <br />stand up well in court. Ruh-Ming Li would be less impressive on the <br />witness stand simply because his English is not always easy to <br />understand. It will be up to Bob to decide whether this poses a serious <br />problem. <br /> <br />Administration <br />Simons & Li's reputation is based not only on technical competence, <br />but also on their ability to get work done smoothly and efficiently. My <br />only concern would be that their great degree of self-confidence may make <br />them less responsive to our needs, or to any changes we wish to make in <br />their contract. (This may not be the case at all; the recommendations <br />that Bob received said that they were easy to work with.) <br />
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