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153 1 up. 1 else, to find out information about this air 2 Q. Well, in the exhibit that has been 2 shaft? 3 brought up -- and we can go to page 9 -- that I just 3 A. Yes, I did. 4 showed you, in April of 2016, the representations 4 Q. What did you find out? 5 are that there are four sinkholes. 5 A. That it was there. 6 A. Correct, by Fugro. Fugro represented 6 Q. I understand. Did you ask or did you 7 them as a geophysical consultant and not an expert 7 make inquiry to find out when it had been built? 8 in geotechnical exploration. Their job is to -- 8 A. I did. I don't remarber what dates, 9 they look at a hole in the ground and they'll call 9 but I did ask Ms. Hammond at what time it was 10 it a sinkhole. That doesn't necessarily mean that's 10 probably built and at what time it may have been 11 what it is. 11 abandoned, and she gave me a range of dates, but I 12 Q. To you, then, what is a sinkhole? 12 think that was prior to her tenure there. 13 A. A sinkhole is a hole that has a 13 Q. Was it prior to the 1970s, to the 14 connection to the subsurface and transmits water. 14 best of your recollection? 15 Q. Okay. So there could be a number of 15 A. I think so, but I can't say 16 holes in the ground and none of them connect to 16 definitively. 17 transmission of water? 17 Q. Okay. And do you recall obtaining 18 A. Correct. 18 any information on haw deep it is? 19 Q. In your geotechnical definition? 19 A. I believe, if I remember -- and 20 A. That's correct. 20 again, this is the best of my recollection -- that 21 Q. However, Fugro, in theirs, define 21 the shaft is about 100 feet. 22 them as a sinkhole. Am I correct? 22 Q. Okay. And haw deep below the surface 23 A. Yes, they did. 23 are these coal caverns? 24 MR. BECKWITH: Okay. Can we go, 24 A. About 100 feet. The shaft extends 25 Mr. Stark -- I don't know how to operate your 25 about 100 feet down to the old mine workings. -- -_ _-- 153 -- -- - -- 155 1 system-- but go back to page 9. 1 Q. Now, in April of 2016 Fugro went out 2 MR. STARK: Okay. 2 at your direction and conducted its first ERT 3 MR. BECKWITH: Thank you so nuch. I 3 testing. Was water added to sane portion of Tract 4 appreciate it. 4 71 to facilitate the ERT testing, so far as you 5 Q. (BY MR. BECKWITH) Now, looking on 5 know? 6 the right, there are not the same symbols, are there 6 A. Yes. 7 not, relative to sinkholes? 7 Q. And where was it added? 8 A. They are there, yes. 8 A. It was added to the northeast -- 9 Q. Well, let me rephrase. You don't 9 we'll call it the northeast sinkhole of the 10 have round red circles with crosses in them on the to Fontanari Ditch. 11 right-hand picture as you do on the left-hand 11 Q. You mean the sinkhole that did the 12 picture? 12 dirty -- that allowed water to go down through the 13 A. That's correct, but the dots are in a 13 trench? 14 similar configuration. 14 A. Right. The sinkhole that had 15 Q. Okay. And so what I understand then 15 previously -- people -- I hadn't been there — but 16 from this representation, that you determined a 16 others had previously observed water entering the 17 definitive subsurface connection between a sinkhole 17 subsurface. 18 at the angle of the Fontanari trench running over to 18 Q. Understood. And that is when 10,000 19 what? 19 gallons were dumped on -- down that sinkhole? 20 A. Running over to the air shaft. 20 A. Correct. 21 Q. Okay. And that is the abandoned air 21 Q. And that was not done by you; that 22 shaft? 22 was done by -- 23 A. Correct. 23 A. Snowcap. 24 Q. Did you do any historical research, 24 Q. Snowcap. In August of 2016 -- or I 25 talk with anybody, perhaps Mr. Stover or anybody 25 should say, the second Fugro testing, was water 154 156