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•~. . 'r • -~ 1 2 3 4 S 6 7 8 9 10 ll 17 18 19 23 25 1 2 3 4 5 6 7 8 9 10 11 13 16 [7 18 19 Crcek v. Bad~ys et al. Page 41 Q. How long was you thers as the Burtises' site? A 17tis Was the Bad Boys. Q. Excuse me, oo the Bed Boys site? A. I was there about 4 hours. Q. Does that include the trip down m the store? A Yes Q. You state that you didn't do ffir environmental audit. Whaz do you [near by m environmental audit? ~. Generally, on these types of evaluations, in today's atmosphere, whaz we would also do is look for -- to sce if somebody had dumped some barreLc or anything that might be noxious on the property that they might be liable for. Q. And you said that you didn't do that? a We did not. I did not do that. Q. What all would a -you're looking for, I guess, obvious signs of cantaminazion. What else would an environmrnta! audit entail? A. I think the big concern today would be if somebody had used that as a dumping ground for barrels of rtes or some albs hard-to-dispose of item thaz some third patty may have dumped Q. Would it be necessary for a mine to have an rnvironmrntal audit? A. Most mining companies, in acauirin¢ orooerties, Page 42 would ioclude that as part of their evaluation. Q. Would thaz be known as a Phase I audit? A I'm not sue. Q. Is an rnvvonnterttal audit something that you can do? a Yes, I can. Q. How much would an rnduonmeptal audit cost? a It depends on the sine of the property. Q. How much would an rnvironmental audit of the Bad Boys site cost? ,~ 15 minutes' time. Q. Not terribly detailed? A. No. Q. You stated that you did no appraisal of the equipmrnt, Again, why did you mrntian that? A Well, it's -then: was no equipment on site, essentially, If I wen; doing a mineral appraisal for, say, another company, part of that appraisal may be the buildings and/or process equipment that might be located on the site as part of the valor of the property. Q. In the geology portion on page 3, you mention gold Was you asked to value gold? a Not az this time. Q. Do you have say opinion as to gold on the Carton E. fierily, P.E. Page 43 1 /-. Yes, I do. 2 Q. What is that? 3 w. 7}rere is gold. 4 Q. Do you know whether or not it's in commercially S feasible amounts to mice? 6 a No, I do not. 7 Q. So you've done no testing whatsoever for gold? 8 A. Pardon me? 9 Q. You've done na testing whatsoever for gold? 10 a No, I have not. 11 Q. And you !lave not been asked to give any opinion 12 as to gold? I3 A 'Ilrat's correct. 14 Q. Have you barn asked to give any opinion as W IS any, I guess, other valuable mineral or rock? 16 ,~. No, I have not. 17 Q. Just turquoise? 18 ~. 'Itrat's comet[. 19 Q. On page 6, you mention a -- I'm assuming it's a 20 geologic term, brsccia, b-r~-c-c-i-a? 21 a 71rat's correct. 22 Q. Can you tell me what brattier is? 23 a It's just a type of rock that occurs in the 24 Cripple Croak area. It's the result of a volcanic explo- 25 sion where the rock is fragmented and then rxanrnted back. Page 44 1 Q. Is it stable? 2 a Yes, it is. 3 Q. And then you mention photo 3. I apologize, I 4 don't !rave an original of this. Does that photo show 5 breccia7 6 a I'm not sue. It probably does. 7 Q. Is the occurrence of brsccia something that you 8 observed personally? 9 a Yes, it is 10 Q. It's not just from the literature? Bemuse that I1 particular sentence is footnoted. 12 a On page 6? 13 Q. Correct. No, excuse me -- yes, page 6. la a I would say that the reference -- Lindgren is the 1 S one who defined the type of rock in the area, and I would 16 merely accept that. 17 Q. So, I guess, did you verify that by independent IS means? r9 A. No, I did not. 20 Q. So you don't know whether it's brsccia or not? 21 a 7trat's correct. 22 Q. Are there any other types of rock besides brattier 23 present in the area? 24 a Yes, there arc. 25 Q. Whaz would those be? Page 41 -Page 4~