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-er price, would he not? <br />A In my opinion, he would, yes. <br />Q Did you also determine the <br />• placement cost of the residence and adjacent <br />-uctures at Solitario? <br />A Actually, I determined the <br />production cost new. Replacement cost is <br />Kerent than reproduction cost new. <br />;production cost new assumes that you will use <br />day's building techniques, and replacement <br />sumes that you will replace it as it was. <br />Q Well, what did you determine -- the <br />production cost, is it? <br />A Yes, reproduction cost. <br />Q -- of Solitario to be? To make the <br />:cord clear and make my question clear, what <br />flue, if any, did you determine for the <br />:production cost of the house -- residence <br />ruse at Solitario and the adjacent structures <br />.ound the residence house? <br />A For the entire structures plus the <br />nd? <br />Q No, just the residence house. <br />A Just the residence house. <br />Q And the veranda, the garage and the <br /> <br />atio. <br />_A I'm referring to my updated report <br />nd the reproduction cost new of the main <br />?s dence is indicated to be $395,228 <br />4 MR. MORRIS: No further questions <br />f`this witness. <br />THE COURT: Cross examination. <br />b CROSS EXAMINATION <br />MR. BIANCO: <br />5 Q Good morning, Mr. Floyd. Good to <br />?E,You again. <br />A How are you this morning? <br />I I Q Before I start, I wonder -- I think <br />Might be useful -- there's some books in <br />Font=of you there. <br />MR. BIANCO: Your Honor, may I <br />Pp oach to help the witness. <br />THE COURT: Counsel may approach <br />MR. BIANCO: This is going to be <br />e-one we will start out with and there are <br />. ?bered tabs that tell you the exhibit. <br />Q Mr. Floyd, I'm going to start out <br />5kiri <br />9 you a few questions about your <br />kground that maybe Mr. Morris didn't go <br />PAGE 495 <br />1 into. <br />2 1 take it you have never testified <br />3 in court as an expert witness before? <br />4 A No, sir, I have not. <br />5 Q. And in terms of your background and <br />6 appraisal work, you didn't really get into <br />7 appraisal work as an occupation until about <br />8 1992; is that right? <br />9 A That is correct. <br />10 Q And you've done other things, a lot <br />11 of agricultural work prior to that? <br />12 A And I was involved in real estate <br />13 prior to that also. <br />14 Q And to some extent, even today you <br />15 spend a small part of your time as a rancher. <br />16 Is that fair? <br />17 A Correct. <br />18 Q Mr. Floyd, as I understand it, you <br />19 have never appraised any other property <br />20 suspected of being subject to coal mine <br />21 subsidence or to any kind of subsidence. Is <br />22 that right? <br />23 A That's correct. <br />24 Q Now, you appraised some property <br />25 for a Dr. Eagan at one time? <br />PAGE 497 <br />1 A Correct.'- <br />2 And you understood that there was <br />3 some affect of subsidence there, but you were <br />4 not asked to take that into account in any way? <br />5 A That is correct. <br />6 Q In connection with this assignment <br />7 for Mr. Morris, I believe you conferred with <br />8 other appraisers about the subsidence issue. <br />9 Is that right? <br />10 A Correct. <br />11 Q But the fact of the matter is, none <br />12 of those appraisers were able to be of help to <br />13 you. Is that right? <br />14 A That's correct. <br />15 Q In terms of subsidence itself, you <br />16 have no expertise in that area. Is that right? <br />17 A No, sir, I do not. <br />18 Q And you're not sure you would know <br />19 the affects of subsidence when you saw them. <br />20 Is that fair? <br />21 A That's fair. <br />22 Q Now, I know when you looked at the <br />23 Tatum house you saw some cracks, correct? <br />24 A Correct. <br />25 Q But you're not qualified, in your <br />REBECCA ERHARDT, CSR, RPR - 719-846-3316 <br /> <br />l? II hh <br />i 4 <br />IIr II 1 <br />1 <br />I IFS I jit <br />I,; i <br /> <br />