Hearing Postponed Until Thursday 3/20 at 1pm

In court filings made on February 29th, UC attorneys and their experts rejected the expert testimony filed by plaintiffs. Here is a summary of the key points UC's experts made in rebuttal.

This article was first published on March 13th under the title Prepping for Friday's Court Hearing at a time when the hearing was set for 1:30 p.m. on March 14. That morning the judge notified the parties that she had postoned the hearing, then later designated Thursday, March 20 at 1 p.m. as the time for it to occur.

What follows is the text of the article as it was originally published.

As has been reported here in some detail, the judge in the case filed against UC's plans for several projects in the southeast quadrant of the campus (one of them is the proposed athletics center, the SAHPC) ordered the parties to submit expert testimony on whether the new center is separate from or an upgrade to the adjacent stadium.

Paraphrasing, she requested that:

  1. The expert testimony be based on the design documents in the record,

  2. It address whether the two structures are independent,

  3. It should be based on the California Building Code,

  4. It should discuss whether structural independence is significant.

In rebuttal to plaintiff's expert testimony reported here and here, UC filed a statement on its own behalf along with 5 others that were prepared by several of UC's exports, each of them responding in their area of expertise.

UC's own statement is quite brief - a fact that readers of these reports will be relieved to know - consisting of just 3½ pages of text.

UC began by objecting to seven key sentences in the testimony submitted by architect Marcy Wong, saying that the topics she covered did not address the topic the judge requested.

For example, Wong opined that the meaning of the words in the seismic safety law called Alquist-Priolo (A-P) "can reasonably be determined from the context of their usage in A-P and their common usage."

In another example, Wong asserted that the common definition of words used in A-P could be used to determine that the center is an upgrade to the stadium.

In making these statements, Wong and plaintiffs' attorneys continue to argue at length that a plain-word-reading of A-P should be applied in this case, rather than whether the two buildings are structurally independent as the judge seems to be implying in her order.

Readers of these articles will by now recognize this to be the ongoing central strategy of plaintiffs: to make as many arguments as possible, from as many angles as possible, that the judge should set aside the structural independence criteria - even though that was the topic the judge requested to be addressed.

As reported earlier, "structural independence" does not appear anywhere in A-P. Nor have there ever been any cases before a California court arguing whether a new building - sited directly adjacent to an existing building that sits on an active fault trace - is either an upgrade to the existing building or not. The issue of structural independence in this circumstance has never been argued in court. So however the judge rules in this case, she will necessarily be adding new interpretation and analysis to A-P practice.

This also makes clear that the plaintiffs are perfectly well entitled to argue for their interpretation of A-P law as it applies to the present situation, precisely because there are no precedents. But it also makes clear why UC has responded to the judge's order with a massive and convincing demonstration that the buildings are structurally independent - precisely because they know they will win if the judge sticks with that criterion.

UC objected to the testimony of David Orth, a retired deputy fire chief for the City of Berkeley, because his testimony did not specify which if any of the building plans for the athletics center he had reviewed. They also objected to an opinion stated by Orth that there was a possibility that UC might in the future make more connections between the center and the stadium, saying that no evidence was offered that Orth had any personal knowledge of that.

Aside from the fact that what he said is pure speculation, of course.

UC also objected to the testimony of civil engineer Fariborz Barzegar where he said users of the two buildings will, "experience the two areas as one single structure," without offering any evidence to support that contention. They also objected to Barzegar's contention that the new center would increase the "rates of use/occupancy" of the stadium, and so must be considered an addition to it.

In each of these instances, UC is attempting up discredit narrowly selected statements from the expert testimony that if discredited would undermine or neutralize the rest of the arguments the experts made.

John Osteraas, a professional engineer and a Group Vice President of Exponent Failure Analysis Associates, came in for similar treatment, though on somewhat more technical grounds. UC attorneys found his arguments about the meaning of words in A-P to be circular and/or not defined. UC also cited to several statements made by Osteraas that "depend on the existence of preliminary facts not stated in his Declaration," and that he has offered no evidence to the Court to support his conclusions.

David Friedman, senior principal and president of the Board of Directors of the structural firm Forell/Elsesser Engineers Inc. ("F/E") (a principal contractor to UC for the construction of the athletics center and the proposed upgrade to Memorial Stadium) said in his rebuttal that he had reviewed the testimony supplied by Wong, Barzegar, Orth, and Osteraas and wanted to express his strong disagreement with their declarations.

First, he pointed out that Barzegar is not a licensed structural engineer (SE) in California or any other state, and notes that only SEs are qualified to peer review UC projects. He also reviewed Barzegar's resume and found nothing relevant to A-P practice.

More broadly, Friedman argued that plaintiffs' experts have badly confused an issue that is otherwise simple and straightforward. He says that plaintiffs' experts "devote substantial space to defining terms such as 'additions' and 'structural independence' (as we have seen) and then try to relate those words to the 'intent' of A-P."

Their "complete disconnect", says Friedman, is that they seem to completely miss the technical engineering content of A-P. And that intent is, per Friedman, directed solely at "surface rupture along active earthquake faults".

He explains that surface rupture is a completely different issue than ground shaking, and that A-P is directed at the former, not the latter. As readers well know, A-P prohibits new structures (and limits building upgrades to buildings) on fault lines because a rupture can tear a building apart. But the statute says little about mere ground shaking. According to Friedman that whole latter arena is implicitly left (by A-P) to building codes inspectors and enforcement.

So given A-Ps clear focus on surface rupture only, any new building that is truly structurally independent from one that does sit on a fault, a new building that is therefore NOT subject to surface rupture failures, isn't even subject to A-P, and therefore cannot possibly be considered an addition to or upgrade of its neighbor under A-P.

Strong words and a useful distinction.

Friedman also takes up Barzegar's contention that soil support provided by the new center to the stadium makes the two dependent. Friedman says that such an interpretation is completely contrary to all civil engineering practice in the country, and notes that were Barzegar right, every building in an urban area would be dependent on every other, and endless upgrades would be required every time a new building was erected.

"As a result, it is my professional opinion as a structural engineer with over three decades of experience that the SAHPC (the center) is not an addition to CMS (the stadium) under Alquist-Priolo."

Because there is a lot of overlap between the various experts UC has called upon to provide testimony and rebuttals, we will cover just one more here.

Civil Engineering Professor Jonathan D. Bray teaches and researches at UC. He has a lengthy resume that includes supervising numerous projects in seismic zones worldwide. His several areas of specialization and lists of honors are themselves to lengthy to repeat here.

Bray is a member of UC's standing Seismic Review Committee that consists of structural engineers, geotechnical engineers and architects, many of whom teach at the University.

He too joins Friedman in declaring, "the SAHPC's structural independence from (the stadium) is absolutely crucial to its status as a separate building within the context of A-P".

He also examines whether the SAHPC is an addition to the stadium under the terms of the current version of the California Building Code (the CBC) and concludes that it is not. (Plaintiffs have argued that the now obsolete building codes that were in effect when A-P was enacted should now be used to properly understand the intent of A-P; they of course find definitions of certain terms used then to be more useful to their case now.)

"In my professional opinion, for purposes of A-P compliance, there is absolutely no doubt that the SAHPC is a stand-alone building, separate from (the stadium). The fact that the SAHPC and (the stadium) are structurally independent is sufficient to determine that the SAHPC is not an addition to the stadium - under both A-P and the CBC." (My emphasis added.)

These are world-class experts professionally certifying UC's contentions in the case. Were there no other legal issues on the table, this writer finds these detailed and logical presentations to be thoroughly convincing. Friedman's point that structural independence of the two buildings by itself removes the SAHPC from the purview of A-P - and therefore makes it impossible for the SAHPC to be considered an addition to the stadium under A-P - is convincing.

But there are other issues afoot.

As reported yesterday, in a late attempt to preempt UC's experts' rebuttals, plaintiffs on March 6th filed a request that the court not consider any of UC's rebuttals, on two grounds:

  1. That UC's rebuttals all contain "new evidence" that should have been submitted on February 22nd when new expert testimony was all due, and
  1. That by including new evidence, the rebuttals went beyond the scope of the testimony the judge's order requested.

This has the aroma of a desperate attempt in the final days to preempt testimony plaintiffs know to be devastating. Still, it seems undeniable that there is new material in the rebuttals submitted by UC's experts; whether that constitutes "new evidence" or merely the opinions and explanations that the judge requested about what is already in the record - only the judge can decide.

The issue will surely be vociferously argued in the oral hearings scheduled for tomorrow (Friday March 14th) in Hayward, the last hearing before a ruling that is expected within 30 days.


©Copyright 2008, BearInsider.com and Scout.com. All rights reserved.

If you haven't done so already, subscribe to The Bear Insider so you can participate in this active online Cal community and get access to the members-only content from the nation-wide Scout.com network.

Bear Insider staff writers visit the Insider discussion board regularly, and are available to discuss questions you may have about this article and Cal Athletics.


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This article was first published on March 13th under the title Prepping for Friday's Court Hearing at a time when the hearing was set for 1:30 p.m. on March 14. That morning the judge notified the parties that she had postoned the hearing, then later designated Thursday, March 20 at 1 p.m. as the time for it to occur.

What follows is the text of the article as it was originally published.

As has been reported here in some detail, the judge in the case filed against UC's plans for several projects in the southeast quadrant of the campus (one of them is the proposed athletics center, the SAHPC) ordered the parties to submit expert testimony on whether the new center is separate from or an upgrade to the adjacent stadium.

Paraphrasing, she requested that:

  1. The expert testimony be based on the design documents in the record,

  2. It address whether the two structures are independent,

  3. It should be based on the California Building Code,

  4. It should discuss whether structural independence is significant.

In rebuttal to plaintiff's expert testimony reported here and here, UC filed a statement on its own behalf along with 5 others that were prepared by several of UC's exports, each of them responding in their area of expertise.

UC's own statement is quite brief - a fact that readers of these reports will be relieved to know - consisting of just 3½ pages of text.

UC began by objecting to seven key sentences in the testimony submitted by architect Marcy Wong, saying that the topics she covered did not address the topic the judge requested.

For example, Wong opined that the meaning of the words in the seismic safety law called Alquist-Priolo (A-P) \"can reasonably be determined from the context of their usage in A-P and their common usage.\"

In another example, Wong asserted that the common definition of words used in A-P could be used to determine that the center is an upgrade to the stadium.

In making these statements, Wong and plaintiffs' attorneys continue to argue at length that a plain-word-reading of A-P should be applied in this case, rather than whether the two buildings are structurally independent as the judge seems to be implying in her order.

Readers of these articles will by now recognize this to be the ongoing central strategy of plaintiffs: to make as many arguments as possible, from as many angles as possible, that the judge should set aside the structural independence criteria - even though that was the topic the judge requested to be addressed.

As reported earlier, \"structural independence\" does not appear anywhere in A-P. Nor have there ever been any cases before a California court arguing whether a new building - sited directly adjacent to an existing building that sits on an active fault trace - is either an upgrade to the existing building or not. The issue of structural independence in this circumstance has never been argued in court. So however the judge rules in this case, she will necessarily be adding new interpretation and analysis to A-P practice.

This also makes clear that the plaintiffs are perfectly well entitled to argue for their interpretation of A-P law as it applies to the present situation, precisely because there are no precedents. But it also makes clear why UC has responded to the judge's order with a massive and convincing demonstration that the buildings are structurally independent - precisely because they know they will win if the judge sticks with that criterion.

UC objected to the testimony of David Orth, a retired deputy fire chief for the City of Berkeley, because his testimony did not specify which if any of the building plans for the athletics center he had reviewed. They also objected to an opinion stated by Orth that there was a possibility that UC might in the future make more connections between the center and the stadium, saying that no evidence was offered that Orth had any personal knowledge of that.

Aside from the fact that what he said is pure speculation, of course.

UC also objected to the testimony of civil engineer Fariborz Barzegar where he said users of the two buildings will, \"experience the two areas as one single structure,\" without offering any evidence to support that contention. They also objected to Barzegar's contention that the new center would increase the \"rates of use/occupancy\" of the stadium, and so must be considered an addition to it.

In each of these instances, UC is attempting up discredit narrowly selected statements from the expert testimony that if discredited would undermine or neutralize the rest of the arguments the experts made.

John Osteraas, a professional engineer and a Group Vice President of Exponent Failure Analysis Associates, came in for similar treatment, though on somewhat more technical grounds. UC attorneys found his arguments about the meaning of words in A-P to be circular and/or not defined. UC also cited to several statements made by Osteraas that \"depend on the existence of preliminary facts not stated in his Declaration,\" and that he has offered no evidence to the Court to support his conclusions.

David Friedman, senior principal and president of the Board of Directors of the structural firm Forell/Elsesser Engineers Inc. (\"F/E\") (a principal contractor to UC for the construction of the athletics center and the proposed upgrade to Memorial Stadium) said in his rebuttal that he had reviewed the testimony supplied by Wong, Barzegar, Orth, and Osteraas and wanted to express his strong disagreement with their declarations.

First, he pointed out that Barzegar is not a licensed structural engineer (SE) in California or any other state, and notes that only SEs are qualified to peer review UC projects. He also reviewed Barzegar's resume and found nothing relevant to A-P practice.

More broadly, Friedman argued that plaintiffs' experts have badly confused an issue that is otherwise simple and straightforward. He says that plaintiffs' experts \"devote substantial space to defining terms such as 'additions' and 'structural independence' (as we have seen) and then try to relate those words to the 'intent' of A-P.\"

Their \"complete disconnect\", says Friedman, is that they seem to completely miss the technical engineering content of A-P. And that intent is, per Friedman, directed solely at \"surface rupture along active earthquake faults\".

He explains that surface rupture is a completely different issue than ground shaking, and that A-P is directed at the former, not the latter. As readers well know, A-P prohibits new structures (and limits building upgrades to buildings) on fault lines because a rupture can tear a building apart. But the statute says little about mere ground shaking. According to Friedman that whole latter arena is implicitly left (by A-P) to building codes inspectors and enforcement.

So given A-Ps clear focus on surface rupture only, any new building that is truly structurally independent from one that does sit on a fault, a new building that is therefore NOT subject to surface rupture failures, isn't even subject to A-P, and therefore cannot possibly be considered an addition to or upgrade of its neighbor under A-P.

Strong words and a useful distinction.

Friedman also takes up Barzegar's contention that soil support provided by the new center to the stadium makes the two dependent. Friedman says that such an interpretation is completely contrary to all civil engineering practice in the country, and notes that were Barzegar right, every building in an urban area would be dependent on every other, and endless upgrades would be required every time a new building was erected.

\"As a result, it is my professional opinion as a structural engineer with over three decades of experience that the SAHPC (the center) is not an addition to CMS (the stadium) under Alquist-Priolo.\"

Because there is a lot of overlap between the various experts UC has called upon to provide testimony and rebuttals, we will cover just one more here.

Civil Engineering Professor Jonathan D. Bray teaches and researches at UC. He has a lengthy resume that includes supervising numerous projects in seismic zones worldwide. His several areas of specialization and lists of honors are themselves to lengthy to repeat here.

Bray is a member of UC's standing Seismic Review Committee that consists of structural engineers, geotechnical engineers and architects, many of whom teach at the University.

He too joins Friedman in declaring, \"the SAHPC's structural independence from (the stadium) is absolutely crucial to its status as a separate building within the context of A-P\".

He also examines whether the SAHPC is an addition to the stadium under the terms of the current version of the California Building Code (the CBC) and concludes that it is not. (Plaintiffs have argued that the now obsolete building codes that were in effect when A-P was enacted should now be used to properly understand the intent of A-P; they of course find definitions of certain terms used then to be more useful to their case now.)

\"In my professional opinion, for purposes of A-P compliance, there is absolutely no doubt that the SAHPC is a stand-alone building, separate from (the stadium). The fact that the SAHPC and (the stadium) are structurally independent is sufficient to determine that the SAHPC is not an addition to the stadium - under both A-P and the CBC.\" (My emphasis added.)

These are world-class experts professionally certifying UC's contentions in the case. Were there no other legal issues on the table, this writer finds these detailed and logical presentations to be thoroughly convincing. Friedman's point that structural independence of the two buildings by itself removes the SAHPC from the purview of A-P - and therefore makes it impossible for the SAHPC to be considered an addition to the stadium under A-P - is convincing.

But there are other issues afoot.

As reported yesterday, in a late attempt to preempt UC's experts' rebuttals, plaintiffs on March 6th filed a request that the court not consider any of UC's rebuttals, on two grounds:

  1. That UC's rebuttals all contain \"new evidence\" that should have been submitted on February 22nd when new expert testimony was all due, and
  1. That by including new evidence, the rebuttals went beyond the scope of the testimony the judge's order requested.

This has the aroma of a desperate attempt in the final days to preempt testimony plaintiffs know to be devastating. Still, it seems undeniable that there is new material in the rebuttals submitted by UC's experts; whether that constitutes \"new evidence\" or merely the opinions and explanations that the judge requested about what is already in the record - only the judge can decide.

The issue will surely be vociferously argued in the oral hearings scheduled for tomorrow (Friday March 14th) in Hayward, the last hearing before a ruling that is expected within 30 days.


©Copyright 2008, BearInsider.com and Scout.com. All rights reserved.

If you haven't done so already, subscribe to The Bear Insider so you can participate in this active online Cal community and get access to the members-only content from the nation-wide Scout.com network.

Bear Insider staff writers visit the Insider discussion board regularly, and are available to discuss questions you may have about this article and Cal Athletics.

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