Engaging with Forensic Engineer Expert, James Cohen

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Welcome to Engaging Experts.
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I'm your host, Noah Baler.
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And today I'm excited to welcome James Cohen to the show.
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Now, Mr.
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Cohen is an award-winning forensic engineer with over 40 years of experience.
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He's a sought-after expert witness and holds a master's of science in concrete structures from Imperial College London.
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Mr.
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Cohen, thank you so much for joining me here today on Engaging Experts.
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Thank you very much.
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I'm pleased to be able to talk with you.
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All right.
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Well, let's jump into it.
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So you've worked as an engineer since at least the late 1970s.
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How did you first become involved in expert witnessing?
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My very first job was at Grumman Aerospace, right after the lunar module.
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And I was assigned to do high what was then high-level finite element analysis with ANSIS, which at that time had just come out as a state-of-the-art package.
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For various reasons, I decided I didn't like working there.
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So then I joined Amon and Whitney in New York, who have been subsumed by other companies now.
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But they were known for the Throgsnak Bridge, the George Washington Bridge, uh, Arecibo Observatory, very high profile, high-level jobs.
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The first thing they did was stick me in their bridge group.
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And at the time, computers were not used much, and calculators were still just the basic multiply-divide stuff.
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There was no scientific calculators.
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And my role was to calculate moments of inertia for built-up bridge sections because it had to get done.
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And I spent one month doing that and went to the partner and said, I can't do this anymore.
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And so he stuck me in what was known as the special structures group.
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The first thing I did was hang off the Chrysler building at the very top.
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I don't remember exactly what my function was, and I knew I was unqualified for almost anything, but I was inspecting the masonry and brick.
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No, no idea why anymore.
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Just that I was on this swing scaffold, which would be condemned outright by OSHA today.
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Looking at the top of the from the top of the Chrysler building down to the sidewalk with nothing between me and the and the pavement.
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You were made of sterner stuff than me, my friend.
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But it it was great.
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Then I got on to another job, um, MIT Kresge Auditorium.
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They had a simple job, which was to re-roof the shell.
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It's an eighth of an inch, eighth of a sphere.
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So if you cut an orange into eighths, that's the way the roof looks.
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And they had lead shingles, and the concern was that this the shell might buckle as they took the heavy lead off.
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No one knew how to do finite element analysis, just like at Grumman.
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I was the only one.
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So they just let me loose on that.
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While the work was going on, they discovered that water had been getting through the lead shingles and percolating through the shell, the concrete shell, which only had three supports, no redundancy.
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The water would collect at the base at one of the supports, and it rotted through the concrete, corroded the steel, and it was losing its support.
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No big deal at the time.
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Got the contractor to do a repair.
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They had to take away the bad concrete, put in the good concrete.
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I was just a junior engineer, I had no say in this.
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Unfortunately, it was also my first experience with how um eager contractors are to do a good job, particularly demolition contractors.
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So they didn't just take out the good, the bad concrete, they also took out the good concrete, thereby compromising one of the three supports.
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So you're now on a three-legged stool, someone's pulled out a leg, and the building started to slowly collapse and sag.
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Then it became an emergency.
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That was my first forensic job.
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I was tasked with finding out what were the internal stresses in the shell after having been uh in service.
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I'm not sure for how long, I think it was built in the 50s.
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I could be wrong, but it had at least 20 years of concrete creep movement, adjustment, shrinkage.
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And so with ANSIS, I created um a time-lapse analysis using ACI, American Concrete Institute creep equations, to try to find out what were the stresses all over after 20 years of service, then taking out the support, and then we were putting in struts and to find out what all those loads would be.
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Today, I would give my analysis zero credibility for accuracy.
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At the time, I thought it was absolutely top-notch, and I was terrific doing that.
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Anyway, that that job finished.
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Um, the special structures group got the jobs nobody else wanted to do.
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So I hung off the Chrysler building, I rode the top of the Rosevide Island tramway to do a cable replacement, and that was the first failure job, real failure job I had for construction.
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As they, I was on Rosewood Island, and as they moved the tram back to Manhattan Island, they were using walkie-talkies to communicate, and someone neglected to tell the contractor on Rosewood Island that there was a crane driving down, I guess, 2nd Avenue, tall crane, unrelated to their job, but the tram went right into it and it got impaled by the crane.
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So we managed to get back over to Manhattan.
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And my task, because I wasn't licensed, you know, I was just an observer, no official capacity, just taking photographs I was asked to do.
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So I started taking loads of pictures of this calamity.
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Um and while I was doing that, the contractor came over to me and said, if you take one more picture, I'm going to take that camera and wrap it around your neck.
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I was hooked.
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I mean, that was the job I wanted to do.
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Hanging off the Chrysler building, doing high-level analysis, looking at these failures.
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It was a it was a real blast.
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When I left, there was no forensic engineering at the time, I referred to it that way, but it was a dirty word.
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A forensic engineer in those days was reputed or had the reputation of being a hired gun and opinion to pay.
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So what we looked at was failure analysis.
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I moved to England, joined a company called Flint and Neil.
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They did nothing but testing and code writing.
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So I was developing test protocols for various things, code writing for wind, flood, working on suspension bridge analysis beyond what any code had.
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So I was getting exposed to that idea of working outside of a code to find out what ultimate values were for strength and performance, as well as learning exactly how codes get developed, their limitations, what those factors of safety really mean when you put them in there, and how it relates or not to when something fails.
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From Flint and Neil, I joined ARIP.
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I got my master's degree, then I joined ARP.
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And at that point, I was looking at failure analysis.
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That was what I was interested in.
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They did not, they put me into their advanced analysis group, which was doing nothing but testing high-level again, ANSIS, they were developing code for ANSIS then, um, testing protocols, code writing, failure analysis, and hands-on instrumentation.
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So one of the two of the jobs that I recall particularly was writing the protocols and developing the instrumentation to put onto a nuclear, a spent nuclear fuel flask container, which would stand being fired at a concrete wall at I think it was a thousand miles an hour, something to simulate a plane crash, then being burnt in aviation fuel, the purpose of which was to see if any gas leaked, because it was going to hold plutonium gas, if I recall.
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This is back in the 80s, so I don't think I'm revealing any secrets.
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And the problem was what could you do to instrument this so you would get readings that would not get destroyed during the process?
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There were no black boxes, they had to take readings somehow.
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The other job was actually instrumenting the Hong Kong Shanghai Bank, which had just been completed.
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Um, that was also an Arab design job, fantastic building.
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But what they wanted, and they were doing it mostly at their own cost, if I recall, was to find out after all the analysis, doing this high-level stuff with typhoons hitting the building, doing dynamic analysis, which at the time was state of the art, how did it really behave?
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Did it match the analysis?
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And they felt that they got permission from the Hong Kong Shanghai Bank to instrument it.
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So my task was to develop the strain gauging and data acquisition, go there, install it, and then they would start to take the measurements.
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That really is the beginning of doing nothing but what now I refer to as forensic engineering, which I don't think is necessarily failure analysis.
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It's analyzing for possibilities, consequences, or results of failure.
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How is it working across all of these different venues in countries?
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You know, I imagine that they all have completely different codes.
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And as you said, you've been involved in writing some of them or uh giving your knowledge to try and develop them.
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Um, to what extent do you have to prepare yourself when you know you're working in Shanghai on an engineering job out there?
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How well do you have to understand the Shanghai engineering codes compared to what you're accustomed to elsewhere?
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It's it's really not a problem because, like all the work I do now, the code that you work with is the code in the contract.
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In this case, we were looking at British codes, British standards, which by that time I was pretty familiar with.
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I had been in the country for three, four years.
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I had forgotten what pounds and kilos were.
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I was working only with Newtons and Pascals, mega Pascals.
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Now I've forgotten completely what those are, and I'm just back to PSI.
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But the the knowledge base I needed was already in the contract.
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Sure.
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And so that is what I follow.
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When I do forensic engineering now, one of the key pieces of information I want, if it's available, because often these things are done unbelievably with a handshake, is what is the contract?
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What's the scope of work?
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What are the codes being invoked?
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Are they the correct codes to invoke?
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So now move working across countries wasn't an issue.
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When you're talking about these contracts, are you typically given one by the engaging attorney or the engaging side, or do you like to use your own contract and go from there?
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Um, I think that's a two-part question.
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When I uh have a client and I'm going to be doing a job, I prepare a contract for them.
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I have a standard set of terms and conditions.
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Um, I have a front part, which very briefly provides the scope of work, um, the payment base.
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Terms and conditions cover the necessaries of insurance, liability, copyright, um, payment terms in terms of 30 days, 60 days, whatever.
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Um, and that's a boilerplate.
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When I'm looking at a forensic job which I'm engaged in, I look to my client to provide me with the contracts which have been used in the job which I'm now analyzing.
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Absolutely.
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So tell me a little bit about these initial phone calls.
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Uh, you, you know, and and also tell me a little bit a bit about how they've changed throughout the decades.
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You know, you get a call from an engaging attorney to do this job.
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What are the sorts of questions?
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Because it's it's a two-way vetting process.
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You're vetting them and they're vetting you if you're the right expert, and you're you want to see if this is something that you actually want to do or are qualified to do.
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Tell me about some of the questions you like to ask and some of the questions that they typically ask you in an initial phone call for an engagement.
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The things that I want to know, there are three basic items.
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One is what is the work?
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And I try to get as much as I can from the attorney with regard to details, which they're not willing to give because it's still not a job and it's all confidential.
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But I need to know: is it within my area of knowledge?
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Um, often, very often, the attorney is not aware of what they need.
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They only can broadly describe the problem.
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And I need to figure out is this a mechanical, electrical, plumbing, geotechnical, structural, civil, architectural, um, OSHA, ADA compliant?
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What is what are the things that they are going to need?
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Is there anything there I can contribute?
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Or is it better just to give them a referral to someone else?
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That's one basic one.
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Another very basic one is where is the job located?
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Am I licensed there?
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If I'm not licensed there, how much time is there to get a license, assuming I'm not refused by the licensing board?
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And is that acceptable to the attorney?
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And the last thing I will want to know, and this usually comes in a second phone call, are the parties involved so I know I don't have a conflict of interest.
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Sure.
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Those are what I want to know.
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What the attorney usually wants to know is do I have the expertise that they need?
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And they often don't know what expertise they need.
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So that's a back and forth education process.
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My availability is key.
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Usually they don't have three years to do the job.
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Sometimes I get a job.
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Can I produce a report in 30 days?
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Occasionally two weeks.
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That's usually a no.
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Um, but there's the timeline that they need.
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Uh they want to know the rates.
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Am I pricing myself out or are they getting a bargain?
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What information might I need?
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Although that comes on later.
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There's a you know, set list of things that I think most experts would want to have.
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Almost always none of it's available, or very little.
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But they're the things that would be great.
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Uh site visit requirements.
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Can I go out?
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When can I go out?
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What else might they be asking?
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They also want to know about conflict of interest.
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Right.
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Those are the basic ones.
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Availability, expertise, conflict of interest.
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For me, it's licensing, scope, and uh conflict of interest.
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Have these calls changed in any significant way over the decades, or engagements these days different than engagements back in the 70s and 80s?
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In terms of the conversation that we've just had, the only real change is my knowledge that these are the things I need to know.
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Rather than finding out, I've become much more fluid in the questions, much more assertive in what I have to know before I say yes or no to a job.
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Uh, the biggest change outs that has happened is, and maybe it's because my rates have gone up, um, is that budget and budget estimates are something which is now a norm.
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I would say 10 years ago, I was almost never asked about how much it was going to cost.
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It was very rare.
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Or whatever it was, that was acceptable.
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Um, I mean, clearly, if somebody decided to take a client to the cleaners, there'd be a problem.
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But assuming that one is acting honorably and within a normal scope, they weren't concerned with how much it was going to be.
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Now, even if I just go to a site visit, I'm often asked, how much will that be?
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That's I'd say the biggest change that's happened.
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When you when you talk about things like site visits and travel, is that something that you bill for in a different way?
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Do you have travel rates?
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I find that experts have their, it's each one seems to have their own favorite way of doing it.
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My particular approach is that if I'm spending my time devoted to a project, I bill for it.
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I don't really care what I'm doing.
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If I'm traveling on the site, twiddling my thumbs in a room waiting to get deposed, it's still devoted to that job.
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For travel, I do put in um a personal limit that if I'm doing nothing but traveling.
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So if I have to go to Florida or Texas, I simply won't bill more than eight hours.
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Gotcha.
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Even if it takes me, you know, for some reason, 20 hours to get there.
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Well, 20 hours are getting to two days.
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But if it's more than one working day, I'll only build the one working day.
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If, on the other hand, I'm expected to be at site at six in the morning, and I've got to get up at four or three and travel two hours to get there, then it goes from six to four, and then it takes me another two to three hours to come back.
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I build all that time.
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I other experts have other protocols that they follow.
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Absolutely.
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One of the things you had mentioned is kind of a litany of different trades that might be involved in various actions.
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Um, to what extent, if any, do you ever work with other experts that are part of the same engagement?
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Do you ever collaborate on pieces of a report or on a site visit or on are there other opportunities to collaborate with other experts during an action, or are you largely segregated?
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There are come to mind three different ways that happens.
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One, the client, who may be an attorney, but it could also be an insurance company, a contractor, an adjuster, engages experts on their own to do different things.
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Um, that's not unusual.
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Sometimes I'm provided with the information that those experts are producing.
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Sometimes we have a conversation, although that's much rarer.
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Um and that's down to the client how they want us to interact, if at all.
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One job I had an opposing expert, they just wanted to see which opinion they wanted.
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So they had two working on the same job for the same thing.
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Another method is that I engage expertise that I don't have as a subconsultant.
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Typically, that'll be mechanical electrical plumbing.
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I don't usually go beyond that except for cost estimating.
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Um, cost estimating is a fuzzy area.
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Yes, I do cost estimating.
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No, I'm not a cost estimator.
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So I am happy to be engaged to assess a cost estimate for reasonableness, but I would not want to be put forward as an expert in cost estimating.
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I leave that to the attorney, and so I'll then engage a cost estimator.
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And the third way is that there is a team which is put together and we all work collaboratively.
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It depends on the job, um, depends on the client.
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Absolutely.
00:20:29.680 --> 00:20:39.680
When you subcontract out to another trade, is that something you have to get approved through the end client or through the engaging attorney, or is that something that you can just do?
00:20:40.799 --> 00:20:44.319
I will get approval.
00:20:44.319 --> 00:20:48.559
Um, I've not ever tested if I can just do it.
00:20:48.559 --> 00:21:00.000
I want the clients to know who is working on it, what their fees are, how we'll interact, who takes responsibility for the opinion.
00:21:00.000 --> 00:21:18.559
Because sometimes if I just need outside expertise in a topic, just like having a drawing that I have to sign and seal, they are doing the work under my direction, and I assume their I assume the data and I form an opinion.
00:21:18.559 --> 00:21:25.119
On the other hand, if I need someone to provide an opinion, then that is what they will do.
00:21:25.119 --> 00:21:31.119
And we produce separate reports for the same job, but on different subject matter.
00:21:31.119 --> 00:21:38.559
So uh MEP comes to mind immediately because that's that's the most common one.
00:21:38.559 --> 00:21:45.839
Is that there are issues with the HVAC HVAC system, there's issues with the sewage.
00:21:45.839 --> 00:21:47.359
I don't do that at all.
00:21:47.359 --> 00:21:51.920
I would not even attempt to represent somebody else's opinion on that.
00:21:51.920 --> 00:21:59.759
So they provide their own report under under my direction to the extent that I'm responsible for payment and making sure.
00:21:59.759 --> 00:22:08.880
They get the work done on time, that they don't have a conflict of interest, that they are available, that they are licensed, just like I would have to do for myself.
00:22:08.880 --> 00:22:14.000
And I produce my report, which be is a separate standalone opinion.
00:22:14.000 --> 00:22:15.519
There is overlap.
00:22:15.519 --> 00:22:26.079
So if I'm looking at water damage to a structure and it's related to the plumbing or the HVAC, yes, there's an interaction there.
00:22:26.079 --> 00:22:31.359
But there is still that separation of discipline.
00:22:31.359 --> 00:22:38.960
Very sort of um has to comply with engineering code of ethics, legal licensing issues.
00:22:38.960 --> 00:22:44.880
So I do not do something which I am not sufficiently familiar and knowledgeable about.
00:22:44.880 --> 00:22:47.200
I always get somebody else for that.
00:22:47.680 --> 00:22:53.759
Speaking of your opinions, you've been developing opinions for quite a long time now.
00:22:53.759 --> 00:22:59.039
How do you keep track of all of the things that you've said and how you said it?
00:22:59.039 --> 00:23:08.480
If you change your mind about something or perhaps a methodology has changed uh and then you're attacked for it in court, how do you deal with those sorts of issues?
00:23:08.960 --> 00:23:12.000
Well, I've never been attacked in court for prior opinions.
00:23:12.240 --> 00:23:13.039
Oh, okay.
00:23:13.920 --> 00:23:21.519
Uh I don't know to what extent the attorneys or adjusters are doing historical research.
00:23:21.519 --> 00:23:32.640
I know that they do because at least one attorney has engaged me based on a deposition that she found I had done in years past and she liked it.
00:23:32.640 --> 00:23:36.720
Uh but how do I keep track of it?
00:23:36.720 --> 00:23:38.480
Is a simple answer.
00:23:38.480 --> 00:23:39.359
I don't.
00:23:39.359 --> 00:23:42.880
My approach is I tell the truth.
00:23:42.880 --> 00:23:44.400
I stick to the truth.
00:23:44.400 --> 00:23:49.839
If I do that, if I'm always honest, I don't have to remember anything I said.
00:23:49.839 --> 00:24:00.640
And I always have in all my reports and work a caveat that if I'm given new information, I have the right to change my opinion or to modify it, which has happened.
00:24:00.640 --> 00:24:02.720
I'm suddenly presented with something new.
00:24:02.720 --> 00:24:06.880
It's happened in court once or twice, which I was never given.
00:24:06.880 --> 00:24:09.519
And yes, I haven't seen that.
00:24:09.519 --> 00:24:11.200
Yes, it's important.
00:24:11.200 --> 00:24:14.559
And yes, it changes my opinion on the spot.
00:24:14.559 --> 00:24:21.519
So when there are new techniques, uh, new codes, whatever, yeah, it's going to change.
00:24:21.519 --> 00:24:30.319
When it gets to the forensic engineering work, it's very important to use the codes and the standards which are applicable to the job.
00:24:30.319 --> 00:24:31.920
Those may be historical.
00:24:31.920 --> 00:24:34.480
So, no, nothing really is going to change there.
00:24:34.480 --> 00:24:38.799
But it has to do with current state-of-the-art knowledge.
00:24:38.799 --> 00:24:47.839
Uh, one side may say, well, we now know that this will deteriorate concrete, or this is going to happen in the windstorm.
00:24:47.839 --> 00:24:55.440
And the other side, which, and it might be me on either side, because it's they're all valid arguments, will say, but we didn't have that then.
00:24:55.440 --> 00:24:58.720
That's not relevant to the fault.
00:24:58.720 --> 00:25:03.759
It may be relevant to the failure, cause of failure, but it's not a cause of fault.
00:25:03.759 --> 00:25:07.599
And it's important to distinguish between those.
00:25:08.079 --> 00:25:11.039
Walk me through a typical deposition for you.
00:25:11.039 --> 00:25:13.359
What are the sorts of questions that you get asked?
00:25:13.359 --> 00:25:15.279
What sort of a venue are you in?
00:25:15.279 --> 00:25:18.240
Tell me a little bit about uh depositions.
00:25:18.559 --> 00:25:21.279
Well, those have evolved for me over time.
00:25:21.279 --> 00:25:44.960
Um, primarily when I started my initial depositions, the focus of the first could have been even half an hour of questions was to destroy my credibility and my um qualification as an expert because my my CV would have been lighter, my experience was lighter, my background was lighter.
00:25:44.960 --> 00:25:48.960
Now they look through my CV, they ask questions.
00:25:48.960 --> 00:25:51.359
I'm not exactly sure why anymore.
00:25:51.359 --> 00:25:56.000
Um, and that challenge to credibility usually doesn't arise.
00:25:56.000 --> 00:26:01.519
There's the advantage of having been working for 40, 45 years versus working for 10.
00:26:01.519 --> 00:26:10.720
Uh, so the the first, destroying one's credibility as an expert and as an individual, doesn't happen to me anymore.
00:26:10.720 --> 00:26:12.079
It did at the beginning.
00:26:12.079 --> 00:26:14.720
Quite honestly, I really do enjoy that part.
00:26:14.720 --> 00:26:15.759
I miss it.
00:26:15.759 --> 00:26:25.519
Um now they do that, then they will go through what did I do for the project?
00:26:25.519 --> 00:26:27.119
How was I engaged?
00:26:27.119 --> 00:26:28.640
What was my scope?
00:26:28.640 --> 00:26:31.920
Very much the same things that we're talking about now.
00:26:31.920 --> 00:26:36.240
Uh was I limited, that often comes up.
00:26:36.240 --> 00:26:38.880
Was I limited in what I was allowed to do?
00:26:38.880 --> 00:26:40.880
And the answer is always yes.
00:26:40.880 --> 00:26:44.079
I'm limited in time, I'm limited in expense.
00:26:44.079 --> 00:26:50.799
Almost every forensic job can turn into a PhD thesis given an unlimited time and money.
00:26:50.799 --> 00:26:55.680
And I've seen that happen with some jobs where you know the other side goes totally bananas.
00:26:55.680 --> 00:27:01.759
And for whatever reason, the client their client is either happy or doesn't know or doesn't care.
00:27:01.759 --> 00:27:07.119
But yes, there are always limitations on time scope, not quality.
00:27:07.119 --> 00:27:12.240
That pyramid, um, you can never reduce the quality.
00:27:12.240 --> 00:27:19.279
Uh, the output should be as good as it can be, given the limitations on time and scope.
00:27:19.279 --> 00:27:22.000
They'll go through the questions on that.
00:27:22.000 --> 00:27:25.519
Then they'll get into a report, if there is a report.
00:27:25.519 --> 00:27:29.599
Some states don't require a report, uh, it varies.
00:27:29.599 --> 00:27:33.599
And they will then go through in a very fine way.
00:27:33.599 --> 00:27:42.319
They obviously had technical consulting going on behind the scenes, and I get the very detailed technical questions.
00:27:42.319 --> 00:27:55.839
Occasionally, um, I have found that I I made an error, and the most important thing to do is to simply confess, yeah, I got that wrong.
00:27:55.839 --> 00:27:57.920
Does it make a difference?
00:27:57.920 --> 00:27:59.759
Hopefully not.
00:27:59.759 --> 00:28:12.160
Uh I've yet to, I don't remember a time when there was an something which happened which I had missed, which had a material effect.
00:28:12.160 --> 00:28:16.720
There was one project, uh, the crane collapse in New York.
00:28:16.720 --> 00:28:19.440
There was a huge crane collapse, killed seven people.
00:28:19.440 --> 00:28:21.119
It was in 2008.
00:28:21.119 --> 00:28:24.720
It's known as the 51st Street crane collapse.
00:28:24.720 --> 00:28:33.200
And I was with ARP, and we were engaged by the New York City Department of Buildings, given a huge, almost unlimited budget.
00:28:33.200 --> 00:28:38.240
And we had six months to do anything we needed to get a report done.
00:28:38.240 --> 00:28:41.680
And we had certain questions they wanted to have answered.
00:28:41.680 --> 00:28:52.559
When it came to the trial, which was a murder trial due to the deaths, and the client at that point was the New York County District Attorney.
00:28:52.559 --> 00:29:07.839
The opposing expert came up with a hypothesis of what may have resulted in a failure, not proof that it happened, but simply that there was a possibility, which in a manslaughter trial is all you need.
00:29:07.839 --> 00:29:19.119
I forget what the legal phrase is.
00:29:19.119 --> 00:29:21.599
We've we've heard it in a lot of movies, though.
00:29:21.599 --> 00:29:26.240
And they presented something which we had not looked at.
00:29:26.240 --> 00:29:44.079
And I sat there for a bit in the witness stand, and I decided that that is possible, but the failure mechanism that they were referring to was not possible.
00:29:44.079 --> 00:29:48.799
Now, that could have just been a I say you say situation.
00:29:48.799 --> 00:30:09.119
Happily, I had created some props to demonstrate certain principles which I thought might be difficult to do just by words, and one of them included a cylinder, like this coffee cup, and on the table, I was also provided with paper towels.
00:30:09.119 --> 00:30:18.559
And the issue was that something going around this cylinder, a collar, could have fractured on the far edge.
00:30:18.559 --> 00:30:33.920
And physically, all things being perfect in a perfect world, you have some friction as it grips around, as the collar grips around the cylinder.
00:30:33.920 --> 00:30:38.799
That far end should not be the highest stress point.
00:30:38.799 --> 00:30:44.000
The highest stress point is going to be closer to the two and ten o'clock position.
00:30:44.000 --> 00:30:50.480
And having no idea what would happen, so this was a big risk, but it was a real question.
00:30:50.480 --> 00:30:57.200
I took the paper towel, I wrapped it around the cylinder, and I pulled, and it broke at the 10 and 2 position.
00:30:57.200 --> 00:31:05.359
Um, so I was able to demonstrate the opinion that I was providing, so there was physical evidence for it.
00:31:06.240 --> 00:31:10.480
Do you use a lot of do you use a lot of demonstratives like that?
00:31:11.519 --> 00:31:12.799
When it's possible.
00:31:12.799 --> 00:31:30.319
I was testifying about an alleged um design defect in a thousand-foot-high telecommunications tower related to a leg connection.
00:31:30.319 --> 00:31:31.839
That was the focus.
00:31:31.839 --> 00:31:42.640
They were the plaintiff was claiming that it was unsafe because the leg was going to fail in a certain way, and we were claiming that no, it's safe the way it was designed.
00:31:42.640 --> 00:31:54.720
And this was in Missouri or Kansas, and I got to the trial, um, which is a long story in itself, getting there.
00:31:54.720 --> 00:32:00.960
And I was in the witness stand and I was just starting a technical explanation.
00:32:00.960 --> 00:32:04.559
And I looked at the jury, it was a jury trial.
00:32:04.559 --> 00:32:07.920
They were all local people, which is proper.
00:32:07.920 --> 00:32:11.759
They were farmers, tradesmen, nobody technical.
00:32:11.759 --> 00:32:19.359
And I started talking about compression, tension, shear, torsion, and they looked at me, I could see like that their eyes glazing over.
00:32:19.359 --> 00:32:25.279
The court had provided me with styrofoam cups for water.
00:32:25.279 --> 00:32:31.279
So I took the cups and I started demonstrating what a tension failure looks like.
00:32:31.279 --> 00:32:33.440
Just take the cups and separate them.
00:32:33.440 --> 00:32:37.920
Torsion failure, shear failure, slide them against each other.
00:32:37.920 --> 00:32:45.680
And then I think what really got their attention is I took a cup, I put it upside down on the table, and I said, and this is a compression failure.
00:32:45.680 --> 00:32:53.039
And I went bam! And they also you know, and they paid attention for the rest of my testimony.
00:32:53.039 --> 00:32:54.799
That was unplanned.
00:32:54.799 --> 00:32:56.960
It was, you know, ad ad lib.
00:32:56.960 --> 00:33:04.960
But it was it was a lesson in my looking at who's making the decisions in the trial.
00:33:04.960 --> 00:33:08.640
Are they understanding what I am saying?
00:33:08.640 --> 00:33:17.440
And if I get the sense they do not understand my words, I have to change my words and my method of approach.
00:33:17.440 --> 00:33:21.119
That is something I've kept with me through all trials.
00:33:21.119 --> 00:33:26.799
If it's a judge trial, a bench trial, I look at the judge when I answer the questions.
00:33:26.799 --> 00:33:31.759
I want to know that he understands or she understands what I'm saying.
00:33:31.759 --> 00:33:37.519
If it's a jury trial, I'm looking at the jury, not the attorney asking me the questions.
00:33:37.519 --> 00:33:42.720
I have to look at him to understand the questions, so I use both lips and sound, you know, for that.
00:33:42.720 --> 00:33:43.519
Sure.
00:33:43.519 --> 00:33:48.000
Um, and I don't want anyone to think I'm ignoring the other counsel.
00:33:48.000 --> 00:33:59.440
But the the people I'm talking to, the testimony is not for the attorney, it's for the decider, the ones who are going to be deciding the decision.
00:33:59.440 --> 00:34:04.640
So all answers get addressed to them in a language that they understand.
00:34:04.640 --> 00:34:07.920
I try to avoid being technical.
00:34:07.920 --> 00:34:12.079
So if you can't explain something to a three-year-old and you don't understand it.
00:34:12.639 --> 00:34:16.880
Does that does that also uh go with uh your report writing?
00:34:16.880 --> 00:34:23.280
Do you make sure that uh an a lay person is able to parse your writings for your reports?
00:34:23.679 --> 00:34:24.480
Absolutely.
00:34:24.480 --> 00:34:29.199
If there are um, my favorite example is the term efflorescence.
00:34:29.199 --> 00:34:34.000
Now, every structural out engineer out there knows what efflorescence is.
00:34:34.000 --> 00:34:39.760
Pick someone at the shopping center, ask them, you know what efflorescence is, and they won't have a clue.
00:34:39.760 --> 00:34:46.559
So it may sound very nice and high-minded, but if if that's the term being used, it has to get completely defined.
00:34:46.559 --> 00:34:52.320
Usually I'll shorten it to white deposits, but I need to explain how they occur.
00:34:52.320 --> 00:35:03.519
In a report, I will define efflorescence, and then I'll use the term because it's a shorthand term, like most technical terms are, for what may be a very long explanation.
00:35:04.000 --> 00:35:04.559
Absolutely.
00:35:04.960 --> 00:35:08.480
I always try to gear the report to the layman.
00:35:09.519 --> 00:35:13.280
So we were talking about depositions and trials.
00:35:13.280 --> 00:35:28.000
One thing I like to ask all of my guests is if they have any pre-deposition or pretrial routine that helps them get into the right headspace and prepared for what could be uh a difficult or long day.
00:35:28.000 --> 00:35:32.800
Um, some people you know like to cram, some people like to do yoga, drink coffee.
00:35:32.800 --> 00:35:36.559
Do you have any routine that works for you that just gets you ready to go?
00:35:37.760 --> 00:35:42.800
Um, a good night's rest and making sure there's a supply of coffee.
00:35:42.800 --> 00:35:44.960
That really is it.
00:35:44.960 --> 00:36:00.719
I again, when I started, my very first testimony was at an arbitration involving a deteriorated wearing course, concrete wearing course at a hospital, which was over the emergency surgery area.
00:36:00.719 --> 00:36:03.119
So they were really concerned about this.
00:36:03.119 --> 00:36:09.679
Um, in order to get prepared, I created a loose leaf.
00:36:09.679 --> 00:36:12.880
There's yeah, there were no, we were not using laptops at those days.
00:36:12.880 --> 00:36:13.920
No one owned a laptop.
00:36:13.920 --> 00:36:16.079
I don't know if they had been invented yet.
00:36:16.079 --> 00:36:21.920
And in it, with all the dividers, a huge loose leaf, I thought it was like a three-inch binder.
00:36:21.920 --> 00:36:26.320
I put all the codes, standards, reports, everything I needed there.
00:36:26.320 --> 00:36:28.800
I nearly memorized the whole thing.
00:36:28.800 --> 00:36:30.800
And when I got there, this was also my first.
00:36:30.800 --> 00:36:33.360
So the credibility issue was major.
00:36:33.360 --> 00:36:36.400
And I was testifying.
00:36:36.400 --> 00:36:45.760
Um, my opposing expert was an expert, a seasoned expert in the subject matter.
00:36:45.760 --> 00:36:53.760
I was not, I had just done the work and I was very convinced of where I was, and I I had all the standards.
00:36:53.760 --> 00:36:56.800
I'd like I'm glad to say my side prevailed.
00:36:56.800 --> 00:36:59.199
I think we were correct, we were right.
00:36:59.199 --> 00:37:02.079
Um, but actually, there's several lessons there.
00:37:02.079 --> 00:37:04.239
One is do know the material.
00:37:04.239 --> 00:37:07.599
You know, winging it is not the way to approach anything.
00:37:07.840 --> 00:37:08.320
Sure.
00:37:08.639 --> 00:37:10.960
And don't be a hired gun.
00:37:10.960 --> 00:37:13.199
Admit when something's there.
00:37:13.199 --> 00:37:20.159
The opposing expert, if I recall correctly, did not admit things which were factual.
00:37:20.159 --> 00:37:24.320
And in my loose leaf, I had proof it was there.
00:37:24.320 --> 00:37:33.440
So the ASC, the ASTM standards for a wearing surface on a deck were very, very clear.
00:37:33.440 --> 00:37:38.320
The drawings of how this was constructed were very clear.
00:37:38.320 --> 00:37:41.599
Um, and he just went into denial on it.
00:37:41.599 --> 00:37:48.320
He was working, the phrase I I now like to use, he was working too hard for his client.
00:37:48.320 --> 00:37:53.360
Um that's the the best way I can do it.
00:37:53.679 --> 00:37:54.639
Absolutely.
00:37:54.639 --> 00:38:04.320
I mean, that that's an expert witness, their duty is to the neutral truth, not to, you know, the uh the end client or the attorney or anyone else.
00:38:04.320 --> 00:38:05.679
It's just to tell the truth.
00:38:05.679 --> 00:38:08.559
So that is absolutely sage advice.
00:38:08.559 --> 00:38:14.000
Um what tell let's let's back up to a couple just very general questions.
00:38:14.000 --> 00:38:21.119
Tell me a little bit about what makes for a solid attorney expert relationship.
00:38:21.119 --> 00:38:26.079
How do you get that started and how do you maintain that momentum throughout the action?
00:38:26.079 --> 00:38:28.960
And part two to that question is the reverse.
00:38:28.960 --> 00:38:45.360
What are some red flags that kind of warn you that this might not go the way that you're hoping uh in my proposal, and this should be in all expert proposals, I have a statement.
00:38:46.159 --> 00:38:54.400
I'm not going to be able to quote it, but it's to the effect that my opinion is my own and is not reflected by the client.
00:38:54.400 --> 00:38:58.000
And I make it clear that my opinion will be my own.
00:38:58.000 --> 00:39:01.119
It's not intended to help them.
00:39:01.119 --> 00:39:07.760
I will phrase my opinion in a way which is most beneficial.
00:39:07.760 --> 00:39:14.400
And my best example of that is the glass, eight-ounce glass, four ounces of liquid.
00:39:14.400 --> 00:39:19.440
The usual way people put it is it's half empty or it's half full.
00:39:19.440 --> 00:39:22.400
There's also there's too much glass.
00:39:22.400 --> 00:39:25.599
There's also there wasn't enough liquid.
00:39:25.599 --> 00:39:28.320
There's also they got the order wrong.
00:39:28.320 --> 00:39:35.119
The other is they ran out of the correct glasses, so they had to get a larger one to accommodate the order.
00:39:35.119 --> 00:39:39.599
The other is the menu doesn't say anything about how much liquid you're gonna get.
00:39:39.599 --> 00:39:48.000
You know, as I put it to one person the other day, if you have an eight-ounce glass and you order some whiskey at a bar, they're not filling the glass.
00:39:48.000 --> 00:39:49.760
They're not even gonna half-fill it.
00:39:49.760 --> 00:39:52.320
So are you gonna complain I have a half-empty glass?
00:39:52.320 --> 00:39:55.280
No, no one in their right mind would expect you to fill it.
00:39:55.280 --> 00:40:01.840
So there are all these ways of saying the same thing, exactly the same thing.
00:40:01.840 --> 00:40:07.599
The way it's said affects is affected by who the client is.
00:40:07.599 --> 00:40:10.320
The facts don't change.
00:40:10.320 --> 00:40:17.760
And the interpretation of the facts has to be consistent, whether it helps or hurts.
00:40:17.760 --> 00:40:25.840
I had one job where the um it had to do with a a severe injury from somebody falling off a telecom tower.
00:40:25.840 --> 00:40:28.079
I used to do a lot of telecom towers.
00:40:28.079 --> 00:40:39.039
And what I didn't know is that the attorney, who is a personal injury attorney, had engaged another expert on exactly the same thing.
00:40:39.039 --> 00:40:41.280
We each gave our reports.
00:40:41.280 --> 00:40:44.239
I gave exactly the facts, my interpretation.
00:40:44.239 --> 00:40:47.039
It wasn't as beneficial as he would have liked.
00:40:47.039 --> 00:40:51.519
And he told me he's going to use the other expert, you know, because it's a better opinion.
00:40:51.519 --> 00:40:57.440
I heard from him a couple of months later that he got rid of him because the guy had no credibility.
00:40:57.440 --> 00:41:02.880
Whereas my approach was highly credible.
00:41:02.880 --> 00:41:11.519
So, no, I didn't say exactly what he wanted, but I was consistent and I could stand behind my opinion without any doubt.
00:41:12.559 --> 00:41:13.360
Absolutely.
00:41:13.360 --> 00:41:19.760
Before we wrap up, do you have any last advice for expert witness or attorneys working with experts?
00:41:21.599 --> 00:41:24.239
Uh stick to the truth.
00:41:24.239 --> 00:41:27.039
Um, an attorney is an advocate.
00:41:27.039 --> 00:41:31.840
They are there, in my opinion, to do the best for their client.
00:41:31.840 --> 00:41:40.000
The expert's opinion work is to provide the best information, correct information.
00:41:40.000 --> 00:41:46.239
So the attorney can do the best for their client given what really happened.
00:41:46.239 --> 00:41:54.400
If it's a personal injury versus a construction defect, it it's still the same.
00:41:54.400 --> 00:42:03.760
It may not be the absolute best thing that the attorney was hoping for, because yes, their client did contribute to their injury.
00:42:03.760 --> 00:42:05.920
They shouldn't have been there.
00:42:05.920 --> 00:42:11.440
But with all the other parties involved, should it have happened anyway?
00:42:11.440 --> 00:42:13.840
How many contributors were there?
00:42:13.840 --> 00:42:24.719
Usually there are multiple in a construction case, there are many subcontractors, many consultants, many designers, could be several inspectors.
00:42:24.719 --> 00:42:32.559
There are typically more than one, more than two, who contributed to the problem.
00:42:32.559 --> 00:42:34.639
Should they pay?
00:42:34.639 --> 00:42:36.400
Should they be held culpable?
00:42:36.400 --> 00:42:37.840
I have no idea.
00:42:37.840 --> 00:42:39.519
That's not my job.
00:42:39.519 --> 00:42:51.840
My job is to point out and to give the attorney the information on where do the faults lie, how much of the faults contributed to whatever it is that's being claimed.
00:42:51.840 --> 00:42:56.480
Not to cover it up, not to say their client didn't do anything.
00:42:56.480 --> 00:43:02.559
They have to have the correct information because if I don't do that, the other side definitely will.
00:43:02.559 --> 00:43:08.480
And if I don't do it for our own client, I will lose all credibility in the opinion I provide.
00:43:08.480 --> 00:43:12.559
And in my client's point of view, they lose the case.
00:43:12.559 --> 00:43:14.719
For me, I still get paid.
00:43:14.719 --> 00:43:20.800
Yeah, so it for my, you know, I'm I'm fine, but that's not the attitude to take.
00:43:20.800 --> 00:43:29.519
I like to think that the work I do serves the cause of justice, not the cause of my bank account.
00:43:29.519 --> 00:43:32.400
The bank account will take care of itself.
00:43:32.400 --> 00:43:37.280
I'm there to provide, as I said, the best honest information.
00:43:37.280 --> 00:43:44.880
If it's simply an insurance claim and it's a defense attorney, they want to know what is their exposure.
00:43:44.880 --> 00:43:47.679
They don't want to know how they can get out of it.
00:43:47.679 --> 00:43:53.920
They want to know how much should they reasonably pay because they almost always take care of it through mediation.
00:43:53.920 --> 00:43:56.880
They want to know how high they can go, how low can they go.
00:43:56.880 --> 00:43:59.760
If it's an injury, what is the contribution?
00:44:01.920 --> 00:44:02.880
Absolutely.
00:44:02.880 --> 00:44:03.440
Mr.
00:44:03.440 --> 00:44:06.079
Cohen, thank you so much for joining me here today.
00:44:06.320 --> 00:44:07.199
It was a pleasure.
00:44:07.199 --> 00:44:08.000
Thank you.
00:44:08.239 --> 00:44:13.519
And thank you as always to our listeners for joining us for another edition of Engaging Experts.
00:44:13.519 --> 00:44:14.320
Cheers.