WEST BROADWAY ENHANCEMENT PROJECT
19th & Rollandet Street Project
Burns Addition Plat
Disclaimer Letter
Defendants knew that the project was incomplete, they caused other Engineers to approve same. (Supplement, Exhibit M, West Broadway Enhancement)
A review of said Exhibit (which I obtained by discovery only after suit was filed) shows: (a) dates on the drawings at times when I was City Engineer (June 10, 1996) and City Design Engineer (July 3, 1996), (b) that the drawings were, in fact, incomplete even as demands were being made upon me to sign and seal; (c) that certain of the drawing pages had been dated July 25, 1996, which is 13 days after I was forced out of my job; and (d) all plans were signed and stamped by CH2M Hill per David Bennion on July 26, 1996, without disclosure to me.
REQUEST NO.20: Admit that subsequent March 18, 1996; you were never asked by Mr. Steve Anderson to affix your engineering seal to any plans, specifications, drawings, reports or other documents other that the documents associated with the West Broadway Enhancement Project.
ANSWER NO. 20: DENIED, See previous Answer and Supplement, Exhibit M.
The demands of Mr. Anderson regarding the West Broadway Enhancement Project were made on an on-going, relentless and continuing basis even after March 18, 1996. In addition, the 19th and Rollandet project (Burns Addition) was assigned to me to design, but Steve Anderson — a non-Engineer — took it away and designed it his way. He was aided in doing so by John Smith, a licensed surveyor, in contravention of law.
I have also provided a Project Progression Chart for 1996 (See Supplement, Exhibit N) which identifies the projects that the City Engineering Department surveyed, designed, drew,
PLAINTIFF’S ANSWERS TO DEFENDANT’S REQUESTS FOR ADMISSIONS
