CBC Walters v Dobre Textiles Engineering Expert Witness MEMO

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California Beauty College


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Date Sample number 1-Aug 7-Aug 20-Aug 28-Aug 5-Sep 13-Sep 20-Sep 29-Sep 3-Oct 10-Oct 27-Oct 5-Nov 12-Nov 26-Nov 1-Dec 8-Dec 15-Dec 21-Dec 29-Dec 4-Jan 11-Jan 19-Jan 25-Jan 31-Jan 7-Feb 14-Feb 22-Feb 1-Mar 8-Mar 18-Mar 31-Mar 5-Apr 10-Apr 19-Apr 25-Apr 1-May 9-May 18-May 25-May 1-Jun 12-Jun 25-Jun 2-Jul 16-Jul 24-Jul 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 Sample value (mg/L) 0.094 0.08 0.112 0.119 0.11 0.115 0.121 0.077 0.094 0.088 0.093 0.117 0.115 0.121 0.077 0.094 0.088 0.093 0.117 0.084 0.084 0.101 0.082 0.094 0.113 0.127 0.123 0.096 0.088 0.092 0.088 0.081 0.088 0.081 0.076 0.081 0.11 0.102 0.1 0.072 0.071 0.079 0.092 0.123 0.106 ME MORANDUM TO: Honorable Waya Thlocco CC: William Buckley, Clerk of the Court Maria Morgan, Plaintiffs’ Counsel Juan Gomez, Defendant’s Counsel FROM: Mariaelena John, Engineering Expert Witness DATE: July 23, 2021 RE: Daylen v Blat Company, Engineering Expert Witness Question Presented Did the wiring in the Blat Company NueAir air purifier fabrication fail to meet industry safety standard leading to fires in customers’ properties, making the manufacturer liable for customers’ fire losses? In this section, you will provide a complete, concise, and grammatically correct statement of the legal question. Brief Answer Blat Company is liable for customers' fire damage losses, as the company's NueAir product has been shown to likely be out of compliance with industry safety standards. In this section, you will state your finding on the answer to the legal question completely, concisely. and grammatically correct. Facts In this section, you will present 1) the context of the case; 2) the data you were provided and its meaning to the case; and 3) how what you were provided will enable you to determine your recommendation. Organize this to read in a way that the readers will understand the issue at the heart of the case and the importance of the input information in addressing the question arising from the issue. Remember the readers are likely not statisticians, engineers or computer scientists. Discussion In this section, you will provide a plain language, the logic of your approach to addressing the case (why does this approach allow you to make a determination on this case?), what you know from your analysis of the data and your finding. End with a statement of your recommended judgement on the case. DO NOT walk the jury through your math, they will not understand it. Conclusion 1 In this section, you will provide a synthesis of the entire memorandum, being sure to include the answer to the legal question. 2 Appendix A – Statistical Calculations Include in this section a typewritten copy of your calculations. Organize them in a way that the steps you took are clear for the reader to see. Start with what you know and how you will approach the problem. End with the mathematical answer, what it means statistically, and what it means for the case. 3 Dobre Textiles, Inc. has a textile production facility located in Baila, FL. It lies along a river that is used for drinking water for the surrounding town and is therefore tested regularly for chemical contaminants according to EPA standards. There is also a recreational beachfront with swimming and boating located ½ mile downstream of the plant. Over the last ten years, the incidence of a skin reaction called allergic dermatitis has increased dramatically for swimmers at the recreational beachfront. Due to public concern, the local water utility began checking for elevated levels of several pollutants that cause skin reactions as well as monitoring discharge sources and possibilities for illegal dumping in the river. Careful surveillance and testing by other consultants have determined there are no chemicals being du . Additionally, over the course of a year, they collected 45 water samples from a location adjacent to the output of the Dobre industrial plant, the closest upstream industrial discharge site. These samples were tested and elevated levels of chromium were identified. The EPA's Maximum Contaminant Level (MCL) for chromium is 0.1 mg/L. With the knowledge that chromium pollution can result from fabric dyeing within textile factories, a group of concerned citizens has brought a class-action lawsuit against ABC Textiles, Inc. The class claims that the company's textile mill has contributed to elevated chromium levels in the river, causing skin reactions at the local beach. The class action lawsuit is Walters v. Dobre Textiles. Due to the significance of this litigation, the Judge involved with the case, The Honorable Olena Leonova, has brought you in as an expert witness, independent of either side of the litigation, to give your expert opinion on the chromium exceedance. At your request, she is providing you with data from the 45 samples the water utility collected. She has requested that you analyze whether the chromium levels in the river exceed the EPA standard. Because there are no other outputs to the river within 5 miles, it can be presumed that the textile plant is the most likely source of elevated chromium levels, if they are present in the river. The Judge is requiring that you complete your work with a high level of confidence, therefore you have suggested using a significance level of .01 (i.e., 99% confidence). You are to provide the jury with which side of the litigation you would support and why in a written document that makes the determination clear and believable to them. The document you are to provide is to follow the court's template and their Legal memorandum guide. You will also copy the document to Art Tatum, Clerk of the Courts, Mykola Boiko, Plaintiffs' Counsel, and Janelle Gibson, Defendant's Counsel. Remember that you are only an expert on statistical analysis of the exceedance of chromium in the river, not on whether elevated chromium can cause allergic dermatitis. Be careful not to overstate your findings - don't make any assumptions that aren't very clearly suggested by the data.Review and evaluate the problem presented evaluate the problem: what you know, the significance of what you know to the problem, and what information you have that can be used in a statistical problem. Determine the appropriate hypothesis test to use, given what input you have, the problem, and the statistical tools you have learned. Additionally, determine the appropriate use of the null and alternative hypotheses for the problem. Sketch a diagram of the problem as it may help you think through how to use the hypothesis test. (This sketch is for your thinking and should not be included in the final document.) You can use the template from the preliminary assignment if it helps you think through the problem. Complete the calculation - Complete the statistical analysis of the problem. Be clear that you understand all of the processes you have completed to get your answer, you will have to document it. You will need to know what you figure out from the analysis to complete the work. Develop your document for the assigned audience and purpose - Be sure that you present a plain language, logical presentation of your process so the jury (a naive audience) can understand and believe what you are sharing. As you will have templates to use with many professional documents you will create, this assignment has a format that you must follow- Memorandum Template. This format includes appearance and content. See the Exemplar for a visual guide. Memorandum Header - This section of the document provides the information a reader needs to know to determine if they need to read the rest of the document. It must be consistent in layout and format so that it is easy to read. This section is graded on your ability to follow directions. TO - The person you have been asked to address the memorandum to. Follow the exemplar, on paper a judge's title is 'Honorable'. Why? This section and the CC section may be addressed to one or more person(s). The amount of information included for each is dependent on an organization's level of formality and the role of hierarchy in the organization. National culture may also play a role in these decisions, as some may place greater importance on titles (such as Mr., Dr., or General). The person's role title is often included, as it will dictate what type of information they need from you. Finally, the location of the addressee can be included, when it also suggests the type of information the document will include. When in doubt, it is better to be more formal and include too much information than to find out it was needed but not included. CC - Emulate the format of the Exemplar. The name of each person being addressed is on a new equally indented line. FROM - Emulate the format of the Exemplar. Use your name, your title is Engineering Expert Witness DATE - Use the due date of the assignment format as Month, day, year RE - For a lawsuit, this will have the suit name and then what it is about relative to the lawsuit. Question Presented - Present specifically, and concisely the question you are being asked to address. This question must include a technical and legal component. Do not present the details of the problem, just the question. Brief Answer - Present specifically, and concisely the answer you got from your analysis. This answer must include a technical and legal component. The answer will not have details on your analysis or numeric outcomes. Do not overstate you findings in terms of what they show statistically and for the problem. Facts - This section will present the input you were given by presenting the context, the data and its meaning in the context, and how this input allows you to structure an analysis to determine an answer. It will not proceed into the analysis. Discussion - This section presents the logic on how you analyzed the problem in language a non-technical audience can understand, starting with the most basic reasoning for the use of this analysis for the problem. This section will end with what you found through your analysis and what it means for the case. Conclusion - This summarizes the entire document ending with the outcome of your analysis and its meaning to the case. Appendix - This section is on its own page (use 'insert/page break). For this section type out the mathematics, you used to calculate an answer in detail, ending with the outcome, what it means for the hypothesis test and the case. (MS Word has the capability to insert formulas and statistical symbols. Look at some online resources to learn how, if you are not familiar with doing this.
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Explanation & Answer

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Memorandum- Outline

Question Presented- Did the Dobre Textiles Inc. industrial plant in Baila, FL. discharge
waste with chromium levels above the U.S Environmental Protection Agency (EPA)
maximum contaminant level of 0.1 mg/L into the nearby river, making Dobre Textiles
liable for allergic dermatitis in the local beach?


Brief Answer- No. Dobre Textiles is not liable for allergic dermatitis experienced in the
local breach and attributed to chromium levels in the river as the plant did not discharge
waste with chromium levels beyond the EPA maximum contaminant level.


A. Dobre Textiles has a textile production facility at Baila, FL, along a river which is used
by the locals for drinking water and recreational activities.
B. To determine whether the claims are true, the honorable judge provided the 45 sample
values as obtained from the water utility for technical analysis of whether Dobre
Textiles contributed to elevated chromium levels in the river.
C. Statistical analysis of the sample values provided will allow me to determine whether
the claim made about Dobre Textiles’ liability is supported by the evidence.


A. The EPA has set maximum contaminant levels for drinking water considering
different common water contaminants.
B. The sample data is analyzed against the claims made against the defendant and the
level of confidence required in that case.
C. A test of hypothesis was conducted, a statistical analysis to determine whether
there is significant evidence to reject the defendant’s claim of non-violation.
D. In light of statistical analysis results, the expert witness recommends a ruling in

favor of Dobre Textiles as the evidence is not conclusive that they violated the
EPA standards on chromium maximum contaminant levels.

A. On these facts, the court will probably find that the plaintiff’s claims are not
supported by evidence.
B. Although chromium levels in the water samples are elevated, the evidence is not
sufficient to show that Dobre Textiles violated EPA standards and hence the
defendant should not be held liable for allergic dermatitis cases associated with the




Honorable Olena Leonova



I was having a hard time with this subject, and this was a great help.


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