Swimming Pool Expert Construction Defect Accident Injury ROBERT HOLMER, PE, GE PRINCIPAL ENGINEER

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1 CURRICULUM VITAE ROBERT HOLMER, PE, GE PRINCIPAL ENGINEER AREAS OF EXPERTISE SWIMMING POOL ACCIDENT INJURY AND CONSTRUCTION DEFECT Education California Polytechnic State University, Bachelors of Science in Civil Engineering, 1994 Engineer of Record for over 30,000 residential and 500 public swimming pool projects Degrees in Civil Engineering from California Polytechnic State University and the University of Colorado Registered Civil and Geotechnical Engineer and licensed in nine states Special Expert on the Technical Advisory Committee with the Uniform Swimming Pool, Spa, and Hot Tub Code Engineering license exam development with the California Board of Professional Engineers Past Director for the California Geotechnical Engineers Association Numerous publications in conference proceedings and trade magazines on various topics for best practices of swimming pool construction Numerous speaking engagements at conferences and trade shows on various topics for best practices of swimming pool construction 15 years expert witness experience including over 30 depositions and testimony at 6 trials University of Colorado, Masters of Science in Geotechnical Engineering, 1998 Certifications Registered Geotechnical Engineer, California (GE) #G2672 Registered Civil Engineer, California, (PE) #C62542 PROFESSIONAL EXPERIENCE Rob is a Principal Engineer and Sacramento Office Manager with Terracon Consultants, Inc. Prior leadership roles have included Director of Aquatic Engineering Services, Director or Field and Laboratory Testing Services, and Chief Operations Officer of Neil O. Anderson & Associates (NOA). In 2005, Rob opened the Concord office of NOA and managed both Sacramento and Concord offices. Rob now provides leadership and supervises a staff of highly motivated and technically proficient professional scientists, engineers, field technicians, materials and construction inspectors. Expert witness consulting makes up less than 10% of Rob s practice. His clients have included owners, contractors, attorneys, insurance companies, and public agencies. He has been retained by both plaintiff and defense, and has testified more than 30 times at deposition and trial. SWIMMING POOL EINGINEERING EXPERTISE Rob has served as the Engineer of Record for the successful construction of over 30,000 residential and 500 commercial swimming pool projects. Rob specializes in the most challenging swimming pool projects including large residential and commercial facilities, rooftop pools, competition pools, public and private recreation facilities, and water parks. His engineering consultation services includes structural, geotechnical, mechanical systems, hydraulics, water treatment, materials engineering, risk management, and code compliance.

2 GEOTECHNICAL ENGINEERING EXPERTISE Over the span of his career, Rob has authored over 1000 Geotechnical reports and investigations. He is an experienced expert in many geotechnical disciplines including: soil mechanics, deep and shallow foundations, expansive soils, ground water monitoring, temporary and permanent construction dewatering, pavement design, slope stability analysis, liquefaction, geosynthetics, retaining walls, and materials testing. PROFESSIONAL AFFILIATIONS Uniform Swimming Pool, Spa, and Hot Tub Code, Technical Advisory Committee Member, Present California Geotechnical Engineers Association (CGEA), Board of Directors 2002 ~ 2008 California Board of Professional Engineers, Geotechnical License Exam Development, 2005~2006 Sacramento State University, Senior Project Professional Participant, 2007 American Society of Civil Engineers (ASCE) American Shotcrete Association (ASA) Colorado Association of Geotechnical Engineers, (CAGE), member Forensics Expert Witness Association (FEWA), Member PUBLICATIONS Hazards of Loose Fill, co-authored with Neil Anderson, Case Study of Swimming Pool Failure, Pool and Spa News, January 23, 2006 Unpopping a Pool, co-authored with Neil Anderson, Case Study of swimming pool failure, Pool and Spa News, April 10, 2006 Patio Deck Heave, co-authored with Neil Anderson, Case Study of swimming pool decking failure, Pool and Spa News, May 22, 2006 Shaky Ground, co-authored with Neil Anderson, Case Study of swimming pool failure, Pool and Spa News, July 24, 2006 Gunite Troubles, co-authored with Neil Anderson, Case Study of swimming pool failure, Pool and Spa News, Septmeber 18, 2006 Reviving a Classic, co-authored with Neil Anderson, Case Study of swimming pool renovation, Pool and Spa News, January 22, 2007 Elevated Engineering, Part 1 of 2, Engineering and Construction Considerations for roof-top pools, Watershapes, November 4, 2015 Overhead Defects, Part 2 of 2, Case Studies of failures of roof-top pools, Watershapes, November 18, LECTURES The Anatomy of a Perfectly Engineered Pool, 9 hour workshop on soils, structures, and materials, Pool Industry Expo, Sept 2004, Monterey, Ca Swimming Pool Engineering, 4 hour workshop on soils and structures, Sacramento Valley Association of Building Officials, June 2005, Sacramento, Ca Case Histories of Swimming Pool Failures, 4 hour lecture on swimming pool failures, their causes, and repairs, April 2006, Hyatt Regency Hotel, Sacramento, Ca Case Histories of Swimming Pool Failures, 4 hour lecture on swimming pool failures, their causes, and repairs, Pool Industry Expo, September 2006, Monterey, Ca Swimming Pool Engineering, 6 hour workshop on soils, structures, and case histories, Sacramento Valley Association of Building Officials, June 2008, Sacramento, Ca Everyone Loves a Pool, But What s Lurking Beneath the Surface, 2 hour lecture on engineering and construction considerations of rooftop pools. RCI Building Envelope Technology Symposium, October 2016, Houston, Tx. Pool Shell Structural Failures, Case Studies, 2 hour lecture on swimming pool failures. International Pool, Spa, and Patio Expo, New Orleans, November 2016

3 EXPERT WITNESS EXPERIENCE 2014-Present Oswald Residence Client: Jack Oswald Attorney: Elizabeth England; Morris, Polich & Purdy Present Vineyard Valley LLC Client: Vineyard Valley, LLC Attorney: Daniel Steinberg; Trainor Fairbrook Present Hyatt Place Hotel Client: Bullivant Houser Bailey Attorney: Brendan Hanrahan Greer v. Legacy Partners Client: Gibbs, Giden, Locher, Turner, Senet & Wittbrodt, LLP Attorney: Michael Geibel during litigation pertaining to a damaged swimming pool. Conducted site inspection, reviewed construction documents and prepared expert report. to investigate construction defects and damage to the swimming pool. Conducted site inspection, destructive testing, preparation of expert report, prepare construction drawings for reconstruction of the pool, expert consultation. defendant pertaining to construction defects including corrosion and leaking of the rooftop swimming pool. Site inspections, review of opposing expert report, consultation. Expert witness consultation retained by defense council for the swimming pool contractor in an accident-injury litigation. Services included a research of appropriate laws and codes, expert site visit, and consultation during settlement negotiations Present Killian Residence Client: Sue Killian Attorney: Elizabeth England; Morris, Polich & Purdy during litigation pertaining to a damaged swimming pool. Seller failed to disclose to buyer the extent of the swimming pool damage. Conducted forensics investigation and prepared expert report. Consultation with plaintiff s attorney during settlement negotiations Campbell v. Cupertino Cupertino, Ca Client: Law Office of David Burnett Attorney: David Burnett 2013 Stofer v. Shapell Client: Newcomb Law Offices Attorney: Bruce Trevithick plaintiff in an accident-injury litigation. A child suffered a broken foot when using the waterslide at the public facility. Services included a research of appropriate laws and codes, expert site visit, and consultation during settlement negotiations. waterfall subcontractor. The swimming pool was constructed in close proximity to a descending slope and suffered some damage. Peer review of expert reports and deposition testimony.

4 2012 Hotel Terra adv. Shaw Construction Client: Schwartz, Bon, Walker, & Studer, LLC Attorney: Judy Studer Hotel Partners v. Swinerton Client: Pahl & McCay Attorney: Karen McCay West Santa Clara, CA Briar Chapel Country Club Client: Parker Poe Attorney: Jason Herndon Raleigh, NC Meridian v. Paradise Pools Client: de la Peña & Holiday LLP Attorney: Bonnie L. Portis San Francisco, CA Quy v. Rapp Pools Client: de la Peña & Holiday Attorney: Bonnie L. Portis Trovato Residence Client: Charter & Davis Attorney: Brian Charter Villa Serena Apartments Roseville, CA Client: Panattoni Law Firm swimming pool contractor. Site visit to inspect construction defects regarding leaking pool at ski resort hotel. Peer review of expert report, prepare engineering report with recommendations for repair.. Forensics Investigation of severely distressed, swimming pool, patio slab, and entrance canopy structures constructed on loose fill. Provided consultation, specifications, and design of repairs. Expert Consultation during 4 years of litigation. Attended expert meetings, peer reviewed opposing experts opinions/findings, two (2) separate depositions which totaled 4 days of testimony, preparation for trial. during negotiation and arbitration of the community club house swimming pool construction defects. Design engineer for repair of damaged structures. Work with contractor and owner during implementation of repairs. swimming pool contractor during accident injury litigation. Demonstrated that the injury suffered was the result of an architectural design issue and not the result of the work of the contractor. Expert witness retained by the swimming pool contractor during settlement negotiation of a damaged residential swimming pool. during litigation pertaining to water damage in a basement space. Seller failed to disclose to buyer of previous flooding. Provided consultation, specifications, and design of repairs. Expert Consultation during litigation, peer reviewed opposing experts opinions/findings, deposition testimony. Expert witness consultation during litigation pertaining to failed sidewalks. Forensics investigation of contractor workmanship. Expert testimony during arbitration, deposition and trial.

5 Swimming Pool Expert Construction Defect Accident Injury