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I represented Indian Lake Improvement Association to recover dredging costs at Indian lake in Marion County that the Association traced to two separate construction projects. The first involved road reconstruction at Pendleton Pike in Lawrence over Indian Creek. The Association alleged that the State of Indiana and its contractors engaged in insufficient storm water protection at the bridge over Indian Creek. After one rain event, the neighborhood association found and photographed orange road construction drums embedded in a newly formed island at the mouth of the lake that was created after a large rain event. That case settled. In the second case, the Association alleged that an assisted living expansion construction project involved insufficient storm water protection, resulting in large amounts of sediment discharge into Indian Creek which ran to the lake and stopped at the dam. The case went to jury trial and was settled on the fifth day of trial. The result of the two cases has helped to fund continuing dredging activities of the Indian Lake for the benefit of the homeowners. Attached is the response brief to a pretrial Daubert motion filed by the defendants.