Sage Everly Direct Examination

Good (morning/afternoon. Please introduce yourself to the members of the jury.

Good (morning/afternoon), my name is Sage Everly.

What do you do for a living?

I've been a mechanical engineer most of my life, and these days I'm primarily running my consulting firm, Power Consulting.

Can you walk us through your education and training?

Absolutely, first I graduated from Case Western University with a degree in mechanical engineering. From there I got a job at Big City Electric. It was a firm very similar to my own where I helped design electrical infrastructure for developing countries. One of my proudest designs was in Tanzania where we designed a grid that massively reduced risk for bush fires in the Serengeti. But afterward I did get homesick so I got a job back in Midlands at the Midlands Department of Transportation, which finally led me to founding my own firm, Power Consulting.

How'd you get involved in today's case?

I was retained by you, defense counsel, to review MG&E's equipment and conduct prior to the Dip fire.

What was the focus of your investigation?

Firstly, I focused on whether MG&E's actions may have contributed to the Dip Fire, and secondly whether those actions were within industry standards.

What facts and data did you review?

I reviewed inspection records, supervisory records, and industry standards themselves

Were they sufficient in forming your conclusions?

Yes, they were

How did you analyze these materials?

I always use the TAB method, which is widely used by experts in my industry. It stands for Timeline, Actions, and Big Picture. It essentially means that I first build the timeline of what happened. Then I examine the actions that were taken and compare them to industry standards. Finally, I took a step back and looked at the big picture.

Did you reliably apply the TAB method in today's case?

Absolutely.

How did you start your investigation?

I first established that timeline, starting with the crash at 1:40, moving to the report at 2:10, and finishing with the call to MG&E reporting the fire.

Why do you start with the timeline?

It's vital for establishing context. We know what happened today, eleven months later, but what I'm interested in is what MG&E knew in the moment.

Where did you begin examining MG&E's actions?

I focused on whether MG&E took proper care of their equipment, specifically the utility pole in question, the one off of Dip Road.

Did you find that MG&E adequately maintained this pole?

Yes, and there are usually a few points that stick out to me. Firstly, the dimensions of the pole itself were all in industry standard. Then I analyzed maintenance records and found that the pole had no history of major electrical malfunctions.

After the proper maintenance and protection, let's talk about the night of the car collision - can you walk us through what happened that night?

Certainly, MG&E was first notified by police that a vehicle struck their pole at 2:10. Later, at 3:30, their environmental sensors started giving unusual readings, which were determined to be non-actionable according to standards.

Why were those alerts listed as "non-actionable?"

Those sensors were notably buggy, and after assuring the stability of the electric lines, it was determined to be a false positive. The systems that analyze the electrical lines are the gold standard in our industry, so we regularly rely on those systems when making important decisions such as dispatching technicians.

What was the final action you reviewed?

MG&E's decision not to immediately de-energize their poles after the report. Doing something like that comes with major consequences, which should never be taken lightly. MG&E quickly investigated the situation and still de-energized promptly, which is within industry standards.

When you compare what MG&E actually did to its own manual and the industry standards you reviewed, what did you find?

I found that all of MG&E's actions on the morning of January 1st were compliant with both the manual and the standards.

When you step back and look at the entire timeline, what is your conclusion?

I see a lot of competing factors form an admittedly complicated picture. A holiday morning, a car crash, reliable sensors showing nothing wrong, and eventually a devastating fire. MG&E was not handed the full picture at 2:10 a.m.; they got one piece at a time. They made every decision in accordance with all of our industry's rules with the information they had on hand. So, I concluded that MG&E followed all the rules and that there is no way to truly know how this fire started.