P.R. Mann Cross-Examination Questions

PG&E does not put up warning signs on power lines despite the danger that they pose, correct?

As a matter of policy, our company does not place warning signs on power poles— because they interfere with our employees’ safety in pole climbing techniques.

However, warning signs may have prevented the accident at hand, correct?

Yes, however, given the dangers of these signs, we did not implement them. We instead invested hundreds of thousands of dollars in other means to make sure that these power lines were safe.

Are you aware that Robbie Curtis, the plaintiff, has never had any PG&E employee inform him of the dangers of power lines?

Beyond my scope

Your company was not informed of the tree house that was built under the line, correct?

Correct, my company was not made aware of the tree house that was built under the line by neither John Carpenter nor the FUHSD school district.

Don’t you think that your company would have been informed of such a thing, considering it is your duty to ensure that there’s nothing safety-threatening involving electricity?

My company should’ve been informed, but it’s their responsibility to communicate such things to us, especially since we rely on this type of information to maintain a safe environment.

Is it true that PG&E doesn’t cut down trees in order to maintain their beauty?

Yes, in some occasions we choose to not cut down the tree to our recommended guidelines as per owner’s request or to not harm the tree. However, we only do so when our crew gauges that doing so will not pose a threat to safety.

Ms. Mann, did your company have the opportunity to decide to cut the tree or not?

Beyond my scope.

Your Honor, permission to enter P.R. Mann’s Deporition into evidence. Ms. Mann, could you read lines 21-23?

Yes. Attorney asked, “You had the opportunity to decide t– to cut the tree. Correct?” I answered, “Um, correct?”

How come in your deposition, you said you did have the opportunity to decide to cut the tree, but now you say beyond your scope?

It was momentary confusion