Introduction
These excerpts address the following issues in the dispute: Dr. Huang's qualifications, his opinion on causation, the French drain, and the data he relied on. All are taken directly from the official court transcript.
Q = Vasko Alexander, Jill's Attorney
A = Dr. Fei-Chiu Huang, HOA Expert Witness
A = Dr. Fei-Chiu Huang, HOA Expert Witness
Key Testimony
What did GeoTek find the French drain was actually doing with collected water?
Reintroducing it into the subsurface of the slope. GeoTek's report found that "surface water that is collected at the area drains is being introduced into the subsurface directly behind the existing retaining wall." The drain was supposed to carry water away from the slope. Instead, it was putting water back in.
When confronted with this reality, Huang could not answer the question without fully admitting what every other civil engineer knows and will testify to: reintroducing water at the toe of the slope is counterproductive and a major contributing factor to slope failure.
However, as the system is currently constructed with perforated drainpipe, surface water that is collected at the area drains is being introduced into the subsurface directly behind the existing retaining wall. Do you see that language?
I saw that, yeah.
Do you have any criticism with an area drain, a French drain, reintroducing water that's supposed to be carried away, away from the slope back into the toe of the slope?
Well, not back into the toe of the slope. What I'm saying is that this French drain system will collect both surface and the subsurface water from the bedrock contact to go into through the perforated hole.
Pages 148-149
Were the drains capped when Dr. Huang visited the site?
No. His site visit was May 21, 2025, more than a year after GeoTek recommended that the drain system "cease the transmission of surface water into the subsurface." The HOA had not capped the drains as of that date.
What was the state of the drains during your site inspection? Were they capped or not capped?
Not ... my recollection is not capped.
Pages 177-178
Has Dr. Huang ever offered expert testimony in deposition or in court related to slope stability?
No. Despite his claimed extensive experience as a civil engineering expert, Dr. Huang has never offered expert testimony in a case related to slope stability.
Do any of these cases, other than, of course, the Mann versus Las Brisas Pacificas matter, do any of them -- strike that. Did any of those cases deal with slope stability?
No.
Page 50
Does Dr. Huang agree that introducing water into a slope is a problem?
Yes. He defined "negative drainage" as exactly this condition, then refused to apply the label to the French drain. When asked what negative site drainage means, he described water being introduced into a slope. When asked to apply that definition to GeoTek's finding, he would not.
What is the opposite of if you do not have positive site drainage with water being taken away from the slope, if you have a situation where the water is being introduced into the subsurface, what would you call that?
Well, you have -- I mean, meaning that the surface of the slope need to be in good or positive drainage allows water from top of the slope to migrate down to the bottom of the slope. That would be the positive drainage. But if there's anything, for example, subsidence or settling or something, the irrigation, you know, that was in the slope that caused the cracking that allows the water to introduce into the slope. That would be the negative drainage.
That would be negative drainage; correct?
If that condition occurred, it could be, yeah.
Pages 167-170
Can adding water to a slope affect its stability?
Yes. Dr. Huang confirmed that excavations, adding water, mud flow, ground cover, and even gopher holes can all affect slope stability.
Well, earlier, you testified that excavations in the slope can affect slope stability, adding water to the slope could affect slope stability, mud flow could affect slope stability, growth cover could affect slope stability, as well as gopher holes; correct?
Yes.
Page 85
Does Dr. Huang believe consulting an engineer is important before making changes to a slope?
Yes. He testified he "would recommend to consult with GeoTek to better understand whether the proposed or intention to cut into the slope would be suitable without causing potential slope failure." The HOA did not consult any engineer before installing the French drain at the toe of the slope in 2019.
Before you cut into the toe of the slope, is it your professional opinion that you need to consult an engineer before cutting into the toe of the slope?
Oh, I would recommend to consult with GeoTek to better understand whether the proposed or intention to cut into the slope would be suitable without causing potential slope failure.
Pages 86-87
Did Dr. Huang know the condition of the drains at the time of the slope failure?
No. He said the drains were "performing good, I think," then admitted he was not present and had no evidence to support that claim. He based his assumption on the absence of a prior slope failure, not on any inspection or testing.
What was the condition of those drains you just described?
What condition?
At the time of the slope failure?
Performing good, I think.
You're speculating; right?
Well, there's --
You have no evidence that they were performing well, correct, Dr. Huang?
No, I'm not assuming. I'm not assuming. It was --
What do you base -- what do you base that opinion on?
Based on the French drain has been done since 2019 and there's no slope failure from 2019 to the -- before the major landslide -- I mean the subject surficial slope failure occurred on or around April 27, 2023. There's no such conditions that tells me that the French drain was not functioning well.
Pages 161-162
Who prepared the data Dr. Huang relied on for his opinions?
The HOA's attorney's office. The water usage chart (Appendix B) was prepared by Craig Combs' assistant. The date ranges for precipitation records (Appendix C) were selected by Combs' office. Dr. Huang did not authorize those decisions.
Who prepared this document?
Mr. Combs' assistant.
Who made the decision to limit the data usage analysis to those two dates?
I don't know who made that decision.
You didn't authorize that decision, did you?
I did not make that decision.
Is Mr. Combs' assistant, to your knowledge, a civil engineer?
I don't know.
Is Mr. Combs' assistant, to your knowledge, a geotechnical engineer?
I don't know.
Is Mr. Combs' assistant, to your knowledge, a meteorologist?
I don't know.
Pages 28-29, 32, 40-41, 59-62
Did GeoTek identify the source of the water that saturated the slope?
No. GeoTek's report stated: "Source of the water was not clearly evident during the investigation and is typically difficult to identify or locate." Dr. Huang acknowledged this but still concluded the source was exclusively rain.
Did they opine in that sentence that this was caused by rain?
Well, it says it's due to the saturation of the soil. But it didn't mention.
Did it identify the source of the water, Dr. Huang?
No.
In fact, the next sentence reads, Source of the water was not clearly evident during the investigation and is typically difficult to identify or locate. That was their conclusion; correct?
Not conclusion; their opinion.
Pages 143-145
Did Dr. Huang review any other depositions before testifying?
No. He did not review Sandra Comouche's testimony, Bill Katz's testimony, or GeoTek's deposition.
Did you review any of the depositions taken to date in this case in preparation for your deposition?
No.
You didn't read Mr. Katz' deposition transcript; correct?
No.
Pages 56, 162