Sept. 12 Cross EXamination

Without identifying who did the cross examination and exactly who was cross examined, here is a rundown of what topics were covered, and a general idea of what answers were given:

• The number of customers for the proposed self storage units at full capacity was estimated to be over 600.   - This estimate was stipulated as possible by Mr. W
• A complete analysis on the number of customers [at full capacity] has not been undertaken by Mr. W. -  This was agreed by Mr. W.
• An estimate of 55 RV's/campers, etc.. in the outdoor storage area was proposed.  - Mr. W. agreed with this estimate
• The infrastructure for the self storage business (curb, water, sewer) would be less costly and involved as compared to residential development.  - Stipulated by Mr. W.
• The number of single family homes possible on this land could be 2 or 3?  - Stipluated by Mr. W. (although a proposed development with around 5-6 homes was shown by one witness)
• No problem with drilling wells? -Agreed by Mr. W.
• Mr. W. Testified that drilling wells on this property could disturb other nearby wells?  - Woolfrey stated that "It's possible"
• Has he performed any studies concerning wells? - "No"
• Was this conjecture on his part?  - "Yes"
• The exhibits shown by W. Lawyer do not distinguish between the types of vehicles that would be coming to the business?  - "Correct"
• Pertaining to photos shown by Mr. W's lawyer: Were there any photos of Mr. W. standing atop a rental truck with his hands up going through the low (9 ft.) bridge with his hands raised (as was shown with the higher bridge on Burgoyne Rd.)  - "No"
• To Mr. W.: You are aware that there are various trucks other than the small truck used in your photos?  - "Yes"
• Shown the wreckage of a Penske truck which didn't make it through the Bridge at the Whitford Train Station, did he think that this truck would fit under the (9 ft.) railroad bridge at the proposed site?  - Mr. W. stipulated that it would not.
• Is it your (Mr. W.'s) testimony that you aren't comfortable discussing a range of sale prices [that he was offered over the years]?  - Mr. W. stated that is not anyone's business.
• Didn't he think that because he was testifying to not being able to realize a reasonable selling price [with residential development], that isn't this then the business of everyone here? -  Mr. W.'s reply was not clear, although he did not offer any dollar amounts regarding offers.
• Was Mr, W aware of other self storage businesses having availability?  - Mr. W. replied that he was not.
• Did Mr. W. think that it was not impossible to build single family homes on the property. - Mr. W. stated that this was correct.
• Is it just that you could not make as much on this as you want to? - Woolfrey agreed.
• So you would make more with the self storage business as opposed to single family homes?  - Mr. W stated that he didn't think that anyone would want to live [in single family homes] on this property.
• A realtor named Hanrahan was admitted as an "expert witness" was asked if there would more or less privacy for the neighbors if there were a self storage business there [as opposed to residental development] - Realtor offered his opinion that there could be more privacy because there would be nobody "getting all up in your business."
• A member of the ZHB asked if there were emergency access on one of the residential schemes considered by Mr.W. -  An "expert witess" stated that there was none.

The cross examination summary shown here is not to be construed as an exact transcript of what was asked and answered, but is is believed to be true & accurate. If anyone has additions or corrections, they may email:

NoSelfStore@yahoo,com

and whatever is found to be inaccurate or missing will certainly be promptly addressed.