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<br />STATE OF MINNESOTA <br /> <br />) <br />) <br />) <br /> <br />SS. <br /> <br />COUNTY OF RAMSEY <br /> <br />James A. Benshoof, being duly sworn on oath, deposes <br />and states: <br /> <br />1. I am a resident of the State of Minnesota and I make <br />this Affidavit based on my own personal knowledge of the facts stated <br />herein, except where on information and belief as indicated. I make <br />this Affidavit in support of my letter of February 25, 1997 concerning <br />Transportation Issues Regarding Environmental Assessment v!orksheet for <br />the Centre Pointe Business Park. <br />2. I am engaged in business as a professional traffic <br />engineer and the principal and sole shareholder of Benshoof & Associates, <br />Inc., a traffic consulting and engineering firm. <br />3. In late 1996 Everest Development, Ltd. sought my assistance <br />in reviewing traffic issues relating to the proposed Centre Pointe <br />Business Park project and the Twin Lakes Business Park project in the <br />City of Rosevi11e. In January, 1997, at Everest's request I reviewed <br />the Environmental Assessment Worksheet (EAW) prepared by the City of <br />Rosevi11e for the Centre Pointe Business Park p~oject, focusing on the <br />traffic section and the Traffic Study for Centre Pointe Business Park, <br />dated January 16, 1997, contained therein, prepared by Orr-Sche1en- <br />aayeron & Associates, Inc. (OSM). <br />4. In the course of reviewing the OSM Traffic Study I <br />noticed that approximately half of the body of the OSM Study was a <br />verbatim copy of the 1985 traffic study report prepared by my firm <br />for the Centre Pointe Business Park project. <br />5. I expressed concern about the obvious plagiarism contained <br />in the OSM Traff~c Study, and several problems with the technical content <br />of the Study to several State agencies who were reviewing the Centre <br />Pointe EA\oI. <br />