John Costello. AGE :64 NATIONALITY British

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1 John Costello AGE :64 NATIONALITY British Professional Qualifications and Affiliations (current & previous) Member of the Academy of Experts Fellow of the Institution of Civil Engineers Fellow of the Hong Kong Institution of Engineers Registered Professional Engineer (Civil & Geotechnical) Registered Professional Engineer in Singapore Registered Consultant - Asian Development Bank Accredited Mediator Member, Chartered Institute of Highways & Transportation Member, Association of Consulting Engineers, Hong Kong Member, Association of Consulting Engineers, Singapore Fellow of the Geological Society of London Member, Society of Construction Law, Hong Kong Member, Hong Kong Mediation Council Master of Science, Engineering Geology & Geotechnics, Leeds University Bachelor of Science (Honours), Civil Engineering, Leeds University Key Experience Over 42 years' experience in heavy civil engineering, specialising in Geotechnical and Civil Engineering issues, including more than thirty years in South-East Asia. International experience on projects in the U.K., Hong Kong, China, Taiwan, Singapore, Thailand, Indonesia, Vietnam, Philippines, Australia, Malaysia, Sri Lanka and the Middle East. Current Position Director of Expert Services consultancy providing specialist advice and Expert Witness services in the fields of Dispute Resolution, Independent Audit, Project Planning & Review, Claims Assessment and Management and Design & Construction Management throughout the construction industry. Projects Experienced in the design and construction of major infrastructure works, including Highways, Bridges & Viaducts, Railways, Airports, Port & Harbour Works, Tunnels, Commercial/Residential Buildings and Industrial and Petrochemical Installations. Examples of Expert Witness, Expert Advisor and Dispute Resolution Assignments: (Hong Kong unless stated) Kwun Lung Lau Landslide: Expert Advisor to the Hong Kong Housing Society at the Coroner s Inquest into five deaths following collapse of a masonry retaining wall. Piling Contracts, W. Kowloon & Fanling: Team Leader and Independent Piling Expert for Hong Kong Housing Authority in contract settlement negotiations for dispute resolution on two major driven and bored piling contracts Culvert Construction in Reclamation: Expert Witness in Arbitration between Hong Kong Govt. Works Bureau and Contractor. in dispute over ground conditions affecting culvert construction in new reclamation. Residential Development, Tai Tam, Hong Kong: Expert Witness assessment for High Court action on the case of stability of slopes adjacent to residential development. SENT Landfill, Hong Kong: Contractor s Expert Witness in the Magistrate s Court in defence of a Labour Department prosecution for non-compliance with Construction Site Safety Regulations. Sheet Piled Wall Collapse, Lok Fu, Hong Kong: Expert Witness for the Hong Kong Housing Authority in the forensic investigation into the collapse of a deep basement wall during construction. Textile Factory, Kwun Tong, Hong Kong: Expert Witness in defence of building settlement damage claim attributed to de-watering of adjacent deep excavation. Sheet Piled Wall Movement, Kwun Tong, Hong Kong: Expert Witness in court case for damages resulting from a water main burst caused by excessive deflection of a temporary retaining wall. Defective Piling: Independent Expert review of evidence for High Court case over alleged defective driven steel H-piling on foundation contract for Hong Kong Housing Authority Bored Pile Bridge Foundations, Hong Kong LRT Project: Expert Witness in Arbitration with over measurement of obstructions encountered during bored piling operations for bridge foundations Ting Kau Bridge, Hong Kong - Pier Ship Impact Protection Works: Independent Expert review of seawall design and construction method undertaken as part of a Mediation case between Designer and Contractor. Ting Kau Bridge Rock Slope Support Works: Independent Expert review of requirements for slope stabilisation undertaken as part of a Mediation on a design and build case. Ting Kau Bridge Viaduct Foundations, Hong Kong: Independent Expert review of requirements for rock sockets in caisson foundations, undertaken as part of a Mediation between Designer and Contractor. Rock Slope Excavation, Tuen Mun Road Widening, Hong Kong: Independent Expert review of rock slope construction methods and safety procedures, following a rockfall incident adjacent to a major highway. New Hong Kong International Airport: Independent Expert assessment of tunnel construction methods in new reclamation for Mediation between Client and Construction JV. Marine Terminal, Bangkok: Independent Expert assessment of quay piling foundations and bridgeworks as part of an International Arbitration and design liability dispute. (Thailand) Page 1 of 5

2 Examples of Expert Witness, Expert Advisor and Dispute Resolution Assignments (cont.) Kwun Tong Town Centre Redevelopment Hong Kong: Engineering Expert advisor to URA on planning study for urban redevelopment proposals adjacent to MTR Station Tunnelling Disturbance to Hotel, Hong Kong: Provided Expert Engineering advice to Hotel operator on planning objection to major tunnel operations at adjacent site. Brunei Naval Base: Expert Witness for the Brunei Government in two International Arbitrations over design and construction issues Naval Base.(Brunei & Singapore) Soil Nailing - Expert Advisor to Contractor in dispute with developer & HK Government over soil nail installation procedures on site formation cut slopes. Mega Hotel Development, Hong Kong: Engineering Expert in planning application for a 74 storey hotel development over a 60m high slope in a dense urban area. Kowloon City Development, Hong Kong: Independent Expert on resolution of dispute between adjacent property owners over effect of sheet piling works. Bored Piling Works, Shek Wu Hui, Hong Kong: - Expert Witness in Arbitration with Contractor over the construction of bridge and retaining wall piling. Penny s Bay Reclamation, Hong Kong: Independent Engineering Expert advising Government on requirements for sea wall dredging in dispute with Contractor. Kwun Lung Lau Estate Redevelopment, Hong Kong: Expert Advisor on Expert Determination on dispute between the HK Housing Society and Piling Contractor. Reem Island Development, Abu Dhabi: Expert Advisor on Commercial Negotiation and settlement of claims on major Regional Roads infrastructure design commission in dispute between Project Manager and Design Consultant. (United Arab Emirates) Aquarium Project, Jeddah: Independent Expert Advisor on contractual issues relating to potential Claims arising as a result of termination of Construction and Project Management contracts. (Saudi Arabia) Jeddah Wastewater Network - Independent Expert Advisor/Facilitator on contractual issues relating to Project Delays and Claims arising as a result of suspension of Construction contracts. (Saudi Arabia) Highway Development Project Expert Witness in International Arbitration between Contractor and Government over construction delays in major 60 km highway contract. (Sri Lanka) Settlement Damage to Factory, Tseung Kwan O, Hong Kong: Independent Expert advice on Court action over claim for damage to factory caused by adjacent excavation works. Sheung Shui Development, Hong Kong: Independent Expert Witness assessment of piled foundations for 68 residential units in Arbitration between Contractor & Owner. Defective Piling Case, Hong Kong: Expert Witness on High Court Action between Main and Sub-contractor in dispute over testing requirements for large diameter pile foundations Civil Engineering Employment Assessment, Hong Kong: Expert Opinion on High Court Case relating to employability of Civil Engineer disabled as a result of site accident. Pipeline Construction: Expert Witness in Arbitration between Hong Kong Government and Contractor in dispute over ground conditions affecting pipe jacking operations Tung Chung MTR Station, Hong Kong: Expert advising Hong Kong Government in dispute with MTRC over the construction of reclamation foundation works. Tai Po Road Development, Hong Kong: Expert Witness for Developer in liability dispute with contractor over bored and driven piling on cut and fill slopes. LPM Slope Works Contract, Hong Kong: Expert Witness in Mediation between Government and Specialist Contractor over soil nail installation in dispute over ground conditions. Construction Waste Sorting Facility, Hong Kong: Expert Advisor to Operator in Mediation with Government for resolution of dispute over material handling requirements Reem Island Development, Abu Dhabi: Expert Advisor on assessment and preparation of claims related to supplementary services and project programme extensions on Development Infrastructure in dispute between Developer and Designer. (United Arab Emirates) Jabal Omar Development, Mecca : Advisor on contractual issues relating to Design & Build Contracts for US$2.5 Billion Development of 40+ Towers adjacent to the Grand Mosque, Mecca. (Saudi Arabia) Sewage Tunnel Construction Expert Engineering Advisor to National Water Company on modification of proposed 15km sewage tunnel project in Riyadh. (Saudi Arabia) Deep Tunnel Construction, Singapore: Expert Witness on Arbitration over ground conditions encountered during construction of highway river crossing tunnel. (Singapore) Page 2 of 5

3 EXPERIENCE RECORD 1996 to date Director, AIM Group, Expert Services Independent Consultant providing specialist Civil, Geotechnical and Marine Engineering Design and Project Management Services to a wide range of clients in Hong Kong, China, S.E. Asia and the Middle East, most recently on a variety of projects in Saudi Arabia. Independent Project Audit and Project Review Services have been provided on Landslip Prevention Measures Contracts, slope and retaining structure stabilisation and remedial works, quarry works, deep tunnelling projects, site formation works, deep foundations, major rock slope excavation and formation works and tunnelling and sewer mainlaying works contracts in Jeddah. Specialist Expert Witness and Dispute Resolution Services have included independent audit, Arbitration, Mediation, Litigation and dispute resolution on major landslides, underground railway station construction, highways, tunnelling projects, landfill facilities, slope works, deep foundations, building and civil engineering structures, including bridgeworks and viaduct foundations, marine structures, driven and bored piling systems, drainage structures, deep sewerage systems, pipe jacking, reclamation and port and harbour works. Design and Project Management projects have included major Highways, residential, commercial and industrial developments and landfill and quarry restoration works as well as management of major infrastructure projects and route planning studies. Civil and Geotechnical and projects have included slope stabilisation, site formation, foundations, basement structures and drainage works. Marine engineering projects include sea walls, jetties and reclamations Director - Hyder Consulting (Managing Director, Acer Wallace Evans Ltd ) Divisional Director - Responsible for the establishment and management of the Geotechnical Engineering, Ports & Harbours and Special Projects divisions of the Group in S.E. Asia. Project Direction and Management - Responsible for numerous major projects including railway and highway projects, industrial and commercial facilities, sea wall and reclamation works, bridge and building foundations, slope stabilisation, Landfill and waste management works, Golf Course design and construction, the HKHA Term Geotechnical Consultancy Programmes, marine structures and civil and engineering infrastructure projects. Involved with major development planning studies in Hong Kong and China and master planning for the Hong Kong Container Port, hazardous chemical sites, and new town infrastructure. Geotechnical and Marine Specialist - Responsible for the provision of geotechnical services to Hyder s Structural and Highway Engineering divisions projects, including immersed tube tunnels, viaduct foundations, and deep excavations for foundations and railway stations. Also responsible for breakwater and marine piling projects and the design of port improvements at Songkhla, Thailand Managing Director and Country Manager - Acer Consultants Pte Limited Corporate Management -Responsible for the establishment, direction and management of the Singapore office of the Acer Group. Particularly responsible for the marketing of the firm's engineering and project management services throughout the region. Project Direction and Management Responsibilities in Singapore included detailed design of major bridge and viaduct structures for the Belfast Harbour Road and Railway Crossing,, Bangkok Expressway in Thailand and West Kowloon Expressway in Hong Kong, design of the Denmark House high-rise office development in Kuala Lumpur, Malaysia, a Hotel development in Indonesia, an Export Processing Zone study in Hanoi, Vietnam and design and project management for various industrial facilities in Singapore and Malaysia, including a major pharmaceutical plant for Fisons through John Brown Engineering, and tender designs for MRT system extensions in Singapore. Geotechnical and Marine Specialist - Provided marine and geotechnical advice on an Offshore Oil Supply base in Australia and Container handling systems in Singapore s container port. Responsible for design and supervision of foundations and deep basements in Singapore and Malaysia. Page 3 of 5

4 Director and Country Manager - Freeman Fox Intercon Consultants Limited Corporate Management - Responsible for the establishment and management of the Bangkok office of Freeman Fox in Thailand, part of the Acer Group of companies. Responsible for the marketing of project management and design of major multi-disciplinary engineering projects Project Direction and Management - Involved with the creation, design and implementation of the Bangkok Second Stage Expressway, a 50 km, US$1.5 billion, Build, Operate and transfer (BOT) highway viaduct project, commercial, industrial and residential developments, rail link and railyard container handling facilities, high-rise office and hotel facilities, highway bridge and viaduct structures and aquaculture developments. Geotechnical and Marine Specialist - Responsible for the design and implementation of container terminals (inland and ports), and civil and transportation related projects. Areas of business included Thailand, Taiwan, Hong Kong and Malaysia Associate Director - Acer Consultants (Far East) Limited Corporate Management - Responsible for direction and management of the Civil and Geotechnical Engineering Division of Acer. Project Direction and Management. Project Manager for the design and engineering cost and feasibility study for a major container terminal in Hong Kong, including civil, structural, geotechnical electrical and mechanical works design and detailed analysis of construction techniques. Project Director for a cross-harbour gas pipeline study, acting Project Manager for the Tai Po Gas Plant. Civil and Geotechnical Specialist - Project Director responsible for Annual Geotechnical Advisory Service to the Hong Kong Housing Authority, and as a specialist advisor to a team of consultants engaged on the development of a privatisation policy and implementation strategy for the design, construction and operation of 50 km of urban expressway and associated commercial development in Bangkok on behalf of the Expressway and Rapid Transit Authority of Thailand Associate Director - Freeman Fox (Far East) Limited Project Direction and Management Responsible as Deputy Project Manager and later Construction Manager for a multi-disciplinary joint venture carrying out the civil, structural, electrical and marine elements of a major new HK$1 billion Towngas production plant at Tai Po on newly reclaimed land. The project included over 26 km of submarine pipeline, a 40,000 tonne naphtha tanker unloading terminal, three 40,000 cu.m. capacity steel storage tanks and foundations, power supply, fire fighting systems and building contracts. The project required extensive liaison and co-ordination with a large number of government departments, statutory bodies and interested and affected parties. Particularly responsible for the interfaces between contracts providing water supply, power and infrastructure for the main gas production systems. Civil and Geotechnical Specialist- Engaged on the management of a variety of civil and geotechnical engineering projects, including site formation design and the design and implementation of remedial works and stabilisation measures for slopes and retaining walls Principal Engineer - Freeman Fox (Far East) Limited Technical Director - Freefox Testing Limited Civil and Geotechnical Specialist - Responsible for the management and direction of teams of engineers engaged on the design and construction of major civil engineering and geotechnical projects, including major highway, marine and drainage works, urban railways and large scale commercial and residential developments. Additionally responsible for the provision of specialist geotechnical consultancy services both in-house and to private and Government clients. Responsible for the establishment, equipping and selection and training of staff for a new soils and materials testing laboratory in Hong Kong. Page 4 of 5

5 Senior Geotechnical Engineer - Freeman Fox & Partners (Far East) Ltd Geotechnical Specialist - Project management of large scale development projects involving residential and commercial complexes with associated highway works, with particular emphasis on the solution of geotechnical problems. Project Manager for the Kwai Chung Container Port Area Development Study for Government, involving reclamation studies for the provision of additional container handling berths south of the existing Container Port. Extensively involved with geotechnical aspects of temporary and permanent works for the Tsuen Wan Extension of the Mass Transit Railway Senior Geotechnical Engineer - Freeman Fox & Partners (Far East) Ltd Responsible for the management of geotechnical staff engaged on design of local development projects, highways, Government Housing schemes and Mass Transit Railway design and construction supervision. Responsible for providing specialised in-house geotechnical consulting service to staff engaged on MTR temporary works Geotechnical Engineer - Freeman Fox & Partners (Far East) Engaged on geotechnical work associated with Mass Transit Railway and Government Highway construction projects. Design of seawall, reclamation and harbour works, Housing redevelopment schemes, slope stabilisation works and developments for both the private and commercial sectors Geotechnical Engineer - Hong Kong Government Buildings Ordinance Office Implemented recommendations made in the Government's Landslide Studies. Responsible for scrutiny and checking of geotechnical aspects of private sector building and construction proposals submitted to the B.O.O. for approval. Geotechnical consultant to the Dangerous Buildings and Works Division of the B.O.O. in the checking of the stability of existing retaining walls, slopes and buildings on private land and the supervision of associated remedial works Senior Soils Engineer - South Yorkshire County Council, England Management of engineers and geologists directing site investigations. Provided a geotechnical advisory service to the design and construction sections of the County Council, District Councils and general public such as local housing developers. Extensively involved with direction and coordination of highway pavement testing and design for highway maintenance programmes Assistant Engineer - South Yorkshire County Council, England Responsible for the supervision of site investigations and the compilation and preparation of technical reports, in particular those investigations associated with mining subsidence and old mineworkings Graduate Engineer- W. Riding County Council Trunk Roads Section, England Engaged under I.C.E./I. Mun. E. training scheme. Engaged on detailed design of major highway schemes in urban and rural areas, with particular emphasis on the solution of geotechnical problems Materials Engineer - N.E. Road Construction Unit, D.O.E., England Materials Engineer on M18 Motorway contract, responsible for geotechnical aspects on 7.5 kms of motorway, 5 kms of roads and 23 road, rail and canal bridges. Responsible for full-scale extensively instrumented trial embankment and management of on-site soils and materials laboratory Trainee Engineer - George Houlton & Sons Limited Papers presented: Staged Engineering Geological Evaluation for the Residential Development at Tai Wo Tsuen, New Territories, Hong Kong Geotechnical Designs for the Construction of Fortress Hill Station Geological Society of Hong Kong - Conference on Geotechnical Aspects of Site Investigation, Hong Kong, August Institution of Mining and Metallurgy - Conference on Rock Engineering in an Urban Environment, Hong Kong, Feb Page 5 of 5