Adv. Dr. Tal Rotman: So you didn't actually measure. I suggest you,
The witness, Prof. M. Echo: Yes
Adv. Dr. Tal Rotman: That you didn't measure people's feelings about quality or air pollution coming from factories
The witness, Prof. M. Echo: True
Adv. Dr. Tal Rotman: Rather, you measured them in general terms of environmental damage as defined broadly in your survey
The witness, Prof. M. Echo: True
(pages 1207-1208)
- The survey is not reliable in terms of the composition of the respondents
Since we are interested in a class action, it is appropriate and proper that the participants in the sample survey reflect as much as possible the members of the group they wish to represent – "residents of Haifa Bay." Prof. Lahad was asked if the sample they worked with was 'random and representative' and he first replied that to the best of his knowledge it was. He replied that the group of potential representatives are "residents of the Haifa Bay area." He was therefore asked:
Adv. Dr. Tal Rotman: So you will agree with me that in order for a person, in order for this sample to be representative of the residents of Haifa Bay, every person in Haifa Bay must have the same probability of being included in the sample.
The witness, Prof. M. Echo: This is how you work in Panel Islands. Isn't it? They didn't take the whole area there and did it?
Adv. Dr. Tal Rotman: I don't know how they work. I'm asking you.
The witness, Prof. M. Echo: Ask Dima, what are you asking me questions?
[....]
Adv. Dr. Tal Rotman: Nope. You know what, how many people from the Haifa area are members of this panel, are on it?
The witness, Prof. M. Echo: No, no.
Adv. Dr. Tal Rotman: Nope. Do you know the percentage of non-Jews in the group that the members here want to represent?
The witness, Prof. M. Echo: Anonymous
Adv. Dr. Tal Rotman: You don't know. You know that your sample includes only Jews?