Ramin Mirfakhraie vs. City of Irvine

Opposition

Cal. Super. - 4th Dist.February 28, 2014

OO 0 9 O N wn A W O N — p t f d e d Ww N = OO & S M A R T A T T O R N E Y S AT L A W C O S T A M E S A J k a WO OD RU FF , SP RA DL IN N N N N N N N N N N N = es em em co 3 ON Un B R A W N = O O X N Y Wn WOODRUFF, SPRADLIN & SMART, APC DANIEL K. SPRADLIN - State Bar No. 82950 dspradlin@wss-law.com ELECTRONICALLY FILED JEANNE L. TOLLISON - State Bar No. 238970 Superior Court of California, jtollison@wss-law.com Saunt of Crange 2p Anton Hoyleyard, suite LOG 09/26/2016 at 08:00:00 Aw osta Mesa, 2626-7 Clerk of the Superior C Telephone: (714) 558-7000 Bp firey a fk, Dey Ele Facsimile: (714) 835-7787 Attorneys for Defendant, Cross-Complainant and Cross-Defendant CITY OF IRVINE, a public entity SUPERIOR COURT FOR THE STATE OF CALIFORNIA FOR THE COUNTY OF ORANGE, CENTRAL JUSTICE CENTER RAMIN MIRFAKHRAIE, SHAHRIAR CASE NO.: 30-2014-00707952 MIRFAKHRAIE, MOJGAN MIRFAKHRALIE, and SEPIDEH ASSIGNED FOR ALL PURPOSES TO MIRFAKHRAIE, HONORABLE JAMES J. DI CESARE DEPARTMENT: C16 Plaintiffs, Vv. DEFENDANT CITY OF IRVINE’S OPPOSITION TO DEFENDANT CITY OF IRVINE, JEFFERSON JEFFERSON ENRIQUEZ’S MOTION ENRIQUEZ, and DOES 1 to 50, inclusive, IN LIMINE NO. 1 TO EXCLUDE JON LANDERVILLE’S TESTIMONY Defendants. REGARDING PERCEPTION REACTION TIME; DECLARATION OF JEANNE L. TOLLISON CITY OF IRVINE, a public entity, HEARING DATES PENDING: Cross-Complainant, Type: Trial Date: September 26, 2016 Vv. Time: 9:00 a.m. JEFFERSON ENRIQUEZ, and ROES 1 to ACTION FILED: February 28, 2014 50, inclusive, TRIAL DATE: September 26, 2016 Cross-Defendants. JEFFERSON ENRIQUEZ, Cross-Complainant, Vv. CITY OF IRVINE, and Moes 1 to 50, inclusive, Cross-Defendants. i i Leroi OF IRVINE’S OPPOSITION TO ENRIQUEZ’S MIL NO. 1 TO EXCLUDE LANDERVILLE TESTIMONY © 60 3 O N wn AH W O N = — p d p e d pe d Ww No = O & S M A R T re e. a A T T O R N E Y S AT L A W C O S T A M E S A W O O D R U F F , S P R A D L I N DN D o No n o NY NY No No — — — pt [— ~ AN wn EE N w N o —_— oO O c o ~ J [@ ) wn No co Defendant, Cross-Complainant, and Cross-Defendant CITY OF IRVINE (the “City”), a public entity, hereby opposes Defendant JEFFERSON ENRIQUEZ’s motion in /imine no. 1 to exclude the testimony of Jon Landerville regarding perception/reaction time, on the following grounds: 1. Enriquez’s vague and overbroad motion fails to specify what testimony will be cumulative. Under Kelly v. New West Fed. Sav. (1996) 49 Cal. App. 4th 659, 670, a motion in limine lacking factual support is improper as it would force a court to “rule in a vacuum.” 2. The matters to which Jon Landerville, MSME, P.E. and Joseph Cohen, Ph.D. will be testifying are not duplicative, as Mr. Landerville is testifying to perception reaction time as it formed the basis for his opinion from an accident reconstruction perspective and Dr. Cohen from the perspective of cognitive functioning and human factors. Both analyses aid the jury in deciding the factual issues in this case, particularly related to causation and reasonable due care. This motion is further based upon this notice, the attached Memorandum of Points and Authorities, the Declaration of Jeanne L. Tollison, and the exhibits attached thereto, all pleadings, documents and records on file herein, and upon such other and further oral and documentary evidence as may properly come before this Court. DATED: September 25 2016 WOODRUFF, SPRADLIN & SMART, APC 7 NNEL. TOLLISON Attorneys for Defendant, Cross-Complainant and Cross-Defendant CITY OF IRVINE, a public entity i . Ng OF IRVINE’S OPPOSITION TO ENRIQUEZ’S MIL NO. 1 TO EXCLUDE LANDERVILLE TESTIMONY CO 0 3 O N nn BR W N — mt h d p a WwW O N = O & S M A R T — E n A T T O R N E Y S AT L A W C O S T A M E S A W O O D R U F F , SP RA DL IN No No B o N o No N o [\ \® ] — — — p— — ~~ SN wn B W — OS NO oe = aN wn Do oo MEMORANDUM OF POINTS AND AUTHORITIES 1. INTRODUCTION On April 18, 2015, the City filed its written exchange of expert witness information and declaration. The City designated Jon Landerville, MSME, P.E. as its expert in accident reconstruction and Joseph Cohen, Ph.D. as its expert in human factors. As described in the designation, Mr. Landerville’s testimony includes his analysis and reconstruction of the subject accident and the causal factors involved. His testimony will refer to perception reaction time of the driver from the perspective of how the accident occurred. In contrast, Dr. Cohen’s opinion relates to perception and reaction from the perspective of liability and cognition. In other words, the human processing of the reaction time and specifically how it relates to due care of the pedestrian and the driver which contributed to the accident. Enriquez’s motion in limine fails to specifically identify which portions of Landerville’s testimony will be duplicative and/or cumulative of Cohen’s. The City can only presume that Enriquez is opposed to the entirety of the perception/reaction time analysis, regardless of how it is used in context. The City is entitled to put on evidence in support of its defense, and the cause of the accident is of critical importance. Each expert’s analysis plays a different role in the causation — from the perspective of an accident reconstruction and a human factors analysis — and assists the jury in deciding liability. Accordingly, Enriquez’s motion in [imine should be denied. 2. ENRIQUEZ’S MOTION IN LIMINE IS FATALLY VAGUE AND OVERBROAD AND FAILS TO IDENTIFY TESTIMONY THAT WILL BE DUPLICATIVE As a matter of law, “[m]otions in limine, to the extent that they rely upon a factual foundation, are no different than any other pretrial motion and must be accompanied by appropriate supporting documents. Absent an appropriate factual showing to support the motion, the court should not entertain the motion.” Kelly v. New West Fed. Savings (1996) 49 Cal. App. 4th 659, 671, fn. 3) Moreover, a party is entitled to present evidence as necessary to establish its defense. 1 CITY OF IRVINE’S OPPOSITION TO ENRIQUEZ’S MIL NO. 1 TO EXCLUDE LANDERVILLE TESTIMONY 1193305.1 A T T O R N E Y S AT L A W C O S T A M E S A W O O D R U F F , S P R A D L I N & S M A R T O© © 3 O N wn HK W N N N N N NN N N N N mm e m e m e t pe em e m e m p a 0 J O N wn A W N = o O N Y E W N Oo The general rule governing the Court’s exercise of discretion is set forth in Evans v. Industrial Accident Commission (1945) 71 Cal. App. 2d 244, 248-49, as follows: A party is entitled to call as many witnesses as he deems necessary to the establishment of his claim or defense, subject to the power of the court reasonably to limit the number who may be heard upon any one issue; ...." Even though the proffered evidence is deemed cumulative, so long as facts testified to by a party are not conclusively established or admitted, they are open to further proof. Here, Enriquez’s motion in imine to exclude duplicative expert testimony is vague and overbroad. In support of his motion, Enriquez attaches as an exhibit the City’s designation which lays out a description of what the experts will testify to. The designation shows no duplication of Mr. Landerville and Dr. Cohen’s testimony. In fact, the designation makes it clear that Mr. Landerville is to testify from an accident reconstruction perspective and Dr. Cohen is to testify to the human factors at play. Enriquez also refers to Mr. Landerville’s deposition but does not identify the portions of the testimony where an alleged duplication with Dr. Cohen would occur. Moreover, the City is entitled to present as many experts as they deem necessary, within reason, until the issues are conclusively established or admitted. Accordingly, Enriquez’s motion in [imine should be denied. 3. LANDERVILLE AND COHEN’S TESTIMONY IS NOT DUPLICATIVE OR CUMULATIVE AND THEREFORE NEITHER SHOULD BE EXCLUDED The City agrees with Enriquez that this case involves disputed liability where Mr. Enriquez’s perception reaction time at the time of the subject accident is a critical issue for the jury to decide. Indeed, the cause of the accident and whether the parties exercised due care are critical to the City’s defense. Mr. Landerville’s analysis regarding the driver’s perception and reaction time goes to understanding the cause of the accident as it is reconstructed for the jury. Dr. Cohen’s analysis of perception reaction time as related to human factors and how the parties responded cognitively at the time of the accident. 2 CITY OF IRVINE’S OPPOSITION TO ENRIQUEZ’S MIL NO. 1 TO EXCLUDE LANDERVILLE TESTIMONY 1193305.1 W O O D R U F F , S P R A D L I N & S M A R T A T T O R N E Y S AT L A W C O S T A M E S A OO 0 3 O N Ww» Bs W N = N O N N N N N N O N N m mm e m e m p m e m e e e m pe d pe 0 ~~ O N u i A W N = O O X I N N E W —= Oo Further, in his September 19, 2016 deposition, Mr. Landerville specifically stated that his testimony would not cross over into Dr. Cohen’s expertise, as follows: Q. I note the City of Irvine has designated Dr. Cohen as a perception reaction of human factor expert. Do you intend on testifying on human factors in this case? A. No. Just where there's overlap between the two of us, I may be asked questions or ole opinions, but I wouldn't do human factors. (Deposition of J. Landerville, 54:13-20, Exhibit A) The “overlap” to which Mr. Landerville refers may include perception reaction time. However, as discussed above, this field will be addressed by the two experts in different ways, each of which will assist the jury in making its factual conclusions as to causation and liability. Notably, Enriquez has designated Judson Welcher, Ph.D., P.E. as an expert in accident reconstruction expert and Anthony Stein, Ph.D. as an expert to testify to human factors. (Exhibit B and C) Presuming an overlap naturally exists in those fields related to perception and reaction time, such duplication would apply to Enriquez’s experts as well. Should the Court be inclined to exclude the testimony of the City’s experts on this issue, the City similarly requests that the Court exclude such testimony as to all of the parties’ experts. 4, IN THE ALTERNATIVE, THE COURT SHOULD GRANT A 402 HEARING To the extent that the Court is inclined to find that Mr. Landerville and Dr. Cohen’s testimony concerning perception reaction time may be duplicative, the City requests a 402 hearing. Evidence Code section 402 requires that a proper foundation be laid before evidence is presented to the finder of fact. The Court has the authority to exclude evidence when the probative value is compromised or is outweighed by any resulting prejudice. (Evid. Code § 352). In lieu of reciting hours and hours’ worth of deposition testimony and subsequently attaching voluminous deposition transcripts, a 402 hearing would allow the Court to determine that Mr. Landerville and Mr. Cohen’s testimony 3 CITY OF IRVINE’S OPPOSITION TO ENRIQUEZ’S MIL NO. 1 TO EXCLUDE LANDERVILLE TESTIMONY 1193305.1 OW 0 3 O&O wn hs W N = p t p d pe d w No — = & S M A R T A T T O R N E Y S AT L A W C O S T A M E S A f — + > W O O D R U F F , S P R A D L I N I N o No No No DN No nN a om e i jy —y ~ ] [@ ) wD ~~ Ww N o —_ << © o o ~ J [@ ) wn No oo related to perception reaction time is not duplicative or cumulative, and that the testimony of each expert will assist the jury in deciding liability. 5. CONCLUSION Based upon the foregoing, the City respectfully request that this Court deny Enriquez’s motion in limine no. 1 to exclude the testimony of Jon Landerville, regarding perception/reaction time, as the testimony is not duplicative of Joseph Cohen’s and will aid the jury in making a factual determination regarding the liability issues in this case. DATED: September 25, 2016 WOODRUFF, SPRADLIN & SMART, APC ARIEL K. SPRADEIN ane L. TOLLISON y orneys for Defendant, Cross-Complainant and Cross-Defendant CITY OF IRVINE, a public entity 4 CITY OF IRVINE’S OPPOSITION TO ENRIQUEZ’S MIL NO. 1 TO EXCLUDE LANDERVILLE TESTIMONY 1193305.1 OO 0 9 S N Ln BAR A W N = i pe d e d pe WwW NN = O & S M A R T A T T O R N E Y S AT L A W C O S T A M E S A po d + W O O D R U F F , SP RA DL IN N o [\ ) No No No N o No nN — pt — pt [— ON wn B W ND = SS © oo SN Wn No oo DECLARATION OF JEANNE L. TOLLISON I, JEANNE L. TOLLISON declare as follows: 1. [ am an associate with the law firm of Woodruff, Spradlin & Smart, counsel of record in this action for Defendant, Cross-Complainant and Cross-Defendant CITY OF IRVINE (the “City”), a public entity. 2 Attached hereto as Exhibit A is a true and correct copy of excerpts from the Deposition Transcript of Jon Landerville. 3. Attached hereto as Exhibit B is a true and correct copy of Defendant Enriquez’s witness designation identifying Judson Welcher as an expert in accident reconstruction. 4. Attached hereto as Exhibit C is a true and correct copy of Defendant Enriquez’s supplemental witness designation identifying Anthony Stein as an expert in human factors. I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct of my own personal knowledge except as to matters stated to be based upon information and belief, and as to those matters I am informed and believe that they are true and correct. Executed on September 25. 2016, at Costa Mesa, California. 1 CITY OF IRVINE’S OPPOSITION TO ENRIQUEZ’S MIL NO. 1 TO EXCLUDE LANDERVILLE TESTIMONY 1193305.1 © 0 N N O N n n BA W N — p d e d fe d WwW NN == OO & S M A R T A T T O R N E Y S AT L A W Ju na d + WO OD RU FF , SP RA DL IN C O S T A M E S A N R N N N N N N = m e e NN ON Un R W = O O N S Y No co PROOF OF SERVICE STATE OF CALIFORNIA, COUNTY OF ORANGE I am over the age of 18 and not a party to the within action; I am employed by WOODRUFF, SPRADLIN & SMART in the County of Orange at 555 Anton Boulevard, Suite 1200, Costa Mesa, CA 92626-7670. On September ¥ , 2016, I served the orepoimg documents described as: DEFENDANT CITY OF IRVINE’S OPPOSITION TO DEFENDANT JEFFERSON ENRIQUEZ’S MOTION IN LIMINE NO. 1 TO EXCLUDE JON LANDERVILLE’S TESTIMONY REGARDING PERCEPTION REACTION TIME; DECLARATION OF JEANNE L. TOLLISON O by placing the true copies thereof enclosed in sealed envelopes addressed as stated on the attached mailing list; O (BY MAIL) I placed said envelope(s) for collection and mailing, following ordinary business practices, at the business offices of WOODRUFF, SPRADLIN & SMART, and addressed as shown on the attached service list, for deposit in the United States Postal Service. I am readily familiar with the practice of WOODRUFF, SPRADLIN & SMART for collection and processing correspondence for mailing with the United States Postal Service, and said envelope(s) will be deposited with the United States Postal Service on said date in the ordinary course of business. (BY ELECTRONIC SERVICE) I caused the above-referenced document to be transmitted to the offices of LARI-JONI & BASSELL, LLP and the LAW OFFICE OF. CLEIDIN Z. ATANOUS via electronic mail whose email addresses are as stated on the attached Service List. Ol (BY OVERNIGHT DELIVERY) I placed said documents in envelope(s) for collection following ordinary business practices, at the business offices of WOODRUFF, SPRADLIN & SMART, and addressed as shown on the attached service list, for collection and delivery to a courier authorized by ; to receive said documents, with delivery fees provided for. T am readily familiar with the practices of WOODRUFF, SPRADLIN & SMART for collection and processing of documents for overnight delivery, and said envelope(s) will be deposited for receipt by on said date in the ordinary course of business. | (BY FACSIMILE) I caused the above-referenced document to be transmitted to the interested parties via facsimile transmission to the fax number(s) as stated on the attached service list. O (BY PERSONAL SERVICE) I delivered such envelope(s) by hand to the offices of the addressee(s). x (State) I declare under penalty of perjury under the laws of the State of California that the above is true and correct. Executed on September 2%. 2016 at Costa Mesa, California. J 1 # } Diane Castillo 1193305.1 Oo 0 N N O N nm BA R W N = f e pe pe Ww NN = O & S M A R T r k Eu N A T T O R N E Y S AT L A W C O S T A M E S A W O O D R U F F , SP RA DL IN No [\ ®) N o No No N o No NY p— pd pt p— p— ~ AN [9 ] E E N Ww b o a oO \ O c o ~ J aN w n Bo co RAMIN MIRFAKHRALIE, et al. v. CITY OF IRVINE, et al. ORANGE COUNTY SUPERIOR COURT, CENTRAL JUSTICE CENTER CASE NO.: 30-2014-00707952 ASSIGNED FOR ALL PURPOSES TO: HONORABLE JAMES J. DI CESARE DEPARTMENT: C16 SERVICE LIST Torsten M. Bassell, Esq. Nicole Lari-Joni, Esq. LARI-JONI & BASSELL, LLP 10940 Wilshire Boulevard, Suite 1250 Los Angeles, CA 90024 Telephone: (310) 803-9088 Facsimile: (310) 803-9084 Email: torsten@ljblaw.com Cleidin Z. Atanous, Esq. LAW OFFICE OF CLEIDIN Z. ATANOUS Brea Park Centre 500 S. Kraemer Blvd., #205 Brea, CA 92821 Telephone: (714) 528-8226 Fax: (714) 528-8227 Email: czatanous@yahoo.com 9/14/16 1193305.1 Attorneys for Plaintiffs RAMIN MIRFAKHRAIE, SHAHRIAR MIRFAKHRAIE, MOJGAN MIRFAKHRAIE, and SEPIDEH MIRFAKHRIAE Attorney for Defendant and Cross- Defendant JEFFERSON ENRIQUEZ EXHIBIT “A” o r s Ww N O 10 11 12 13 14 15 16 17 18 19 20 21 22 2.3 24 25 Jon B. Landerville, MSME, PE SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF ORANGE-CENTRAL JUSTICE CENTER RAMIN MIRFAKHRAIE; SHAHRIAR ) MIRFAKHRATE; MORGAN MIRFAKHRAIE; ) “AND SEPIDEH MIRFAKHRAIE, ) ) Plaintiffs, ) ) VS. ) ) CITY OF IRVINE; JEFFERSON ENRIQUEZ; and DOES 1 to 50, inclusive, Defendants. ) ) 2) ) ) Videotaped deposition of JON B. LANDERVILLE, MSME, PE, taken on behalf of the Defendants, at 2862 Columbia Street, Torrance, California 90503, commenci ng at 9:13 a.m., on Monday, September 19, 2016, before Gloria A. Apiecionek, CSR 12776, a Certified Shor thand Reporter within and for the State of California. CORNERSTONE REPORTING (714) 529-3943 TEL (714) NO. 30-2014-00707952 529-3982 FAX Page 2 Jon B. Landerville, MSME, PE 1 BY MR. ATANOUS: 2 0. Correct? 3 A. From 50. Yes. 4 Qs At two seconds, perception reaction time at the 5 moment when the SUV applies its brakes, if the Toyota 6 starts applying its brakes, it will come to a stop at 270 7 feet distance? 8 Bx Two seconds? 9 Q. At two seconds. 10 A. That sounds about right. I mean, that's a long 11 perception reaction time, but yes. That would calculate 12 out to 270. 13 Q. I note the City of Irvine has designated 14 Dr. Cohen as a perception reaction of human factor 15 expert. 16 Do you intend on testifying on human factors in 17 | this case? 18 A. No. Just where there's overlap between the two 19 of us, I may be asked questions or give opinions, but I 20 wouldn't do human factors. So... 21 Q. Right. I just want to make sure, though, Zt because you're using different perception reaction times. 23 I want to see if you intend on offering any 24 testimony, any opinion as to what you believe the 25 perception reaction time was given the conditions of the CORNERSTONE REPORTING (714) 529-3943 TEL (714) 529-39 82 FAX Page 54 S w DN ~~ o o Ou 10 Ll 12 13 14 15 16 17 18 42 20 2. 22 23 24 25 Jon B. Landerville, MSME, PE CORNERSTONE REPORTING (714) I, GLORIA A. APIECIONEK, CSR 12776, a Certified Shorthand Reporter within and for the State of california, do hereby declare: That pursuant to Code of Civil Procedure 2093 (b), I administered the oath to the deponent; That the foregoing deposition was taken before me at the time and place set forth and was taken down by me in shorthand and thereafter transcribed into typewriting under my direction and supervision; That the foregoing deposition is a full, true, and correct transcript of my shorthand notes so taken. I further certify that I am neither . counsel for not related to any of the parties to said action nor in any way interested in the outcome thereof. I declare under penalty of perjury this day of , 2016, that the foregoing is true and correct. Gloria A. Apiecionek Certified Shorthand Reporter (714) 529-3982 FAX Page 203 EXHIBIT “B” 10 11 12 13 14 15 16 17 18 18 20 21 22 23 24 25 26 27 28 CLEIDIN Z. ATANOUS, ESQ., , (State Bar No.: 189149) LAW OFFICE OF CLEIDIN Z. ATANOUS 500 8. Kraemer Boulevard Suite 205 Brea, California 92821 PH: (714) 528-8226 / FAX: (714) 528-8227 Attorney for: Defendants, JEFFERSON ENRIQUEZ File No.: 14-0703e SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF ORANGE RAMIN MIRFAKHRAIE, SHAHRAIR MIRFAKHRAIE, MOJGAN MIRFAKHRAIE, and SEPIDEH MIRFAKHRAIE Plaintiff(s), Vs. CITY OF IRVINE, JEFFERSON ENRIQUEZ, and DOES 1 to 50, inclusive, Defendant(s). CASENO: 30-2014 00707952 WRITTEN EXCHANGE OF REQUIRED EXPERT WITNESS INFORMATION AND EXPERT DECLARATION (C.C.P. §2034.210, et al.) TRIAL DATE: 6/1/15 TO: ALL PARTIES AND TO THEIR ATTORNEYS OF RECORD: PLEASE TAKE NOTICE that Defendants, JEFFERSON ENRIQUEZ offer the following individual as an expert ready to testify at time of trial: 1. Weston Stewart Pringle, Traffic Engineer, or other qualified individual at Weston Pringle Traffic & Transportation Engineering, 44 Richmond Hill, Laguna Niguel, California 92677; (949) 443-5049. 2, Judson 1B. Welcher, PhD. Biomechanical Engineer/Accident Reconstructionist or other qualified individual at Biomechanical Research & Testing, LLC located at 2201 N Lakewood Blvd., Suite 1285, Long Beach, California 90815; (562) 494-4407. Deposit Signal Hill, California 90755. ions taken at: 1329 E 28" Street, 10 11 12 13 14 15 16 17 18 19 20 21 24 23 24 25 26 27 28 Defendants, also reserve the right to call any and all of the following expert witnesses at the time of trial: 1) 2) 3) 4) 5) Any and all individuals designated as expert by any other party, whether ot not a party at the time of trial; Any and all of plaintiff's healthcare providers, including treating physicians, medical doctors, or other specialists who in any way treated decedent or reviewed h is medical records. Defendants reserve the right to designate additional or supplemental expert witnesses, as well as expert witnesses for purpose of rebuttal as authorized by CCP §2034. Defendants hereby reserve the right to augment, supplement, modify or otherwise amend the above referenced list of expert witnesses. Defendants incorporate by reference and makes a part herein any and all experts identified by all other parites herein and therfore reserves the right to call any experts designated by any other party. DATED: April 13, 2015 LAW OFFICES OF CLEIDIN Z. ATANOUS 10 11 12 13 14 15 16 7 18 19 20 21 22 23 24 25 26 27 28 EXPERT WITNESS DECLARATION 1, Cleidin Z. Atanous, Esq. , say and declare: L. I am an attorney duly licensed to practice law before the Courts of the State of California, and am associated with the Law Offices of Cleidin Z. Atanous, attorneys of record for defendant, JEFFERSON ENRIQUEZ . I have personal knowledge of the matter set forth in this declaration, and would testify thereto if called as a witness. 2. Defendant, JEFFERSON ENRIQUEZ , hereby gives notice pursuant to C.C.P. §2034, that he intends to call a qualified individual at Weston Pringle, Traffic & Transportation Engineering. A. Said expert witness will qualify as a Traffic and Transportation Engineer. B. Said expert witness will testify concerning issues including but not limited to traffic conditions, planning, and operations. C. Said expert witness has agreed to testify at the trial. D. Said expert witness will be sufficiently familiar with the pending action to submit to a meaningful oral deposition concerning the specific testimony, including any opinion and its basis, that he is expected to give at trial. BE. Said expert's expert fee for deposition will be $ 350.00per hour, with the deposition to take place in his office. ¥ Attached hereto is a true and correct copy of Weston Pringle's curriculum vitae. 3. Defendant, JEFFERSON ENRIQUEZ , hereby gives notice pursuant to C.C.P. §2034, that he intends to call JUDSON B. WELCHER, PH.D., P.E., whose address and telephone information is 2201 N Lakewood Blvd., Suite 1865, Long Beach, California 908135, as an expert witness at Trial. A. Said expert will qualify as a Bio-mechanical engineer and accident reconstruction expert. B. Said expert will be sufficiently familiar with the pending action to submit to a meaningful deposition concerning the specific testimony he is expected to 3 10 1 12 13 14 15 16 17 18 15 20 21 22 23 24 25 26 27 28 give at trial, including any opinions and its basis. C. Said expert is expected to testify regarding traffic accident, dynamics of the vehicles forces upon the vehicle and body of decedents and mechanism of any injuries to decedent; relative positions of the vehicles and decedent, accident and injury causation, general accident reconstruction, human factors, and liability in this matter. Said expert witness has agreed to testify at the trial. td Said expert witness will be sufficiently familiar with the pending action to submit to a meaningful oral deposition concerning the specific testimony, including any opinion and its basis, that he is expected to give at trial. F. Said expert's expert fee for deposition will be $400.00 per hour, and the deposition is requested to take place at 1329 E 28% Street, Signal Hill, California 90755, unless otherwise agreed. G. A copy of his Curriculum Vitae is attached hereto. I declare under penalty of perjury pursuant to the laws of the State of California, that the foregoing is true and correct. Dated this A day of Ppa | __ 2015, at Brea, California. — ae — pp TERT OUS, ESQ, OO o o 3 O&O wv HS» WwW N = N O N O N N O N N O N N N m m e s e d e d pe 0 3 O N Lh bh W N R = SD WO 0 N Y D B R N e Oo PROOF OF SERVICE (10134, 2015.5 C.C.P.) STATE OF CALIFORNIA ss. MIRFAKHRAIE v CITY OF IRVINE/ENRIQUEZ COUNTY OF ORANGE ) I am employed in the County of Orange, State of California, I am over the age of eighteen years and not a party to the within entitled action; my business address is 500 S. Kraemer Boulevard, Suite 205, Brea, California 92821. I am readily familiar with the business practice at my place of business for collection and processing of correspondence for mailing with the United States Postal Service, Correspondence so collected and processed is deposited with the United States Postal Service that same day in ordinary course of business. On this date, I served the forgoing WRITTEN EXCHANGE OF REQUIRED EXPERT WITNESS INFORMATION AND EXPERT DECLARATION (C.C.P. §2034.210, et al.) on the interested parties in this action, by placing a true copy thereof, enclosed in a sealed envelope, addressed as follows: Torsten N. Bassell, Esq. Nicole Lari-Joni, Esq. LARI-JONI & BASSELL, LLP 12400 Wilshire Boulevard, Suite 1050 Los Angeles, CA. 90025 Fax: (310) 803-9084 Attorneys for plaintiffs Daniel K. Spradlin, Esq. WOODRUFF, SPRADLIN & SMART 555 Anton Boulevard, Suite 1200 Costa Mesa, CA 92626-7670 Fax: (714) 835-7787 Attorney for defendant, cross-complainant, City of Irvine (XX) (BY MAIL) I caused such envelope with postage thereon fully prepaid at my place of business to be placed in the United States mail at Brea, California. 0 (BY FACSIMILE) I caused the attached document to be transmitted via facsimile to the number(s) listed above, from fax number (714) 528-8227. () (BYPERSONAL SERVICE) I caused such document to be delivered by hand to the office of the addressee(s). I declare under penalty of petjury under the laws of the State of California that the above is true and correct. rd Dated: APRIL 13, 2015 14-0703e EXHIBIT A z SE L > [ 3 j m Weston Pringle TRAFFIC & TRANSPORTATION ENGINEERING WESTON STEWART PRINGLE Firm Principal - Registered Professional Engineer, State of California, Civil and Traffic Enginee ring. - Professional Traffic Operations Engineer - Honorary Member, Institute of Transportation Engineers and Life Member, American Society of C ivil Engineers. Institute of Transportation Engineers Activities: International Director; President, Disirict 6; Presiden t, Southern California Section; Delegate, Program Development Conference; Member, Special Publications Committee; Member, International Admissions and Transfers Committee; Senior Editor, “Technical Notes"; Member, Parking Facilities for I ndustrial Plants Commitiee; Member, Traffic Improvement Data Collection Guidelines Committee; Member, Traffic Characteristics and Consi derations for Tomorrow's Airports Committee; Member, Impact Analysis of Proposed New Developmént Committee; Member , Employment Center Parking Facilities Committee; Member, Guidelines for Tr vansportation Impact Assessment of Proposed New D evelopment Committee and Chairperson, Implementing Road Safety Audits in the Unites States Committee. Mr. Pringle received the Burton W, Marsh Award for Distinguished Service from the Ins titute of Transportation Engineers in 2 000. This © qward was in récoghition of long-term and continuing oulstanding contributions. In 2004, he received the Lifetime Achievement Award from District 6 of the Institute of Transportation Engineers. In 2014, the Board of Direc tion of the Institute of Transportation Engineers elected him a Honorary Member, the highest recognition of professional accomplish ment. Mp. Pringle has had avaried experience in both the planning and operational fields of traff ic engineering. Some of the projects with which he has been involved include: TRANSPORTATION PLANNING - Circulation and Transportation Elements of General Plans for cities; freeway location & fmpdct studies; @ecess, circulation, and parking systems for industrial plants, airports, central business districts, colleges, shopping centers, and other developments; traffic impact analyses for Evvironmental I mpact Reports. | TRAFFIC OPERATIONS - TOPICS areawide plan studies Jor eleven citles; traffic signal and traffic signal system designs; parking studies; street and parking lot lighting designs; school safety programs; acc ess, circulation, and parking studies Jor commercial, residential, and public developments. : Mp, Pringle has also provided traffic engineering services related to litigation for both plaintiff and defense in approximately 1500 cases. This involvement has inchided both deposition and court testimony. " : My. Pringle has served as a Subject Matter Exper! for the California Board of Registrat ion, for Professional Engineers & Land, Surveyors in the field of traffic engineering. This has included the preparation and review of test questions and the evaluation of test materials, EDUCATIONAL QUALIFICATIONS: California State University - Fresno, Bachelor of Science i n Civil Engineering, 1960; Certificate, Municipal Public Works Administration; Guest Lecturer in Transportatio n and Traffic Engineering, California State Polytechnic University, Pomona,; Instructor, Fundamentals of Téiffic Engineering, University of California, Institute of Transportation Studies. From 1960, Mr. Pringle has been Civil Engineering Assistant, City of West Covin a; Assistant, Traffic Engineer, Traffic Engineer, and Associate Civil Engineer, City of Downey; Principal Engineer, Wilbur Smith and Associates , Consulting Engineers, Los Angeles; Vice President, Lampman and Associates, Inc., Consulting Engineers, Pomona; Vice President, Crommelin-Pringle and Associates, Inc, Placentia; and owner of Weston Pringle & Associates since 1976. | 44 Richmond Hill = Laguna Niguel, CA 92677 = 949/443-5049 = Fax 94 9/443-5049 EXHIBIT B CURRICULUM VITAE JUDSON B. WELCHER, Ph.D. Biomechanical Engineer / Accident Reconstructionist Biomechanical Research & Testing, LLC Phone (562) 494-4407 2201 N. Lakewood Blvd, Fax (562)494-4412 Suite 1865 E-mail: jwelcher@brteng.com Long Beach, California 90815 Tax LD. No.; 33-065-0923 EDUCATIONAL BACKGROUND Aug 9, 2011 University of Southern California, Los Angeles, California Ph.D. Degree in Biomedical Engineering, Dissertation “Development, Validation and Testing of a New Sensor Array for Intra-Articular Pressure Measurement: In-Vitro Human Lumbar Spine Intra-Axticulat Facet Testing,” January 2003-April 2005 USC Orthopaedic Research Laboratory, Departments of Orthopaedic Surgery (Researcher) July 2005-January 2010 Biomechanics and Spinal Research Laboratory, Institute for Spinal Disorders Cedars-Sinai Medical Center (Stipend Student) Dec. 2001 University of Southern California, Los Angeles, California Master of Science Degree in Biomedical Engineering. Thesis “Whiplash Associated Disorders: Related Anatomy, Biomechanics of Injury, and the Relationship between Injury Potential and Automotive Seat Design.” June 2000 Vetronix Corporation, Santa Barbara, California Certified Crash Data Retrieval (CDR) System Operator, Recertified August 11-12, 2003, Feb. 1995 Accreditation Commission for Traffic Accident Reconstruction (ACTAR), Denver, Colorado Accredited Traffic Accident Reconstructionist, registration number 628 1990 California Polytechnic State University, San Luis Obispo, California Bachelor of Science Degree in Mechanical Engineering EMPLOYMENT SUMMARY Oct, 1994 - Present Biomechanical Research & Testing, LLC, Long Beach, California Biomechanical Engineer and Accident Reconstructionist/Principal Responsible for the analysis of injury-causing accidents and accident reconstruction. This includes vehicle inspections, accident reconstruction and necessary biomechanical engineering calculations. Performs biomechanical testing to determine occupant response to various types of accidents and forces, Conducts fully instrumented tests in which human subjects are used (has conducted over 500 instrumented vehicle impact tests), Data collected includes acceleration, high speed film/video, and electromyography (EMG). Has evaluated bumper, restraint system and seat design/response to impact. Conducts ongoing research to evaluate human tolerance and injury mechanisms associated with accidents. Performs biomechanical analyses of various events for purposes of litigation, including impact reconstruction and occupant force exposure and injury potential, Provides forensic consultation for amusement park incidents involving the evaluation of occupant force exposure and injury potential. Consults with theme park developers and amusement patk operators to test and determine vehicular and biodynamic response of various rides and attractions. Conducts fully | instrumented human subject testing of amusement park attractions, Mas tested roller coasters, motion platforms, water rides, go-kart/bumper cars, and video arcade attractions for purposes of ride evaluation, design and development, Currently serves on the ASTM F-24 committes to develop biodynamic standards for testing and evaluation of amusement rides. Judson B. Welcher, Ph.D. Page 2 Curriculum Vitae 6/22/09, 1/28/10 1996 — Dec, 2001 Sept. 1990 - Oct, 1994 June 1989 - Sept. 1989 Clark Training Center, Law Enforcement & Public Safety Training Instructor — Traffic Collision Investigation (TCI) — Reconstruction (POST certified) Teach a half day course on an “Introduction to Biomechanics — Occupant Kinematics and Collision Trauma Biomechanics (injury).” Topic covered include: Definitions of Occupant Kinematics and Biomechanics, Occupant Protection Systems, Occupant Kinematics in Frontal, Reat, Side (near and far), Rollovers and Other Crashes, Occupant Simulation Models for Occupant Kinematics, and Sources of Information and References. Texas A&M University, Texas Engineering Extension Service, College Station, Texas Assistant Adjunct Professor/Instructor Taught (beginning in 1999) “Collision Tranma Biomechanics” courses periodically through the year. Taught "Analysis of Low-Speed Collisions" courses periodically through the year. Blodynamics Engineering, Inc., Pacific Palisades, California: Biomechanical Engineer Responsible for the biomechanical analysis of injury-causing accidents, This included evaluation of accident reports, witness statements and medical records, as well as vehicle inspections, accident reconstruction and engineering calculations. Performed biomechanical testing and reseatch to determine human response to various events, Baxter Healthcare Corporation Edwards Division, Irvine, California: Associate Engineer Responsible for a root-cause analysis of product failure in an 8F Cardiac Monitoring Catheter. This involved a thorough examination of all the steps of the manufacturing process, with special emphasis on biological compatibility, material selection and processing time. Supervised the inspection of raw fiber optic cables, including training in light dispersion analysis. Constructed and qualified a test fixture for a Right Heart Ejection Fraction Catheter. CONTINUING EDUCATION May 12-16, 2013 March 15-16, 2013 Sept. 28, 2012 Tune 4-7, 2012 March 10, 2012 February 6-9, 2012 ARC Network & Collision Safety Institute (ARC-CSI) Crash Conference 2013: Topics included: Advancement in Forensic Photography for Crash Investigation, Braking Systems for Passenger Cars and Light Trucks, Differentiating Potentially Causal Pre-crash Component Damage from Crash Damage, Accuracy and Utility of Crash Triggered Video and Data Recorders for Accident Reconstruction, Crush Coefficients Process and Pitfalls, Introduction to Energy-Review, Motorcycle Case Study and New Technology, Further Developments Regarding the Dynamic Modeling of Motor Vehicle Collision Response using the SDOF Approach, How a Large Metropolitan Transit Agency Investigates Collisions (Transit Bus Collision Investigation), and Determination of Vehicle Orientation at Ground Contact for Rollover Accidents, Southwestern Association of Technical Accident Investigators (SATAL Seminar: Topics included: consumer GPS, traffic enforcement cameras, surveillance cameras, and force balance in accident teconstruction, Toyota EDR Delta V anomalies, post-collision speedometer readings, and forensic seat belt analysis, Southwestern Association of Technical Accident Investigators (SATAI) Seminar: Topics included commercial motor vehicle ait brake systems, and methods and myths of commercial motor vehicle collision investigations. ARC Network & Collision Safety Institute (ARC-CSI) Crash Conference 2012: Tn addition to full scale crash testing, industry experts spoke on a variety of topics including Hybrid and Electric Vehicle Technology and Its Relationship to EDR Data, Scat Belt Analysis, Reconstruction and biomechanical analysis of Low Speed Coltisions, Highway Design, and Using ECM Diagnostic Data in Crash Reconstruction, Southwestern Association of Technical Accident Investigators (SATAL) Seminar: Topics included: sudden acceleration incidents, data acquisition systems, transportation engineering, and bicycle collision reconstruction, ARAS 360; Advanced three dimensional computer modeling for accident reconstruction, Topics included getting vehicles to move, adding crush, terrain mapping, exporting animations, and momentum applications. Judson B. Welcher, Ph.D. Page 3 “Curriculum Vitae May 23-26, 2011 ARC Network & Collision Safety Institute (ARC-CSI) Crash Conference 2011: Tn addition to full scale crash testing, industry experts spoke on a variety of topics including computer aided accident reconstruction and simulation, utilizing global positioning systems (GPS) in accident reconstruction, human factors considerations, effect of aftermarket bumper push-bats on supplemental restraint systems, momentum applications, automobile pedestrian collisions, occupant dynamic simulations, and roadway design, Sept 27-29, 2010 National Crash Analysis Conference (NCAC): A three day conference combining full scale testing and technical presentations about current topics in automotive safety, Session topics included: The Role of the National Motor Vehicle Crash Causation Study in Highway related Data Analysis, Sensitivity Study of Vehicle Rollovers to Various Initial Conditions & Jordan Rollover System & Un~Constrained Model Comparison Finite Element Model Based, Influence of NCAP Crash Testing on Passenger Vehicle Design, Rollover Rates and Severity — Dynamic Testing Results, NCAP Rating for Far-side Occupant Protection, Overview of TFHRC & FOIL Federal Highway Administration, Accident Reconstruction Considerations in Rear and Side Impacis, Nature of Natrow Overlap Frontal Collisions: FLEE and FREE, NCAC Overview, June 16-19, 2010 American Society of Mechanical Engineers (ASME), Summer Bioengineering Conference: One of the premier Bioengineering conference events of the year. Session topics included: Accident and Injury, Injury Biomechanics, Joint, Spine, Cell and Tissue Transport, Tissue Engineering, Cardiac Mechanics, Biomechanics of Growth and Remodeling, Cardiovascular Design and Devices, Musculoskeletal Engineering, Vascular Mechanics, Mechanical Properties of Musculoskeletal Soft Tissues, Rionanotechnology in Diagnosis and Treatment, Simulation in Human Movement, Biologic Effects on Musculoskeletal Soft Tissues, Structural Mechanics of Bone, Cerebral Aneurysm, and Orthopedic Design and Devices, May 24-27, 2010 ARC Network & Collision Safety Institute (ARC-CSI) Crash Conference 2010: Eleven industry experts spoke on various technical topics, including; Devices for Accident Reconstruction Testing, PDOF and Angle Development Over Time, Using Motion Equations in Accident Reconstruction, Automotive Filament Analysis, Conspicuity Issues, Forensic Commercial Motor Vehicle Inspection, Motorcycle Accident Reconstruction, Impact Speed and Post Collision Speedometer Readings, Speed and Acceleration from Video Frames, GPS the Overlooked EDR, and Low Speed Crash Analysis. In addition, this year we held three workshops that focused on using the information obtained during the crash testing and integrating it with real-world accident reconstruction techniques. April 28-30, 2010 PC-Crash Special 3-day Workshop: The special 3-day workshop includes an accelerated essentials survey on the first day, followed by two days of advanced special topics, Topics included: «Get it up and running, Starting a project, Get the vehicle to move, Get vehicles to crash, Scenes, Seeing what's going on, 3D vehicles, Suspension, ABS, The trajectory model, 3D scenes, Tire models, 3D collisions, Collision optimizer, Next level animation, Inverse kinematics, The trailer model, The multtbody model ~ Theory, Multibody pedestrians, The rollover model (a multibody vehicle), Exporting data using DDE — getpceerashdata xls. Nov. 6-7, 2009 Southwestern Association of Technical Accident Investigators (SATAI); Training course in aftermarket components and the EDR, EDR discrepancies, stiffness data research and calculations, experts and lawyers in the courtroom, June 1-4, 2009 ARC Network & Collision Safety Institute (ARC-CSI) Crash Conference 2009: Industry experts spoke on various technical topics including; Death Investigation and Their Psychological Effect on the Police Officers, Estimations of Vehicle Speed and Trajectory Based on Video from a Vehicle-Mounted Camera, Commercial Vehicle Dynamics, Evaluation of Driver Response at Night, Optics, Lighting and Visibility for the Forensic Investigator, Using Critical Speed Formula on Yaw Marks Leading to Rollover, Air Brake Basics, Braking Efficiencies of Motorcycles by Experienced Riders, Practical Applications of Accelerometer data, and Commercial Vehicle Air Brake Performance, May 1-3, 2009 Photomodeler Collision Investigation: Three day course that covered a wide range of topics such as proper planning and photography methods, using the basic tools, export and measure, camera calibration, standard procedures for field work, using advanced tools, and working with complex projects. Judson B, Welcher, Ph.D. Page 4 Curriculum Vitae Aug, 5-9, 2008 Jan. 20-22, 2008 Tune 4-7, 2007 March 1-3, 2007 Tune 5-8, 2006 March 31-April 1, 2006 February 27, 2006 February 13-14, 2006 ARC Network & Collision Safety Institute (ARC-CSI) Crash Conference 2008: Topics covered include: New Vehicle Technologies and Their Relationship to Proper Crash Reconstruction Techniques, Close-Range Photogrammetry as a Routine Accident Reconstruction Tool, Judkin’s Law and Its Application to Human Factors of Collision Avoidance and Witness Recall, Motorcycle Crash Analysis, Pedestrian Crash Analysis and Excel Program Workshop, Current Trends in Pedestrian Crash Analysis, Video Applications in Crash Reconstraction, Rollover Workshop, Airborne Analysis and Rotational Mechanics, Momentum and Energy, and Reconstruction of PIT Crashes, World Congress of Neck pain 2008: Present the latest scientific research and findings of evidence- based systematic reviews, on the cause, prevention, diagnosis, treatment and societal iapact of neck pain and associated functional disability. The Program Format includes plenary, break-out sessions, panels, postet sessions, question and answer sessions. Jointly sponsored by the Canadian Institute for the Relief of Pain and Disability and the American College of Occupational and Environmental Medicine, ARC Network & Collision Safety Institute (ARC-CSI) Crash Conference 2007: Topics covered include: Accelerometer Sampling Rates, Two Vehicles In-Three Pieces Out, Airbag Related Injuries, Angular Velocity Analysis of SUV Collisions Using PC Crash, Low Speed Crash Tests, Eutopean Reconstruction Techniques, Factors impacting Pre-Crash Data, Hit & Run-~Closing the Loop, Human Factors-Beyond Perception Reaction Time, Investigating Nighttime Pedestrian Collisions, Investigating Snowmobile Crashes, Seat Belts, and Traffic Reconstruction at Traffic Signal Intersections. Cedars-Sinai Medical Center Institute for Spinal Disorders — Sixth Annual Symposium on Current Concepts in Spinal Disorders 2007; Topics coveted included: surgical indications for interventional injections, therapeutic nerve blocks, discography, multimode intrasurgical imaging of the spine, biology of disc repair (BMP-2, BMP-7, GDE-5), biology and clinical relevance of the nucleus pulposus, stem cell based spinal fusion, biomechanics of artificial disc replacement (ADR) versus fusion (lumbar, cervical, crosslinking, biomechanics of non-fusion devices, imaging based spine biomechanics), lumbar total disc (TDR) replacement clinical data, motion preservation, deformities, cervical TDR, posterior non-fusion technologies, and innovative technologies. ARC Network & Collision Safety Institute (ARC-CSI) Crash Conference 2006: Topics covered included: Lower extremity injuries, collision speed analysis of angular collisions involving secondary impacts, simulations, motorcycle brakes, braking tests and sources of information, rollover tests of a 1991 Ford Explorer, crash data retrieval-legal brief, pictometry in crash scene mapping, deceleration rates for modern vehicles, principle direction of force, vehicle dynamics resulting from curb impacts. The Essential Soft Tissue Injury Conference: Topics covered included: The latest research on injury thresholds; The death of the low velocity impact defense, the biomechanics of whiplash: the latest evidence surrounding soft tissue injuries, orofascial pain, the sacroiliac join, causes, consequences and treatment of labral and rotator cuff injury, traumatic brain injury, neuroimaging, and centrally mediated pain and patient/client with no objective findings. Diversified Technical Systems (DTS) Principles of Dynamic Data Collection: Data Collection Fundamentals, Sensors, Noise Reduction, Grounding and Shielding, Data Analysis and Trouble Shooting. Crash Data Retrieval User's Conference: Topics covered at the conference included: Vetronix CDR system updated, CDR as a tool for intelligent transportation systems and human factors issues, A review of various ACM module types and data recorded, motorcycle collisions involving motor vehicles equipped with event data recorders, Analysis of the GM. SDM in 360 degree linear momentum collisions-Real Case Analysis, CDR presentation and validation in legal proceedings, Legal implications of data collection, investigation into the durability of ACM, quantifying uncertainties in Ford and GM event data recorders, the accuracy of speed recorded by an SDM and the effects of brake and yaw events, overview of the new GM modules using CAN bus technology, and practical applications for CDR. gathered CAN bus data. Judson B. Welcher, Ph.D. Page 5 Curriculum Vitae February 2-4, 2006 June 6-10, 2005 June 21-25, 2004 August 11-12, 2003 June 8-12, 2003 April 28-May 2, 2003 Aug. — Dec 2002 © August 18-21, 2002 May 13-15 2002 Jan.-May 2002 Avg, - Deo, 2001 Cedars-Sinai Medical Center Institute for Spinal Disorders-Iifth Annual Symposium on Current Concepts in Spinal Disorders 2006; Topics covered at the conference included: cervical artificial disc replacement, spine centers of excellence, disc repair, gene therapy, nucleus replacement, collagen crosslinking, stem cell based biological disc, posterior non-fusion instruments, lumbar artificial disc replacement, selection criteria, complications, minimally invasive surgery, cervical plate design, and thoracic screws for deformity, ARC Network & Collision Safety Institute (ARC-CS1) Crash Conference 2005, Presenter: Topics covered at the conference included: Human Factors, Independent Witness System, Airbag Deployment Thresholds, Commercial Vehicle EDR data, Using Crash Data, Commercial Vehicle Crashes, Damage and Enetgy Concepts, Child Safety Seats, Pedestrian Crash Analysis, and Pedestrian Crash Injuries. ARC Network & Collision Safety Institute (ARC-CSI) Crash Conference 2004: Topics covered at the conference included: EDR data in Criminal Prosecution, Crash Data Retrial System Update, Crush Measuring Protocol, Commercial Vehicle Event Data Recorders, Crash Testing — A Historical Perspective, A Comparison of Crush Stiffness Characteristics from Partial ~Ovetlap and Full-Overlap Frontal Crash Tests, A Method for Determining Crush Stiffness Coefficients from Partial-Overlap Frontal Crash Tests, and LTT Laser and Pocket Zone Crush Measurements. Crash Data Retrieval System Operator’s Certification Course, Collision Safety Institute: Provided the CDR system end user with the skills and information to effectively download data from an automobile event data recorder and understand the meaning of the information provided through the software. ARC Network & Collision Safety Institute (4RC-CSI) Crash Conference 2003, Presenter: Topics covered at the conference included: Low Speed Collisions — Analysis and Biomechanics, Collision Trauma Biomechanics, Airborne Events — Analysis and modeling, Commercial Vehicle Event Data Recorders, New Version CDR. System — GM and Ford, Field Data Review and Data Distribution, NHTSA Crash Data — Problems in Obtaining and Using, and Vehicle Crush Analysis. Special Problems in Traffic Crash Reconstruction, Institute of Police Technology and Management (IPTM), Presenter at Breakout Sessions: Topics covered at the conference included motorcycle brake testing, validation of vehicle spin model, rotational mechanics in traffic crash reconstruction, geometric roadway design, three point trajectory analysis, motorcycle impact friction values, occupant kinematics (biomechanics), photogrammetry, NHTSA crash test data errors, pedestrian amputation and speed association, rollovers, and variability in human forta, Principles of Epidemiology, Department of Preventive Medicine Biostatistics Division, USC School of Medicine: Terminology and uses of epidemiology and demography; sources and uses of population data, types of epidemiological studies, risk assessment; common sources of bias in population studies; principles of screening, ARC Network & Collision Safety Institute (ARC-CSI) Crash Conference, Presenter; Three day crash conference that included instrumented crash tests. Lecture subjects included rollover reconstruction, human surrogates for crash testing, rollover biomechanics, accelerometer systems, advanced vehicle safety, EDR update, examination of the Susan Smith case, underwater investigations, rollover simulations, vehicle design and rollover, and a review of crash test data. McHenry Software Training 2000: Three day training seminar including hands on training in the use of M-Edit, M-SMAC and other McHenry software utilities. List of topics included: history, background, RICSAC validations, other validations, creating the basis for admission to court, SNAG- Impulsive restraints, tire cornering stiffness, center of collision interface, SMACO — simplified ocoupant model, SMACTHP - to determine speed change at any occupant location, steer degrees of freedom, path follower driver model, and creating what if scenarios. Principles of Biostatistics, Department of Preventive Medicine Biostatistics Division, USC School of Medicine: Concepts of biostatics; appropriate uses and common misuses of health statistics; practice in the application of statistical procedures; introduction to statistical software including EXCEL and SPSS. Included laboratory. Seminar in Bioengineering, Department of Biomedical Engineering, USC: Presentation of curtent research in Biomedical Engineering, Judson B. Welcher, Ph.D. Page 6 Curriculum Vitae August 1-2, 2001 June 30, 2000 January 27-28, 2000 December 9-10, 1999 December 9-10, 1999 October 25-27, 1999 February 8-11, 1999 November 2-4, 1998 Advances in Side Impact Test Methodologies and Occupant Protection TOPTEC, Society of Automotive Engineers: A two-day TOPical, TEChnical workshop where researchers from various : disciplines provided insight into the problems associated with injuries from side impact collision, The i objectives were to gain insight into new injury criteria for side impact injuries, contrast the different ; side impact test methodologies, learn about current and future side impact and occupant protection i advancements, compare various dummies used for side impact analysis, interface with an international : panel of experts, analyze the effects that new developments have on side impact passenger injuries, : understand the relationship between side impact and subsequent occupant injuries, learn how and why various side impact test methodologies were developed, compare the different ways countries evaluate side impact crashes, learn state of the art occupant protection countermeasures, and understand what emerging issues will influence future vehicle design. CDR (Crash Data Retrieval system) 2000 Training Seminar, Vetronix Corporation. A one day training class providing an overview of Vetronix, an overview of the CDR systems, methods to access data, software tips, history of SDM. (Sensory Diagnostic Modules), SDM data overview, SDM data parameters and their limitations, field training and demonstration of downloading the data from vehicles, Lower Extremity Injuries TOPTEC, Society of Automotive Engineers: A two-day TOPical, TEChnical workshop that helped safety professionals understand the significance of lower limb injuries in the field and their injury mechanisms, Expert presenters reviewed the status of new test dummies that are being developed and compared the various safety countermeasures. The objectives were to understand the biomechanics of the foot, ankle, leg, knee, thigh and pelvis; understand the injury mechanisms in various crash modes; receive an overview of new dummy development and global regulations; and compare various safety countermeasures and understand how they might mitigate injuries. Frontal Offset Crash Testing TOPTEC, Society of Automotive Engineers. A two-day TOPical, TEChnical workshop that examined the current offset tests and the differences between the vatious international crash tests, Presenters provided an overview of the problem of occupant protection in offset crashes, The history and current status of frontal offset crash testing was reviewed. The : objectives wers to understand the nature and sevetity of frontal offset crashes; gain new insight into the current role of offset crash testing; and gain awareness of the relationship of frontal offset crash protection to the growing public concern regarding vehicle compatibility, Accident Reconstruction: State-of-the-Art TOPTEC, Society of Automotive Engineers, Presenter, A two-day TOPical, TEChnical workshop presenting the latest developments and ongoing research in accident reconstruction, Topics included collision analysis, reconstruction techniques, collision performance, computet simulation and modeling, research, and testing, 43™ STAPP Car Crash Conference: The premier forum for presentation of research in impact biomechanics, human injury tolerance and related fields that advance the knowledge of crash injury protection, Papers presented grouped by topic into Current and Future Crashworthiness Priorities, Side Impact, Lower Limb Biomechanics, Spinal Biomechanics, Brain Injury, Upper Extremity Biomechanics and Airbag Side Effects. World Congress on Whiplash-Associated Disorders, Physical Medicine Research Foundation — Presenter: Disseminated the latest research on traffic safety and suto-engineering including issues : such as crash prevention, traffic safety and education, injury prevention/reduction, automobile safety i and design, crash dynamics and injury exposure. Disseminated the latest research on the diagnosis and ! treatment of whiplash-associated disorders including issues such as the evaluation of diagnosis and treatment programs, medical intervention, physical therapies, treatment modalities, exercise and interdisciplinary approaches, prognostic indicators and prevention of chronicity, 42" STAPP Car Crash Conference: The premier forum for presentation of research in impact biomechanics, human injury tolerance and related fields that advance the knowledge of crash injury protection, Papers presented on topics addressing biomechanics of injury to the upper and lower extremities; head and neck response and injury mechanisms; new insights on occupant protection from safety research in motorsports; improvements in occupant-protection systems; and the development of new crash dummies, human models, and test procedures for occupant injury assessment in simulated crashes. Judson B, Welcher, Ph.D. Page 7 Curriculum Vitae July 13-16, 1998 International Association of Accident Reconstruction Specialists 1998 Conference: Topics covered included the role of the accident reconstruction expert in the legal system, biomechanics of low-speed impacts, low-velocity/insurance fraud, elderly driving issues, issues of driver awareness and traffic control devices, transfer and trace evidence in traffic accident investigation, blood evidence in accident reconstruction, and tire dynamics and nomenclature, November 13-14, 1997 41% STAPP Car Crash Conference: The premier forum for presentation of research in impact biomechanics, human injury tolerance and related fields that advance the knowledge of crash injury protection, Papers presented on topics addressing the biomechanics of child injuries, and injuries in side, frontal, rear and rollover impacts. Human impact responses from the head to the lower extremities are reported. Aug. - Dec, 1997 Experimental Projects in Biomedical Engineering, Department of Biomedical Engineering, USC: Application of modern instrumentation and data processing techniques to the experimental study of selected biosystems. Laboratory. March 24-28, 1997 Crash '97 Conference on Reconstruction and Safety on the Highway, Texas Engineering Extension Services (TEES): Topics covered included commercial vehicle involved in undertide collisions, commetcial vehicle collision investigation, system-based energy momentum, human subject testing and response to low-level accelerations, nighttime vision and reaction time, when the coefficient of restitution approaches "1", rollover accidents, demonstrative evidence, water-related traffic accidents, a brief introduction to vectors, commercial motor vehicle driver fatigue and alertness study, and forensic animation computer-based training, March 20-22, 1997 TA4.ARS -S.0.4.R - W.AT.AL Combined Conference: Topics presented included the practical application of biomechanics towards motor vehicle crash trauma, tractor truck/semi-trailer underride accidents, investigation of safety protocols with inflatable safety restraint systems, bloodbourne pathogens, and human subject and biomechanical responses to low-speed impacts. Tan, - May 1997 Biomechanics of Injury, Department of Biomedical Engineering, USC: Lectures on the specific mechanical and biomechanical properties of involved human tissues to determine injury patterns and injury criteria. Case studies were utilized from such areas as automobile and sports accidents. Specifics involved taldng a set of medical records regarding a given injury and determining the amount and type of force necessary to cause the injury pattern. Course content included mechanics of bone, the skull and brain, the cervical and lumbar spine, the upper extremities, the lower extremities and mechanics of soft tissue, Jan, - May, 1997 Seminar in Bioengineering, Department of Biomedical Engineering, USC: Presentation of current research in Biomedical Engineering, November 4-6, 1996 40" STAPP Car Crash Conference: The premier forum for presentation of research in impact biomechanics, human injury tolerance and related fields that advance the knowledge of crash injury protection, Papers presented on topics including side impact injuries and testing, pelvis injuries, age effects on thoracic injury, lower extremities injuries (patelofemoral, knee, foot, ankle), mathematical models, human subject response to rear-end collisions, and accidents involving children and child restraints. Aug, - Dec. 1996 Biomechanics, Department of Biomedical Engineering, USC: Mechanical properties of biological tissues and fluid transport in physiological systems: blood, rheology, bioviscoelastic solids and fluids; gas flow and mixing; and prosthetic design. Aug, - Dec. 1996 Seminar in Bioengineering, Department of Biomedical Engineering, USC: Presentation of current research in Biomedical Engineering. August 19-20, 1996 Low-Speed Rear-Impact Collision TOPTEC, SAE — Presenter: A. two-day topical, technical workshop (TOPTEC) presenting the latest research in assessing low-speed impact severity and occupant kinematic analysis. Topics covered included biomechanics of soft tissue injuries, understanding “whiplash,” human volunteer testing, human subject responses, structures and injuries of the neck, dummy development, seat testing, experimental neck injury research, comparisen of different cars seats regarding head-neck kinematics, reconstructing minor collisions, and low-speed vehicle impact demonstration, Judson B, Welcher, Ph.D, Page § Curriculum Vitae Jan, - May 1996 Jan, - May 1996 Aug, - Dec, 1995 November 11-12, 1995 November 8-10 1995 August 3-4, 1995 July 21-22, 1993 Jan, - May 1995 Jan, - May 1995 Aug, - Dec. 1994 August 6-8, 1994 Advanced Studies of the Nervous System, Department of Biomedical Engineering, USC: Advanced topics on the structure and function of the nervous system examined from the viewpoint of computational systems science, Advanced Topics in Biomedical Systems, Department of Biomedical Engineering, USC: Advanced topics in selected biomedical systems: cell membrane transport and electrophysiological approaches; skeletal muscle physiology, adaptation of skeletal muscle to endurance training, effects of aging on the neuromuscular system and cellular mechanisms of skeletal muscle fatigue and muscle pain; auditory physiology, vestibular physiology; vestibulo-ocular reflex; and respiratory physiology. Mathematical Biophysics, Department of Biomedical Engineering, USC: Formulation of biological problems in mathematical terms, Analytical and computational solution of the relevant equations, Accidental Injury: Biomechanics and Prevention, UCSD School of Medicine: A state of the art review of the biomechanics of human injury. Emphasis was placed upon human tolerance, mechanisms of injury to anatomic areas and contemporary techniques of injury prevention. 39" STAPP Car Crash Conference: The premier forum for presentation of research in impact biomechanics, human injury tolerance and related fields that advance the knowledge of crash injury protection. Papers presented on topics addressing airbag effectiveness and airbag injury patterns, frontal impact tolerance, rollovers, brain injury, biomechanics of the face, cervical spine biomechanics, properties of skeletal muscle and its relevance to human cervical spine impact dynamics, low speed rear-end collisions, shear and bending response of the knee joint to lateral impact, effects of age on fracture tolerance of the patellofemoral joint, and side impact crash test dummy biofidelity. Automotive Seat Design for Safety TOPTEC, SAE: A two-day topical, technical workshop presenting the latest developments on safety in automotive seat design. Topics included designing for ergonomics and manufacturing, safety seat concepts, real world collision performance, testing, regulatory issues and advanced concepts, Southwest Association of Traffic Accident Investigators, Low-Speed Seminar; Seminar provided an understanding of the mechanics of low-speed rear-end collisions. Numerous low-speed rear-end, vehicle-to-vehicle, collisions were performed. Vehicle contact components were viewed. Selected occupant (human volunteer) kinematics and acceleration data collected during low-speed rear-end impacts were reviewed, A sideswipe and a broadside collision were also performed. Seminar in Biomechanics, Department of Biomedical Engineering, USC: Biomechanical analysis of the human spinal column, Vatiations in the anatomical structures were investigated as they related to mechanical stability, structural rigidity and dynamic performance, Current research into developing mathematical and computer models of the spine was reviewed, Measurement and Processing of Biological Signals, Department of Biomedical Engineering, USC: Acquisition, analysis and display of biological data using digital computers: laboratory applications of digital signal processing and real time analysis. Signal and System Analysis in Biomedical Engineering, Department of Biomedical Engineering, USC: Classification; representation; statistical analysis; orthogonal expressions; least squares estimation; harmonic analysis; Fourier, Laplace and Z-transforms; the linear system; filtering; modeling and simulation; and linear control theory. Low- Speed Rear-Impact Collision TOPTEC, SAE — Presenter: A two-day topical, technical workshop presenting the latest research in the area of rear-impact frequency and resulting injuries. Topics covered included accident reconstruction, occupant kinematics, kinematics of occupant response, cervical injuries, crash severity and injury frequency, current research in rear- impact collisions, and staged collisions; role of bumpers, estimating impact severity and injury potential. Smaller working groups focused on crash severity, legal ramifications and accident reconstruction, Judson B. Welcher, Ph.D. Page 9 Curriculum Vitae Sept, - May 1994 December 8-10, 1993 July 16-18, 1993 April 1993 January 18-22, 1993 August 12-14, 1992 June-July 1992 November 16-17, 1991 October 1-2, 1991 Feb, ~ June 1991 December 10, 1990 December 1-2, 1990 Gross Human Anatomy A and B, Department of Anatomy and Cell Biology, USC School of Medicine: A complete dissection of the adult human body with supplementary lectures and demonstrations, Emphasis on correlating development, structure and function. Additional areas of study included interpretation of x-rays, cross-sectional anatomy and identification of functional deficiencies through practical case studies. Head and Neck Injury Symposium, Automotive Engineers continuing professional development group and The Safety Advisory Panel: Topics of discussion included; anatomy of the head and neck, macro and microscopic brain injury, biomechanics of brain injury, clinical aspects of central nervous system trauma, psychological effects of central nervous system trauma, facial trauma, helmet performance and test requirements, closed head injuries, biomechanics of neck injury, anterior neck injuries, musculoskeletal injuties of the cervical spine, prevention of head and neck injuries, and costs of head and neck trauma, Biomechanics of Injury, The University of Northern California: Instruction on the fundamentals of injury causation, specifically covering injuries of the head, neck, spine, brain, face, abdomen, cardiovascular system and extremities. Biomechanical issues related to roof crush, passive restraints, comfort features, seat belt effectiveness, airbag injuries and low velocity injuries wore covered, Technical Workshop: Skids and Collisions, the San Bernardino County Sheriff Emergency Vehicle Operations Center and Government Employee's Insurance Company - Co-sponsor: ‘Workshop included vehicle skid and handling tests on wet and dry surfaces, centrifugal skids, commercial vehicle (semi-trucks) skid performance, motorcycle skid performance and low velocity car-to-car impacts. Engineering Dynamics Corporation Simulations Seminar: One week intensive seminar on the use of EDVAP software for simulating motor vehicle accidents. Thorough examination of tire models, collision models, estimating initial conditions, driver input tables and evaluation of case studies. BH VK Crash Testing Seminar, Mobility Systems and Equipment Co.: Experimental collision research to gain knowledge about the relationship between energy of approach and residual crush. for eventual reconstruction purposes. Tixed-barrier impact tests at 15, 20, 40 and 50 mph were observed and analyzed, as well as a 40 mph vehicle-to-vehicle test. Standard accident reconstruction methodologies were applied to predict impact speeds and residual crush. These values were correlated with actual tests and crush data. Structural Biomechanics, California State University, Northridge: Functional anatomy of the human body with emphasis on biomechanical laws and their application in analysis of movement activities. Accidental Injury: Biomechanics and Prevention, UCSD School of Medicine and the Institute for Medical Education and Research. A presentation of anatomy, injury mechanics and tolerance of the human head and spine, ocoupant kinematics, restraint systems effectiveness and occupant compartment integrity, Biomechanics of Impact Trauma, Association for the Advancement of Automotive Medicine: Analysis of different injury types and mechanisms associated with automobile accidents. Topics coveted included: biomechanics, occupant kinematics and crash severity assessment; crash injury and impairment assessment; injury types, mechanisms, tolerance criteria and limits of the skull, brain, cervical spine, extremities and pelvis; biomechanical evaluation of helmet standards; biomechanics of thoracic injury; biomechanical evaluation of seat belt use and occupant restraint technology; clinical aspects of lower limb injuries for motorcyclists and pedestrians; and crash performance standards integrated with biomechanical knowledge. General Human Anatomy, Santa Monica College: An intensive study of the structure of the human body. Major consideration was given to tissue structure and the skeletal, muscular, circulatory, respiratory, digestive, excretory, reproductive, integumentary and nervous systems. Vehicle Control Course, Willow Springs International Driving School: Basic techniques of vehicle control including proper braking techniques, skid performance and vehicle response to improper driver input, Anatomy for Attorneys, Medi-Legal Institute: Examination of traumatic injuries and degenerative conditions, anatomical structure of the vertebral column, mechanisms of injury to the cervical spine, head injury and proximate causes, and injuries and fractures of the limbs. Judson B. Welcher, Ph.D. Page 10 Curriculum Vitae RESEARCH AND TESTING Tuly 2013 Performed and participated in instrumented Hybrid IX dummy straight leg vertical drop tests at various heights to analyze loads in the lower extremities and spine in Signal Hill, CA. May 2013 ARC-CSI 2013 - Performed and participated in remote-driven Saturn SL2, Chevrolet Cavalier, and Chevrolet Impala rear-ending and broadsiding a Neoplan city bus containing an instrumented driver, passengers, and a Hybrid III dummy; human driver and remote-driven Toyota Yaris(s) in front-to-barrier impacts; angled head-on collisions between human-driven Ford Crown Victorias and Chevrolet Cavaliers; and a head-on collision between remote-driven Pontiac Grand Ams. All tests performed at the Las Vegas Motor Speedway, Nevada. Results presented at ARC-CSI Conference, May 13-16, 2013, Las Vegas, NV May 13, 2013 Performed and participated in front and rear to barrier impacts using a Toyota Yaris with an instrumented human driver and a Hybrid III dummy passenger; as well as hard braking of a Neoplan city bus and an angled broadside to a Honda Civic with an instrumented human driver, passengers and a Hybrid III dummy at the Las Vegas Motor Speedway, Nevada. May 13, 2013 Performed and participated in instrumented Hybrid II dummy head impacts with an industrial light fixture, as well as an un-instromented human volunteer light fixture-to-head impact test in Signal Hill, California. Tune 4, 2012 ARC-CSI 2012 - Performed and participated in crash tests with instrumented human volunteers and anthropomorphic dummies, including a remote-driven Pontiac Grand Prix striking a Ford E350 Ambulance in an angled broadside, a Chrysler Town & Country with a remote tire deflation striking a Ford Aspire in an offset rear-end and then broadsiding a Toyota Corolla, a Ford Crown Victoria striking a Saturn SL2 ina high speed high angle broadside, a remote-driven Kia Rio striking a Toyota Yaris in an angled head-on, & remote-driven Jeep Grand Cherokee striking a Fiat Bertone in a high speed offset head-on with override and a rollover, a Ford Crown Victoria side-swiping a Kia Sephia and then broadsiding a Ford Escort, and a remote-driven VW Jetta broadsiding a Chrysler Town & Country at the Las Vegas Motor Speedway, Nevada, Results presented at ARC-CSI Conference, June 4-7, 2012, Las Vegas, NV Results presented for instruction at Collision Safety Institute, Inc. CDR Data Analyst Course, October 1-5, 2012, Glendale, AZ June 3, 2012 Performed and Participated in rear-end crash tests between a Jeep Grand Cherokee with active head restraints and a Chrysler Town & Country utilizing instrumented human volunteers and anthropomorphic dummies and a remote tire deflator at the Las Vegas Motor Speedway, Nevada. Results presented at ARC-CSI Conference, June 6, 2012, Las Vegas, NV Results presented at CDR User's Summit, January 21-23, 2013, Houston, TX June 2012 Performed and Participated in a broadside crash test between a Ford Contour and a Ford Crown Victoria utilizing instrumented anthropomorphic dummies at the Las Vegas Motor Speedway, Nevada, Nov, 14, 2011 Performed and participated in instrumented offset rear-end, over-ride rear-end, angled rear-end, and side-swipe collisions between a Chrysler LeBaron, Kia Sephia, and Ford F-150 in Las Vegas, Nevada. May 22-23, 2011 ARC-CSI 2011 - Performed and participated in a series of instrumented automobile to automobile collision tests utilizing human volunteers. Testing included a series of rear end collisions involving a 2008 Buick Regal into a 2008 Buick LaCrosse, frontal collision between a 2006 Chrysler 300 and a 2002 Pontiac Grand Prix; impact between the front of a 2006 Ford Crown Victoria and the left side of a 2004 Hyundai Sonate; chain reaction rear end collision involving a 2006 Toyota Sienna, 1989 Ford Probe, and 1997 Dodge Neon; collision between the front of a 2008 Buick LaCrosse and the left side of a 1997 Ford Aspire; offset collision between the let front of a 2006 Chrysler 300 and a 2006 Ford Escape; chain reaction collision between a 2009 Buick Regal, 1999 Chevrolet Cavalier, and 1598 Chevrolet Camaro. Results presented at ARC-CSI Conference, May 23-26, 2011, Las Vegas, NV Results published in Collision: The International Compendium for Crash Research, Volume 6, Issue 2, Fall 2011 Results presented for instruction at Collision Safety Institute, Inc. CDR Data Analyst Course, October 1-5, 2012, Glendale, AZ Judson B, Welcher, Ph.D, Page 11 Curriculum Vitae May 23, 2011 Performed and Participated in vehicle-to-vehicle low-speed crash tests, with an instrumented human volunteer driver in a Toyota Celica convertible during a frontal and broadside-to-right door impacts with the trailer hitch of a backing Chevrolet Suburban at the Las Vegas Motor Speedway, NV, Feb 17-18,2011 Performed and participated series of head impact tests with a Hybrid IIT 5th percentile female dummy, Implements included vatious balls, sporting equipment and household items. Acceleration, high speed film, and angular velocity data was collected for analysis. Feb 8, 2011 Performed testing with a Hybrid ITT 5th percentile female dummy to evaluate the effects of a sink faucet falling from a shelf onto someone’s head, The dummy head was instrumented and the impact conditions of the faucet were varied. Kinematic and injury data was captured and processed. Sept 28, 2010 National Crash Analysis Conference (NCAC) — Performed a high speed xear end collision with an : instrumented Hybrid III 50th percentile male dummy, Assisted with test set-up, ATD placement, sensor calibration and data collection. May 24, 2010 ARC-CSI 2010 — Performed and participated in 19 instrumented vehicles and some instrumented human impact tests. Tests included inline/chain reaction rear end impact of a 2002 Cadillac SLS into a stopped 2002 Pontiac Grand AM and a stopped 2000 Chevrolet/Geo Metro, two motoreycle and one scooter impact it the side of a 1998 Mercury Grand Marquis, 2002 Pontiac Grand AM into the rear of a semi trailer, 2001 Monte Carlo into the side of a semi-trailer, a 1996 Saturn SL into the side of a semi- trailer, frontal impact of a 2002 Ford Crown Victoria into a 2000 Ford Crown Victoria, offset frontal impact of a 2001 Chevrolet Impala into a 1996 Chevrolet Cavalier, four lower specd rear-end impacts with a Chevrolet S10 pickup rear-ending a 2001 Chevrolet Impala and six impact where a 2001 Chevrolet S-10 pickup hits common debris such as a water heater, washing machine, mattress, latter, and a wheel (tite and rim). June 1, 2009 ARC-CSI 2009 — Performed and participated in 11 instrumented vehicles and some instrumented volunteer impact tests including a 2009 Dodge Journey into a 1991 Chevrolet Cavalier, a 2002 Chevrolet Malibu into a semi-trailer, 2002 Ford Crown Victoria Police Interceptor info a semi-trailer, a 2003 Ford Taurus into a semi-trailer, a 2009 Dodge Ram 1500 pickup into a 1991 Ford Ranger pickup, 2006 Ford Crown Victoria into a 1997 Ford Contour, four attempted rollovers of a 2009 Jeep Grand Chetokee, and a 2009 Jeep Grand Cherokee into a 2009 Dodge Journey. Tune 2, 2008 ARC-CSI 2008 — Performed and participated in 12 instrumented vehicles and some instramented volunteer impact tests, Tests included a 1989 Yamaha FZR600 motorcycle broad siding a 1989 Honda Civic CRX, two PIT maneuvers with a 2002 Ford Crown Victoria Police Interceptor and a 2000 Dodge Intrepid and 1991Ford Ranger, a pedestrian dummy impact by a 1998 Chevrolet Malibu, an angled frontal impact between a 2002 Ford Crown Victoria and a 1989 Honda Civic CRX, a 1989 Yamaha XJTO00N motorcycle broad siding a 1984 Dodge van, a bus hitting a 1996 Kia Sephia, a 2000 Intrepid broad siding a 1984 Dodge Van, a Ford Ranger frontal and rear impact to a K-Rail type batrier, Dodge Intrepid sideswiping a K~Type rail, and a tire falling off of a 2000 Dodge Intrepid with instrumented human volunteet, June 3-4, 2007 ARC-CSI 2007 — Performed and participated in 18 instcumented vehicles and some instrumented volunteer impact tests. Tests included eleven crashes with the front of a YEAR Chevrolet impacting the reat of a 1986 Jeep Cherokee at incrementally increasing impact speeds for bumper-to-bumper impacts and bumpet-to-trailer hitch impacts at the same speeds, the front of a 1993 Jeep Grand Cherokee contacted the right front cotner of a 1983 Toyota Tercel, the front of a 2000 Chevrolet Malibu broadsided a 1995 Ford Aspire, the front of a 2002 Ford Crown Victoria contact the front of a 1994 Chevrolet Corsica, The front of a 2000 Ford Crown Victoria contacted a trailer towed by a 1986 Jeep Cherokee. Additional testing included two tests where an instrumented human volunteer drove a 1991 Chevrolet Cavalier while the wheel dropped off the vehicle. January 11, 2007 Performed and participated three instrumented vehicle rear-end impact tests examining the impact performance of a 1989-1995 Toyota pickup rear bumper, Judson B, Welcher, Ph.D. Page 12 Curriculum Vitae August 19, 2006 Performed and participated in a series of fourteen instrumented vehicle crash tests, Tests included twelve front-to-rear (rear-end) impacts with an instrumented 1994 Lincoln Continental rear-ending a 1993 Chrysler LeBaron with either an instrumented human volunteer or an instrumented Hybrid IIT crash test dummy and two high-speed pedestrian impacts with the front of the 1994 Lincoln Continental impacting a crash test dummy as a pedestrian. Tune 4-5, 2006 Performed and participated in a series of twenty six instrumented vehicle crash tests. Tests included sixteen curb impact tests with a 1997 Chevrolet Astro van and a 1991 Geo Metro, a rollover of a 1991 Ford Explorer, two car to motorcycle test, the front of 2000 Chevrolet Malibu contacting the side of a 1991 Geo Metro,.two tests with a 1975 Establishment fire engine impacting the front right cotner of a 1997 Chrysler Lebaron and the front of a 1997 Chevrolet Astrovan, a three vehicle collision with 1973 Thomas school bus rear-ending a 1994 Hyundai Elantra and pushing the Hyundai forward into the rear of a 1972 Winnebago, a three vehicle collision with 1998 Ford Crown Victoria rear-ending a 1987 Subaru GL and pushing the Subaru forward into the side of a 1993 Chevrolet Caprice, August 27, 2005 Performed and participated in a seties of twelve insfrumented vehicle crash tests, Tests included nine front-to-reat (rear-end) impacts with an instrumented 1998 Monte Catlo rear-ending a 1992 Chrysler LeBaron with an instrumented human volunteer and three moderate speed instrumented frontal collisions between the 1992 Chrysler LeBaron, 1998 Monte Carlo and a 1992 Mazda 929 (broadsided). June 6-7, 2005 Performed and participated in a series of nine instrumented vehicle crash tests, Tests included a front- ‘ to-rear (rear-end) impact with an instrumented 2001 Ford Crown Victoria (push bars) with an instrumented occupent traveling at approximately 50 mph rear-ending an instrumented 1997 Ford Crown Victoria traveling at approximately 40 mph, a front-to-rear (rear-end) impact with an instrumented 1997 Ford Crown Victoria (no push bars) with an instrumented occupant traveling at approximately 50 mph rear-ending an instrumented 2001 Ford Crown Victoria traveling at approximately 40 mph, two impacts with the front of an instrumented 2001 Chevrolet Cavalier impacting a crash test dummy as a pedestrian, the front of an instrumented 2001 Crown Victoria with an instrumented human volunteer impacting the front of a 1998 Hyundai Sonata, the front of an instrumented 1986 Mazda RX7 impacting an instrumented tractor trailer, the front of an 1997 Pontiac Grand Prix impacting the rear of the 1986 RX7 (at POR from prior), and the front of an 2001 Pontiac Grand AM impacting and instrumented 2001 Chevrolet Cavalier and shoving the Cavalier under the side of tractor trailer. August 21, 2004 Performed and participated in a series of fourteen instrumented vehicle crash tests. Tests included eleven front-to-rear (rear-end) impacts with an instrumented 1992 Ford Crown Victoria rear-ending a 1993 Chrysler LeBaron with an instrumented human volunteer and instrumented Hybrid IIT crash test dummy and two high-speed pedestrian impacts with the front of the 1992 Ford Crown Victoria impacting a crash test dummy as a pedestrian, July 14, 2004 Performed and participated in a series of four acceleration, deceleration and turning tests ofa 2001 Thomas MTA bus. June 21, 2004 Performed and participated in a seties of seven instrumented vehicle crash tests. Tests included a high speed frontal impact of a 1996 Chevrolet Cavalier into a barrier, the front of an instrumented 1998 Pontiac Grand AM with an instrumented human volunteer into the front of 2000 Buick Century with a human volunteer, the front of an instrumented 2000 Buick Century with an instrumented human volunteer into the side of an instrumented Neon, two moderate speed frontal impacts with an instrumented 2000 Buick Century with an instrumented driver impacting a barrier, a high speed frontal impact with and instrumented 1998 Pontiac Grand AM impacting a barrier, and the front of an instrumented 1997 Ford Crown Victoria with an instrumented driver impacting the side of a Ford Tempo. June 20, 2004 Performed and participated in six instrumented vehicle crash tests. Tests included a front-to-rear (rear- end) impacts with the front of an instrumented 1998 Pontiac Grand AM with an instrumented human volunteer driver impacting the rear ofa instrumented 2000 Buick Century with an instrumented human volunteer and front of an instrumented 2000 Buick Century with an instrumented human volunteer driver impacting the reat of a instrumented 1998 Pontiac Grand AM with an instrumented human volunteet. Judson B. Welcher, Ph.D. Page 13 Curriculum Vitae April 20, 2004 April 6, 2004 March 29, 2004 February 24, 2004 August 27, 2003 July 17, 2003 June 8-9, 2003 April 29, 2003 April 17, 2003 April 16, 2002 February 12, 2003 December 17, 2002 Performed and participated in two instrumented seat pull tests and nine instrumented Hybrid III head form drop tests. Instrumented seat pull tests were conducted to evaluate the rearward force deflection characteristics of a 1993 Dodge Dakota pickup seat. Head form drop tests were conducted to evaluate the effects of an occupant hitting their head on the rear cab and rear glass of a 1994 Dodge Dakota pickup, An instrumented head form was dropped onto the rear body panel at various speeds. Performed and participated in three instrumented Hybrid III head form drop tests to evaluate the effects of an occupant hitting their head on the rear interior body panel of a Chevrolet S10/GMC Sonoma after seat failure, An instrumented head form was dropped onto the rear body panel at various speeds. Performed and participated in a series of four instrumented vehicle crash tests, Tests included four frontal impact tests to determine the low speed impact performance of the front bumper of a 1998 Chevrolet Suburban, Performed and participated in a series of five instrumented vehicle crash tests, Tests included a front- to-rear (rear-end) impacts with the center front of an 1986 Honda Prelude rear-ending a trailer hitch on an instrumented 1993 Chevrolet Blazer with and instrumented human volunteer, a front-to-rear (rear end) impacts with the left front of an 1986 Honda Prelude rear-ending the right approximately 40% of an instrumented 1993 Chevrolet Blazer with and instrumented human volunteer, and there tests with an instrumented 1993 Chevrolet Blazer with trailer hitch backing into the door of a 1986 Honda Prelude. Performed and participated in a series of thirteen instrumented vehicle crash tests. Tests included eleven front-to-rear (rear-end) impacts with an instrumented 1994 Ford Crown Victoria rear-ending a 1987 Chrysler LeBaron with instrumented human volunteers and BioRID crash test dummy and two high-speed pedestrian impacts with the front of the 1994 Ford Crown Victoria impacting a crash test dummy as a pedestrian, Performed and participated in three instrumented Hybrid [I head form drop tests to evaluate bicycle helmet performance, An instrumented head form was dropped with out a helmet on, The test was then repeated with a standard bicycle helmet on the head form, Performed and participated in a series of seven instrumented vehicle crash tests. Tests included three low speed froni~to-rear (rear-end) impacts with an instrumented 2000 Chevrolet Malibu reat-ending a 1994 Kia Sephia to produce near-deploy files in Ford RCM’s and GM SDM’s in the Chevrolet, a ramp vault of the instrumented Chevrolet with an instrumented human volunteer and Hybrid ITI crash test dummy with a subsequent high-speed broadside into the side of the Kia with airbag deployment in the Chevrolet, two ramp vaults of a instrumented 1995 Ford Crown Victoria with an instrumented human volunteer and Hybrid III crash test dummy, and a high-speed broadside collision of the Ford with an instrumented human volunteer and Hybrid III crash test dummy into the side a 1994 Ford Tempo with airbag deployment in the Ford Crown Victoria, Observed two rollover tests and numerous motorcycle breaking tests. Tests were conducted as part of the Special Problems in Traffic Crash Reconstruction, Institute of Police Technology and Management (IPTM) Conference, Performed and participated in four instrumented golf cart tests, Tests were conducted to quantify the vehicle acceleration associated with driving a golf cart along the normal golf cart path, Performed and participated in a series of six tests to determine the motions and accelerations associated with an amusement park ride. Testing was conducted with and instrumented vehicle and human volunteer, Performed and participated in a series of five tests to determine the motions and accelerations associated with an amusement park ride. Testing was conducted with and instrumented vehicle and human volunteer. Performed 8 instrumented tests in which the force of impact from retail sign dropped various distances was quantified, Judson B, Welcher, Ph.D, Curriculum Vitae Page 14 October 9,2002 October 8, 2002 October 3, 2002 August 18-21, 2002 August 10, 2002 Tune 29-30, 2002 June 27, 2002 January 25, 2002 January 24, 2002 November 7, 2001 October 31, 2001 August 25, 2001 April 5, 2001 Performed and participated in a series of 6 instrumented vehicle crash tests in which a 2002 Buick Century Custom was backed into the front of 2002 Chevrolet Cavalier. Aun uninstrumented human volunteer with pre-existing 7 mm disc bulges at C5-6 and C6-7 drove the Buick, Performed and participated in a high speed instrumented human volunteer frontal-broadside impact to examine air-bag performance. Tests were conducted and aired on the Tonight Show. Performed and participated in a serics of 8 instrumented vehicle impacts, Testing included 4 bus into vehicle impacts with instrumented vehicle and human volunteers and 3 semi trailer into vehicle and one vehicle into semi-trailer. Crashes were part of the CAARS conference. Performed and participated in a series of 5 crash tests, Two of the crash tests use an instrumented Hybrid I crash test dummy along side an instrumented human volunteer, Three lower speed crashes were conducted to examine data that may be collected by the standard SDM/CDR compared to actual recorded data, Vehicles included a 1996 Chevrolet Lumina, 1994 Ford Taurus, 1980 Mazda GLC, and 1989 Hyundai Excel, Crashes were part of the ARC-CSI Conference. Performed and participated in a series of 14 instrumented vehicle-to-vehicle impact tests with human volunteers and a RID2 crash test dummy. Impact configurations included 13 rear-end impacts and one lateral impact. Vehicles used included a 1994 Ford Crown Victoria, 1989 Chrysler LeBaron, and a 1989 Toyota Corolla, Performed and participated in a series of 10 instrumented front-to-rear vehicle-to-vehicle ctash tests with human volunteers, Tests were configured to compare bumper-to-bumper vehicle and occupant response to underride response. Test vehicles included 1984 Dodge Aires, 1987 Ford Escort, 1987 Honda Accord, 1989 Acura Integra, and a 1996 Acura Integra. Performed and participated in a series of 8 instrumented tests in which bumper components from the rear of a 1989-1992 Chevrolet S-10 pickup, 1985 Volvo and Jaguar XTS were tested. Performed and participated in a series of 5 instrumented tests in which an instrumented Hybrid IIT crash test dummy was exposed to various everyday activities. The dummy was instrumented to record head acceleration, neck force and neck moments. Performed and participated in a series of 9 instrumented tests in which various ceiling materials where dropped on the head of an instrumented Hybrid III crash test dummy. The dummy was instrumented to record head acceleration, neck force and neck moments, Performed and participated in a seties of 3 instrumented side impact vehicle-to-vehicle crash tests with human volunteers. An instrumented 1991 Ford Explorer impacted side A-pillar area of a 1996 Acura Integra at impact angles from 46 to 82 degrees. An instrumented male volunteers was seated in the driver's seat for two of the tests, Performed and participated in a series of 5 impact tests in which an instrumented Hybrid TIT crash test dummy was dropped from a standing height onto various deck surfaces, The dummy was instrumented to record pelvis acceleration, neck force and neck moments, Performed and participated in a series of 13 instrumented vehicle~to-vehicle impact tests with human volunteers, Impact configurations included three impacts with the front of a 2000 Chevrolet Trapala rear-ending a 1994 Ford Taurus, three impacts with the Taurus rear-cnding the Impala, three impacts with the Impala reat-ending a 1996 Chevrolet Cavalier, three impacts with the Cavalier rear-ending the Impala, one higher speed impact with the left rear corner of the Taurus backing into the right side of the Cavalier at approximately 50 degrees, and one high-speed frontal impact with the front of the Impala impacting the front of the Taurus, Human volunteers were present in both vehicles and the airbags deployed in both vehicles, Performed and participated in a series of two instrumented high-speed frontal airbag deployment tests. Tmpact configuration included the front of a 1991 Isuzu Stylus impacting the front of a similar 1991 Tsuzu Stylus at 28 mph, The bullet Isuzu had an instrumented human volunteer driver exposed to an airbag deployment, The target vehicle had an unrestrained Hybrid IT crash test dummy (no airbag). An additional test was performed with a 1994 Mercury Cougar traveling at 43 mph broad-siding a Judson B, Welcher, Ph.D, Page 15 - Curriculum Vitae January 23, 2001 September 9-10, 2000 September 7, 2000 August 28, 2000 August 11, 2000 July 6-7, 2000 June-August 15, 2000 May 25, 2000 May 11,2000 stationary 1990 Ford Festiva. The bullet Mercury had an instrumented human volunteer driver exposed to an airbag deployment, A non-seat belted, rearward facing child safety seat with a child CPR dummy in the right front seat was exposed to the passenger side airbag deployment. Performed a series of 17 kicks to the side of an instrumented Hybrid III crash test dummy to quantify the head injury potential from a kick to the head of a prone individual, Various shoes and kick configurations were utilized. Performed and participated in a series of 25 instrumented side impact vehicle-to-vehicle crash tests with human volunteers. An instrumented FMVSS 301 moving barrier impacted the front, middle and rear of the right and left side of 1989 Ford Escort. Instrumented male and female volunteers were seated in the passenger and driver seat for each test. Performed a series of three instrumented Hybrid II head form drop tests. The instrumented head form was dropped on foam, and two times on the passenger door panel of a Nissan 300 ZX 2+2. Testing was conducted at Biomechanical Research & Testing, LLC, Performed a seties of two instrumented Hybrid II head form drop tests. The instrumented head form was dropped on to foam and on the side glass from a 1996 Ford Crown Victoria. Testing was conducted at Biomechanical Research & Testing, LLC, with Burkhard Methods and Analysis Corporation, Performed and participated in a series of 19 instrumented vehicle-to-vehicle impact tests with human volunteers, Impact configurations included six impacts with the front of a 1992 Ford Taurus rear- ending a 1992 Chrysler LeBaron Convertible, six impacts with the LeBaron rear-ending the Taurus, three impacts with the LeBaron rear-ending a 1994 Hyundai Excel, three impacts with the Hyundai rear-ending the LeBaron, and one high-speed frontal impact with two moving vehicles in a head on collision, Human volunteers wets present in both vehicles and the airbags deployed in both vehicles. Performed and participated in a serles of 19 instrumented FMVSS 301 moving barrier into a 1992 and 1995 Ford F150 pickup, Both the target pickup and moving batrier were instrumented. All impact configurations included impact severities to cause only cosmetic damage, damage onset, and minor damage. Impacts were conducted to the front, rear, left front corner, right front corner, offset rear, right and left bedside panel, right and left door, and right and left fender, Tests were conducted at Biomechanical Research & Testing, LLC. Performed and participated in over 228 instrumented pendulum (Title 49 CFR Part 581bumper impact testing pendulum with modified impacting plate) test sled impact tests, Over 100 of the tests utilized a BioRID-P3 anthropomorphic test device (i.e. “crash test dummy”) instrumented with head, T1, T8, L1, and pelvis accelerometers; neck load cell; and head mounted angular rate sensor, Three separate 2000 model GM seats were utilized for testing with a total of 32 separate foam configurations. Differing bumper foams were used during testing to evaluate the effects of impact duration and pulse shape on occupant kinematics and injury potential, Over 100 occupant response variables were utilized for statistical analysis, Performed and participated in a series of four instrumented vehicle-to-vehicle impact tests with human volunteers. Impact configuration included two tests with a 1989 Acura Legend rear-ending a 1996 Volvo 850, a broadside impact with the front the Acura contacting the left side of the Volvo, and a high speed rear-end collision with an instrumented human volunteer driving a 1999 Cadillac Deville into the rear of a 1986 Oldsmobile 98 Regency Brougham. The airbag on the Cadillac deployed and the SDM data from the Cadillac was downloaded, Performed and participated in a series of seven instrumented vehicle-to-vehicle impact tests with human volunteers, Impact configurations included three impacts with a 1987 Ford Escort rear-ending a 1986 Buick Skylatk, two angled broadside impacts with the left front and right front, respectively of the Buick contacting the side of a 1986 Ford Aerostar minivan, an engled rear-end impact with the right front of the Aerostar rear-ending the Buick, and a sideswipe impact with the right side of the Buick contacting the left side of the Aerostar. Tests were conducted at the Texas A&M University, Texas Engineering Extension Service campus in Houston, Texas, Judson B., Welcher, Ph.D. Page 16 Curriculum Vitae April 24, 2000 Performed and participated in two tests to determine the force and change in speed required to deform the control arm from a 1980-1992 Volkswagen Vanagon, Tests were conducted at Biomechanical Research & Testing, LLC, with Collision Dynamics Analysis. April 8, 2000 Performed and participated in a series of ten instrumented vehicle-to-vehicle impact tests with human volunteers, Impact configurations included two impacts with the front of a 1984 Volkswagen Rabbit rear-ending a 1990 Mercury Sable, and angled rear-end impact with the corner of 1986 Chevrolet Astro Van rear-ended the Sable, & angled broadside impact with the other corner of the 1986 Chevrolet Astro Van contacting the left rear side of the Sable, a sideswipe impact with the right side of the Rabbit sliding along the left side of the Astro Van, two offset rear-end collisions with the Rabbit rear-ending the Astro Van, a broadside impact with the rear of the rabbit backing into the side of the Astro Van, and two high-speed chain reaction rear-end collisions in which an instrumented human volunteer driving the Sable reat-ended the stationary Rabbit pushing it forward into the Astro Van, The airbag in the Sable deployed in the second impact test. March 27, 2000 Performed and participated in two instrumented frontal crash tests evaluating the performance of piston energy absorbers from a 1992-1997 Cadillac Seville. Tests were conducted at Biomechanical Research & Testing, LLC in conjunction with Collision Dynamics Analysis. March 2000 Performed a high speed human volunteer frontal collision into a pedestrian crash test dummy and a high speed instrument human volunteer frontal-broadside collision test with airbag deployment , Tests were conducted at the Law Enforcement Training Facilities in Charlotte, North Carolina February 28, 2000 Performed a high speed instrument human volunteer frontal collision test with airbag deployment. The front of 2 1992 Volvo 965 wagon rear-ended a 1979 Fiat, August 26, 1999 Performed and participated in a seties of eight instrumented vehicle-to-vehicle impact tests with human volunteers. Impact configurations included three impacts with the front of 1983 Oldsmobile Regency 98 contacting the rear of a 1975 Buick Skylark, an angled offset rear-end collision with the left front corner of the Oldsmobile contacting the rear bumper of the Buick, a sideswipe/lane-change impact with the left side of a 1976 AMC Gremlin contacting the tight side of the Buick, a chain reaction rear-end impact with the front the Buick rear-ending the Gremlin pushing it forward into the rear of the Oldsmobile, one impact with the left front of the Buick contacting the side the Gremlin, Tests were conducted at the Washington Criminal Justice Training Center in Seattle, Washington. August 14, 1999 Performed and participated in a one instrumented offset angled rear-end impact test. The right front of cornet of a 1997 Ford Range pickup contacted the right rear corner of a 1995 Chevrolet Astro Passenger van, Tests were conducted with Jerry Eubanks, August 14, 199% Performed and participated in series of fifteen instrumented vehicle-to-vehicle impact tests with human volunteers. Impact configurations included three impacts with the front of a 1991 Honda Civic reat- ending a 1991 Lincoln Continental, three impacts with the front of the 1991 Lincoln Continental rear- ending the 1991 Honda Civie, three impacts with the front of a 1989 Ford Tempo rear-ending the Honda, one impact with the 1989 Ford Tempo contacting the right rear side of the Honda in an eccentric broad-side impact, one impact with the left rear corner of the Honda backing into the left rear side of the Ford, a sideswipe/lane-change impact with the left side of the Lincoln contacting the right side of the Tempo, one impact with the front of the Lincoln contacting the rear of the stopped Ford at 36.8 mph. Rusty Haight and Jerry Eubanks. June 30, 1999 Performed and participated in a series of fifteen instrumented human volunteer tests examining effects of evasive vehicle swerving, accelerations (forces) of everyday activities including being bumped into from a walking individual both rear-to-back and side-to-side contacts, being slapped, and hitting one’s own head. Tests were conducted at Biomechanical Research & Testing, LLC, May 6, 1999 Performed and participated in a series of six tests to determine the motions and accelerations associated with an amusement-patk ride. April 5, 1999 Performed and participated in a series (April 5, 1999, April 9, 12 and 28, 1999, and May 27, 1999) of in excess of 110 mstrumented tests to determine the motions and accelerations associated with multi- directional amusement-park ride. Instrumented human subject testing was conducted with a small male child, a 50" percentile female, and a 50™ percentile male. Judson B. Welcher, Ph.D. : Page 17 Curriculum Vitae March 17, 1999 Feb, 25-26, 1999 January 10, 1999 January 10, 1999 January 9, 1999 Nov.30 - Dec, 4, 1998 November 16, 1998 October 27, 1998 October 20, 1998 Qctober 13, 1998 Participated in an instrumented vehicle-to-barrier impact with an instrumented Ford van impacting a trailer hitch receptacle mounted to a rigid barrier. Test was part of a four impact series to assess the i bumper performance in contacts with a trailer hitch receptacle, Tests were conducted at Biomechanical Research & Testing, LLC. | Performed and participated in 13 vehicle-to-vehicle impact tests with instrumented human volunteers. Impact configuration included two rear-end impacts with the front of a 1989 Nissan 240SX rear-ending a 1987 Honda Prelude, one underride impact with the front of the Nissan underriding the rear of the i Honda, two lateral impacts with the front of the Nissan contacting the side of the Honda, three rear-end impacts with a 1996 Chevrolet C1500 pickup rear-ending a 1992 Ford Aerostar van, two rear-end impacts with the Ford Aerostar van rear-ending the Chevrolet pickup, two rear-end impacts with the i front of the Nissan rear-ending a 1992 Ford Taurus and one high-speed frontal impact with the front of the Ford Taurus contacting the reat of the Ford Aerostar, deploying the Ford's airbag. Tests were conducted in Houston, Texas with Engineering and Fire Investigations, Inc, Performed and participated in eight vehicle-to-vehicle rear-end impact tests with instrumented human volunteers, Three different volunteers were tested representing an approximately 50" percentile female, a 50% percentile male and a 95" percentile male, Each occupant was exposed to two different vehicle velocity changes. Two of the tests were conducted at higher impact severities to evaluate contemporary seat safety designs, Tests were conducted to evaluate the influential variables affecting occupant injury parameters in rear-end collisions, Tests were conducted at Biomechanical Research & Testing, LLC. Performed and participated in five vehicle-to-vehicle rear-end impact tests. An instrumented female ; human volunteer representing an approximately 50" percentile female was exposed to vehicle Delta ! V'sof 1,2, 3, 4 and 5 mph. Tests were conducted to assess the relationship between vehicle velocity change and occupant kinematic parametets and injury potential, Tests at BRT, LLC. Performed and participated in instrumented seat component testing to evaluate different vehicle seat dynamic and static properties. Static tests were performed in a manner consistent with Federal Motor Vehicle Safety Standard (FMVSS) 202, Dynamic tests were conducted to simulate a 50% percentile male contacting the seat at 2,5 and 5 mph. Tests were conducted at Karco Engineering, Performed and participated in eight vehicle~to-vehicle impact tests with instrumented human volunteers, Impact configurations included tiree impacts with the front of a 1984 Nissan Sentra rear- ending a 1987 Rord Escort, one angled rear-end impact with the Escort rear-ended by a 1985 Nissan pickup, one impact with the Nissan pickup broad-siding the Escort, one impact with the Nissan sideswiping the Escort, one impact with the Nissan broad-siding the Nissan and one impact with the pickup broad-siding the other side of the Nissan at 33 mph. Tests were conducted with the Massachusetts State Police at the Massachusetts State Police Academy in New Braintree, MA. i Performed and participated in elevator drop tests with an instrumented human volunteer. Tests were conducted to determine the effects of various elevator malfunctions on an instrumented occupant, Additional everyday activity testing was conducted to quantitatively compare with the elevator tests. Performed and participated in train deceleration tests with an instrumented human volunteer. Tests were conducted to determine the magnitude and effects of train deceleration on an occupant suspended from the side ladder of a freight car. Performed and participated in instramented go-kert rollover tests, The go-kart was instrumented with i triaxial accelerometers and a triaxial array of pitch sensors to measure vehicle response. An ; instrumented Hybrid INT anthropomorphic test dummy seated in the occupant compartment was instrumented with a triaxial accelerometer array at the head center of gravity, chest center of gravity and pelvis. Chest deflection was measured via a potentiometer, Neck forces and moments were measured in all three orthogonal directions. Femur loads were recorded, Tests at Karco Engineering, Performed and participated in instrumented seat component testing to evaluate different vehicle seat dynamic and static properties. Static tests were performed in a manner consistent with FMVSS 202. Dynamic tests were conducted to simulate a 50™ percentile male contacting the seat at 2.5 and 5 mph. Judson B. Welcher, Ph.D, Page 18 Curriculum Vitae September 4-6, 1998 August 14, 1998 July 25, 1998 July 14-16, 1998 June 26, 1998. April 23, 1998 December 13, 1997 December 12, 1997 Performed and participated in 34 vehicle-to-vehicle rear-end impact tests with instrumented human volunteers. Three different volunteers were tested representing an approximately 50 percentile female, 50™ percentile male and 95" percentile male, Each occupant was exposed to two different Delta V's in 5 different seat configurations. Two of the tests were conducted at higher impact severities to evaluate contemporary seat safety designs. Tests were conducted to evaluate the influential variables affecting occupant injury parameters in rear-end collisions. Tests conducted at Biomechanical Research & Testing, LLC, Performed and participated in two vehicle-to-vehicle rear-end impact tests with an instrumented human volunteer. The first test involved the front of a 1991 Ford Explorer contacting the left rear corner of a 1987 Plymouth Voyager minivan, The second impact involved the Ford contacting the right rear corner of the minivan, Tests conducted at C.D.A. and at BRT, LLC, Performed and participated in ten vehicle-fo-vehicle rear-end impact tests with an instrumented human volunteer, Tests were conducted at target vehicle changes of speed between approximately 0.1 and 5 mph. All tests were conducted with the same female volunteer. Varying target vehicle velocity . changes where utilized to examine the relationship between impact severity and the forces and resultant occupant motions. Tests were conducted at Biomechanical Research & Testing, LLC, Performed and participated in 22 vehicle-to~vehicle impact tests with instrumented human volunteers. Impact configurations included five impacts composed of sideswipes, broadsides and lane change-type impacts with a 1989 Volvo coming inte contact with a 1992 Ford Taurys, one impact with a 1985 Nissan 200 SX broad-siding a 1987 Oldsmobile Regency, one impact with Oldsmobile contacting the left rear side of the Nissan in an offset broadside impact, four impacts with a 1988 GMC Suburban backing into the side of a 1992 Mercury Sable GS, two impacts with the Sable’s tight front contacting the left front side of a 1986 Chevrolet Caprice, three impacts with the Ford Taurus rear-ending a 1990 Acura Integra at various speeds and with various Acura braking conditions, one impact with a 1990 Honda Civic rear-ending and underriding the rear of the GMC Suburban, one impact with the GMC Suburban rear-ending and overriding the Honda Civic’s tear bumper, one impact with the Suburban sideswiping the Civic, two offset angled rear-end impacts with a 1988 Chevrolet Camaro rear-ending a 1984 Ford Range picloup truck and one impact with the Ford Ranger pickup truck sideswiping the Camaro. Tests were conducted for the JAARS conference Boston, MA. Performed and participated in a broadside impact in which the front of a 1991 Ford Explorer contacted the right rear bed section of a 1985 Chevrolet pickup truck (component test), Test was conducted at Collision Dynamics Analysis and Biomechanical Research & Testing, LLC. Performed and participated in seven vehicle-to-vehicle impact tests with instrumented human volunteers, Impact configurations included two impacts with a Buick Regal rear-ending a Ford Tempo, the Buick rear-ending the Ford with the Buick at a 35 to 40 degree angle, one rear-end impact with the Tempo underriding the Buick’s rear bumper, the Tempo broad-siding the Buick and one override impact of a large dump truck into the rear of the Buick, An additional ten tests were performed with the Tempo perpendicularly impacting a curb at speeds between 2.2 and 23.5 mph, Human volunteer data were collected on the three fastest curb impacts. Tests were conducted at the TEEX facility in Mesquite, Texas. Performed and participated in two vehicle-to-barrier impact tests with human volunteers and an instrumented Mazda RX7, Impact configurations involved an impact to the right reat corner at approximately 15 degrees from perpendicular and into the left rear corner at approximately 15 degrees from perpendicular. An instrumented male volunteer driver and an uninstrumented male volunteer wete present in the first test. Tests were conducted at Biomechanical Research & Testing, LLC with Thomas Fugger of Accident Research and Biomechanics. Performed and participated in six vehicle-to-barrier impact tests with an instrumented 1997 Jaguar XK8 and an instrumented human volunteer. Impact configurations included three impacts with the vehicle backed into the barrier and three with the vehicle driven forward into the barrier. An instrumented male volunteer was present in all tests, Tests were conducted at Biomechanical Research & Testing, LLC with Clark and Nelson, Inc. Judson B. Welcher, Ph.D. Page 19 Curriculum Vitae December 3, 1997 October 2, 1997 September 11, 1997 August 19, 1997 August 12, 1997 Tune 1, 1997 April 25, 1997 April 24, 1997 April 15, 17, 18, 1997 Performed and participated in ten vehicle-to~vehicle impact tests with instrumented human volunteer. Impact configurations included four impacts with a Oldsmobile rear-ending a Ford Mustang, two impacts with the corner of a Toyota Celica impacting the front fender and rear quarter panel of an Oldsmobile, one impact with the front of a Toyota Corolla impacting the edge of an open driver’s door of a Toyota Celica, one offset broadside impact with the front of a Ford Mustang contacting the right front tire area of a Toyota Corolla, a Ford Mustang sideswiping a Toyota Corolla and one high speed frontal impact with the front of the Ford Mustang contacting the front of the Oldsmobile. Both airbags deployed in the Ford Mustang during the high-speed frontal. Performed and participated in twelve vehicle-to-vehicle impact tests with instrumented human volunteers. Impact configurations included five impacts with a Chevrolet Chevette rear-ending a Nissan Maxima, four impacts with the Nissan Maxima rear-ending the Chevrolet Chevette, two impacts with a Oldsmobile Achieva rear-ending a Ford Taurus and one impact with a Ford Taurus rear- ending the Chevrolet Chevette. Two of the impacts involved chain-reaction rear-end impacts. Tests were conducted at the NJAAR/NAPARS/NATARI/MATAI Joint Conference in Atlantic City, New Jersey with Rusty Haight and Jerry Eubanks. Performed and participated in eight vehicle-to-vehicle impact tests with an instrumented human volunteer. Tmpact configurations included four rear-end impacts with a Ford Crown Victoria rear- ending a Ford Mustang, two rear-end impacts with the Ford Mustang rear-ending the Ford Crown Victoria, one offsct lateral impact with the front of the Mustang contacting the front of the Crown Victoria and one sideswipe impact. An instrumented male volunteer was used in all tests. Tests were conducted at the South Carolina State Highway Patrol facilities in conjunction with the South Carolina Major Accident Investigation Team (MAIT), Performed and participated in twenty two vehicle-to-vehicle front-to-rear impact tests with a Dodge Shadow as the target vehicle and a Pontiac Bonneville as the bullet vehicle, An instrumented male volunteer was used in all tests. Test conditions evaluated the effects of varying degrees of occupant braking and bracing, Tests were conducted at Biomechanics Analysis in Tempe, Arizona. Performed and participated in two instrumented vehicle-to-vehicle impacts. One rear-end impact was performed with a Plymouth Horizon rear-ending a similarly weighed vehicle at approximately 30 mph. The other impact involved a Chevrolet Suburban rear-ending a Plymouth Horizon at approximately 30 mph. Tests were conducted with Rusty Haight and Jerry Eubanks, Film footage aired on the television program 20/20 on Septeraber 11, 1997. Performed and participated in a rear-end-to-bartier impact with an instrumented volunteer driver at an 8.0 mph closing speed. The instrumented driver was positioned with his head rotated 90 degrees to his right and his right arm was positioned across the bench-type seat back. The vehicle impacted the barrier at an angle of approximately 12,5 degrees from perpendicular, The test was conducted by Collision Dynamics Analysis and B.R.T. Performed and participated in fourteen vehicle-to-vehicle impact tests with instrumented human volunteers. Impact configurations included rear and frontal impacts into poles, override impacts, aligned rear-end impacts and sideswipe impacts. Vehicles included a Ford F350 pickup, a Pontiac T1000, a Toyota Corolla, a Pontiac LeMans and a Ford Aerostar minivan, Tests were conducted at Billy Cox and Associates in Houston, Texas. Performed and participated in seven vehicle-to-vehicle impacts with instrumented human volunteers, Impact configurations included rear-end impacts with various degrees of occupant braking and awareness, offset rear-end collisions, thres~vehicle chain-reaction rear-end collisions, one oblique side impact and underride collisions. Performed and participated in a series of tests to determine the motions and accelerations associated with an amusement park ride. Judson B, Welcher, Ph.D. . Page 20 Curriculum Vitae March 20-28, 1997 December 8, 1996 October 3, 1996 Tuly 14, 1996 Tuly 12-13, 1996 Tuly 9, 1996 Tune 28-29, 1996 June 15, 1996 June 14, 1996 Tune 14, 1996 April 24, 1996 February 3-4, 1996 January 19, 1996 Performed and participated in twenty seven instrumented vehicle impacts. A total of nine different vehicles were used including a Kia Sephia, a Bluebird Wanderlodge, a Ford Explorer, a Kenworth tractor with a Great Dane trailer, an Oldsmobile Cutlass Supreme, a Ford LTD, an Oldsmobile Cutlass Calais, a Ford LTD Landau and a Chevrolet Caprice. Eighteen of the impacts were reat-end type impacts, Underride collisions were performed to the side and rear of the Great Dane {railer. Frontal impacts to Jersey barriers were performed. Broadside collisions were also performed with instrumented vehicles and volunteers, All tests were performed at the TAARS — SOAR — WATAI ~ Crash 97 Combined Conference in College Station, Texas, Performed and participated in twelve vehicle-ta-vehicle impacts with an instrumented human volunteer. Tmpact configurations included aligned rear-end impacts, offset left and offset right rear-end impacts, a sideswipe, a broadside, a sideswipe of an open door, angled rear-end impacts and underride impacts. Vehicles used included a Pontiac Grand Am and an Oldsmobile Cutlass. Performed and participated in eight vehicle-to~vehicle impacts with instrumented human volunteers. In all tests, an instrumented 1989 Hyundai Excel was contacted by a 1988 Ford Festiva, Impact configurations included five aligned front-to-rear tests, one angled rear-end impact, one sideswipe and one broadside impact, Performed and participated in fifteen vehicle-to~vehicle front-to-rear impact tests with a Dodge Shadow as the target vehicle and a Chevrolet Nova as the bullet vehicle. An instrumented female volunteer was used in all fifteen tests, Tests were conducted at Biomechanics Analysis in Tempe, Arizona. Observed nineteen instrumented vehicle-to-vehicle impacts with various types of vehicles with changes in velocity between 48 and 9.2 mph, Impact configurations included rear impacts to pickup trucks, aligned rear-end impacts, high-angle sideswipe, sideswipe and a three-vehicle chain-reaction impact, Vehicles included standard passenger vehicles and pickup trucks. Performed and participated in three vehicle-to-barrier impact tests with an instrumented male human volunteer ih a 1990 Chevrolet Corsica. The Chevrolet Corsica was backed into a barrier at three different impact speeds. Tests were conducted at Biomechanical Research & Testing with John Perry, Ph.D. Performed and participated in a series of tests with instrumented human volunteers to determine the motions and accelerations during horseback riding and riding in a motor boat. Performed and participated in a series of tests with insttumented human volunteers to determine the motions and accelerations associated with activities of daily living, Performed and participated in a series of five tests with instrumented human volunteers determining the motions and accelerations associated with braking a vehicle while driving backward, braking a vehicle while driving forward, going over a speed bump, plopping into vehicle seat and making a sharp turning maneuver, Performed and participated in a series of five vehicle-to-vehicle front-to-rear impact tests with an instrumented human volunteer in a 1990 Honda Accord. Tests were conducted with target vehicle changes in velocity of 0.8, 1.1, 1.5, 1.8 and 3.3 mph. The volunteer was instrumented with accelerometers to measure occupant accelerations, Performed and participated in a series of tests to determine the motions and accelerations associated with a new amusement park ride, Performed and participated in a series of ten vehicle-to-vehicle front-to-rear impact tests with instrumented human volunteers in 1976 and 1977 Volvos, Volunteers were instrumented with EMG electrodes to measure muscle activity and with accelerometers to measure occupant accelerations, Performed and participated in a seties of tests to determine the motions and accelerations associated with numerous amusement park rides. Judson B. Welcher, Ph.D. Page 21 Curriculum Vitae July 21-22, 1995 October 15, 1993 July 1, 1993 June 16, 1993 May 13, 1993 Match 4, 1993 January 19, 1993 January 1993 January 1993 September15,17, 1992 June 28, 1992 March 14, 1992 January 1992 August 1991 July 1991 March 1991 Observed twenty six rear-end impacts with various types of vehicles and impact speeds between 2.5 and 9.7 mph. Five of the tests included instrumented human volunteers exposed to Delta V's between 4,6 and 5.66 mph, A sideswipe and a lateral collision were also observed. Performed and participated in a series of tests to determine the motions and accelerations associated with a boat-type amusement-park ride. Performed and participated in a series of tests to determine the motions and accelerations experienced while riding a roller coaster. Performed a seties of tests for the Scottsdale Police Department to determine the amount of force generated by various types of police batons utilizing three different stroke techniques. Performed testing to determine the forces generated by the use of "less-than-lethal” projectiles for the Los Angeles Police Department. . Performed and participated in a seties of tests to detetmine the motions and acceletation experienced while riding a roller coaster. Performed a series of tests for the Los Angeles Police Department to determine the amount of force generated with a side-handle police baton using a power stroke technique. Also, conducted testing to determine the forces generated by the use of "less-than-lethal” projectiles, Performed a series of impact tests using an accelerometer-instrumented FMVSS headform. The headform was impacted against a passenger vehicle head restraint at various speeds. Performed a series of three bus-to-car impact tests. The car was instrumented with accelerometers. Performed and participated in a series of tests to determine the motions and accelerations experienced while riding amusement park rides, Performed and participated in a series of six vehicle-to-vehicle impacts tests with instrumented volunteers and vehicles at impact speeds of 6.6 to 10,6 mph. These tests were conducted with vatious impact configurations. Performed a series of tests to determine the amount of force generated with various types of police batons using different stroke techniques. Performed and participated in six vehicle-to-vehicle front-to-rear impact tests using 1981-83 Ford Escorts at 5, 10 and 15 mph. Tests wete conducted at Mobility Systems and Equipment Company, San Bernardino, California. Performed and participated in five vehicle~to-vehicle front-to-rear impact tests at 10 mph using 1981~ 83 Ford Escorts with instrumented human volunteers and anthropomorphic dummies, These tests were conducted at Mobility Systems and Equipment Company, San Bernardino, California, Observed a high-speed car-to-motoreycle front-to-rear staged crash test. Petformed two pendulum-to-vehicle rear-impact tests at 5 and 10 mph using a 1988 Lincoln Towncar and an instrumented human volunteer. These tests wete conducted at Mobility Systems and Equipment Company, San Bernardino, California. Judson B. Welcher, Ph.D. Page 22 - Curriculum Vitae PROFESSIONAL AFFILIATIONS American Society of Biomechanics American Society of Mechanical Engineers American Society for Testing and Materials - F24 Committee on Amusement Rides and Devices Association for the Advancement of Automotive Medicine Biomedical Engineering Society Pi Tau Sigma, Mechanical Engineering Honor Society Society of Automotive Engineers Southwestern Association of Technical Accident Investigators Sports Car Club of America (Licensed SSGT race car driver for 1989) PRESENTATIONS AND PUBLICATIONS Popovich, J.M.,, Jr., Welcher, .B., Hedman, T.P., Tawackoli, W., Anand, N., Chen, T.C., Kulig, K. (2013). Lumbar facet joint and intervertebral disc loading during simulated frontal plane pelvic obliquity. The Spine Journal, [published online ahead of print May 21, 2013]. Welcher, I., Popovich J,, Hedman, T., Tawackoli W., “A New Sensor Array for Measuring Intra-Articular Pressure; Evaluation and Validation, ” Published and presented at 2010 Summary Bioengineering Conference, American Society of Mechanical Engineers. Naples, FL, Accepted for publication and presentation on June 18, 2010. Randles, B., Jones, B., Welcher, J., Szabo, T., Elliott, D. and MacAdams, C, (2010). The accutacy of photogrammetry vs. hands- on measurement techniques used in accident reconstruction. Presented at the Society of Automotive Engineers International Congress and Exposition, Occupant Protection and Accident Reconstruction technical session, April 14, 2010, Society of Automotive Engineers Paper No, 2010-01-0065, Published in SP-2267 Accident Reconstruction 2010, Popovich J., Welcher I., Cholewicki, J., Tawackoli W., Kulig K., “Zhe Effect of ‘Follower Load on Lumbar Spine Facet Joint Forces and Intervertebral Disc Pressures,” Published and presented at the Annual Meeting of the American Society of Biomechanics, Penn State University, University Park, PA, Poster presented August 28, 2009, Welcher, T., Popovich J,, Hedman, T., Tawackoli W., “Development and Validation of a Versatile Intra-Articular Pressure Sensing Array,” Published and presented at the Fourth North American Congtess of Biomechanics (Joint meeting of the American Society of Biomechanics and Canadian Society of Biomechanics), Ann Arbor, Michigan, Presented August 6, 2008, Singh J., Perry, I., Welchet, J., “Single Point Crush Variation,” Collision Magazine, Volume 3, Issue 1, 90-93, Spring 2008. Popovich, TM, Ir., Welcher, J.W,, Kulig, K., Pelled, G., Gazit, D,, and Tawackoli, W. (2007). The effect of loading rate on porcine lumbar spinal segments: An in-vitro biomechanical study. American Society of Biomechanics 2007 Annual Conference, Palo Alto, CA, August 22-25, 2007. (Abstract) Welcher, I., Popovich, J., and Hedman, T. “Development of a Novel Intra-Articular Pressure Sensing Array,” 5 published and presented at the 11" Annual Grodins Graduate Research Symposium, University of Southern California, Biomedical Engineering Department, April 11, 2007, Welcher, J., “Pedestrian Impact Biomechanics” invited presentation and publication at ARC-CSI Crash Conference 2005. Patel V., Welcher I, Bae H., Delamarter R., Pradhan B., Hedman T, “Floating and Fixed Center of Rotation Intervertebral Prostheses; Biomechanical Comparison” Proceedings of the Spine Arthroplasty Society Summit 4, Vienna Austria, May 2004, Singh, J,, Welcher, J, and Petry, J., “N-point Linear Interpolation of. ‘Motor Vehicle Crush Profiles Applied to Various Force- Shortening Models,” International Journal of Crash Worthiness, 2003; 8: 321-328, Welcher, J., “Collision Trauma Biomechanics” invited presentation and publication at ARC-CSI Crash Conference 2003, Welcher, J., “Occupant Kinematics (Biomechanics) ” invited presentation and publication at Special Problems in Traffic Crash Reconstruction, Institute of Police Technology and Management (IPTM), presented at Breakout Sessions : i i + i Judson B. Welcher, Ph.D. Page 23 Curriculum Vitae Fugger, T., Randles, B., Welcher, J., and Szabo, T., “Vehicle and Occupant Kinematics in Low- Speed Override/Underride Collisions, " presented at the Society of Automotive Engineers International Congtess and Exposition, March 2003. SAE Paper No. 2003-01-0158. Singh, J., Welcher, J. and Perry, J., “Effects of Mass and Stiffness Ratio Variation on Vehicle Speed Change and Closing Speed Calculations," presented at the Society of Automotive Engineers International Congress and Exposition, March 2003. SAE Paper No, 2003-01-0890. Orange County American Board of Trial Advocates, “Masters in Trial: A Trial Demonstration,” Orange County, September 27, 2002. Presiding Judge Honorable Ray Ikola, Orange County Superior Court, ‘ Szabo, T., Voss, D. and Welcher, I.: “fluence of Seat Foam and Geometrical Properties on BioRID P3 Kinematic Response to Rear Impacts,” proceedings of 2002 International IRCOBI Conference on the Biomechanics of Impact, pp 87-101, Munich, Germany, September 18-20, 2002. Orange County American Board of Trial Advocates, “Masters in Trial: Technologies in the Courtroom,” Chapman University School of Law, June 21, 2002. Szabo, T., Voss, D. and Welcher, J, “Relationship Between Impact Pulse Duration and Occupant Kinematics in Low Speed Rear Impacts,” presented at the Society of Automotive Engineers International Congress and Exposition, March 4, 2002, Published in . SP 1665. SAE Paper No, 2002-01-0029, Fugger, T., Randles, B., Wobrock, J., Welcher, J. and Voss, D., “Human Occupant Kinematics in Low Speed Side Impacts,” presented at the Society of Automotive Engineers International Congress and Exposition, March 4, 2002. Published in SP 1665. SAE Paper No, 2002-01-0020, Welcher, J., Szabo, T. and Voss, D., “Statistical Dependence of Human Occupant Accelerations on Vehicle Impact Measures in Rear-End Impacts,” presented at the 2001 ASME (American Society of Mechanical Engineering) International Mechanical Engineering Congress & Exposition, November 13, 2001, Published in Volume 1 of the IMEC2001 Proceedings. ASME Paper No. BED-23103. - Welcher, J. and Szabo, T., “Relationship Between Seat Properties and Human Subject Kinematics in Rear-Impact Tests,” Accident Analysis & Prevention, 33, pp 289-304, 2001. Welcher, J., “Admissibility of Biomechanical Testimony Under Daubert,” Presented at the ANPAC 2001 SIUMIST/ Litigation Training Conference, Springfield, Missourd, June 8, 2001, Welcher, J, “Mitigating Whiplash Associated Disorders (WAD) Through Automotive Seat Design, # 5 Annual Grodins Graduate Research Symposium, University of Southern California, Biomedical Engineering Department, April 30, 2001, Singh, J., and Welcher, J., “Subacromial Impingement Syndrome in the Context of Minor Velocity Rear-End Motor Vehicle Collisions,” S™ Annual Grodins Graduate Research Symposium, University of Southern California, Biomedical Engineering Department, April 30, 2001, Welcher, J., Szabo, T., and Voss, D., “Human Occupant Motion in Rear-End Impacts: Effects of Incremental Increases in Velocity Change," presented at the Society of Automotive Engineers International Congress and Exposition, March 7, 2001. Published in SP 1572. SAE Paper No. 2001-01-0899. Caxpenter, N. and Welcher, I., “Stiffness and Crush Energy Analysis for Vehicle Collision and Its Relationship to Barrier Equivalent Velocity (BEV),” presented at the Society of Automotive Engineers International Congress and Exposition, March 6, 2001. Published in SP 1572, SAE Paper No, 2001-01-0500. Welcher, J., “Occupant Modeling for Accident Reconstruction,” presented at the Accident Reconstruction: State-of-the-Art TOTPEC, sponsored by the Society of Automotive Engineers (SAE) Continuing Professional Development Group, December 9- 10, 1999. Published in the proceedings. Welcher, J, and Szabo, T., “Relationship Between Seat Properties and Human Subject Kinematics in Rear-Impact Tests,” presented at the World Congress on Whiplash Associated Disorders (WAD), Vancouver, British Columbia, Canada, February 7- 11, 1999, Published in the compendium of papers of the Traffic Safety and Auto Engineering Stream. Received the award for best paper in the Traffic Safety and Auto Engineering Stream for demonstrating innovation and excellence in research activities, Szabo, T. and Welchet, J., “Biomechanics of Low-Speed Impacts,” presented and distributed at the International Association of Accident Reconstruction Specialists (IAARS) 1998 Conference, Boston, Massachusetts, July 13, 1998. Judson B. Welcher, Ph.D. : Page 24 Curriculum Vitae Anderson, R., Welcher, I., Szabo, T., Eubanks, J. and Haight, W., “Effect of Braking on Human Occupant and Vehicle Kinematics in Low-Speed Rear-End Collisions, ” presented af the Society of Automotive Engineers International Congress and Exposition, February 1998. SAE Paper No. 980298 (In SAE Transactions). ‘Weber, B., Evenson, D., Szabo, T. and Welcher, J, “Low-Speed Car Impacts with Different Bumper Systems: Correlation of Analytical Model with Tests,” published in Mechanisms of Protection (SP 1355). SAE Paper No. 980365. Schmidt, B., Haight, W., Szabo, T. and Welcher, J,, “System-Based Energy and Momentum Analysis of Collisions,” presented at the Society of Automotive Engineers International Congress and Exposition, February 1998. Published in Accident Reconstruction; Technology and Animation VIII (SP 1319), SAE Paper No. 980026 (In SAE Transactions). Szabe, T. and Welcher, I., “Recent Research on Low-Speed Collisions,” presented at the Society of Forensic Engineers and Scientists meeting in Santa Barbara, California, October 18, 1997, Welcher, T. and Szabo T., “Introduction to Low-Speed Impacts,” introductory section to Analysis of Low-Speed Collisions, an extension course for University Engineering Extension Services, Texas A&M University, College Station, Texas. Regularly updated since 1996, Szabo, T. and Welcher, J,, “Human Subject Kinematics and Electromyographic Activity During Low-Speed Rear Impacts,” published in the Proceedings of the 40" Stapp Car Crash Conference. SAE Paper No, 962432, Szabo, T, and Welcher, J, "Human Subject Response to Various Acceleration Fields,” presented at the Low-Speed Collision TOPTEC, sponsored by SAE Continuing Professional Development Group, August 19-20, 1996. Published in the proceedings. Vangsness, C., Heinsohn, R., Scharphuis, 1, Schmotzer, H., Welcher, J. and Hedman, T., “The In-Vitro Analysis of the Weight Bearing Kinematics of the Intact and ACL Deficient Knee,” presented at the ACL Study Group Meeting, Nevis, West Indies, April 27-May 4, 1996. Also presented at the Annual Meeting of the University of Southern California Graduate Orthopaedic Society, June 20-21, 1996. ‘Ward, C., Szabo, T. and Welcher, J., "Recent Research on Rear-Impact Collisions," presented at the Low-Speed Rear-Impact Collision TOPTEC, sponsored by SAE Continuing Professional Development Group, August 8-9, 1994, Published in the proceedings, Szabo, T., Welcher, T., Anderson, R,, Rice, M., Ward, J., Paulo, L. and Carpenter, N., "Human Occupant Kinematic Response to Low-Speed Rear-End Impacts,” presented at the Society of Automotive Engineers International Congress and Exposition, March 1994, Published in Occupant Containment and Methods of Assessing Occupant Protection in the Crash Environment (SP 1045). SAE Paper No, 940532 (In SAE Transactions), Rice, M., Welcher, I. and Ward, J., "Comparative Analysis of Riot-Control Projectile Testing, “ presented at the American Academy of Forensic Sciences 46th Annual Meeting, San Antonio, Texas, February 1994. Abstracted in the proceedings, Welcher, J, and Ward, J., "The Rodney King Case: An Analysis of the Forces Produced From Baton Strikes," presented at the Tnternational Association of Forensic Sciences 13th Meeting, Diisseldorf, Germany, August 1993, Published in the proceedings. "Riot-Control Projectile Tests: Data Report," prepared for Sergeant George E, Haines of the Los Angeles Police Department, Metropolitan Division, July 1993. “Baton and Riot-Control Projectile Tests: Data Report" prepared for Sergeant George I, Haines of the Los Angeles Police Department, Metropolitan Division, April 1993, Welcher, J., Ward, J, and Ward, C., "Biomechanical Analysis of Forces Produced from Baton Strikes," presented at the American Academy of Forensic Seiences 45th Annual Meeting, Boston, Massachusetts, February 15-20, 1993. Abstracted in the proceedings. Szabo, T. and Welchet, I., "Dynamics of Low-Speed Crash Tests with Energy-4bsorbing Bumpers," presented at the Future Transportation Technology Conference, Costa Mesa, California, August 1992. Published in Automobile Safety: Present and Future Technology (SP 925). SAT Paper No. 921573 (Tn SAE Transactions), Welcher, ., "Contribution of Energy-Absorbing (EA) Bumpers to Occupant Protection," presented at the American Academy of Forensic Sciences 44th Annual Meeting, New Orleans, Louisiana, February 17-22, 1992. Abstracted in the proceedings. Revised 10/25/13 (4/06-585+228) EXHIBIT “C” S O W [62 ] 10 11 12 13 14 15 16 17 18 19 20 gil 22 23 24 25 26 27 28 TEE VE | 1 24 200 CLEIDIN Z. ATANOUS, ESQ., , (State Bar No.: 189149) ii {2s J LAW OFFICE OF CLEIDIN Z. ATANOUS 500 S. Kraemer Boulevard Suite 205 Brea, California 92821 PH: (714) 528-8226 / FAX: (714) 528-8227 Attorney for: Defendants, JEFFERSON ENRIQUEZ ERODRUFF, SPRADLIN & SMART File No.: 14-0703¢ SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF ORANGE RAMIN MIRFAKHRAIE, SHAHRAIR CASE NO: 30-2014 00707952 MIRFAKHRAIE, MOJGAN MIRFAKHRAIE, and SEPIDEH MIRFAKHRAIE AUGMENTED WRITTEN EXCHANGE OF REQUIRED Plaintiff(s), EXPERT WITNESS INFORMATION AND EXPERT VS. DECLARATION (C.C.P. §2034.210, et al.) CITY OF IRVINE, JEFFERSON ENRIQUEZ, and DOES 1 to 50, inclusive, TRIAL DATE: 6/1/15 Defendant(s). TO: ALL PARTIES AND TO THEIR ATTORNEYS OF RECORD: PLEASE TAKE NOTICE that Defendant, JEFFERSON ENRIQUEZ, augments his previously served Written Exchange of Required Expert Witness Information to include the following individual as an expert ready to testify at time of trial: Anthony Stein, PhD., Human Factors, or other qualified individual at Safety Research Associates, Inc., 4739 La Canada, CA 91011; (818) 952-1500. Co DATED: April 22, 2015 LAW OFFICES OF CLEIPIN ” Z ~ATANOUS LT ye yd yd A me i— ., CLEIDIN'Z. ATANOUS; ESQ. Attoraeys for Defendant(s) JEFFERSON ENRIQUEZ ioc, 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 EXPERT WITNESS DECLARATION I, Cleidin Z. Atanous, Esq. , say and declare: 1. I am an attorney duly licensed to practice law before the Courts of the State of California, and am associated with the Law Offices of Cleidin Z. Atanous, attorneys of record for defendant, JEFFERSON ENRIQUEZ . I have personal knowledge of the matter set forth in this declaration, and would testify thereto if called as a witness. Zs Defendant, JEFFERSON ENRIQUEZ , hereby gives notice pursuant to C.C.P. §2034, that he intends to call Anthony Stein, PhD., or other qualified individual at Safety Research Associates, Inc., 4739 La Canada, CA 91011; (818) 952-1500. A. Said expert witness will qualify as a Human Factors. B. Said expert witness will testify concerning issues including but not limited to human factors, perception, reaction, behaviors, and cognition. C. Said expert witness has agreed to testify at the trial. Said expert witness will be sufficiently familiar with the pending action to submit to a meaningful oral deposition concerning the specific testimony, including any opinion and its basis, that he is expected to give at trial. E. Said expert's expert fee for deposition will be $480/ hour, with the deposition to take place in his office. F. Attached heretois a true and correct copy of Anthony Stein, PdD’s curriculum vitae. I declare under penalty of perjury pursuant to the laws of the State of California, that the foregoing is true and correct. Dated this _ 22nd day of _April 2015, at Bxea, California, ri apni” ” [ rr ) ” ra mn erie (LEI Z-ATANOUS; BS, prs” SAFETY RESEARCH ASHOEIATES, ING. - Anthony C. Stein, Ph.D. Dr. Stein received his Ph.D. in Psychology at Saybrook University in 1985. He received his B.A. in Psychology from Immaculate Heart College in 1975. He is currently President and Technical Director of Safety Research Associates, Inc. and is an Adjunct Assistant Professor in the Department of Neurology, School of Medicine at the University of Kansas. Since 1975 he has been involved in studying various aspects of human operator performance. His major research areas have involved impaired operator behavior, vision and visibility and advanced vehicle technologies. Dr. Stein has been responsible for several studies whose primary purpose has been determination of operator fitness-for-duty. These studies have included development of equipment and tests for such determination, and conducting both controlled and work place field studies. He has also been responsible for several field studies on the effectiveness of various in-vehicle warning systems. Other areas of research expertise include: studying the effects of alcohol, marijuana, reduced visibility, noise, vibration, stress, fatigue, and workload on the operator's ability to make decisions and control vehicles. Recent research studies have included developing new methods for investigating pedestrian behavior. Dr. Stein has also studied driver reaction to various road signs; determined the expected behavior of drivers and pedestrians in various situations, including the use of in-vehicle navigation systems; determining the safety aspects of cellular mobile telephones; and assessing the safety aspects of various in-vehicle anti—collision warning devices. He has also studied the requirements for drivers’ to detect and identify various parts of the highway visual scene, Because of his heavy vehicle research Dr. Stein held a Class A drivers license from 1978 through 2008. Dr. Stein has authored over 100 published technical articles, reports, and papers. He was invited to give sworn testimony to the California Senate Transportation Committee on the effects of alcohol on driving performance, and to the California Senate Industrial Relations Committee on fitness-for-duty testing devices. Dr. Stein has been sponsored by the New Zealand Government and New Zealand National Research Council to lecture on the effects of alcohol and drugs on driving performance. He has also been the invited Keynote Speaker at many international conferences where he has spoken on operator fitness for duty, human factors in the transportation system, and driver impairment due to fatigue, alcohol and drugs, and visual impairment. Dr. Stein has qualified as an expert witness in court on numerous occasions; and has been interviewed on the effects of alcohol, drugs, fatigue and operator behavior on national and international television and radio, and by the print media in the U.S, Canada, Japan, New Zealand and Australia. - SAFETY RESEARCH ASSOCIATES, INC, - Dr. Stein is the recipient of the Transportation Research Board’s Pedestrian Committee Outstanding Research Paper Award in 2000, the Society of Automotive Engineers’ Arch T. Coldwell Award for Outstanding Paper of the Year in 1991, and the Association for the Advancement of Automotive Medicine’s Best Scientific Paper Award in 1984. Dr. Stein has also been chosen as a judge of the 2007 Michelin Challenge Design Competition where international design teams were challenged to develop an “Independently Safe Vehicle Designed to Share the Road.” Dr. Stein is the Past-Chairman of the Human Factors Section of the Association for the Advancement of Automotive Medicine, and he served on the Association’s Scientific Review Committee from 1989 to 1992, and he is currently serving his second term on the committee. He served on the editorial review boards of Human Factors in Transportation and Accident Analysis and Prevention. He currently serves on the editorial review board of Traffic Injury Prevention. He isa Grants Reviewer for the National Institute of Alcoholism and Alcohol Abuse. He is also a member of the American Psychological Association, the Human Factors and Ergonomics Society where he was Secretary of the Los Angeles Chapter, the Association for the Advancement of Automotive Medicine, the International Council on Alcohol Drugs and Traffic Safety, and the Society for Engineering Psychologists. Dr. Stein completed nine years service on the Transportation Research Board’s Committee on Alcohol, Other Drugs, and Transportation, and over 25 years on the Committee on Road User Characteristics. He served for 12 years as a member of the Board’s Committee on Bicycle Transportation where he was the past Secretary, and he founded and chaired a Task Force on Emerging Technologies in Personal Transportation for 12 years. Dr. Stein also serves on the Society of Automotive Engineers Working Group on IVHS Human Factors and Safety where he chaired a subcommittee on human factors guidelines for warning system interfaces from 1993 to 1999. He serves as a member of the advisory group to the United States Delegation to the International Standards Organization technical group on Human Factors Standards for ITS systems. SAFETY RESEARCH ASBO0EIATES, INC. - Selected Publications Driving simulator performance in patients with possible and probable Alzheimer’s disease. Annals of Advances in Automotive Medicine, 55, pp 235-334, 2011. What is driving the legal interest in hepatic encephalopathy? Clinical Gastroenterology and Hepatology. 9, pp. 97-98, 2011, Practice Parameter update: Evaluation and management of driving risk in dementia: Report of the Quality Standards Subcommittee of the American Academy of Neurology. Neurology, 74 (16), pp 1316-1324, 2010. Editorial: MHE and Driving, Hepatology, 50 (4), pp 1007-1008, 2009 Commercial drivers and drowsy driving: An overview and implications for research, public policy, and education, Washington, D.C.: National Sleep Foundation, 2003. Analysis of Pedestrian Gait and Perception/Reaction at Signal-Controlled Crosswalk Intersections. Washington, D.C. : Transportation Research Board, 2000. Intelligent Transportation Systems: How Can Cutting Edge Technology Reduce Road Crashes?. In Road Safety Council of Western Australia (ed.) 2001: A Road Safety Odyssey. Perth, Western Australia: Road Safety Council of Western Australia, 1997. Driving Simulator Study of the Performance Effects of Low Blood Alcohol Concentrations. In HFES (ed.) Proceedings of the 40" Annual Meeting of the Human Factors and Ergonomics Society. Santa Monica, CA: HFES, 1996 The Effect of Phenytoin on Driving Performance in Well Controlled Epileptics. In L. Hartley (ed.) Fatigue and Transportation: Engineering, Enforcement and Education Solutions, Perth, Western Australia: Promaco, 1996, pp. 303-310. An Annotated Bibliography of Human Factors Literature in Intelligent Transportation Systems. Detroit, MI: AAMA, 1995. A Brief History of the Use of In-Vehicle Devices for Preventing Alcohol-Impaired Driving. In Transportation Research Board (ed.) Strategies for Dealing with the Persistent Drinking Driver. Washington, D. C.: Transportation Research Board, 1995, pp. 56-59 (TRR 437). _ SAFETY RESEARCH ASSOCIATES, INC. [ Performance Testing as a Determinant of Fitness-for-Duty: Recent U.S. Experiences. In A. Feyer (Ed.), Human Factors in Transportation: Current Issues, Sydney, Australia: Worksafe Australia, 1993, pp. 1-9. Vehicle Simulation and Fatigue. In Promaco Conventions Pty. Ltd (Ed.), Proceedings of the Chartered Institute of Transport in Australia - National Conference. Perth, Australia: Chartered Institute of Transport in Australia, 1993, pp. 115-129. Detecting Fatigue Impaired Drivers with Low Cost Interactive Driving Simulators. In Centers for Disease Control (ed), Abstracts of The Second World Conference on Injury Control. Atlanta, GA: Centers for Disease Control, 1993, pp. 199. Low-cost interactive Driving Simulator - Monash University Accident Research Centre. In E. Hoffman & O. Evans (eds.) Unlocking Potential for the Future Productivity and Quality of Life. Melbourne, Australia: Ergonomics Society of Australia, 1992, pp. 213. In-Vehicle Navigation Systems: Research on Driver Behavior and Traffic System Performance. Washington, D. C.: Transportation Research Board, 1992. High Risk Driver Project: Theory, Development and Validation of the Truck Operator Proficiency System (TOPS). Vol. 1: Executive Summary. Hawthorne, CA: Systems Technology, Inc., 1992 (NTIS: in press). National Advanced Driving Simulator (NADS) Requirement Study. Washington, D.C.: U.S. Department of Transportation, 1991 (NTIS, DOT HS 807 827). A Human Factors Simulation Investigation of Driver Route Diversion and Alternate Route Selection Using In-Vehicle Navigation Systems. Warrendale, PA: Society of Automotive Engineers, 1991 (SAE Paper 912731). Validation of Real-Time Man-in-the-Loop Simulation. In N. O. Joergensen (ed.) Proceedings of the Conference Strategic Highway Research Program and Traffic Safety on Two Continents (Part 4). Linkoeping, Sweden: Statens Vaeg- och Trafikinstitut,, 1991. The Development of a Low-Cost Portable System for the Detection of Truck Driver Fatigue. In B. Petrocelli (Bd.) Proceedings of the 34th Annual Conference of the American Association for Automotive Medicine. Des Plains, IL: American Association for Automotive Medicine, 1990. - EAPETY RESEARCH ASSOCIATES, ING, ~ A Low Cost, Part Task Driving Simulator Based on Microcomputer Technology. Washington, D.C., National Academy of Sciences, Transportation Research Board, 1990. High Risk Driver Project: Development of Methods for Testing Truck Driver Fatigue, Hawthorne, CA: Systems Technology, Inc., 1990 (NTIS: in press). Human Factors and the National Transportation Policy: How to Remove the Impaired Transportation Worker. Hawthorne, CA: Systems Technology, Inc., 1989. Overhead Guide Sign Visibility Factors, Volumes I and II. Washington, D.C.: U.S. Department of Transportation, 1989 (NTIS, FHWA-RD-88-196, 197). Field Evaluation of a Nissan Laser Collision Avoidance System. Washington, D.C.: U.S. Department of Transportation, 1989 (NTIS, DOT-HS-807 375). The Driving Task, Driver Performance Models and Measurements. In J. F. O'Hanlon and J. J. de Gier (Eds.) Drugs and Driving - II. Philadelphia: Taylor and Francis, in press. A Simulator Study of the Safety Implications of Cellular Mobile Phone Use. In E. Petrocelli (Ed.) Proceedings of the 31st Annual Conference of the American Association for Automotive Medicine. Arlington, IL: American Association for Automotive Medicine, 1987. A Simulator Study of the Effects of Alcohol and Marihuana on Driving Behavior. InP. C. Noordzij and R. Roszbach (Eds.) Alcohol, Drugs and Traffic Safety - T86. New York: Excerpta Medica, 1987. The Effects of Alcohol on Driver Decision Making and Risk Taking. InP. C. Noordzij and R. Roszbach (Eds.) Alcohol, Drugs and Traffic Safety - T86. New York: Excerpta Medica, 1987. ’ The Development and Use of Tn-Vehicle Devices to Reduce Alcohol and Drug Impaired Driving. InP. C. Noordzij and R. Roszbach (Eds.) Alcohol, Drugs and Traffic Safety - T86.. New York: Excerpta Medica, 1987. The Effects of Alcohol on Driver Decision Making and Risk Taking. In E. Petrocelli (Ed.) Proceedings of the 30th Annual Conference of the American Association for Automotive Medicine. Arlington, IL: American Association for Automotive Medicine, 1986. SAFETY RESEARCH ASSOCIATES, ING. = Factors Affecting Blood Alcohol Concentrations in Humans A Review. In E. Petrocelli (Ed.) Proceedings of the 30th Annual Conference of the American Association for Automotive Medicine. Arlington, IL: American Association for Automotive Medicine, 1986. The Use of In-Vehicle Detectors to Reduce Impaired Driving Trips. InD. C. Viano (Ed.) Alcohol, Accidents, and Injuries. Warrendale, PA: SAE P-173, 1986 Traffic Signal Display Complexity. Washington, D.C.: National Academy of Sciences, National Cooperative Highway Research Projects, 1986. Full-Scale Testing of Devices to Reduce Splash and Spray from Heavy Trucks. Hawthorne, . CA: Systems Technology, Inc., 1985 (NTIS: HS 806 694). Visibility Requirements for Overhead Guide Signs. Transportation Research Circular, 1985, 297, pp. 21-22, The Interaction of Alcohol and Fatigue on Driver Simulator Performance. In E. Petrocell (Ed.) Proceedings of the 29th Annual Conference of the American Association for Automotive Medicine. Arlington, IL: American Association for Automotive Medicine, 1985. A Vehicle Mounted Drunk Driving Warning System (DDWS): Concept, Laboratory Validation, and Field Test. In: Traffic Accident Data, Driver Performance, and Motor Vehicle Update, Transportation Research Record 1047, 1985, pp. 33-39. A Cybernetic Test for the Detection and Deterrence of Impaired Human Operators. Proceedings of the IFAC IXth Triennial World Congress. Budapest, Hungary: 1984. The Combined Effects of Alcohol and Marihuana on Driving Behavior. In E. Petrocelli (Ed.) Proceedings of the 28th Annual Conference of the American Association for Automotive Medicine. Arlington, IL: American Association for Automotive Medicine, 1984, pp. 289- 304. Effective Signing to Reduce Truck Downgrade Runaways. In E. Petrocelli (Ed.) Proceedings of the 28th Annual Conference of the American Association for Automotive Medicine. Arlington, IL: American Association for Automotive Medicine, 1984, pp. 77-89. © 0 NN a n t B R A W N No nN N o No rN No No N o N o — f d — r d — —_ F t f t p t fn o o ~ ~ aN wn ES N Ww N o pt oo Oo o o ~~ aN wn + Ww DN . = <> PROOF OF SERVICE (1013A, 2015.5 C.C.P.) STATE OF CALIFORNIA ) ) ss. MIRFAKHRAIE v CITY OF IRVINE/ENRIQUEZ COUNTY OF ORANGE ) I am employed in the County of Orange, State of California, I am over the age of eighteen years and not a party to the within entitled action; my business address is 500 S. Kraemer Boulevard, Suite 205, Brea, California 92821. I am readily familiar with the business practice at my place of business for collection and processing of correspondence for mailing with the United States Postal Service. Correspondence so collected and processed is deposited with the United States Postal Service that same day in ordinary course of business. On this date, I served the forgoing =~ AUGMENTED WRITTEN EXCHANGE OF REQUIRED EXPERT WITNESS INFORMATOIN AND EXPERT DECLARATION on the interested parties in this action, by placing a true copy thereof, enclosed in a sealed envelope, addressed as follows: Torsten N. Bassell, Esq. Nicole Lari-Joni, Esq. LARI-JONI & BASSELL, LLP 12400 Wilshire Boulevard, Suite 1050 Los Angeles, CA 90025 Fax: (310) 803-9084 Attorneys for plaintiffs Daniel X. Spradlin, Esq. WOODRUFF, SPRADLIN & SMART 555 Anton Boulevard, Suite 1200 Costa Mesa, CA 92626-7670 Fax: (714) 835-7787 Attorney for defendant, cross-complainant, City of Irvine (XX) (BY MAIL) I caused such envelope with postage thereon fully prepaid at my place of business to be placed in the United States mail at Brea, California. (Xx) (BY FACSIMILE) I caused the attached document to be transmitted via facsimile to the number(s) listed above, from fax number (714) 528-8227. () (BY PERSONAL SERVICE) I caused such document to be delivered by hand to the office of the addressees). rl alithrnia that the above is true and I declare under penalty of perjury under the laws of the State 9 correct. Dated: APRIL 23, 2015 14-0703¢