2016 cnmi high school mock trial case -...

CNMI Mock Trial 2016/Douglas v. Harrison

2016 CNMI HIGH SCHOOL MOCK TRIAL

CASE

Devon Douglas

v.

Riley Harrison1

1 This case is an adaptation of a prior case created for and utilized by the Colorado Bar Association High

School Mock Trial Program. The CNMI Bar Association and NMI Judiciary are grateful to Carolyn P. Gravit,

Director, Public Legal Education Department, Meghan S. Bush, Program Manager, Public Legal Education

Department, the Colorado Bar Association, and the Denver Bar Association for their assistance and

permission to adapt the case for our 2016 CNMI High School Mock Trial

All names, events, places, and circumstances in this case are fictitious or are used fictitiously. Any

resemblance to any person (living or dead), place, thing, or event is purely coincidental.

CNMI Mock Trial 2016/Douglas v. Harrison Page 1

CASE MATERIALS

Table of Contents

THE PROBLEM

Case Summary ...................................................................................................... 2

Witness and Exhibit Lists ....................................................................................... 3

Stipulations ............................................................................................................. 4

JURY INSTRUCTIONS ......................................................................................................... 5

WITNESS STATEMENTS

For the Plaintiff

Shane MacDonald .............................................................................................................. 10

Young Van Buren ................................................................................................................. 13

Devon Douglas .................................................................................................................... 19

For the Defense

Mar Almanza ........................................................................................................................ 24

Addison Klaver ..................................................................................................................... 27

Riley Harrison ......................................................................................................................... 30

EXHIBITS............................................................................................................................................... 35

Exhibit Number Description

1 Image of Defendant's Vehicle

2 Image of Cross Walk Instructions at Scene

3 Image of Scene from the North Side of S. Golden Rd

4 Image of the Intersection of the Incident

5 Image of the MacDonald Family Residence and Blue Truck

6 Facebook Screenshot

7 Road Map

8 Addison Klaver's CV

9 Young Van Buren's CV

10 Image of Damaged Bicycle


CASE SUMMARY

On June 26, 2015, Riley Harrison, a student at Harbor High School, drove into an

intersection in Golden Harbor, Saipan, at the same Devon Douglas, a working parent

attending Golden Tech and Trade, started to cross through the intersection on a

bicycle. The two collided and Devon Douglas was injured.

Right before driving into the intersection, Riley Harrison looked down at a text

message that had just come through on his/her smartphone. While riding his bike into

the intersection, Devon Douglas was talking on his/her smartphone. Both parties claim

the other one had a red light.

Two witnesses, Shane MacDonald and Mar Almanza, saw the accident, but both

have their biases. Shane MacDonald doesn’t like Riley Harrison, and Mar Almanza

doesn’t like bicyclists.

Young Van Buren, an expert on distracted driving, blames the accident on Riley

Harrison. Addison Klaver, an accident reconstructionist, states it was Devon Douglas’

fault.


WITNESS and EXHIBIT LISTS

WITNESS LIST

Plaintiff

Shane MacDonald

Young Van Buren – Plaintiff designates this witness as expert in forensic traffic

psychiatry

Devon Douglas

Defense

Mar Almanza

Addison Klaver – Defendant designates this witness as an expert in accident

reconstruction

Riley Harrison

EXHIBIT LIST

Exhibit 1 - Image of Defendant's Vehicle

Exhibit 2 - Image of Cross Walk Instructions at Scene

Exhibit 3 - Image of Scene from the North Side of S. Golden Rd

Exhibit 4 - Image of the Intersection of the Incident

Exhibit 5 - Image of the MacDonald Family Residence and Blue Truck

Exhibit 6 - Facebook Screenshot

Exhibit 7 - Road Map

Exhibit 8 - Addison Klaver's CV

Exhibit 9 - Young Van Buren's CV

Exhibit 10 - Image of Damaged Bicycle


Stipulations

1. All exhibits (and their pre-markings) are authentic. No objections to the

authenticity of any exhibit shall be entertained. The parties reserve the right to

dispute any legal or factual conclusions based on any exhibit and to make

objections other than to authenticity.

2. The signatures on the witness statements and all other documents are authentic.

3. Chain of custody for evidence is not in dispute.

4. Stipulations cannot be contradicted or challenged.

5. Exhibits 2 through 5 fairly and accurately represent the way the intersection

looked on June 26, 2015.

6. Exhibit 6 accurately reflects the information on Riley Harrison’s Facebook page

on June 26, 2015.

7. The Case Summary is of no legal consequence in terms of the trial. The Case

Summary is not admissible for impeachment purposes or for any other purpose

during the trial.

8. This case will be bifurcated. The only issue before the jury is fault. The Plaintiff must

establish that he/she was injured, however, the amount of damages, if any, is

not before the jury at this time.

9. The Defendant’s phone records are unavailable due to no fault of either party.


JURY INSTRUCTIONS

Instruction No. 1

The plaintiff claims that the defendant was negligent, and that that the

defendant’s negligence caused an injury to the plaintiff.

As an affirmative defense, the defendant asserts that the plaintiff’s injuries were

caused in whole or in part by the plaintiff’s own negligence.

The plaintiff has the burden of proving the plaintiff’s claim by a preponderance

of the evidence.

The defendant has the burden of proving the affirmative defense by a

preponderance of the evidence.

To prove something by a "preponderance of the evidence” means to prove that

it is more probably true than not.

“Burden of proof” means the obligation a party has to prove his or her claim or

defense by a preponderance of the evidence. The party with the burden of proof can

use evidence produced by any party to persuade you.

If a party fails to meet his or her burden of proof as to any claim or defense, or if

the evidence weighs so evenly that you are unable to say that there is a

preponderance on either side, you must reject that claim or defense.

Instruction No. 2

The parties have agreed to the amount of damages to be awarded in the event

the jury finds that the defendant, Riley Harrison, is liable to the plaintiff, Devon Douglas.

Accordingly, the only issues to be decided by the jury are whether the defendant is

liable for any injuries suffered by the plaintiff, and whether the plaintiff is liable for any of

the plaintiff’s own injuries.

Instruction No. 3

Evidence may be either direct or circumstantial. Circumstantial evidence is the

proof of facts or circumstances from which the existence or nonexistence of other facts

may reasonably be inferred. All other evidence is direct evidence. The law makes no

distinction between the effect of direct evidence and circumstantial evidence.

Instruction No. 4

You must not be influenced by sympathy, bias, or prejudice for or against any

party in this case.


Instruction No. 5

You are the sole judges of the credibility of the witnesses and the weight to be

given their testimony. You should take into consideration their means of knowledge,

strength of memory, and opportunities for observation; the reasonableness or

unreasonableness of their testimony; the consistency or lack of consistency in their

testimony; their motives; whether their testimony has been contradicted or supported

by other evidence; their bias, prejudice or interest, if any; their manner or demeanor

upon the witness stand; and all other facts and circumstances shown by the evidence

which affect the credibility of the witnesses.

Based on these considerations, you may believe all, part, or none of the

testimony of a witness.

The weight of evidence is not necessarily determined by the number of witnesses

testifying to a particular fact.

A witness qualified as an expert by education, training, or experience may state

opinions. You should judge expert testimony just as you would judge any other

testimony. You may accept it or reject it, in whole or in part. You should give the

testimony the importance you think it deserves, considering the witness's qualifications,

the reasons for the opinions, and all of the other evidence in the case.

Instruction No. 6

For the plaintiff, Devon Douglas, to recover from the defendant, Riley Harrison, on

the plaintiff’s claim of negligence, you must find that all of the following have been

proved by a preponderance of the evidence:

1. The plaintiff had injuries;

2. The defendant was negligent; and

3. The defendant's negligence was a cause of the plaintiff's injuries.

If you find that any one or more of the above three statements has not been

proved, then your verdict must be for the defendant and you may disregard the

remainder of this instruction.

On the other hand, if you find that all of the above three statements have been

proved, then you must determine whether the defendant has proven the affirmative

defense of comparative negligence.

The affirmative defense of the comparative negligence of the plaintiff, Devon

Douglas, is proved if you find all of the following:


1. The plaintiff was negligent; and

2. The negligence of the plaintiff was a cause of the plaintiff's own claimed injuries.

If you find the plaintiff, Devon Douglas, was injured, and that the plaintiff's injuries

were caused by both the negligence of the plaintiff, Devon Douglas, and the

defendant, Riley Harrison, then you must determine to what extent the negligent

conduct of each contributed to the injuries of the plaintiff, expressed as a percentage

of 100 percent.

If you find that both the plaintiff and the defendant were negligent, and that the

negligence of the plaintiff was equal to or greater than the negligence of the

defendant, then the plaintiff will not be allowed to recover.

On the other hand, if you find that both the plaintiff and the defendant were

negligent, and that the negligence of the defendant was greater than the negligence

of the plaintiff, then the plaintiff will be allowed to recover.

If the plaintiff is allowed to recover, the total damages awarded will be reduced

by the Court by the percentage of the plaintiff's negligence.

Instruction No. 7

Negligence means a failure to do an act which a reasonably careful person

would do, or the doing of an act which a reasonably careful person would not do,

under the same or similar circumstances to protect oneself or others from injury.

The mere occurrence of an accident does not raise any presumption of

negligence on the part of either the plaintiff or the defendant.

Instruction No. 8

A driver must maintain a proper lookout to see what that driver could and should

have seen in the exercise of reasonable care.

Instruction No. 9

To look in such a manner as to fail to see what must have been plainly visible is to

look without a reasonable degree of care, and is of no more effect than not to have

looked at all.

Instruction No. 10

At the time of the occurrence in question in this case, the following statutes were

in effect:


Vehicular traffic facing a circular green signal may proceed straight through the

intersection.

Vehicular traffic facing a steady circular red signal shall stop before entering the

intersection, and shall remain standing until an indication to proceed is shown.

A person under eighteen years of age shall not use a wireless telephone while

operating a motor vehicle. A person eighteen years of age or older shall not use

a wireless telephone for the purpose of engaging in text messaging or other

similar forms of manual data entry or transmission while operating a motor

vehicle. “Use” means talking on or listening to a wireless telephone or engaging

the wireless telephone for text messaging or other similar forms of manual data

entry or transmission.

Whenever special pedestrian-control signals exhibiting the words "Walk" or "Don't

Walk" are in place, such signal shall control the actions of bicyclists using the

pedestrian crosswalks as follows:

- While the "Walk" indication is illuminated, a bicyclist facing such signal

may proceed across the roadway in the direction of the signal indication.

- Whenever the "Don't Walk" indication is flashing, no bicyclist shall start to

cross the roadway in the direction of the indication, but any bicyclist who

has partially completed his crossing during the "Walk" indication shall

proceed to a sidewalk or to a safety island, and all drivers of vehicles shall

yield to any such bicyclist.

- While the "Don't Walk" indication is steadily illuminated, no bicyclist shall

enter the roadway to cross that roadway in a pedestrian crosswalk in the

direction of the signal indication.

A violation of any of the above statutes constitutes negligence.

If you find such a violation, you may only consider it if you also find that it was a

cause of the plaintiff’s claimed injuries.

It is not a defense to a claimed act of negligence that a person was unaware

that his or her conduct constituted a violation of one of the above statutes.

Instruction No. 11

A person has the right to believe that others will obey applicable laws and

regulations, unless there are reasonable grounds to believe otherwise.

Instruction No. 12

Although a driver may have the right of way, the driver must exercise reasonable

care considering the existing conditions.


Although a bicycle operator may have the right of way, the bicycle operator

must exercise reasonable care considering the existing conditions.

Instruction No. 13

The word “cause” as used in these instructions means an act or failure to act that

in natural and probable sequence produced the claimed injury. It is a cause without

which the claimed injury would not have happened.

If more than one act or failure to act contributed to the claimed injury, then

each act or failure to act may have been a cause of the injury. A cause does not have

to be the only cause or the last or nearest cause. It is enough if the act or failure to act

joins in a natural and probable way with some other act or failure to act to cause some

or all of the claimed injury.


Affidavit of Shane MacDonald – Plaintiff Witness

All right, so you just want me to start talking? You don’t want to use the video 1

camera to record this statement? If you do, use my right side - it’s the better side of my 2

profile. Okay, anyway, I am Shane MacDonald. That’s my name and I live in Golden 3

Harbor, where I go to high school at Harbor High. I have a super good memory so you 4

should totally take this statement as the whole truth. Because I’d never lie under oath – I 5

take this legal stuff very seriously. I do mock trial for my school and totally want to be a 6

lawyer because I’m pretty good at arguing and I watch a bunch of Law & Order and 7

re-runs of JAG when all my friends are watching reality shows. 8

Anyway, so you want me to tell you about Mr./Mrs. Douglas' accident, right? 9

OMG… It was horrible. I babysit for the Douglas family. I have been watching their kids 10

since they moved to the area. They’ve got these two really adorable little kids. Like, it’s 11

fun to watch the kids but I don’t enjoy cleaning poopy diapers. But otherwise they are a 12

pretty cool family, or at least, they were until the accident. It’s been a total bummer 13

that Mr./Mrs. Douglas got in the accident because they're the source of my spending 14

money at Mariana Mall. 15

I live down the street from them and I would run over and grab the kids when 16

Mr./Mrs. Douglas went on his/her bike rides and I’d bring them back to my house. On 17

the night of the accident, I picked up the kids probably about five-ish? I was just 18

supposed to have the kids for an hour-ish until Mr./Mrs. Douglas got back from the bike 19

ride. I know s/he also needed to talk to someone about work stuff because Mr./Mrs. 20

Douglas had a phone headset on, like s/he always did, and s/he said I could call if 21

there was a problem. 22

My house is on the corner, where the intersection and the traffic light are. My 23


older brother is selling his blue truck which is parked in our front yard. We had someone 24

call from buy-sell-swap who wanted to come check it out. I went outside to make sure 25

it was unlocked and clean. I had the kids playing inside, it was ok, my mom was in there 26

watching them. I saw Mr./Mrs. Douglas riding back from his/her ride and I waved, but 27

s/he didn’t see me. That’s when I saw the car coming. The car was blaring the song 28

“We Can’t Stop” by Miley Cyrus, it was obnoxious, I really can’t stand that song or Miley 29

for that matter, especially after the stunt she pulled at the MTV VMA’s a couple of years 30

ago. That song and Miley are so over. But I noticed that the car looked familiar, so I was 31

looking to see who the driver was. 32

It turns out the driver goes to my school. His/her name is Riley Harrison and s/he is 33

very popular – always doing the school plays, sports, student council. I know him/her 34

because we both tried out for the lead attorney role for last year’s Mock Trial. Of 35

course, Riley got it! S/he hangs out with the “cool” crowd, everyone seems to like 36

him/her, except me because I don’t really care about that kind of stuff, but I 37

recognized him/her when s/he got out of the car. Sometimes I see Riley in the hallway 38

at school and it seems like s/he’s always looking at his/her phone, even when walking 39

with other friends and just going between classes. I bet Riley sends a million texts. 40

Myself? I never send more than 40 texts per day. 41

When I first saw Riley, s/he was looking down at his/her lap. I couldn’t see if s/he 42

was looking at a phone, but his/her head was definitely looking downwards. Then the 43

accident happened. I could see that Riley might not be looking at the intersection and 44

I could see that Mr./Mrs. Douglas was starting to cross the street and they just collided. It 45

was awful! Like a slow motion YouTube horror video that you just can't stop watching. 46

The bike and Mr./Mrs. Douglas went flying, and Riley’s head popped up as she/he 47


stomped on the brakes. I started screaming for my mom to call 911. Mr./Mrs. Douglas 48

seemed okay. I mean s/he was walking around while the police came, and when s/he 49

first got up after the crash, I saw him/her reach up and take his/her ear buds out. The 50

car ended up across the street in the 7-11 parking lot. I saw Riley get out of the car and 51

run to the front of the car. Riley had something in his/her hand and when she/he put it 52

on the hood of the car, I could see that it was a phone. It was shaped like a smart 53

phone, anyway. 54

I stayed with the kids until Mr./Mrs. Douglas got back from the hospital and came 55

to pick them up. It was really terrible. Now Mr./Mrs. Douglas can’t ride his/her bicycle 56

anymore and it’s just been devastating for their family. My spending money has 57

evaporated because they don’t ask me to babysit any more. I never even look at my 58

phone now when I’m driving, since I’m sure the whole accident happened because 59

Riley was too busy texting or something to watch where s/he was driving. 60

I have carefully reviewed this statement, and it includes everything I know of that 61

could be relevant to the events I discussed. I understand that I can and must update 62

this statement if anything new occurs to me before the trial. 63

Subscribed and Sworn to in Golden Harbor, Saipan, CNMI on the 1st Day of 64

November, 2015. 65

________Shane MacDonald________ 66

Shane MacDonald 67


Affidavit of Young Van Buren – Plaintiff Witness

My name is Young Van Buren. I am a forensic traffic psychiatrist. I attended the 1

University of California where I obtained a dual degree in psychology and forensic 2

science. My minor was criminology. I then attended medical school at the University of 3

California, Irvine School of Medicine. After completing medical school, I did a four-year 4

psychiatry residency at the University of California, San Francisco School of Medicine, 5

focusing on traffic psychiatry, in the Department of Psychiatry there. I then took the 6

medical board examination and was licensed to practice in California. I subsequently 7

completed a one-year fellowship in forensic psychiatry, at UC Davis. Upon completion 8

of my fellowship, I sat for a board certification in forensic psychiatry and became board 9

certified in California. I began to work for the California State Department of Safety in 10

the traffic safety unit. There, I served as a forensic traffic psychiatrist for two years. My 11

focus and research became centered on accidents that involved distracted drivers. I 12

have read everything available on the subject, including the most recent AAA 13

research. One year ago, I left the CSDS and opened my own practice to work as a 14

forensic traffic psychiatrist on a consultation basis. I’ve been hired by both plaintiff and 15

defense counsels, all around the country, but this is the first time my testimony will be 16

required at trial. I charge $200 an hour for preparation and investigation, plus actual 17

transportation charges. I do not charge for actual travel time, I love to travel and 18

explore new places, so I can take my time getting to and from locations. I also charge 19

$500 for time spent testifying on a case. 20

Traffic psychiatry is a discipline of psychiatry that studies the relationship between 21

psychological processes and the behavior of road users. Behavior is frequently studied 22

in conjunction with accident research in order to assess causes and differences in 23


accident involvement. Behavior research in traffic psychiatry often deals with subjects 24

likes, motivation, personality and gender differences, habits, overconfidence, age and 25

skill differences, attention, and violations of traffic rules. In addition to behavior 26

research, accident research also is a component in traffic psychiatry, looking at driving 27

methodology, individual differences, characteristics of personality, temporary 28

impairments, and relevant capabilities, the driver as an information processor (includes 29

perception and reaction times), human factors on highway accidents, and the 30

pedestrian (identifying vulnerability, causes and prevention of accidents). 31

Examination of the operator plays a large role in transportation psychiatry. While 32

many external factors influence traffic safety, internal factors are also significant. Some 33

factors include: decision-making, demographics, distraction, detection thresholds, 34

drugs and alcohol, driving training and experience, familiarity with vehicle and 35

environment, fatigue, inattention, perception-reaction time, response to the 36

unexpected, risky behaviors, stress, and panic. 37

In August 2015, I was contacted by Devon Douglas to review the circumstances 38

of an accident that occurred on June 26, 2015. Mr/s. Douglas was riding a bicycle at 39

the time of the accident and was hit by a car being driven by Riley Harrison. As a result 40

of the accident, Mr/s. Douglas suffered severe body trauma. As part of my 41

investigation, I reviewed the affidavits of Devon Douglas, Riley Harrison, Addison Klaver 42

and Mar Almanza, as well as Exhibits 1 through 10. 43

Based on my review of the witness statements, I learned that Mr/s. Douglas, age 44

twenty two, was riding a bicycle on the pedestrian path along Quaker Street near the 45

intersection of South Golden Road in the city of Golden Harbor, Saipan. Mr/s. Douglas 46

was wearing a helmet and having a phone conversation about work using earplugs. 47


S/he is an IT consultant with client management responsibilities, and the conversation 48

was about a client project that was going badly. From my experience, I know that bad 49

news tends to cause tension in a person and then the person will focus on that news, 50

which often leads them to lose focus on other aspects. Here, if Mr/s. Douglas was 51

worried about her client, s/he was probably a little distracted from the action of bicycle 52

riding. However, it is very hard to measure how much a distraction impacts a person. 53

Each individual handles focus very differently. Adults handle it better than developing 54

teenagers. In addition, the type of distraction matters a great deal. 55

Although, I believe Mr/s. Douglas was likely distracted by her conversation, I do 56

not believe that was the cause of this accident. S/he was on a hand-free set and 57

looking up and ahead of her/him the entire time. From my review of the affidavits, the 58

pedestrian crossing signal had gone from flashing to solid when Devon Douglas 59

reached the intersection. The better practice would have been for her/him to stop, but 60

s/he still would have had the right of way in the intersection because the light was red 61

for cars. At that same time and place, the defendant, Mr/s. Harrison, driving a Marina 62

Civic, was proceeding westbound on South Golden Road approaching this red light. 63

Mr/s. Harrison ran the red light and hit Mr/s. Douglas, who had entered the intersection. 64

Mr/s. Harrison, is a teenager who we can assume has only had a driver’s license 65

a short amount of time. Just before the accident, Mr/s. Harrison had left his/her house 66

after a heated argument with her/his parents and s/he admits in her/his statement to 67

being very upset while driving. Emotional swings in teenagers are common, and most 68

teenagers are not equipped to deal with emotional upheaval as well as most adults. 69

Being emotional behind the wheel of a car will cause distraction and less attention 70

focused on the act of driving. In this situation, we have an emotional teenager who 71


adds to his/her distraction by frequently glancing away from the road to look at his/her 72

phone. Mr./s. Harrison says that shortly after leaving the house s/he decided to vent on 73

Facebook via her/his phone about her argument with her parents. His/her comment 74

received numerous likes and comments that Mr/s. Harrison checked immediately and 75

even responded to. As s/he was about to cross the intersection where the accident 76

occurred, Mr/s. Harrison received another message. Mr/s. Harrison stated that s/he 77

momentarily looked down at his/her phone on his/her lap. It is not clear whether s/he 78

had one or both hands on the wheel at this time, but for sure s/he did not have both 79

eyes on the road. 80

Based on my research and experience as forensic traffic psychiatry, it is clear that 81

distracted driving is extremely dangerous because it diminishes the ability of the brain to 82

focus. Some of the most recent scientific findings include: 83

66% of drivers 18 to 24 years old are sending or receiving text messages while 84

driving. 85

Teenagers, in particular, use texting as major means of communication. A 2012 86

study said that the average teenager sends/receives 60 texts per day. 87

Motorists on cell phones exhibit the reaction speed and coordination of drivers 88

with blood alcohol levels exceeding 0.08 – that’s like getting behind the wheel 89

after 4 drinks. This would also be the case for bicyclists. 90

Drivers on cell phones are four times more likely to be in an accident. 91

A 2002 study showed that talking on a cell phone was the cause of at least 2,600 92

deaths and 330,000 injuries annually. 93

The National Safety Council's 2014 Injury Facts reported that the use of 94

cellphones caused 26% of the nation's car accidents. 95


Research also shows that simply looking at a text message while traveling at 40 96

mph is like driving the entire length of a football field blindfolded. 97

My expertise is not about the scene of the accident specifically, but more about the 98

events and behaviors that caused the two individual’s traffic interaction. I’ve already 99

explained that while Mr/s. Douglas was distracted by his/her phone conversation, I do 100

not believe he/she is the cause of this accident. S/he is an adult who is better equipped 101

to handle multiple tasks at one time, s/he is older and likely has years of experience 102

riding a bicycle, and s/he was on a hand free set allowing her/his head to be looking 103

up and her/his vision was clear. 104

Based on my investigation, it is my opinion that the subject accident was caused by 105

the distracted driving of Mr/s. Harrison. The defendant, Mr/s. Harrison, is a teenager and 106

a fairly new driver with limited experience behind the wheel. Just before the accident, 107

Mr/s. Harrison was in a heated argument with her/his parents and s/he admits to being 108

very upset while driving. Mr/s. Harrison was distracted just prior to the accident by 109

sending texts and receiving Facebook messages. But, most significantly, Mr/s. Harrison 110

was distracted at the time of the accident by looking at the message s/he received, 111

causing him/her to run the red light and strike Mr/s. Douglas. Therefore, in my expert 112

opinion, Mr/s. Harrison’s agitated state and distracted driving was the real cause of this 113

accident. 114




// 118

// 119



November, 2015. 121

Young Van Buren 122

Young Van Buren 123


Affidavit of DEVON DOUGLAS – Plaintiff Witness

My name is DEVON DOUGLAS. For most of my 22 years, I have run into obstacles 1

others have put in front of me and I have pushed through those obstacles to get what I 2

deserve. But on June 26, 2013, an obstacle ran into me – a vehicle driven by Riley 3

Harrison. My life was starting to turn around, and I was making plans for a bright future. 4

That all changed the day Riley Harrison decided that reading a text message was more 5

important than watching the road. 6

I moved to Golden Harbor after graduating from George Washington in Guam. 7

My high school grades were good enough to get me a partial scholarship to Golden 8

Tech and Trade, which I needed because my family has never been rich. I moved here 9

with just enough money to pay the tuition and books not covered by my partial 10

scholarship. I met my spouse my freshman year and we got married before the end of 11

the first semester. Our daughter, Nancy, arrived my sophomore year and our son, 12

James, my junior year. Before the accident, my spouse took care of the kids and I went 13

to school during the day and worked evenings and weekends. I worked the help desk 14

in the IT department for Xplorotech. They are a global oilfield services supplier with 15

operations and offices all over the world, but most of their computer support operations 16

are based here in Saipan. Computer support is not what I wanted to do with my life, 17

though. The help desk job paid enough that I could pay living expenses and college 18

expenses not covered by my scholarship, and the position gave me the flexibility to 19

work evenings, weekends, and even remotely. Xplorotech, however, had promised to 20

hire me on in their technology research division and transfer me to California once I got 21

my electrical engineering degree. That would have been my dream job. 22


Since I moved to Golden Harbor, I have become an accomplished bicyclist. 23

Riding helps me work out some of my frustration. I always wear a helmet, but one which 24

allows me to wear ear buds. That way I can listen to music, but it also lets me talk on the 25

phone so I could be on-call with Xplorotech. On-call shifts pay overtime and you just 26

have to be available by phone to take service calls. I always talk hands-free, of course. 27

In fact, I was on the phone trying to fix a major system outage in Calgary when the car 28

hit me. 29

I like to bike farther up north, to Radar. I have ridden up to that area a couple 30

hundred times or more. I always take the same route from my house there and back. 31

On the day I got hit I was finishing my ride and heading back home. I was talking with 32

the field office in Calgary. All they had left to do was restart the system, but that has to 33

be done in a very specific order. Since I was riding on the street, I had my left ear bud 34

out. I know some people have said that I had both ear buds in, but I always take the 35

left ear bud out when I’m riding on the street. Anyway, I was riding south on Quaker 36

Street, and I was at a critical point in the restart sequence. As I came up on the 37

intersection with South Golden Road, the crosswalk signal had been flashing. It’s not like 38

I wasn’t watching what I was doing. I can talk with someone on the phone and watch 39

what I’m doing. Yeah, I was a little focused on the phone call, but I was still aware of 40

what was going on around me. 41

I remember a lot of what happened in the crash. Thankfully, my helmet stayed 42

on and I don’t think I ever passed out. Just as I got to the intersection the crosswalk 43

signal stopped flashing. I had expected it to flash a little longer, but even when it stops 44

flashing you still have about five seconds before the light turns green for the cross traffic. 45

That was more than enough time to get safely across the road. Maybe if I hadn’t been 46


dealing with the system restart I might have looked harder to make sure nobody was 47

going to run the light, but that doesn’t mean the accident was my fault. I am 100% sure 48

that the light had not turned green for traffic on Golden Road. In fact, there was a big 49

truck in the east-bound lanes stopped at the light. I was watching the truck and 50

checking the light, while talking to the people in Calgary, as I rode into the intersection. 51

Out of nowhere, a car shot into the intersection and hit me. I did not even have time to 52

swerve. 53

I was thrown about thirty feet. My bike was so mangled that my spouse had it 54

mounted on a wall – as a sort of trophy for my surviving the crash. At first, it seemed like I 55

was okay. Sure, I hurt everywhere and I had some nasty scrapes, but I could get up and 56

walk around. Then about a week later I got my first migraine. I had never had a 57

headache like that before - blinding pain so intense I could barely crawl into the 58

bathroom to vomit. It wiped me out for days afterward. Then I got another one – and 59

another one. Pretty soon I was having multiple migraines a day. Apparently, the 60

accident damaged a facet joint in one of the cervical vertebrae in my neck. When the 61

vertebrae rub together, it irritates a nerve that triggers the migraines. At first, the doctors 62

treated it with cortisone injections. That gave me some relief, but it was a short term 63

solution. Eventually I had to have what’s called a facet rhizotomy. The doctor injected 64

phenol into the damaged facet joint to destroy the nerve ending. Sticking a needle into 65

my spine made me nervous, but it wasn’t that painful. Burning the nerve with the 66

phenol was a different story. I guess for some people it’s not that bad, but for me it was 67

excruciating. When the injection was done, it felt like the needle was still there because 68

I couldn’t move. I was actually in tears because it hurt so much. They gave me pain 69


killers, but they didn’t do much and I was in such bad pain for about two weeks that I 70

couldn’t go to work. 71

Then things were pretty good for a while. I could work again, and I started school 72

in the fall, but then the migraines started coming back. It turns out that rhizotomies are 73

not necessarily permanent, and the burned nerve ending grows back. When that 74

happens, I have to go through the process all over again – maybe every few months for 75

the rest of my life. The pain from the rhizotomy procedure was bad enough that I put off 76

the second one as long as I could, but eventually the migraines were so bad I couldn’t 77

work and I couldn’t go to school. The second rhizotomy procedure was just as horrible 78

as the first, but at least now I should be okay for several months. 79

Sometimes, though, when I think about having to go through this cycle, over and 80

over and over again, for the rest of my life – it’s more than I can take. Worse, I’m not 81

sure how I can pay for it. The help desk is a contract position at Xplorotech, so I don’t 82

have health insurance. Since I was talking on the phone about work when I got hit, I 83

filed for workers’ compensation, but my claim was denied. I have used up all of my sick 84

time at work, but I know that when the headaches start up again, I will have to take 85

more time off. I really don’t know what I am going to do. Plus, there’s no way I can put 86

the necessary time into school. The last series of headaches coupled with the time I was 87

out of commission from the rhizotomy, and it really hurt my grades. I don’t want to 88

accept it just yet, but I don’t see how I can keep working for Xplorotech, let alone stay 89

in school long enough to get my degree. 90

I have a spouse and two young children who depend on me, and I am not sure I 91

am going to be able to keep my help desk job, let alone finish my degree and become 92

an engineer. I can’t afford to buy a new bike at a time like this, but biking was my stress 93


release. It may seem like a small thing to other people, but it’s a huge thing to me that I 94

can’t bike anymore. In fact, I worry about making my neck worse now that it has 95

already been injured. That means I don’t dare ski any more. In fact, I don’t do anything 96

that might be high impact, like running or any sports. I used to be very active and I hate 97

that this accident has taken that away from me. 98

This crash changed my life, and it’s all the defendant’s fault! It is one thing for 99

someone like me who is used to talking hands free on a bike to talk on the phone. It is 100

unforgiveable to be distracted by texting while driving a vehicle that can do the level 101

of damage that this did to me. 102





November, 2015. 107

Devon Douglas . 108

DEVON DOUGLAS 109


Affidavit of Mar Almanza – Defense Witness

My name is Mar Almanza. I’m retired. I was a rancher up outside of Butte, 1

Montana, until I retired and moved to Golden Harbor. Docs say I need to live at a 2

lower elevation, because of my ticker needing oxygen. My better half is from here and 3

seems everyone in the family is a doctor here in Golden. Which is good, cause my 4

spouse has a touch of diabetes, and they are keeping a good eye on it. I will say, it is 5

easier for me to function here during the winter, since it isn't freezing like at the ranch. 6

Still, we ran a pretty good outfit, ten thousand acres, five to ten thousand head, horse 7

herd of forty, hay operation, irrigation, until we gave up on the cattle. Then I ran hunters 8

and fishermen and dudes, right up to age 72, five years ago. My boys run it now. Miss it. 9

We get back there, when it isn't winter to visit, but not enough and it’s not the same. 10

Room to breathe back at the ranch, not like here where things are just nuts. Things like 11

this happening all the time. Up there everybody except the tourist dudes know how to 12

drive, worst that can happen on the ranch is to have a horse step on you. 13

I remember the accident, sure. You never forget stuff like that. I was on my way 14

home going south on Quaker Street in the right lane. There are two lanes going in each 15

direction. The roads were dry and traffic was fine. 16

Anyway as I was saying, I was headed home when I saw him/her – the biker. 17

Well, not a real biker, not riding a real bike, like a Harley or anything, a bicyclist. S/he 18

was riding the shoulder, weaving around traffic a bit. S/he was hard to miss in the loud 19

shirt and the tight shorts and the weird shoes, the whole nine yards. Helmet and ear 20

phones, in both ears, deaf as a post. Bicyclers even cut through our property here, to 21

get to some trail they like to ride. Trespassers with no respect. Anyway,I had been 22

behind him/her for a bit, but s/he beat me to the light because s/he was busting the 23


rules the way they all do – weaving back and forth from the shoulder into the traffic 24

lane. Blocking legitimate traffic. They act like they are cars on the road and won’t let 25

you pass, then act privileged in the intersections, like pedestrians. Too good to wait at a 26

light like the rest of us law abiding citizens. Jerk. 27

I was 40 yards away from the intersection, about, when the light turned yellow. I 28

started slowing down, but the biker just kept going. The light turned red and the biker 29

cruised across exactly like the lights didn’t apply to him/her, head down, oblivious. 30

Well this wasn’t going to end well, accident waiting to happen. Sure enough, in 31

the intersection, wham-o, a car crushed the biker. I was punching 911 before the biker 32

hit the ground. S/he was thrown like a broken doll and landed maybe 30 feet away 33

from the impact. The bike landed maybe 20 feet beyond that on someone’s lawn. The 34

car swerved like mad before the brake lights came on, went about 75 feet past the 35

intersection and jumped the curb. 36

I got to the biker who was hurt pretty bad. Out cold, but not bleeding except for 37

being banged up, lying at an odd angle so I didn’t try to straighten her/him out, airway 38

clear, breathing good, but maybe internal bleeding. I been taking care of the cowboys 39

on the ranch since we hired the first one––someone’s gotta do it and couldn’t trust 40

anyone else––so I picked up plenty of emergency medicine along the way. Damn fool 41

cowboys always coming off horses, flatland hunters shooting each other or the dogs, 42

birdshot. Anyway, I still had 911 so I told her to get moving, we had a body that wasn’t 43

going to get any better by her/himself. 44

The driver of the car came over all shook up, a baby, maybe 16 or 17 years old. 45

So I had a mess on my hands. I told one guy to direct traffic and another to get the 46

attention of the medics when they arrived and tell them where we were, and another 47


to keep folks away from us. Let us breathe. The medics with the Fire Department got 48

there before the cops, about normal. And that was it. 49

When the police showed up, I told them what I had seen. The light turned red 50

before the biker got there, and s/he just rode on through. I was watching good 51

because I knew that biker was going to ignore the signal – just normal for them. 52

I did not know either of the parties involved in the accident, until they made me 53

late getting home. I just did what I could and want to see justice. 54





November, 2015. 59

Mar Almanza . 60

Mar Almanza


Affidavit of Addison Klaver– Defense Witness

My name is Addison Klaver. I was born in Durango, Colorado and I have lived in 1

Colorado my entire life. After completing my engineering degree at the Colorado 2

School of Mines in only 3 years, I got a job as a stunt coordinator in the movie industry. 3

Colorado has great scenery for action movies. I was primarily responsible for explosives 4

and high-action reconstruction. It was then when I met my greatest mentor, a retired 5

police officer. He was primarily responsible for code enforcement. You know, making 6

sure that our work was squarely within the law. He was also responsible for doing a 7

reconstruction of the event anytime something went wrong and people got hurt or 8

died. I learned many things from him over the years, including code enforcement and 9

reconstruction. He actually put together a formal training for me leading to a 10

certification in accident reconstruction through the state of Colorado. Life was perfect 11

then. 12

Unfortunately, he tragically died during one of his reconstructions. A bicyclist 13

decided to drive through a closed reconstruction zone, nipping a wire, and leading to 14

a premature detonation. There were many signs warning the bicyclist to not enter the 15

area. There even was a clearly marked detour. 16

I was devastated. Everything changed. I changed. People just do not get how 17

dangerous bicyclists can be. We have to do something or we will never be safe. 18

With respect to this case, I was hired by the Defendant’s attorney to give expert 19

opinions about the cause of the Plaintiff’s allegations. I have been giving this sort of 20

expert testimony for about 21 years and testified at trial hundreds of times. My office has 21

been in Durango since I opened it in '92, but I have testified all over. I do have a 22


pension that pays me about $42,000 per year and a cabin up in Durango Hills, so I do 23

not need to do this work. However, when I do expert work I charge $250 per hour. 24

My services include, but are not limited to, investigation, engineering analysis, 25

safety analysis of equipment and facilities, accident reconstruction, reports, affidavits 26

and consultations in anticipation of trial. 27

When analyzing these accidents I use principles of engineering in addition to 28

human factors, safety design, safeguarding, sensory warnings, and state codes and 29

standards. As part of my investigation, I reviewed the affidavits of Devon Douglas, Riley 30

Harrison, Young Van Buren, and Mar Almanza, as well as Exhibits 1 through 10. 31

In this particular case, I reviewed the available evidence, obtained relevant 32

vehicle information, and evaluated and analyzed the subject accident using 33

accepted accident reconstruction techniques, including the principles of conservation 34

of energy and conservation of momentum. I also visited the incident site myself to 35

confirm the topography of the bike crossing and also to take some measurements. 36

Based on available evidence and my training, education, and experience, with 37

a reasonable degree of probability I have reached the following conclusions: 38

The relative closing speed between the vehicle and the bicycle at the time of 39

contact was approximately 8 mph, or less. 40

As a result of the bicycle making contact with the vehicle, the bicycle 41

accelerated forward in the direction it was going originally with a change in velocity in 42

the range of 4 to 6 mph. It should be noted that the actual change in velocity and 43

peak acceleration experienced by the bicycle may vary slightly from the values 44

reported here, in particular there could possibly be slightly less velocity. 45


The bicyclist was subject to forces at the point of collision that are similar to 46

forces which humans are routinely subjected to, such as forces produced by 47

accidentally backing into a rigid stationary object at approximately 3 to 5 mph, as well 48

as the activities of daily life. 49

At those speeds, the bicyclist is to be blamed for the collision when s/he ran the 50

traffic light. Specifically, but-for the bicyclist’s running the light, the accident would not 51

have happened. The bicyclist’s was in an inattentive state due to the use of the 52

headset to engage in a phone conversation and therefore, failed to carefully observe 53

his surroundings. It is my expert opinion that because of the the bicyclists’ inattentive 54

state, and running the light, the accident took place. 55

Furthermore, given the above force analysis, the bicyclist would have had ample 56

time and means to bring the bicycle to a halt prior to the subject collision had s/he 57

been paying attention. 58

Ultimately, the bicyclist was asking to be hurt. 59





November, 2015. 64

Addison Klaver . 65

Addison Klaver 66


Affidavit of Riley Harrison– Defense Witness

My name is Riley Harrison. I am a senior at Harbor High School. I am 18 years old,

but I was 17 on the day of the accident. Next year I am going to college at the

University of Wisconsin at Madison. Well, that’s assuming this lawsuit doesn’t ruin those

plans. I think my parents would rather have me to go to Golden Tech and Trade, but I

really want to go away for school.

My parents think I spend way too much time texting my friends, but I’m not just

texting. The world has changed since their day. Yes, I text, but I also have to keep up

with Facebook and Twitter. I also post a little on Google+, but my friends don’t use it as

much as Facebook. Personally, I know it is old, but think it’s a better system. That doesn’t

mean anything if people aren’t using it. My friend Darius tried to start a thing last year to

get everybody using it, but it just wouldn’t take off. I also use Instagram, Snapchat, and

Tumblr sometimes, but I don’t use it as much as some people. For me, social media is

more about communicating with my friends and less about knowing what blogs they

like. I do admit that I text more than some kids in my school. I sent more than 3,000 texts

last month. Some months I send more, some months I send less, but it’s usually right

around that amount even when I’m in school. I don’t know exactly how many texts I

sent in June, 2015, but it was probably pretty close to 3,000, too.

I really can’t wait to get out of the house next year. I love my parents, but we

come from way different generations. In fact, it’s not even really about my parents. I just

need some freedom. I want to go someplace where I can run my own life. More than

anything, that’s why I chose to go to Madison rather than stay in Golden Harbor next

year.


On June 26, 2015, my parents and I got into an argument about how much I text.

It actually started earlier than that. I get pretty good grades, but my parents think they

would be better if I wasn’t texting all the time. On the 26th, my mom asked me to put

some clothes away. I had been looking at some memes on my Facebook newsfeed,

and I was commenting on one. It took maybe ten seconds, but my dad got upset. He

said “I don’t know what’s so important on your iPhone that you can’t put it down for

two minutes to put your clothes away. It’s not like you had to wash them or anything.” I

said “fine, I’m going” but he had already gotten started. “It’s just like that biology test.

You’re supposed to be studying, but you’re spending all your time socializing on your

phone.” One bad grade on one biology test and I hear about it every time he thinks I

am texting too much. Things went downhill from there.

When the fight was finally over, I went back to my room and posted on

Facebook “News flash. I just found out that I am the worst child a parent could ever

have. #sueme #worstparentsever #acceptmeforme #mylife #lol #madisonbound.” I

got 24 likes on that post, and a bunch of my friends made comments. I guess I’m not

the only high school student who is ready to move out. Then my friend Cameron texted

“What’s up?” Cameron knows me really well and probably knew what my post was

really about. I texted back “I’m too mad to talk about it right now. Can I come hang

out?” Cameron texted “Sure” and I grabbed my car keys and took off.

Back then I had a Marina Honda Civic. We bought it used, but it was in great

shape. I paid for part of the car and the rest was a gift from my parents, but I had to

pay all of the insurance. I worked hard for the money I paid, and I had to keep working

to be able to make the insurance payments. I loved that car.


Cameron lived about five minutes from me, but halfway there I realized I had

forgotten my wallet. I probably forgot because I was so mad at my parents when I left,

but all my money was in it so I had to go back. I texted Cameron, “Slight delay. Be

there soon.” Then I turned around to head back home.

Yeah, I know all about texting and driving. We hear about it over and over in

school and my parents won’t stop talking about it. I don’t text in front of my parents, but

I do text when I drive sometimes. Everybody in school does. They say a texting driver is

just as impaired as somebody who is legally drunk, but I don’t believe it. I’ve seen some

of my friends get drunk. I would never get in a car with them when they were like that,

but I would ride with somebody who was texting. When you are drunk you can’t

suddenly become sober, but when I’m texting I can put my phone down and then I am

the same as if I was never texting. I know you have to take your eyes off the road for a

second, but you have to do that when you change the station on the radio or turn on

the A/C. Besides, I can “blind text.” By that, I mean that I text often enough that I can

do it without looking at my phone when I type. I get some words wrong, but spell check

catches most of them. When I get a text, I usually hold my phone up so that I can read

the text and still see the road. Sometimes I even have Siri read the text out loud. I don’t

really see what the problem is. Besides, usually when I am driving and the phone buzzes

for a new text or Facebook message I just have to check it. If I don’t it drives me crazy

and I am more anxious and distracted wanting to know what the message said. In that

case, it just makes more sense to just check the message than wait until you have

arrived. If you know what you are doing, I think you can text and drive just fine.

On my way home, I was driving west on South Golden Road. I did not have my

radio blaring like Shane MacDonald says. Trust me, I would never crank up Miley Cyrus.


Anyway, as I was coming up on Quaker Street, the light was red, and I started slowing

down, but before I came to a stop, it turned green and I started to go again. Right then

I heard my phone buzz. My phone was in my lap and I looked down for a fraction of a

second to see what it buzzed about. When I get a text or have Facebook activity my

phone buzzes. I could see it was a text from Cameron. I looked back up just as I was

entering the intersection. For a fraction of a second it was all disorienting, and then

everything started moving in slow motion.

A bicyclist was riding into the intersection – cutting right across in front of me. I

know I had the green light. I slammed on my breaks and yanked the steering wheel to

the left. There just wasn’t enough room to avoid the bike. Like I said, it was like watching

everything in slow motion. Even though my car started turning, the right front fender hit

the front of the bike. It was like the bike got sucked under my car, and the bicyclist flew

up on the hood. The bicyclist kept going up the hood and hit the windshield on the

passenger side. The windshield smashed and the bicyclist went off the right side of my

car. I kept going across the intersection and ran into a car parked in the 7-11 parking

lot. I hit it hard enough that my airbags went off and it smashed up the front of my car.

I was stunned for a minute, but then I got out of my car. I don’t quite know how,

but the bicyclist was on the sidewalk, on the north side of the street. I have no idea

where the bike ended up. I could see the bicyclist lying on the ground, and I clearly

saw that the bicyclist had at least one ear bud in. I figure the bicyclist must have been

listening to music or talking on the phone. The bicyclist must not have heard me coming

and just rode into the intersection trying to beat the light.

I realized I should call my parents, so I went back and found my phone in the

car. The screen was smashed so I couldn’t use it. I set it on the hood of my car and


started to walk over to the bicyclist. Somebody stopped me and said maybe I shouldn’t

go over there. I went back to look at my phone, but it was gone. I have no idea who

took it off my hood or why. To this day, I have no idea where my phone is.

The accident was not my fault. I have been driving for almost two years. Yes, I

may have looked down at my phone for a fraction of a second; yes, I was still upset

about the fight with my parents; but I had the green light and this was not my fault. I

could have been changing the station on the radio and the same thing would have

happened. I admit I stopped texting for six months after the accident – not because it

had anything to do with the accident, but because I didn’t have a phone. I have

another one now, but I had to pay for it myself and my parents kicked me off their

phone plan. I think that is so unfair. I can’t wait to get out of here and go to college.

I have carefully reviewed this statement, and it includes everything I know of that

could be relevant to the events I discussed. I understand that I can and must update

this statement if anything new occurs to me before the trial.

Subscribed and Sworn to in Golden Harbor, Saipan, CNMI on the 1st Day of

November, 2015.

Riley Harrison .

Riley Harrison


EXHIBITS

Exhibit 1 - Image of Defendant's Vehicle

Exhibit 2 - Image of Cross Walk Instructions at Scene

Exhibit 3 - Image of Scene from the North Side of S. Golden Rd

Exhibit 4 - Image of the Intersection of the Incident

Exhibit 5 - Image of the MacDonald Family Residence and Blue Truck

Exhibit 6 - Facebook Screenshot

Exhibit 7 - Road Map

Exhibit 8 - Addison Klaver's CV

Exhibit 9 - Young Van Buren's CV

Exhibit 10 - Image of Damaged Bicycle

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

Exhibit 5

News flash: I just found out that I am the worst child a parent could ever have. #sueme #worstparentsever #acceptmeforme #mylife #lol #Madisonbound

Ralph Johnson Are you ok? What’s going on?

Carly Patterson Hey, right there with you! I am so unbelievably ready to get out of this place. Golden…more like Bronze. Lol

Exhibit 6

Screenshot of Facebook Post by Riley Harrison

Riley Harrison

Harbo

Gracie Smith Hope everything is ok. Message me if you want to talk. I am here for you.

Richard James Seriously? Don’t you think you are being a little dramatic, Riley. Why would you want to leave right now? Can’t you just enjoy life and be thankful? Nothing is that bad. #itcanwait

Gracie Smith Richard, you have no idea what is going on. If you can’t be supportive why don’t you just stay out of it?!?! #omg

Exhibit 7

Road Maps of Incident Area

N

E W

S

EXHIBIT 8

ADDISON K. KLAVER

ACCIDENT RECONSTRUCTION, LLC 708 Main St., Durango, Colorado | 970-555-8947 |

EDUCATION: May 1986 Bachelor of Science Degree in

Engineering

Colorado School of Mines

May 2000 Master of Engineering

Colorado School of Mines

PROFESSIONAL WORK EXPERIENCE: June 1992 to Present Accident Analysis Consultant

Accident Reconstruction, LLC

Durango, CO

June 1986 to July 1992 Stunt Coordinator

J & J Stunts, Inc.

Denver, CO

OTHER CERTIFICATIONS & TRAININGS: January, 1991 Accident Reconstruction State Training

Denver, CO

May, 1991 The State of Colorado Certification in

Accident Reconstruction

Denver, CO

October, 1991 NAFE Accident Reconstruction Course

Chicago, IL

1991 - 2006 Stapp Car Crash Conference

Orlando, FL

December 2000 Accident Reconstruction of Commercial

Vehicles Course

June 1993 Testifying in Court

Expert Witness Course

SEAK

Denver, CO

PROFESSIONAL AFFILIATIONS: Contributing editor, Engineering the Law Press (project-based), 2000 – Present

Consulting expert, National Association of Criminal Attorneys, Champion Magazine,

September 2009 – Present

EXHIBIT 9 Curriculum Vitae of

Young Van Buren Forensic Traffic Psychiatrist Consultation, LLC

100 El Camino Real, Suite 160

Palo Alto, CA 94304

Main Line: (415) 555-4155

EDUCATION

University of California, Irvine School of Medicine

M.D., magna cum laude 2005

Psychiatry residency at the University of California, San Francisco

School of Medicine 2005 – 2009

Fellowship in forensic psychiatry at University of California - Davis May 2010

University of California - Davis

B.A Honors in Psychology and Forensic Science, minor in criminology 2001

CERTIFICATIONS

American Board of Professional Psychology Certified 2009

American Board of Forensic Psychology 2010

PROFFESSIONAL EXPERIENCE

Forensic Traffic Psychiatrist Consultant 2012

Offers consultation services for both plaintiff and defense councils

California State Department of Safety - Forensic Traffic Psychiatrist 2010 – 2012

Dealt primarily with accidents that involved distracted driving.

PUBLICATIONS AND PAPERS

“The Dangers of Distracted Driving”

Article published on the Occupational Safety & Heath Administration’s

Distracted Driving website 2010

“It Can Wait”

Guest speaker at annual Don’t Text & Drive Conference, Los Angeles, CA 2011

“The Text that Kills – It Could Be You”

Article published as apart of AT&T Texting and Driving Campaign 2012

PROFFESSIONAL AFFILIATIONS

American Psychology

International Association for Correctional and Forensic Psychology

Forensic Expert Witness Association

Exhibit 10

2016 cnmi high school mock trial case -...

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