ECONOMIC ANALYSIS
REPORT RE:
ANGELA MEEKS
Prepared by
Angela Meeks
Student of Litigation Support
Ball State university
Muncie, Indiana
March 21, 1994
.-
TABLE I
SUMMARY OF ECONOMIC LOSSES
ANGELA MEEKS, AGE 32 TO 60
Date of Birth:
Marital status:
Appraisal Period:
Education:
Married
Position/Occupation:
2/23/94
BS (legal admin.)
Paralegal with the firm of James and Ballard
1993 to 2022, 29 years
Projected Retirement:
-
Date of Death:
3/16/62
Age 60, 2022 (1)
$2,344,144
A.
Future Earnings (2 )
B.
Personal consumption (3)
(74% of A)
1,734.667
c.
Future Value of Household Work (4)
1,232,050
D.
subtotal (A + C - B)
1,841,527
E.
Net Present Value of Loss
1.
Projected retirement at age 60 is a conservative estimate as
most individuals work beyond age 60. Such a projection,
however, has built in latitude for absences from the labor
market for such things as child bearing and illness.
It is
assumed that Mrs. Meeks would finish out the work year in which
she turned 60.
2.
see Table II, These figures for future earnings also make an
allowance for any fringe benefits.
3.
see Table IV and application of Table IV
4.
see Table! V
478,797
2
-
TABLE II
PROSPECTIVE INCOME STREAK OF ANGELA MEEKS
FROM AGE 32 TO 60
Date of Birth:
Appraisal Period:
-
2/23/94
1993 - 2022, 29yrs.
Projected Retirement:
YEAR
Date of Death:
3/16/62
Age 60, 2022
FUTURE INCOME
1993
1994
1995
1996
1997
1998
1999
2000
2001
2002
2003
2004
2005
2006
2007
2008
2009
2010
2011
2012
2013
2014
2015
2016
2017
2018
2019
2020
2021
2022
$
31,254
33,035
34,917
36,907
39,011
41,235
43,585
46,069
48,695
51,471
54,405
57,506
60,784
64,249
67,911
71,782
75,874
80,199
84,770
89,602
94,709
100,107
105,813
111,844
118,219
124,957
132,080
139,609
147,567
155,978
TOTALS
$2,344,144
Notes follow on the next page.
3
PRESENT DISCOUNTED
VALUE AT 1994
$
31,254
30,223
29,226
28,262
27,329
26,427
25,555
24,712
23,897
23,108
22,345
21,608
20,895
20,205
19,538
18,893
18,270
17,667
17,084
16,520
15,975
15,448
14,938
14,445
13,968
13,507
13,061
12,630
12,213
11,818
$601,021
NOTES FOR TABLE II
1.
Projected at a 5.7% annual rate of increase based on current
averages for paralegals nationwile as presented in Legal Assistants
Today (Vol. 10, No. 5 May/June 1993, p.48+)
2.
The earnings for 1993 are based on a national average for a
paralegal with 10 years of experience working in a private law firm
of 6 to 9 attorneys. (found in same article)
3. Discounted at 9.0%, the average annual yield on long-term U.S.
government bonds over the last ten years.
This rate (9.0%)
represents the rate of return a peron could expect on investments
with virtually no risk.
If interest rates should rise above this
in the futurE~, wage, an salary growth will also rise, an thus the
present discounted values presented here will remain essentially
unchanged.
'rhe key here is the difference between the growth in
compensation and the discounted rate:
5.7%-9.0% = -3.3%.
Therefore, the real income would have suffered an annual decline of
3.3%. This figure is quite conservative.
4.
Rounding may slightly affect the Totals .
-
.
4
TABLE III
ANNUAL CHANGES IN EARNINGS AND COMPENSATION
IN THE PRIVATE BUSINESS SECTOR
-
YEAR
PERCENT
CHANGE
1984
7.0
1985
7.4
1986
7.1
1987
7.0
1988
7.5
1990
4.4
1991
4.0
1992
3.5
1993
3.6
AVERAGE
5.7
5
--
TABLE IV
SUMMARY OF FAMILY EXPENDITURES,
INCOME, AND SAVINGS, FOR FAMILY
WITH INCOME OF $30,000 OR MORE
AVERAGE
IN DOLLARS
Money Income, before taxes
-
PERCENTAGE
OF MONEY
INCOME
$57,364
100%
Taxes
10,326
18%
Money Income, after taxes
47,038
82%
Current Consumption
(Housing Expenditure)
(Personal Insurance)
(Case contributions)
40,154
12,046
287
1,147
70%
21%
7,457
13%
Savings
6
•
5~
0
2%
APPLICATION OF TABLE IV TO MEEKS HOUSEHOLD
The deceased Angela Meeks's net contribution to household welfare
(what Jeffrey Meeks will lose monetarily as a result of his wife's
death) will consist of:
1.
2.
3.
Her contributions to savings,
Her gifts and other contributions, and
One-half of the housing expenditures.
Based on the information contained in Table IV, savings will
average 13% of income, gifts and other will average 2.5% of income,
and one-half of housing will average 10.5% of income.
Therefore,
the total
income available to the
discretionary use in any given year will average
decedent's income.
-
-
If the 26% figure is used as the
to the household welfare, her
present value, should be reduced
losses to her husband caused by
household's
26% of the
deceased's projected contribution
projected income, discounted to
by 74% in order to project the net
her death.
7
.TABLE V
PROJECTED VALUE OF HOUSEHOLD ACTIVITIES OF
ANGELA MEEKS FROM AGE 32 TO 60
FUTURE VALUES
YEAR
-
PRESENT DISCOUNTED
VALUE AT 1994
1993
1994
1995
1996
1997
1998
1999
2000
2001
2002
2003
2004
2005
2006
2007
2008
2009
2010
2011
2012
2013
2014
2015
2016
2017
2018
2019
2020
2021
2022
$
16,425
17,361
18,351
19,397
20,503
21,672
22,907
24,213
25,593
27,052
28,594
30,224
31,947
33,768
35,693
37,728
39,878
42,151
44,554
47,094
49,778
52,615
55,614
58,784
62,135
65,677
69,421
73,378
77,561
81,982
$
16,425
15,883
15,359
14,852
14,362
13,888
13,430
12,987
12,558
12,144
11,743
11,355
10,980
10,618
10,268
9929
9601
9284
8978
8682
8395
8118
7850
7591
7340
7098
6864
6637
6418
6206
TOTALS
$ 1,232,050
$
315,842
Notes follow on the next page.
8
1.
It is assumed that a working wife would on the average spend
three hours per day on household work. The value of Mrs. Meeks's
present time is $15.00 per hour as a paralegal.
($31,254/2080)
Thus, $15.00/hr x 3 hrs/day x 365 days/yr. = $16,425.
2.
Projected at the same 5.7% increase and 3.3% discount.
3.
Again, totals may be slightly off due to rounding.
9
-
·March 14, 1994
POLS 403
EVALUATING THE CASE
SETTLE/PLEA BARGAIN OR GO TO TRIAL
Questions to ask
-How much is this going to cost? (money/time)
-What kind of psychological impact will there be?
-What are your chances of winning?
.
.
Evaluation of this type is extremely important and will involve
discussion with your attorney, other paralegals on the case, and
the client. Objective and open discussion increase your chances of
success in making the right decision.
To begin, you should
establish some objective criteria by which you can evaluate any
case.
criteria
-
-
1.
2.
3.
4.
Can we win? (% chances)
How much is involved? (time/money)
What is our evidence?
What are the clients wishes?
SETTLEMENT
Form 7.1 reflects basic negotiating concepts:
You must know before starting the negotiation what you (and what you anticipate
your opponent) would be satisfied with and what would be a "good" settlement.
7
-
A planned opening demand.
-
Knowledge of the course of negotiations.
Some thoughts are:
-
You must understand the needs, desires, concerns and fears of your client and your
opponent.
As plaintiff, your initial figure will be higher than you would be willing to settle for, but
is within a realistic range.
Concessions from you will come reluctantly and then will be small.
You will continually emphasize fairness.
If your opponent's response is to decline to make a counteroffer, attempt to draw a
counteroffer by emphasizing that your proposal was sincere and thoughtful with a
desire to settle the matter.
A formal offer of settlement should be made and the response recorded.
NEGOTIATION HISTORY
My Response Will Be:
Opponent's Demand/Response
-
-
/
/
/
/
/
-/ - /
/
/
-/ -/
/
/
/
/
/
SETTLEMENT WORKSHEET
7.1
OBJECTIVES
The least my client should settle for is
A "good" settlement for my client is
My opponent will probably settle for
The anticipated initial response/demand of my opponent is ________________
My initial response/demand will be
MY NEGOTIATING IMAGE
I will project an image of:
Having complete knowledge of the facts.
Being totally prepared to litigate.
An ability and eagerness to try the case.
Firmness - reasonableness is not for me, it's for the judge.
Confidence in my ability and the client's cause.
THE INTERESTS OF THE PARTIES
My client's needs, desires, concerns and fears are:
The opponent's-needs, desires, concerns and fears are:
These interests can be reconciled by:
I
POSSIBLE ALTERNATIVE SOLUTIONS ARE:
OBJECTIVE STANDARDS THAT COULD BE USED IN ACHIEVING A SETTLEMENT ARE:
CONSEQUENCES
If this case is not settled, the consequences to my opponent are:
If this case is not settled, the consequences to my client are:
THE 4 POINTS I WILL EMPHASIZE IN THE NEGOTIATIONS ARE:
THE POINTS THE OPPONENT WILL EMPHASIZE ARE:
His Points
My Response Will Be:
February 21, 1994
POLS 403
Legal Theory and a Plan
How to begin:
1.
2.
3.
4.
5.
6.
7.
8.
9.
get the facts
organize the facts
make a fact chronology
break out the most. impol;tant facts that will motivate the trier
of fact to rule in your favor
a. appeal to common sense
b. appeal to sense of fairness
know which facts you must prove (do the same for your opponent)
make a list of the facts most dangerous to your case
identify your opponents general position
do evidentiary research
DEVELOP THE THEME
Developing the Theme
--
The theme is the summary of your case and should be concise (25
words or less).
Your entire case should revol ve around this
summary.
Its important to prepare several themes in order to
revise, expand, and elaborate. The theme that you choose will be
the heart of your case.
It is important
to remember that
perception is reality, and the jury will believe what they perceive
to be true.
Getting Started
1.
2.
3.
4.
review your opponent's theme
review your favorable facts
brainstorm
be creative, be bold, be honest, be blunt
Revising the Theme
1.
2.
3.
4.
5.
6.
7.
always be conscious of your opponent's position
Is it logical/simple?
Is it consistent with common sense?
Is it understandable?
will the facts, as perceived, support your theme.
Does it appeal to fairness/equity?
Does it overcome your opponent's favorable facts?
Uses for your Theme
~
1.
2.
3.
4.
simplification of your case
precise description of your position
voir dire
frame for your opening and closing statements
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THINGS FOR ME TO DO
NOW
BY
WEEKS
BEFORE TRIAL
By
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-
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_ _ City directory info.
_
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orders
Amendments to pleadings _ __
~Outline
V
of proof
Jury list II.
investigation
~oir
dire outline
~Opening
~Witness
~Direct
statement
outline
list &. SUbPoenas4!t/)q<..j
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Explanation!>: &. 1119tructions (Ref. to Nos. Above)
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evidence
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.'
CASE IN A NUTSHELL
WHY You will find it helpful to be able to summarize the case in a few sentences:
to the Court: at hearings, on motions, and at other pre-trial matters.
to the potential witnesses in, interviews and trial preparation .
!
,.
.. ' 1',
to the jury in voir dire.
to ultimately incorporate into your opening statement and closing argument.
HOW The summary should be structured so as to pose the Issue fairly, but favorably.
should incorporate the one or two facts most persuasive
your position .
or
.
'
Example:
"This is a divorce case where 75% of the marital estate in this 8
year marriage came from gifts and inheritances from the wife's
parents. The cou.rt's task is to decide how much of the marital
estate is to be given to the husband."
FACTS
On this form you will record the facts underlying your client's case. At this point, do
concern yourself with organizing the facts in any particular fashion - just get all the f.
down on paper.
'
-
1.1
CASE IN A NUTSHELL WORKSHEET
1.
ISSUE
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till
. 2.
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FACTS
The 1 or 2 facts most persuasive of my client's position are:
-
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RESTATEMENT
A fair, but favorable summary of this case and the issue is:
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FACT CHRONOLOGY
WHAT Here, you will arrange the facts bearing on the case In chronological order.
HOW When In doubt the chronology will Include a fact rather than omitting it. As the case
progresses the chronology will be revised as you learn more about the case. The chronolcxJ':i
will always include the materials covered in sections 4 and 5. Your initial draft of +fit:.
chronology should leave ample space between entries to facilitate insertion of additiorol
facts. In complex cases the witnesses, documents and other back-up sources of the facts
noted so that I:ater the source can be easily pinpointed.
WHY The chronology will be useful:
in giving an overview of the facts and to prevent an Important fact from be
overlooked.
in your witness preparation.
in assuring that all important facts have been obtained from the client.
in preparing opening statement and closing arguments.
in determining the order In which witnesses will be called.
FACT CHRONOLOGY WORKSHEET
2.1
The facts which bear on this case in chronological order are:
FACT/CIRCUMSTANCE
3 ~ 3)
3.'46
SOURCE
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_____________________________ 11w"J _____ _
MY MOST IMPORTANT FACTS
Out of the universe of facts that may be relevant to the case, you must select those wh
are truly important. A Judge or jury is only able to appreciate and retain a portion of
evidence presented.
You must Identify those facts which are going to motivate the trier to decide in y<
client's favor. Most of the time these will be facts which create an appeal to justice, equity, e
common sense . Of course you must not overlook the necessity of presenting evidence wh
will support the legal requirements of your claim or defense.
-
-
MY MOST IMPORTANT FACTS WORKSHEET
3.1
MOTIVATING FACTS
The 10 or 15 facts which are most likely to motivate the trier of facts
to rule in my client's favor, and which would appeal to one's sense of
fairness, justice and common sense are:
WITNESS/DOCUMENT
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LEGAL REQUIREMENTS
Other facts which I must prove to satisfy the legal requirements of my
claim or defense are:
WITNESS/DOCUMENT
.-
MY OPPONENT'S MOST IMPORTANT FACTS
Proper preparation requires that you anticipate the facts that your opponent will prese
This prevents surprise and enables you to feel comfortable when that evidence comes
Most importantly, identifying the opponent's facts will permit you to rebut those facts if they c
not true or to blunt their effect If they are true. A knowledge of your opponent's facts is al
necessary for effective witness preparation •
-
.
-
MY OPPONENT'S MOST IMPORTANT FACTS WORKSHEET
MOTIVATING~r~'A~C_T~~S
4.1
___________________________________________________
The facts most harmful to my client's case,
which my opponent may attempt to prove are:
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THE GENERAL POSITIONS MY OPPONENT WILL TAKE ARE:
THE LEGAL REQUIREMENTS OF MY OPPONENT'S CLAIM OR DEFENSE
WHICH HE MAY HAVE DIFFICULTY IN PROVING ARE:
!dw:-ecJ..ud
(I~
(rLl~')
L111Gt;07 , :Ot,
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(LOR
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RESPONSE
I will defeat my opponent's position by showing that his facts are not
as he pictures them or I will avoid their impact. Specifically, I will:
til ~~-- ~::iYt.fdtJ;
oJ!y.a
LL:J -'.~f:1.i:J1.l:~~ __ .!J)fA..!~---- - - ------,LiilIh'-:1J~_J::i1t_-_-AL~7_. ___'lt-__ '1!L~::J~_{f;j:;&./l. ----------iU;Q
- -- -.-- ._-----_._----- -_.- - - . - - - . - -------.----_.- -.
---- ._----- ---- --- - - -- -
.-.
--
- ------ -- -- -- --.-
- _. - -_._--_ ..
=================. _-=-=-==..===--_. ._--- ._._-.
"'
---.--.------- -~---
----. . .__ ...
_-_•._----------
THEME OF THE CASE
The most important and productive 20 minutes of trial preparation will be spent
selecting an appropriate theme. The theme of the case is the answer you would give if ask
to explain in 20 words or less why your client's position Is meritorious.
The theme is the basic concept which everything at trial Is going to revolve around. If t
whole case is the body, the theme is the spine. It Is the equivalent of the headline in
newspaper article - It's the central message.
You are going to prevail because of what the trier of facts perceives the facts to be. Y
will not win because of eloquence or an exciting cross-examination. Prevail by showing tt
the result you dl3sire will serve justice. It's the "right" decision. Satisfying the legal requil
ments of a claim or defense is not enough to prevail.
It takes courage and good sense to ruthlessly discard all but the most important parts
the case. Responding to the fear that the trier will make his decision on an obscure po
results in a scatter-gun approach; one whose impact is defused.
-
-
-
THEME OF THE CASE WORKSHEET
DONE
My Facts
Review the favorable facts listed in Form 3-1 which you
believe are most likely to motivate a decision favorable
to your client.
Opponent's Facts
Review the unfavorable facts listed in Form 4-1 which you
anticipate your 0
onent will seek to rove.
Possible Theme
List 2 or3 possible themes drawn from your favorable facts.
Brainstorm and think boldly and creatively.
The fine tuning
and deep thinking can come later.
1.
LU K I -iJ7ce ,lit le
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'--(K{z A. (}vyn;
AWN ~{M'72c/
J.rUU£4);CY15
y:x CUd\t?kh3.
Revised Theme
Review the possible themes to harmonize one with the
other or to make one of them a logical sub-part of another or
simply choose the strongest of the possible themes.
The revised theme reads:
------_.- ------_._-------------------+--_._--
...,--------
..
---
--_._._..__._-----_
....-
...
_-
"--'- - ..
- -
-
- -_. -.------..- - .
----_._------
POSSIBLE THEMES FOR THE DEFENSE
c.
Shrackle Defense
1.
We, the defense, agree that the unfortunate death of Katherine Potter
is a tragedy; however, due to actions on the part of Mrs Potter this
accident was unavoidable. She clearly breached her duty as a
pedestrian to cross the street with caution. Charles Shrackle acted as
he should as a cautious and lawful driver of a motor vehicle. The facts
in this case will prove contributory negligence on the part of Mrs.
Potter and free our client of any liability.
2.
We are in agreement that Katherine Potter's death is a tragic one;
however, due to actions by Mrs. Potter, the accident of November 3D,
1992, was unavoidable. Evidence will show that Mrs Potter was struck
some distance from the crosswalk and that Charles Shrackle was
driving as a normal and cautious motorist. Katherine Potter was
contributorily negligent relieving any liability from the defense.
-
February 7, 1994
POLS 403 notes
Investigation
1. Direct
Direct investigation is used to get the facts and get the facts as
quickly as possible.
It is usually the gathering of pertinent
documents and witnesses to the accident or action in question.
Investigations should be as completely thorough as possible. Most
times it is as simple as asking questions and piggybacking on the
work of others like insurance companies and newspapers.
It is
important to include the client in this process, but do not allow
the client to control the information.
YOU decide what is of
importance. Do not assume that all of the information you get is
correct
either.
Read everything and make any necessary
corrections.
a. information to obtain
-
-accident reports/police reports
-driving records
-coroner's report
-medical histories and hospital records
-news reports
-weather information
-insurance policies
-tax returns
*Know your rights to find this information under FOIA (Freedom of
Information Act)
2. Indirect
Indirect investigation compliments the facts obtained in direct
investigation by working to add human opinion and perception to
them. It is important here to make an effort to think critically,
analytically, and creatively about the facts.
a. things to do
-go to the scene yourself/get a feel for the environment--Could
things have happened like the statements say?
-Act out the occurrences
-get measurem.ents and video tape the accident from your point of
view
-have client keep a diary of their injuries
-
My name is
id1lDJY-tl d
My address is
lCj Ie
ke.=,.:.....:../I-=fL/'--_ _ _ _ _ _ _ _ _ _ _ _ __
6ldey Ivn.
IJlhi. &kl1
I
My phone number is
~5=.~S~':~-)_-~/~~~_\3=_
I am/~~ related to or
invol ve r--tfl the acc ident.
I
____________________________________
acquainted
with any
of
the
parties
have previously made statements regarding the accident to
To the best of my knowledge and recollection, the accident
k, vbq (Jt Je:x
-fL.. m.
I
on
at approximately -=3~:~~3E~J_____________ o'clock
During the accident, I ob::=;erved the following: VJ 4f/1/){('.£ d
d.JU. \QtC(2,
/)."H1.1./n
V2 }].Laht1 a~ -kiVA,
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-
QA.c;P*
s i ~"" d
rn·,ck
d,
"--/2)/2
.n '
ru.i~"':t· mtt.a··
....
INVESTIGATION
----------_._._--WHAT DID
FRIENDS?
_
YOU KNOW OF PLAINTIFF'S PERSONAL LIFE \HTII FAMILY &
(SUMMARIZE) --A~,~u~W~j~'7~/~a~11r~'------____________________________
._-----_._"_
, .. _------._------_.
DESCRIBE \-JllAT YOU OBSERVED ABOUT THE PLAINTIFF THAT CHANGED AFTER
THE INJURY.
(GIVE SPECIFIC EXAMPLES IF POSSIBLE, i. e., STOPPED
BOWLING, FACE SHOWED TENSION, PAIN, ETC.)
IN REGARD TO APPEARANCE
IN REGARD TO WORK MISSED,
WORK DIFFICULTIES
! ...- - - -
IN REGARD TO RECREATIONAL ACTIVITIES
--------------------------.-------
----------------_._--._----IN REGARD TO IImlE ACTIVITIES (NO HORE GARDENING, SEHING, LAHN CARE,
ETC. ) ____ _______________._. _______ .. ____ .. __ ...... _. ____ . _. ________._ _ ._._____._ .' _____ .
-- --_ •...
__.._--- -_._---
"-"
..
-
._-----
- ...•
---- ._-_.. __ .... _--_.- ._.. _--.- ......_._-- --_._----------------:;::---- -------_._--_._/'
- -"---'--'--
-
My name is
My address
iJJKe_hl(L~ _ _ _ _ _ _ _ __
~,euille
is
P('. i3cy; I d3
My phone number is
3'73- U{)lct
-----------------------------------------------
I am/~ ~8..0 related to or
involve 1n the accident.
I
acquainted with any
of
the
parties
have previously made statements regarding the accident to
To the best of my knowledge and recollection, the accident
NCcfu5
was at
,/ L3D/CjJ
~.m:
Qilci
kl vlJ.~
Clve)5
LSisLu
at approximately
CL,('Y1er- 0+
.3'. ;}5
ink6eC+Ui~1 __
on
Ha.tfis
i
During the accident, I observed the following: \.[)
:.lJuL,)xp-A/nd
,-
(f[;CI21
a
{if:)
(Pzeaud tL
J/} 2( ,') M (Lw hli.& .
0'
clock
INVESTIGATION
WIIAT DID
FRIENDS?
YOU KNOW OF
(SUMMARIZE)
PLAINTIFF'S
PERSONAL
LIFE
\HTII
FAMILY
&
-
------------------.-----.---------------------------- --------,
DESCRIBE WHAT YOU OBSERVED ABOUT THE PLAINTIFF THAT CHANGED AFTER
THE INJURY.
(GIVE SPECIFIC EXAMPLES IF POSSIBLE, i. e., STOPPED
BOWLING, FACE SHOWED TENSION, PAIN, ETC.)
IN REGARD TO APPEARANCE
,---
IN REGARD TO WORK MISSED, WORK DIFFICUL
IN REGARD TO RECREATIONA
ACTIVITIES
----------------------- --7---
--------------------- - - - - - - - - - - - - - - - - - - - - - - - - -
--------------------------------------------IN REGARD T HmlE ACTIVITIES (NO NORE GARDENING, SEWING, LAWN CARE.
ETC. l _____________ .___ _________________________________________________________________ _
.•;;<-=- . . :.•. . . . . .-.• •. =~--~~-:-~:=-:~~~=-.:-::.=--: ~-~=~:~-:-••
.
.
\,0
.
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I
- ...•-
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.
_
...
-.-...
.. _..
__.-
~m c)
.. _........
- .. -_..
{tLUtLud"-
-_
.....
-
-
My name i s
~~ ____b--ksLYL (-,-I-----,-=-l--l-f:iJ..U...IA
My ad d res s i s
_---1-1=(0-""'-0-'-1
My phone number is
--I-M-.J..Ia.",-,A,,-,-b-I-C5~_--L.tJ=.!-'-1t;~(.L=-~C~L,,"-+L....:\.J"'I--_ _ _ _ _ _ _ _ __
5:5;) - 0033
--~~--~~~------------------------------------
I am~~ related to or
involved in the accident.
I
--L·/~e}L~a~c~Q'J~___
1 '-=..5
VL-=:Stii!l...l])w:lo....lIL..:...-
acquainted
with any
of
the
parties
have previously made statements regarding the accident to
To the best of my knowledge and recollection, the accident
was a t ~fu
II 130lq~l
I
hlo
on
+h~ and ki
at approximately ~~~!_,1)=-_____________ o'clock
nj.ev;5t'-cbon of
,k-y
~.m.
At that time I was
CVn
,-
L!:/Yl
Cd /iJ!
.
liJVJ. PLY24J l1YL'YlLL6
eia....:tcQ1....:
hc<b.LU! CLVh-&-
'-fJ
Prior to the. accident, I observed the following:
ahA,) CV
j L)-fYY)lt301
rAja i. AQ,Ll1%
v.tJ.Di: tmr)J (J ~/)Q1I ~h
,..f'\a.H J?- JW (IV (/
0-t cU dna ,Q.£ -
I
(
Other observations and comments:
----.------.----.-----
-
._--- -----.--.- ._-_._--_._-----_._----------------_.-----
----------- - . - -
-.