Preview
Krsto Mijanovic (Bar No. 205060)
Ionjianovic@hbblaw.corn
Lisa T. Omoto (Bar No. 303830) ELECTRONICALLY
lomoro@hbblaw. corn
HAIGHT BROWN & BONESTEEL LLP F I L E D
Superior Court of California,
555 South Flower Street, Forty-Fifth Floor County of San Francisco
Los Angeles, California 90071
Telephone: 213.542.8000 11/13/2020
Clerk of the Court
Facsimile: 213.542.8100 BY: YOLANDA TABO-RAMIREZ
Deputy Clerk
Attorneys for Defendants SHERMAN LEWIS
WRIGHT, FORD MOTOR COMPANY, and
CHARIOT TRANSIT, INC.
SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF SAN FRANCISCO
10
DAVID NGUYEN, Case No. CGC-19-576056
12 Plaintiff, DECLARATION OF BRYANT WOO
13 V. Action Filed: May 16, 2019
Trial Date: May 11, 2020
14 SHERMAN LEWIS WRIGHT, FORD
MOTOR COMPANY, CHARIOT TRANSIT,
15 INC., and DOES I to 30,
16 Defendants.
17
18 DECLARATION OF BRYANT WOO
19 I, Bryant Woo , declare as follows:
20
21 l. I am an Engineer with the Sustainable Streets Division of the San Francisco
22 Municipal Transportation Agency for the City and County of San Francisco. I have occupied the
23 position of Engineer between July 2008 and October 2020, Senior Engineer since October 2020,
24 and with the Department of Parking and Traffic (" Traffic Engineering Division" ) since October
25 2004. Prior to October 2004, I have worked at the San Francisco International Airport, previously
26 occupying the positions of Associate Transportation Engineer, Assistant Transportation Engineer,
27 and Junior Transportation Engineer. I graduated from U.C. Berkeley with a Bachelor's Degree in
28 Civil Engineering in 1994. I am a licensed Traffic Engineer in the State of California. I have
PS27-0000012 I
13393949.1 DECLARATION OF BRYANT WOO
personal knowledge of the contents of this declaration by virtue of my employment with the
Sustainable Streets and Traffic Engineering Divisions, and if called upon to testify, could and
would competently testify thereto. My job duties include performing a variety of traffic
engineering studies and responding to requests from the public for various traffic control devices,
and representing the Municipal Transportation Agency at public meetings. I am the person most
qualified to testify about the operation of the traffic signals located at the intersection of
Silver Avenue and Alemany Boulevard in San Francisco, California (" Subject
Intersection" ). The original records from which Exhibit A were made, prepared, and/or
maintained by the San Francisco Municipal Transportation Agency, through its employees,
10 in the ordinary course of business at the time of the acts, conditions, or events recorded
therein.
12 3. Attached hereto as Exhibit A is a true and correct copy of the timing card
13 records for the traffic signals located at the Subject Intersection that was in effect on
14 October 5, 2018.
15 4. Exhibit A shows that the lights controlling Northbound and Southbound
16 traffic on Alemany Boulevard display the same color at all times, and change their
17 indications from green, to yellow, to red, and back to green at the same time at all times.
18 At 3:40 pm, both northbound and southbound signals on Alemany Boulevard are green for
19 27 seconds, yellow for 4.5 seconds, and then red for 38.5 seconds.
20 5. I am informed and believe that the traffic lights located at the Subject
21 Intersection were functioning properly on October 5, 2018.
22 I declare under penalty of perjury under the laws of the State of California that the
23 foregoing is true and correct. Executed on this 13th day of November, 2020, at San
24 Francisco, California.
25
26
27
Bryant(Voo ~
28
PS27-0000012 2
13393949.1 DECLARATION OF BRYANT WOO
EXHIBIT A
Alemany and Silver DESCRIPTION Added xing,
yellows, all-reds,
new 2070
new M-SF cabinet.
co, new splits, FRH,
CHANGE: 11 NOTES: 1 of clock reset time = 4 AM
CNN ¹: 21781000 PHASE STREET Em Controller; 207 0
ENGINEER; J. Hornbostel 2/6 Alemany NB/SB R Cabinet: M-S F
Revision date: 1/12/2016 6 Silver WB R Oper. Date: 12/12/1 949
Programmed by: g
Installed by: System Alem any
I(ttt/(,
&
hJ/A
t'ate Master: Local TBC (GPS)
Com l go 2r/ Q
ATTACHMENTS CL
~X Base Timing ~Actuation ~Transit Priority ~Preemption (II
(I
Stea Demand Se nce
X= YES — = NO S M T W T F S CYCLE SPLIT OFFSET FLASH
7:00 TO 9:00 X X X X X — 2 1 2
16:00 TO 19:00 X X X X X — 3 1 3
ALL OTHER TIMES X X X X X X X 1 1 1
STREET PHASE 1 3 5 6 7 9 1 11 12 13 15
NB/SB 2/6 G Y
ilver WB G. Y
Peds Silver ES FRH
Ped SS/NS FRH
I
O
ws3.5 Z
s
seconds seconds 1 3 4 5 7 9 10 11 13 15
111 700 2 100 45 15 40 20.0 4.0 2.5 m
212 80 0 41 200 45 .5 40 20.0 4. 2.5
313 80.0 36 20.0 4.5 1. 4.0 20.0 2.5
PAGE 2: BASE TIMING, ACTUATION, COORDINATION SETTINGS
2 of 2 1/1 2/201 6
Alemany and Silver
+- +
— — —
tpttp Cl
tptt 3
te
rb4P 'C
&96 rb2 rp2P tc
Q.
V)
there left turn ? n/a (re
Phase 2/6 4P/8
Movement NB/SB WB
Absolute Min Green (whole ¹) 17" 20.
Early Walk '-4
Yellow 4.5 4.0
Red Clearance "
1.5 ..2.5
Absolute Min Walk (whole ¹) g. 10
FRH (whole ¹) 17 20
Actu ng use comments.
Phase 2/6 4P/8
Vehicle Detection Type NONE NONE
Ped Detection Type NONE NONE
Vehicle Recall (Max, Min, Soft or None MAX MAX
Absolute Min Green (sam
Vehicle Extension (seconds)
Max Green (only used for FREE) 27 27
Pedestrian Recall (Yes or No) YES YES
Ped Recycle (Yes or No) YES YES
"WALK EXPAND" (Yes or No) YES YES
+ + earance
Dial 1 Splits
Max Transition
Min Transition
Dial 2 Splits
Max Transition
Min Transition
Dial 3 Splits,
Max Transition
Min Transition
Coordinated Phases
Comments
all-red = 6 seconds
'
t
~ ~
'
tt
1 2
'2 3 4P
'2
7
37
3
37
5 6
7
43
7 8
37
42
37
45
37
37
45
37
cycle
length
'e
e
e'
7"
0
te
Preview
Krsto Mijanovic (Bar No. 205060) Ionjianovic@hbblaw.corn Lisa T. Omoto (Bar No. 303830) ELECTRONICALLY lomoro@hbblaw. corn HAIGHT BROWN & BONESTEEL LLP F I L E D Superior Court of California, 555 South Flower Street, Forty-Fifth Floor County of San Francisco Los Angeles, California 90071 Telephone: 213.542.8000 11/13/2020 Clerk of the Court Facsimile: 213.542.8100 BY: YOLANDA TABO-RAMIREZ Deputy Clerk Attorneys for Defendants SHERMAN LEWIS WRIGHT, FORD MOTOR COMPANY, and CHARIOT TRANSIT, INC. SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF SAN FRANCISCO 10 DAVID NGUYEN, Case No. CGC-19-576056 12 Plaintiff, DECLARATION OF BRYANT WOO 13 V. Action Filed: May 16, 2019 Trial Date: May 11, 2020 14 SHERMAN LEWIS WRIGHT, FORD MOTOR COMPANY, CHARIOT TRANSIT, 15 INC., and DOES I to 30, 16 Defendants. 17 18 DECLARATION OF BRYANT WOO 19 I, Bryant Woo , declare as follows: 20 21 l. I am an Engineer with the Sustainable Streets Division of the San Francisco 22 Municipal Transportation Agency for the City and County of San Francisco. I have occupied the 23 position of Engineer between July 2008 and October 2020, Senior Engineer since October 2020, 24 and with the Department of Parking and Traffic (" Traffic Engineering Division" ) since October 25 2004. Prior to October 2004, I have worked at the San Francisco International Airport, previously 26 occupying the positions of Associate Transportation Engineer, Assistant Transportation Engineer, 27 and Junior Transportation Engineer. I graduated from U.C. Berkeley with a Bachelor's Degree in 28 Civil Engineering in 1994. I am a licensed Traffic Engineer in the State of California. I have PS27-0000012 I 13393949.1 DECLARATION OF BRYANT WOO personal knowledge of the contents of this declaration by virtue of my employment with the Sustainable Streets and Traffic Engineering Divisions, and if called upon to testify, could and would competently testify thereto. My job duties include performing a variety of traffic engineering studies and responding to requests from the public for various traffic control devices, and representing the Municipal Transportation Agency at public meetings. I am the person most qualified to testify about the operation of the traffic signals located at the intersection of Silver Avenue and Alemany Boulevard in San Francisco, California (" Subject Intersection" ). The original records from which Exhibit A were made, prepared, and/or maintained by the San Francisco Municipal Transportation Agency, through its employees, 10 in the ordinary course of business at the time of the acts, conditions, or events recorded therein. 12 3. Attached hereto as Exhibit A is a true and correct copy of the timing card 13 records for the traffic signals located at the Subject Intersection that was in effect on 14 October 5, 2018. 15 4. Exhibit A shows that the lights controlling Northbound and Southbound 16 traffic on Alemany Boulevard display the same color at all times, and change their 17 indications from green, to yellow, to red, and back to green at the same time at all times. 18 At 3:40 pm, both northbound and southbound signals on Alemany Boulevard are green for 19 27 seconds, yellow for 4.5 seconds, and then red for 38.5 seconds. 20 5. I am informed and believe that the traffic lights located at the Subject 21 Intersection were functioning properly on October 5, 2018. 22 I declare under penalty of perjury under the laws of the State of California that the 23 foregoing is true and correct. Executed on this 13th day of November, 2020, at San 24 Francisco, California. 25 26 27 Bryant(Voo ~ 28 PS27-0000012 2 13393949.1 DECLARATION OF BRYANT WOO EXHIBIT A Alemany and Silver DESCRIPTION Added xing, yellows, all-reds, new 2070 new M-SF cabinet. co, new splits, FRH, CHANGE: 11 NOTES: 1 of clock reset time = 4 AM CNN ¹: 21781000 PHASE STREET Em Controller; 207 0 ENGINEER; J. Hornbostel 2/6 Alemany NB/SB R Cabinet: M-S F Revision date: 1/12/2016 6 Silver WB R Oper. Date: 12/12/1 949 Programmed by: g Installed by: System Alem any I(ttt/(, & hJ/A t'ate Master: Local TBC (GPS) Com l go 2r/ Q ATTACHMENTS CL ~X Base Timing ~Actuation ~Transit Priority ~Preemption (II (I Stea Demand Se nce X= YES — = NO S M T W T F S CYCLE SPLIT OFFSET FLASH 7:00 TO 9:00 X X X X X — 2 1 2 16:00 TO 19:00 X X X X X — 3 1 3 ALL OTHER TIMES X X X X X X X 1 1 1 STREET PHASE 1 3 5 6 7 9 1 11 12 13 15 NB/SB 2/6 G Y ilver WB G. Y Peds Silver ES FRH Ped SS/NS FRH I O ws3.5 Z s seconds seconds 1 3 4 5 7 9 10 11 13 15 111 700 2 100 45 15 40 20.0 4.0 2.5 m 212 80 0 41 200 45 .5 40 20.0 4. 2.5 313 80.0 36 20.0 4.5 1. 4.0 20.0 2.5 PAGE 2: BASE TIMING, ACTUATION, COORDINATION SETTINGS 2 of 2 1/1 2/201 6 Alemany and Silver +- + — — — tpttp Cl tptt 3 te rb4P 'C &96 rb2 rp2P tc Q. V) there left turn ? n/a (re Phase 2/6 4P/8 Movement NB/SB WB Absolute Min Green (whole ¹) 17" 20. Early Walk '-4 Yellow 4.5 4.0 Red Clearance " 1.5 ..2.5 Absolute Min Walk (whole ¹) g. 10 FRH (whole ¹) 17 20 Actu ng use comments. Phase 2/6 4P/8 Vehicle Detection Type NONE NONE Ped Detection Type NONE NONE Vehicle Recall (Max, Min, Soft or None MAX MAX Absolute Min Green (sam Vehicle Extension (seconds) Max Green (only used for FREE) 27 27 Pedestrian Recall (Yes or No) YES YES Ped Recycle (Yes or No) YES YES "WALK EXPAND" (Yes or No) YES YES + + earance Dial 1 Splits Max Transition Min Transition Dial 2 Splits Max Transition Min Transition Dial 3 Splits, Max Transition Min Transition Coordinated Phases Comments all-red = 6 seconds ' t ~ ~ ' tt 1 2 '2 3 4P '2 7 37 3 37 5 6 7 43 7 8 37 42 37 45 37 37 45 37 cycle length 'e e e' 7" 0 te