Motion for Expert Witness List in Amatul Wallace v. Brickney Henry, Ean Holdings, Llc, Enterprise Holdings, Inc. D/B/A Enterprise Rent-A-Car, Enterprise Leasing Company, Cheryl Wallace| Trellis.Law

On April 07, 2017 a Motion-Secondary was filed involving a dispute between Amatul Wallace, and Brickney Henry, Cheryl Wallace, Ean Holdings, Llc, Enterprise Holdings, Inc. D B A Enterprise Rent-A-Car, Enterprise Leasing Company, for Torts - Motor Vehicle in the District Court of Queens County.

Preview
FILED: QUEENS COUNTY CLERK 12/01/2022 05:03 PM INDEX NO. 705531/2018
NYSCEF DOC. NO. 118 RECEIVED NYSCEF: 12/01/2022

SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF QUEENS
_________________________________________________________________Ç
AMATUL WALLACE,
Index No.: 705531/2018

Plaintiff,
EXPERT WITNESS
-against- DISCLOSURE PURSUANT
TO CPLR §3101(d)
BRICKNEY HENRY, EAN HOLDINGS, LLC,
ENTERPRISE HOLDINGS, INC. d/b/a
ENTERPRISE RENT-A-CAR, ENTERPRISE
LEASING COMPANY and CHERYL WALLACE,

Defendants.
_________________________________..______________________Ç

PLEASE TAKE NOTICE, that defendant, CHERYL WALLACE, by her and through

her attorneys, BRAND GLICK & BRAND, P.C., respectfully set forth for her Response to

Demand for Expert Information, as follows, pursuant to CPLR §3101(d):

1. Defendant, CHERYL WALLACE, intends to call Ashley Liston Dunn, Ph.D.,

P.E., for the purpose of giving testimony at the time of trial.Dr. Dunn maintains offices located

at 7001 Buffalo Parkway, Columbus, Ohio 43229. Dr. Dunn is an engineer with extensive

experience in knowledge of the area of accident reconstruction, automotive engineering and

automotive technology. Defendants expect to call the above-named at trial as an accident

reconstruction expert.

2. The substance of the facts and opinions upon which Dr. Dunn will testify is set

forth in the text of his reports dated December 1, 2022. Dr. Dunn will testify as to a

reconstruction of the relevant details regarding the subject accident, including the dimensions of

the roadway, dimensions of the vehicles involved, speed of the vehicles involved, reaction time,

braking distance, visibility, vehicle dynamics, movement of the vehicles involved, steering

inputs to the vehicles, braking distances, time interval relative to the distance covered by the two

1 of 37
FILED: QUEENS COUNTY CLERK 12/01/2022 05:03 PM INDEX NO. 705531/2018
NYSCEF DOC. NO. 118 RECEIVED NYSCEF: 12/01/2022

(2) vehicles immediately prior to the subject accident, vehicle points of contacts, and all factors

relevant to accident reconstruction. A copy of Dr. Dunn's report that is consistent with his

anticipated testimony is annexed and hereby served in accordance with the Appellate Division

rules governing the exchange of medical information.

3. Dr. Dunn will further testify based upon his general knowledge and expertise in

the field of accident reconstruction regarding the injuries allegedly sustained by the plaintiff.

4. A copy of Dr. Dunn's Curriculum Vitae is annexed hereto.

Defendants reserve the right to name additional experts to testify upon conclusion of

discovery up to and including the time of trial.Defendants further reserve the right to amend

and/or supplement this response up to and including the time of trial.

Dated: East Meadow, New York
December 1, 2022
Yours etc.,
BRAND GLICK & BRAND, P.C.

By: Savid 'W . $mnd

David W. Brand
Attorneys for Defendant
CHERYL WALLACE
90 Merrick Avenue, Suite 203

East Meadow, New York 11554

(516) 746-3500
File No.: 02-13635-DWB

TO: WILLIAM SCHWITZER & ASSOCIATES, P.C.

Attorneys for Plaintiff

820 2nd Avenue, 10th Floor

New York, NY 10016

(212) 683-3800
File No.: SMSC18-068

2 of 37
FILED: QUEENS COUNTY CLERK 12/01/2022 05:03 PM INDEX NO. 705531/2018
NYSCEF DOC. NO. 118 RECEIVED NYSCEF: 12/01/2022

THE LAW OFFICE OF MICHAEL FERRO & ASSOCIATES
Attorneys for Defendant
BRICKNEY HENRY
2 Huntington Quadrangle, Suite 2N01

Melville, New York 11747

(516) 229-4228
File No.: 17Q1726

3 of 37
FILED: QUEENS COUNTY CLERK 12/01/2022 05:03 PM INDEX NO. 705531/2018
NYSCEF DOC. NO. 118 RECEIVED NYSCEF: 12/01/2022

INVESTIGATION, RESEARCHANDTESTING

Since 1970
* -
1970 2020

Wallace vs. EAN Holdings, LLC, et al.

EAN Holdings
East 103rd Streetnear Avenue K
Kings,NY

Date of Incident:June 9, 2016

Prepared for:

Brand Glick & Brand, P.C.

Anna Bangiyev
90 Merrick Avenue, Suite203
East Meadow, NY 11554

S-E-A Matter No. 01.126198

Issue Date: December 1, 2022

S-E-A | 7001Buffalo Parkway, Columbus,OH 43229 | 800.782.6851 | SEAlimited.com

ATLANTA " BALTIMORE/DC " CHARLOTTE" CHICAGO CLEVELAND" COLUMBUS " DENVER" DETROlT " FT. LAUDERDALE" HOUSTON " ST.LOUlS " TAMPA

4 of 37
FILED: QUEENS COUNTY CLERK 12/01/2022 05:03 PM INDEX NO. 705531/2018
NYSCEF DOC. NO. 118 RECEIVED NYSCEF: 12/01/2022

Table of Contents

Listof Figures.........................................................................................................................3

I. Executive Summary ....................................................................................................5

Matter Assignment .............................................................................................................
5

Scope ...................................................................................................................................
5

Methodology.......................................................................................................................
5

Conclusions .........................................................................................................................
5

Signatures............................................................................................................................
6

II. Procedures.................................................................................................................7

Ill. Discussion..................................................................................................................8

Accident Background ..........................................................................................................
8

Damage to the Accident Vehicles .......................................................................................
8

Impact Configuration and Impact Positions........................................................................
9

Cause(s) of the Accident ...................................................................................................
10

Appendices..........................................................................................................................25

Investigator Credentials ....................................................................................................
25

S-E-A Matter No. 01.126198
Issue Date: December 1, 2022 2 of25

5 of 37
FILED: QUEENS COUNTY CLERK 12/01/2022 05:03 PM INDEX NO. 705531/2018
NYSCEF DOC. NO. 118 RECEIVED NYSCEF: 12/01/2022

List of Figures

Figure 1:Google aerial image of the accident area. The arrow indicates the entrance to the
premise of Ms. Patterson's residence (the building of 1117 East 103rd Street)...........................11

Figure 2: Google aerial image of the accident area at a lower levelthan Figure 1........................12

Figure 3: Google street view, looking north toward the accident area. The entrance to Ms.
Patterson's building isindicated with the arrow............................................................................12

Figure 4: Google street view, looking north toward the accident area. The entrance to Ms.
Patterson's building is indicatedwith the arrow............................................................................13

Figure 5: Google street view, looking toward the entrance to the building of Ms. Patterson's
residence........................................................................................................................................14

Figure 6: Right front view of the Nissan Sentra. Note itsdamage spanned from the right
front to the leading edge of the rightfront door. The rightfront tirehas been replaced with
the spare tire when this photograph was taken............................................................................15

Figure 7: Close-up view of the right front of the Nissan Sentra.....................................................16

Figure 8: View of the damage to the rightfront quarter panel and the right front door of the
Nissan Sentra..................................................................................................................................17

Figure 9: Photograph of the rear leftside of the Nissan Altima. Note the damage started
from the rear bumper and extended to the trailingedge of the leftrear door. ...........................18

Figure 10: Close-up view of the left rear of the Nissan Altima. The arrow shows the

beginning of the contact on the leftside of the rear bumper.......................................................19

Figure 11: Close-up view of the damage to the trailing edge of the left rear door of the
Nissan Altima..................................................................................................................................20

Figure 12: Impact configuration between the Nissan Altima and the Nissan Sentra. The
Nissan Altima is stopped along the curb line.The Nissan Sentra engages with the Nissan
Altima at a slightangle to cause the damage to both vehicles as seen inthis accident. This
scenario can be ruled out...............................................................................................................21

Figure 13: Impact configuration between the Nissan Altima and the Nissan Sentra. The
Nissan Altima is stopped along the curb line.The Nissan Sentra isparallel to the roadway.
Under this impact configuration, the Nissan Sentra would make contact with other parked
vehicles before itreaches the Nissan Altima. Therefore, this scenario can be ruled out..............22

Figure 14: Impact configuration between the Nissan Altima and the Nissan Sentra. The
Nissan Altima is stopped parallelto the roadway but into the travel portion of the
northbound lane, and the Nissan Sentra is moving parallelto the roadway. In thisimpact

configuration, itis likelythat the Nissan Sentra would engage with the rear face of the
Nissan Altima's rear bumper, which isnot seen inthis accident. Therefore, this scenario can
be ruled out....................................................................................................................................23

Figure 15: Impact configuration between the Nissan Altima and the Nissan Sentra. The
Nissan Altima is ata slightangle with the roadway. The Nissan Sentra is parallelto the
roadway. The way the Nissan Sentra engages with the Nissan Altima inthis configuration

S-E-A Matter No. 01.126198
Issue Date:December 1, 2022 3 of25

6 of 37
FILED: QUEENS COUNTY CLERK 12/01/2022 05:03 PM INDEX NO. 705531/2018
NYSCEF DOC. NO. 118 RECEIVED NYSCEF: 12/01/2022

would result inthe damage similar to what is seen on both vehicles inthis accident.

Therefore, thisis theaccident impact configuration.....................................................................24

S-E-A Matter No. 01.126198
Issue Date: December 1, 2022 4 of25

7 of 37
FILED: QUEENS COUNTY CLERK 12/01/2022 05:03 PM INDEX NO. 705531/2018
NYSCEF DOC. NO. 118 RECEIVED NYSCEF: 12/01/2022

I. Executive Summary

Matter Assignment

On or about September 14, 2022, Ms. Anna Bangiyev contacted SEA, Ltd. (S-E-A) regarding the

investigation of an accident that occurred on East 103rd Street near the intersection with

Avenue K in Kings,NY. The subject accident occurred at approximately 10:15 p.m. on June 9,

2016. The accident involved a 2010 Nissan Altima and a 2016 Nissan Sentra. This investigative

matter was assigned to Ashley L Dunn, Ph.D., P.E. as S-E-A matter number 01.126198.

Scope

The scope of the assignment included reviewing case-related materials, reviewing related

publications, and rendering opinions regarding the reconstruction of the subject accident.

Methodology

The methodology utilized by S-E-A during the investigation of thisincident was inaccordance

with The Scientific Method and applicable principles. The investigation and analysisof any

incident is a complex and endeavor.
scientific The methodology of such an endeavor, therefore,

must include the comprehensive, objective, and accurate compilation and analysisof the

available data.

Conclusions

" Based on the damage to the Nissan Altima and the Nissan Sentra, the impact speed of the

Nissan Sentra was approximately 7 to 10 mph. The rightfront of the Nissan Sentra made

contact with the rear leftside of the Nissan Altima. Itis likelythat the Nissan Sentra came

to a stop when itsright front reached the leftrear door of the Nissan Altima.

" The Nissan Altima was partially in the travel portion of the northbound lane of

East 103rd Street and at a slightangle with the roadway. The front of the Nissan Altima

was closer to the roadway centerline than the rear at impact.

" The improper reversing/stopping of the Nissan Altima at thetime of the accident created

an unexpected hazard to the northbound drivers and contributed to the cause of the

accident.

S-E-A Matter No. 01.126198
Issue Date: December 1, 2022 5 of25

8 of 37
FILED: QUEENS COUNTY CLERK 12/01/2022 05:03 PM INDEX NO. 705531/2018
NYSCEF DOC. NO. 118 RECEIVED NYSCEF: 12/01/2022

Signatures

S-E-A and the undersigned hereby certifythe opinions and conclusions expressed herein were

formed to a reasonable degree of professional certainty. They are based upon the applicationof

reliableprinciples and scientificmethodologies to allofthe facts known by S-E-A and the

undersigned when thisreport was issued,as wellas knowledge, experience,
skill, training and/or

education. Should additionalinformation be discovered, S-E-A and the undersigned reserve the

right to appropriately amend or augment these findings.

Prepared By: Technically Reviewed By:

Ashley L Dunn D.,P.E. hn F. Wiechel
Senior Mechanical Engineer
State of New York
License No. 089348-1

ESSIO

Warning: Itis a violation
of NYS Education Law, Article 145, for any person to alterthis

document inany way, unlessacting under the direction of a licensedprofessional engineer.

S-E-A Matter No. 01.126198
IssueDate: December 1, 2022 6 of25

9 of 37
FILED: QUEENS COUNTY CLERK 12/01/2022 05:03 PM INDEX NO. 705531/2018
NYSCEF DOC. NO. 118 RECEIVED NYSCEF: 12/01/2022

II. P rocedures

1. The following case-related material has been made available to S-E-A and reviewed by S E-A:

" New York State Department of Motor Vehicle Accident Report with accident number

MV-2016-069-010487;

" Holdings'
EAN Verified Answers to Verified
Plaintiff's Complaint;

" Repair appraisal and photographs of the accident Nissan Sentra;

" Repair appraisal and photographs of the accident Nissan Altima;

" Deposition transcript of Amatul Wallace taken October 30, 2019;

" Deposition transcript of Cheryle Wallace taken May 23, 2019;

" Deposition transcript of Teresa H. Patterson taken April 3, 2019.

" Deposition transcript of Brickney Henry taken September 23, 2019.

2. S-E-A has alsoreviewed the following information:

" Google aerialimages and street views of the area of the accident;

" VINLink and Clearvin reports of the Nissan Altima;

" VINLink and Clearvin reports of the Nissan Sentra;

" Graphic demonstration of vehicle impact configuration and positions, based on S-E-A's

reconstruction.

S-E-A Matter No. 01.126198
Issue Date:December 1, 2022 7 of25

10 of 37
FILED: QUEENS COUNTY CLERK 12/01/2022 05:03 PM INDEX NO. 705531/2018
NYSCEF DOC. NO. 118 RECEIVED NYSCEF: 12/01/2022

Ill. Discussion

Accident Background

According to the New York Police Accident Report, this accident occurred on East 103rd Street

near the intersection with Avenue K in Kings,New York at or about 10:15 p.m. on June 9, 2016.

East 103rd Street is a northand southbound two-lane roadway with parking space on both sides

of the roadway. At the time of the accident, itwas dark but the roadway was illuminated with

streetlights. East 103rd Street at theaccident location is straightand level. The road surfaces

were dry. This accident involved a 2016 Nissan Sentra driven by Cheryl Wallace and a 2010

Nissan Altima driven by Brickney Henry.

The policecrash report describes the accident as follows:

"AT TPO DRIVER OF VEHICLE 1 STATES THEY WERE HEADING NORTHBOUND ON EAST 103
WHEN VEHICLE 2 WAS REVERSING AND THEY HIT VEHICLE2. DRIVER OF VEHICLE 2 STATES
THEY WERE PARKED DROPPING OFF A FRIEND WHEN VEHICLE 1 STRUCK THEIR VEHICLE ON
VEHICLE."
THE BACK LEFT DRIVER SIDE OF THE

Unit 1 is theNissan Sentra, and Unit 2 is theNissan Altima.

Figure 1 through Figure 5 are Google aerialimages and street views of the accident area. Figure

1 and Figure 2 are Google aerialimages of East 103rd Street. The accident locationwas likelyto

be around the entrance to the premise of Mr. Patterson's residence at the time of the accident,

1117 East 103rd Street. Figure 3 through Figure 5 are progressive street views toward the

entrance to Mr. Patterson's residence. The entrance was wide enough to allow a passenger

vehicle to stop along the street.

Damage to the Accident Vehicles

Figure 6 through Figure 8 are views showing the damage to the Nissan Sentra. The damage

started from itsrightfront and extended to the leading edge of the rightfront door. The right

front tire shown in thephotographs was the spare tire.

Figure 9 through Figure 11 are views of the damage to the Nissan Altima. The damage to the

Nissan Altima was limitedto the leftrear quarter panel and the trailingedge of the leftrear

door.

S-E-A Matter No. 01.126198
IssueDate: December 1, 2022 8 of25

11 of 37
FILED: QUEENS COUNTY CLERK 12/01/2022 05:03 PM INDEX NO. 705531/2018
NYSCEF DOC. NO. 118 RECEIVED NYSCEF: 12/01/2022

The extent of the damage to both vehicles is comparable, which indicates that the Nissan Sentra

came to a stop when itsrightfront reached the leftrear door of the Nissan Altima. The speed of

the Nissan Sentra at the beginning of the contact was approximately 7 to 10 mph.

Impact Configuration and Impact Positions

To complete the accident reconstruction, S-E-A has analyzed four different accident scenarios

and ruled out three of them. The four accident scenarios analyzed are discussed below.

Ms. Patterson stated in her deposition (pp. 24 and 25) that the Nissan Altima was parked

(stopped) along the curb and not far from the curb. Ms. Henry also stated similarly in her

deposition (pp. 16 to 17 and 61 to 62). Based on their descriptions of the positioning of the

Nissan Altima, inorder to engage the rightfront of the Nissan Sentra with the rear leftside of

the Nissan Altima as they did inthis accident, the Nissan Sentra would have toyaw clockwise

and drivetowards the leftrear of the Nissan Altima (Figure 12). That is notconsistent with

normal driving of a vehicle. East 103rd Steet is approximately 44 feet wide (22 feet for each

direction). Ms. Wallace had enough room to proceed through safely without being close to

parked or stopped vehicles that were adjacent to the curb. Therefore, based on expected driver

behaviors, the configuration shown in Figure 12 isruled out.

If theNissan Sentra was traveling parallelto the roadway when itmade contact with the Nissan

Altima, the Nissan Sentra would have been close to the other parked vehicles before itreached

the Nissan Altima (Figure 13). Under thisscenario, the rightrear-view mirror of the Nissan

Sentra would likely impact the leftrear-view mirrors of other parked vehicles prior to making

contact with the Nissan Altima. However, thisdid not happen inthis accident, and based on the

vehicle damage profiles,the configuration shown in Figure 13 isruled out.

If theNissan Altima was stopped partiallyinthe travel portion of the northbound lane (Figure

14), the Nissan Sentra, under normal driving in itsown lane, could make contact with the Nissan

Altima. Under thisscenario, one would expect to see evidence of contact toward the rear face

of the Nissan Altima's rear bumper. However, the onset of the damage to the Nissan Altima's

rearbumper was more forward, which suggests that the two vehicles were not collinear at the

initialcontact. Rather, they were at a slightangle. Therefore, based on the vehicle damage

profiles, the configuration shown in Figure 14 is ruledout.

S-E-A Matter No. 01.126198 . .
IssueDate: December 1, 2022 9 of25

12 of 37
FILED: QUEENS COUNTY CLERK 12/01/2022 05:03 PM INDEX NO. 705531/2018
NYSCEF DOC. NO. 118 RECEIVED NYSCEF: 12/01/2022

The likelyscenario, consistent with Ms. Cheryl Wallace's testimony that the reverse lightson the

Altima were illuminated (pp. 56 and 64), is thatthe Nissan Altima was reversing or in reverse

and was positioned at an angle to the roadway with itsleftfront closer to the centerline than its

leftrear, and itwas protruding into the travel portion of the northbound lane as depicted in

Figure 15. When the driver of the Nissan Sentra, Ms. Wallace, was approaching the Nissan

Altima, the Nissan Altima protruded into her travel lane. Without proper warnings, the Nissan

Altima was unexpected to the northbound drivers and created an unnecessary hazard.

Cause(s) of the Accident

This accident was likelycaused by the improper reversing of the Nissan Altima that protruded

into the travel portion of the northbound lane of East 103rd Street, creating an unexpected

situation for other drivers.

S-E-A Matter No. 01.126198
SEA.
IssueDate: December 1, 2022 10 of25

13 of 37
FILED: QUEENS COUNTY CLERK 12/01/2022 05:03 PM INDEX NO. 705531/2018
NYSCEF DOC. NO. 118 RECEIVED NYSCEF: 12/01/2022

yi Restaurants lapHotels
@ Things
todo TransitP Parking Pharmacies ATMs 99

Figure 1: Googleaerial image of theaccident area. The arrow indicates the entrance to the premise of
Ms. Patterson's residence (the buildingof 1117 East 103rd Street).

S-E-A Matter No. 01.126198
S-E·A.
Issue Date:December 1, 2022 11 of25

14 of 37
FILED: QUEENS COUNTY CLERK 12/01/2022 05:03 PM INDEX NO. 705531/2018
NYSCEF DOC. NO. 118 RECEIVED NYSCEF: 12/01/2022

Restaurants InqHotels
@ Things
todo @Transit P Parkng Pharmacies @ ATMs .

Figure 2: Googleaerialimage ofthe accident area ata lower levelthan Figure 1.

Figure 3: Googlestreet view, looking north toward the accident area.The entrance to Ms. Patterson's
building is indicatedwith the arrow.

S-E-A Matter No. 01.126198
Issue Date: December 1, 2022 12 of25

15 of 37
FILED: QUEENS COUNTY CLERK 12/01/2022 05:03 PM INDEX NO. 705531/2018
NYSCEF DOC. NO. 118 RECEIVED NYSCEF: 12/01/2022

School el

Figure 4:Google street view, lookingnorth toward the accident area. The entrance to Ms. Patterson's
building is indicated
with the arrow.

S-E-A Matter No. 01.126198
IssueDate: December 1, 2022 13 of25

16 of 37
FILED: QUEENS COUNTY CLERK 12/01/2022 05:03 PM INDEX NO. 705531/2018
NYSCEF DOC. NO. 118 RECEIVED NYSCEF: 12/01/2022

11tastaardst ;
9

1School

Figure 5: Google streetview, looking toward the entrance to the buildingof Ms. Patterson's residence.

S-E-A Matter No. 01.126198
Issue Date: December 1, 2022 14 of25

17 of 37
FILED: QUEENS COUNTY CLERK 12/01/2022 05:03 PM INDEX NO. 705531/2018
NYSCEF DOC. NO. 118 RECEIVED NYSCEF: 12/01/2022

Figure 6:Right frontview of the Nissan Sentra. Note itsdamage spanned from the rightfront to the
leading edge of the rightfrontdoor. The rightfront tirehas been replaced with the spare tirewhen this
photograph was taken.

S-E-A Matter No. 01.126198
SÉ-A.
Issue Date:December 1, 2022 15 of25

18 of 37
FILED: QUEENS COUNTY CLERK 12/01/2022 05:03 PM INDEX NO. 705531/2018
NYSCEF DOC. NO. 118 RECEIVED NYSCEF: 12/01/2022

close. U Vie 8ht f t o e Nissan

S-E-A
issue
Matter
Date:
No. 01.126198
December 1, 2022 Of
&
19 of 37
FILED: QUEENS COUNTY CLERK 12/01/2022 05:03 PM INDEX NO. 705531/2018
NYSCEF DOC. NO. 118 RECEIVED NYSCEF: 12/01/2022

Figure 8: View of thedamage to the rightfrontquarter panel and the rightfront door ofthe Nissan
Sentra.

S-E-A Matter No. 01.126198
Issue Date:December 1, 2022 17 of25

20 of 37
FILED: QUEENS COUNTY CLERK 12/01/2022 05:03 PM INDEX NO. 705531/2018
NYSCEF DOC. NO. 118 RECEIVED NYSCEF: 12/01/2022

Figure 9:Photograph of the rearleftside ofthe Nissan Altima. Note the damage startedfrom the rear
bumper and extended to thetrailingedge of the leftreardoor.

S-E-A Matter No. 01.126198
SEA.
Issue Date: December 1, 2022 18 of25

21 of 37
FILED: QUEENS COUNTY CLERK 12/01/2022 05:03 PM INDEX NO. 705531/2018
NYSCEF DOC. NO. 118 RECEIVED NYSCEF: 12/01/2022

Figure 10:Close-up view of the left
rear of the NissanAltima. The arrow shows the beginning of the
contact on the leftsideof the rear bumper.

S-E-A Matter No. 01.126198
S A.
Issue Date: December 1, 2022 19 of25

22 of 37
FILED: QUEENS COUNTY CLERK 12/01/2022 05:03 PM INDEX NO. 705531/2018
NYSCEF DOC. NO. 118 RECEIVED NYSCEF: 12/01/2022

Figure 11 lose-up view of the damage to the edge
trailing of the leftreardoor of theNissan Altima.

S-E-A Matter No. 01.126198
SE A.
IssueDate: December 1, 2022 20 of 25

23 of 37
FILED: QUEENS COUNTY CLERK 12/01/2022 05:03 PM INDEX NO. 705531/2018
NYSCEF DOC. NO. 118 RECEIVED NYSCEF: 12/01/2022

rants M Hotels Thingsto do 6 Transit P Parking Pharmacies ATMs

010 Nissan Altima

Figure 12: Impact configuration between the Nissan Altima and the Nissan Sentra. The Nissan Altima is
stopped along the curb line.The Nissan Sentra engages with theNissan Altima ata slightangle tocause
the damage to both vehicles as seen accident.
in this Thisscenario can be ruled out.

S-E-A Matter No. 01.126198
g .A.
Issue Date: December 1, 2022 21 of 25

24 of 37
FILED: QUEENS COUNTY CLERK 12/01/2022 05:03 PM INDEX NO. 705531/2018
NYSCEF DOC. NO. 118 RECEIVED NYSCEF: 12/01/2022

rants sq Hotels (B Thingsto do Transit P Parking Pharmacies ATMs

10 Nissan Altima

Figure 13: Impact configuration between the Nissan Altima and the Nissan Sentra. The Nissan Altima is
stopped along the curb line.The Nissan Sentra is parallel
to the roadway. Under thisimpact
configuration,the Nissan Sentra would make contactwith other parked vehiclesbefore it
reaches the
Nissan Altima. Therefore, thisscenario can be ruled out.

S-E-A Matter No. 01.126198
Issue Date: December 1, 2022 22 of25

25 of 37
FILED: QUEENS COUNTY CLERK 12/01/2022 05:03 PM INDEX NO. 705531/2018
NYSCEF DOC. NO. 118 RECEIVED NYSCEF: 12/01/2022

rants Þq Hotels Thirgs to do@ Transit P Parking Pharmacies ] ATMs

.. . 010 NissanAltirna
USDGJ

Figure14: Impact configuration between the Nissan Altima and the Nissan Sentra. The Nissan Altima is
stopped paralleltothe roadway but into the travelportion ofthe nort

Case Info

Judge

Mojgan Lancman Track Judge’s New Case

Case No.

(Subscribe to View)

Document Filed Date

December 01, 2022

Case Filing Date

April 07, 2017

County

Parties

Amatul Wallace Plaintiff
BANGIYEV, ANNA Attorney for the Defendant
BANGIYEV, ANNA Attorney for the Defendants
BRAND, DAVID WILLIAM Attorney for the Defendant
Brickney Henry Defendant
CHERNY, ALEKSANDR SIMON Attorney for the Plaintiff
Cheryl Wallace Defendant
COSTIGAN, SEAN MICHAEL Attorney for the Defendant
DIAMOND, BETH MICHELLE Attorney for the Plaintiff
EAN HOLDINGS, LLC Defendant
ENTERPRISE HOLDINGS, INC. d/b/a ENTERPRISE RENT-A-CAR Defendant
ENTERPRISE LEASING COMPANY Defendant
PODOLSKY, STEVEN VYACHESLAV Attorney for the Plaintiff
ROSENBERG, PETER DAVID Attorney for the Defendant
TURI, MICHAEL PAUL Attorney for the Defendant
TURI, MICHAEL PAUL Attorney for the Defendants
ANNA BACON Attorneys for Defendants
MICHAEL FERRO Attorney
JONATHAN NOBLE Attorney
BENJAMIN SALK Attorneys for Plaintiffs
TODD ARBESFELD Attorneys for Plaintiffs
MICHAEL TURK Attorneys for Defendants

For full print and download access, please subscribe at https://www.trellis.law/.

Motion-Secondary: Amatul Wallace v. Brickney Henry, Ean Holdings, Llc, Enterprise Holdings, Inc. D/B/A Enterprise Rent-A-Car, Enterprise Leasing Company, Cheryl Wallace

Preview

Related Topics

Case Info

Parties