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FILED: SUFFOLK COUNTY CLERK 09/02/2022 02:47 PM INDEX NO. 611214/2015
NYSCEF DOC. NO. 991 RECEIVED NYSCEF: 09/02/2022
EXHIBIT NN
FILED: SUFFOLK COUNTY CLERK 09/02/2022 02:47 PM INDEX NO. 611214/2015
NYSCEF DOC. NO. 991 RECEIVED NYSCEF: 09/02/2022
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF SUFFOLK
_______________________________________________________________________x
ALICIA M. ARUNDEL; SUZANNE SCHULMAN, AS Index No.: 611214/15
ADMINISTRATRIX OF THE ESTATE OF BRITTNEY
M. SCHULMAN, DECEASED; OLGA LIPETS; MINDY
GRABINA, AS ADMINSTRATRIX OF THE ESTATE
OF AMY GRABINA, AND M1NDY GRABINA,
INDIVIDUALLY; STEVEN BARUCH, AS ADMINISTRATOR
OF THE ESTATE OF LAUREN BARUCH, DECEASED,
AND STEVEN BARUCH, INDIVIDUALLY; JOELLE
DIMONTE; MELISSA A. CRAI AND ARTHUR A. BELLI, JR.,
AS PARENT AND NATURAL GUARDIAN OF
STEPHANIE BELLI, DECEASED, AND AS THE
ADMINISTRATOR OF THE ESTATE OF STEPHANIE BELLI
Plaintiffs, AFFIDAVIT
-against-
ULTIMATE CLASS LIMOUSINE, INC., CARLOS P1NO,
ROMEO DIMON MARINE SERVICE, INC., STEVEN
ROMEO, TOWN OF SOUTHOLD and COUNTY OF
SUFFOLK, CABOT COACH BUILDERS, INC., d/b/a
1-5"
ROYALE LIMOUSINE and "XYZ COMPANIES
name being fictitious but intended to be the remanufacturers,
distributors and/or sellers of the 2007 Lincoln Town Car
stretch limousine involved in the collision,
Defendants.
_______________________________________________________________________Ç
STATE OF MASSACHUSETTS )
COUNTY OF pt/C£ff)( )
Stuart Brown, being duly sworn, deposes and says:
1. I am an engineer at Veryst Engineering, LLC, located at 47 Kearney
Road, Needham, Massachusetts. I am an expert in the field of material behavior and mechanical
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engineering and behavior as well as manufacturing processes including welding. I also have
expertise in failure analysis. A copy of curriculum vitae is attached as Exhibit A.
2. I have reviewed the Interrogatory Responses exchanged by each of the
Plaintiffs, the Complaints filed in this matter, the deposition transcripts of the surviving Plaintiffs
and Defendants STEVEN ROMEO and CARLOS PINO, and the police documentation including
photographs. I have conducted the inspections of the vehicles as well as the inspections and
testing of the limousine and its parts that were conducted.
3. I have calculated the energy absorbed by the limousine at the time of it
being struck by the Dodge Dakota truck. This was a severe collision with substantial
deformation of the limousine.
4. The vehicle had an intrusion bar to assist in the protection of the
occupants in low-speed collisions. The intrusion bar transfers the force applied to itto the metal
plates on its ends. Those plates then transfer the impact force into the vertical structural pillars
of the vehicle. The welds that are located at the structural pillars are present primarily to hold
the intrusion bar in place and allow the transfer of force.
5. The inspection of the bar and vehicle revealed that the intrusion bar on
the passenger side and the attachment plates next to it showed deformation in response to the
collision which indicates that they performed their intended function. As a result, the force was
transferred to the pillars and the vehicle frame as the primary load-bearing structures even given
the severity of the deformation to the pillars and frame. The deformation resistance and steel
strength of the intrusion bar installed by Cabot Coach Builders, Inc., was the same as the original
equipment in the vehicle before the vehicle was modified. Given the energy of the impact, the
intrusion bar as designed by the vehicle manufacturer would have contributed approximately 1%
of the energy absorption of this impact.
6. Any areas on the vehicle where the welds may not have had a complete
fusion had no effect on the outcome. The welds on the frame for the body mounts were intact.
The alleged defects in the welds to the door skin, door frames, rocker panels, etc. were a
consequence of the severity of the impact and not any defective design or manufacture.
7. The foregoing is set forth with a reasonable degree of engineering
certainty.
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Stuart Brown
Sworn to before me this _2_ day of August, 2022
Notary Public
CERTIFICATE OF CONF ORMITY OF ACKNOWLEDGEMENT UNDER
MASSACHUSETTS LAW
STATE OF MASSACHUSETTS )
COUNTY OF PR4 K )
I, , do hereby certify:
1. That I am a Notary Pub ic in the State of Massachusetts and am properly licensed. My
office is located at ,f A
EFaeary
&4qh ,
y¾EbdAn ! 4 ?A
My
2. I administered the oath and acknowledged the signature of Stuart Brown on the annexed
affidavit.
3. I hereby certify that this affidavit was taken in the manner prescribed by, and in
conformity with, the laws of the State of Massachusetts, which is the place where the
acknowledgement was taken.
In witness thereof, I have hereunder set my hand this _3__ day of August, 2022
TONI L. KNIGHTS
Notary Public
COMMONWEALTH OF MASSACHUSETTS
My Commission Expires
September 19. 2025
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Stuart B. Brown
Dr. Stuart Brown is the Managing Partner of Veryst Engineering® LLC, an engineering
consulting firm located in the Boston area. Veryst provides services in product design,
manufacturing processes, and failure analysis. Dr. Brown’s technical background includes
mechanical engineering and materials science. Specific topics of expertise include material
mechanics and behavior with subspecialties in plasticity, fracture, fatigue, elasticity,
viscoelasticity and viscoplasticity, creep, thixotropy, nonlinear behavior, and wear, subjects
that he taught to both graduate and undergraduate students at the Massachusetts Institute of
Technology (M.I.T.). He also performed research in nonlinear dynamics and simulation of
industrial processes using finite element analysis. He has experience with a wide variety of
materials encompassing metals, polymers, elastomers, composites, and ceramics, including
glass. He has consulted in manufacturing processes including metal and polymer
manufacturing processes, semi-solid materials, extrusion, powder metallurgy, drawing,
forging, welding, cold and hot rolling, using engineering analysis, computational modeling,
experimentation, and materials characterization. He has also extensive research and
development experience in thin films and microelectromechanical systems (MEMS).
Dr. Brown consults regularly within medical device, consumer products, manufacturing,
transportation, and energy industries. He also provides technical advice on consumer
products, electronic and electrical components, and industrial equipment.
Prior to founding Veryst Engineering, Dr. Brown was director of the Boston office of
Exponent, Inc. Before Exponent, Dr. Brown was on the faculty of the Department of
Materials Science and Engineering at the Massachusetts Institute of Technology. While at
M.I.T. he has performed research in the characterization of materials, metal and polymer
forming operations, welding, other industrial processes, thin films, and MEMS.
EDUCATION
Ph.D., Mechanical Engineering, Massachusetts Institute of Technology, 1987
M.B.A., Business Administration, Stanford Graduate School of Business, 1979
M.S., Mechanical Engineering, Stanford University, 1980
B.S., Mechanical Engineering, Washington University, 1977
A.B., English Literature, Washington University, 1977
Tau Beta Pi; Phi Beta Kappa; Pi Tau Sigma; Omicron Delta Kappa; Materials Science and
Engineering Graduate Teaching Award; NASA Certificate of Excellence
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SOCIETY MEMBERSHIPS
American Society of Mechanical Engineers; American Society of Metals; American Welding
Society; Society of Automotive Engineering, American Association for the Advancement of
Science; American Society for Testing and Materials (Committee F04 on Medical and
Surgical Materials and Devices), Society of Plastics Engineers.
PATENTS
US 2017 / 0340037 A1, Apparel Thermo - Regulatory System, Filed May 26 , 2017
Patent 8,217,523 Apparatus for in vivo energy harvesting, issued July 10, 2012
Patent 7,740,595 Tissue and Fluid Sampling Device, issued June 22, 2010
Patent 7,626,279 B2: Method and Apparatus for Energy Harvesting Using Rotational Energy
Storage and Release, issued December 1, 2009
Patent 7,605,482 B2: Method and Apparatus for Energy Harvesting Using Energy Storage
and Release, issued October 20, 2009
European Patent 2,102,498, Method and Apparatus for Energy Harvesting Using Energy
Storage and Release, issued September 23, 2009
Patent 7,505,244: Micro-switches For Downhole Use, issued March 17, 2009
European Patent 1545318: Tissue and Fluid Sampling Device, published February 13, 2008
Patent 7,116,542: Micro-Switches for Downhole Use, issued October 3, 2006
Patent 6,349,588: System and Method for Performing Bulge Testing of Films, Coatings
and/or Layers, issued February 26, 2002
Patent 6,321,594: System and Method for Performing Bulge Testing of Films, Coatings
and/or Layers, issued November 27, 2001
Patent 6,308,768: Apparatus and Method for Semi-Solid Material Production, Issued, October
30, 2001
European Patent 1,025,420 System and Method for Performing Bulge Testing of Films,
Coatings and/or Layers, issued August 9, 2000
Patent 6,050,138: System and Method for Performing Bulge Testing of Films, Coatings,
and/or Layers, issued April 18, 2000
European Patent 0,946,771 Apparatus and Method for Semi-Solid Material Production, issued
October 6, 1999
Patent 5,945,911: Footwear with Multilevel Activity Meter, issued August 31, 1999
European Patent 0,930,947 Apparatus and Method for Integrated Semi-Solid Material
Production and Casting, issued July 28, 1999
Patent 5,893,404: Method and Apparatus for Metal Solid Freeform Fabrication Utilizing
Partially Solidified Metal Slurry, issued April 13, 1999
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Patent 5,887,640: Apparatus and Method for Semi-Solid Material Production, issued March
30, 1999
Patent 5,881, 796: Apparatus and Method for Integrated Semi-solid Material Production and
Casting, issued March 16, 1999
European Patent 0,853,517 Method and Apparatus for Producing a Component from Partially
Solidified Metal Slurry, issued July 22, 1998
Patent 5,622,216: Method and Apparatus for Metal Solid Freeform Fabrication Utilizing
Partially Solidified Metal Slurry, issued Apr. 22, 1997
Patent 4,939,368: Polychromatic Optical Strain Gauge, issued July 3, 1990
PUBLICATIONS
“Additive Manufacturing Using Semi-Solids,” American Welding Society Education 2020
Virtual Summit, November 15-20, 2020 (with Patricio Mendez and Chris Rice).
“Techniques to Measure Impact Properties of Polymers,” Society of Plastics Engineers
Annual Technical Meeting, May 7-10, 2018 (with S. Teller, J. Bergstrom, and M. Oliver).
“High Strain Rate Testing of Reinforced Polyetherether Ketone,” Plastics Research Online,
Society of Plastic Engineers, 2016 (with Jorgen Bergstrom).
“Coupled Thermomechanical Forging Simulations and the Effect of Material Constitutive
Laws,” Conference Proceedings, Science in the Age of Experience, May 23-25, 2016,
Boston, Massachusetts.
“Child resistant closure performance aging study”, November 13-19, 2015 American Society
of Mechanical Engineers International Mechanical Engineering Congress, Houston, Texas
(with R. McCarthy).
“Simulation Solves the Mystery Behind an Elevator Accident” COMSOL News 2015, p. 34-
35. (with N. Elabbasi and M Hancock).
“High Strain Rate Testing of Glass Fiber Reinforced PEEK,” Society of Plastics Engineers
Annual Technical Meeting, March 23, 2015. (with J. Bergstrom, G Freeburn, D.
Anderson, and E. Ananny).
High Strain Rate Testing and Modeling of Polymers for Impact Simulations, 13th
International LS-DYNA Users Conference, June 8-10, 2014, Dearborn, Michigan (w. J.
Bergstrom, D. Anderson, D. Quinn, E. Schmitt, and S. Chow).
“Modeling of Reinforced Elastomeric Hoses,” Simulia Conference, May 19-22, 2014, (with
N. Elabbasi and J. Bergstrom).
“High Strain Rate Testing of Polymers for Impact Simulations,” Society of Plastics
Engineers, ANTEC 2014, April 28-30 (with J. Bergstrom, D. Quinn, E. Schmitt, and S.
Chow).
“Conjugate Thermal Analysis of LED Light Bulb,” NASA Tech Briefs, 2013 (with N.
Elabbasi and M. Heiss).
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“Modeling of Laminar Flow Static Mixers”, COMSOL News, 2012, p. 64-65, (with N.
Elabbasi, X. Liu, M. Vidal, and M. Pappalardo).
“Harvest of Motion,” Mechanical Engineering Magazine, Vol. 130, No. 9, September 2008
(with B. Hendrickson).
“Motion Energy Harvesting Using Catch-And-Release Mechanism,” Proceedings of ASME
Energy Sustainability 2008, August 10-14, 2008 (with B. Hendrickson).
“Modeling of Fluoropolymer Deformation,” Fluoropolymers Applications in Chemical
Processing Industries, Chapter 11, Sina Ebnesajjad (ed.), 2004 (with J. Bergstrom).
“FRP Flumes: Repeated Impact,” Composite Manufacturing Magazine, April 2004 (with J.
Bergstrom).
“Putting it in Scale,” Mechanical Engineering Design Magazine, February 2004 (with P.
Mendez).
“Surface Topography Evolution and Fatigue Fracture of Polysilicon,” Journal of Materials
Science, Vol. 38, No. 23, October 2003 (with S. Allameh, P. Shrotriya, A. Butterwick, and
W. Soboyejo).
“Reliability of Microelectromechanical Systems (MEMS),” Mechanical Engineering
Magazine, October 2003.
“Surface Topography Evolution and Fatigue Fracture in Polysilicon MEMS Structures,”
Journal of Microelectromechanical Systems, Vol. 12, No. 3, June 2003 (with S. Allameh,
P. Shrotriya, A. Butterwick, and W.S. Soboyejo).
“Large Strain Time-and Temperature-Dependent Modeling of PTFE,” Computational Fluid
and Solid Mechanics, Elsevier Science, Ltd., June 2003 (with L.B. Hilbert).
“Comments on ‘Solid Freeform Fabrication by Extrusion and Deposition of Semi-Solid
Alloys,” Journal of Materials Science Letters, Vol. 22, pp. 1047–1049, 2003 (with P.
Mendez and C. Rice).
“Fatigue Damage Evolution in Silicon MEMS Structures for Micromechanical Applications,”
Experimental Mechanics, 2003 (with P. Shrotriya, S. Allameh, Z. Suo and W.O.
Soboyejo).
“Fatigue Damage Evolution in Silicon Films for Micromechanical Applications,”
Experimental Mechanics Vol. 43 No. 3, pp 289-302, 2003 (with P. Shrotriya, S. Allameh,
Z. Suo, and W.O. Soboyejo).
“Mechanisms of Fatigue in Polysilicon MEMS Structures,” Materials Research Symposium,
Vol. 687, pp. 29–34, 2002 (with P. Shrotriya, S. Allameh, A. Butterwick, and W.O.
Soboyejo).
“On the Micromechanisms of Fatigue Crack Nucleation and Propagation in Polysilicon,” J.
Microelectromechanical Systems, 2002 (with S.M. Allameh, P. Shrotriya, A. Butterwick,
N. Yao, and W.O. Soboyejo).
“Fatigue Damage Evolution in Silicon Films for Micromechanical Applications,” Proceedings
of Fatigue 2002, Proceedings of the 8th International Fatigue Congress, Stockholm,
Sweden, A. Blom (ed.), Vol. 5, pp. 3395–3400, 2002, EMAS, Cradley Heath, West
Midlands, United Kingdom (with P. Shrotriya, S. Allameh, Z. Suo, and W.O. Soboyejo).
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“Joining Using Semisolid Metals,” Welding Journal, Vol. 81, No. 9, pp. 181s–187s, 2002
(with P. Mendez and C. Rice).
“High-Cycle Fatigue of Single-Crystal Silicon thin Films,” Journal of
Microelectromechanical Systems, Vol. 11, No. 1, p. 91, February 2002; Vol. 10, p. 593,
2001 (with C. Muhlstein and R. Ritchie).
“High-Cycle Fatigue of Single-Crystal Silicon Thin Films,” Journal of
Microelectromechanical Systems, Vol. 10, No. 4, pp. 593–600, December 2001 (with C.
Muhlstein).
“High-Cycle Fatigue and Durability of Polycrystalline Silicon Thin Films in Ambient Air,”
Sensors and Actuators A-Physical, Vol. 94, No. 3, pp. 177–188, November 20, 2001 (with
C. Muhlstein and R. Ritchie).
“Surface Topography Evolution and Fatigue Fracture of Polysilicon,” Mechanics of
Materials, (special issue dedicated to proceeding of ASME 2001), Annual Meeting, NY,
2002 (with S.M. Allameh, P. Shrotriya, A. Butterwick, N. Yao, and W.O. Soboyejo).
“Analysis of the Stem-Sleeve Interface in a Modular Titanium Alloy Femoral Component for
Total Hip Replacement,” Vol. 198-1, pp. 41–68, 2001 (with S. Kurtz (Reprint), S.
Srivastav, K. Dwyer, and J. Ochoa).
“Mechanical Properties of Structural Films,” Standard Technical Publication 1413, American
Society for Testing and Materials, 2001 (with C. Muhlstein).
“On the Evolution of Surface Morphology of Polysilicon MEMS Structures During Fatigue,”
Proceedings, MRS Symposium of MEMS Devices III, H. Kahn et al. (eds.), 2001 (with S.
Allameh, B. Gally, and W.O. Soboyejo).
“Surface Topology and Fatigue in Si MEMS Structures,” Mechanical Properties of Structural
Films, STP 1413, C. Muhlstein and S. Brown, (eds.), American Society for Testing and
Materials, West Conshohocken, PA, pp. 3–16, 2001 (with S.M. Allameh, B. Gally, and
W.O. Soboyejo).
“Metal Solid Freeform Fabrication Using Semi-Solid Slurries,” Journal of Metals, Vol. 52,
No. 12, pp. 31–33, December 2000 (with C. Rice and P. Mendez).
“Micromechanisms of Fatigue in Polysilicon MEMS Structures,” Proceedings, Materials
Research Society Symposium, Materials Science of Microelectromechanical Systems
(MEMS) Devices III, November 26–28, 2000 (with S.M. Allameh, P. Shrotriya, B. Gally,
and W.O. Soboyejo).
“On the Evolution of Surface Morphology of Polysilicon MEMS Structures During Fatigue,”
Proceedings, Materials Research Society Symposium, Materials Science of
Microelectromechanical Systems (MEMS) Devices III, November 26–28, 2000 (with
S.M. Allameh, B. Gally, and W.O. Soboyejo).
“MEMS Raise Testing Issues From The Beginning To The End Of The Design Cycle”
Electronic Design, Vol. 48, No. 15, 2000, pp 95-104 (with B. Gally, R. Grace, and P.
Mukai).
“High-Cycle Fatigue of Polycrystalline Silicon Thin Films in Laboratory Air” MRS
Proceedings, Vol 657, 2000 (with C. Muhlstein, R. Ritchie).
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“Reliability of Mechatronic Silicon MEMS Structures,” Proceedings, 7th Mechatronics
Forum International Conference, Atlanta, GA, C. Ume, (ed.), Elsevier. Paper No. 41.03,
2000 (with W.O. Soboyejo, S. Allameh, B. Gally, D. Freeman, and A.G. Evans).
“Surface Topology and Fatigue in Si MEMS Structures,” Proceedings, American Society for
Testing and Materials, Symposium on the Mechanical Properties of Structural Films,
November 15–16, 2000 (with S.M. Allameh, B. Gally, and W.O. Soboyejo).
“Wafer Scale Testing of MEMS Structural Films,” Proceedings, Materials Research Society
Symposium, Thin Films—Stresses and Mechanical Properties VIII, pp. 195–200,
November 29–December 3, 1999 (with B. Gally, C. Abnet, and C. Chui).
“Investigation of Wear of Microelectromechanical Contacts,” Proceedings, Materials
Research Society Symposium, Materials Science of Microelectromechanical Systems
(MEMS) Devices II, pp. 117–122, November 29–December 1, 1999 (with B. Gally and C.
Abnet).
“Subcritical Crack Growth in Silicon MEMS,” IEEE Journal of Microelectromechanical
Systems, Vol. 8, No. 3, September 1999 (with W. Van Arsdell).
“Testing of MEMS Material Properties and Stability” IEEE Systems Readiness Technology
Conference, pp. 161-162, August, 1998 (with C. Muhlstein, C. Chui and C. Abnet).
“Microelectromechanical Structures for Materials Research,” Proceedings, Materials
Research Society Symposium, Vol. 518, pp. 57–65, 1998 (editor with J. Gilbert, H.
Guckel, R. Howe, G. Johnson, P. Krulevitch, and C. Muhlstein).
“MEMS testing techniques for long-term stability” presented at the 1998 ASME International
Mechanical Engineering Congress and Exposition: November 15-20, 1998, Anaheim,
California, Vol. 84, pp 145 (with C. Muhlstein, C. Abnet and C. Chui).
“Round-Robin Tests of Modulus and Strength of Polysilicon,” Proceedings, Materials
Research Society Symposium, Microelectromechanical Structures for Materials Research,
Vol. 518, pp. 57–65, April 1998 (with W. Sharpe, G. Johnson, and W. Knauss).
“Modeling of Selected SFF Process Limits,” Proceedings, Solid Freeform Fabrication
Symposium, pp. 299–306, August 8–10, 1994 (with P. Mendez).
“Crack Growth in Polysilicon MEMS”, ASME, DSC-Vol 66, 1998 (with W. Arsdell).
“Survey of MEMS Failure Mechanisms,” Proceedings, International Reliability Physics
Symposium, IEEE 1998 Tutorial Notes, pp. 4b.1–4b.17, March–April 1998 (with C.
Muhlstein).
“Reliability and Fatigue Testing of MEMS,” Tribology Issues and Opportunities in MEMS,
NSF/AFOSR/ASME Workshop, p. 80, November 1997 (with C. Muhlstein).
“Materials Reliability in MEMS Devices,” Proceedings, 1997 International Conference on
Solid-State Sensors and Actuators, Transducers 97 Chicago, June 1997 (with W. Van
Arsdell and C. Muhlstein).
“On-Board Truck Computers and Accident Risk,” SERA, Vol. 6, pp. 1–6, 1996 (with T.J.
Ayres, A. Donelson, V.M. Bjelajac, and W. Van Selow).
“Semi-Solid Processing: New Advances in Net Shape Forming,” Light Metals, pp. 763–766,
W. Hale (ed.), TMS Publishers, 1996.
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“Reliability and Long Term Stability of MEMS,” Digest IEEE/LEOS 1996 Summer Topical
Meetings, August 1996 (with E.W. Jansen).
“Process Planning for Aluminum Tubes: An Engineering––Operations Perspective,”
Operations Research, Vol. 44, No. 1, pp. 7–20, January–February 1996 (with A.
Balakrishnan).
“Interdisciplinary Industry-University Collaboration: Lessons from an Operations
Improvement Project,” Interfaces 25, pp. 12–41, September–October 1995 (with A.
Balakrishnan, D. Dunlap, and R. Pahl).
“Mold filling of semisolid metal slurries” Journal of Materials Engineering and Performance,
Vol. 4 No. 4 pp 486-493, August 1995 (with O. Ilegbusi).
“Shear Deformation of High Solid Fraction (>0.60) Semi-Solid Sn-Pb under Various
Structures,” Materials Science & Engineering, pp. 112–122, February 1995 (with C.L.
Martin, D. Favier, and M. Suéry).
“Crystal Plasticity Simulations of Thermal Stresses in Thin-Film Aluminum Interconnects,”
Journal of Applied Physics, Vol. 77, No. 2, pp. 598–606, January 1995 (with G.L. Povirk
and R. Mohan).
“Powder Forging,” Encyclopedia of Materials, M. Flemings (ed.), Pergamon Press, New
York, NY, 1994.
“Semi-Solid Processing,” Encyclopedia of Materials, M. Flemings (ed.), Pergamon Press,
New York, NY, 1994.
“Constitutive Modeling and Characterization of the Flow Behavior of Semi-Solid Metal Alloy
Slurries: Part 1, The Flow Response,” Acta Metallurgica et Materialia, Vol. 42, 1994
(with P. Kumar and C. Martin).
“Constitutive Modeling and Characterization of the Flow Behavior of Semi-Solid Metal Alloy
Slurries: Part II, Structural Evolution under Shear Deformation,” Acta Metallurgica et
Materialia, Vol. 42, 1994 (with C. Martin and P. Kumar).
“Yield Behavior of Metal Powder Assemblages,” Journal of the Mechanics and Physics of
Solids, Vol. 42, No. 3, 1994 (with G. Abou-Chedid).
“Critical Experiments Used to Determine Flow Relations for Rate-Dependent Metal
Deformation,” International Journal of Plasticity, Vol. 10, 1994 (with V. Dave).
“Long-Term Stability of Nickel in Resonant Micro-Mechanical Devices,” Proceedings,
Symposium on Stresses and Mechanical Properties in Thin Films, Materials Research
Society Spring Meeting, San Francisco, CA, 1993 (with G.L. Povirk and J. Bernstein).
“Rezoning and Dynamic Substructuring Techniques in FEM Simulations of Welding
Processes,” ASME Journal of Engineering for Industry, November 1993 (with H. Song).
“Simulation of Solid Freeform Fabrication,” Proceedings, Solid Free form Fabrication
Symposium, Austin, TX, August 1993.
“Constitutive Behavior of Powders During Compaction,” Proceedings, Powder Metallurgy
World Congress, Kyoto, Japan, July 1993 (with G. Abou-Chedid).
“Micromechanical Fatigue Testing,” Experimental Mechanics, pp. 81–90, June 1993 (with J.
Connally).
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“Shear Thickening Flow Behavior of Semi-Solid Slurries,” Metallurgical Transactions A,
Vol. 24A, pp. 1107–1116, May 1993 (with P. Kumar and C. Martin).
“Evaluation of Yield Functions Due to Powder Cohesion,” Proceedings, International
Conference on Powder Metallurgy and Particulate Materials, Nashville, TN, May 1993
(with G. Abou-Chedid).
“Test Machine and Control System Interactions in the Evaluation of Rate-Dependent Metal
Flow,” Journal of Engineering Materials and Technology, Vol. 115, pp. 179–186, April
1993 (with V. Dave).
“Measurement of Slow Crack Growth in Silicon and Nickel Micromechanical Devices,”
Proceedings, IEEE/ASME Workshop on Micro Electro Mechanical Systems, Fort
Lauderdale, FL, February 1993 (with G. Povirk and J. Connally).
“Appropriate Yield Functions for Metal Powder Compaction,” Scripta Metallurgica and
Materialia, Vol. 28, No. 1, January 1993 (with G. Abou-Chedid).
“Net-shape Forming via Semi-Solid Processing,” Advanced Materials and Processes, Vol.
143 No. 1, pp 36-40, 1993 (with M. Flemings).
“Material Parameter Estimation for Modern Constitutive Equation” Presented at the 1993
ASME Winter Annual Meeting, New Orleans, Louisiana, November 28-December 3,
1993 (MD (Series), V. 43. (with Bertram and Freed).
“Semi-Solid Processing,” Advanced Materials and Processes, Vol. 143, No. 1, pp. 36–40,
January 1993.
“Constitutive Behavior of Semi-Solid Metal Slurries,” Proceedings, Materials Research
Society (MRS) Symposium on the Flow and Microstructure of Dense Suspensions,
Boston, MA, December 1992 (with P. Kumar and C. Martin).
“Finite Element Simulation of Welding of Large Structures,” Journal of Engineering for
Industry, Vol. 114, No. 4, pp. 441–451, November 1992 (with H. Song).
“Application of Invariant Set Theory to Dynamic Recrystallization Constitutive Behavior,”
Metallurgical Transactions A, Vol. 23A, pp. 2091–2103, August 1992 (with J. Wlassich).
“Proceedings of Second International Conference on the Processing of Semi-Solid Alloys and
Composites,” ed., Cambridge, MA, M.I.T. Press, June 1992 (with M. Flemings).
“On the Mechanical Behavior of Metal Powder Compaction,” Proceedings, MPIF/APMI
World Congress on Powder Metallurgy and Particulate Materials, San Francisco, CA,
June 1992 (with G. Abou-Chedid).
“Flow Behavior of Semi-Solid Materials,” Proceedings, Second International Conference on
the Semi-Solid Processing of Alloys and Composites, Cambridge, MA, pp. 250–262, June
1992 (with P. Kumar and C. Martin).
“Process Planning for Metal Forming Operations: An Integrated Engineering-Operations
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“Exploiting and Characterizing the Fundamental Rheology of Semi-Solid Materials,”
Proceedings, Second International Conference on the Semi-Solid Processing of Alloys and
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“Constitutive Response of Semi-Solid Slurries,” Proceedings, Symposium on the Nature and
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FILED: SUFFOLK COUNTY CLERK 09/02/2022 02:47 PM INDEX NO. 611214/2015 NYSCEF DOC. NO. 991 RECEIVED NYSCEF: 09/02/2022 EXHIBIT NN FILED: SUFFOLK COUNTY CLERK 09/02/2022 02:47 PM INDEX NO. 611214/2015 NYSCEF DOC. NO. 991 RECEIVED NYSCEF: 09/02/2022 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF SUFFOLK _______________________________________________________________________x ALICIA M. ARUNDEL; SUZANNE SCHULMAN, AS Index No.: 611214/15 ADMINISTRATRIX OF THE ESTATE OF BRITTNEY M. SCHULMAN, DECEASED; OLGA LIPETS; MINDY GRABINA, AS ADMINSTRATRIX OF THE ESTATE OF AMY GRABINA, AND M1NDY GRABINA, INDIVIDUALLY; STEVEN BARUCH, AS ADMINISTRATOR OF THE ESTATE OF LAUREN BARUCH, DECEASED, AND STEVEN BARUCH, INDIVIDUALLY; JOELLE DIMONTE; MELISSA A. CRAI AND ARTHUR A. BELLI, JR., AS PARENT AND NATURAL GUARDIAN OF STEPHANIE BELLI, DECEASED, AND AS THE ADMINISTRATOR OF THE ESTATE OF STEPHANIE BELLI Plaintiffs, AFFIDAVIT -against- ULTIMATE CLASS LIMOUSINE, INC., CARLOS P1NO, ROMEO DIMON MARINE SERVICE, INC., STEVEN ROMEO, TOWN OF SOUTHOLD and COUNTY OF SUFFOLK, CABOT COACH BUILDERS, INC., d/b/a 1-5" ROYALE LIMOUSINE and "XYZ COMPANIES name being fictitious but intended to be the remanufacturers, distributors and/or sellers of the 2007 Lincoln Town Car stretch limousine involved in the collision, Defendants. _______________________________________________________________________Ç STATE OF MASSACHUSETTS ) COUNTY OF pt/C£ff)( ) Stuart Brown, being duly sworn, deposes and says: 1. I am an engineer at Veryst Engineering, LLC, located at 47 Kearney Road, Needham, Massachusetts. I am an expert in the field of material behavior and mechanical FILED: SUFFOLK COUNTY CLERK 09/02/2022 02:47 PM INDEX NO. 611214/2015 NYSCEF DOC. NO. 991 RECEIVED NYSCEF: 09/02/2022 engineering and behavior as well as manufacturing processes including welding. I also have expertise in failure analysis. A copy of curriculum vitae is attached as Exhibit A. 2. I have reviewed the Interrogatory Responses exchanged by each of the Plaintiffs, the Complaints filed in this matter, the deposition transcripts of the surviving Plaintiffs and Defendants STEVEN ROMEO and CARLOS PINO, and the police documentation including photographs. I have conducted the inspections of the vehicles as well as the inspections and testing of the limousine and its parts that were conducted. 3. I have calculated the energy absorbed by the limousine at the time of it being struck by the Dodge Dakota truck. This was a severe collision with substantial deformation of the limousine. 4. The vehicle had an intrusion bar to assist in the protection of the occupants in low-speed collisions. The intrusion bar transfers the force applied to itto the metal plates on its ends. Those plates then transfer the impact force into the vertical structural pillars of the vehicle. The welds that are located at the structural pillars are present primarily to hold the intrusion bar in place and allow the transfer of force. 5. The inspection of the bar and vehicle revealed that the intrusion bar on the passenger side and the attachment plates next to it showed deformation in response to the collision which indicates that they performed their intended function. As a result, the force was transferred to the pillars and the vehicle frame as the primary load-bearing structures even given the severity of the deformation to the pillars and frame. The deformation resistance and steel strength of the intrusion bar installed by Cabot Coach Builders, Inc., was the same as the original equipment in the vehicle before the vehicle was modified. Given the energy of the impact, the intrusion bar as designed by the vehicle manufacturer would have contributed approximately 1% of the energy absorption of this impact. 6. Any areas on the vehicle where the welds may not have had a complete fusion had no effect on the outcome. The welds on the frame for the body mounts were intact. The alleged defects in the welds to the door skin, door frames, rocker panels, etc. were a consequence of the severity of the impact and not any defective design or manufacture. 7. The foregoing is set forth with a reasonable degree of engineering certainty. FILED: SUFFOLK COUNTY CLERK 09/02/2022 02:47 PM INDEX NO. 611214/2015 NYSCEF DOC. NO. 991 RECEIVED NYSCEF: 09/02/2022 Stuart Brown Sworn to before me this _2_ day of August, 2022 Notary Public CERTIFICATE OF CONF ORMITY OF ACKNOWLEDGEMENT UNDER MASSACHUSETTS LAW STATE OF MASSACHUSETTS ) COUNTY OF PR4 K ) I, , do hereby certify: 1. That I am a Notary Pub ic in the State of Massachusetts and am properly licensed. My office is located at ,f A EFaeary &4qh , y¾EbdAn ! 4 ?A My 2. I administered the oath and acknowledged the signature of Stuart Brown on the annexed affidavit. 3. I hereby certify that this affidavit was taken in the manner prescribed by, and in conformity with, the laws of the State of Massachusetts, which is the place where the acknowledgement was taken. In witness thereof, I have hereunder set my hand this _3__ day of August, 2022 TONI L. KNIGHTS Notary Public COMMONWEALTH OF MASSACHUSETTS My Commission Expires September 19. 2025 FILED: SUFFOLK COUNTY CLERK 09/02/2022 02:47 PM INDEX NO. 611214/2015 NYSCEF DOC. NO. 991 RECEIVED NYSCEF: 09/02/2022 Stuart B. Brown Dr. Stuart Brown is the Managing Partner of Veryst Engineering® LLC, an engineering consulting firm located in the Boston area. Veryst provides services in product design, manufacturing processes, and failure analysis. Dr. Brown’s technical background includes mechanical engineering and materials science. Specific topics of expertise include material mechanics and behavior with subspecialties in plasticity, fracture, fatigue, elasticity, viscoelasticity and viscoplasticity, creep, thixotropy, nonlinear behavior, and wear, subjects that he taught to both graduate and undergraduate students at the Massachusetts Institute of Technology (M.I.T.). He also performed research in nonlinear dynamics and simulation of industrial processes using finite element analysis. He has experience with a wide variety of materials encompassing metals, polymers, elastomers, composites, and ceramics, including glass. He has consulted in manufacturing processes including metal and polymer manufacturing processes, semi-solid materials, extrusion, powder metallurgy, drawing, forging, welding, cold and hot rolling, using engineering analysis, computational modeling, experimentation, and materials characterization. He has also extensive research and development experience in thin films and microelectromechanical systems (MEMS). Dr. Brown consults regularly within medical device, consumer products, manufacturing, transportation, and energy industries. He also provides technical advice on consumer products, electronic and electrical components, and industrial equipment. Prior to founding Veryst Engineering, Dr. Brown was director of the Boston office of Exponent, Inc. Before Exponent, Dr. Brown was on the faculty of the Department of Materials Science and Engineering at the Massachusetts Institute of Technology. While at M.I.T. he has performed research in the characterization of materials, metal and polymer forming operations, welding, other industrial processes, thin films, and MEMS. EDUCATION Ph.D., Mechanical Engineering, Massachusetts Institute of Technology, 1987 M.B.A., Business Administration, Stanford Graduate School of Business, 1979 M.S., Mechanical Engineering, Stanford University, 1980 B.S., Mechanical Engineering, Washington University, 1977 A.B., English Literature, Washington University, 1977 Tau Beta Pi; Phi Beta Kappa; Pi Tau Sigma; Omicron Delta Kappa; Materials Science and Engineering Graduate Teaching Award; NASA Certificate of Excellence FILED: SUFFOLK COUNTY CLERK 09/02/2022 02:47 PM INDEX NO. 611214/2015 NYSCEF DOC. NO. 991 RECEIVED NYSCEF: 09/02/2022 SOCIETY MEMBERSHIPS American Society of Mechanical Engineers; American Society of Metals; American Welding Society; Society of Automotive Engineering, American Association for the Advancement of Science; American Society for Testing and Materials (Committee F04 on Medical and Surgical Materials and Devices), Society of Plastics Engineers. PATENTS US 2017 / 0340037 A1, Apparel Thermo - Regulatory System, Filed May 26 , 2017 Patent 8,217,523 Apparatus for in vivo energy harvesting, issued July 10, 2012 Patent 7,740,595 Tissue and Fluid Sampling Device, issued June 22, 2010 Patent 7,626,279 B2: Method and Apparatus for Energy Harvesting Using Rotational Energy Storage and Release, issued December 1, 2009 Patent 7,605,482 B2: Method and Apparatus for Energy Harvesting Using Energy Storage and Release, issued October 20, 2009 European Patent 2,102,498, Method and Apparatus for Energy Harvesting Using Energy Storage and Release, issued September 23, 2009 Patent 7,505,244: Micro-switches For Downhole Use, issued March 17, 2009 European Patent 1545318: Tissue and Fluid Sampling Device, published February 13, 2008 Patent 7,116,542: Micro-Switches for Downhole Use, issued October 3, 2006 Patent 6,349,588: System and Method for Performing Bulge Testing of Films, Coatings and/or Layers, issued February 26, 2002 Patent 6,321,594: System and Method for Performing Bulge Testing of Films, Coatings and/or Layers, issued November 27, 2001 Patent 6,308,768: Apparatus and Method for Semi-Solid Material Production, Issued, October 30, 2001 European Patent 1,025,420 System and Method for Performing Bulge Testing of Films, Coatings and/or Layers, issued August 9, 2000 Patent 6,050,138: System and Method for Performing Bulge Testing of Films, Coatings, and/or Layers, issued April 18, 2000 European Patent 0,946,771 Apparatus and Method for Semi-Solid Material Production, issued October 6, 1999 Patent 5,945,911: Footwear with Multilevel Activity Meter, issued August 31, 1999 European Patent 0,930,947 Apparatus and Method for Integrated Semi-Solid Material Production and Casting, issued July 28, 1999 Patent 5,893,404: Method and Apparatus for Metal Solid Freeform Fabrication Utilizing Partially Solidified Metal Slurry, issued April 13, 1999 2 FILED: SUFFOLK COUNTY CLERK 09/02/2022 02:47 PM INDEX NO. 611214/2015 NYSCEF DOC. NO. 991 RECEIVED NYSCEF: 09/02/2022 Patent 5,887,640: Apparatus and Method for Semi-Solid Material Production, issued March 30, 1999 Patent 5,881, 796: Apparatus and Method for Integrated Semi-solid Material Production and Casting, issued March 16, 1999 European Patent 0,853,517 Method and Apparatus for Producing a Component from Partially Solidified Metal Slurry, issued July 22, 1998 Patent 5,622,216: Method and Apparatus for Metal Solid Freeform Fabrication Utilizing Partially Solidified Metal Slurry, issued Apr. 22, 1997 Patent 4,939,368: Polychromatic Optical Strain Gauge, issued July 3, 1990 PUBLICATIONS “Additive Manufacturing Using Semi-Solids,” American Welding Society Education 2020 Virtual Summit, November 15-20, 2020 (with Patricio Mendez and Chris Rice). “Techniques to Measure Impact Properties of Polymers,” Society of Plastics Engineers Annual Technical Meeting, May 7-10, 2018 (with S. Teller, J. Bergstrom, and M. Oliver). “High Strain Rate Testing of Reinforced Polyetherether Ketone,” Plastics Research Online, Society of Plastic Engineers, 2016 (with Jorgen Bergstrom). “Coupled Thermomechanical Forging Simulations and the Effect of Material Constitutive Laws,” Conference Proceedings, Science in the Age of Experience, May 23-25, 2016, Boston, Massachusetts. “Child resistant closure performance aging study”, November 13-19, 2015 American Society of Mechanical Engineers International Mechanical Engineering Congress, Houston, Texas (with R. McCarthy). “Simulation Solves the Mystery Behind an Elevator Accident” COMSOL News 2015, p. 34- 35. (with N. Elabbasi and M Hancock). “High Strain Rate Testing of Glass Fiber Reinforced PEEK,” Society of Plastics Engineers Annual Technical Meeting, March 23, 2015. (with J. Bergstrom, G Freeburn, D. Anderson, and E. Ananny). High Strain Rate Testing and Modeling of Polymers for Impact Simulations, 13th International LS-DYNA Users Conference, June 8-10, 2014, Dearborn, Michigan (w. J. Bergstrom, D. Anderson, D. Quinn, E. Schmitt, and S. Chow). “Modeling of Reinforced Elastomeric Hoses,” Simulia Conference, May 19-22, 2014, (with N. Elabbasi and J. Bergstrom). “High Strain Rate Testing of Polymers for Impact Simulations,” Society of Plastics Engineers, ANTEC 2014, April 28-30 (with J. Bergstrom, D. Quinn, E. Schmitt, and S. Chow). “Conjugate Thermal Analysis of LED Light Bulb,” NASA Tech Briefs, 2013 (with N. Elabbasi and M. Heiss). 3 FILED: SUFFOLK COUNTY CLERK 09/02/2022 02:47 PM INDEX NO. 611214/2015 NYSCEF DOC. NO. 991 RECEIVED NYSCEF: 09/02/2022 “Modeling of Laminar Flow Static Mixers”, COMSOL News, 2012, p. 64-65, (with N. Elabbasi, X. Liu, M. Vidal, and M. Pappalardo). “Harvest of Motion,” Mechanical Engineering Magazine, Vol. 130, No. 9, September 2008 (with B. Hendrickson). “Motion Energy Harvesting Using Catch-And-Release Mechanism,” Proceedings of ASME Energy Sustainability 2008, August 10-14, 2008 (with B. Hendrickson). “Modeling of Fluoropolymer Deformation,” Fluoropolymers Applications in Chemical Processing Industries, Chapter 11, Sina Ebnesajjad (ed.), 2004 (with J. Bergstrom). “FRP Flumes: Repeated Impact,” Composite Manufacturing Magazine, April 2004 (with J. Bergstrom). “Putting it in Scale,” Mechanical Engineering Design Magazine, February 2004 (with P. Mendez). “Surface Topography Evolution and Fatigue Fracture of Polysilicon,” Journal of Materials Science, Vol. 38, No. 23, October 2003 (with S. Allameh, P. Shrotriya, A. Butterwick, and W. Soboyejo). “Reliability of Microelectromechanical Systems (MEMS),” Mechanical Engineering Magazine, October 2003. “Surface Topography Evolution and Fatigue Fracture in Polysilicon MEMS Structures,” Journal of Microelectromechanical Systems, Vol. 12, No. 3, June 2003 (with S. Allameh, P. Shrotriya, A. Butterwick, and W.S. Soboyejo). “Large Strain Time-and Temperature-Dependent Modeling of PTFE,” Computational Fluid and Solid Mechanics, Elsevier Science, Ltd., June 2003 (with L.B. Hilbert). “Comments on ‘Solid Freeform Fabrication by Extrusion and Deposition of Semi-Solid Alloys,” Journal of Materials Science Letters, Vol. 22, pp. 1047–1049, 2003 (with P. Mendez and C. Rice). “Fatigue Damage Evolution in Silicon MEMS Structures for Micromechanical Applications,” Experimental Mechanics, 2003 (with P. Shrotriya, S. Allameh, Z. Suo and W.O. Soboyejo). “Fatigue Damage Evolution in Silicon Films for Micromechanical Applications,” Experimental Mechanics Vol. 43 No. 3, pp 289-302, 2003 (with P. Shrotriya, S. Allameh, Z. Suo, and W.O. Soboyejo). “Mechanisms of Fatigue in Polysilicon MEMS Structures,” Materials Research Symposium, Vol. 687, pp. 29–34, 2002 (with P. Shrotriya, S. Allameh, A. Butterwick, and W.O. Soboyejo). “On the Micromechanisms of Fatigue Crack Nucleation and Propagation in Polysilicon,” J. Microelectromechanical Systems, 2002 (with S.M. Allameh, P. Shrotriya, A. Butterwick, N. Yao, and W.O. Soboyejo). “Fatigue Damage Evolution in Silicon Films for Micromechanical Applications,” Proceedings of Fatigue 2002, Proceedings of the 8th International Fatigue Congress, Stockholm, Sweden, A. Blom (ed.), Vol. 5, pp. 3395–3400, 2002, EMAS, Cradley Heath, West Midlands, United Kingdom (with P. Shrotriya, S. Allameh, Z. Suo, and W.O. Soboyejo). 4 FILED: SUFFOLK COUNTY CLERK 09/02/2022 02:47 PM INDEX NO. 611214/2015 NYSCEF DOC. NO. 991 RECEIVED NYSCEF: 09/02/2022 “Joining Using Semisolid Metals,” Welding Journal, Vol. 81, No. 9, pp. 181s–187s, 2002 (with P. Mendez and C. Rice). “High-Cycle Fatigue of Single-Crystal Silicon thin Films,” Journal of Microelectromechanical Systems, Vol. 11, No. 1, p. 91, February 2002; Vol. 10, p. 593, 2001 (with C. Muhlstein and R. Ritchie). “High-Cycle Fatigue of Single-Crystal Silicon Thin Films,” Journal of Microelectromechanical Systems, Vol. 10, No. 4, pp. 593–600, December 2001 (with C. Muhlstein). “High-Cycle Fatigue and Durability of Polycrystalline Silicon Thin Films in Ambient Air,” Sensors and Actuators A-Physical, Vol. 94, No. 3, pp. 177–188, November 20, 2001 (with C. Muhlstein and R. Ritchie). “Surface Topography Evolution and Fatigue Fracture of Polysilicon,” Mechanics of Materials, (special issue dedicated to proceeding of ASME 2001), Annual Meeting, NY, 2002 (with S.M. Allameh, P. Shrotriya, A. Butterwick, N. Yao, and W.O. Soboyejo). “Analysis of the Stem-Sleeve Interface in a Modular Titanium Alloy Femoral Component for Total Hip Replacement,” Vol. 198-1, pp. 41–68, 2001 (with S. Kurtz (Reprint), S. Srivastav, K. Dwyer, and J. Ochoa). “Mechanical Properties of Structural Films,” Standard Technical Publication 1413, American Society for Testing and Materials, 2001 (with C. Muhlstein). “On the Evolution of Surface Morphology of Polysilicon MEMS Structures During Fatigue,” Proceedings, MRS Symposium of MEMS Devices III, H. Kahn et al. (eds.), 2001 (with S. Allameh, B. Gally, and W.O. Soboyejo). “Surface Topology and Fatigue in Si MEMS Structures,” Mechanical Properties of Structural Films, STP 1413, C. Muhlstein and S. Brown, (eds.), American Society for Testing and Materials, West Conshohocken, PA, pp. 3–16, 2001 (with S.M. Allameh, B. Gally, and W.O. Soboyejo). “Metal Solid Freeform Fabrication Using Semi-Solid Slurries,” Journal of Metals, Vol. 52, No. 12, pp. 31–33, December 2000 (with C. Rice and P. Mendez). “Micromechanisms of Fatigue in Polysilicon MEMS Structures,” Proceedings, Materials Research Society Symposium, Materials Science of Microelectromechanical Systems (MEMS) Devices III, November 26–28, 2000 (with S.M. Allameh, P. Shrotriya, B. Gally, and W.O. Soboyejo). “On the Evolution of Surface Morphology of Polysilicon MEMS Structures During Fatigue,” Proceedings, Materials Research Society Symposium, Materials Science of Microelectromechanical Systems (MEMS) Devices III, November 26–28, 2000 (with S.M. Allameh, B. Gally, and W.O. Soboyejo). “MEMS Raise Testing Issues From The Beginning To The End Of The Design Cycle” Electronic Design, Vol. 48, No. 15, 2000, pp 95-104 (with B. Gally, R. Grace, and P. Mukai). “High-Cycle Fatigue of Polycrystalline Silicon Thin Films in Laboratory Air” MRS Proceedings, Vol 657, 2000 (with C. Muhlstein, R. Ritchie). 5 FILED: SUFFOLK COUNTY CLERK 09/02/2022 02:47 PM INDEX NO. 611214/2015 NYSCEF DOC. NO. 991 RECEIVED NYSCEF: 09/02/2022 “Reliability of Mechatronic Silicon MEMS Structures,” Proceedings, 7th Mechatronics Forum International Conference, Atlanta, GA, C. Ume, (ed.), Elsevier. Paper No. 41.03, 2000 (with W.O. Soboyejo, S. Allameh, B. Gally, D. Freeman, and A.G. Evans). “Surface Topology and Fatigue in Si MEMS Structures,” Proceedings, American Society for Testing and Materials, Symposium on the Mechanical Properties of Structural Films, November 15–16, 2000 (with S.M. Allameh, B. Gally, and W.O. Soboyejo). “Wafer Scale Testing of MEMS Structural Films,” Proceedings, Materials Research Society Symposium, Thin Films—Stresses and Mechanical Properties VIII, pp. 195–200, November 29–December 3, 1999 (with B. Gally, C. Abnet, and C. Chui). “Investigation of Wear of Microelectromechanical Contacts,” Proceedings, Materials Research Society Symposium, Materials Science of Microelectromechanical Systems (MEMS) Devices II, pp. 117–122, November 29–December 1, 1999 (with B. Gally and C. Abnet). “Subcritical Crack Growth in Silicon MEMS,” IEEE Journal of Microelectromechanical Systems, Vol. 8, No. 3, September 1999 (with W. Van Arsdell). “Testing of MEMS Material Properties and Stability” IEEE Systems Readiness Technology Conference, pp. 161-162, August, 1998 (with C. Muhlstein, C. Chui and C. Abnet). “Microelectromechanical Structures for Materials Research,” Proceedings, Materials Research Society Symposium, Vol. 518, pp. 57–65, 1998 (editor with J. Gilbert, H. Guckel, R. Howe, G. Johnson, P. Krulevitch, and C. Muhlstein). “MEMS testing techniques for long-term stability” presented at the 1998 ASME International Mechanical Engineering Congress and Exposition: November 15-20, 1998, Anaheim, California, Vol. 84, pp 145 (with C. Muhlstein, C. Abnet and C. Chui). “Round-Robin Tests of Modulus and Strength of Polysilicon,” Proceedings, Materials Research Society Symposium, Microelectromechanical Structures for Materials Research, Vol. 518, pp. 57–65, April 1998 (with W. Sharpe, G. Johnson, and W. Knauss). “Modeling of Selected SFF Process Limits,” Proceedings, Solid Freeform Fabrication Symposium, pp. 299–306, August 8–10, 1994 (with P. Mendez). “Crack Growth in Polysilicon MEMS”, ASME, DSC-Vol 66, 1998 (with W. Arsdell). “Survey of MEMS Failure Mechanisms,” Proceedings, International Reliability Physics Symposium, IEEE 1998 Tutorial Notes, pp. 4b.1–4b.17, March–April 1998 (with C. Muhlstein). “Reliability and Fatigue Testing of MEMS,” Tribology Issues and Opportunities in MEMS, NSF/AFOSR/ASME Workshop, p. 80, November 1997 (with C. Muhlstein). “Materials Reliability in MEMS Devices,” Proceedings, 1997 International Conference on Solid-State Sensors and Actuators, Transducers 97 Chicago, June 1997 (with W. Van Arsdell and C. Muhlstein). “On-Board Truck Computers and Accident Risk,” SERA, Vol. 6, pp. 1–6, 1996 (with T.J. Ayres, A. Donelson, V.M. Bjelajac, and W. Van Selow). “Semi-Solid Processing: New Advances in Net Shape Forming,” Light Metals, pp. 763–766, W. Hale (ed.), TMS Publishers, 1996. 6 FILED: SUFFOLK COUNTY CLERK 09/02/2022 02:47 PM INDEX NO. 611214/2015 NYSCEF DOC. NO. 991 RECEIVED NYSCEF: 09/02/2022 “Reliability and Long Term Stability of MEMS,” Digest IEEE/LEOS 1996 Summer Topical Meetings, August 1996 (with E.W. Jansen). “Process Planning for Aluminum Tubes: An Engineering––Operations Perspective,” Operations Research, Vol. 44, No. 1, pp. 7–20, January–February 1996 (with A. Balakrishnan). “Interdisciplinary Industry-University Collaboration: Lessons from an Operations Improvement Project,” Interfaces 25, pp. 12–41, September–October 1995 (with A. Balakrishnan, D. Dunlap, and R. Pahl). “Mold filling of semisolid metal slurries” Journal of Materials Engineering and Performance, Vol. 4 No. 4 pp 486-493, August 1995 (with O. Ilegbusi). “Shear Deformation of High Solid Fraction (>0.60) Semi-Solid Sn-Pb under Various Structures,” Materials Science & Engineering, pp. 112–122, February 1995 (with C.L. Martin, D. Favier, and M. 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