Preview
FILED: SUFFOLK COUNTY CLERK 11/28/2022 05:31 PM INDEX NO. 611214/2015
NYSCEF DOC. NO. 1172 RECEIVED NYSCEF: 11/28/2022
Exhibit “8”
FILED: SUFFOLK COUNTY CLERK 11/28/2022 05:31 PM INDEX NO. 611214/2015
NYSCEF DOC. NO. 1172 RECEIVED NYSCEF: 11/28/2022
FILED: SUFFOLK COUNTY CLERK 11/28/2022 05:31 PM INDEX NO. 611214/2015
NYSCEF DOC. NO. 1172 RECEIVED NYSCEF: 11/28/2022
R. A. HOFFMANN ENGINEERING, P.C. October 17, 2022
3544-RPT-01
Page 1
TABLE OF CONTENTS
Section Page
1.0 INTRODUCTION ................................................................................................................................. 2
2.0 BACKGROUND ................................................................................................................................... 3
2.1 Construction of the Limousine .......................................................................................................... 3
2.2 Details of Accident and Focus of Metallurgical Evaluation ............................................................... 4
3.0 PROFESSIONAL EXPERIENCE ............................................................................................................. 4
4.0 WORK PERFORMED........................................................................................................................... 5
4.1 Documents Reviewed ....................................................................................................................... 5
4.2 List of Inspections, Examinations Testing ......................................................................................... 5
5.0 INSPECTIONS, EXAMINATIONS AND TESTING................................................................................... 6
5.1 Group Inspection of Limousine – October 22, 2019 ......................................................................... 6
5.2 Nondestructive Inspection of GJ Exhibits 119z and 120z – February 14, 2020 ................................ 7
5.3 Group Lab Exam at LPI, Inc.– June 22, August 31 and September 27-28, 2021 ............................... 8
5.3.1 Identification of Components from Limousine ...................................................................... 8
5.3.2 Initial Visual Examination – As-Received................................................................................ 9
5.3.3 Removal of Samples from Limousine and Additional Sectioning........................................... 9
5.3.4 Visual Examination and Stereomicroscopy of Samples ....................................................... 10
5.3.5 Dimensional Measurements ................................................................................................ 13
5.3.6 Tensile Testing of Anti-Intrusion Beams .............................................................................. 12
5.3.7 Chemical Analyses ................................................................................................................ 14
5.3.8 Optical Microscopy and Microhardness Measurements ..................................................... 14
6.0 SUMMARY AND DISCUSSION .......................................................................................................... 17
7.0 CONCLUSIONS ................................................................................................................................. 19
FIGURES
APPENDIX A
APPENDIX B
FILED: SUFFOLK COUNTY CLERK 11/28/2022 05:31 PM INDEX NO. 611214/2015
NYSCEF DOC. NO. 1172 RECEIVED NYSCEF: 11/28/2022
R. A. HOFFMANN ENGINEERING, P.C. October 17, 2022
3544-RPT-01
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1.0 INTRODUCTION
I have been retained as a metallurgical engineering expert by the plaintiffs representing the Estate
of Stephanie Belli in this matter. Specifically, I was requested to conduct a metallurgical
evaluation of the structural welding associated with the conversion of a 2007 Lincoln Town Car to
a limousine.
On July 18, 2015, the subject 2007 Lincoln Town Car limousine was hit in the passenger-side
midsection by 2005 Dodge Dakota truck. Because of the collision, significant intrusion of the
truck into the passenger compartment of the limousine occurred. This intrusion resulted in
interaction with the occupants within the passenger compartment.
FILED: SUFFOLK COUNTY CLERK 11/28/2022 05:31 PM INDEX NO. 611214/2015
NYSCEF DOC. NO. 1172 RECEIVED NYSCEF: 11/28/2022
R. A. HOFFMANN ENGINEERING, P.C. October 17, 2022
3544-RPT-01
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2.0 BACKGROUND
2.1 Construction of the Limousine
The original unaltered 2007 Lincoln Town Car was modified immediately after production, in
March 2007, to increase its length for the purposes of increasing the passenger capacity (modified
to a limousine).
Anti-intrusion beams (or bars) are installed in the modified portion of the vehicle body for added
resistance to intrusion during side impact. One anti-intrusion beam is installed on each side
(passenger-side and driver-side) of the limousine.
On the passenger-side of the limousine, a fifth (after-market) door is also added as part of the
modification. The fifth door is located immediately to the rear of the original passenger-side front
door. An anti-intrusion beam is also installed inside of the fifth door. The original vehicle doors
(front and rear on both driver and passenger sides) are also manufactured with an internal anti-
intrusion beam.
The anti-intrusion beam added to the limousine body on the passenger-side of the vehicle was
approximately 52 inches in length. The front end of the passenger-side anti-intrusion beam was
attached to “C” pillar. The passenger-side “C” pillar was located at the rear end of the fifth door
and was installed as part of the vehicle modification. The rear end of the passenger-side anti-
intrusion beam was attached to “D” pillar. The passenger-side “D” pillar was installed during the
original manufacturing process of the unaltered 2007 Lincoln Town Car. Both ends of the
passenger-side anti-intrusion beam were welded to carbon steel plates (or mounting brackets)
and the anti-intrusion beam brackets were welded to a separate bracket attached to the pillars.
The stretch portion of the driver-side of the subject limousine did not have an additional door
added. Only the original front and rear doors were present on the driver-side. On the driver-
side, the anti-intrusion beam added to the stretched portion of the body spanned from the “B”
pillar on its front end to ”D” pillar on its rear end. The driver side anti-intrusion beam was also
welded to “C” pillar, located between “B” and “D” pillars. The “B” and “D” pillar ends of the driver-
side anti-intrusion beam were attached using a bracket design similar to that used on the
passenger side. The driver-side anti-intrusion beam was attached to the “C” pillar at approximately
the mid-span position. The attachment at this “C” pillar location utilized a different design than
“B” and “D” pillars.
The fifth door and rocker panels in the stretched portion of the limousine were fabricated utilizing
welds also.
FILED: SUFFOLK COUNTY CLERK 11/28/2022 05:31 PM INDEX NO. 611214/2015
NYSCEF DOC. NO. 1172 RECEIVED NYSCEF: 11/28/2022
R. A. HOFFMANN ENGINEERING, P.C. October 17, 2022
3544-RPT-01
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2.2 Details of Accident and Focus of Metallurgical Evaluation
The limousine was impacted on its passenger-side during the accident. The forces associated
with the impact were applied primarily to the area of the fifth (mid-compartment) door, “C” pillar,
and the intermediate body panel. The front end of the passenger-side anti-intrusion beam
(welded to “C” pillar) was discovered disconnected from the pillar immediately after the accident.
During emergency response efforts, the rear end (“D” pillars) of the anti-intrusion beams on both
the passenger and driver sides became separated from their attachments. Both the passenger-
side and driver-side anti-intrusion beams were cut into two sections during the emergency
response efforts to facilitate access to the rear passenger compartment of the limousine.
My metallurgical evaluation of the subject limousine was focused on the welds associated with
the attachment plates/brackets used to join the anti-intrusion beams to the respective pillars on
passenger and drives sides of the vehicle. The mechanical properties and dimensions of the
anti-intrusion beams were also evaluated.
3.0 PROFESSIONAL EXPERIENCE
My experience as an expert metallurgical engineer is summarized below.
• I am a metallurgical engineer with 33 years of experience performing failure analysis of
metal components associated with building services, industrial environments and structural
applications. My experience includes performing nondestructive and destructive examinations of
welds used for structural and pressure-containing components. I also have expertise in
analyzing the effects of various failure mechanisms (such as fatigue, stress overload, impact
loading, corrosion, etc.) on carbon steel and a variety of other metals/alloys. A complete copy of
my curriculum vitae is annexed to this report as Appendix A.
• I received a Bachelor of Science in Metallurgical Engineering from the University of Notre
Dame (1989). I am a licensed Professional Engineer (P.E.) and a Certified Weld Inspector
(CWI). I am a member of American Society for Metals International (ASM), American Society of
Mechanical Engineers (ASME), American Welding Society (AWS), Association for Materials
Protection and Performance (AMPP) and the National Society of Professional Engineers (NSPE).
• I am a Senior Metallurgical Engineer of R.A. Hoffmann Engineering, P.C. d/b/a Hoffmann
& Feige, a materials engineering consulting firm which services a diversified group of utilities (gas,
LNG and power), building owners and managers, manufacturers, fabricators and design
engineering firms.
• During my professional career, I have experience identifying and analyzing failure
mechanisms, such as failures of welds in carbon steel components due to defects, poor
workmanship, overload, fatigue cracking, embrittlement, stress corrosion cracking, general
corrosion, pitting corrosion and various other failure mechanisms. I have performed failure
analyses on a variety of carbon steel industrial products, including structural components, tubing,
piping, heavy equipment and fasteners.
FILED: SUFFOLK COUNTY CLERK 11/28/2022 05:31 PM INDEX NO. 611214/2015
NYSCEF DOC. NO. 1172 RECEIVED NYSCEF: 11/28/2022
R. A. HOFFMANN ENGINEERING, P.C. October 17, 2022
3544-RPT-01
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4.0 WORK PERFORMED
4.1 Documents Reviewed
A list of the documents that I have reviewed regarding this matter are listed below.
• Interrogatory Responses exchanged by each of the Plaintiffs
• Complaints filed
• Deposition transcripts of the surviving Plaintiffs and Defendants, Steven Romeo
and Carlos Pino
• Police documentation including photographs
• Cabot Motion for Summary Judgement including Affidavits associated with
Cabot Motion for Summary Judgement
• Dimon Motion for Summary Judgement including Affidavits associated with
Dimon Motion for Summary Judgement
• Town of Southold Motion for Summary Judgement including Affidavits
associated with Town of Southold Motion for Summary Judgement
• Expert Disclosures
• 2003 and 2008 Builder’s Guides for the Qualified Vehicle Modifiers (QVM)
Program for Ford Motor Company
• Grand Jury Report, CPL 190.85(1)(C), dated September 20, 2016
4.2 List of Inspections, Examinations Testing
As part of the metallurgical evaluation of the subject Limousine, I have performed the following
inspections and participated in laboratory testing and examinations as detailed below.
• Group inspection of the subject limousine on October 22, 2019 at
the Suffolk County Police Department (SCPD) impound yard in Westhampton,
New York.
• Nondestructive visual inspection of Grand Jury (GJ) Exhibits 119Z and 120Z
at the Law Offices of Andrea G. Sawyers in Melville, NY on February 14, 2020.
• Participation in group lab exam of the subject limousine at LPI, Inc. (LPI, a
SOCOTEC Company) in Brooklyn, NY on June 22, 2021, August 31, 2021 and
September 27-28, 2021.
5.0 INSPECTIONS, EXAMINATIONS AND TESTING
5.1 Group Inspection of Limousine – October 22, 2019
On October 22, 2019, I participated in a group inspection of the subject limousine at the SCPD
impound yard in Westhampton, NY. This inspection was a nondestructive inspection with no
alteration of the evidence permitted. The storage of the subject limousine at the SCPD impound
yard began a short time after the accident in 2015.
FILED: SUFFOLK COUNTY CLERK 11/28/2022 05:31 PM INDEX NO. 611214/2015
NYSCEF DOC. NO. 1172 RECEIVED NYSCEF: 11/28/2022
R. A. HOFFMANN ENGINEERING, P.C. October 17, 2022
3544-RPT-01
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The focus of my inspection was on the welds associated with the joining of the following
components from the limousine as listed below.
• Anti-intrusion beam added to the stretch portion of the limousine’s body (during
modification) on its driver-side.
• “C” and D” pillars on the driver-side of limousine.
The anti-intrusion beam that was added to the passenger-side of the vehicle during the vehicle
modification was not present at this inspection. Additionally, passenger-side “C” and “D pillars
were inaccessible due to the excessive damage that had occurred to the limousine during the
accident.
The driver- side anti-intrusion beam was also cut with a “jaws-of-life” tool by emergency response
personnel at the time of the accident. It was reported that the rear section of the driver-side anti-
intrusion separated at its weld attaching the associated bracket to “D” pillar during the emergency
response efforts.
The portion of the weld on the plate (bracket) attached to the driver-side anti-intrusion beam (at
“D” pillar) spanned approximately 1-¾” (the width of the plate (bracket) was approximately 2”).
The weld appeared to have fractured along its length. The weld, including its fracture surface,
was covered with a layer of corrosion product (rust) and/or debris, therefore the fracture surface
features were not evident. This weld was an approximate ¼” fillet weld
The mating half of the fractured weld on “D” pillar was also covered with a layer of rust and/or
debris and could not be inspected in detail during this inspection. The “D” pillar had been
separated from the frame of the limousine during emergency response efforts along with the
driver-side rear door.
The brackets and welds that attached the driver-side anti-intrusion beam to “C” pillar utilized a
more robust design than at “D” pillar. There was no separation of the welds associated with the
driver-side anti-intrusion bar to “C” pillar.
The weld attachments associated with the brackets and “B” pillar at the front end of the driver-
side anti-intrusion beam were not accessible during this inspection.
The anti-intrusion beam on the driver’-side had a tubular geometry with an approximate outside
diameter of 1-1/4” (measured with a tape measure).
Figures 1 through 7 illustrate the conditions observed during the October 22, 2019 inspection.
FILED: SUFFOLK COUNTY CLERK 11/28/2022 05:31 PM INDEX NO. 611214/2015
NYSCEF DOC. NO. 1172 RECEIVED NYSCEF: 11/28/2022
R. A. HOFFMANN ENGINEERING, P.C. October 17, 2022
3544-RPT-01
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5.2 Nondestructive Inspection of GJ Exhibits 119z and 120z – February 14, 2020
The passenger-side anti-intrusion beam (with brackets attached) was submitted as GJ Exhibits
119z and 120z as part of the Grand Jury investigation involving the subject accident. GJ Exhibits
119z and 120z had been attached to “D” and “C” pillars, respectively, prior to the accident. A
visual inspection was performed of GJ Exhibits 119z and 120z at the Law Offices of Andrea G.
Sawyers in Melville, NY on February 14, 2020. No other components from the limousine were
included in this inspection. Figures 8 and 9 provide overall views of GF Exhibit 119z and 120z
during this inspection.
The outside diameter (OD) of the anti-intrusion beam (on both GJ Exhibits 119z and 120z) was
approximately 1-1/4” (measured with dial calipers). The length of the anti-intrusion beam
associated with GJ Exhibit 119z was approximately 32” and the length of the anti-intrusion beam
associated with GJ Exhibit 120z was approximately 20”.
A fillet weld was observed on the end of the bracket associated with GJ Exhibit 119z that would
have attached to “D” pillar. The length of this weld was approximately 1-¾” and the weld
appeared to have fractured along its entire length. This weld, including its fracture surface and
the end of the bracket, were covered with a layer of corrosion product (rust) and/or debris which
again prohibited detailed examination of these areas. The conditions observed on GJ Exhibit
119z are illustrated in Figure 10.
On GJ Exhibit 120z, a fillet weld was observed on the end of the bracket which would have
attached to “C” pillar. The length of this fillet weld was approximately ¼”. This weld had also
fractured. Along most of the remaining width of this bracket, substantial weld metal was not
observed, but it appeared that a shallow fracture surface was present indicating that separation
of weld metal from the surface of the bracket had occurred. Again, the weld and surrounding
surface on the bracket were covered with a layer of corrosion product (rust) and/or debris which
prohibited detailed examination of these surfaces. The conditions observed on GJ Exhibit 120z
are illustrated in Figure 11.
5.3 Group Lab Exam at LPI, Inc.– June 22, August 31 and September 27-28, 2021
A joint destructive lab examination of the subject limousine was conducted at LPI, Inc. on June
22, August 21 and September 27-28, 2021. The limousine was transported from the SCPD
impound yard to LPI, Inc. in Brooklyn, NY for the destructive examination.
The test protocol used as a guideline for the joint lab exam is provided in Appendix B.
The destructive examination of the limousine consisted of the following.
• Visual examination of the limousine and all individual components of interest.
• Removal of samples from limousine and additional sectioning of components from
limousine to allow for inspection and examination.
• Dimensional measurements.
• Optical stereomicroscopy.
FILED: SUFFOLK COUNTY CLERK 11/28/2022 05:31 PM INDEX NO. 611214/2015
NYSCEF DOC. NO. 1172 RECEIVED NYSCEF: 11/28/2022
R. A. HOFFMANN ENGINEERING, P.C. October 17, 2022
3544-RPT-01
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• Optical metallographic examination.
• Chemical Analysis
• Tensile Testing
• Hardness Testing
5.3.1 Identification of Components from Limousine
The components to be removed from limousine were selected prior to the group lab exam. For
the purposes of the destructive testing and examination, the components of interest were
assigned a sample number designation. The sample designations are provided below in Table
1.
TABLE 1 – Sample Identification
Sample GJ Side of Limousine
Description
No.1 Exhibit (Passenger or Driver)
Section of anti-intrusion beam that was attached to “D” pillar.
1 120z Passenger
Approximately 20 inches in length.
Section of anti-intrusion beam that was attached to “C” pillar.
2 119z Passenger
Approximately 32 inches in length.
3 NA Driver Section of anti-intrusion beam that was attached to “D” pillar.
4 NA Passenger Rocker panel between “C” and “D” pillars.
5 NA Passenger Sections of “C” pillar.
6 NA Passenger Sections of “D” pillar.
7 NA Driver Sections of “D” pillar.
8 NA Driver Section of anti-intrusion beam attached to “B” and “C” pillars.
9 NA Passenger Floor mounts in stretch portion.
10 NA Passenger Roof rail in stretch portion.
11 NA Passenger Fifth (after-market) door
12 NA Driver Rear door
Note 1: Samples 1-4, 12 were removed from the limousine prior to the group lab exam at LPI. Samples 5-
11 were removed from limousine during the group lab exam at LPI.
5.3.2 Initial Visual Examination – As-Received
The limousine was delivered to LPI, Inc. unaltered from its condition observed at the SCPD
impound lot on October 22, 2019. Samples 1 and 2, GJ Exhibits 120z and 119z, respectively,
were brought to LPI, Inc. separately for the joint lab exam. Overall photos of the limousine in its
as-received condition at LPI are provided in Figure 12.
5.3.3 Removal of Samples from Limousine and Additional Sectioning
As indicated in Table 1, Samples 1-4, 12 had been removed or separated from the limousine prior
to the group lab exam at LPI and Samples 5-11 were removed from the limousine during the
group lab exam. The sectioning was performed with slow-speed portable and table band saws
and abrasive cut-off wheels. The removal process for the samples is illustrated in Figure 13.
FILED: SUFFOLK COUNTY CLERK 11/28/2022 05:31 PM INDEX NO. 611214/2015
NYSCEF DOC. NO. 1172 RECEIVED NYSCEF: 11/28/2022
R. A. HOFFMANN ENGINEERING, P.C. October 17, 2022
3544-RPT-01
Page 9
5.3.4 Visual Examination and Stereomicroscopy of Samples
The visual examination and stereomicroscopy of the samples are summarized below.
Samples 1 and 6
The bracket welded to the end of the passenger-side anti-intrusion beam for Sample 1 had been
welded to a bracket on the section of “D” pillar for Sample 6. Detailed visual examination of the
weld joint associated the joining of Samples 1 and 6 confirmed that this attachment used a fillet
weld. The joint design was essentially a T-joint with the Sample 1 bracket positioned
approximately 1/16” from the end of the bracket for Sample 6. The weld joint incorporated a
portion of the sheet metal from the pillar. Figures 14 and 15 illustrate the design of this weld joint
before and after sectioning to remove subsegments for further examination.
The length of the fillet weld was confirmed to be approximately 1-¾” (the width of the bracket on
Sample 1 was approximately 2.0”). The weld had fractured (broken) along its entire length. As
observed during the visual inspection on February 14, 2020, the fracture surfaces associated with
the failed weld were covered with a layer of corrosion product (rust)/debris. Therefore, the
morphology of the fracture surface was not apparent. The mating fracture surfaces on the weld
for these samples was gently cleaned in a solution of methanol, however only minimal removal of
the corrosion product (rust) occurred.
Cross sections of subsegments removed from Samples 1 and 6 at the weld attachment between
the passenger-side anti-intrusion beam bracket and “D” pillar (rear of vehicle) were mounted
together to examine the weld quality on macroscopic and microscopic scales.
Figures 16 and 17 provided a macroscopic view of the cross section prior to mounting and
stereomicroscopic images (in the etched condition) illustrating the condition of this weld. This
weld was a fillet weld that joined the brackets from the anti-intrusion beam and “D” pillar. The
ends of a portion of the sheet metal for “D” pillar were also attached to this fillet weld. The fillet
weld leg along the anti-intrusion beam bracket was approximately 0.177” (4.501 mm) long and
the fillet weld leg along the bracket on “D” pillar was approximately 0.229” (5.820 mm) long. The
fillet weld had fractured near the weld attachment to the anti-intrusion beam bracket where the
fillet weld had a throat dimension of approximately 0.079” (2.0 mm).
A portion of the weld fusion line between the weld metal and “D” pillar exhibited Lack of Fusion
(LOF). This condition is a defect associated with the weld/weld process.
Samples 2 and 5
As with Samples 1 and 6, the bracket welded to the end of the passenger-side anti-intrusion beam
for Sample 2 had been welded to a bracket on a section of “C” pillar for Sample 5. Detailed visual
examination of the weld joint associated the joining of Samples 2 and 5 confirmed that this
attachment also used a filletweld. Again, the joint design was essentially a T-joint with the
Sample 2 bracket positioned approximately 1/16” from the end of the bracket for Sample 5. The
weld joint incorporated a portion of the sheet metal from the pillar. Figure 18 illustrates the design
of this weld joint with a cross sectional view prior sectioning with the location for sectioning marked
(in yellow) on the samples.
FILED: SUFFOLK COUNTY CLERK 11/28/2022 05:31 PM INDEX NO. 611214/2015
NYSCEF DOC. NO. 1172 RECEIVED NYSCEF: 11/28/2022
R. A. HOFFMANN ENGINEERING, P.C. October 17, 2022
3544-RPT-01
Page 10
Weld metal was observed over approximately a ¼” length of the approximate 2.0” width of the
bracket associated with Sample 2. The edge of the bracket for Sample 5 (“C” pillar) that was
attached to the Sample 2 bracket (anti-intrusion beam) had weld metal present along its complete
width. This indicated that weld metal was applied along the length of this joint, but fusion of the
weld to the bracket (plate) for the anti-intrusion beam only occurred over approximately 13% of
the bracket width. In other words, there was LOF over approximately 87% of the fillet weld on
the Sample 2 bracket interface. Complete fusion of the fillet weld on the bracket for Sample 5
side of the joint (“C” pillar) was evident.
Cross sections of subsegments removed from Samples 2 and 5 at the weld attachment between
the passenger-side anti-intrusion beam bracket and “C” pillar (near of fifth door) were mounted
together to examine the weld quality at macroscopic and microscopic scales.
Figures 19 and 20 illustrate the condition of the weld joint associated with Samples 2 and 5 with
a macroscopic view (Figure 19) and microscopic views with use of a stereomicroscope (Figures
19 and 20). The photomacrograph shows this cross section in the unetched condition and the
stereomicroscopic images show the cross section in the etched condition. Figure 19
(stereomicroscopic image) provides identification labels of each of the components for this weld
joint. Figure 20 shows the dimensions of the weld. This weld was a fillet weld that joined the
brackets from the anti-intrusion beam and “C” pillar. The ends of a portion of the sheet metal for
“C” pillar was also attached to this fillet weld.
The fillet weld along anti-intrusion beam bracket had separated at the fusion line for this cross
section due to LOF (as indicated in Fig. 20). The fillet weld leg along the bracket on “C” pillar
was approximately 0.223” (5.666) mm) long.
Samples 3 and 7
The bracket welded to the end of the driver-side anti-intrusion beam for Sample 3 had been
welded to a bracket on the section of “D” pillar for Sample 7. The comprehensive visual
examination of the weld joint associated the joining of Samples 3 and 7 confirmed that this
attachment used a fillet weld also. Again, the joint design utilized a T-joint configuration with the
Sample 3 bracket positioned approximately 1/16” from the end of the bracket for Sample 7. As
with the other anti-intrusion beam/pillar connection, the weld joint incorporated a portion of the
sheet metal from the pillar. Figure 21 illustrates the design of this weld joint with a cross sectional
view prior sectioning with the location for sectioning marked (in black) on the samples.
Cross sections of subsegments removed from Samples 3 and 7 at the weld attachment between
the driver-side anti-intrusion beam bracket and “D” pillar were mounted together to examine the
weld quality at macroscopic and microscopic scales.
Figures 22 illustrates the condition of the weld joint associated with Samples 3 and 7 with a
macroscopic view in the unetched condition and in the etched condition using a
stereomicroscope. The stereomicrograph in Figure 22 (bottom image) provides identification
labels of each of the components for this weld joint. Figure 23 shows the dimensions of the weld.
This weld was a filletweld that joined the brackets from the anti-intrusion beam and “D” pillar.
The end of a portion of the sheet metal for “D” pillar was also attached to this fillet weld.
The length of the fillet weld was confirmed to be approximately 1-¾” (the width of the bracket on
FILED: SUFFOLK COUNTY CLERK 11/28/2022 05:31 PM INDEX NO. 611214/2015
NYSCEF DOC. NO. 1172 RECEIVED NYSCEF: 11/28/2022
R. A. HOFFMANN ENGINEERING, P.C. October 17, 2022
3544-RPT-01
Page 11
Sample 3 was approximately 2”). The weld had fractured (broken) along its entire length. As
observed during the visual inspection on October 22, 2019, the fracture surfaces associated with
the failed weld were covered with a layer of corrosion product (rust)/debris. Therefore, the
morphology of the fracture surface was not apparent. The mating fracture surfaces on the weld
for these samples was gently cleaned in a solution of methanol, however only minimal removal of
the corrosion product (rust) occurred.
The fillet weld leg along the anti-intrusion beam bracket was approximately 0.145” (3.678 mm)
long and the fillet weld leg along the bracket on “D” pillar was approximately 0.172” (4.374 mm)
long. The fillet weld had fractured near the weld attachment to the anti-intrusion beam bracket
where the fillet weld had a throat dimension of approximately 0.137” (3.469 mm).
Sample 8
Sample 8 included all the driver-side anti-intrusion beam except for the portion associated with
Sample 3. The welded attachments at the drive-side “B” and “C” pillars along with a portion of
each respective pillar was also removed from the limousine for closer examination. Overall views
of this weld attachment after the subsegment had been removed for further examination are
provided in Figure 24.
The weld joint between the front-end bracket on the anti-intrusion beam and “B” pillar of Sample
8 had a similar configuration to that of Samples 1/6 and 2/5. The entire 2” width of the bracket
attached to the anti-intrusion beam was welded to the bracket and pillar on the pillar side of the
joint. This weld remained intact.
The weld connections between the anti-intrusion beam and “C” pillar on the driver-side
incorporated a different design than that used for all the end connections between the anti-
intrusion beams and the associated pillar. At this location, a rectangular tube was welded on
one end to the anti-intrusion beam and on the other end to “C” pillar. Fillet welds were also used
for attachment on these joints as well. The sheet metal associated with “C” pillar exhibited
tearing, however the weld connection to the pillar had not failed. The weld connection of the
tubular bracket to the anti-intrusion beam was intact.
Figures 25 and 26 illustrate the condition of the weld joint associated with Sample 8 with a
macroscopic view (Figure 25) and microscopic views with use of a stereomicroscope (Figures 25
and 26). The photomacrograph shows this cross section in the unetched condition and the
stereomicroscopic images show the cross section in the etched condition. Figure 25
(stereomicroscopic image) provides identification labels of each of the components for this weld
joint. Figure 26 shows the dimensions of the weld. This weld was a fillet weld that joined the
brackets from the anti-intrusion beam and “B” pillar. The end of a portion of the sheet metal for
“B” pillar was also attached to this fillet weld.
The ends of a portion of the sheet metal for “B” pillar was also attached to this fillet weld. The
fillet weld leg along the anti-intrusion beam bracket was approximately 0.289” (7.334 mm) long
and the fillet weld leg along the bracket on “B” pillar was approximately 0.206” (5.224 mm) long.
This fillet weld did not exhibit any cracks/fractures.
A portion of the weld fusion line between the weld metal and “B” pillar exhibited LOF.
FILED: SUFFOLK COUNTY CLERK 11/28/2022 05:31 PM INDEX NO. 611214/2015
NYSCEF DOC. NO. 1172 RECEIVED NYSCEF: 11/28/2022
R. A. HOFFMANN ENGINEERING, P.C. October 17, 2022
3544-RPT-01
Page 12
Sample 4
A portion of the rocker panel from the stretch portion of the limousine on its passenger-side had
been removed prior to October 22, 2019. Detailed inspection of this component was not
performed.
Sample 9
The floor mounts added to the stretch portion of the limousine on its passenger-side, Sample 9,
Preview
FILED: SUFFOLK COUNTY CLERK 11/28/2022 05:31 PM INDEX NO. 611214/2015 NYSCEF DOC. NO. 1172 RECEIVED NYSCEF: 11/28/2022 Exhibit “8” FILED: SUFFOLK COUNTY CLERK 11/28/2022 05:31 PM INDEX NO. 611214/2015 NYSCEF DOC. NO. 1172 RECEIVED NYSCEF: 11/28/2022 FILED: SUFFOLK COUNTY CLERK 11/28/2022 05:31 PM INDEX NO. 611214/2015 NYSCEF DOC. NO. 1172 RECEIVED NYSCEF: 11/28/2022 R. A. HOFFMANN ENGINEERING, P.C. October 17, 2022 3544-RPT-01 Page 1 TABLE OF CONTENTS Section Page 1.0 INTRODUCTION ................................................................................................................................. 2 2.0 BACKGROUND ................................................................................................................................... 3 2.1 Construction of the Limousine .......................................................................................................... 3 2.2 Details of Accident and Focus of Metallurgical Evaluation ............................................................... 4 3.0 PROFESSIONAL EXPERIENCE ............................................................................................................. 4 4.0 WORK PERFORMED........................................................................................................................... 5 4.1 Documents Reviewed ....................................................................................................................... 5 4.2 List of Inspections, Examinations Testing ......................................................................................... 5 5.0 INSPECTIONS, EXAMINATIONS AND TESTING................................................................................... 6 5.1 Group Inspection of Limousine – October 22, 2019 ......................................................................... 6 5.2 Nondestructive Inspection of GJ Exhibits 119z and 120z – February 14, 2020 ................................ 7 5.3 Group Lab Exam at LPI, Inc.– June 22, August 31 and September 27-28, 2021 ............................... 8 5.3.1 Identification of Components from Limousine ...................................................................... 8 5.3.2 Initial Visual Examination – As-Received................................................................................ 9 5.3.3 Removal of Samples from Limousine and Additional Sectioning........................................... 9 5.3.4 Visual Examination and Stereomicroscopy of Samples ....................................................... 10 5.3.5 Dimensional Measurements ................................................................................................ 13 5.3.6 Tensile Testing of Anti-Intrusion Beams .............................................................................. 12 5.3.7 Chemical Analyses ................................................................................................................ 14 5.3.8 Optical Microscopy and Microhardness Measurements ..................................................... 14 6.0 SUMMARY AND DISCUSSION .......................................................................................................... 17 7.0 CONCLUSIONS ................................................................................................................................. 19 FIGURES APPENDIX A APPENDIX B FILED: SUFFOLK COUNTY CLERK 11/28/2022 05:31 PM INDEX NO. 611214/2015 NYSCEF DOC. NO. 1172 RECEIVED NYSCEF: 11/28/2022 R. A. HOFFMANN ENGINEERING, P.C. October 17, 2022 3544-RPT-01 Page 2 1.0 INTRODUCTION I have been retained as a metallurgical engineering expert by the plaintiffs representing the Estate of Stephanie Belli in this matter. Specifically, I was requested to conduct a metallurgical evaluation of the structural welding associated with the conversion of a 2007 Lincoln Town Car to a limousine. On July 18, 2015, the subject 2007 Lincoln Town Car limousine was hit in the passenger-side midsection by 2005 Dodge Dakota truck. Because of the collision, significant intrusion of the truck into the passenger compartment of the limousine occurred. This intrusion resulted in interaction with the occupants within the passenger compartment. FILED: SUFFOLK COUNTY CLERK 11/28/2022 05:31 PM INDEX NO. 611214/2015 NYSCEF DOC. NO. 1172 RECEIVED NYSCEF: 11/28/2022 R. A. HOFFMANN ENGINEERING, P.C. October 17, 2022 3544-RPT-01 Page 3 2.0 BACKGROUND 2.1 Construction of the Limousine The original unaltered 2007 Lincoln Town Car was modified immediately after production, in March 2007, to increase its length for the purposes of increasing the passenger capacity (modified to a limousine). Anti-intrusion beams (or bars) are installed in the modified portion of the vehicle body for added resistance to intrusion during side impact. One anti-intrusion beam is installed on each side (passenger-side and driver-side) of the limousine. On the passenger-side of the limousine, a fifth (after-market) door is also added as part of the modification. The fifth door is located immediately to the rear of the original passenger-side front door. An anti-intrusion beam is also installed inside of the fifth door. The original vehicle doors (front and rear on both driver and passenger sides) are also manufactured with an internal anti- intrusion beam. The anti-intrusion beam added to the limousine body on the passenger-side of the vehicle was approximately 52 inches in length. The front end of the passenger-side anti-intrusion beam was attached to “C” pillar. The passenger-side “C” pillar was located at the rear end of the fifth door and was installed as part of the vehicle modification. The rear end of the passenger-side anti- intrusion beam was attached to “D” pillar. The passenger-side “D” pillar was installed during the original manufacturing process of the unaltered 2007 Lincoln Town Car. Both ends of the passenger-side anti-intrusion beam were welded to carbon steel plates (or mounting brackets) and the anti-intrusion beam brackets were welded to a separate bracket attached to the pillars. The stretch portion of the driver-side of the subject limousine did not have an additional door added. Only the original front and rear doors were present on the driver-side. On the driver- side, the anti-intrusion beam added to the stretched portion of the body spanned from the “B” pillar on its front end to ”D” pillar on its rear end. The driver side anti-intrusion beam was also welded to “C” pillar, located between “B” and “D” pillars. The “B” and “D” pillar ends of the driver- side anti-intrusion beam were attached using a bracket design similar to that used on the passenger side. The driver-side anti-intrusion beam was attached to the “C” pillar at approximately the mid-span position. The attachment at this “C” pillar location utilized a different design than “B” and “D” pillars. The fifth door and rocker panels in the stretched portion of the limousine were fabricated utilizing welds also. FILED: SUFFOLK COUNTY CLERK 11/28/2022 05:31 PM INDEX NO. 611214/2015 NYSCEF DOC. NO. 1172 RECEIVED NYSCEF: 11/28/2022 R. A. HOFFMANN ENGINEERING, P.C. October 17, 2022 3544-RPT-01 Page 4 2.2 Details of Accident and Focus of Metallurgical Evaluation The limousine was impacted on its passenger-side during the accident. The forces associated with the impact were applied primarily to the area of the fifth (mid-compartment) door, “C” pillar, and the intermediate body panel. The front end of the passenger-side anti-intrusion beam (welded to “C” pillar) was discovered disconnected from the pillar immediately after the accident. During emergency response efforts, the rear end (“D” pillars) of the anti-intrusion beams on both the passenger and driver sides became separated from their attachments. Both the passenger- side and driver-side anti-intrusion beams were cut into two sections during the emergency response efforts to facilitate access to the rear passenger compartment of the limousine. My metallurgical evaluation of the subject limousine was focused on the welds associated with the attachment plates/brackets used to join the anti-intrusion beams to the respective pillars on passenger and drives sides of the vehicle. The mechanical properties and dimensions of the anti-intrusion beams were also evaluated. 3.0 PROFESSIONAL EXPERIENCE My experience as an expert metallurgical engineer is summarized below. • I am a metallurgical engineer with 33 years of experience performing failure analysis of metal components associated with building services, industrial environments and structural applications. My experience includes performing nondestructive and destructive examinations of welds used for structural and pressure-containing components. I also have expertise in analyzing the effects of various failure mechanisms (such as fatigue, stress overload, impact loading, corrosion, etc.) on carbon steel and a variety of other metals/alloys. A complete copy of my curriculum vitae is annexed to this report as Appendix A. • I received a Bachelor of Science in Metallurgical Engineering from the University of Notre Dame (1989). I am a licensed Professional Engineer (P.E.) and a Certified Weld Inspector (CWI). I am a member of American Society for Metals International (ASM), American Society of Mechanical Engineers (ASME), American Welding Society (AWS), Association for Materials Protection and Performance (AMPP) and the National Society of Professional Engineers (NSPE). • I am a Senior Metallurgical Engineer of R.A. Hoffmann Engineering, P.C. d/b/a Hoffmann & Feige, a materials engineering consulting firm which services a diversified group of utilities (gas, LNG and power), building owners and managers, manufacturers, fabricators and design engineering firms. • During my professional career, I have experience identifying and analyzing failure mechanisms, such as failures of welds in carbon steel components due to defects, poor workmanship, overload, fatigue cracking, embrittlement, stress corrosion cracking, general corrosion, pitting corrosion and various other failure mechanisms. I have performed failure analyses on a variety of carbon steel industrial products, including structural components, tubing, piping, heavy equipment and fasteners. FILED: SUFFOLK COUNTY CLERK 11/28/2022 05:31 PM INDEX NO. 611214/2015 NYSCEF DOC. NO. 1172 RECEIVED NYSCEF: 11/28/2022 R. A. HOFFMANN ENGINEERING, P.C. October 17, 2022 3544-RPT-01 Page 5 4.0 WORK PERFORMED 4.1 Documents Reviewed A list of the documents that I have reviewed regarding this matter are listed below. • Interrogatory Responses exchanged by each of the Plaintiffs • Complaints filed • Deposition transcripts of the surviving Plaintiffs and Defendants, Steven Romeo and Carlos Pino • Police documentation including photographs • Cabot Motion for Summary Judgement including Affidavits associated with Cabot Motion for Summary Judgement • Dimon Motion for Summary Judgement including Affidavits associated with Dimon Motion for Summary Judgement • Town of Southold Motion for Summary Judgement including Affidavits associated with Town of Southold Motion for Summary Judgement • Expert Disclosures • 2003 and 2008 Builder’s Guides for the Qualified Vehicle Modifiers (QVM) Program for Ford Motor Company • Grand Jury Report, CPL 190.85(1)(C), dated September 20, 2016 4.2 List of Inspections, Examinations Testing As part of the metallurgical evaluation of the subject Limousine, I have performed the following inspections and participated in laboratory testing and examinations as detailed below. • Group inspection of the subject limousine on October 22, 2019 at the Suffolk County Police Department (SCPD) impound yard in Westhampton, New York. • Nondestructive visual inspection of Grand Jury (GJ) Exhibits 119Z and 120Z at the Law Offices of Andrea G. Sawyers in Melville, NY on February 14, 2020. • Participation in group lab exam of the subject limousine at LPI, Inc. (LPI, a SOCOTEC Company) in Brooklyn, NY on June 22, 2021, August 31, 2021 and September 27-28, 2021. 5.0 INSPECTIONS, EXAMINATIONS AND TESTING 5.1 Group Inspection of Limousine – October 22, 2019 On October 22, 2019, I participated in a group inspection of the subject limousine at the SCPD impound yard in Westhampton, NY. This inspection was a nondestructive inspection with no alteration of the evidence permitted. The storage of the subject limousine at the SCPD impound yard began a short time after the accident in 2015. FILED: SUFFOLK COUNTY CLERK 11/28/2022 05:31 PM INDEX NO. 611214/2015 NYSCEF DOC. NO. 1172 RECEIVED NYSCEF: 11/28/2022 R. A. HOFFMANN ENGINEERING, P.C. October 17, 2022 3544-RPT-01 Page 6 The focus of my inspection was on the welds associated with the joining of the following components from the limousine as listed below. • Anti-intrusion beam added to the stretch portion of the limousine’s body (during modification) on its driver-side. • “C” and D” pillars on the driver-side of limousine. The anti-intrusion beam that was added to the passenger-side of the vehicle during the vehicle modification was not present at this inspection. Additionally, passenger-side “C” and “D pillars were inaccessible due to the excessive damage that had occurred to the limousine during the accident. The driver- side anti-intrusion beam was also cut with a “jaws-of-life” tool by emergency response personnel at the time of the accident. It was reported that the rear section of the driver-side anti- intrusion separated at its weld attaching the associated bracket to “D” pillar during the emergency response efforts. The portion of the weld on the plate (bracket) attached to the driver-side anti-intrusion beam (at “D” pillar) spanned approximately 1-¾” (the width of the plate (bracket) was approximately 2”). The weld appeared to have fractured along its length. The weld, including its fracture surface, was covered with a layer of corrosion product (rust) and/or debris, therefore the fracture surface features were not evident. This weld was an approximate ¼” fillet weld The mating half of the fractured weld on “D” pillar was also covered with a layer of rust and/or debris and could not be inspected in detail during this inspection. The “D” pillar had been separated from the frame of the limousine during emergency response efforts along with the driver-side rear door. The brackets and welds that attached the driver-side anti-intrusion beam to “C” pillar utilized a more robust design than at “D” pillar. There was no separation of the welds associated with the driver-side anti-intrusion bar to “C” pillar. The weld attachments associated with the brackets and “B” pillar at the front end of the driver- side anti-intrusion beam were not accessible during this inspection. The anti-intrusion beam on the driver’-side had a tubular geometry with an approximate outside diameter of 1-1/4” (measured with a tape measure). Figures 1 through 7 illustrate the conditions observed during the October 22, 2019 inspection. FILED: SUFFOLK COUNTY CLERK 11/28/2022 05:31 PM INDEX NO. 611214/2015 NYSCEF DOC. NO. 1172 RECEIVED NYSCEF: 11/28/2022 R. A. HOFFMANN ENGINEERING, P.C. October 17, 2022 3544-RPT-01 Page 7 5.2 Nondestructive Inspection of GJ Exhibits 119z and 120z – February 14, 2020 The passenger-side anti-intrusion beam (with brackets attached) was submitted as GJ Exhibits 119z and 120z as part of the Grand Jury investigation involving the subject accident. GJ Exhibits 119z and 120z had been attached to “D” and “C” pillars, respectively, prior to the accident. A visual inspection was performed of GJ Exhibits 119z and 120z at the Law Offices of Andrea G. Sawyers in Melville, NY on February 14, 2020. No other components from the limousine were included in this inspection. Figures 8 and 9 provide overall views of GF Exhibit 119z and 120z during this inspection. The outside diameter (OD) of the anti-intrusion beam (on both GJ Exhibits 119z and 120z) was approximately 1-1/4” (measured with dial calipers). The length of the anti-intrusion beam associated with GJ Exhibit 119z was approximately 32” and the length of the anti-intrusion beam associated with GJ Exhibit 120z was approximately 20”. A fillet weld was observed on the end of the bracket associated with GJ Exhibit 119z that would have attached to “D” pillar. The length of this weld was approximately 1-¾” and the weld appeared to have fractured along its entire length. This weld, including its fracture surface and the end of the bracket, were covered with a layer of corrosion product (rust) and/or debris which again prohibited detailed examination of these areas. The conditions observed on GJ Exhibit 119z are illustrated in Figure 10. On GJ Exhibit 120z, a fillet weld was observed on the end of the bracket which would have attached to “C” pillar. The length of this fillet weld was approximately ¼”. This weld had also fractured. Along most of the remaining width of this bracket, substantial weld metal was not observed, but it appeared that a shallow fracture surface was present indicating that separation of weld metal from the surface of the bracket had occurred. Again, the weld and surrounding surface on the bracket were covered with a layer of corrosion product (rust) and/or debris which prohibited detailed examination of these surfaces. The conditions observed on GJ Exhibit 120z are illustrated in Figure 11. 5.3 Group Lab Exam at LPI, Inc.– June 22, August 31 and September 27-28, 2021 A joint destructive lab examination of the subject limousine was conducted at LPI, Inc. on June 22, August 21 and September 27-28, 2021. The limousine was transported from the SCPD impound yard to LPI, Inc. in Brooklyn, NY for the destructive examination. The test protocol used as a guideline for the joint lab exam is provided in Appendix B. The destructive examination of the limousine consisted of the following. • Visual examination of the limousine and all individual components of interest. • Removal of samples from limousine and additional sectioning of components from limousine to allow for inspection and examination. • Dimensional measurements. • Optical stereomicroscopy. FILED: SUFFOLK COUNTY CLERK 11/28/2022 05:31 PM INDEX NO. 611214/2015 NYSCEF DOC. NO. 1172 RECEIVED NYSCEF: 11/28/2022 R. A. HOFFMANN ENGINEERING, P.C. October 17, 2022 3544-RPT-01 Page 8 • Optical metallographic examination. • Chemical Analysis • Tensile Testing • Hardness Testing 5.3.1 Identification of Components from Limousine The components to be removed from limousine were selected prior to the group lab exam. For the purposes of the destructive testing and examination, the components of interest were assigned a sample number designation. The sample designations are provided below in Table 1. TABLE 1 – Sample Identification Sample GJ Side of Limousine Description No.1 Exhibit (Passenger or Driver) Section of anti-intrusion beam that was attached to “D” pillar. 1 120z Passenger Approximately 20 inches in length. Section of anti-intrusion beam that was attached to “C” pillar. 2 119z Passenger Approximately 32 inches in length. 3 NA Driver Section of anti-intrusion beam that was attached to “D” pillar. 4 NA Passenger Rocker panel between “C” and “D” pillars. 5 NA Passenger Sections of “C” pillar. 6 NA Passenger Sections of “D” pillar. 7 NA Driver Sections of “D” pillar. 8 NA Driver Section of anti-intrusion beam attached to “B” and “C” pillars. 9 NA Passenger Floor mounts in stretch portion. 10 NA Passenger Roof rail in stretch portion. 11 NA Passenger Fifth (after-market) door 12 NA Driver Rear door Note 1: Samples 1-4, 12 were removed from the limousine prior to the group lab exam at LPI. Samples 5- 11 were removed from limousine during the group lab exam at LPI. 5.3.2 Initial Visual Examination – As-Received The limousine was delivered to LPI, Inc. unaltered from its condition observed at the SCPD impound lot on October 22, 2019. Samples 1 and 2, GJ Exhibits 120z and 119z, respectively, were brought to LPI, Inc. separately for the joint lab exam. Overall photos of the limousine in its as-received condition at LPI are provided in Figure 12. 5.3.3 Removal of Samples from Limousine and Additional Sectioning As indicated in Table 1, Samples 1-4, 12 had been removed or separated from the limousine prior to the group lab exam at LPI and Samples 5-11 were removed from the limousine during the group lab exam. The sectioning was performed with slow-speed portable and table band saws and abrasive cut-off wheels. The removal process for the samples is illustrated in Figure 13. FILED: SUFFOLK COUNTY CLERK 11/28/2022 05:31 PM INDEX NO. 611214/2015 NYSCEF DOC. NO. 1172 RECEIVED NYSCEF: 11/28/2022 R. A. HOFFMANN ENGINEERING, P.C. October 17, 2022 3544-RPT-01 Page 9 5.3.4 Visual Examination and Stereomicroscopy of Samples The visual examination and stereomicroscopy of the samples are summarized below. Samples 1 and 6 The bracket welded to the end of the passenger-side anti-intrusion beam for Sample 1 had been welded to a bracket on the section of “D” pillar for Sample 6. Detailed visual examination of the weld joint associated the joining of Samples 1 and 6 confirmed that this attachment used a fillet weld. The joint design was essentially a T-joint with the Sample 1 bracket positioned approximately 1/16” from the end of the bracket for Sample 6. The weld joint incorporated a portion of the sheet metal from the pillar. Figures 14 and 15 illustrate the design of this weld joint before and after sectioning to remove subsegments for further examination. The length of the fillet weld was confirmed to be approximately 1-¾” (the width of the bracket on Sample 1 was approximately 2.0”). The weld had fractured (broken) along its entire length. As observed during the visual inspection on February 14, 2020, the fracture surfaces associated with the failed weld were covered with a layer of corrosion product (rust)/debris. Therefore, the morphology of the fracture surface was not apparent. The mating fracture surfaces on the weld for these samples was gently cleaned in a solution of methanol, however only minimal removal of the corrosion product (rust) occurred. Cross sections of subsegments removed from Samples 1 and 6 at the weld attachment between the passenger-side anti-intrusion beam bracket and “D” pillar (rear of vehicle) were mounted together to examine the weld quality on macroscopic and microscopic scales. Figures 16 and 17 provided a macroscopic view of the cross section prior to mounting and stereomicroscopic images (in the etched condition) illustrating the condition of this weld. This weld was a fillet weld that joined the brackets from the anti-intrusion beam and “D” pillar. The ends of a portion of the sheet metal for “D” pillar were also attached to this fillet weld. The fillet weld leg along the anti-intrusion beam bracket was approximately 0.177” (4.501 mm) long and the fillet weld leg along the bracket on “D” pillar was approximately 0.229” (5.820 mm) long. The fillet weld had fractured near the weld attachment to the anti-intrusion beam bracket where the fillet weld had a throat dimension of approximately 0.079” (2.0 mm). A portion of the weld fusion line between the weld metal and “D” pillar exhibited Lack of Fusion (LOF). This condition is a defect associated with the weld/weld process. Samples 2 and 5 As with Samples 1 and 6, the bracket welded to the end of the passenger-side anti-intrusion beam for Sample 2 had been welded to a bracket on a section of “C” pillar for Sample 5. Detailed visual examination of the weld joint associated the joining of Samples 2 and 5 confirmed that this attachment also used a filletweld. Again, the joint design was essentially a T-joint with the Sample 2 bracket positioned approximately 1/16” from the end of the bracket for Sample 5. The weld joint incorporated a portion of the sheet metal from the pillar. Figure 18 illustrates the design of this weld joint with a cross sectional view prior sectioning with the location for sectioning marked (in yellow) on the samples. FILED: SUFFOLK COUNTY CLERK 11/28/2022 05:31 PM INDEX NO. 611214/2015 NYSCEF DOC. NO. 1172 RECEIVED NYSCEF: 11/28/2022 R. A. HOFFMANN ENGINEERING, P.C. October 17, 2022 3544-RPT-01 Page 10 Weld metal was observed over approximately a ¼” length of the approximate 2.0” width of the bracket associated with Sample 2. The edge of the bracket for Sample 5 (“C” pillar) that was attached to the Sample 2 bracket (anti-intrusion beam) had weld metal present along its complete width. This indicated that weld metal was applied along the length of this joint, but fusion of the weld to the bracket (plate) for the anti-intrusion beam only occurred over approximately 13% of the bracket width. In other words, there was LOF over approximately 87% of the fillet weld on the Sample 2 bracket interface. Complete fusion of the fillet weld on the bracket for Sample 5 side of the joint (“C” pillar) was evident. Cross sections of subsegments removed from Samples 2 and 5 at the weld attachment between the passenger-side anti-intrusion beam bracket and “C” pillar (near of fifth door) were mounted together to examine the weld quality at macroscopic and microscopic scales. Figures 19 and 20 illustrate the condition of the weld joint associated with Samples 2 and 5 with a macroscopic view (Figure 19) and microscopic views with use of a stereomicroscope (Figures 19 and 20). The photomacrograph shows this cross section in the unetched condition and the stereomicroscopic images show the cross section in the etched condition. Figure 19 (stereomicroscopic image) provides identification labels of each of the components for this weld joint. Figure 20 shows the dimensions of the weld. This weld was a fillet weld that joined the brackets from the anti-intrusion beam and “C” pillar. The ends of a portion of the sheet metal for “C” pillar was also attached to this fillet weld. The fillet weld along anti-intrusion beam bracket had separated at the fusion line for this cross section due to LOF (as indicated in Fig. 20). The fillet weld leg along the bracket on “C” pillar was approximately 0.223” (5.666) mm) long. Samples 3 and 7 The bracket welded to the end of the driver-side anti-intrusion beam for Sample 3 had been welded to a bracket on the section of “D” pillar for Sample 7. The comprehensive visual examination of the weld joint associated the joining of Samples 3 and 7 confirmed that this attachment used a fillet weld also. Again, the joint design utilized a T-joint configuration with the Sample 3 bracket positioned approximately 1/16” from the end of the bracket for Sample 7. As with the other anti-intrusion beam/pillar connection, the weld joint incorporated a portion of the sheet metal from the pillar. Figure 21 illustrates the design of this weld joint with a cross sectional view prior sectioning with the location for sectioning marked (in black) on the samples. Cross sections of subsegments removed from Samples 3 and 7 at the weld attachment between the driver-side anti-intrusion beam bracket and “D” pillar were mounted together to examine the weld quality at macroscopic and microscopic scales. Figures 22 illustrates the condition of the weld joint associated with Samples 3 and 7 with a macroscopic view in the unetched condition and in the etched condition using a stereomicroscope. The stereomicrograph in Figure 22 (bottom image) provides identification labels of each of the components for this weld joint. Figure 23 shows the dimensions of the weld. This weld was a filletweld that joined the brackets from the anti-intrusion beam and “D” pillar. The end of a portion of the sheet metal for “D” pillar was also attached to this fillet weld. The length of the fillet weld was confirmed to be approximately 1-¾” (the width of the bracket on FILED: SUFFOLK COUNTY CLERK 11/28/2022 05:31 PM INDEX NO. 611214/2015 NYSCEF DOC. NO. 1172 RECEIVED NYSCEF: 11/28/2022 R. A. HOFFMANN ENGINEERING, P.C. October 17, 2022 3544-RPT-01 Page 11 Sample 3 was approximately 2”). The weld had fractured (broken) along its entire length. As observed during the visual inspection on October 22, 2019, the fracture surfaces associated with the failed weld were covered with a layer of corrosion product (rust)/debris. Therefore, the morphology of the fracture surface was not apparent. The mating fracture surfaces on the weld for these samples was gently cleaned in a solution of methanol, however only minimal removal of the corrosion product (rust) occurred. The fillet weld leg along the anti-intrusion beam bracket was approximately 0.145” (3.678 mm) long and the fillet weld leg along the bracket on “D” pillar was approximately 0.172” (4.374 mm) long. The fillet weld had fractured near the weld attachment to the anti-intrusion beam bracket where the fillet weld had a throat dimension of approximately 0.137” (3.469 mm). Sample 8 Sample 8 included all the driver-side anti-intrusion beam except for the portion associated with Sample 3. The welded attachments at the drive-side “B” and “C” pillars along with a portion of each respective pillar was also removed from the limousine for closer examination. Overall views of this weld attachment after the subsegment had been removed for further examination are provided in Figure 24. The weld joint between the front-end bracket on the anti-intrusion beam and “B” pillar of Sample 8 had a similar configuration to that of Samples 1/6 and 2/5. The entire 2” width of the bracket attached to the anti-intrusion beam was welded to the bracket and pillar on the pillar side of the joint. This weld remained intact. The weld connections between the anti-intrusion beam and “C” pillar on the driver-side incorporated a different design than that used for all the end connections between the anti- intrusion beams and the associated pillar. At this location, a rectangular tube was welded on one end to the anti-intrusion beam and on the other end to “C” pillar. Fillet welds were also used for attachment on these joints as well. The sheet metal associated with “C” pillar exhibited tearing, however the weld connection to the pillar had not failed. The weld connection of the tubular bracket to the anti-intrusion beam was intact. Figures 25 and 26 illustrate the condition of the weld joint associated with Sample 8 with a macroscopic view (Figure 25) and microscopic views with use of a stereomicroscope (Figures 25 and 26). The photomacrograph shows this cross section in the unetched condition and the stereomicroscopic images show the cross section in the etched condition. Figure 25 (stereomicroscopic image) provides identification labels of each of the components for this weld joint. Figure 26 shows the dimensions of the weld. This weld was a fillet weld that joined the brackets from the anti-intrusion beam and “B” pillar. The end of a portion of the sheet metal for “B” pillar was also attached to this fillet weld. The ends of a portion of the sheet metal for “B” pillar was also attached to this fillet weld. The fillet weld leg along the anti-intrusion beam bracket was approximately 0.289” (7.334 mm) long and the fillet weld leg along the bracket on “B” pillar was approximately 0.206” (5.224 mm) long. This fillet weld did not exhibit any cracks/fractures. A portion of the weld fusion line between the weld metal and “B” pillar exhibited LOF. FILED: SUFFOLK COUNTY CLERK 11/28/2022 05:31 PM INDEX NO. 611214/2015 NYSCEF DOC. NO. 1172 RECEIVED NYSCEF: 11/28/2022 R. A. HOFFMANN ENGINEERING, P.C. October 17, 2022 3544-RPT-01 Page 12 Sample 4 A portion of the rocker panel from the stretch portion of the limousine on its passenger-side had been removed prior to October 22, 2019. Detailed inspection of this component was not performed. Sample 9 The floor mounts added to the stretch portion of the limousine on its passenger-side, Sample 9,