Party Statement: Sz Huang et al vs Tesla Inc. et al

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                                1   ERIN E. HOLBROOK, Chief Counsel
    G. MICHAEL HARRINGTON, Deputy Chief Counsel
2   LANDA LOW, Assistant Chief Attorney (SBN 125121)
    ROSEMARY LOVE, Deputy Attorney (SBN 257907)
3   111 Grand Avenue, Suite 11-100, kland, CA 94612
    Mail: P.O. Box 24325, Oakland, California 94623
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    Telephone: (510) 433-9100, Fax: (510) 433-9167
    Attorneys for Defendant STATE OF CALIFORNIA,
    acting by and through the Department of Transportation (“Caltrans”)
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                         SUPERIOR COURT OFTHE STAT E OF CALIFORNIA
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                                       COUNTY OF SANTA CLARA
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      SZ HUA HUANG, Individually and as                          Case No. 19CV346663
      successor in interest to WEI LUN HUANG,
      deceased; TRINITY HUANG, a minor;
      TRISTAN HUANG, a minor; HSI KENG                           DECLARATION OF ROSEMARY LOVE
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      HUANG; and CHING FENHUANG,                                 IN SUPPORT OF CALTRANS’ REPLY
                                                                 IN SUPPORT OF ITS MOTIONTO
                              Plaintiffs,                        AUGMENT EXPERT WITNESS
                                                                 INFORMATION
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              vs.                                                (Code Civ. Proc. §§ 2034.610, 2034.620)
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      TESLA INC. dba TESLA MOTORS, INC.,                          ate:     November 7, 2023
      THE STATE OF CALIFORNIA, and Does                          Time:     9:00 a.m.
      1 through 100,                                               cation: Dept. 6

                      Defendants.

                                                                 Complaint Filed: April 2
                                                                 Trial Date: March , 202

    I, ROSEMARY LOVE, declare as follows:
                      I am an attorney admitted to practice law in the State oCalifornia and in this

    Court, and I make this declaration in support of the Caltrans’ Motion to Augment Expert Witness

    Information.

                      I am employed by the State of California, Department of Transportation, Legal

    Division, and am one of the attorneys representing the Department in this action. I have personal

    knowledge of the facts set forth below based upon my role as an attorney in this matter, and if called,
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    could testify to the facts stated inthis Declar ation.
                                                             1
          DECLARATION OF ROSEMARY LOVE IN SUPPORT OF CALTRANS’ REPLY IN SUPPORT OF
         MOTION TO AUGMENT EXPERT WITNESS INFORMATION (Code Civ. Proc. §§ 2034.610, 2034.620)
1                     The parties spent over ten hourstak ing    e deposition of Caltrans’ accident

2   reconstruction expert Stephen Fenton on August 14, 2023 in order to elicit his opinions, which

3   included the sequenceand severity of the cras       after impact with the attenuator.

4                     Plaintiff biomechanic engin       Mark Shattuck was deposed on August 28, 2023

5   and discussed his opinions about the likelihood of the fatal injury occurring in the first impact with

6   the attenuator, as opposed to the second impact with the Mazda. A true and correct excerpt of Mar

7   Shattuck’s deposition is attached hereto as Exhibit L     92:20-93:1)

8              ake this declaration based upon my personal knowledge of the matters set forth herein. If

9   called as a witness in this case, I could and would testify competently as set forth herein. I certify,

0   under penalty of perjury, under the laws of th    tate of California, that the foregoing is true

    and correct and that this declaration was executed in Oakland, California on the 31st day of October,

    2023.

3                                                             ROSEMARY LOVE


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          DECLARATION OF ROSEMARY LOVE IN SUPPORT OF CALTRANS’ REPLY IN SUPPORT OF
         MOTION TO AUGMENT EXPERT WITNESS INFORMATION (Code Civ. Proc. §§ 2034.610, 2034.620)
MARK SHATTUCK, PH.D.               August 28, 2023
SZ HUA HUANG vs TESLA, INC.                      1




                              800.211.DEPO (3376)
                              EsquireSolutions.com
MARK SHATTUCK, PH.D.               August 28, 2023
SZ HUA HUANG vs TESLA, INC.                     92




                              800.211.DEPO (3376)
                              EsquireSolutions.com
                                                 YVer1f
MARK SHATTUCK, PH.D.               August 28, 2023
SZ HUA HUANG vs TESLA, INC.                     93




                              800.211.DEPO (3376)
                              EsquireSolutions.com
                                                 YVer1f