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Filing # E-Filed 01/03/2022 09:15:42 PM
IN THE CIRCUIT COURT OF THE SEVENTH JUDICIAL CIRCUIT IN AND FOR
VOLUSIA COUNTY, FLORIDA
TAMMY BRADFORD,
as Personal Representative of the Estate
of MICHAEL BLAZE BRADFORD, deceased; CASE NO.: 2019 10377 CIDL
and as Personal Representative of the
Estate of WARREN MICHAEL BRADFORD,
Deceased
Plaintiff,
VS.
MICHELIN NORTH AMERICA, INC.,
a foreign corporation; and DISCOUNT
TIRE CO., a Florida corporation
Defendants.
/
PLAINTIFF'S EXPERT WITNESS DISCLOSURE
Plaintiff, Tammy Bradford, by and through undersigned counsel and pursuant to this
Court's Pretrial Order hereby files its Expert Witness disclosure as follows:
1. Troy Cottles
25884 Katpaugh Lane
Toney, AL 35773
Mr. Cottles is an expert in Tire Failure Analysis. Mr. Cottles is expected to testify regarding
the cause of the failure in the subject tire, proper tire inspection practices, tire placement,
mounting and tire rotation for an expert tire service provider such as Discount Tire held
themselves out to be. Cottles will testify as to chronological aging and oxidation of tires and the
reasons and dangers associated with tire aging. His opinions and conclusions are based on his
experience and training during his seventeen years in the tire industry, testing he has performed,
testing he has observed, the documents and sworn testimony provided by Discount Tire in this
matter and his visual inspection of the subject tire and companion tires.
2. David Southwell
27 Netherby Ave
Netherby, South Australia 5062
Mr. Southwell is an expert in Tire Failure Analysis. Mr. Southwell is expected to testify
regarding the cause of the failure in the subject tire, proper tire inspection practices, tire
placement, mounting and tire rotation for an expert tire service provider such as Discount Tire
held themselves out to be. He will testify as to chronological aging and oxidation of tires and the
reasons and dangers associated with tire aging. His opinions and conclusions are based on his
experience and training during his years in the tire industry, testing he has performed, testing he
has observed, the documents and sworn testimony provided by Discount Tire in this matter and
his visual inspection of the subject tire and companion tires.
3. Micky Gilbert
16254 W. 77th Lane
Arvada, CO 80007
Mr. Gilbert is an expert in Accident Reconstruction and Vehicle Handling. He is
expected to testify as to the reconstruction of the subject accident of June 1, 2017 and the
handling and dynamics of the subject vehicle including the effect of a tread separation as
occurred in the subject accident resulting in a loss of control. His opinions are based on his
experience, education and training in accident reconstruction and vehicle handling, his inspection
of the subject vehicle and accident site, testing he has performed and testing he has observed.
4. W. Jay Zembower
956 East Altamonte Drive
Altamonte Springs, FL 32701
Mr. Zembower is an expert in Standard of Care. He is expected to testify regarding the
standard of care for tire service providers such as Discount Tire held themselves out to be
including proper training of tire service professionals, inspection of tires, mounting of tires,
rotation of tires. Mr. Zembower is expected to testify regarding documents produced by Discount
Tire and practices of Discount Tire and policies of Discount Tires, specifically how those
practices and policies were not adhered to in this case. Mr. Zembower's opinions are based on
his education, training and experience in the vehicle service industry.
5. Dr. Bernard Pettingill
93 Sandbourne Lane
PGA National
Palm Beach Gardens, FL 33418
Dr. Pettingill is an economist expected to testify regarding the economic losses suffered by
the Plaintiff as a result of the sudden and untimely death of her husband and only son. He is
expected to testify as to the economic loss of support, services and earnings that the plaintiff has
suffered as result of the death of her husband and only son.
6. John Baldwin
John Baldwin is an expert in tire aging. He will be called either live and/or by deposition to
discuss reasons for tire aging and oxidation and the dangers associated with tire aging. His
opinions are based on his education, training and experience in the tire industry. Baldwin has
written extensively on the subject of tire aging and will be called to discuss his articles,
publications and presentations.
Respectfully submitted,
BY: /s/Skip Edward Lynch
Skip Edward Lynch
Florida Bar No. 21085
skip@thetirelawyers.com
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on January 3, 2022, the foregoing was electronically filed with the
Clerk of Court by using the Florida Courts e-Filing Portal and served on all parties by the e-portal.
Respectfully submitted,
KASTER, LYNCH, FARRAR & BALL, LLP
BY: /s/Skip Edward Lynch
Skip Edward Lynch
Florida Bar No. 0021085
Skip@thetirelawyers.com
josh@thetirelawyers.com
Jessica@thetirelawyers.com
Bruce R. Kaster
Florida Bar No. 200271
brk@thetirelawyers.com
daneen@thetirelawyers.com
125 N.E. 1st Avenue, Suite 3
Ocala, FL 34470
Phone: 352-622-1600
Fax: 352-622-1611
ATTORNEYS FOR PLAINTIFF
Troy W. Cottles
Resume
Forensic Tire Failure Analyst
Tire Design and Manufacturing Consultant: (7/2005 — present)
Education:
Bachelors of Science, Mathematics/Physics minor, Athens St. University, 1988.
Mechanical Engineering Study, University of AL Huntsville
Additional Training:
3-month design study with Sumitomo Rubber Ind., Ltd. Kobe, Japan
MSOffice Suite; MSProject; AutoCad; Taguchi Techniques (DOE)
Management Skills for Engineers
Design Failure Mode and Effects Analysis (DFMEA)
Technical Focus:
My 17 years of experience in the tire and rubber industry culminated with a promotion to the
position of technical director of tire development for Goodyear-Dunlop Tires N.A. Ltd. I provided
direct technical input into products specific to passenger and light truck OE products from 1997
onward and most recently, OE and aftermarket lines of ATV products (both bias ply and radial
constructions).
Professional Experience:
Goodyear-Dunlop Tires N.A., Ltd. (Buffalo, NI9
Technical Director (6/2005 to 7/2005)
• Responsible for all joint venture development programs (motorcycle, ATV, passenger).
• Responsible for meeting annual financial goals through product development management
and cost improvements.
• Administration of the annual divisional capital and expenditure budgets.
• Negotiating technical support for outsourcing ATV products.
• Initiated technology thrusts for ATV products, including innovative ply and belt materials.
• Supporting OEM commitments through inter-company prioritization.
• Technical support on product liability issues (review claim tires, provide documentation and
drawings, interpret technical specifications, and provide background on original design
requirements).
Goodyear-Dunlop Tire N.A., Ltd. (Buffalo, NY)
Senior Technical Manager (1/2003 to 6/2005)
• Responsible for ATV and OEM passenger program activities.
• Product integrity test laboratory. Testing including: endurance, regulatory, and
force/moment measurement.
41
• Achievement of annual financial goals through product development, cost improvement
efforts.
• Guidance/countermeasures for product performance improvements as required per internal,
regulatory, or customer standards.
Goodyear-Dunlop Tire N.A., Ltd. (Akron, OH)
Senior Manager-OEM Passenger Development (8/2001 to 1/2003)
• Integration of the OE passenger technical development team of Dunlop Tire Corp. into
Goodyear Tire and Rubber Company's technical headquarters in Akron, OH.
• Responsible for OEM passenger/light truck tire design programs in support of Toyota and
Honda per scope of the joint venture.
• Manage an annual departmental budget, including cash flow.
• Departmental staffing, annual performance reviews, and associate training.
• Conduct program kickoff meetings and design reviews with Sumitomo, OEM, and internal
management in compliance with TS standards.
• Responsible for profitability of all OEM production programs.
• Formulation of countermeasures for any in-service product concerns.
Goodyear-Dunlop Tire N.A., Ltd. (Huntsville, AL)
Senior Manager-OEM Engineering (9/1999 to 8/2001)
• Responsible for OEM passenger/light truck tire design programs for Mercedes, Toyota,
Nissan, and Honda.
• Supervision of development engineering, CATIA support staff, Detroit liaison office, and
inventory control personnel.
• Manage an annual departmental budget, including cash flow.
• Introduction (by presentation) of new technologies to technical executive management of all
OEM customers.
• Departmental staffing, annual performance reviews and associate training.
• Global negotiation with counterparts regarding technical roles for OE business based in
Japan, Europe, or North America (semi-annual to quarterly meetings overseas).
• Formulation of countermeasures for any in-service product concerns.
Dunlop Tire Corporation (Huntsville, AL)
Senior Manager-OEM Engineering (10/1997 to 9/1999)
• Responsible for OEM passenger/light truck tire design programs for Mercedes, Toyota,
Nissan, and Honda.
• Supervision of development engineering, CATIA support staff, Detroit liaison office, and
inventory control personnel.
• Manage an annual departmental budget, including cash flow.
• Introduction (by presentation) of new technologies to technical executive management of all
OEM customers.
• Departmental staffing, annual performance reviews and associate training.
• Global negotiation with counterparts regarding technical roles for OE business based in
Japan, Europe, or North America (semi-annual to quarterly meetings overseas).
• Formulation of countermeasures for any in-service product concerns.
42
Dunlop Tire Corporation (Huntsville, AL)
OEM Senior Development Engineer (8/1996 to 10/1997)
• Responsible for all Dunlop N. American OEM tire development program technical activities.
• Customer interface for technical issues.
Dunlop Tire Corporation (Los Angeles, CA)
Customer Liaison Manager (11/1994 to 8/1996)
• Technical and field service representative to Japanese OEM R&D and service organizations.
• Negotiation of field service policies with customer corporate service management groups.
• Inspection of field returns at regional and corporate customer sites. Determination on
legitimacy of claims.
• Organization of field tire surveys, JDPower roundtable conferences, and auto show surveys.
• Technical representative to FAA (Long Beach) on regulatory requirements for new aircraft
tire submissions on Boeing 777 and Lockheed programs for Sumitomo Rubber Industries.
Dunlop Tire Corporation (Huntsville, AL)
OEM Design Engineer (7/1988 to 11/1994)
• Program development support to Japanese automotive manufacturers.
• Preparation of CAD tire design drawings, manufacturing specifications, and tire designs.
Steelcase Inc. (Athens, AL)
Production Operator (1987 to 1988)
• Manufacturing of office equipment.
Midsouth Testing, Inc. (Decatur, AL)
Waste Water System Operator (1986 to 1987)
• Titration of industrial waste water to eliminate metals.
• System repair and maintenance.
Eaton Corporation (Athens, AL)
Engineering Technician (1984 to 1986)
• Prototype engineering of electromechanical temperature control switches.
• Process engineering improvements—new raw material certification.
• Product engineering—environmental laboratory and field verification testing.
43
Curriculum Vitae- David Roy Southwell
Date of birth - October 11, 1962
Address - 27 Netherby Avenue
Netherby SA 5062
Education
Other - "Firestone University" — Akron, Ohio, USA, 1997 (Graduate)
Tire design factors
Compounding
Construction
Field Engineering
Analysis of operating conditions
Performance measurement and analysis
Stahlgruber Foundation Tire Inspection, Repair & Retreading training, 2003
Damage and failure modes
- Repair limits
- Repair techniques
- Repair failure analysis
Tertiary - Master of Engineering
University of South Australia
Bachelor of Management
University of South Australia
Trade certificate in Automotive Mechanics
O'Halloran Hill TAFE
Secondary - Matriculation
Prince Alfred College, 1979
Memberships and Associations
Member, Society of Automotive Engineers
64
Employment History
Feb 2005 - Independent tire industry consultant and failure analyst
www.tirexperts.com.au
July 2004 — South Pacific Tires
February 2005 (Manufacturer of Goodyear, Dunlop and related brands for
Australasian and export markets)
New Product Manager
Responsibility for new product design and development processes
Managing indoor and outdoor tire test activities
Recommending and implementing construction and compound
specifications to ensure appropriate performance levels
Surveying market conditions to determine suitability of
specifications
Co-ordinating market trials of new products
Ensuring product compliance with all necessary legislative
requirements
January 2001 - Bridgestone Corporation of Japan
June 2004
Technical Manager, Bridgestone/Firestone Training & Communication
Centre, Bangkok, Thailand.
• Establishment of formal in-service tire inspection procedures for all
product groups (Passenger and light truck, Truck & Bus, Industrial,
bias ply and radial ply designs)
• Training of technical service staff from Asia/Oceania, Middle East
and African offices:
o tire design, development and production processes
o production quality systems
o tire materials - origin, properties and appropriate uses
o inspection techniques to determine failure mode & causes
o assessment of tire designs for market suitability
o impact of service conditions on performance and durability
o dynamic behaviour of tires — interaction with vehicle/road
o international regulations, design standards & test methods
o tire performance monitoring and measurement
o tire economics
o software development — fleet tire monitoring
o all aspects of field technical service work
May 1999 to Dealer Principal (Self employed)
October 2000
• Director and Dealer Principal of The Tireman, a retail tire and
automotive mechanical services outlet in Adelaide.
• conduct of a consultancy for transport operators, tire dealers,
importers & wholesalers in the areas of fleet tire management,
product quality and related matters.
The business was purchased by the Franchisor (Bridgestone Australia) to enable me
to take up the above role with Bridgestone Corp. in Thailand.
65
January 1992 to Bridgestone Australia Ltd.
May 1999
National Technical Field Service Manager
Wide ranging technical management responsibilities across all tire
product groups, the major ones being listed below:
• make technical representations to major end users, original
equipment manufacturers, distributors and dealers
• development and implementation of formal technical procedures
and techniques for use by technical service staff
• prepare and present product and industry information to the media
and other concerned bodies
• production and distribution of technical material
• technical training at all levels in the distribution channel
• responsibility for the technical elements of 6 tire retread plants
Product Development
• plan and manage new product development programmes
• preparing compound and construction specifications for new and
revised products
• recommend and implement changes to product design and
specification
• test track evaluation of handling, noise, ride and other dynamic tire
response characteristics
• design and conduct extensive field trials to assess/confirm
suitability of new products and/or specification changes
• ongoing inspection and analysis of failed and damaged tires to
ascertain mode and cause of failure; determine and implement
countermeasures where appropriate
Other
• design and administration of the national warranty system
• direct the design and implementation of fleet tire management
software
• responsibility for product and public liability claims
• fulfil the position of Director of the Tire and Rim Association of
Australia, the organisation that formulates and publishes
engineering standards for the design, manufacture and fitment of
automotive wheels and tires
• serve as Chairman of the Technical Committee of the Australian
Tire Manufacturers Association. ATMA's task is to represent the
industry to Government, public and other relevant bodies.
January 1989 to Bridgestone Australia Ltd.
December 1991
State Technical Service Manager — SA/NT
• responsibility for all Bridgestone tire technical matters within
SA/NT
• Inspect tires submitted for warranty, product and/or public liability
claim to determine mode and cause of failure
• prepare and make technical representations to commercial vehicle
fleets, dealers, wholesalers, government bodies and other parties
66
• administration of new product design and development
programmes
January 1987 to Bridgestone Australia Ltd.
December 1988
OE Engineering and Product Co-ordinator
• responsibility for development of new and improved products for
sale to vehicle and machinery manufacturers
• new product performance testing/evaluation, and liaising with
design staff concerning product specifications and changes
thereto
• investigation and resolution of production and field quality issues
across all product groups
October 1985 to Ford Motor Company of Australia Ltd.
December 1986
Field Manager
• responsibility for the parts and service activities of 24 Ford dealers.
This encompassed service technical support and staff training,
investigating & reporting on product failures and similar activities.
February 1984 to Mitsubishi Motors Australia Ltd.
October 1985
Vehicle Development Technical Officer
• this position involved Australian Design Rule certification, test
track driving to assess vehicle dynamic response characteristics,
durability test driving to evaluate vehicle and component durability,
technical report compilation, new model road tests and
subsequent market suitability evaluation, vendor liaison, and
dealer field problem investigation/resolution.
Jan 1980 — Dec 1983 Mitsubishi Motors Australia Ltd.
Automotive Apprenticeship
an intensive four year Company training course involving rotation
throughout all of the Company's operations, from fitting & machining to
manufacturing, warranty, industrial engineering, engine development,
service communication and vehicle development.
Extracurricular Designer/builder of Clubman sports car for motorsport competition
Motorsport competitor (rally, hillclimb and circuit sprints) since 1983.
67
Micky Gilbert, P.E.
Gilbert Engineering LLC
16254 W 77th Lane
Arvada CO 80007
Education
Bachelor of Science degree in Mechanical Engineering, Colorado State
University, 1993
Worked with Professional Engineers and Accident Reconstructionists since 1993, studying vehicle and
accident dynamics
Employment
Race Car Mechanic at Skip Barber Racing,
Mechanical Engineer, James L. Gilbert and Associates,
Mechanical Engineer, Gilbert Engineering LLC, 1998-present
Associate Engineering Consultant, Professional Investigative Engineers,
Professional Experience
➢ Reconstruction/Analysis of Accidents
➢ Vehicle Dynamics Testing of Race Cars and Passenger Cars
➢ Automotive Computer Analysis and Simulation
➢ Analysis of Auto Manufacturer Documents and Tests
➢ Design Analysis of Vehicle Structures and Systems
➢ Patent Design Work of Anti-Rollover Device and Rollover Steering System
➢ Car-to-Car Crash Testing
➢ Testing and Design of Modified Passenger Vehicles
➢ Teaching courses on accident reconstruction and vehicle dynamics to Police Officers,
Engineers, Insurance Adjusters and Attorneys
➢ Design and rollover crash testing of automated SUV systems (with and without tread
separation)
Related Vehicle Dynamics/Auto Racing Experience
Skip Barber Formula 2000 and Race Karts
1996 National Champion, Skip Barber Formula 2000 Midwest series
1997 2nd place, Superkarts 250cc National Championship
1997-present BMW School Instructor, Teen Survival Instructor
Test Driver for Hoosier Racing Tires
Chief driving instructor of Pro-One Motorsports academy
1999 SCCA National Champion — Formula Mazda, Central Division
2000 Third consecutive podium — SCCA Valvoline Runoffs — Formula Mazda
2005 Star Mazda Pro Series — Expert Champion
2006 Obtained Indy Racing League license and drove in first Indy Pro race
Firestone Indy Lights Series driver
Professional Affiliations
Colorado Professional Engineer, Registration No. 35682
Accreditation Commission for Traffic Accident Recon. (ALTAR), Reg. No. 1240 (
Society of Automotive Engineers (SAE)
Society of Accident Reconstructionists (SOAR)
American Society for Testing and Materials (ASTM)
American Society of Mechanical Engineers (ASME)
Accident Reconstruction Communications Network (ARC Network) — No. ARC0827
National Association of Professional Accident Reconstruction Specialists (NAPARS) — No. 26114
Canadian Association of Road Safety Professionals (CARSP)
1
Pu blications/Patents
Micky Gilbert, Jim Gilbert, "Engineering Principles in Vehicle Rollover Litigation" in
Crashworthiness Litigation, published by West Group, 1998
Micky Gilbert, "Analysis of Toyota LAR Testing", NHTSA Docket 2000-8298, No. 4
"Method and Apparatus for Reducing Vehicle Rollover", Micky Gilbert, United States Patent
Number 6,170,594, January 9, 2001
Micky Gilbert, "Prevention of On-Road, Untripped Rollover by use of an Anti-Rollover Device",
presented to Society of Automotive Engineers, IBEC Conference, 10/00
Micky Gilbert, "Reconstruction of SUV Untripped Rollovers", The Investigative Engineer, 7/02
Micky Gilbert, Michael Kaplan, David Bilek, Steve Kaplan, David Vellos, "An Examination of
Rim Gouging and Its Relation to On-Road Vehicle Rollover", The SOARce, Spring 2004
Micky Gilbert, "Effects of Tire Shoulder Wear on Vehicle Rollover Limit Testing", SAE #2003-
O1-2865, JSAE #20037145, presented in Tokyo, Japan on 10/28/03
Gilbert Engineering, LLC comments to Rollover Docket NHTSA
"Rotation Limiter", Micky Gilbert, John Olmstead, United States Patent Number 7,134,357,
November 14, 2006
Micky G. Gilbert, John Olmstead, Erich Woessner, Tom Mueller, "Effect of Yaw Control on SUV
Rollover", The SOARce, Autumn 2004
Renfroe, D., Roberts, A., Gilbert, M., "Vehicle Rollover Maximum Limits", International Journal of Vehicle Design, 2004
Micky G. Gilbert, John Olmstead, Erich Woessner, Tom Mueller, "Wet Pavement Handling
Tests", The SOARce, Autumn 2005
Micky G. Gilbert, John Olmstead, Erich Woessner, Tom Mueller, "Rollover Testing: Analysis of
Steer Input Timing", SAE Paper Number — presented at 2006 SAE World
Congress (4/6/06)
Gilbert Engineering LLC, "1991 Ford Explorer XLT 4x2: Automated Untripped Rollover Test", ARC-CSI Crash Conference 2006 also Published in Summer 2006
SOARce, also
Presented at International Traffic Medicine Association conference Melbourne,
Australia 10/17/06
Gilbert Engineering LLC, Rollover Crash Test of 1997 Toyota 4Runner SR5 4x2,
ARC-CSI Crash Conference 2006
Micky Gilbert, Tom Mueller, "2001 Ford E-350 XLT Super Duty Vehicle Dynamic Performance
Testing" The SOARce, Winter 2007
Wilson, L.A., Gilbert, M., Godrick, D., "Reconstruction and Analysis of Steering-induced, On-
road, Untripped SUV Rollover Tests" Collision, Spring 2007
Wilson, L.A., Gilbert, M., Godrick, D., "Reconstruction and Analysis of Steering-induced, On-
road, Untripped SUV Rollover Tests (Part 2)" Collision, Winter 2007
Micky Gilbert, P.E. and Daniel A. Godrick, "Vehicle Dynamic Performance Testing 2002 Volvo S80 T6," The SOARce, Winter 2008
Michael Gilbert, Daniel Godrick, Richard Klein, "The Effect of Longitudinal Center of Gravity Position
On the Sway Stability of a Small Cargo Trailer", DAECE — presented at 2008 ASME
International Mechanical Engineering Congress and Exposition
M. Gilbert, D. Yanda, T. Mueller, "Dynamic testing of an SUV with Tire Tread Separation", Canadian
Multidisciplinary Road Safety Conference XIX — presented in Saskatoon, Saskatchewan at
CMRSC, CCMSR Conference 6/8/09
S. Andrews, M. Partain, D. Renfroe, M. Gilbert, "A Comparison of Computer Modeling to Actual Data and Video of a
Staged Rollover Collision", 21' International Technical Conference on the Enhanced Safety of Vehicles 6/09
M. Gilbert, B. Stolz, "Pre-Rollover Vehicle Dynamics of SUVs in Untripped Rollover Tests", 20' Canadian
Multidisciplinary Road Safety Conference, June 2010
M. Gilbert, T. Mueller, J. Nirvelli, "The Effect of Tread-Separation on Vehicle Controllability", Hazard Information Foundation, Inc (HIFI)
Tire Tech Conference, 8/10
M. Gilbert, T. Mueller, J. Nirvelli, "Forensic Interpretation of Driver Countersteer", 22nd Canadian Multidisciplinary Road Safety
Conference, Banff, Alberta, June 10-13, 2012
Desmoulin GT, Rabinoff, Stolz. B and Gilbert M, "A Biomechanical Method for Reconstruction of Tumbling Trampoline-Associated Cervical Spine Injuries Using
Human and Anthropometric Test Dummy Data, Journal of Forensic Bio mechanic, Volume 5 • Issue 1 • 101, April 2014
M. Gilbert, B. Stolz. "Effect of Oversized Wheels and Tires on SUV Roll Stability", 24th Canadian Multidisciplinary Road Safety
Conference, Vancouver, Canada June 2-4, 2014
M. Gilbert, G. Hoffman "Tow Dolly Handling & Stability", The SOARce, Winter 2018
2
956 East Altamonte Drive Phone 407-831-5620
Altamonte Springs,FL 32701 Fax 407-831-4630
E-mail cardoctor1@hotmail.com
W. Jay Zembower CMAT / CTT
Summary of 1991 — Present Zembower's Auto-RV Center Orlando, FL
qualifications CEO- Service Manager- Master Technician
â– Manage corporate activities; oversee a management team that includes
all operations, human resources and financial departments. Oversee and
perform technician training and head up diagnostic assault team.
Transmatic Inc. Orlando, FL
VP-Operations
Responsible for all service and sales operations. Instituted new service
department procedures that increased productivity while at the same time
increasing the quality of service to 99`)/0 customer satisfaction rating. Started
new training procedures for automotive technicians and service consultants
that increased productivity and employee relations.
Recruited large service clients from the recreational vehicle market to
diversify the services offered by the company, this was virtually untapped
market at that time.
State of Florida Licensed car dealer handling sales of vehicles and
recreational vehicles.
1978 - 1987 Transmatic Inc. Orlando, FL
Automotive and Truck Service Technician / Service Manager
Responsible for all aspects of service and repair of automobiles, trucks, and
recreational vehicles. Specialized in diagnostics and troubleshooting
technical aspects of the same. Handled all budget and reporting of service
departments.
Education 1976 - Present Numerous Automotive related and ongoing
updates
Factory Authorized Training
â– General Motors, Ford, Acura, BMW, Volvo, Mercedes Benz, Toyota,
Nissan, Jaguar, Volkswagen, Lexus, Infiniti, Honda, Mazda, John Deere
Chassis, Oshkosh Chassis, Freightliner, Spartan Chassis, Allison,
Cummins, Navistar, Caterpillar, Eaton, Spicer, TRW, Midland Brake,
Kelsey Hayes, exotic vehicle analysis, emergency vehicle and apparatus
training, Bosch, Lucas, Delco, Motorcraft, Mercury Marine, OMC marine,
Moore-ryde, Onan, Suburban, HVVH, VDO Instrumentation, Vetronix
Scanner systems, General Motors Power-train control system
programming TECH 1,Tech 2,MDI. Daimler Benz Chrysler power train
programming DRB and VViTech, Ford, Lincoln, Mercury power train and
electronic system programming IDS/VVDS. Toyota/Lexus power train
programming electronic system programming TECHSTREAM,
Nissan/Infiniti Power train and electronic system programming Consult
11,111 and GT. Mazda power train and electronic system programming IDS.
Jaguar power train and electronic systems programming 1DS/WDS.
Hunter Alignment and Tire Diagnostic training. Michelin Tire dealer
training, Advanced Hybrid Vehicle Diagnostics, Advanced CAN network
diagnostics. Ford advanced Power Stroke Diesel Diagnostics. CDR
(VEHICLE BLACK BOX) download and analyst training. Bosch advanced
vehicle reprogramming and software training. Pro-cut advanced brake
rotor hub match training. Tire Industry Association TIA/RMA Tire
Advanced level technician training. TIA advanced instructor training. Tire
Pressure Monitoring System training.
1984 - 2008 Seminole State College Sanford, FL
■Automotive Service Technology — Automotive Advanced Electronics
â– Electronic Fuel Injection and Fuel systems
â– Studies for Automotive Technology Certificate
1989 University of VVisconsin — Milwaukee
Automotive Consumer Affairs
1980 - 1981 Valencia Community College
1979 Graduated from Colonial High School
Professional 1989 - 1993 Ford Motor Company Southeast Zone
experience Technical Consultant and Chairman For Ford Consumers Appeal
Board
â– Performed vehicle and document evaluation of problem vehicles and
reviewed all Lemon Law Cases prior to arbitration. Performed as technical
advisor for 4 years and Chaimian 1 year. Reviewed approximately 2000
cases.
1993 to present Orlando Police Department Traffic Homicide Div.
Technical Consultant
Perform inspection of vehicles involved in traffic homicide. The scopes of my
activities involve determination of mechanical, structural conditions of
vehicles and assist in determining and recreating events prior to collision.
Perform air bag crash data retrieval and data analysis. I report directly to the
Chief Investigator and any detectives involved in a case.
2010 to present City of Altamonte Springs, Florida
Technical Consultant
Member of the accident review board, review all accidents involving city
employees associated with city vehicles and rendering causal analysis and
recommendations for corrective action and compliance.
1988 - 1997 Seminole State College
Technical Advisor
Member of Automotive Advisory Council
Reported to the President of the College as a Board, worked with instructors
and automotive department heads for running of the Automotive Technology
Program at the College. Worked with industry officials, Manufactures and
State Officials in instituting policy, standards and new technology curriculum.
2012 National Automotive Technicians Education Foundation
Seminole State College
Curriculum review and program facility certification for NATEF and State
Certification program in Automotive Technology
Mid Florida Tech. Orange County Public Schools
Technical Advisor
Assist school officials in instituting and operating the automotive curriculum..
1980 — Present
Technical Consultant and Expert Witness
For the following
Florida State Attorney's Office
Allstate Insurance Company
State Farm Insurance
Nationwide Insurance
Shelby Insurance
Searcy,Denney,Scarola,Barnhart & Shipley
Robert Wattles P.A.
Chandler Mueller P.A.
J. Gordon Blau P.A.
Dominique J. Salfi P.A.
Pinel & Carpenter P.A.
Butler, McDonald, Moon & Hosch P.A.
Beers, Jack, Tudhope, Wyatt P.A.
Giuliana Associates P.A.
Saalfield, Coulson, Shad, & Jay P.A.
Holland & Knight LLP
Kirk Pinkerton P.A.
Louise Zueli P.A.
Alana C. Brenner P.A.
Vemis & Bowling of Central FL. P.A.
William Bromagen P.A.
General Motors Corporation
Ford Motor Company
Safari Motor Coach
SMC Corporation
Spartan Motors
Oshkosh Chassis Products
John Deere Chassis Division
Freightliner Corporation
American Automobile Association
Fleetwood Corporation
Motors Insurance Corporation
Safeco Insurance Corporation
Russell Bergen P.A.
William Folsom P.A.
McKeever, Albert & Barth P.A.
Zachory Stoumbos P.A.
W. Riley Allen P.A.
William Osborne P.A.
Paul Coppet P.A.
Cianfrogna, Telfer, Faherty & Anderson P.A.
Ian Forsythe Esq.
The Nation Law Firm
Direct General Insurance Company
Butler & Pappas ( Tampa )
Butler, Pappas, Weihmuller, Katz, Craig LLP ( Tallahassee)
Steven Faulgren P.A.
Overchuck & Newsome P.A.
Fischer, Rushmer, Werrenrath, Dickson, Tally & Dunlap, P.A.
Allen, Kopet & Associates, PLLC
Meyers, Mooney, Stanley & Colvin
Infiniti of Orlando
Frito-Lay Corporation
Rissman, Weisberg, Barrett, Hurt, Donahue & McLain, P.A.
Gray, Harris & Robinson, P.A.
Cousins Law Firm
Courtesy Mercedes and Porsche
Greenway Ford
Lexus of Orlando
Auto Nation Group
Newsome & Didier P.A.
Overchuck & DeNault P.A.
Jay Halperen & Associates P.A.
Krupnick, Campbell, Malone,
Buser, Slama, Hancock, Liberman & McKee P.A.
Colson, Hicks, and Eidison P.A.
Leeper and Associates P.A.
State Farm Insurance Company
Travelers Insurance Company
Overchuck and Byron P.A.
Colling, Gilbert and Wright P.A
Paul and Perkins P.A..
Pajic and Pajic P.A.
Cole,Scott &Kissane P.A.
Scottsdale Insurance Comapany
Performed inspection services, consulting services and prepared reports for
the above clients in regard to motor vehicles, recreational vehicles, trucks
and related products.
Worked directly with legal counsel in preparing cases and providing technical
information for litigation.
1993 to Present
Radio talk show host Automotive related
VWVNZ 740 AM
VVTLN 95.3 FM
WAJL 1020 AM
ESPN 1080 AM
VVFLA 540 AM
1994 — Present
Technical Consultant Investigative reporting
VVFTV Television ABC Local Affiliate
VVESH Television NBC Local Affiliate
Professional Automotive Service Association
memberships
Automotive Service Excellence
American Management Association
Vehicle Service Counsel
Tire Industry Association
Service Technician Society div. of Society of Automotive Engineers( SAE)
Family Motorcoach Association
Community Advisory Board Member - Master's Academy Christian School
activities
Meals on Wheels Sponsor
Citizens Police Academy (Orlando Police Department)
Board of Director and President of Lake Pickett Woods Homeowners
Association
Technical Seminar sponsors for civic groups, church group's etc. for
automotive related issues.
Little League Coach and Team Sponsor
Private Christian School Scholarship for Underprivileged children.
Board of Director for Central Florida Marine Conservation Corp.
Board of Director and President of Central Florida Offshore Anglers
Accreditation's Master's Certificate — Automotive ( ASE )
Certified Engine Repair Gas/Diesel (ASE)
Certified Automatic Transmisson/Transaxle (ASE)
Certified Manual Transmisson and Axle (ASE)
Certified Suspension and Steering (ASE)
Certified Brakes (ASE)
Certified Electrical Systems (ASE)
Certified Heating and Air conditioning (ASE)
Certified Engine Performance (ASE)
Certified Medium & Heavy Thick Technician (ASE )
Certified Electronic Systems (ASE)
Certified Engine Machinist (ASE)
Certified Cylinder Head Specialist Gas / Diesel (ASE)
Certified Mechanical and Electrical Components (ASE)
Certified Electronic Diesel Engine Diagnostics (ASE)
Certified Engine Assembly Specialist (ASE)
Certified Medium/Heavy Truck DriveTrain (ASE)
Certified Medium/Heavy Truck Heating,Ventilation,Air Conditioning (ASE)
Certified Level II Specialist (ASE)
Tire Industry Association Certified Instructor
Certified Arbitrator- Florida State Lemon Law Ford Consumers Affairs Board.
Consumer Affairs Arbitrator— University of Wsconsin at Milwaukee
Crash Data Recovery Technician ( Collision Safety Institute )
Crash Data Analyst ( Collision Safety Institute )
State of Florida — Refrigerant Handling
State of Florida — Notary Public
Volunteer Meals on Wheels
experience
Better Business Bureau
Florida Conservation Association
Fellowship of Christian Athletes
Career Days- Orange County Public Schools
Hurricane Andrew Emergency supply transport team
Public defender's office (Brevard County,Florida)
Advisory board member Seminole County Florida Youth Outdoor Hunting
and Recreation development program
East Central Florida Trail Connection project advisory board member
Awards received Good Citizenship Award - City of Orlando 1994 and 1999
Superior Customer Service Award — American Automobile Association
Pioneer Award — Towing and Recovery Association of America
ASE/ NAPA Automotive Technician of the year 1998/1999
ASE/NAPA Automotive Technician of the year participant 2007/2008
Congressional Medal of Distinction 2005
BERNARD F. PETTINGILL, JR., PH.D.
Consulting Economist
EDUCATION
Manchester University
Manchester, England
Graduate, January 1977, Ph.D. - Economics
Department of Economics and Social Administration
Dissertation: "Cost-Benefit Analysis of the Treatment of Arthritis - A
Comparison of Five Hospitals"
Tulane University
Contact New Orleans, Louisiana
Graduate, June 1973 - MPH - Master Public Health
ADDRESS: Department of Health Economics and Medical Care Administration
#93 SANDBOURNE LANE Loyola University
New Orleans, Louisiana
PGA NATIONAL
PALM BEACH GARDENS, FL 33418 Graduate, June 1971. MBA - Economics, June 1969
BBA - Business Administration
PHONE:
ORGANIZATIONS
561-622-0330
561-346-7828 • Member, American Society of Health Economists, 2008-Present
561-503-0181 • Member, City of Palm Beach Gardens Budget Committee,
888-577-7747 • Member, AAEFE, 1989-Present
• Member, American Economic Association, 1983-Present
• Member, National Association of Forensic Economists, 1989-Present
FAX:
• Member, National Association of Business Economists, 1990-Present
561-624-2854 (Health Roundtable)
• Member, Health Economics Study Group, Great Britain, 1973-Present
WEB PAGE: • Member, Gideons International, 1978-Present (Past President)
www.bpettingill.com • Member, Rotary International,
• Referee Journal of Forensic Economics (2 years)
EMAIL: • Licensed, State of Florida and State of Louisiana, Health and Life
Insurance. No. 43972-6317 (FL)
biffpett@gmail.com
Bernard F. Pettingill, Jr., Ph.D.
Consulting Economists
Page 2
EXPERIENCE
1985 to Present FORENSIC ECONOMIST/MEDICAL & PROFESSIONAL PRACTICE
Financial Analysis, Structured Settlement Negotiations
1988 to 1998 FLORIDA INSTITUTE OF TECHNOLOGY
Graduate Business School
Treasure Coast Graduate Center
Stuart, Florida.
Professor of Economics - Taught Advanced Macroeconomics,
Managerial Economics, Health Care Economics, Advanced
Microeconomics (Retired)
PALM BEACH ATLANTIC COLLEGE
1987 to 1988
Rinker School of Business
West Palm Beach, Florida
Professor of Economics - Taught Microeconomics, Macroeconomics,
Free Enterprise System and International Economics
UNIVERSITY OF SOUTHWESTERN LOUISIANA
1980 to 1987
Lafayette, Louisiana.
College of Business Administration
Associate Professor - Taught undergraduate and graduate courses
Preview
Filing # E-Filed 01/03/2022 09:15:42 PM IN THE CIRCUIT COURT OF THE SEVENTH JUDICIAL CIRCUIT IN AND FOR VOLUSIA COUNTY, FLORIDA TAMMY BRADFORD, as Personal Representative of the Estate of MICHAEL BLAZE BRADFORD, deceased; CASE NO.: 2019 10377 CIDL and as Personal Representative of the Estate of WARREN MICHAEL BRADFORD, Deceased Plaintiff, VS. MICHELIN NORTH AMERICA, INC., a foreign corporation; and DISCOUNT TIRE CO., a Florida corporation Defendants. / PLAINTIFF'S EXPERT WITNESS DISCLOSURE Plaintiff, Tammy Bradford, by and through undersigned counsel and pursuant to this Court's Pretrial Order hereby files its Expert Witness disclosure as follows: 1. Troy Cottles 25884 Katpaugh Lane Toney, AL 35773 Mr. Cottles is an expert in Tire Failure Analysis. Mr. Cottles is expected to testify regarding the cause of the failure in the subject tire, proper tire inspection practices, tire placement, mounting and tire rotation for an expert tire service provider such as Discount Tire held themselves out to be. Cottles will testify as to chronological aging and oxidation of tires and the reasons and dangers associated with tire aging. His opinions and conclusions are based on his experience and training during his seventeen years in the tire industry, testing he has performed, testing he has observed, the documents and sworn testimony provided by Discount Tire in this matter and his visual inspection of the subject tire and companion tires. 2. David Southwell 27 Netherby Ave Netherby, South Australia 5062 Mr. Southwell is an expert in Tire Failure Analysis. Mr. Southwell is expected to testify regarding the cause of the failure in the subject tire, proper tire inspection practices, tire placement, mounting and tire rotation for an expert tire service provider such as Discount Tire held themselves out to be. He will testify as to chronological aging and oxidation of tires and the reasons and dangers associated with tire aging. His opinions and conclusions are based on his experience and training during his years in the tire industry, testing he has performed, testing he has observed, the documents and sworn testimony provided by Discount Tire in this matter and his visual inspection of the subject tire and companion tires. 3. Micky Gilbert 16254 W. 77th Lane Arvada, CO 80007 Mr. Gilbert is an expert in Accident Reconstruction and Vehicle Handling. He is expected to testify as to the reconstruction of the subject accident of June 1, 2017 and the handling and dynamics of the subject vehicle including the effect of a tread separation as occurred in the subject accident resulting in a loss of control. His opinions are based on his experience, education and training in accident reconstruction and vehicle handling, his inspection of the subject vehicle and accident site, testing he has performed and testing he has observed. 4. W. Jay Zembower 956 East Altamonte Drive Altamonte Springs, FL 32701 Mr. Zembower is an expert in Standard of Care. He is expected to testify regarding the standard of care for tire service providers such as Discount Tire held themselves out to be including proper training of tire service professionals, inspection of tires, mounting of tires, rotation of tires. Mr. Zembower is expected to testify regarding documents produced by Discount Tire and practices of Discount Tire and policies of Discount Tires, specifically how those practices and policies were not adhered to in this case. Mr. Zembower's opinions are based on his education, training and experience in the vehicle service industry. 5. Dr. Bernard Pettingill 93 Sandbourne Lane PGA National Palm Beach Gardens, FL 33418 Dr. Pettingill is an economist expected to testify regarding the economic losses suffered by the Plaintiff as a result of the sudden and untimely death of her husband and only son. He is expected to testify as to the economic loss of support, services and earnings that the plaintiff has suffered as result of the death of her husband and only son. 6. John Baldwin John Baldwin is an expert in tire aging. He will be called either live and/or by deposition to discuss reasons for tire aging and oxidation and the dangers associated with tire aging. His opinions are based on his education, training and experience in the tire industry. Baldwin has written extensively on the subject of tire aging and will be called to discuss his articles, publications and presentations. Respectfully submitted, BY: /s/Skip Edward Lynch Skip Edward Lynch Florida Bar No. 21085 skip@thetirelawyers.com CERTIFICATE OF SERVICE I HEREBY CERTIFY that on January 3, 2022, the foregoing was electronically filed with the Clerk of Court by using the Florida Courts e-Filing Portal and served on all parties by the e-portal. Respectfully submitted, KASTER, LYNCH, FARRAR & BALL, LLP BY: /s/Skip Edward Lynch Skip Edward Lynch Florida Bar No. 0021085 Skip@thetirelawyers.com josh@thetirelawyers.com Jessica@thetirelawyers.com Bruce R. Kaster Florida Bar No. 200271 brk@thetirelawyers.com daneen@thetirelawyers.com 125 N.E. 1st Avenue, Suite 3 Ocala, FL 34470 Phone: 352-622-1600 Fax: 352-622-1611 ATTORNEYS FOR PLAINTIFF Troy W. Cottles Resume Forensic Tire Failure Analyst Tire Design and Manufacturing Consultant: (7/2005 — present) Education: Bachelors of Science, Mathematics/Physics minor, Athens St. University, 1988. Mechanical Engineering Study, University of AL Huntsville Additional Training: 3-month design study with Sumitomo Rubber Ind., Ltd. Kobe, Japan MSOffice Suite; MSProject; AutoCad; Taguchi Techniques (DOE) Management Skills for Engineers Design Failure Mode and Effects Analysis (DFMEA) Technical Focus: My 17 years of experience in the tire and rubber industry culminated with a promotion to the position of technical director of tire development for Goodyear-Dunlop Tires N.A. Ltd. I provided direct technical input into products specific to passenger and light truck OE products from 1997 onward and most recently, OE and aftermarket lines of ATV products (both bias ply and radial constructions). Professional Experience: Goodyear-Dunlop Tires N.A., Ltd. (Buffalo, NI9 Technical Director (6/2005 to 7/2005) • Responsible for all joint venture development programs (motorcycle, ATV, passenger). • Responsible for meeting annual financial goals through product development management and cost improvements. • Administration of the annual divisional capital and expenditure budgets. • Negotiating technical support for outsourcing ATV products. • Initiated technology thrusts for ATV products, including innovative ply and belt materials. • Supporting OEM commitments through inter-company prioritization. • Technical support on product liability issues (review claim tires, provide documentation and drawings, interpret technical specifications, and provide background on original design requirements). Goodyear-Dunlop Tire N.A., Ltd. (Buffalo, NY) Senior Technical Manager (1/2003 to 6/2005) • Responsible for ATV and OEM passenger program activities. • Product integrity test laboratory. Testing including: endurance, regulatory, and force/moment measurement. 41 • Achievement of annual financial goals through product development, cost improvement efforts. • Guidance/countermeasures for product performance improvements as required per internal, regulatory, or customer standards. Goodyear-Dunlop Tire N.A., Ltd. (Akron, OH) Senior Manager-OEM Passenger Development (8/2001 to 1/2003) • Integration of the OE passenger technical development team of Dunlop Tire Corp. into Goodyear Tire and Rubber Company's technical headquarters in Akron, OH. • Responsible for OEM passenger/light truck tire design programs in support of Toyota and Honda per scope of the joint venture. • Manage an annual departmental budget, including cash flow. • Departmental staffing, annual performance reviews, and associate training. • Conduct program kickoff meetings and design reviews with Sumitomo, OEM, and internal management in compliance with TS standards. • Responsible for profitability of all OEM production programs. • Formulation of countermeasures for any in-service product concerns. Goodyear-Dunlop Tire N.A., Ltd. (Huntsville, AL) Senior Manager-OEM Engineering (9/1999 to 8/2001) • Responsible for OEM passenger/light truck tire design programs for Mercedes, Toyota, Nissan, and Honda. • Supervision of development engineering, CATIA support staff, Detroit liaison office, and inventory control personnel. • Manage an annual departmental budget, including cash flow. • Introduction (by presentation) of new technologies to technical executive management of all OEM customers. • Departmental staffing, annual performance reviews and associate training. • Global negotiation with counterparts regarding technical roles for OE business based in Japan, Europe, or North America (semi-annual to quarterly meetings overseas). • Formulation of countermeasures for any in-service product concerns. Dunlop Tire Corporation (Huntsville, AL) Senior Manager-OEM Engineering (10/1997 to 9/1999) • Responsible for OEM passenger/light truck tire design programs for Mercedes, Toyota, Nissan, and Honda. • Supervision of development engineering, CATIA support staff, Detroit liaison office, and inventory control personnel. • Manage an annual departmental budget, including cash flow. • Introduction (by presentation) of new technologies to technical executive management of all OEM customers. • Departmental staffing, annual performance reviews and associate training. • Global negotiation with counterparts regarding technical roles for OE business based in Japan, Europe, or North America (semi-annual to quarterly meetings overseas). • Formulation of countermeasures for any in-service product concerns. 42 Dunlop Tire Corporation (Huntsville, AL) OEM Senior Development Engineer (8/1996 to 10/1997) • Responsible for all Dunlop N. American OEM tire development program technical activities. • Customer interface for technical issues. Dunlop Tire Corporation (Los Angeles, CA) Customer Liaison Manager (11/1994 to 8/1996) • Technical and field service representative to Japanese OEM R&D and service organizations. • Negotiation of field service policies with customer corporate service management groups. • Inspection of field returns at regional and corporate customer sites. Determination on legitimacy of claims. • Organization of field tire surveys, JDPower roundtable conferences, and auto show surveys. • Technical representative to FAA (Long Beach) on regulatory requirements for new aircraft tire submissions on Boeing 777 and Lockheed programs for Sumitomo Rubber Industries. Dunlop Tire Corporation (Huntsville, AL) OEM Design Engineer (7/1988 to 11/1994) • Program development support to Japanese automotive manufacturers. • Preparation of CAD tire design drawings, manufacturing specifications, and tire designs. Steelcase Inc. (Athens, AL) Production Operator (1987 to 1988) • Manufacturing of office equipment. Midsouth Testing, Inc. (Decatur, AL) Waste Water System Operator (1986 to 1987) • Titration of industrial waste water to eliminate metals. • System repair and maintenance. Eaton Corporation (Athens, AL) Engineering Technician (1984 to 1986) • Prototype engineering of electromechanical temperature control switches. • Process engineering improvements—new raw material certification. • Product engineering—environmental laboratory and field verification testing. 43 Curriculum Vitae- David Roy Southwell Date of birth - October 11, 1962 Address - 27 Netherby Avenue Netherby SA 5062 Education Other - "Firestone University" — Akron, Ohio, USA, 1997 (Graduate) Tire design factors Compounding Construction Field Engineering Analysis of operating conditions Performance measurement and analysis Stahlgruber Foundation Tire Inspection, Repair & Retreading training, 2003 Damage and failure modes - Repair limits - Repair techniques - Repair failure analysis Tertiary - Master of Engineering University of South Australia Bachelor of Management University of South Australia Trade certificate in Automotive Mechanics O'Halloran Hill TAFE Secondary - Matriculation Prince Alfred College, 1979 Memberships and Associations Member, Society of Automotive Engineers 64 Employment History Feb 2005 - Independent tire industry consultant and failure analyst www.tirexperts.com.au July 2004 — South Pacific Tires February 2005 (Manufacturer of Goodyear, Dunlop and related brands for Australasian and export markets) New Product Manager Responsibility for new product design and development processes Managing indoor and outdoor tire test activities Recommending and implementing construction and compound specifications to ensure appropriate performance levels Surveying market conditions to determine suitability of specifications Co-ordinating market trials of new products Ensuring product compliance with all necessary legislative requirements January 2001 - Bridgestone Corporation of Japan June 2004 Technical Manager, Bridgestone/Firestone Training & Communication Centre, Bangkok, Thailand. • Establishment of formal in-service tire inspection procedures for all product groups (Passenger and light truck, Truck & Bus, Industrial, bias ply and radial ply designs) • Training of technical service staff from Asia/Oceania, Middle East and African offices: o tire design, development and production processes o production quality systems o tire materials - origin, properties and appropriate uses o inspection techniques to determine failure mode & causes o assessment of tire designs for market suitability o impact of service conditions on performance and durability o dynamic behaviour of tires — interaction with vehicle/road o international regulations, design standards & test methods o tire performance monitoring and measurement o tire economics o software development — fleet tire monitoring o all aspects of field technical service work May 1999 to Dealer Principal (Self employed) October 2000 • Director and Dealer Principal of The Tireman, a retail tire and automotive mechanical services outlet in Adelaide. • conduct of a consultancy for transport operators, tire dealers, importers & wholesalers in the areas of fleet tire management, product quality and related matters. The business was purchased by the Franchisor (Bridgestone Australia) to enable me to take up the above role with Bridgestone Corp. in Thailand. 65 January 1992 to Bridgestone Australia Ltd. May 1999 National Technical Field Service Manager Wide ranging technical management responsibilities across all tire product groups, the major ones being listed below: • make technical representations to major end users, original equipment manufacturers, distributors and dealers • development and implementation of formal technical procedures and techniques for use by technical service staff • prepare and present product and industry information to the media and other concerned bodies • production and distribution of technical material • technical training at all levels in the distribution channel • responsibility for the technical elements of 6 tire retread plants Product Development • plan and manage new product development programmes • preparing compound and construction specifications for new and revised products • recommend and implement changes to product design and specification • test track evaluation of handling, noise, ride and other dynamic tire response characteristics • design and conduct extensive field trials to assess/confirm suitability of new products and/or specification changes • ongoing inspection and analysis of failed and damaged tires to ascertain mode and cause of failure; determine and implement countermeasures where appropriate Other • design and administration of the national warranty system • direct the design and implementation of fleet tire management software • responsibility for product and public liability claims • fulfil the position of Director of the Tire and Rim Association of Australia, the organisation that formulates and publishes engineering standards for the design, manufacture and fitment of automotive wheels and tires • serve as Chairman of the Technical Committee of the Australian Tire Manufacturers Association. ATMA's task is to represent the industry to Government, public and other relevant bodies. January 1989 to Bridgestone Australia Ltd. December 1991 State Technical Service Manager — SA/NT • responsibility for all Bridgestone tire technical matters within SA/NT • Inspect tires submitted for warranty, product and/or public liability claim to determine mode and cause of failure • prepare and make technical representations to commercial vehicle fleets, dealers, wholesalers, government bodies and other parties 66 • administration of new product design and development programmes January 1987 to Bridgestone Australia Ltd. December 1988 OE Engineering and Product Co-ordinator • responsibility for development of new and improved products for sale to vehicle and machinery manufacturers • new product performance testing/evaluation, and liaising with design staff concerning product specifications and changes thereto • investigation and resolution of production and field quality issues across all product groups October 1985 to Ford Motor Company of Australia Ltd. December 1986 Field Manager • responsibility for the parts and service activities of 24 Ford dealers. This encompassed service technical support and staff training, investigating & reporting on product failures and similar activities. February 1984 to Mitsubishi Motors Australia Ltd. October 1985 Vehicle Development Technical Officer • this position involved Australian Design Rule certification, test track driving to assess vehicle dynamic response characteristics, durability test driving to evaluate vehicle and component durability, technical report compilation, new model road tests and subsequent market suitability evaluation, vendor liaison, and dealer field problem investigation/resolution. Jan 1980 — Dec 1983 Mitsubishi Motors Australia Ltd. Automotive Apprenticeship an intensive four year Company training course involving rotation throughout all of the Company's operations, from fitting & machining to manufacturing, warranty, industrial engineering, engine development, service communication and vehicle development. Extracurricular Designer/builder of Clubman sports car for motorsport competition Motorsport competitor (rally, hillclimb and circuit sprints) since 1983. 67 Micky Gilbert, P.E. Gilbert Engineering LLC 16254 W 77th Lane Arvada CO 80007 Education Bachelor of Science degree in Mechanical Engineering, Colorado State University, 1993 Worked with Professional Engineers and Accident Reconstructionists since 1993, studying vehicle and accident dynamics Employment Race Car Mechanic at Skip Barber Racing, Mechanical Engineer, James L. Gilbert and Associates, Mechanical Engineer, Gilbert Engineering LLC, 1998-present Associate Engineering Consultant, Professional Investigative Engineers, Professional Experience ➢ Reconstruction/Analysis of Accidents ➢ Vehicle Dynamics Testing of Race Cars and Passenger Cars ➢ Automotive Computer Analysis and Simulation ➢ Analysis of Auto Manufacturer Documents and Tests ➢ Design Analysis of Vehicle Structures and Systems ➢ Patent Design Work of Anti-Rollover Device and Rollover Steering System ➢ Car-to-Car Crash Testing ➢ Testing and Design of Modified Passenger Vehicles ➢ Teaching courses on accident reconstruction and vehicle dynamics to Police Officers, Engineers, Insurance Adjusters and Attorneys ➢ Design and rollover crash testing of automated SUV systems (with and without tread separation) Related Vehicle Dynamics/Auto Racing Experience Skip Barber Formula 2000 and Race Karts 1996 National Champion, Skip Barber Formula 2000 Midwest series 1997 2nd place, Superkarts 250cc National Championship 1997-present BMW School Instructor, Teen Survival Instructor Test Driver for Hoosier Racing Tires Chief driving instructor of Pro-One Motorsports academy 1999 SCCA National Champion — Formula Mazda, Central Division 2000 Third consecutive podium — SCCA Valvoline Runoffs — Formula Mazda 2005 Star Mazda Pro Series — Expert Champion 2006 Obtained Indy Racing League license and drove in first Indy Pro race Firestone Indy Lights Series driver Professional Affiliations Colorado Professional Engineer, Registration No. 35682 Accreditation Commission for Traffic Accident Recon. (ALTAR), Reg. No. 1240 ( Society of Automotive Engineers (SAE) Society of Accident Reconstructionists (SOAR) American Society for Testing and Materials (ASTM) American Society of Mechanical Engineers (ASME) Accident Reconstruction Communications Network (ARC Network) — No. ARC0827 National Association of Professional Accident Reconstruction Specialists (NAPARS) — No. 26114 Canadian Association of Road Safety Professionals (CARSP) 1 Pu blications/Patents Micky Gilbert, Jim Gilbert, "Engineering Principles in Vehicle Rollover Litigation" in Crashworthiness Litigation, published by West Group, 1998 Micky Gilbert, "Analysis of Toyota LAR Testing", NHTSA Docket 2000-8298, No. 4 "Method and Apparatus for Reducing Vehicle Rollover", Micky Gilbert, United States Patent Number 6,170,594, January 9, 2001 Micky Gilbert, "Prevention of On-Road, Untripped Rollover by use of an Anti-Rollover Device", presented to Society of Automotive Engineers, IBEC Conference, 10/00 Micky Gilbert, "Reconstruction of SUV Untripped Rollovers", The Investigative Engineer, 7/02 Micky Gilbert, Michael Kaplan, David Bilek, Steve Kaplan, David Vellos, "An Examination of Rim Gouging and Its Relation to On-Road Vehicle Rollover", The SOARce, Spring 2004 Micky Gilbert, "Effects of Tire Shoulder Wear on Vehicle Rollover Limit Testing", SAE #2003- O1-2865, JSAE #20037145, presented in Tokyo, Japan on 10/28/03 Gilbert Engineering, LLC comments to Rollover Docket NHTSA "Rotation Limiter", Micky Gilbert, John Olmstead, United States Patent Number 7,134,357, November 14, 2006 Micky G. Gilbert, John Olmstead, Erich Woessner, Tom Mueller, "Effect of Yaw Control on SUV Rollover", The SOARce, Autumn 2004 Renfroe, D., Roberts, A., Gilbert, M., "Vehicle Rollover Maximum Limits", International Journal of Vehicle Design, 2004 Micky G. Gilbert, John Olmstead, Erich Woessner, Tom Mueller, "Wet Pavement Handling Tests", The SOARce, Autumn 2005 Micky G. Gilbert, John Olmstead, Erich Woessner, Tom Mueller, "Rollover Testing: Analysis of Steer Input Timing", SAE Paper Number — presented at 2006 SAE World Congress (4/6/06) Gilbert Engineering LLC, "1991 Ford Explorer XLT 4x2: Automated Untripped Rollover Test", ARC-CSI Crash Conference 2006 also Published in Summer 2006 SOARce, also Presented at International Traffic Medicine Association conference Melbourne, Australia 10/17/06 Gilbert Engineering LLC, Rollover Crash Test of 1997 Toyota 4Runner SR5 4x2, ARC-CSI Crash Conference 2006 Micky Gilbert, Tom Mueller, "2001 Ford E-350 XLT Super Duty Vehicle Dynamic Performance Testing" The SOARce, Winter 2007 Wilson, L.A., Gilbert, M., Godrick, D., "Reconstruction and Analysis of Steering-induced, On- road, Untripped SUV Rollover Tests" Collision, Spring 2007 Wilson, L.A., Gilbert, M., Godrick, D., "Reconstruction and Analysis of Steering-induced, On- road, Untripped SUV Rollover Tests (Part 2)" Collision, Winter 2007 Micky Gilbert, P.E. and Daniel A. Godrick, "Vehicle Dynamic Performance Testing 2002 Volvo S80 T6," The SOARce, Winter 2008 Michael Gilbert, Daniel Godrick, Richard Klein, "The Effect of Longitudinal Center of Gravity Position On the Sway Stability of a Small Cargo Trailer", DAECE — presented at 2008 ASME International Mechanical Engineering Congress and Exposition M. Gilbert, D. Yanda, T. Mueller, "Dynamic testing of an SUV with Tire Tread Separation", Canadian Multidisciplinary Road Safety Conference XIX — presented in Saskatoon, Saskatchewan at CMRSC, CCMSR Conference 6/8/09 S. Andrews, M. Partain, D. Renfroe, M. Gilbert, "A Comparison of Computer Modeling to Actual Data and Video of a Staged Rollover Collision", 21' International Technical Conference on the Enhanced Safety of Vehicles 6/09 M. Gilbert, B. Stolz, "Pre-Rollover Vehicle Dynamics of SUVs in Untripped Rollover Tests", 20' Canadian Multidisciplinary Road Safety Conference, June 2010 M. Gilbert, T. Mueller, J. Nirvelli, "The Effect of Tread-Separation on Vehicle Controllability", Hazard Information Foundation, Inc (HIFI) Tire Tech Conference, 8/10 M. Gilbert, T. Mueller, J. Nirvelli, "Forensic Interpretation of Driver Countersteer", 22nd Canadian Multidisciplinary Road Safety Conference, Banff, Alberta, June 10-13, 2012 Desmoulin GT, Rabinoff, Stolz. B and Gilbert M, "A Biomechanical Method for Reconstruction of Tumbling Trampoline-Associated Cervical Spine Injuries Using Human and Anthropometric Test Dummy Data, Journal of Forensic Bio mechanic, Volume 5 • Issue 1 • 101, April 2014 M. Gilbert, B. Stolz. "Effect of Oversized Wheels and Tires on SUV Roll Stability", 24th Canadian Multidisciplinary Road Safety Conference, Vancouver, Canada June 2-4, 2014 M. Gilbert, G. Hoffman "Tow Dolly Handling & Stability", The SOARce, Winter 2018 2 956 East Altamonte Drive Phone 407-831-5620 Altamonte Springs,FL 32701 Fax 407-831-4630 E-mail cardoctor1@hotmail.com W. Jay Zembower CMAT / CTT Summary of 1991 — Present Zembower's Auto-RV Center Orlando, FL qualifications CEO- Service Manager- Master Technician ■Manage corporate activities; oversee a management team that includes all operations, human resources and financial departments. Oversee and perform technician training and head up diagnostic assault team. Transmatic Inc. Orlando, FL VP-Operations Responsible for all service and sales operations. Instituted new service department procedures that increased productivity while at the same time increasing the quality of service to 99`)/0 customer satisfaction rating. Started new training procedures for automotive technicians and service consultants that increased productivity and employee relations. Recruited large service clients from the recreational vehicle market to diversify the services offered by the company, this was virtually untapped market at that time. State of Florida Licensed car dealer handling sales of vehicles and recreational vehicles. 1978 - 1987 Transmatic Inc. Orlando, FL Automotive and Truck Service Technician / Service Manager Responsible for all aspects of service and repair of automobiles, trucks, and recreational vehicles. Specialized in diagnostics and troubleshooting technical aspects of the same. Handled all budget and reporting of service departments. Education 1976 - Present Numerous Automotive related and ongoing updates Factory Authorized Training ■General Motors, Ford, Acura, BMW, Volvo, Mercedes Benz, Toyota, Nissan, Jaguar, Volkswagen, Lexus, Infiniti, Honda, Mazda, John Deere Chassis, Oshkosh Chassis, Freightliner, Spartan Chassis, Allison, Cummins, Navistar, Caterpillar, Eaton, Spicer, TRW, Midland Brake, Kelsey Hayes, exotic vehicle analysis, emergency vehicle and apparatus training, Bosch, Lucas, Delco, Motorcraft, Mercury Marine, OMC marine, Moore-ryde, Onan, Suburban, HVVH, VDO Instrumentation, Vetronix Scanner systems, General Motors Power-train control system programming TECH 1,Tech 2,MDI. Daimler Benz Chrysler power train programming DRB and VViTech, Ford, Lincoln, Mercury power train and electronic system programming IDS/VVDS. Toyota/Lexus power train programming electronic system programming TECHSTREAM, Nissan/Infiniti Power train and electronic system programming Consult 11,111 and GT. Mazda power train and electronic system programming IDS. Jaguar power train and electronic systems programming 1DS/WDS. Hunter Alignment and Tire Diagnostic training. Michelin Tire dealer training, Advanced Hybrid Vehicle Diagnostics, Advanced CAN network diagnostics. Ford advanced Power Stroke Diesel Diagnostics. CDR (VEHICLE BLACK BOX) download and analyst training. Bosch advanced vehicle reprogramming and software training. Pro-cut advanced brake rotor hub match training. Tire Industry Association TIA/RMA Tire Advanced level technician training. TIA advanced instructor training. Tire Pressure Monitoring System training. 1984 - 2008 Seminole State College Sanford, FL ■Automotive Service Technology — Automotive Advanced Electronics ■Electronic Fuel Injection and Fuel systems ■Studies for Automotive Technology Certificate 1989 University of VVisconsin — Milwaukee Automotive Consumer Affairs 1980 - 1981 Valencia Community College 1979 Graduated from Colonial High School Professional 1989 - 1993 Ford Motor Company Southeast Zone experience Technical Consultant and Chairman For Ford Consumers Appeal Board ■Performed vehicle and document evaluation of problem vehicles and reviewed all Lemon Law Cases prior to arbitration. Performed as technical advisor for 4 years and Chaimian 1 year. Reviewed approximately 2000 cases. 1993 to present Orlando Police Department Traffic Homicide Div. Technical Consultant Perform inspection of vehicles involved in traffic homicide. The scopes of my activities involve determination of mechanical, structural conditions of vehicles and assist in determining and recreating events prior to collision. Perform air bag crash data retrieval and data analysis. I report directly to the Chief Investigator and any detectives involved in a case. 2010 to present City of Altamonte Springs, Florida Technical Consultant Member of the accident review board, review all accidents involving city employees associated with city vehicles and rendering causal analysis and recommendations for corrective action and compliance. 1988 - 1997 Seminole State College Technical Advisor Member of Automotive Advisory Council Reported to the President of the College as a Board, worked with instructors and automotive department heads for running of the Automotive Technology Program at the College. Worked with industry officials, Manufactures and State Officials in instituting policy, standards and new technology curriculum. 2012 National Automotive Technicians Education Foundation Seminole State College Curriculum review and program facility certification for NATEF and State Certification program in Automotive Technology Mid Florida Tech. Orange County Public Schools Technical Advisor Assist school officials in instituting and operating the automotive curriculum.. 1980 — Present Technical Consultant and Expert Witness For the following Florida State Attorney's Office Allstate Insurance Company State Farm Insurance Nationwide Insurance Shelby Insurance Searcy,Denney,Scarola,Barnhart & Shipley Robert Wattles P.A. Chandler Mueller P.A. J. Gordon Blau P.A. Dominique J. Salfi P.A. Pinel & Carpenter P.A. Butler, McDonald, Moon & Hosch P.A. Beers, Jack, Tudhope, Wyatt P.A. Giuliana Associates P.A. Saalfield, Coulson, Shad, & Jay P.A. Holland & Knight LLP Kirk Pinkerton P.A. Louise Zueli P.A. Alana C. Brenner P.A. Vemis & Bowling of Central FL. P.A. William Bromagen P.A. General Motors Corporation Ford Motor Company Safari Motor Coach SMC Corporation Spartan Motors Oshkosh Chassis Products John Deere Chassis Division Freightliner Corporation American Automobile Association Fleetwood Corporation Motors Insurance Corporation Safeco Insurance Corporation Russell Bergen P.A. William Folsom P.A. McKeever, Albert & Barth P.A. Zachory Stoumbos P.A. W. Riley Allen P.A. William Osborne P.A. Paul Coppet P.A. Cianfrogna, Telfer, Faherty & Anderson P.A. Ian Forsythe Esq. The Nation Law Firm Direct General Insurance Company Butler & Pappas ( Tampa ) Butler, Pappas, Weihmuller, Katz, Craig LLP ( Tallahassee) Steven Faulgren P.A. Overchuck & Newsome P.A. Fischer, Rushmer, Werrenrath, Dickson, Tally & Dunlap, P.A. Allen, Kopet & Associates, PLLC Meyers, Mooney, Stanley & Colvin Infiniti of Orlando Frito-Lay Corporation Rissman, Weisberg, Barrett, Hurt, Donahue & McLain, P.A. Gray, Harris & Robinson, P.A. Cousins Law Firm Courtesy Mercedes and Porsche Greenway Ford Lexus of Orlando Auto Nation Group Newsome & Didier P.A. Overchuck & DeNault P.A. Jay Halperen & Associates P.A. Krupnick, Campbell, Malone, Buser, Slama, Hancock, Liberman & McKee P.A. Colson, Hicks, and Eidison P.A. Leeper and Associates P.A. State Farm Insurance Company Travelers Insurance Company Overchuck and Byron P.A. Colling, Gilbert and Wright P.A Paul and Perkins P.A.. Pajic and Pajic P.A. Cole,Scott &Kissane P.A. Scottsdale Insurance Comapany Performed inspection services, consulting services and prepared reports for the above clients in regard to motor vehicles, recreational vehicles, trucks and related products. Worked directly with legal counsel in preparing cases and providing technical information for litigation. 1993 to Present Radio talk show host Automotive related VWVNZ 740 AM VVTLN 95.3 FM WAJL 1020 AM ESPN 1080 AM VVFLA 540 AM 1994 — Present Technical Consultant Investigative reporting VVFTV Television ABC Local Affiliate VVESH Television NBC Local Affiliate Professional Automotive Service Association memberships Automotive Service Excellence American Management Association Vehicle Service Counsel Tire Industry Association Service Technician Society div. of Society of Automotive Engineers( SAE) Family Motorcoach Association Community Advisory Board Member - Master's Academy Christian School activities Meals on Wheels Sponsor Citizens Police Academy (Orlando Police Department) Board of Director and President of Lake Pickett Woods Homeowners Association Technical Seminar sponsors for civic groups, church group's etc. for automotive related issues. Little League Coach and Team Sponsor Private Christian School Scholarship for Underprivileged children. Board of Director for Central Florida Marine Conservation Corp. Board of Director and President of Central Florida Offshore Anglers Accreditation's Master's Certificate — Automotive ( ASE ) Certified Engine Repair Gas/Diesel (ASE) Certified Automatic Transmisson/Transaxle (ASE) Certified Manual Transmisson and Axle (ASE) Certified Suspension and Steering (ASE) Certified Brakes (ASE) Certified Electrical Systems (ASE) Certified Heating and Air conditioning (ASE) Certified Engine Performance (ASE) Certified Medium & Heavy Thick Technician (ASE ) Certified Electronic Systems (ASE) Certified Engine Machinist (ASE) Certified Cylinder Head Specialist Gas / Diesel (ASE) Certified Mechanical and Electrical Components (ASE) Certified Electronic Diesel Engine Diagnostics (ASE) Certified Engine Assembly Specialist (ASE) Certified Medium/Heavy Truck DriveTrain (ASE) Certified Medium/Heavy Truck Heating,Ventilation,Air Conditioning (ASE) Certified Level II Specialist (ASE) Tire Industry Association Certified Instructor Certified Arbitrator- Florida State Lemon Law Ford Consumers Affairs Board. Consumer Affairs Arbitrator— University of Wsconsin at Milwaukee Crash Data Recovery Technician ( Collision Safety Institute ) Crash Data Analyst ( Collision Safety Institute ) State of Florida — Refrigerant Handling State of Florida — Notary Public Volunteer Meals on Wheels experience Better Business Bureau Florida Conservation Association Fellowship of Christian Athletes Career Days- Orange County Public Schools Hurricane Andrew Emergency supply transport team Public defender's office (Brevard County,Florida) Advisory board member Seminole County Florida Youth Outdoor Hunting and Recreation development program East Central Florida Trail Connection project advisory board member Awards received Good Citizenship Award - City of Orlando 1994 and 1999 Superior Customer Service Award — American Automobile Association Pioneer Award — Towing and Recovery Association of America ASE/ NAPA Automotive Technician of the year 1998/1999 ASE/NAPA Automotive Technician of the year participant 2007/2008 Congressional Medal of Distinction 2005 BERNARD F. PETTINGILL, JR., PH.D. Consulting Economist EDUCATION Manchester University Manchester, England Graduate, January 1977, Ph.D. - Economics Department of Economics and Social Administration Dissertation: "Cost-Benefit Analysis of the Treatment of Arthritis - A Comparison of Five Hospitals" Tulane University Contact New Orleans, Louisiana Graduate, June 1973 - MPH - Master Public Health ADDRESS: Department of Health Economics and Medical Care Administration #93 SANDBOURNE LANE Loyola University New Orleans, Louisiana PGA NATIONAL PALM BEACH GARDENS, FL 33418 Graduate, June 1971. MBA - Economics, June 1969 BBA - Business Administration PHONE: ORGANIZATIONS 561-622-0330 561-346-7828 • Member, American Society of Health Economists, 2008-Present 561-503-0181 • Member, City of Palm Beach Gardens Budget Committee, 888-577-7747 • Member, AAEFE, 1989-Present • Member, American Economic Association, 1983-Present • Member, National Association of Forensic Economists, 1989-Present FAX: • Member, National Association of Business Economists, 1990-Present 561-624-2854 (Health Roundtable) • Member, Health Economics Study Group, Great Britain, 1973-Present WEB PAGE: • Member, Gideons International, 1978-Present (Past President) www.bpettingill.com • Member, Rotary International, • Referee Journal of Forensic Economics (2 years) EMAIL: • Licensed, State of Florida and State of Louisiana, Health and Life Insurance. No. 43972-6317 (FL) biffpett@gmail.com Bernard F. Pettingill, Jr., Ph.D. Consulting Economists Page 2 EXPERIENCE 1985 to Present FORENSIC ECONOMIST/MEDICAL & PROFESSIONAL PRACTICE Financial Analysis, Structured Settlement Negotiations 1988 to 1998 FLORIDA INSTITUTE OF TECHNOLOGY Graduate Business School Treasure Coast Graduate Center Stuart, Florida. Professor of Economics - Taught Advanced Macroeconomics, Managerial Economics, Health Care Economics, Advanced Microeconomics (Retired) PALM BEACH ATLANTIC COLLEGE 1987 to 1988 Rinker School of Business West Palm Beach, Florida Professor of Economics - Taught Microeconomics, Macroeconomics, Free Enterprise System and International Economics UNIVERSITY OF SOUTHWESTERN LOUISIANA 1980 to 1987 Lafayette, Louisiana. College of Business Administration Associate Professor - Taught undergraduate and graduate courses