Allegations

Allegations
- Operating automobile without limitation
- Traveling at excessive rate of speed
- Failing to keep proper lookout
- Inattentively driving
- Talking/texting on cell phone
- Failing to pay attention

Alex Cooper 
- No personal connection with Taylor Hamilton
- Snuck out of game
- Hood was up, camouflaging him even further
- Dark Maroon & Black Sweatshirts = Blended/ Camouflaged
- “My hood does not affect my performance” o He is equally vigilant with hood on o Maybe not when he is texting and listening to music {Jerry Houseman Affidavit Reference}
- “I must have looked both ways” = not certain
- “I started jogging across the street” = caution not shown, reckless

Blake Green 
- “My brothers are so annoying… snitching on me to my parents” = obviously hates snitches
- Hung out with Taylor only for the rides = Used him (displays poor character)
- “Taylor cried like a baby and told the cops it was all my idea and then ratted out me and a bunch of my friends” o Seems a bit exaggerated {“Cried like a baby”) o Obvious resentment/ grudge
- “Hates” Taylor Hamilton
- Taylor was supposed to have only 1 person in the car – displays negligence to law
- Speeding to P-Cubed (late)
- Claims that Taylor was speeding
- Never actually looked at speedometer - uncertainty
- Taylor begged me to read the text messages – knew to keep eyes on road o I did = kept eyes on road
- Taylor ASKED for him to text back = aware not to text and drive
- Claims that Taylor grabbed the phone and began to text and drive
- Right after the collision occurred, WHILE Taylor was texting
- Contradicting Deposition/ Interview (occurred before snitch incident) = (no bias) o Said that he indeed was the one to send the response for Taylor
- Mentions all the incriminating AFTER telling the story of Taylor Hamilton allegedly “snitching and lying”.

Black Green’s Examination (Interview)
- Never looked at speedometer
- Doesn’t know if the speed went faster than 35 MPH o Seemed sure of it in Affidavit
- Claimed that Taylor never picked up his phone during the drive (not to call/ text) o Inconsistent with Affidavit o “Taylor got even more upset and grabbed the phone away from my hands to send it himself”
- #42 onward is a much less exaggerated version of what happened/ Taylors anger during the drive – she actually seems calm in this version of events.
- “She asked me to send a response so I did, and that was the message that went out right before we hit Alex”
- Says that he/she was the ONLY person to use the phone during the drive.
- This version of event is considerably more dependable then Blake’s affidavit because it was taken before his conflict with Taylor Hamilton, therefore contains no bias.

Ryan Crawley, MSME, PE 
- Collision took place at dusk
- There was a footpath leading from the street
- No streetlights
- Alex Cooper was wearing a maroon and black sweatshirt w/ blue jeans
- #1. Speed, actions, and course of the vehicle driven by Taylor Hamilton in the moments leading up to the collision o Headlights visible 160 ft ahead of the vehicle on FLAT surface (he was on a hill {Taylors Affidavit}) o “If a vehicle is traveling 35 MPH, or 51 ft per second, its braking distance is 59 ft. per second, its breaking distance is 59 ft.” o 1.1 second reaction time for Alex Cooper o Taylor should have been aware of the pedestrians present o Should have heightened awareness
- #2. Ability for Taylor Hamilton to see Alex Cooper before the collision o Failed to engage in proper lookout o Delay b/w turning off cruise control and braking, this would have avoided the collision o Headlight would have illuminated Alex crossing the street o Football game & light from Jerry Houseman’s house added light
- #3. The ability for Taylor Hamilton to take evasive action to avoid a collision after Alex Cooper entered the roadway. o Taylor should have seen Alex 160 ft from the collision spot
 “Braking distance of 59 feet plus y=traveling 56.43 feet during the perception/ reaction period would have Taylor Hamilton stopped at 115.43 ft – 44.57 ft before the collision.” o Taylor had enough time to swerve/ brake.

Taylor Hamilton 
- Was angry at the time because Avery didn’t want to hang out (cancelled plans)
- Was aware that he/she was only supposed to have 1 other person in the car - negligence
- Heard roars from stadium – aware of game and “special driving condition”
- Watched dashboard – kept steady pace of 35 MPH
- Asked Blake to read texts in order to stay vigilant (especially since it was getting dark
- Speaks further of his girl/boyfriend = displays anger even more
- “just as I was coming up to the top of the HILL by the woods...”
- Saw “a person” RUN out from the woods – Alex displays negligence
- Blake acknowledges that the person “came out of nowhere!”
- Pled no contest in order to end all the drama
- Blake did a lot of stupid stuff
- Blake suggests to go out into the baseball field and there he commits vandalism
- Taylor was surprised and disturbed.
- Did not deserve to get punished for Blake’s reckless behavior and told the truth.

Jerry Houseman
- Watches over kids during games like this
- Prescribed glasses – didn’t have them on o “I can see just fine.”
- Dusk
- Dark hoodie
- Didn’t seem to look both ways – negligence
- Had headphones in - negligence
- Looking down at electronic - negligence
- Dashed out in front of car – negligence
- Heard driver say “They ran out of nowhere!” Kirby Latanatto 
- Worked as in police department as patrol officer and detective for 10 years.
- Taylor traveled 35-37 MPH right b4 the accident o The weather was clear so the limit was reasonable
- Headlights were properly adjusted, illuminated 160 ft
- Giving Alex 3.12 seconds to move
- Easier for pedestrian to spot car then vice versa.
- Drivers keeps eyes straight not to the sides, especially somewhere where there is no intersection or crosswalk. = Longer recognition time
- Alex cooper had to cross an entire lane to reach Taylor’s car – should’ve seen the car
- 1.1 average reaction/perception time
- in 1-3 seconds Taylor saw the plaintiff, removed him foot from the accelerator, then attempted to stop.
- Possible error with data sensor (why would he stop cruise control and take off his seatbelt 5 seconds before the crash?)
- In 1.5 sec’s of perception time, car would have gone more than 75 ft.
- Stopping distance in a 2001 Lincoln Town Car at 35 MPH is app. 60 ft.
- Taylor was NOT being negligent