Shultz v. Abe's Trash Service, Inc. et al

Filing 114

ORDER ON FINAL PRETRIAL CONFERENCE - Jury Trial set for 9/10/2018 at 09:00 AM in Courtroom 4, Roman L. Hruska Federal Courthouse, 111 South 18th Plaza, Omaha, NE before Judge Robert F. Rossiter Jr. Ordered by Magistrate Judge Susan M. Bazis. (LKO)

IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF NEBRASKA

VANESSA SHULTZ,
Plaintiff(s),
vs.
ABE’S TRASH SERVICE, INC., and
CHRISTOPHER F. SKINNER,
Defendant(s).

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Case No. 8:16-CV-243

ORDER ON
FINAL PRETRIAL
CONFERENCE

A final pretrial conference was held on the 23rd day of May, 2018.
Appearing for the parties as counsel were:
Steven H. Howard, #18582
DOWD, HOWARD LAW FIRM
1411 Harney Street, Suite 100
Omaha, NE 68102
Ph: [phone]
Fx: [phone]
[e-mail]
Attorney for Plaintiff
James R. Walz, #22497
WALZ LAW OFFICES, PC, LLO
6519 Sunshine Drive
Omaha, NE 68107
Ph: [phone]
Fx: [phone]
[e-mail]
Attorney for Plaintiff

Heather L. Horst, #25001
WALZ LAW OFFICES, PC, LLO
6519 Sunshine Drive
Omaha, NE 68107
Ph: [phone]
Fx: [phone]
[e-mail]
Attorney for Plaintiff
Michael T. Gibbons, #21263
WOODKE, GIBBONS LAW FIRM
619 North 90th Street
Omaha, NE 68114
Ph: [phone]
Fx: [phone]
[e-mail]
Attorney for Defendants
Christopher D. Jerram, #19430
WOODKE, GIBBONS LAW FIRM
619 North 90th Street
Omaha, NE 68114
Ph: [phone]
Fx: [phone]
[e-mail]
Attorney for Defendants
(A)

Exhibits. See attached Exhibit List.

(B) Uncontroverted Facts. The parties have agreed that the following
may be accepted as established facts for purposes of this case only:
1. At the time of the accident, Plaintiff, Vanessa Shultz was a citizen of
Nebraska. Defendant, Abe’s Trash Service, Inc., is a Nebraska
corporation with its principal office located in Omaha, Nebraska.
Defendant, Christopher Skinner is a citizen of Iowa. Jurisdiction is based
on 28 U.S.C. §1332 as Plaintiff and one of the Defendants are citizens of
2

difference states and the matter in controversy exceeds the value of
$75,000.
2. On April 6, 2016 at approximately 2:40 p.m., the Plaintiff, Vanessa
Shultz was operating her vehicle Eastbound on Highway 36 approaching
264th street in Douglas County, Nebraska.
3. On April 6, 2016 at approximately 2:40 p.m., Defendant Skinner was
operating a garbage truck owned by Defendant Abe’s Trash Service
traveling Southbound on 264th Street across Highway 36 in Douglas
County, Nebraska.
4. On April 6, 2016 at approximately 2:40 p.m., Plaintiff’s vehicle collided
with Defendant’s vehicle at the intersection of Highway 36 and 264th
Street in Douglas County, Nebraska.
5. At the time of the accident, Defendant was attempting to cross Highway
36 from 264th Street.
6. At the time of the accident, Highway 36 was protected by stop signs at its
intersection with 264th street commanding northbound and southbound
traffic on 264th Street to stop.
7. At the time of the accident, the authorized speed limit on Highway 36
was 60 mph at or near the location of the accident.
8. That Deputy Russell Swanson of the Douglas County Sheriff’s Office
responded to the accident on April 6, 2016.
9. That there were no weather conditions that would have contributed to the
cause of the accident on April 6, 2016.
10.That there were no environmental or roadway conditions present on April
6, 2016 that would have contributed to the cause of the accident.
11.At all times relevant hereto, Defendant Skinner was employed by and
acting within the course and scope of his employment with Abe’s Trash.
12.If Defendant Skinner is found to be negligent by the trier of fact, Abe’s
Trash would be vicariously liable for said acts of negligence pursuant to
the doctrine of respondeat superior.
13.That Plaintiff was taken by ambulance to Immanuel Medical Center on
April 6, 2016 after the accident and released the same day.
(C) Controverted and Unresolved Issues. The issues remaining to be
determined and unresolved matters for the court’s attention are:
1. Plaintiff’s Issues:
3

a. Elements of negligence claimed by Plaintiff:
i. Whether any of the Defendants were negligent in one or
more of the following ways:
1. Failure to maintain a proper lookout (alleged against
Defendant, Christopher Skinner);
2. Failure to yield to the right of way (alleged against
Defendant, Christopher Skinner);
3. Failure to maintain reasonable control of the vehicle
(alleged against Defendant, Christopher Skinner);
4. Failure to properly investigate Defendant, Christopher
Skinner’s driving history (alleged against Defendant,
Abe’s Trash Service, Inc.);
5. Failure to investigate whether or not Defendant,
Christopher Skinner, was a safe, fit, and competent
driver (alleged against Defendant, Abe’s Trash
Service, Inc.).
ii. Whether said negligence was a proximate cause of injury or
damage to the Plaintiff.
iii. The nature and extent of Plaintiff’s damages.
b. Special Damages claimed and permanent injuries:
i. Property damage related to the loss of Plaintiff’s vehicle is
$13,670.65.
ii. Past medical expenses as of May 3, 2018 is $58,934.36.
iii. Past wage loss as of May 3, 2018 is $6,866.60.
iv. Future medical expenses are at least $30,000.00.
v. Future loss of earning capacity discounted to present value is
$291,976.05 (at 4%).
2. Defendant’s Issues:
The Defendants each deny that they were negligent or that the collision was
the proximate cause of any injuries or damages to Plaintiff. Defendant, Abe’s
Trash Service, Inc., admits that if Defendant, Christopher Skinner is found
4

negligent and his negligence proximately caused or contributed to causing the
accident and damages, it would be vicariously liable for any judgment against him,
provided Plaintiff is found to be less than fifty percent at fault in causing or
contributing to causing the collision.
The Defendants affirmatively allege that the collision was proximately
caused by the negligence and/or contributory negligence of the Plaintiff in one or
more of the following particulars: (a) In failing to keep a reasonable and proper
lookout; (b) By operating her vehicle at a speed that was too fast for the
circumstances then and there existing; (c) By failing to yield the right-of-way to
the vehicle operated by Defendant Skinner when she knew or should have known
said vehicle’s presence and dominant position in the intersection; (d) By failing to
bring her vehicle to a stop within her range of vision as required by Nebraska Law;
and (e) By failing to maintain reasonable and proper control of her vehicle.
The Defendants further affirmatively allege that the Plaintiff’s Complaint
fails to state a claim upon which relief may be granted as to any claim for negligent
entrustment and that the Plaintiff failed to mitigate her damages as required by
Nebraska Law.
The Defendants believe there is evidence supporting an inference that
Plaintiff was contributory negligent. (a) photographic evidence documents spilled
coffee in her car; (b) very long skid marks on the road; (c) extent of damage to the
front of Plaintiff’s vehicle; (d) no obstructed view; and (e) size and color of trash
truck.
The Defendant believes the evidence of Christopher Skinner’s past driving
record is not relevant and even if relevant, unfairly prejudicial under Rule 403.
Such evidence is not relevant for two primary reasons. (1) Defendant has admitted
it would be vicariously liable in the event of a judgment against Skinner.
Ultimately, Skinner must be found to be negligent for vicarious liability or in a
negligent entrustment theory. There is no evidence that Abe’s Trash did not know
or check Skinner’s driving record. Skinner’s driving record is insufficient as a
matter of law to support the theory of negligent entrustment.

5

(D) Witnesses. All witnesses, including rebuttal witnesses, expected to be
called to testify by plaintiff, except those who may be called for impeachment
purposes as defined in NECivR 16.2(c) only, are:
Vanessa Shultz
6602 W. Yellow Stone
Kennewick, WA 99336
[phone]
Jon Maine
6602 W. Yellow Stone
Kennewick, WA 99336
[phone]
Lynn Shultz
410 9th Street
Scribner, NE 68057
[phone]
Chris Shultz
401B Saint Francis Avenue
Nashville, TN 37205
[phone]
Christopher Skinner
307 W. Anderson St
Modale, IA 51556
[phone]
Abe’s Trash Service, Inc. by
Josh Christensen
8123 Christensen Ln
Omaha, NE 68122
[phone]
Deputy Russell Swanson S-318
Douglas County Sheriff’s Dept
3601 N. 72nd Street
6

Omaha, NE 68122
[phone]
Chris P. Mannel, Accident Reconstructionist
Nebraska Accident Reconstruction, LLC
19714 Woolworth Avenue
Omaha, NE 68130
[phone]
Rick Houlton, CFO (F)
Cornhusker International Trucks, Inc.
4502 South 110th Street
Omaha, NE 68137
[phone], ext 222
Nathaniel Vazquez
14211 Birchwood Circle
Omaha, NE 68137
[phone]
Misty Janssen, MD
Family Medicine
10109 Maple Street
Omaha, NE 68134
[phone]
Kairul Lehardi, ARNP
Kadlec Neuroscience Center
1100 Goethals Drive, Suite B
Richland, WA 99352
[phone]
Dr. Jessica Almaguear
Kadlec Clinic
9040 W. Clearwater Avenue
Kennewick, WA 99336
[phone]
Johnathan Perry, MD (Fact witness only per Memorandum and Order filed
7

on April 23, 2018. See Document 103.)
Tri-City Orthopaedics
6709 W. Rio Grande Avenue
Kennewick, WA 99336
[phone]
Tyler Shaw, PA-C (F)
Tri-City Orthopaedics
6709 W. Rio Grande Avenue
Kennewick, WA 99336
[phone]
Sheila Tyrell (F)
Oasis Physical Therapy
4303 W. 24th Ave, Suite B
Kennewick, WA 99338
[phone]
Daniel Shalom Powell, DPT (F)
Hughes Physical Therapy
3121 W. Kennewick Avenue
Kennewick, WA 99336
[phone]
Dr. Shannon Phipps, DO (F)
9040 W. Clearwater Avenue
Kennewick, WA 99336
[phone]
ER Staff, Kadlec Emergency Room (F)
3290 W. 19th Avenue
Kennewick, WA 99338
[phone]
Dr. Sittilerk Trikalsaransuk (F)
Tri-Cities Endoscopy Center
7114 W. Hood PL
Kennewik, WA 99336
[phone]
8

Shun Kwong, MD (F)
6901 North 72 Street
Omaha, NE 68122
[phone]
John Hogue, MD (F)
450 E. 23rd Street
Fremont, NE 68025
[phone]
John Knox, PT (F)
Del Norte Physical Therapy
440 L Street
Crescent City, CA 95531
[phone]
Dr. Stephen Trapani
1618 E. Isaacs Ave
Walla Walla, WA 99362
[phone]
Scott Roberts, RN (F)
3290 W. 19th Avenue
Kennewick, WA 99338
[phone]
Michael Dobson (F)
3810 Plaza Way
Kennewick, WA 99338
[phone]
All witnesses who may be called to testify by defendant, except those who
may be called for impeachment purposes as defined in NECivR 16.2(c) only, are:
See Defendant’s Witness List, attached.
9

It is understood that, except upon a showing of good cause, no witness
whose name and address does not appear herein shall be permitted to testify over
objection for any purpose except impeachment. A witness whose only testimony is
intended to establish foundation for an exhibit for which foundation has not been
waived shall not be permitted to testify for any other purpose, over objection,
unless such witness has been disclosed pursuant to Federal Rule of Civil Procedure
26(a)(3). A witness appearing on any party’s witness list may be called by any
other party.
(E) Expert Witnesses’ Qualifications. Experts to be called by plaintiff
and their qualifications are:
Chris P. Mannel (Accident Reconstructionist), see attached C.V.
Nebraska Accident Reconstruction, LLC
Address above
Treating doctors (non-retained experts), treated Plaintiff
Misty Janssen, MD (Defendants objects to this witness.)
Address above
Primary care physician who treated Plaintiff
Kairul Lehardi, ARNP (Defendants objects to this witness.)
Address above
Neurologist who treated Plaintiff
Dr. Jessica Almaguear (Defendants objects to this witness.)
Address above
Primary care physician who treated Plaintiff
Johnathan Perry, MD (Fact witness only per Memorandum and Order filed
on April 23, 2018. See Document 103.)
Address above
Orthopedic physician who treated Plaintiff
10

Dr. Stephen Trapani (Defendants objects to this witness.)
Address above
Chiropractor who treated Plaintiff
Defendant objects to All of the above-listed experts except Christopher
Mannel based upon this Court’s Order excluding experts, failure to comply with
expert witness disclosure rules and failing to supplement interrogatories requesting
expert opinion disclosures.
Experts who may be called by defendant and their qualifications are:
Scott Vincent, MD (Orthopedic Surgeon), see attached C.V.
University of Nebraska Medical Center
Department of Orthopedic Surgery & Rehabilitation
Address above
Bruce Gutnik, MD (Psychiatrist), see attached C.V.
Address above
(F) Voir Dire. Counsel have reviewed Federal Rule of Civil Procedure
47(a) and NECivR 47.2(a) and suggest the following with regard to the conduct of
juror examination: The attorneys shall conduct Voir Dire.
(G) Number of Jurors. Plaintiff has reviewed Federal Rule of Civil
Procedure 48 and NECivR 48.1 and suggest that this matter be tried to a jury
composed of 6 members.
Defendants have reviewed Federal Rule of Civil Procedure 48 and NECivR
48.1 and suggest that this matter be tried to a jury composed of 12 members.
(H)
verdict.

Verdict.

The parties will not stipulate to a less-than-unanimous
11

(I)
Briefs, Instructions, and Proposed Findings.
Counsel have
reviewed NECivR 39.2(a), 51.1(a), and 52.1, and suggest the following schedule
for filing trial briefs, proposed jury instructions, and proposed findings of fact, as
applicable: Unless otherwise ordered, trial briefs, proposed jury instructions, and
proposed findings of fact shall be filed five (5) working days before the first day of
trial.
(J) Length of Trial. Counsel estimate the length of trial will consume
not less than 2 day(s), not more than 5 day(s), and probably about 5 day(s).
Defendant believes that if the plaintiff actually calls the witnesses she lists, this
will be at least a five day trial and likely greater.
(K)

Trial Date. Trial is set for September 10, 2018.

/s/ James R. Walz
James R. Walz, #22497
Walz Law Offices, PC, LLO
2809 S. 160th Street, #101
Omaha, NE 68130
[phone]
[phone] (fax)
[e-mail]
Counsel for Plaintiff

/s/ Michael T. Gibbons
Michael T. Gibbons, #21263
Woodke & Gibbons, PC, LLO
619 N. 90th Street
Omaha, NE 68114
[phone]
[phone] (fax)
[e-mail]
Counsel for Defendants

BY THE COURT:

__________________________ 5-24-18

12

IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF NEBRASKA
VANESSA SHULTZ,
Plaintiff,

v.
ABE’S TRASH SERVICE, INC., and
CHRISTOPHER F. SKINNER,
Defendants.
Trial Dates:

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LIST OF EXHIBITS
Case Number: 8:16-cv-243
Courtroom Deputy: Marian Frahm
Court Reporter: Susan DeVetter

September 10, 2018

Plaintiff’s Exhibits
EXHIBIT NO.
PLF.

DEF.

3

NO.

NO.

PTY

1

2

3

4

5

6

DESCRIPTION

OFF

OBJ

RCVD

NOT

DATE

RCVD

State of Nebraska Investigator’s
Motor Vehicle Accident Report
dated April 6, 2016
Christopher Skinner guilty plea
and waiver dated April 17, 2016
Photos of accident scene and
both vehicles taken by Douglas
County Crime Lab on April 6,
2016
Photos of Plaintiff’s automobile
taken by Plaintiff after April 6,
2016
Photographs of Truck #143
taken by Plaintiff’s counsel on
November 9, 2017
Photos of intersection of
Highway 36 and 264th Street
taken on or before April 12,
2016

H,
R, F
H,
R, F
403
X

5-23-18

X

5-23-18

X

5-23-18

R,
H,
403

7
8

9

10

11

12

13

14
15
16

17

18

19

20

21

22

Run Report from Valley Fire
and Rescue dated April 6, 2016
Medical records from Immanuel
Medical Center dated April 6,
2016
Billing records from Immanuel
Medical Center dated April 6,
2016
Billing
Statements
from
Radiology Consultants dated
April 6, 2016
Billing
statements
from
Emergency Clinician Associates
dated April 6, 2016
Medical records from Fremont
Area Medical Center dated
April 9, 2016
Billing records from Fremont
Area Medical Center dated
April 9, 2016
Billing records from Dr. John H.
Hogue, dated April 9, 2016
Billing records from General
Radiology dated April 9, 2016
Medical records from Dr. Misty
Janssen, dated April 12, 2016 to
September 26, 2016
Billing records from Dr. Misty
Janssen, dated April 12, 2016 to
September 26, 2016
Medical records from Del Norte
Physical Therapy dated June 3,
2016 to July 14, 2016
Billing records from Del Norte
Physical Therapy dated June 3,
2016 to July 14, 2016
Medical records from Dr.
Stephen Trapani, dated June 27,
2016 to August 8, 2016
Billing records from Dr.
Stephen Trapani, dated June 27,
2016 to August 8, 2016
Medical
records
from
Kennewick General Hospital

-2-

R,
H, F
R,
H,
F, O
R,
H, F
R,
H, F
R,
H, F
R,
H,
F,O
R,
H, F
R,
H, F
R,
H, F
R,
H,
F,O
R,
H, F
R,
H,
F,O
R,
H, F
R,
H,
F,O
R,
H, F
R,
H,

23

24

25
26

27

28

29

30

31

32

33

34

35

dated September 1, 2016 to
September 15, 2016
Billing records from Kennewick
General
Hospital
dated
September 1, 2016 to September
15, 2016
Billing records from Kennewick
Radiology
Group
dated
September 1, 2016 to September
15, 2016
Receipt from back to life
massage dated October 3, 2016
Medical records from Kadlec
Emergency
Center
dated
October 11, 2016
Billing records from Kadlec
Emergency
Center
dated
October 11, 2016
Medical records from Kadlec
Neuroscience Center dated
February 14, 2017 to August 1,
2017
Billing records from Kadlec
Neuroscience Center dated
February 14, 2017 to August 1,
2017
Medical records from Dr.
Jessica
Almaguer,
dated
February 15, 2017 to present
Medical records from Dr.
Shannon Phipps, dated October
10, 2017 to present
Billing records from Dr. Jessica
Almaguer and Dr. Shannon
Phipps, dated February 15, 2017
to present
Medical records from Tri City
Orthopaedics, dated February
21, 2017 to present
Billing records from Tri City
Orthopaedics, dated February
21, 2017 to present
Medical records from Oasis
Physical Therapy, dated March

-3-

F,O
R,
H, F

R,
H, F

R,
H, F
R,
H,
F,O
R,
H, F
R,
H,
F,O
R,
H, F

R,
H,
F,O
R,
H,
F,O
R,
H, F

R,
H,
F,O
R,
H, F
R,
H,

36

37

38

39

40

41

42

43

44
45

46

47

48

7, 2017 to June 8, 2017
Billing records from Oasis
Physical Therapy, dated March
7, 2017 to June 8, 2017
Medical records from Hughes
Physical Therapy, dated July 25,
2017 to present
Billing records from Hughes
Physical Therapy, dated July 25,
2017 to present
Medical records from Kadlec
Medical
Center,
dated
November 17, 2017
Billing records from Kadlec
Medical
Center,
dated
November 17, 2017
Billing records from Kadlec ER
Physicians, dated November 17,
2017
Billing records from Columbia
Basin Imaging, dated November
17, 2017
Medical records from Kadlec
ER, dated April 19, 2018
Billing records from Kadlec ER,
dated April 19, 2018
Medical records from Dr.
Sittilerk Trikalsaransukh, dated
April 20, 2018
Billing records from Dr.
Sittilerk
Trikalsaransukh/TriCity Endoscopy Center, dated
April 20, 2018
Functional Capacity Evaluation
performed by Jennifer Beran
dated December 8, 2017

Ergonomics Analysis performed
by Pramila Kalaga dated Januar
3, 2018

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F,O
R,
H, F
R,
H,
F,O
R,
H, F
R,
H,
F,O
R,
H, F
R,
H, F
R,
H, F
R,
H,
F,O
R,
H, F
R,
H,
F,O
R,
H, F

R,
H,
F,
403,
0
R,
H,
F,
403,
0

49

Prescription
records
from
Walgreens, dated April 6, 2016
to present

50

Letter
from
Plaintiff’s
Physician, Dr. Jonathan Perry
dated May 30 2017

51

Price report for 2003 Mazda6
V6
Correspondence from City of
Omaha
Law
Department
concerning impound fees for
Plaintiff’s vehicle dated June 27,
2016
Documentation from Sutter
Business Services concerning
terms of car loan for Plaintiff’s
replacement vehicle
Plaintiff’s
itemization
of
mileage expenses incurred due
to loss of vehicle
Invoice from Enterprise Rent-ACar dated April 12, 2015;
Correspondence from
CHI
Health concerning Plaintiff’s
wage loss dated June 9, 2016
Correspondence from Medical
Solutions concerning Plaintiff’s
wage loss dated May 19, 2016
Plaintiff’s
request
and
documentation for FMLA leave
Plaintiff’s tax return from tax
year 2011
Plaintiff’s tax return from tax
year 2012
Plaintiff’s tax return from tax
year 2013
Plaintiff’s tax return from tax
year 2014
Plaintiff’s tax return from tax
year 2015

52

53

54

55
56

57

58
59
60
61
62
63

-5-

R,
H,
F,
403,
0
R,
H,
F,
403,
0
R,
H, F
R,
H, F

R,
H, F

R,
H, F
R,
H, F
R,
H, F
R,
H, F
R,
H, F
R,
H, F
R,
H, F
R,
H, F
R,
H, F
R,
H, F

64
65
66
67
68
69

70

71

72

73

74

75

76

77

Plaintiff’s tax return from tax
year 2016
Plaintiff’s W-2 Statements from
tax year 2016
Plaintiff’s tax return from tax
year 2017
Life expectancy table
Plaintiff’s
itemization
of
damages
Transcript
of
Plaintiff’s
recorded statement taken by
Defendant’s
Insurance
Company dated April 12, 2016
All safety and procedure
manuals used by employees of
Abe’s Trash Service, Inc.
Defendant, Abe’s Trash Service,
Inc’s Answers to Plaintiff’s First
Set of Interrogatories
Facebook business review by
Nate Vazquez of Abe’s Trash
Services, Inc. dated May 18,
2016
Defendant,
Christopher
Skinner’s Answers to Plaintiff’s
First Set of Interrogatories
Defendants, Abe’s Trash and
Christopher Skinner’s Answers
to Plaintiff’s Second Set of
Interrogatories
Defendant,
Christopher
Skinner’s
responses
to
Plaintiff’s First Set of Request
for Admissions
Defendant,
Christopher
Skinner’s
responses
to
Plaintiff’s Second Set of
Request for Admissions
Defendant,
Christopher
Skinner’s
responses
to
Plaintiff’s Third Set of Request
for Admission

-6-

R,
H, F
R,
H, F
R,
H, F
R,
H, F
R,
H, F
R,
H, F

R,
H,
F,
403
R,
H,
403
R,
H,
F,
403
R,
H,
403
R,
H,
403
R,
H,
403
R,
H,
403
R,
H,
403

78

79
80
81
82
83

84

85

86

87

88
89

Defendant’s
Mandatory
Disclosures filed August 25,
2016
Report from Plaintiff’s expert
witness, Chris Mannel
Curriculum Vitae of Plaintiff’s
expert witness, Chris Mannel
Deposition
of
Christopher
Skinner
Deposition of Vanessa Shultz
Eyeglasses prescription for
Christopher
Skinner
dated
September 6, 2013
Eyeglasses prescription for
Christopher
Skinner
dated
September 2, 2017
Time clock slips for Christopher
Skinner from pay period ending
March 12, 2016 to pay period
ending April 9, 2016
Inspection and maintenance logs
for vehicle #143 verified by
Josh Christensen
Repair records for vehicle #143
from Cornhusker International
Trucks, Inc.
Exhibit #34 from deposition of
Christopher Skinner
Photographs of Abe’s Garbage
Truck taken by Plaintiff counsel
on December 19, 2017

-7-

R,
H,
403
R,
H, F
X
R,
H, O
R,
H, O
R, F,
H
R,H,
F
R,
H, F

R,
H,
F,
403
R,
H,
403
R
R,
H,
F,
403

5-23-18

Defendant’s Exhibits
EXHIBIT NO.

PLF

DF

3 PTY

DESCRIPTION

OFF

OBJ

RCVD

NOT RCVD

DATE

101

E1 to Plaintiff’s Deposition-color
photograph

X

5-23-18

102

E3 to Plaintiff’s Deposition-color
photograph

X

5-23-18

103

E3 to Plaintiff’s Deposition-color
photograph

X

5-23-18

104

E4 to Plaintiff’s Deposition-color
photograph

X

5-23-18

105

E5 to Plaintiff’s Deposition-color
photograph

X

5-23-18

106

E6 to Plaintiff’s Deposition –
American Chiropractic Clinic
Patient Information Form (5
pages)

H,R,
403

107

E7 to Plaintiff’s Deposition – Dr.
Stephen Trapani Letter to
Kennewick General Hospital
dated 2/16/2007

H, R,
403

108

E8 to Plaintiff’s Deposition –
Assessment dated 6/1/5/2007

H, R,
403

109

E9 to Plaintiff’s Deposition –
Kennewick General Hospital
Documented Notice of
Performance/Behavioral
Concern

H, R,
403

-8-

110

E10 to Plaintiff’s Deposition –
Kaiser Permanente Medical
Record dated 12/20/2010

X

5-23-18

111

E11 to Plaintiff’s Deposition –
Kaiser Permanente Medical
Record dated 5/31/2011

X

5-23-18

112

E12 to Plaintiff’s Deposition –
Kaiser Permanente Medical
Record dated 6/09/2011 (2
pages)

X

5-23-18

113

E13 to Plaintiff’s Deposition –
Kaiser Permanente Medical
Record dated 0/26/2011 (3
pages)

X

5-23-18

114

E14 to Plaintiff’s Deposition –
Kaiser Permanente Medical
Record dated 2/06/2012

X

5-23-18

115

E15 to Plaintiff’s Deposition –
Kaiser Permanente Medical
Record dated 2/06/2012

X

5-23-18

116

E16 to Plaintiff’s Deposition –
Kaiser Permanente Medical
Record dated 2/14/2012

X

5-23-18

117

E17 to Plaintiff’s Deposition –
Kaiser Permanente Medical
Record dated

X

5-23-18

X

5-23-18

12/29/2012 (2 pages)
118

E18 to Plaintiff’s Deposition –
Kaiser Permanente Medical
Record dated 1/14/2013 (2
pages)

-9-

119

E19 to Plaintiff’s Deposition –
CHI Health – ACH Maple Hills
Medical Clinic Medical Record
dated 8/08/2014 (2 pages)

X

5-23-18

120

E20 to Plaintiff’s Deposition –
CHI Health – ACH Maple Hills
Medical ClinicMedical Record
dated 8/12/2014

X

5-23-18

121

E21 to Plaintiff’s Deposition –
CHI Health – ACH Maple Hills
Medical Clinic Medical Record
dated 4/02/2015

X

5-23-18

122

E22 to Plaintiff’s Deposition –
CHI Health – ACH Maple Hills
Medical Clinic Medical Record
dated 1/18/2016

X

5-23-18

123

E23 to Plaintiff’s Deposition –
CHI Health – ACH Maple Hills
Medical Clinic Medical Record
dated 3/23/2016

X

5-23-18

124

E24 to Plaintiff’s Deposition CHI Health – ACH Maple Hills
Medical Clinic Medical Record
dated 3/23/2016

X

5-23-18

125

Transcript of Plaintiff’s
Deposition taken 8/31/2017 (77
pages)

126

Color Photograph at accident
scene depicting vehicles looking
south

X

5-23-18

127

Color Photograph at accident
scene of Plaintiff’s vehicle
looking west

X

5-23-18

-10-

R, 403

128

Color Photograph at accident
scene of Plaintiff’s vehicle
looking northwest

X

5-23-18

129

Color Photograph at accident
scene of Plaintiff’s vehicle
looking

X

5-23-18

130

Color Photograph at accident
scene of Plaintiff’s vehicle
looking northeast

X

5-23-18

131

Color Photograph at accident
scene of Plaintiff’s vehicle
looking east

X

5-23-18

132

Color Photograph at accident
scene of Plaintiff’s vehicle
looking southeast

X

5-23-18

133

Color Photograph at accident
scene of Plaintiff’s vehicle
looking in from passenger side
front

X

5-23-18

134

Color Photograph at accident
scene of Plaintiff’s vehicle
looking toward at inside of
Driver’s door and in toward the
driver’s side

X

5-23-18

135

Color Photograph at accident
scene of Plaintiff’s vehicle
looking in from driver’s side
front

X

5-23-18

136

Color Photograph at accident
scene of Plaintiff’s vehicle
looking down at inside front
driver’s side

X

5-23-18

-11-

137

Color Photograph at accident
scene of Defendant, Abe’s Trash
Service vehicle of rear of vehicle

X

5-23-18

138

Color Photograph at accident
scene of Defendant, Abe’s Trash
Service vehicle of Driver’s side
and rear looking southwest

X

5-23-18

139

Color Photograph at accident
scene of Defendant, Abe’s Trash
Service vehicle of Driver’s side
looking west

X

5-23-18

140

Color Photograph at accident
scene of rear half of Defendant,
Abe’s Trash Service Vehicle and
Plaintiff’s vehicle showing front
and driver’s side looking
northwest

X

5-23-18

141

Color Photograph blow up-close
in of E140

X

5-23-18

142

Color Photograph at accident
scene of Defendant, Abe’s Trash
Service vehicle front and driver’s
side looking northwest

X

5-23-18

143

Color Photograph at accident
scene of Defendant, Abe’s Trash
Service vehicle front and
passenger’s side looking
northeast

X

5-23-18

144

Color Photograph at accident
scene looking north at the
Defendant, Abe’s Trash Service
truck, Plaintiff’s vehicle and
north

X

5-23-18

-12-

145

Color Photograph at accident
scene of Defendant, Abe’s Trash
Service Truck of passenger side
of vehicle looking southeast

X

5-23-18

146

Color Photograph at accident
scene of Defendant, Abe’s Trash
Service Truck of passenger side
rear axel, tire and truck

X

5-23-18

147

Color Photograph at accident
scene of Defendant, Abe’s Trash
Service Truck of rear passenger
side step at rear of truck

X

5-23-18

148

Color Photograph at accident
scene of Defendant, Abe’s Trash
Service Truck looking Down at
rear passenger side step with
damage depicted

X

5-23-18

149

Color Photograph at accident
scene of Defendant, Abe’s Trash
Service Truck looking at rear and
passenger side facing southeast

X

5-23-18

150

Color Photograph at accident
scene of Plaintiff’s vehicle
driver’s side looking west

X

5-23-18

151

American Chiropractic Clinic
Records for Plaintiff (Bates
Stamped 0051-0054) 2/13/2007
(4 pages)

H, R,
403

152

CHI Health - Lasting Hope
Recovery Center (Bates
Stamped 02209- 02219, 0222702342 (9/03-04/2014 – 127
pages)

H, R,
403

-13-

153

Roger Roubal, DDS records for
Plaintiff (Bates Stamped 02760286) (11 pages)

154

General Health Cooperative
(Kaiser Permanente )medical
records for Plaintiff (bates
stamped 0448, 0449, 0458,
0459, 0460, 0461, 0462, 0465,
0466, 0469, 0470, 0471, 0472,
0473, 0474, 0475, 0476, 0477,
0478, 0479, 0480, 0481, 0483,
0484, 0485, 0486, 0487, 0488,
0494, 0495, 0505, 0518, 0519,
0520, 0526, 0527, 0528, 0535,
0536, 0537, 0542, 0543, 0546,
0553, 0557, 0558, 0603, 0604,
0613, 0614, 0615, 0623, 0624,
0655, 0656, 0658, 0659. (57
pages)

X

5-23-18

155

CHI Health- ACH- Immanuel
Medical Center records for
Plaintiff (bates stamped 0888,
0889, 0890, 0893, 0912, 0915,
0921, 0922, 0935, 0936, 0944.
(11 pages)

X

5-23-18

156

Kennewick General Hospital
employment records for Plaintiff
(bates stamped 1068, 1069,
1075, 1076, 1077, 1078, 1079,
1080. (8 pages)

X

5-23-18

157

Johnathan Perry, MD medical
record for Plaintiff dated
2/21/2017 (3 pages)

X

5-23-18

158

Kennewick General Hospital
medical records for Plaintiff
bates stamped 1390, 1391,

X

5-23-18

-14-

H, R,
403

1392, 1417, 1418, 1419, 1420,
1460, 1584. (9 pages)
159

Carlson Counseling Services
records (7 pages)

H, R

160

Lutheran Family Service records

H, R

161

Curriculum Vitae of Scott
Vincent, MD

162

Curriculum Vitae of Bruce
Gutnik, MD

X

R

OBJECTIONS:
R: Relevancy
H: Hearsay
A: Authenticity
O: Other (specify)

-15-

5-23-18

Chris P. Mannel
Nebraska Accident Reconstruction, LLC

Curriculum Vitae

Mailing Address

19714 Woolworth Avenue, Omaha, Nebraska 68130

Voice

Cellular 402.750.6433

Email

[e-mail]

Web

www.nar-llc.com

1 of 15

Chris P. Mannel: CV

April, 2017

Work Experience
2006 - Current

Nebraska Accident Reconstruction, LLC
Traffic Crash Consultation Services
Founding Member
Photography, Animation & Technical Services Specialist
NLETC Accident Course Instructor, CAD Software Instructor

2001 - Current

Pixel Engineering / Digital Creations
Technology Services Company
Computer repair / Network installation
Photography / Graphic design and print work
Website development and management

2012 - 2016

Werner Enterprises, Inc.
Transportation and Logistics Corporation
Safety Specialist Supervisor
Catastrophic Loss Team
HAZMAT Specialist
FMCSA Regulation Specialist
Information Technology Services Department

1997 to 1999

State of Nebraska
Nebraska State Patrol - Carrier Enforcement Division
Carrier Enforcement Officer
Enforcment of Size and Weight Restrictions on Commercial Motor Vehicles
Enforcement of Federal Motor Carrier Safety Regulations
CVSA North American Standard Level I Inspections
CVSA North American HAZMAT Inspection Certification

1999 - 2012

State of Nebraska
Nebraska State Patrol - Traffic Services Division
State Trooper
Accident Investigation Instructor
Crash Reconstruction Specialist
Court Recognized Expert Witness
Forensic Mapping and Diagramming software Instructor

Confidential

2 of 15

Page 2 of 5
!
!

Chris P. Mannel: CV

April, 2017

Crash Reconstruction Certifications
2005

ACTAR Full Accreditation - Certificate #1634
Accreditation Commission for Traffic Accident Reconstruction

2004

Accident Reconstruction Specialist Certification
Institute of Police Technology and Management

2003

Technical Accident Investigation Certification
Institute of Police Technology and Management

2002

Advanced Accident Investigation Certification
Institute of Police Technology and Management

2001

Intermediate Accident Investigation Certification
Institute of Police Technology and Management

Education
2011 - 2012

Web Design and Interactive Media Study
Art Institute of Pittsburgh
Studied website and design principles

1996 - 1997

Criminal Justice Major
University of Nebraska at Omaha
Criminal justice studies

1995 - 1996

Criminal Justice Major
Metropolitan Community College
Criminal justice studies
Transfer

1993 - 1995

Political Science Major / Criminal Justice Minor
Iowa State University
Transfer

Ongoing
education

Memberships / Clubs
Current Member
Midwest Association of Technical Accident Investigators (2002)

Confidential

3 of 15

Page 3 of 5
!
!

Chris P. Mannel: CV

April, 2017

Specialty Certifications
2013

EDR Heavy Truck Data Retrieval
Preserving and Analyzing Information from Heavy Vehicle EDRs
Northwestern Center for Public Safety, Northwestern University — 40 hours

2008

Crash Data Retrieval (CDR) Technician and Analyst
Preserving and Analyzing Information from Heavy Vehicle EDRs
Lincoln Police Department, Lincoln, NE — 40 hours

2007

Crash Zone Forensic Diagramming CAD Software Instructor
Certification for course instruction

2006

Crash Zone Forensic Diagramming (Basic & Advanced)
Northeast Community College, Norfolk, NE — 32 hours

2003

SOKKIA Total Station / MapScenes CAD Software
NLETC, Grand Island, NE — 40 hours

Confidential

4 of 15

Page 4 of 5
!
!

Chris P. Mannel: CV

April, 2017

References / Addendum
The people listed here are quite willing to be contacted and/or send a written recommendation. Please get in touch with me to
arrange for references to be sent or to provide you with contact information.
Attorney

Dr. Patrick Cullan
Cullan & Cullan, LLC
1113 Harney Street
Omaha NE 68102

Detailed Lists
Available by
request

Career Achievements / Specialized Training Courses / Course Instruction
The following items can be requested as addendum to this CV if required:
Specialized Training Outline (including dates and locations)
- Hundreds of hours of coursework related to crash investigation and instruction
Career Achievements
- Detail of State Patrol related achievements as well as details of numbers of crash
investigations to date
Crash Course Instruction Outline
- Detail of nearly 600 hours of instruction time related to the topic of crash investigation

Expert Witness Testimony
Log of court cases where this witness has been qualified by the court to testify his opinions based on the investigation and
analysis. All cases were based in Nebraska.

2017

Private NAR Case Analysis - Traffic Crash - Deposition
Lincoln, NE
(Kimminau vs. County of Adams)

2014

Private NAR Case Analysis - Traffic Crash - Trial
US District Court - Omaha, NE
(Moyle v. Concrete Industries)

2013

Private NAR Case Analysis - Traffic Crash - Deposition
US District Court - Omaha, NE
(Moyle v. Concrete Industries)

2011

Private NAR Case Analysis - Traffic Crash - Trial
Butler County Court, Nebraska
(Moore v. GT Express, LLC)

2010

Nebraska State Patrol - Police Pursuit - Grand Jury
Butler County Court, Nebraska

2010

Private NAR Case Analysis - Traffic Crash - Trial
Lancaster County Court, Nebraska
(Horn v. Novacek)

2010

Private NAR Case Analysis - Traffic Crash - Trial
Lancaster County Court, Nebraska
(SSC v. Snuttjer)

2005

Nebraska State Patrol - Police Pursuit - Grand Jury
Platte County Court, Nebraska

Confidential

5 of 15

Page 5 of 5
!
!

Chris P. Mannel
Nebraska Accident Reconstruction, LLC

Curriculum Vitae
Addendum

Mailing Address

19714 Woolworth Avenue, Omaha, Nebraska 68130

Voice

Cellular 402.750.6433

Email

[e-mail]

Web

www.nar-llc.com

6 of 15

Chris P. Mannel: CV - Addendum

July, 2017

SPECIALIZED TRAINING
Dates

Course Title

Course Location / Hours

June 2017

MATAI Conference - Various Topics

Wisconsin Dells, WI — 17 hours

March 2017

EDR Summit Conference

Houston, TX — 24 hours

March 2013

Preserving and Analyzing Information from Heavy Vehicle EDRs

Northwestern Center for Public Safety
Evanston, IL – 40 hours

March 2012

December 2010

CDR Summit Conference

Houston, TX — 19 hours

Applied Physics for the Traffic Crash Investigator

Institute of Police Technology and Management (IPTM)
Grand Island, NE – 40 hours

August 2009

Advanced Commercial Vehicle Crash Investigation

Institute of Police Technology and Management (IPTM)
Grand Island, NE – 40 hours

July 2009

Inspection and Investigation of Commercial Vehicle Crashes

Institute of Police Technology and Management (IPTM)
Grand Island, NE – 40 hours

May 2009

Traffic Accident Reconstruction Conference

Midwest Association of Technical Accident Investigators
Wisconsin Dells, WI – 20 hrs

November 2008

Energy Methods (Crush Analysis) Practical Exercise

Nebraska State Patrol
Norfolk, NE – 10 hrs

June 2008

May 2008

Energy Methods in Traffic Crash Reconstruction
(Crush Analysis)

Institute of Police Technology and Management (IPTM)

Traffic Accident Reconstruction Conference

Midwest Association of Technical Accident Investigators

St. Peters, MO – 40 hours

St. Paul, MN – 20 hrs
January 2008

Human Factors in Traffic Crash Reconstruction

Accident Dynamics Research Center Jeff Mutart
St. Paul, MN – 40 hrs

August 2006

Commercial Vehicle Air Brakes Update Training

Nebraska Law Enforcement Training Center
Grand Island, NE — 8 hours

June 2006

June 2006

CAD Zone - Crash Zone - Computer Aided Diagramming Advanced Course

Specialized Training Course

Traffic Accident Reconstruction Conference

Midwest Association of Technical Accident Investigators

Norfolk, NE – 10 hrs

28 hrs
June 2005

Traffic Accident Reconstruction Conference

Midwest Association of Technical Accident Investigators
20 hrs

June 2004

Traffic Accident Reconstruction Conference

Midwest Association of Technical Accident Investigators
20 hrs

Confidential

7 of 15

Page 2 of ! 4
!

Chris P. Mannel: CV - Addendum

July, 2017

Specialty Certifications
2013

EDR Heavy Truck Data Retrieval
Preserving and Analyzing Information from Heavy Vehicle EDRs
Northwestern Center for Public Safety, Northwestern University — 40 hours

2008

Crash Data Retrieval (CDR) Technician and Analyst
Preserving and Analyzing Information from Heavy Vehicle EDRs
Lincoln Police Department, Lincoln, NE — 40 hours

2007

Crash Zone Forensic Diagramming CAD Software Instructor
Certification for course instruction

2006

Crash Zone Forensic Diagramming (Basic & Advanced)
Northeast Community College, Norfolk, NE — 32 hours

2003

SOKKIA Total Station / MapScenes CAD Software
NLETC, Grand Island, NE — 40 hours

Career Achievements
2011

Nebraska State Patrol
Trooper of the Year Award
Development of highway fatality tracking system using Google Earth technology
Advancement of NLETC Accident Investigation curriculum

2008

Nebraska State Patrol
Distinguished Service Award
Development of Public Seatbelt Safety Display

2005 - 2013

Crash Investigation Courses Instructor
Nebraska Law Enforcement Training Center

Since 2004

Active membership with Midwest Association of Accident Investigators

Career Investigations
Since

Approximate

2003

90

Traffic Crash Reconstruction Investigations

1999

94

Fatality Crash Investigations

1997

300

Personal Injury Crash Investigations

2003

55

Total Station Accident Scene Maps

2003

4

Total Station Crime Scene Maps

Confidential

Description

8 of 15

Page 3 of ! 4
!

Chris P. Mannel: CV - Addendum

July, 2017

Crash Instruction Hours
Date
May-17
March-17
July-16
March-16
Apr-13
Apr-12
Aug-11
May-11
Apr-11
Oct-10
Aug-10
Apr-10
May-09
Apr-09
Apr-09
Dec-08
Nov-08
Aug-08
Jul-08
Apr-08
Mar-08
Feb-08
Dec-07
Jun-07
May-07
Apr-07
Mar-07
Dec-06
Aug-06
Apr-06
Dec-05
May-05

Course Details
NLETC Advanced Accident Investigation - Primary Instructor
NLETC Intermediate Accident Investigation - Primary Instructor
NLETC Intermediate Accident Investigation - Primary Instructor
NLETC Technical Accident Investigation - Instructor and Course Advisor
NLETC Intermediate Accident Investigation - Instructor and Course Advisor
NLETC Intermediate Accident Investigation - Instructor and Course Advisor
NLETC Advanced Accident Investigation - Student Assistant and Instructor
NLETC Technical Accident Investigation - Instructor and Course Advisor
NLETC Intermediate Accident Investigation - Instructor and Course Advisor
NSP Basic Academy Class #52 - Scene Photography/Diagramming
NLETC Advanced Accident Investigation - Student Assistant and Instructor
NLETC Intermediate Accident Investigation - Instructor and Course Advisor
NLETC Technical Accident Investigation - Instructor and Course Advisor
NLETC Intermediate Accident Investigation - Instructor and Course Advisor
NAR Cad Zone & Total Station Class - Instructor
NSP Total Station & Crash Zone (CAD) - Student Asst. and Instructor
NSP Accident Reconstruction InService (Night Time Photo) - Lead Instructor
NLETC Advanced Accident Investigation - Student Assistant and Instructor
NSP InService Basic Computer Diagramming - Lead Instructor
NLETC Intermediate Accident Investigation - Student Assistant and Instructor
NSP InService - Easy Street Draw accident diagramming courses
Basic Computer Diagramming Train the Trainer - Assistant Instructor
NSP Basic Academy Class #52 - Scene Photography/Diagramming
NLETC Intermediate Accident Investigation - Student Assistant
Technical Accident Investigation - Student Assistant & Instructor
NLETC Basic Recruit Accident Investigation Practical - Student Assistant
NSP InService Accident Investigation - Instructor
NSP Basic Academy Class #51 - Scene Photography/Diagramming
NLETC Basic Recruit Accident Investigation Practical
Intermediate Accident Investigation - Assistant
NSP Basic Academy Class #50 - Scene Photography/Diagramming
Technical Accident Investigation NLETC Assistant
Total

Confidential

Hours
40
40
40
16
10
20
22
30
8
32
22
40
60
40
24
40
4
22
4
11
16
4
20
16
32
8
8
20
16
24
20
20
709

9 of 15

Page 4 of ! 4
!

Chris P. Mannel
Nebraska Accident Reconstruction, LLC

Curriculum Vitae

Mailing Address

19714 Woolworth Avenue, Omaha, Nebraska 68130

Voice

Cellular 402.750.6433

Email

[e-mail]

Web

www.nar-llc.com

10 of 15

Chris P. Mannel: CV

July, 2017

Work Experience
2006 - Current

Nebraska Accident Reconstruction, LLC
Traffic Crash Consultation Services
Founding Member
Photography, Animation & Technical Services Specialist
NLETC Accident Course Instructor, CAD Software Instructor

2001 - Current

Pixel Engineering / Digital Creations
Technology Services Company
Computer repair / Network installation
Photography / Graphic design and print work
Website development and management

2012 - 2016

Werner Enterprises, Inc.
Transportation and Logistics Corporation
Safety Specialist Supervisor
Catastrophic Loss Team
HAZMAT Specialist
FMCSA Regulation Specialist
Information Technology Services Department

1997 to 1999

State of Nebraska
Nebraska State Patrol - Carrier Enforcement Division
Carrier Enforcement Officer
Enforcment of Size and Weight Restrictions on Commercial Motor Vehicles
Enforcement of Federal Motor Carrier Safety Regulations
CVSA North American Standard Level I Inspections
CVSA North American HAZMAT Inspection Certification

1999 - 2012

State of Nebraska
Nebraska State Patrol - Traffic Services Division
State Trooper
Accident Investigation Instructor
Crash Reconstruction Specialist
Court Recognized Expert Witness
Forensic Mapping and Diagramming software Instructor

Confidential

11 of 15

Page 2 of 6
!
!

Chris P. Mannel: CV

July, 2017

Crash Reconstruction Certifications
2005

ACTAR Full Accreditation - Certificate #1634
Accreditation Commission for Traffic Accident Reconstruction

2004

Accident Reconstruction Specialist Certification
Institute of Police Technology and Management

2003

Technical Accident Investigation Certification
Institute of Police Technology and Management

2002

Advanced Accident Investigation Certification
Institute of Police Technology and Management

2001

Intermediate Accident Investigation Certification
Institute of Police Technology and Management

Education
2011 - 2012

Web Design and Interactive Media Study
Art Institute of Pittsburgh
Studied website and design principles

1996 - 1997

Criminal Justice Major
University of Nebraska at Omaha
Criminal justice studies

1995 - 1996

Criminal Justice Major
Metropolitan Community College
Criminal justice studies
Transfer

1993 - 1995

Political Science Major / Criminal Justice Minor
Iowa State University
Transfer

Ongoing
education

Memberships / Clubs
Current Member
Midwest Association of Technical Accident Investigators (2002)

Confidential

12 of 15

Page 3 of 6
!
!

Chris P. Mannel: CV

July, 2017

Specialty Certifications
2013

EDR Heavy Truck Data Retrieval
Preserving and Analyzing Information from Heavy Vehicle EDRs
Northwestern Center for Public Safety, Northwestern University — 40 hours

2008

Crash Data Retrieval (CDR) Technician and Analyst
Preserving and Analyzing Information from Heavy Vehicle EDRs
Lincoln Police Department, Lincoln, NE — 40 hours

2007

Crash Zone Forensic Diagramming CAD Software Instructor
Certification for course instruction

2006

Crash Zone Forensic Diagramming (Basic & Advanced)
Northeast Community College, Norfolk, NE — 32 hours

2003

SOKKIA Total Station / MapScenes CAD Software
NLETC, Grand Island, NE — 40 hours

Confidential

13 of 15

Page 4 of 6
!
!

Chris P. Mannel: CV

July, 2017

References / Addendum
The people listed here are quite willing to be contacted and/or send a written recommendation. Please get in touch with me to
arrange for references to be sent or to provide you with contact information.
Attorney

Dr. Patrick Cullan
Cullan & Cullan, LLC
1113 Harney Street
Omaha NE 68102

Detailed Lists
Available by
request

Career Achievements / Specialized Training Courses / Course Instruction
The following items can be requested as addendum to this CV if required:
Specialized Training Outline (including dates and locations)
- Hundreds of hours of coursework related to crash investigation and instruction
Career Achievements
- Detail of State Patrol related achievements as well as details of numbers of crash
investigations to date
Crash Course Instruction Outline
- Detail of nearly 600 hours of instruction time related to the topic of crash investigation

Expert Witness Testimony
Log of court cases where this witness has been qualified by the court to testify his opinions based on the investigation and
analysis. All cases were based in Nebraska.

2017

Private NAR Case Analysis - Traffic Crash - Trial
Hastings, NE
(Kimminau vs. County of Adams) - Adams County District Court

2017

Private NAR Case Analysis - Traffic Crash - Deposition
Lincoln, NE
(Moore vs. Lanza) - Rock County

2017

Private NAR Case Analysis - Traffic Crash - Deposition
Lincoln, NE
(Kimminau vs. County of Adams) - Adams County

2014

Private NAR Case Analysis - Traffic Crash - Trial
US District Court - Omaha, NE
(Moyle v. Concrete Industries)

2013

Private NAR Case Analysis - Traffic Crash - Deposition
US District Court - Omaha, NE
(Moyle v. Concrete Industries)

2011

Private NAR Case Analysis - Traffic Crash - Trial
Butler County Court, Nebraska
(Moore v. GT Express, LLC)

2010

Nebraska State Patrol - Police Pursuit - Grand Jury
Butler County Court, Nebraska

2010

Private NAR Case Analysis - Traffic Crash - Trial
Lancaster County Court, Nebraska
(Horn v. Novacek)

Confidential

14 of 15

Page 5 of 6
!
!

Chris P. Mannel: CV

July, 2017

2010

Private NAR Case Analysis - Traffic Crash - Trial
Lancaster County Court, Nebraska
(SSC v. Snuttjer)

2005

Nebraska State Patrol - Police Pursuit - Grand Jury
Platte County Court, Nebraska

Confidential

15 of 15

Page 6 of 6
!
!