ZIMAND v. VOLKSWAGEN AKTIENGESELLSCHAFT et al

Filing 49

OPINION. Signed by Judge Jose L. Linares on 5/8/2017. (JB, )

UNITED STATES DISTRICT COURT
DISTRICT OF NEW JERSEY

QUIFMAN ROBINSON.

Plaintiff,

:

Civil Action No, 2: 14 Civ. 2679 (SRC)

against
NEW JERSEY TRANSIT RAIL
OPERATIONS, INC.

HNAL PRETRIAl. ORF)ER

Defendant

A pretrial conference* having been held before the Honorable Cathy L Waldor,
U.S.M.J., Marc Wietzke having appeared for plaintiff(s) and
Grego Sullivan _having
appeared for defendant(s), this Final Pretrial Order is hereby entered:

[PRECEDE WITH DIVIDER #1]

1.

JURISDICTION (set foih specifically)

45 U.S.C. §51 et seq. uncontested
-

[PRECEDE WITH DIVIDER #2]

2,
PENDING/CONTEMPLATED MOTIONS (Set forth all pending or contemplated
motions, whether dispositive or addressed to discovery or the calendar. Also set forth the nature
of the motion, if the Court indicated that it would rule on any matter at pretrial, summarize that
matter and each party’s position contemplated in limine motions should also be set forth.)

Plaintiff intends to move in limine pursuant to Elehel v. New York Central R. Co., 375
U.S. 253 (1963) to preclude the introduction of any evidence of disability beneffls as deriving
f’rom a collateral source.

[PRECEDE WITH DIVIDER #3]

STIPULATION OF FACTS (Set forth in numbered paragraphs all uncontested t’aets,
3.
including all answers to interrogatories and admissions to which the parties agree.)

1. This action is brought under the Federal Employers’ Liability Act, (45 U.S.C. Sec. 51 et
seq ).
2. The defendant is a corporation engaged in interstate commerce by rail and operates a
railroad system and railroad yards within the jurisdiction of this Court and in various
other

States,

3. That priot to November 7. 2(111, and at all times hereinafter mentioned, the defendant
employed the plaintiff as a maintainer under its direction, supervision and control and

in furtherance of defendant’s business in interstate commerce.
4. That prior to November 7, 2011 and at all times hereinafter mentioned, the defendant
,

maintained, operated and controlled M275 in Morristown, New Jersey, which
contained defendant’s tracks, rails, switches, sidings, roaciheds and appurtenances
thereto. over, through and upon which the defendant operated engines, trains and cars
under its control and direction.
5. Plaintiff was earning $27.40, gross. per hour at the time of the accident.

6. Plaintiff received a wage increase to $27.54 per hour effective January 1, 2012.
7.

Ptaintift received a wage increase to $27.81 per

hour

effective July 1. 2012

8. Plaintiff received a wage increase to S28.09 per hour effective January 1, 2013
9.

Plaintiff received a wage increase to $28.51 per [ioiir effective July I, 2013

10. Plaintiff received a wage increase to $28.94 per hour effective January 1, 2014

11. Plaintiff received a wage increase to $29.37 per hour effective July 1, 2014
12. Plaintiff received a wage increase to $29.81 per hour effective January 1. 2015

13. Plaintiff received a wage increase to $30.26 per hour effective July 1, 2015
14. PLaintiff received a wage increase to $30.72 per hour effective January I, 2016
15. Plaintiff received a wage increase to $31.18 per hour effective July (.2016
(6. Plaintiff is entitled to a wage increase to $31.64 per hour effective January 1.2017
17. Plaintiff is entitled to wage increase to $32.38 per hour effective July 1.20(7
18. Plaintiff is out of work from August 3,20(3 to present.
(9. Plaintiff is currently 59 years old.
20. Plaintiff has a life expectancy of 23. years National Vital Statistics Reports.
-

21. Plaintiff has a work expectancy of 18.3 years US Department of Labor Bureau of
-

Labor Statistics

—

[PRECE[)E WITH DIVIDER #4]

4.
PLAINTIFF’S CONTESTED FACTS (Proofs shall be limited at trial to the contested
facts set forth. Failure to set forth any contested facts shall be deemed a waiver thereot.)
A. Plaintiff intends to prove the following contested facts with regard to Liability:

1. Plaintiff was kneeling in the hale bent over at the waist, due to not being able to
stand up underneath the bungalow, digging/removing dirt and exposing the working
cables when he went to turn to put the heavy wet dirt in another area of the hole,
2. There was a discussion days before the incident in question between plaintiff and
Nunzio Mazza requesting that the bungalow be pulled off the legs in order to do the
digging under the bungalow.
3. The request was denied because it would slow down trains. Additionally, Frank
Ruggiero knew what the conditions were and should have requested lifting of the
bungalow.
4. The employees, including plaintiff, were required to work bent over tinder the
bungalow to do the digging, exposing them to potential cave-ins and increasing the
likelihood of a back injury due to awkward posture.
5. Plaintiff was required to dig while kneeling
6. The cables could have been removed by alternate means.
7. The hut was placed using a boom.
8. The defendant negligently and carelessly conducted itself toward the plaintiff
in failing to provide plaintiff with a reasonably safe place to work;

9. Defendant failed to ;)rOVide proper equipment;
it). Defendant failed to provide adequate manpower;
11. Defendant failed to properly install the signal hut in the first instance;
12. l)efendant failed to inspect plaintiff’s work area;
B. Plaintiff intends to pro’e the following contested facts with regard to damages:
1. Plaintiff sustained a herniation at L5-S1 which compressed the proximal right Si
nerve root.
2. Plaintiff underwent surgery on 8/6/13 when Dr. Andrew Hecht, Chief of Spine

Surgery at Mount Sinai Medical Center performed a right L5-S1 microdiskectomy
and right L4-L5 forami notomy.

3. The stirgery was successful in the sense of reducing the leg pain. but since that date,
I)r. Hecht has kept Mr. Robinson out of work on account of his back

injury

due to

the likelihood of re-injury from the heavy labor nature of Mi-. Robinson’s job.
4. As a result of his injuries, plaintiff was unable to resume his rigorous outdoor work.
5. Plaintiff has not returned to work following his surgery for his injury of ovember
7, 2t)1l.

6. The following are the contractual

%
Date
Increase
7/1/201 1
1/1/2012
0.5%
7/1/2012
1.0%
l/1/2013
1.0%
7/1/2013
1.5%
I/t/2014
1.5%
7/1/2014
1.5%
1/1/2015
1.5%
7/1/2015
1.5%
1/1/2016
1.5%
7/1/2016
1.5%
1/1/2017
1.5%
7/1/2017
2%

S
Increase
$
S
$
$
$

$
$
$
$
$

$
$

0.14
0.28
0.28
0.42
0.43
0.43
0.44
0.45
0.45
0.46
0.47
0.63

wage.

increases:

Rate
S 27.4t)
S 27.54

S 27.8I
S 28.09

S28i1
28.94
29.37
29.81
30.26
30.72
$ 31.18
$ 31.64
$ 32.2$
S
S
$
$
$

7. The plaintiff claims past wage loss of $271.930.15 calculated as follows:
Straight
OT
Hours hours
Overtime
per
Per
flourlv rate
Rate
week
Week Weekly Loss
28.51
$42.77
.5
40
12.5 $1,675.07
40
543.41
12.5 51.70020
$ 28.94
29.37
4C)
$44.06
12.5 $1.725.70
$
29.81
4t)
$44.72
12.5 $1,751.59
$
40
$45.39
12.5 $1,777.86
$ 30.26
40
$46.07
12.5 $1,804.53
$ 30.72

Start
End
8/3/2013 12/31/2013
1/1/2014 6/30/2014
7/1/2014 12/31/2014
1/1/2015 6/30/2015

7/1/2015 12/31/2015
8/4/2016
1/1/2016

Past Wage

Weeks
Missed
21.429
25.714
26.143
25.714
26.143
30.857

Combined
Wage Loss
$35,894.38
$43.719.36
$45.1J4.74
$45,04t).78
$46,478.33
555.68256

$271,930.15

1x)SS

8. Plaintiff claims a future wage loss of $234,718.61 calculated as follows:

Start
8/5/2016
1/1/2017
7/1/2017
1/1/2018

Full
OT
Hourly OT Hourly Hours Hour.s Weekly
rate
Rate
/week /week
Loss
40 115 $1,831.60
$31.18 5 46.76
$ 31.64 S 47.47
40 115 $1,859.07
40 115 51,896.25
$ 32.2$ S 48.41
40 115 51,896.45
5 32.2$ $ 48.42

hnd
12/31/2016
6/30/2017
12/31/2017
12/31/2018

Weeks
Missed
21.143
25.714
26,143
52

Future Wage Loss

9. Plaintiff claims a total net wage loss of $430,651.44 calculated as follows:
ast Wage Loss
Future Wag Loss
Total Gross Watie Loss

Total et Wage Loss
(tess 15% taxes)

$271 .930.15
$234,7 1 16i
$506,648.76

-

-

$

430,651.44

it). Plaintiff would have worked until at least 2017.

Combined
Wage Loss
$38,725.16
$47,804.64
$49,573.41
$98,615.40

I

$234,718.61

11. As a result of the accident and injuries in question, plaintiff has been and continues
to be unable to perform the essential functions of his job.
12. Plaintiff’s doctor has determined that plaintiff is 100% disabled from working in
any capacity secondary to lower back pain.
13. Plaintiff’s doctor has advised plaintiff that he should do no bending or lifting
greater thati 8 Ibs, no twisting, no kneeling and no sitting for more than 30 minutes
at a time.

14. Plaintiff will claim wage loss, unreimbursed/unpaid, medical treatment and co-pays,
past and future pain and suffering, mental anguish and loss of enJt.)yment of life.
5,
DEFENDANT’S CONTESTED FACTS (Proofs shall be limited at trial to the contested
facts set forth. Fai]ure to set forth any contested facts shall he deemed a waiver thereof.)
A. Defendant intends to prove the following contested facts with regard to liability:
1. At the time of his alleged in,jury, plaintiff was working within the duties set forth in
his jot) description.
2. Defendant had provided plaintiff with a reasonably safe place to work.
3. Defendant provided the proper equipment for and supervision of the work assigned
to plaintiff.

B. Defendant intends to prove the following contested facts with regard to damages: (This
statement must include the factual basis for each defense against the plaintiff’s claims for
damages.)
1. Plaintiff contends he suffered a herniation in his back at L5-S1. That problem was
surgically repaired with an excellent result.
2. Prior to his surgery, plaintiff was cleared to return to full duty by NJ Transit on
July 5, 2013.
3. Plaintiff never returned to work. Instead, he underwent back surgery on August 6,
2013.
4. In October of 2013, plaintiff was diagnosed with liver cancer.
5. Plaintiff never contacted NJ Transit’s office for Strategic Staffing to inquire about
a position that he tvotild be able physically to do after his surgery.

6. Plaintiff’s health situation was severely worsened by the discovery of his liver
cancer.

[PRECEDE WITH DIVIDER #5]

FACT WITNESSES: (Aside from those called for impeachment purposes, only the fact
6.
witnesses set forth by name and address may testify at thai, No summary of testimony is
necessary.)
A.

Plaintiff:
Quitman Robinson
Mike Flaherty
Nunzio Mazza
Frank Ruggiero
Terry Maher

B.

Defendant:
Frank Ruggerio
Mike flaherty

IPRECEDE WITH DIVIDER #71

PLAINTIFF’S EXPERT WITNESSES (No expert or specialized lay opinion Witness
offering scientific, technical or other specialized knowledge will he pemiitted to testify at trial
unless listed below. A summary ot the expert qualitications and a copy of his/her report rnt.ist he
pto\’ided for the Court’s review at the pretrial conterence. No opposing counsel shall he
permitted to question the expert’s qualifications unless the basis of the objection is set torth
herein.)
7.

A. Plaintiff’s expert and specialized lay opinion witnesses are:
Dr. Robert Adair, 699 Teaneck Road, Teaneck, NJ C)7666

—

will testify regarding his

examination. testing. records reviewed, chart regarding plaintiff, findings, diagnosis, prognosis

and treatment of plaintiff, including his discussions with plaintiff regarding his likelihood of
recovery and future limitations.
I)r. Neil Kahanovitz, Center for orthopaedics, 1500 Pleasant Valley Way, Suite 101,
Vest Orange, N.J 07052

—

may testify regarding his examination, testing, records reviewed.

chart regarding plaintiff, findings, causation. diagnosis, prognosis and treatment of plaintiff.
including his discussions with plaintiff regarding his likelihood of recovery and future

limitations.
I)r. Andrew Heeht. Mount Sinai Medical Center, 5 East 9S Street, Box 11, Suite 9,
New York, NY 10029

—

will testify’ regarding his examination, testing, records reviewed, chart

regarding plaintiti, findings, causation, diagnosis, prognosis and treatment of plaintiff, inctuding

his discussions with plaintiff regarding his likelihood of recovery and future limitations,
Dr. Liang, All Care Clinic, 349 East Northf’ield Road. Suite 217, Livingston, NJ
07052

—

will testify regarding his examination, testing. records reviewed, chart regarding

plaintiff. findings, causation, diagnosis, prognosis and treatment of plaintiff, including his
clisctissions with plaintiff regarding hi.s likelihood of recovery and future limitations.

I)efendant’s objections to the qualifications of the plaintiff’s experts and
B.
specialized lay opinion witnesses are:

C.

Defendant’s expert and specialized lay opinion witnesses an:
Defendant’s orthopedic expert. Joseph W. Dryer, M.D., prepared reports on April

9, 2015 and January 8, 2016. He concluded and will testify that plaintiff either developed an U
SI disc herniation or exacerbated a preexisting U-SI disc hemiation as a result of the workrelated injury on November 17. 2011. Conservative treatment was not successful. Robinson
eventually underwent under-went micmdiscectomy at li-Si as well as micmdeompression at
LA-S. Following this surgery, excellent results have been obtained. Dr. I)ryer’s physical
examination of the lumbar spine demonstrated a minimal functional limitation consistent with a
successful lumbar microdecompression.

Plaintiff’s objections to the qualifications of the defendant’s experts and
D.
specialized lay opinion witnesses an:

[PRECEDE WITH i)IVtDER #8]

8.
DEPOSITION: (List, by page and line, all deposition testimony to be offired into
evidence. All irrelevant and redundant matters and all colloquy between counsel must be
eliminated, unless ruled relevant, Deposition testimony to be used solely for impeachment
purposes need not he listed).

A. On liability plaintiff intends to read into evidence the following:

None anticipated, absent unavailability of witness.

B. On damages plaintiff intends to read into evidence the fNlowing:

[PRECEDE WITII DIVIDER

#91

(Except for exhibits the need ftr which could not reasonably have
EXIIIBTTS
9.
been foreseen or which are used solely for impeachment purposes, oniy the exhibits set fltth on
the exhibit list attached hereto may be introduced at trial. Any objections to an exhibit, and the
reason k)r said objection, must he set forth below or it shall be deemed waived, All parties herby
agree that it will not be necessary to bring in the custodian of any exhibit as to which no such
objection is made.
In accordance with the Pretrial Scheduling Order, three (3) weeks before the entry of the
final Pretrial Order, counsel tbr each party shalt serve upon all parties copies of all the trial
exhibits, fully pre-marked with exhibit tabs and numbering to be utilizcd at trial).

A. Plaintiff intends to introduce into evidence the exhibits listed on the attached
exhibit list (list by number with a description ot’ each exhibit):
See attached list.

B. Defendant objects to the introduction of plaintiff’s exhibits (set forth number of
exhibit and grounds for objection). Objections shall be provided two weeks before the trial
brief’ is due.

[PRECEDE WITH DIVIDER

#10]

10. DEFENDANT EXhiBITS
(Except for exhibits the need for which could not reasonably have been foreseen or tvhich
are used solely for impeachment purposes, only the exhibits set forth on the exhibit listed
attached hereto may he introduced at trial. Any objections to an exhibit, and the reason for said
objection. must he set forth below or it shall be deemed waived. All parties hereby agree that it
will not be necessary to bring in the custodian of any exhibit as to which no such objection is
made.
In accordance with the Pre-triat Scheduling Order, three (3) weeks hefi)re the entry of the
final Pre-trial Order. counsel for each party shall serve upon all partie copies of all trial exhibits,
fully pre-marked with exhibit tabs and numbering to he utilized at tHat).
A. Defendant intends to introduce into evidence the exhibits listed on the attached
exhibit list (list by number with a description of each exhibit).
See attached list.
B. Plaintiff objects to the intro(luction of defendant’s exhibits (set forth number of
cXhit)it and grounds for objection). Ob,jections shalt he provided two weeks before the trial
brief is due.

Report of Joseph W. Dryer, M.D. (4.915)
Supplemental report of Joseph W. Dryer, M.D. (1.8.16)

—_____

Second Supplemental report of Joseph W. Dryer, M.D.

The reports of defendant’s experts are objected to as cumulative and based on hearsay. Dr. Dryer
will presurnabty testify in person at trial and he was not a treating provider.

(COPIES OF EXHIBITS ARE TO BE MADE FOR OPPOSING COUNSEL. ANI) A BENCH
BOOK OF EXHIBITS IS TO BE DELIVERED TO ‘IHE JUDGE ONE WEEK PRIOR TO TilE
START OF TIlE TRiAL. [F COUNSEL DESIRES TO DISPLAY EXHIBITS TO THE JURY.
SUFFICIENT COP[ES SHOULD BE AVAU.ABLE TO PROVIDE EACH JUROR WITH A
COPY; ALTERNATIVELY, ENLARGE[) PHOTOGRAPHIC OR PROJECTED COPIES
MAY BE USEI)).

[PRECEDE WITH DIVIDER #11]

ii.

PLAtNTIFF’S LEGAL ISSUES

A. Whether the defendant, through its agents, servants and employees were
negligent in failing to provide plaintiff with a safe place to work.
B. Whether the negligence of the railroad, its agents, servants and
employees caused, in whole or in part, no matter how slight, plaintiff’s injuries?

C. What are the monetary damages suffered by the plaintiff?

(PRECEDE WITH DIVIDER #121
12.

DEFENDANTS LEGAL ISSUES
Whether NJ Transit provided a reasonably safe place to work for plaintiff.

Whether plaintiff is entitled to future lost wages in light of the fact that he made no
attempt to return to work in any position at NJ Transit following his back surgery on August 6.
2013.

IPRECE1) WITH DIVIDER #13]

I 3.

MISCELLANEOUS (Set forth any matters which require action or
should be brought to the attention of the Court.)

[PRECEDE WITH DIVIDER #14]

14.

TRIAL COUNSEL: (List the names of trial counsel for all parties.)
For Plaintiff:

Marc T. Wietzke, Esq.
Flynn & Wietzke. PC
t205 Franklin Avenue, Suite 370
Garden City, NY 11530
[phone]

l)efendant:

Gregory Sullivan, Esq.
John J. Hoffman, Acting Attorney General
R. J. Hughes Justice Complex
P0 Box 116
Trenton, NJ 08625
(609) 292-6 1 16

___________________________________________

_____________________________________________

IPRECEDE WITH DIVIDER
15.

A.

#151

]URYT RIALS:
Not

later

than

1. Each party shall submit to the District Jude and to opposin counsel a
trial brief in accordance with Local Civil Rule 7.2(b) (SEE ATTACHED “RIDER ON LENGTH
OF BRIEFS”) with citations to authorities cited and arguments In support of its position on all
disputed issues of law. THE BRIEF SHALL ALSO ADDRESS ANY ANTICIPATED
EVIDENCE DISPUTE. In the event a brief is not submitted, The delinquent party’s pleading

may be stricken.
2. Any hypothetical questions to be put to an expert witness on direct
examination shall be submitted to the District Jude and to opposing counsel.
3. Each party shall submit to the District Judge and to opposing counsel
proposed voir dire.

4. Plaintiff shall submit to opposing counsel, in writing, proposed jury
instructions. Each instruction shall be on a separate sheet of legal sized paper and shall be
numbered in sequence. Each instruction shall include citations to authorities, if any.
Within 7 days of the above, opposing counsel shall, on the face of the
instructions submitted by plaintiff, set forth any objections to the proposed jury instructions

and/or proposed counter-instructions.

B.

NON-.JURY TRIALS:

Not later than
1. Each party shall stibmit to the District Judge and to opposing counsel a
trial brief in accordance with Local Civil Rule 7.2(b) (SEE ATTACHED “RIDER ON
LENGTH OF BRIEFS”) with citations to authorities cited and arguments in support of its
position on all disputed issues of law. THE BRIEF SHALL ALSO ADDRESSANY
ANTICIPATED EVIDENCE DISPUTE. In the event a brief is not submitted, the delinquent
party’s pleading may be stricken.

2. Any hypothetical questions to be put to an expert witness on direct
exami nation shall be submitted to the District Judge and to opposing counsel.
Proposed findings of Fact and Conclusions of Law shall be
3.
to the District Judge and to opposing counsel after the close of evidence. These shall
submitted
include annotations to trial transcripts and exhibits.

[PRECEDE WITH DIVIDER #16]

16.
BIfURCATION (When appropriate, liability issues shall be severed and tried to verdict.
Thereafter, damage issues will be tried to the same jury.)
The issues of liability and damages shall not be tried separately.

[PRECEDE WITH DIVIDER #17]

17.

ESt’IMi\TEI) LENGTH oF TRIAL
2

days For liability and

days for damages.

TRIAL DATE:__________________

AMENDMENTS TO THIS FINAL PRETRIAL ORDER SHALL NOT BE PERMITTED
UNLESS THE COURT DETERMINES THAT MANIFEST INJUSTICE WOULD RESULT IF
THE AMENDMENT IS DISALLOWED. THE COURT MAY FROM TIME TO TIME
SCHEDULE CONFERENCES AS MAY BE REQUIRED EITHER ON ITS OWN MOTION
OR AT THE REQUEST OF COUNSEL.

h
(Attorney for Plaintiff)
Marc T. Wietzke, Esquire
Flynn & Wietzke, PC
12()5 Franklin Avenue, Suite 250
Garden City, New York 11530
Te]ephone: 516-877-1234
Facsimile: 516-877-1177
E-mail: [e-mail]

Gregory Sutli’
John]. Hoffman, Acting Attorney General
R.J, Hughes Justice Complex
P0 Box 116
Trenton, NJ 08625
Telephone: [phone]
Facsimile: 609-633-8702
E-mail: Gregorv.Sul [e-mail]
,

CATHY L. WALDOR
UNITED STATES MAGISTRATE JUDGE

R[t)ER ON LENGTH OF BRIEFS

The attention of the parties is directed to Local Civil Rule 7.2, Briefs shall not exceed 40
(emphasis added). This page limitation shall he strictly
ordmary typed or punted pages
enforced.
*‘“

When subti itted a brief in accordance with this rule a party may request special
permission to submit an additional brief on any point or points deemed to need additional pages
of argument. This request must be made by letter not to exceed two ordinary typed or printed
pages and must he submitted with the brief.
The Court shall, in its sole discretion, decide whether to allow additional briet’ing on
review of the party’s brief and letter.
The Court also reserves the right, in its sole discretion, to require additional briefing on
any point or points after review of the written submissions of the parties or oral argument.

_______________

UNITED STATES DISTRICT COURT
DISTRICT OF NEWJERSEY
QUITMAN ROBINSON,
Plaintiff,
-against

Civil Action #: 2:14 Civ, 2679
FINALPRE-TRIALORDER

NEWJERSEYTRANSIT RAIL OPERATIONS, INC.

Trial Date:

Defendant.
EXHIBIT P
DESCRIPTION OF EXHIBIT
1
NJT Report of_Personal_Injury_{redactcd)
Preliminary_Morning_Status_Report_Employee
2
3
Employee_Statement_-_Mike_Flaherty
NiT Initial Medical Record
4
NJT Medical_Services_Form_MD4Q
5
NJT Personnel File (redacted)
6
7
NiT Wage & Payroll File
S
NiT Medical_Department_File_(redacted)
Google_Earth_Photograph_of Accident_Location
9
10
Signalman_Physical_Requirements_Summary
11
Medical records from Dr. Andrew Hecht
12
Medical_records_from_Dr._Robert Adair
13
Medical_records_from_Dr._Liang_at_All_Care_Clinic
14
Medical_records_from_Bush_Kill_EMS
15
Medical records from Mount Sinai Medical Center
16
Medical records from Pocono Medical Center
17
Medical records from Radiology Associates
18
Medical records from Centerfor Orthopaedics (Dr. Neil Kahanovitz)

A
B
C
D
E
F

DEFENDANTS_EXHIBITS
Medical_Services_Form_(MD-40)
NJ_Transit_Surigcal_Authorization
Report of Joseph_W._Dryer,_M.D._t4.9.15)
Supplemental_report_of Joseph_W._Dryer,_M.D._(1.8.16)
Second_Supplemental_report_of Joseph_W._Dryer,_M.D.
Signalman_Physical_Requirements_Summary

ID

EVID