Sample Request for Traffic Light Sequence Report

April 4, 2019

Baltimore County Department of Public Works
Bureau of Traffic Engineering and Transportation Planning
Division of Traffic Engineering
111 W. Chesapeake Avenue
Towson, Maryland 21204
Attention: Stephen E. Weber, P.E., Acting Chief

RE: Clark v. Needham
In the Circuit Court of Maryland for Baltimore City
Case No: 24-C-05-002797

Dear Mr. Weber:

Please be advised that this firm has been retained to represent Eartie Clark with regard to injuries she sustained when involved in an automobile accident on October 10, 2004 at the intersection of Painters Mill and McDonough Roads in Baltimore County, Maryland

As such, we need a traffic light sequence report for the intersection in question. I would also request that you provide me with the name of an employee who would be able to provide additional information and answer questions regarding the sequence report. I have enclosed a copy of the accident investigation report, for your reference. I have also enclosed a self addressed, stamped envelope for your convenience in returning the requested information.

Thank you in advanced for your anticipated prompt attention to this matter. Should you have any questions or concerns, or should you require additional information, please do not hesitate to contact me.

Very truly yours,
Laura G. Zois
LGZ/kry
Enclosures

Sample Trial Examination of Light Sequence Expert

Our lawyer have brought light sequencing experts, usually employees of the county or city, to testify at trial to make sure the jury understands that the defendant is, for lack of a more charitable phase, a big liar.  
  • full name
  • business address
  • name of your employer
  • what is your position there
  • how long have you worked with the city
  • what does the department of transportation do for our city
  • does the dot keep official city documents about intersections
  • does it keep official city documents for the lay out of roads
  • does it keep official city documents about traffic signals
  • earlier this year did you receive a request from my office about the lighting sequences at the intersection of Charles and University in Baltimore, Maryland
  • did you send me the lighting sequence diagram and a report
  • did the dot you receive a subpoena from my office to appear here in trial
  • did you bring those same documents to court with you today
  • do these documents show the geographic layout of the signals
  • do these documents show the lighting sequence 
  • are these records kept as a regularly conducted business activity
  • are these records also public records kept by a public agency

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