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CONFIDENTIAL ATTORNEY WORK PRODUCT
Deposition Summary
of
Molly Carney
Taken May 30, 2013
Re: Carney v. Geiger,...
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Carney v. geiger deposition summary 2013.06.01.doc

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Deposition summary for Mock answer and counterclaim of Ms. Geiger who allegedly rear-ended the plaintiff on I-540 by following too closely but alleges that the collision was the result of the plaintiff's proximate negligence.

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Carney v. geiger deposition summary 2013.06.01.doc

  1. 1. Page 1 of 1 CONFIDENTIAL ATTORNEY WORK PRODUCT Deposition Summary of Molly Carney Taken May 30, 2013 Re: Carney v. Geiger, rear-end collision. Case No.: 58942 Appearances: For the Plaintiff: For the Defendant: Cherish Sadang Cassie Geiger By: Samia Morteo Plaintiff’s Answers to Defendant’s Interrogatories 3 Page:Line Testimony Examination by Samia Morteo 3:7 4:5 Deponent’s name and employment Deponent states that her full name is Molly Carney and she works at Wachovia as a financial advisor and account manager. 3:19 4:1 No use of seatbelt Prior to and during the accident, Ms. Carney was not wearing her seatbelt. 5:6 5:21 Particularities of the accident Ms. Carney was driving East on 540 and headed to work at 9 a.m. when she attempted a lane change around a slow moving tractor-trailer. She was travelling 10 miles over the posted speed limit. It is likely that no turn signal was used and she did not see the Defendant in her rear-view mirror. A rear-end collision forced Ms. Carney off the road. She indicates that she was not under the influence of alcohol or any medications or illegal substances. Attorney Work Product

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