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GRAPHIC: [Walkup, Melodia, Kelly & Schoenberger]
KHALDOUN BAGHDADI: We have represented victims of catastrophic injury for over 50-years here. A substantial number of those cases involve Muni. As a result of that work we have been able to amass a databank of all the operator manuals, guidelines, and training booklets, so every time we represent a client we bring that 50-year collective experience to bear. Every time we take a deposition of anybody from Muni, before we even walk into the conference room we know what is expected of a Muni operator because we have the manuals that are used to train them. We let the jury know that this is what Muni itself expects of its operators and this is what Muni itself expects its operators to do to operate their vehicles in a manor that makes sure that pedestrians are safe and so once the trial even begins we have set forth almost a road map of what Muni requires by using its own manuals, and its own policies and procedures in order to tell the story to the jury of what was required here and why it didn't happen.
GRAPHIC: [Walkup, Melodia, Kelly & Schoenberger]