on Two-Wheels Seminar

Page 1


On Two Wheel

Tuesday 17th September 2024

No5 Barristers’ Chambers Birmingham

Contents

Section 1

Members List – Page 5 - 6

Programme – Page 8

Section 2 – Page 10 - 12

Henry Pitchers KC

Section 3 – Page 14 - 35

Scenarios for discussion

Mark Radburn and Paul Evans

Section 4 – Page 37 - 52

Accident Reconstruction

Chris Goddard

Section 4 – Page 54 - 58

Traumatic Brain Injuries

Dr Dougall McCorry

Section 5 – Page 60 - 62

Trauma and Orthopedics

Mr. Badri Narayan

MembersList PersonalInjuryGroup

ToviewordownloadmembersCVspleasevisitNo5.com

HenryPitchersKC-HeadofGroup (Silk:2020Call:1996)

RobertSmallwood-DeputyHeadofGroup (1994)

PaulBleasdaleKC (Silk:2001Call:1978)

ChrisBrightKC (Silk:2009Call:1985)

JonathanJonesKC (Silk:2013 Call:1994)

DavidTyackKC (Silk:2021Call:1994)

JohnCoughlinKC (Silk:2021Call:1999)

RogerSGiles (1976)

TimothyNewman (1981)

NeilThompson (1982)

RichardMoat (1985)

PeterDean (1987)

MalcomDuthie (1989)

MarkRadburn (1991)

NickXydias (1992) AdamFarrer (1992)

JamesStoll (1994)

EmmaHogan (1996)

GarethCompton (1997)

StephanGoodfellow (1997)

JonathanDerrington (1998)

RichardAdams (1999)

CharlesCrow (1999)

LouisaDenning (1999)

JamieGamble (1999)

TeresaHargreaves (1999)

StevenFisher (2000)

PaulEvans (2001)

EstherGamble (2001)

DeniseOwen (2003)

MamtaGupta (2004)

RichardCooke (2005)

KatieFeeney (2005)

NicholasFerrari (2005)

GemmaRoberts (2006)

RichardOakes (2007)

CharlotteRobinson-Jones (2008)

RichardGrimshaw (2010)

StevenSmith (2011)

FrancescaMartin (2010) RichardMcLoughlin (2012)

LucyCoulson (2013)

JodieKembery (2013)

EamonnHurley-Flynn (2013) AlexanderMellis (2013)

AndrewRhodes (2015)

ElliotClifton-Thompson (2016)

RuthCostello (2016)

RebeccaLivesey (2016)

GraceGwynne (2017)

OliverMay (2018)

DrLouisaSherlock (2018) DrNeilShastri-Hurst (2018)

ThomasBeasley (2020)

AfiyaAmesu (2022)

MelanieMills (2022) ChiefExecutive&DirectorofClerking

TonyMcDaid PracticeDirectors

PracticeGroupClerks

PeteMottram EdMilburn

MatthewReeves

TraceyWitherford

MorganSmith

Tel:08452417006

Email:MT@no5com

On Two-Wheel Seminar

No5 Barristers’ Chambers, Birmingham

Programme

10:15 – 10:45 Registration

10:45 – 11:00 Welcome – Henry Pitchers KC, No5 Barristers’ Chambers

11:00 – 11:45 Scenarios for discussion – Mark Radburn and Paul Evans, No5 Barristers’ Chambers

11:45 – 12:30 Accident Reconstruction – Chris Goddard, Accident Reconstruction expert

12:30 – 13:30 Lunch

13:30 – 14:15 Traumatic Brain Injuries – Dr Dougall McCorry, Consultant Neurologist

14:15 – 15:00 Trauma and Orthopedics – Mr Badri Narayan, Trauma and Orthopedic Surgeon

15:00 – 15:15 Refreshment break

15:15 – 15:45 Group discussions of scenarios – No5 Counsel

15:45 – 16:15 Q&A

16:15 – 17:15 Networking drinks

Henry Pitchers KC

Call: 1996 | Silk: 2020

He puts clients at ease and ensures they fully understand their legal position. Legal 500 2020 (Clinical Negligence)

clients, ensuring that trust and confidence is established and maintained throughout the case.

Most claims in which Henry is instructed have a value in seven or eight figures and he currently has several cases underway which are likely to have a capitalised value in excess of £30M. Although Henry has very extensive trial experience, he understands the importance of effective representation in alternative dispute resolution, be that in mediation or at joint settlement meetings.

Expertise

Personal Injury

Henry is Head of the Personal Injury Group and has been undertaking personal injury work since he commenced practice in the 1990s. As a result, he has huge court experience across all areas of work, such as road traffic collisions; workplace accidents; industrial disease; public liability (such as highways and occupiers liability claims); accidents abroad or with a foreign element; and group litigation (such as the sofa dermatitis claims).

In silk, it is routine for Henry for work closely with experts on liability issues, including accident reconstruction; helmet and seatbelt causation; mechanical and electrical engineering; construction sites; ergonomics; PPE; and CCTV.

The profile of injuries of the claimants in the cases in which Henry is instructed is wide-ranging, but there is a preponderance of traumatic brain injury; spinal cord injury; amputation; complex polytrauma; and psychiatric disorders (such as PTSD and functional or somatic disorders). The claims are generally of high value and/or significant complexity. These cases commonly require a very large number of expert disciplines to be instructed. Henry has substantial experience of working with foreign lawyers and other experts when injuries are sustained outside the jurisdiction.

Henry is often instructed in cases involving fatalities and all the claims which may arise from them. He has attended many inquests across the country, the highest profile of which being the Fishmongers Hall Terrorist Inquest, in which he appeared for the family of one of the two victims.

Clinical Negligence

Henry has real depth of experience in clinical negligence work, having taken many cases to trial and an appeal all the way to the Supreme Court (Paul/Polmear/Purchase).

In silk, cases tend to be of significant complexity and/or very high value. Henry has a sub-specialism of cerebral palsy and birth injuries. At any given time, he is instructed in numerous paediatric brain injury cases of the utmost severity. Henry is aware of the demands and sensitivities of this work and endeavours to work as a team with his junior, his instructing solicitors and his clients.

It is common for Henry to be instructed on behalf of adults with acquired brain injuries, which may have arisen from hypoxia, stroke, haemorrhage, brain tumours or infection.

Spinal injury work, adult and paediatric, forms an important part of Henry s practice. This may have resulted from surgical negligence or delayed diagnosis of conditions such as cauda equina syndrome or spinal abscess.

With profound and life-changing injuries in particular, Henry supports the claimant s access to rehabilitation during the claim. Many of these claims will conclude with an order for periodical payments.

Other areas of interest include delayed diagnosis of cancer; surgical negligence, including orthopaedics; other claims arising out of pregnancy and birth; and psychiatric injuries.

Henry has a great deal of inquest experience for deaths arising in medical settings, including suicide and end-of-life care.

Awards

Qualifications

BA (Hons) Jurisprudence; University of Oxford

Mark Radburn

Call: 1991

Brain injury

Spinal injury

General orthopaedic injury

Neurological injury/ paralysis

Pain disorders

Psychiatric injury for both primary and secondary victims

Amputations

Having served in the Armed Forces Mark has developed a substantial practice over the years dealing with cases involving forces/ex-forces personnel. He speaks their language .

With over 25 years at the Bar, he has extensive experience of personal injury litigation in all areas, including:

Workplace injury

Road traffic collisions (with particular experience relating to catastrophic injury/ fatal accident claims arising from motorcycle collisions)

Occupiers liability

Defective premises

Highways Act claims involving both pedestrians and vehicles Sports injury

Animals Act claims (particularly claims involving horses)

Fatal accidents

Inquests

Marks Defendant practice encompasses all the above areas acting for major motor and public liability insurers. He has particular experience of road accident claims relating to taxis and employer and public liability work arising in the context of care homes and schools.

Expertise

Personal Injury

Described as A very impressive advocate indeed, Mark acts in multitrack cases of all levels and complexity and at all stages of the claim, from initial advice, interlocutory and case management hearings, conferences up to trial and settlement meetings. He often deals with substantial value claims and has been instructed on many cases against silks without a leader.

Mark has an extremely approachable manner and is excellent at putting clients at ease.

He is always ready to chat with solicitors who wish to discuss a case in its early stages, without obligation.

Mark s current caseload covers the full spectrum up to and including the most serious injuries, including;-

Brain injury

Spinal injury

General orthopaedic injury

Neurological injury/ paralysis

Pain disorders

Psychiatric injury for both primary and secondary victims

Amputations

Having served in the Armed Forces, Mark has developed a substantial practice over the years dealing with cases involving forces/exforces personnel. He speaks their language .

With over 25 years at the Bar he has extensive experience of personal injury litigation in all areas, including:

Workplace injury

Road traffic collisions (with particular experience relating to catastrophic injury/ fatal accident claims arising from motorcycle collisions)

Occupiers liability

Defective premises

Highways Act claims involving both pedestrians and vehicles Sports injury

Animals Act claims (particularly claims involving horses)

Fatal accidents

Inquests

Marks Defendant practice encompasses all the above areas acting for major motor and public liability insurers. He has particular experience of road accident claims relating to taxis and employer and public liability work arising in the context of care homes and schools.

Clinical Negligence

With over 30 years at the Bar, Mark has built-up extensive experience in the field of clinical negligence with claims arising from all areas of clinical practice, including Obstetrics and gynaecology, Oncology, delayed diagnosis, Accident and emergency, Ophthalmology, ENT, General surgery, Cardiology, General practice, Orthopaedic surgery, Anaesthetics, Nursing care, Dental practice and Care of psychiatric patients

On Two-Wheel Motorcycle Scenario

17th September 2024, No5 Barristers’ Chambers, Birmingham

1. At approximately 5 pm on the 12th of October, Andy Brown a skilled motorcyclist aged 50, was riding his two-year-old Kawasaki Ninja 1000SX motorcycle southbound along the A43, a busy dual carriageway, approaching a large roundabout. The weather was bright and clear. The roundabout had exits to both the left, for the A4031, and right, for the A421, with the dual carriageway continuing straight ahead. The approach to the roundabout has two lanes, both clearly marked with arrows indicating that they were for proceeding straight ahead. There are no “left” or “right” turn arrows.

2. The weather was warm. Andy was wearing an open-faced helmet with sunglasses, a thin leather jacket, jeans and lightweight boots His bike was standard specification save that he had fitted a modified exhaust.

3. Andy says “As I approached the roundabout I was in the offside lane as the nearside lane was full of traffic. When I entered the roundabout, I could see a white van about two or three car lengths in front of me but in the near side lane. It was not indicating. As I was about to exit the roundabout the van suddenly cut in front of me. I braked and tried to turn to the right but I couldn’t avoid the van and I clipped the rear just behind the rear wheel. I remember it clearly but that’s the last thing I remember”.

4. The driver of the Ford Transit van, Charlie Davis, age 47, says "I was in the offside lane when I entered the roundabout, indicating to turn right. After I have passed the exit for the dual carriageway, I moved to the nearside lane in order to take my exit. when I was in the nearside lane I heard a loud bang to my rear and I felt the van jolt. I exited the roundabout and immediately pulled over onto the side of the road. I looked back and I could see a motorcycle and rider on the ground and a red car that had stopped in the middle of the roundabout.”

5. The driver of the red 2013 Subaru WRX STI, Ed Farrell, says “The motorbike was in front of me. It shot off over the roundabout really fast. I couldn’t say what speed it was travelling but it was fast. I was indicating to turn right and as I pulled off, I lost sight of the motorcycle. As I came around the roundabout, suddenly the rider and the bike were on the road in front of me. I braked but didn’t have time to stop and I felt my car hit something which I now know to be the motorcyclist”.

6. Gerald Harris was the second car in the short queue of traffic in the nearside lane of the approach to the roundabout. He says “I didn’t see the motorcycle, but I heard a really loud bike engine noise and then a red car shot off at high speed after it. As I was going around the roundabout I became aware that an accident involving the motorcycle and the red car had taken place”.

7. The motorcycle, debris and marks on the road were all in the vicinity of the centre of the two lanes of the roundabout roughly between the northbound and southbound lanes.

8. Andy sustained multiple serious injuries, including;

a. Traumatic brain injury.

b. Extensive soft tissue facial injuries;

c. Extensive lower leg fractures including a severe crash injury to the left ankle/ foot;

d. Psychological injury/PTSD.

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Paul Evans

Call: 2001

"Paul is extremely capable of dealing with very complex, difficult and high-value claims." "Paul is an excellent advocate with detailed and extensive knowledge."

Chambers UK 2024

Paul regularly undertakes cases of several million pounds as sole Counsel, is frequently against Kings Counsel and given his experience, is regularly instructed as a junior to Kings Counsel in highly complex or catastrophic claims, where he undertakes much of the drafting, interlocutory Court hearings and conferences with the full range of expert witnesses.

Paul has a particular interest in cases involving amputations and prosthetics, and as a keen cyclist and former motorcyclist, claims arising from cycling and motorcycling accidents.

Expertise

Personal Injury

Paul has a substantial advisory element to his practice, is regularly instructed for his advice in conference, his drafting skills, Schedules/ Counter Schedules, in addition to undertaking all forms of ADR, including Round Table Settlements, Pathways/ Way Forward meetings, the full range of interlocutory hearings, trials, appeals and inquests.

Paul is extremely accessible, easy to work worth, has a prompt turnaround of work and excellent attention to detail. Paul is very effective in a team, regularly working with Kings Counsel and multiple solicitors in catastrophic claims. Paul utilised paperless working, technology and e-bundles long before Covid-19 and is happy undertaking all forms of remote hearings and ADR.

Costs formed a large part of Paul s early practice and with CCMHs being so fundamental to the effective running of catastrophic claims, Paul is frequently instructed to advise on case planning and budgets. Paul is happy to attend CCMHs without a separate costs draftsperson.

Costs formed a large part of Paul s early practice and with CCMHs being so fundamental to the effective running of catastrophic claims, Paul is frequently instructed to advise on case planning and budgets. Paul is happy to attend CCMHs without a separate costs draftsperson.

Paul has extensive experience across the full range of issues in complex and high value claims, including:

Rehabilitation Code and the Serious Injury

Full Care and Case Management packages

Capacity

Accommodation claims

Substantial loss of earnings, including for the self employed

Elective amputation

Prosthetics

Assistive Technology

Provisional Damages

Statutory Funding

Periodical Payments

Pain conditions

Catastrophic Injury

Paul has a substantial advisory element to his practice, is regularly instructed for his advice in conference, his drafting skills, Schedules/ Counter Schedules, in addition to undertaking all forms of ADR, including Round Table Settlements, Pathways/ Way Forward meetings, the full range of interlocutory hearings, trials, appeals and inquests.

Paul is extremely accessible, easy to work worth, has a prompt turnaround of work and excellent attention to detail. Paul is very effective in a team, regularly working with Kings Counsel and multiple solicitors in catastrophic claims. Paul utilised paperless working, technology and e-bundles long before Covid-19 and is happy undertaking all forms of remote hearings and ADR.

Costs formed a large part of Paul s early practice and with CCMHs being so fundamental to the effective running of catastrophic claims, Paul is frequently instructed to advise on case planning and budgets. Paul is happy to attend CCMHs without a separate costs draftsperson.

Paul has extensive experience across the full range of issues in complex and high value claims, including:

The Rehabilitation Code and the Serious Injury Guide

Full Care and Case Management packages

Capacity

Accommodation claims

Substantial loss of earnings, including for the self employed

Elective amputation

Prosthetics

Assistive Technology

Provisional Damages

Statutory Funding

Periodical Payments

Pain conditions

Mediation

Paul qualified as an Accredited Mediator following a 5 day facilitative mediator training with the London School of Mediation in 2011 and is happy to undertake mediations across the range of personal injury cases.

Awards

Qualifications

Kings College, University of London, BSc. Biology (First Class) Nottingham Post Graduate Diploma in Law (Commendation) Inns of Court School of Law Bar Vocational Course (Very Competent)

OnTwo-WheelSeminar Cycling

SafetyStatistics

Gov.UK-averagedovertheperiod2018to2022:

anaverageof2cyclistsdiedand81wereseriouslyinjuredperweekinreported roadcasualties

amajorityofpedalcyclefatalities(58%)donotoccuratorwithin20mofajunction comparedto33%ofallseriouslyinjuredcasualties

almosthalf(46%)ofpedalcyclefatalitieswerein2vehiclecollisionsbetweena pedalcycleandacar

56%ofpedalcyclefatalitiesoccurredonruralroadscomparedto30%oftraffic

82%ofpedalcyclekilledorseriouslyinjuredcasualtiesweremale

themostcommoncontributoryfactorallocatedtopedalcyclistsinfatalorserious collisionswithanothervehiclewas‘driverorriderfailedtolookproperly’.Itwas alsothemostcommonfactorallocatedtotheothervehiclesinvolved

CycleScenario Parties

TheClaimant,SarahJenkins,wasa40-year-oldcyclistridingthrougha residentialsuburbwhilstheadingoutonasolotrainingride.TheClaimant wasanexperiencedcyclist,sheregularlyrodewithacyclingcluband competedincyclingevents.TheClaimantwasridingabikethatwas predominantlyblack,withyellowhandlebars,wearingablackandgreen Lycracyclingkitandablackandgreencyclehelmet.

TheDefendantwasa60-year-oldmaledrivingaFordFiestamotor vehicle.Thevehiclewaswellmaintained,hadnomechanicalissuesand theDefendantnohealthconditionsthataffectedhiseyesightordriving ability.

Locus

TheaccidentoccurredatthejunctionofStratfordRoadandWarwick Road,inanareawhichwassubjecttoa30mphspeedlimit.Theareawas residentialhousing,theroadswerelinedwithmaturetreesandcarswere parkedalongbothsides.TheClaimantwascyclingalongStratfordRoad, whichwasasinglecarriageway,two-wayroad,intendingtocontinuepast thejunctionwithWarwickRoad,whichwasonhernearside.

TheDefendantapproachedthejunctionalongtheStratfordRoad,butin theoppositedirection.TheDefendant’sintentionwastoturnrightatthe junctionintoWarwickRoad,acrossthepathoftheClaimant.

Atthejunctiontheroadhadaslightdownhillgradientinthedirectionof travelforthecyclistandwasstraightforadistanceof100m.

TheaccidentoccurredonaJulymorning.Theweatherwasclear,dryand bright.

Claimant’sevidence

“Iamaveryexperiencedcyclist,regularlyridingwithaclub,onmyown andincyclingevents.Irideapproximately5,000kmperyear.Iamavery competentandsafecyclistandhaveexcellentbikehandlingskills.Ihad setofffromhome,about500mfromthecollisionforoneofmyusual trainingrides.Iwaswearingmyclubcyclingkitandwasnotdisplaying lightsbecauseitwasabrightsunnymorning.

MylastmemoryisapproachingthejunctionwhereIwaspositionedclose tothecentrewhiteline.BeyondthatIhavenorecollection.MyGarmin datashowsthatIwascyclingatasafespeedfortheroadconditionsand allIcansayisiftherehadbeenanyopportunitytoavoidthecollisionby brakingorswerving,Iwouldhavedoneso.Thecarleftmewithno chance”.

Defendant’sevidence

 “Iwastravellingatnomorethan20mphonapproachtothejunction, intendingtoturnright.Ihadmyright-handindicatoron,slowedmy vehicle,almosttoastopandcheckedthatitwassafetoturn.Ididnotsee thecyclistbeforethecollision,butIhadalmostcompletedmyturn,when thecyclistcrashedintothefrontpassengerdoorofmycar.

“AsIturnedthesunwasinmydirectionandtherewereparkedcarsback upthehillonStratfordRoad.Thecyclistmusthavebeengoingveryfast”.

IndependentWitnessevidence

WitnessA.

“Iwasapedestrianwalkinginthesamedirectionasthecyclist.Thecar turneddirectlyintothepathofthecyclist.Thecyclistwasonlyashort distancefromthecarwhenitstartedtoturnright”.

WitnessB.

“Iwasworkinginmygardenonthecornerofthejunction.Thecyclist camedownthehilltoofastasthecarwasalreadyturning”.

AdditionalDetails

TheClaimant’sGarmindeviceshowedthatshewasridingbetween20to 25mph(32to40kph)reducingtoapproximately15to20mph(24to32 kph)justbeforeimpact.

BothpartiesweregivenpermissionbytheCourttorelyuponexpert AccidentReconstructionevidence.

Injuries

TheClaimantsustainedseriouspolytrauma,includingchestandabdominal injuriesandapsychiatricreaction,butthetwokeyinjurieswere:-

Aheadinjury,categorisedamild(probable)TBI,diagnosedfromabrief lossofconsciousness,aclearCTscanandsomeposttraumaticamnesia, withanundeterminedperiodduetomedication.

Atibialplateaufracture,classifiedasaSchatzkerVI(lateralplateausplitdepressedfracture).Thefracturewastreatedinitiallybyanexternal fixator,thenaTaylorSpatialFrame.

OnTwo-WheelSeminar

Presentedby–PaulEvans Presentersemail–pe@no5.com

Christopher Hugh Goddard

Profile

A highly experienced collision investigator and Physics graduate with an extensive engineering and scientific background. He has conducted a number of high profile reconstructions and has received Chief Constable’s and Crown Court Judge’s commendations. Regularly lectures in Forensic Science and Physics at Universities and colleges. Has authored technical papers and presented at International conferences in the subject of Collision Investigation. He is a Professional Review Interviewer with the IET and is an Ambassador with the Bloodhound Supersonic Car project. Was the sole technical expert in Operation Dino case where 176 people were prosecuted for insurance fraud.

Career History

Forensic Collision Engineer: Freelance: 2010 - current

Providing a forensic collision reconstruction service to the legal profession. Producing locus reports, 3D computer scene models, animations, collision analysis and technical reports.

Senior Collision Investigator, Gwent Police: 2002 - 2020

Additional responsibilities now include the verification of reports, the training & supervision of new investigators, and sourcing technical equipment for the department. Provide specific expertise on PC-Crash reconstruction software, insurance fraud, instrument cluster, CCTV and tachograph analysis. I am also the lead for the implementation of ISO 17020.

Tutor for Collision Investigation course at De Montfort University: 2010 - current I am the personal tutor for ten students studying on a distance learning course. I provide guidance and support to the students, and mark their course assignments. I also lecture at the residential summer school for this course.

External Examiner at De Montfort University: 2005 - 2009

I received training in the University assessment protocol. My responsibilities were to ensure that the Collision Investigation course objectives were met and reflected current best practice. Verified the final year examination paper.

Lecturer in Forensic Science and Physics at Filton College, Bristol: 2005 - 2008

Lectured to a wide range of full and part time students who were undertaking a BTEC Certificate in Forensic Science. I specifically taught the module on road traffic accident investigation, but was also asked to present Physics modules. When assessed by OFSTED, I achieved a “good” result for my teaching.

Collision Investigator, Gwent Police: 1997 - 2002

Trained as a Collision Investigator and qualified in 1998. I have been awarded seven commendations for my work in investigating road deaths and have provided Collision investigation skills in ten murder cases. I have also conducted a number of investigations into police related deaths for the Independent Office for Police Conduct I have been involved in the investigation of approximately 400 fatal collisions plus a considerable number of less serious cases.

Police Constable, Gwent Police: 1992 - 2020

After four years as a divisional officer in Newport city centre, I transferred to the Traffic department where I performed a dual role covering traffic officers’ duties and trained as a firearms officer to form part of the Armed Response Unit for the force.

Office Manager, Grove Design Ltd: 1990 - 1992

Grove Design is a small Engineering Consultancy providing a computer aided design service. Projects involved developing a CCTV camera pan and tilt unit, Steelworks rolling mill, Pressure sensors for a nuclear power plant and North Sea oil-rig drill bits.

Design Engineer, Lucas Automotive Ltd: 1985 - 1990

Design Engineer working as part of a European team developing new braking systems for Heavy Goods vehicles, coaches and specialist vehicles. I was designated as Inventor of a US and European wide patent for the design of a new disc brake pad. I was resident in Germany for four months working on an Anglo-German project, I also a qualified test driver for test track research.

Apprentice Engineer, Lucas Girling Ltd: 1981 - 1985

Four year apprenticeship covering Toolmaking, Quality Assurance, Mechanical Maintenance, Production Engineering and Product Design. Produced prototype suspension for the ‘new’ XR3i and made the brakes for the Thrust 2 land speed record that later achieved the record at 621mph and then stopped!

Qualifications/ Professional Memberships

Registered as a full member of the Chartered Society of Forensic Sciences (MCSFS) - 2018

Registered as a Chartered Engineer with the Engineering Council (CEng) – 2014

Registered as a full member of the Institute of the Motor Industry (MIMI) – 2021

Advanced Automotive Engineer (AAE) with the MIMI - 2021

The Open University - BSc Hons Physics, 2:1 - 2004 - 2010

City and Guilds Graduateship Award in Engineering (GCGI) - 2006

Full Member of the Institute of Engineering & Technology (MIET) - 2001

Gwent College of H.E. - HNC in Engineering - 1986

Pontypool College of F.E. - ONC in Engineering - 1984

Technical Papers and Books

1. Goddard C and Thompson R, Friction Pad assemblies, U.S Patent 4993520

2. Goddard, C. and Price, D., A Review of Speedometers and The Criteria to Be Considered Before Accepting ‘Frozen’ Readings and Other Marks, Proceedings of the 10th Institute of Traffic Accident Investigators International Conference, Leeds 2011

3. Goddard, C. and Price, D., A Review of Speedometers and The Criteria to Be Considered Before Accepting ‘Frozen’ Readings and Other Marks (update), 22nd Annual Congress, EVU Conference, Florence, Italy. 2013

4. Goddard C, Crash Testing Stepper Motors and Speedometers, Institute of Traffic Accident Investigators’ ‘Impact’ Vol. 21, No. 3

5. Goddard, C. and Price, D., An Assessment of Speedometers Using Stepper Motors to Hold Their Position During High Speed Impact Testing, Proceedings of the 11th Institute of Traffic Accident Investigators International Conference, Birmingham 2014

6. Goddard, C. and Price, D., The Behaviour of Instrument Clusters during High-Speed Crash Testing, 24th Annual Congress, EVU Conference, Edinburgh, Scotland. 2015

7. Goddard, C. and Price, D., "Speedometers and Collision Reconstruction," SAE Technical Paper 2017-01-1412, 2017,

8. Goddard C, Finding Order in Chaos: The Manual of Collision Scene Evidence, ISBN 978-87995320-2-5

9. Goddard C, The UK’s biggest Insurance Fraud Investigation, 27th Annual Congress, EVU Conference, Dubrovnik, Croatia. 2018

10. Goddard C, The Behaviour of Motorcycle Instrument Clusters During a Collision, 28th Annual Congress EVU, Barcelona Spain. 2019

11. Goddard C, Modelling the Deceleration of a Car During a Spin, Institute of Traffic Accident Investigators’ ‘Impact’ Vol. 27, No. 2, 2019

12. Goddard, C., "Motorcycle Instrument Clusters for Collision Reconstruction," SAE Technical Paper 2020-01-0879, 2020

13. Goddard C, Presenting Expert Witness Evidence at Court, Institute of Traffic Accident Investigators’ ‘Impact’ Vol. 28, No. 1, 2020

14. Goddard, C. and Anderson, S., "Validation of Frozen Speedometer Readings Against EDR Data," SAE Technical Paper 2022-01-0821, 2022, https://doi.org/10.4271/2022-01-0821.

TwoWheelSeminar–Collision

Reconstruction

ChrisGoddard Chris@viewpointis.co.uk

ChrisGoddardBScCEngMIETMITAIMCSFSMIMIAAE

EngineeringDesigner(BrakingSystems)

28yearsinGwentPolice(23yearsasaCollisionInvestigator)

Authorof14technicalandresearchpublications

Authorofthe‘TheManualofCollisionSceneEvidence’

4yearsinprivatepractice

Ridebicyclesandmotorcycles!

TheScene

TheScene

TheScene

TheBicycle

Roadracingbicycle

Blackwithyellow handlebars

Yellowforks

FittedwithaGarmin Edge500computer

TheCar

TheImpact

TheReconstruction

GarminEdge500 computerrecords position,speed, distanceetcbyGPS

Recordsat1second intervals

StoresdatainGarmin’s .fitformat

Thiscanbeexported intoGarmin’sown software,Stravaetcor Excel

TheReconstruction

TheReconstruction

FordFiestaspeedwasobtainedfromwitnessaccountsandpractical testing

Ifwitnessevidenceisnotavailable,researchpapersprovidean expectedtimetoturn.

TheReconstruction

Replaytheeventsbackwardsintime

Takeintoaccountthetimetoturn

PerceptionResponseTime(PRT)canbedeterminedforeachparty

TheReconstruction

PerceptionResponseTime(PRT)isthetimebetweentheonsetofan emergencysituationandwhenadriverbeginsameasurable manoeuvre.

PRThasdevelopedsignificantlyinthelastfewyears.

Traditionally,PRTtimeof1.5to2secondshasbeenused.

Anewsystemisavailablethatconsidersthefactsandcircumstancesof theeventsuchasdaytime/nighttime,wasthehazardexpected,multiple hazardsetcareallconsidered,andeachfactorwillcontribute(positively ornegatively)totheexpectedresponse.

TheReconstruction

TheReconstruction

TheReconstruction

TheReconstruction

TheReconstruction

TheReconstruction

TheReconstruction

TheReconstruction

TheFuture

ElectricBicycles -ElectricAssistedPedalCycles(EAPC)areclassedasbicyclesratherthanmotor vehicles -Toqualify,theymusthave -Maximumpowerof250w -Maxassistedspeedof25km/h(15.5mph) -Tohavemotorassistance,youmustpedal -Iftheabovedonotapply,thenthe‘bicycle’isamotorvehicle.

TheFuture

MotorcycleScenario

TheScene

TheScene

TheScene

Speed

Tip-overEmergencyShut-down(ES)Rearwheel>2mphatES

Speed

TwoWheelSeminar–Collision

Reconstruction

ChrisGoddard

chris@viewpointis.co.uk

AB…TBI?

HasABsustainedatraumaticbraininjury?

Ifso–how‘bad’wasit?

Whataretheconsequencesoftheinjury?

Candowepredicthisrecovery?

Wouldhebenefitforrehabiliation?

Whatifhenotdoingaswellashoped?

Neurocogntiveconsquences…headaches..Senseofsmell…

Unexpectedconsquences…mood..epilepsy..dementia

Isthereanythinginthescenariothathelpsus?

Onlythatthereisminimalantegradeamnesia[heremembersupuntil thepointofimpact]

ThesememeoriescommonlylostinsignficantTBI’s,butdontcorrelate withseverity

AtmeassessmentIwouldbeaskingABabouthismemoriesafterthe injury[post-traumticamnesia….]

WhatpredictstheoutcomeafteraTBI?

ABScenario

Hisfirstmemoryisonawardtheeveningoftheinjury

Paramedicrecords-indicatehewasconfused[GCS14/15]

Damagetohishelmet

CTheadnormal,[exceptoccipitalcondlyarfracture]

3/12later-lowmood,impairedshorttermmemory,headaches,off work..

Thoughts?

TheMarkersofTBI

Lossofconciounsess

GlasgowComaScore

Post-traumaticamnesia

ImagingCThead

ThecomplexityoftheBrain

Neurology/neurosurgery

Neuropsychology

[neuro]psychiatry

Allapproachthebrainfromverydifferentwaystraining

Hottopics

Post-concussionsyndrome

Imaging3TMRI

Dementia

Helmetuse

Observations/Pitfalls.

CasesbasedonTBI–withnoclinicalevidenceofit

Noearlyevidenceofproblems-yetprogressivecogntivecomplainsand disability

Yearsintocases-No3timagingdone.

NeuropsychologydemeontratingacquireddefititswithTBImarkers

Pre-injuryproblemsandinjuriescomplicatingthepresentation.

Observations/Pitfalls.

CasesbasedonTBI–withnoclinicalevidenceofit

Noearlyevidenceofproblems-yetprogressivecogntivecomplainsand disability

Yearsintocases-No3timagingdone.

NeuropsychologydemeontratingacquireddefititswithTBImarkers

Pre-injuryproblemsandinjuriescomplicatingthepresentation.

TwowheeledSeminar

Abridged CV and Terms of Engagement

Mr Badri Narayan MS, MCh (Orth), FRCS (Tr. & Orth), PG Dipl (Med Law)

Consultant Orthopaedic Surgeon and Honorary Senior Lecturer

Professional Details

Name

Initial communication

Secretary and all commn

Postal Address

Consultation Sites

NHS Position

Medico-legal Experience

email: bn@traumareports.co.uk

Jill o’Brien jill@traumareports.co.uk

Tel: 0151 284 3184 (Mon-Fri, 0900 to 1700)

Trauma Reports

PO Box 168

Liverpool, L10 2YW

Liverpool, Manchester, Birmingham and Hull

Consultant in Trauma and Orthopaedic Surgery

Liverpool University Hospitals Foundation Trust

I have been in medicolegal practice from 2002 I hold a post-graduate diploma with commendation in Medical Law, and maintain regular medicolegal CPD using accredited learning methods Most of my reports are now on complex fractures and seriously injured patients My reports are illustrated as necessary, and referenced as needed to the orthopaedic literature

Personal Injury (about 150 reports a year)

Specialist Interest: Complex fractures (upper and lower limb), multiply injured patients, amputations, fractures treated with external fixation, open fractures, compartment syndrome, osteomyelitis and Fracture Related Infection

Claimant: Defendant

About 60:40 for catastrophic injury, amputation, and multiply injured claimants, and about 85:15 overall.

Court Appearances: 2011,2016,2018 (settled in Court), many scheduled for 2025

Clinical Negligence (about 12 reports a year)

Area of expertise: Complications of fracture treatment, amputations, compartment syndrome, nonunion, malunion.

Limb Reconstruction Surgery - limb lengthening, deformity correction, osteomyelitis and Fracture Related Infection

Claimant: Defendant

About 50:50

Court Appearances: called on many occasions, but all settled before hearing.

Clinical Experience

I have been a full-time Consultant in Orthopaedic Trauma and Limb Reconstruction from 2002.

My specific area of acute trauma expertise is in treating multiply injured patients, complex fractures of both upper and lower limbs, open fractures, and the use of external fixation devices such as Ilizarov frames and Taylor Spatial Frames.

I carry out limb lengthening, deformity correction, and regularly treat osteomyelitis in both upper and lower limbs. I treat complications of fractures such as nonunion, malunion, Fracture Related Infection, joint stiffness and contractures.

I have a specialist tertiary practice in reconstruction of foot and problems after neurological injury, after complications of diabetes, and in the treatment of complications after amputation surgery.

I am an Examiner Assessor for the Intercollegiate Surgical Board and the International Surgical Board I was previously an intercollegiate examiner, Training Programme Director, member of the Specialist Advisory Council, and part of Council of the British Limb Reconstruction Society.

A full list of my publications can be found here. My full CV is available on request.

Terms of Engagement and Timeframes

I prefer paperless communication An email regarding any further records required to complete my report is sent within 5 working days after the medicolegal consultation.

My approximate turnaround times are:

Personal Injury Reports and Condition and Prognosis Reports: about 35 working days* from the consultation if all records provided prior to appointment, and about 30 working days* after receipt of last set of records needed for report.

Breach of Duty and Causation reports: about 10 to 12 weeks after receipt of all records

Supplementary Reports, Correspondence, CPR Part 35 responses: 25 working days* after receipt

*working days exclude prebooked annual leave and professional leave – calendar available on request.

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