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`J.D. OF STAMFORD/NORWALK
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`AT STAMFORD
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`JULY 18, 2017
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`NO. CV 15 6026712 S
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`DEBRA BURTON
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`V
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`USA TAXI OF STAMFORD, LLC, ET AL.
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`EXPERT DISCLOSURE
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`Pursuant to Practice Book § 13-4, the defendant hereby discloses that he
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`expects to call Douglas W. Peden, R.A., NCARB, as an expert witness in this case. Mr.
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`Peden is employed by Robson Forensic, 354 North Prince Street, Lancaster,
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`Pennsylvania.
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`SUBJECT MATTER
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`Mr. Peden is an architect with expertise in building design and planning. In
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`particular, he has expertise in building codes and standards, site design and planning
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`and assessment of premises safety.
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`SUBSTANCE OF FACTS AND OPINIONS
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`Mr. Peden is expected to testify that the available exterior lighting at 7 Woodrow
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`Street provided reasonable levels of illumination and met the standard of care for the
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`type of structure located at 7 Woodrow Street. It is expected that Mr. Peden will testify
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`that the defendant, Mr. Anacaya, complied with all reasonable practices and standards
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`and that he was not required to put a light at the end of his driveway especially in this
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`case where there was more than enough illumination present for a residential structure.
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`Mr. Peden is expected to testify that in the area where Ms. Burton was allegedly
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`standing, there would have been more than sufficient light provided by both the City of
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`Stamford lighting and the lighting on the property, and that the lighting exceeded the
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`minimal level suggested for exterior lighting of a residential structure. He will further
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`testify that there is no legal requirement that the driveway have lighting structures at the
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`end of the driveway. He is also expected to testify that the defendant, Mr. Anacaya,
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`complied with the standard of care for exterior site lighting as required by the State of
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`Connecticut and the City of Stamford. He is further expected to testify that there is no
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`evidence that reasonably leads to the conclusion that exterior illumination is a factor in
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`Ms. Burton’s claim that a taxi driver ran over her foot. It is further expected that Mr.
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`Callahan will testify regarding light trespass and light disturbance to adjacent residential
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`areas and why the exterior lighting of 7 Woodrow Street was reasonable and met the
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`standard of care. He will discuss how lights can cause nuisance, glares to homes in a
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`residential community and other places of sleep. He will further testify as to the duties of
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`a homeowner versus a municipality in repairing, maintaining and operating a city street
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`light. He is expected to testify that based on his review and analysis of the materials and
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`evidence to date that any amount of lighting would not have prevented this accident. He
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`will further testify that there was a city street light present just above where the accident
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`happened that would have illuminated the area properly and it is logical, reasonable,
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`and responsible for a landowner who owns and possesses adjacent property to rely on
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`the city to properly illuminate a city sidewalk area.
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`SUMMARY OF GROUNDS
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`The grounds of the opinion for Mr. Peden are his visits to the accident site, his
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`measurements taken at the scene, his review of the testimony in this case, his review of
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`the relevant residential exterior lighting standards including the standards for the City of
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`Stamford and/or the State of Connecticut. Mr. Callahan will testify regarding the
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`measurements he took on the property and the standard of care required for a home
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`owner.
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`THE DEFENDANT ILDER ANACAYA
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`/s/412821
`BY
`MICHAEL O. CONNELLY
`MURPHY KARPIE CONNELLY &
`SICKINGER LLC #104071
`350 Fairfield Avenue, Suite 408
`Bridgeport, CT 06604
`Tel (203)333-0177; Fax (203)333-8475
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`CERTIFICATION
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`This is to certify that a copy of the foregoing has been mailed, U.S.Mail,
`postage prepaid, on July 18, 2017 to:
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`Adam Blank, Esq.
`Wofsey Rosen Kweskin & Kuriansky, LLP
`600 Summer Street
`Stamford, CT 06901
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`Dennis M. Laccavole, Esq.
`Goldstein and Peck, PC
`1087 Broad Street
`Bridgeport, CT 06604
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`J. Kevin Golger, Esq.
`1087 Broad Street, 3rd Floor
`Bridgeport, CT 06604
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`/s/412821
`MICHAEL O. CONNELLY
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