Bailey Parker Direct Examination PDF

**BAILEY PARKER DIRECT EXAMINATION:** **(first 10 questions based on rule 702 of the federal rules of evidence)** 1. **My name is Bailey Parker and I'm an independent safety consultant under Safety Defense Risk Management (SDRM) (1-3).** 2. **I went to the University of Montana for my under...

**BAILEY PARKER DIRECT EXAMINATION:** **(first 10 questions based on rule 702 of the federal rules of evidence)** 1. **My name is Bailey Parker and I'm an independent safety consultant under Safety Defense Risk Management (SDRM) (1-3).** 2. **I went to the University of Montana for my undergraduate in Mechanical Engineering (6). And while safety consulting isn't a degree you obtain in college, I have numerous other certifications that prove my expertise in the field including a Master's Certification from the National Casualty and Risk Assessment Center, along with the esteemed Gold Certification from the Utopia Commission on Risk Assessment (7-9). I also worked in insurance one summer during college with the Sweetgrass Insurance Company (SIC) before I started my independent risk management consulting company (9-11).** 3. **I believed that since there wasn't a specific degree for safety consulting a degree in mechanical engineering could help me along with supplementing it of course.** 4. **I have supplemented this degree with various certifications in safety consulting and risk management, including the Master's Certificate from the National Casualty and Risk Assessment Center, along with the esteemed Gold Certification from the Utopia Commission on Risk Assessment (7-9).** 5. **My current occupation as a safety consultant and my experience in risk assessment along with mechanical engineering aid me in my abilities to effectively perform safety consulting.** 6. **I did about every imaginable task in the insurance field (17). I worked as a local agent in sales and customer service, as a home and auto claims adjuster, an agency branch manager, and a regional manager (17-19). I then switched to the corporate side of claims like this one regarding Wade Stark here in Utopia (19-20).** 7. **I used the facts and data observed while investigating Springs Park after Wade Stark's death, and based my conclusions on those results.** 8. **I will be a voice of reason and fact to explain the evidence as they are, to aid in the verdict of your honor and honorable members of the jury. I will demonstrate the knowledge pertained from observing and investigating Springs Park, and the testimony provided will be the result of reliable principles and methods applied to the facts of the case.** 9. **In case of objection: Your honor, according to rule 702 of the federal rules of evidence, it has been sufficiently proved that Baily Parker has enough prior education and experiences in the field of risk management and safety consulting to be admitted as an expert.** 10. **I was contacted by Sydney Wilson the evening the incident occurred to work as the independent investigator to the West Maple location of Springs Park where the incident occurred. I am here today to give my expert opinion regarding what happened using the experience and understanding fostered.** 11. **The cases I investigated while I was a part of the SIC involved some severe neck, leg, and arm injury cases (32-33).** 12. **Springs Park puts safety as their first priority (38-39) and they're "on top" of all the IATP recommendations (42-43) but even with that Sidney wants to work harder to make the park even safer! Springs Park has also never been filed a lawsuit before and no one has ever been badly injured enough to require 911 assistance.** 13. **I believe that Springs Park is "rocking" with their safety measures!** 14. **I noticed that Springs Park is really organized and courteous (52) and they have also been up to date with anything asked of them (53). I noticed that they had the proper signage of both risks and rules posted throughout their facilities, safety rules appeared as posters and on digital display boards, all in all, their facilities were pretty spot on and they did all that they could to keep the facilities safe (53-55).** 15. 16. **These are the safety rules and posters at Springs Park.** 17. **Yes, I do.** **Your honor, at this time, the defense would like to enter exhibit 2 into evidence.** 18. **This evidence showed that there were numerous warnings and rules that must be followed in Springs Park.** 19. **They have posters all throughout the facilities and digital display boards (54-55).** 20. **I would say that the amount of signage at this facility was definitely beyond average. There were sufficient warnings everywhere.** 21. **They conduct daily safety checks of all equipment in the park (67-69).** 22. **The information collected helps me, and others like me, assess the overall likelihood of an accident at Springs Park occuring, as well as give valuable insight and information regarding this particular incident (69-71).** 23. **To my knowledge no lawsuits of any kind have been previously filed against Springs Park (73).** 24. 25. **It is the Springs Park Liability Waiver, signed by the plaintiff, Dakota Stark.** 26. **Yes, I do.** **Your honor, at this time, the defense would like to enter exhibit 3 into evidence.** 27. **It includes not just information regarding injuries but basically states that Springs Park is not responsible for any harm or loss. It also includes consent to any attorney fees, release for photos, and express an understanding of the liability form along with acknowledging that Utopia laws will apply should a lawsuit be filed (77-81.** 28. **I believe that if Dakota Stark did indeed sign the waiver without a proper read-through that they would be considered irresponsible as a parent for not reading before signing as signing a liability waiver should not be taken lightly (96-101).** 29. **I believe that Springs Park did all that they could do and more, due to the extensive measures they took, such as the warning signage throughout the facility.** **No further questions your honor.** **MILLS BARTON CROSS EXAMINATION:** 1. 2. 3. 4. 5. 6. 7. 8. 9. 10. 11. 12. 13. **No further questions your honor**