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Carla Reddy is suing the Tesla Motor Company for the wrongful death of her husband Robert, who died when his 2016 Tesla S Sedan left

Carla Reddy is suing the Tesla Motor Company for the wrongful death of her husband Robert, who died when his 2016 Tesla S Sedan left the road and collided with a tree.Carla contends that the accident was the result of a failure in the autonomous driving feature of the vehicle, attributable to a manufacturer's design defect.Tesla contends that Mr. Reddy was driving under the influence of alcohol at the time of the accident and improperly navigated a turn in the road, over-riding the autonomous navigation features of the vehicle.

The following transcript presents excerpts from the direct and cross-examination of Carla Reddy and direct examination of Deputy Patrick Allen.Applying the Florida Rules of Evidence, indicate for each set of numbered linesany objections that should have been madeconsidering both the question and answer given.Explainthe grounds for the objections,any argument that might be appropriate by opposing counsel, and the probable ruling of the trial judge. If you believe no objection should have been raised indicate why you believe the question and answer were proper.

Direct exam of Deputy Patrick Allen

  1. Did you respond to a radio dispatch regarding a collision on I275 near St Petersburg on March 20, 2019 at 11:00pm? Yes, I did
  2. Please describe what you observed. . On a northbound stretch of 275 prior to the Howard Frankland Bridge I found a 2016 Tesla Model S had left the roadway and come to rest against a large palm tree.
  3. Was anyone in the automobile when you arrived? A male driver was pinned behind the wheel, very badly injured. By time I arrived he had clearly lost a lot of blood.
  4. Was he conscious? I saw his eyes blink and he was groaning. I told him an ambulance was on the way
  5. Did he say anything? He said "I think I can make it.My wife was right.My steering went out."He then began convulsing so I attempted to extract him from the car without success.Paramedics and the fire and rescue team arrived but determined he had expired.

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