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CONFIDENTIAL ATTORNEY WORK PRODUCT

Deposition Summary

of

Molly Carney

Taken May 30, 2013

Re: Carney v. Geiger, rear-end collision.

Case No.: 58942

Appearances:

For the Plaintiff: For the Defendant:

Cherish Sadang Cassie Geiger

By: Samia Morteo

Plaintiff’s Answers to Defendant’s Interrogatories 3

Page:Line Testimony

Examination by Samia Morteo

3:7 4:5 Deponent’s name and employment

Deponent states that her full name is Molly Carney and she works at Wachovia

as a financial advisor and account manager.

3:19 4:1 No use of seatbelt

Prior to and during the accident, Ms. Carney was not wearing her seatbelt.

5:6 5:21 Particularities of the accident

Ms. Carney was driving East on 540 and headed to work at 9 a.m. when she

attempted a lane change around a slow moving tractor-trailer. She was

travelling 10 miles over the posted speed limit. It is likely that no turn signal

was used and she did not see the Defendant in her rear-view mirror. A rear-end

collision forced Ms. Carney off the road. She indicates that she was not under

the influence of alcohol or any medications or illegal substances.

Attorney Work Product