Free Reply to Response to Motion - District Court of Connecticut - Connecticut

Case 3;02—cv-01802-AVC Document 104-3 Filed 09/21/2004 Page 1 of 2 ,_
UNITED STATES DISTRICT COURT I
· 4 DISTRICT-OF CONNECTICUT
PHILIP GLYNN, : I
Plaintiff, : »
v. Civil No. 3 :02CVl 802(AVC)
BANKERS LIFE AND CASUALTY I
COMPANY, : .
Defendant : JULY 19, 2004
AFFIDAVIT
The undersigned being duly sworn, hereby deposes and says: , .
I of legal age and believe in the obligation of an oath or affirmation; _
2. I make this affidavit based upon my personal knowledge;
3. I am currently a Professor of Economics and Decision Sciences at Southern
l Connecticut State University;
4. In 1987, I received my Ph.D. in Systems Engineering from the University of
Virginia; s
5. I am a past President of the Connecticut Chapter of the American Statistical
Association; V
A 6. I have experience and expertise as a decision analyst with substantial applied
g work in economic problems and probability assessment;
7, I have reviewed various studies andstatistics forthe year , including
g _ . __ _those_fr0m the National IéIighway Traffic and Safety Administration; _ g

Case 3:02-cv-01802-AVC Document 104-3 Filed 09/21/2004 Page 2 of 2 _
. A l I
8. I have prepared an expert report entitled "Calculation of Probabilities for li
' Alcohol Related Fatalities in Auto Accidents," which was disclosed to the
defendant on October 24, 2003, in the plaintiff’ s expert disclosure;
9. I have come to the conclusion that the probability of an alcohol related fatal
accident for an alcohol impaired driver and non-driver per 20 vehicle miles I
traveled is about one in a million for both the United States and Connecticut.
' .04 ki `
ehdr o aghimi,_P .D.
i Subscribed and sworn to, before me, at I _ _ Mp · A/I _ V this Q 3 kl day of
,2004. •
Ya Q gn . »
. o u lic
A My commission expires:
HENRYTBAUM JR
_ MYOOMMISS|ONE>(PlRES03I31I2009
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