Cyclist was in driver’s blind spot, defence crash specialist testifies

‘[Victim] would have been in the driver’s blind spot,’ senior collision reconstructionist tells court

The truck involved in the crash that killed Ottawa cyclist Nusrat Jahan didn’t have side guards. (CBC)

A collision reconstructionist called by the defence at the trial examining the cycling death of Nusrat Jahan says the driver of the construction truck would not have seen her when they were stopped at a red light in downtown Ottawa.

Steven Conley, 40, has pleaded not guilty to criminal negligence causing death and dangerous driving causing death.

Jahan, a 23-year-old student originally from Bangledesh, was cycling to school on the morning of Sept. 1, 2016, when the truck struck her at the intersection of Laurier Avenue W. and Lyon Street just before 8 a.m., pinning her under its rear wheels.

Mark Paquette, a senior collision reconstructionist with 30 Forensic Engineering in Toronto, conducted a blind spot analysis of the fatal collision for the defence team.

Paquette has been a forensic engineer for 10 years, developing specialities in reconstructing vehicle collisions of both cars and commercial vehicles and analyzing driver blind spots.

He has not yet been qualified as an expert by Ontario Court Justice David Berg.

Tested blind spot

In late May, Paquette went to an Ottawa parking lot with the same Tomlinson vehicle involved in the collision.

Paquette placed himself in the driver’s seat and adjusted his seating position to Conley’s height.

An assistant put a rod equal to Jahan’s height to the right side of the passenger door. The rod was moved back in increments in order to determine at what point the rod was no longer visible to the driver.

The engineer then layered that data over 3D photographs from the fatal intersection — including the stop lines as they were at the time of the crash.

Paquette concluded that when Conley and Jahan were stopped at the red light, the driver couldn’t see Jahan on her bicycle.

Nusrat Jahan, 23, was struck by a truck and killed while cycling on Laurier Avenue West on Sept. 1, 2016.(courtesy of family)

“Ms. Jahan would have been in the driver’s blind spot, she would have not been visible to Mr. Conley when they were both stopped at the stop line on the red light,” Paquette testified.

Bike stop lines moved since collision

At the time of the collision there was a 1.77-metre separation between the bicycle and vehicle painted stop lines marked on Laurier Avenue W.

After Jahan’s death the city moved the stop lines, and there is now five metres of separation.

In court, defence lawyer Dominic Lamb asked Paquette if he agreed with the blind spot analysis conducted by Det.-Const. Greg Rhoden, who concluded that Conley would not have seen Jahan from the cab of his truck.

“I would agree with that,” Paquette replied.

Rhoden was replaced on the investigation for “unrelated reasons” and his replacement, Det.-Const. Alain Boucher, conducted a re-enactment at the fatal intersection.

Boucher’s report was revealed in court to contain several key mistakes, and Berg ruled Monday that Boucher wasn’t qualified as an expert witness, and both his testimony and report are inadmissible.

Paquette told court Boucher’s finding that Conley would have been able to see Jahan was “incorrect” because he used a stand-in driver taller than Conley and used an incorrect location of the bicycle stop line.


2018 Forensic Investigation Forum: Ottawa

30 Forensic Engineering, Canada’s leading and fully-independent multi-disciplinary forensics firm was pleased to host the 2018 Forensic Investigation Forum in our nation’s capital. Held downtown Ottawa on June 19th, the afternoon seminar brought together senior industry leaders and was designed to provide a current forensic engineering perspective on property and casualty claims and risk mitigation.  30 Forensic Engineering would like to take this opportunity to thank our Ottawa area insurance and legal industry partners for making the event a success.

Behind the Wheel of Truck & Auto Investigations

What’s Driving The Future of Collision Reconstruction?  Understanding The Role of Biomechanics and Human Factors in Motor Vehicle Accidents.



Jamie Catania, B.E.Sc., M.Eng., P.Eng
President, Head of Casualty Group




Mark Fabbroni, B.A.Sc., M.A.Sc., P.Eng
Principal, Trucking Claims




Rob Parkinson, B.Sc., M.Sc., Ph.D
Principal, Biomechanics and Personal Injury




Adam Campbell, B.Kin., Ph.D
Senior Associate, Human Factors




Mark Paquette, B.A.Sc., P.Eng.
Senior Associate, Collision Reconstruction



A Forensic Engineering View on Fire, Flood 
& Property Loss Investigations 

A Multidisciplinary Approach to Mitigate Risk & Expense on
Property Files.



Robert Sparling, B.Eng.Mgt., P.Eng
Vice President




Jeff Reitsma, MBA, PMP, P.Eng
Principal, Multidisciplinary Remediation




Tom Pepper, B.Eng., P.Eng
Practice Lead, Building and Fire Code





Mrinmoy Kanungo, M.E.Sc., P.Eng
Practice Lead, Geotechnical & Mining





The Society of Automotive Engineers International Publishes 30 Forensic Engineering Research Paper

(TORONTO) — 30 Forensic Engineering, Canada’s leading and fully-independent multi-disciplinary forensics firm, is pleased to announce that the Society of Automotive Engineers International (SAE) has published a technical paper produced by the 30 FE Trucking and Collision Reconstruction groups.

Titled “A Study of In-Service Truck Weights” – the paper was presented by Mark Fabbroni, Principal Trucking, at the SAE World Congress in Detroit, Michigan on April 5, 2017. This event is the annual global meeting place of the automotive industry. The 30 Forensic Engineering presentation was part of the “Occupant Protection: Collision Reconstruction” session of the Congress, which is dedicated to “the latest research related to methods and techniques for reconstructing vehicle crashes.”

Mark Fabbroni, Jennifer Rovt and Mark Paquette (members of the 30 Forensic Engineering Trucking and Collision Reconstruction groups) developed the paper in response to a data gap they discovered relating to the weights of heavy vehicles such as tractor-semitrailers, straight trucks and combination vehicles travelling on North American roads. When such vehicles are involved in collisions, their weights are rarely known. As collision reconstruction relies on the availability of accurate numbers for use in calculations and simulations, this lack of data is a significant barrier to producing accurate reconstructions.

About the Research Paper
The team discovered that the Ministry of Transportation of Ontario had conducted a Commercial Vehicle Survey in 2012, which sampled the weights of over 45,000 heavy vehicles of various configurations. Fabbroni, Rovt and Paquette gained access to this data and immediately recognized its value in the context of collision reconstruction involving heavy vehicles. The next step was to organize the data into a practical resource, which could be referenced by professionals in their field. The resultant paper analyzes weight data according to the vehicle configuration, body style, and total number of axles and presents the results for the empty and in-service weights of the surveyed trucks. Through comparing these results to prior studies, the 30 Forensic Engineering team was able to conclude that the results should be applicable to most North American jurisdictions.

About SAE International
SAE International, founded as the Society of Automotive Engineers, is a nonprofit organization that develops and publishes standards used for the aerospace, automotive and commercial-vehicle industries. Headquartered near Pittsburgh, SAE standards are authorized, revised and maintained by over 9,000 engineers and other professionals and are used by 120,000 members located around the world.

30 Forensic Engineering Strengthens its Collision Reconstruction Group with the Appointment of Brad Muir

(TORONTO) — 30 Forensic Engineering, Canada’s leading and fully-independent multi-disciplinary forensics firm, is pleased to announce the appointment of Brad Muir as a Consultant within the Collision Reconstruction division.

Having been one of the longest-serving and most senior collision reconstructionists within the Ontario Provincial Police (OPP), Brad brings over two decades of experience to the firm, along with internationally-recognized expertise as a thought leader in crash data (‘black box’) retrieval, analysis, and interpretation for both passenger and commercial vehicles.

Brad has assisted on or led more than 1000 serious personal injury and fatal motor vehicle collision investigations, brings extensive experience conducting full-scale crash testing, and has been qualified as an expert in his field in Ontario Courts. “30 is excited to have someone of Brad’s caliber and experience and commitment to traffic safety onboard—he is a welcome addition to our growing firm,” stated Jamie Catania, Vice President, Forensic Consulting of 30 Forensic Engineering.

30 Forensic Engineering (, based in Toronto, has been serving the insurance and legal industries for 15 years and is one of Canada’s largest and most respected multi-disciplinary forensic firms. Our core team of 60+ professional investigators is enhanced through relationships with some of the top scientists, standard-makers and specialized consultants in North America. We provide world-class engineering and consulting expertise in: Civil/Structural, Geotechnical and Mining, Construction Claims, Personal Injury and Collision Reconstruction, Electrical and Renewable Energy, Environmental Health and Safety, Remediation, Materials Failure/HVAC, and Fire and Explosion investigations.

For further information, please contact:

Paul Aquino, Director, Marketing
Direct: 647-738-5326

For confidential inquiries on becoming a member of the -30- Forensic Engineering team, please contact:

Jamie Burns, Director, Human Resources & Talent Acquisition
Direct: 647-738-5472

30 Welcomes Marina Momcilovic to the Collision Reconstruction Team!

30 is excited to announce Marina Momcilovic as the newest addition to the Collision Reconstruction Team! Marina will be supporting Collision Reconstruction on a maternity contract for the next 12 months.

Marina hails from Serbia and attended York University where she obtained a double major degree in Psychology and Sociology. Previously, Marina was an Assistant Manager at various retail stores and brings valuable experience in areas of client relations and customer service.

In her spare time, Marina loves to stay active working out and is also an avid biker (as are many other 30’ers!).

Welcome to the team, Marina!

30 Forensic Engineering (, based in Toronto, is one of Canada’s largest and most respected forensic firms. Our core team of professional investigators is enhanced through relationships with some of the top scientists, standard-makers and specialized consultants in North America.

30 Welcomes Nishan Perera to the Collision Reconstruction Group!

30 is excited to annouce our newest member of the Collision Reconstruction team, Nishan Perera!

Nishan joins us from SkyJack Inc. where he spent the last few years as a Senior Product Safety Engineer responsible for investigating incidents involving SkyJack equipment as well as working with safety regulations for their products. Prior to working at SkyJack Inc., Nishan spent time with Hitachi Construction Truck Manufacturing as a Designer and Analyst. A graduate from the Mechanical Engineering (Automotive option) at the University of Windsor, Nishan has already obtained his P.Eng and has shown a true passion for the forensic engineering field by taking Crash Investigation courses through Northwestern University.

Nishan brings a deep knowledge and passion for automobiles, and is often working on his vehicles in some capacity or another. In addition to working on them, he also enjoys finding out has fast he can make those vehicles go around a course.

With all these things combined we feel that he will be a fantastic addition to the team, and we are excited to welcome him on board. Welcome to the team, Nishan!

Giffin Koerth Sponsors Advocate Society’s event “Making a Fundraiser: An Evening with Dean Strang”

Giffin Koerth was proud to be a sponsor of last night’s Advocates Society event featuring Dean Strang, one of Steven Avery’s trial lawyers featured in the Netflix documentary “Making a Murderer”.

It was an incredible event with all proceeds going to War Child; a non-profit organization that is helping mothers and families around the world give their children a safe start in life and give their communities the best chance of a peaceful future.

Thank you to the Advocates Society for organizing such a great event!

GK’s Collision Reconstruction Group Welcomes Harrison Griffiths!

Giffin Koerth’s Collison Reconstruction Group is happy to welcome Harrison Griffiths as their newest Associate!

Prior to joining GK, Harrison spent the last 3+ years working for Kenaidan Construction on various projects across the GTA (including the Ashbridges Bay Wastewater Treatment Plant upgrade and the West Richmond Hill Pumping Station) in the role of Mechanical/Electrical Coordinator, as well as Commissioning Agent. In addition to his interest in rock climbing, Harrison competes in a number of different sports such as softball!

Harrison is a graduate of Queen’s University where he completed his degree in Mechanical Engineering.

Welcome, Harrison!

Giffin Koerth Participates in Advocate’s Society Civil Litigation Skills Program in Calgary, Alberta

On November 3rd, Giffin Koerth’s Road Safety Principal, Russell Brownlee, and Collision Reconstruction Senior Associate Dave Porter participated in the Advocates’ Society Civil Litigation Skills Program in Calgary, Alberta. The event brought together lawyers to further develop their skills in Examining and Cross-Examining Experts.

The program offered lawyers the chance to practice examining expert witnesses, learn about preparing for witness examination and learn from the experts about their experience in court. Although the full day program was geared towards assisting lawyers in trial, Dave and Russell were excited for the opportunity to participate in the educational sessions and provide their input.

“The Advocates’ Society was established in 1963 to ensure the presence of a courageous and independent bar and the maintenance of the role of the advocate in the administration of justice.” (The Advocates’ Society) It is through programs such as this that they are able to do just that.