LOCUS REPORT Prepared For: Mr John Jones 30 Claims Avenue Claimstown Hurtington WH8 1SH Our Ref: FLS TWI0000 Prepared for: Stop Claims Insurers Stop Claims House Liability Road Defendit Defendantshire AA1 7AA 2020 Investigations 17a High Park Place, Southport, Merseyside, PR9 7QP Tel: 0844 5888 335 Fax: 0844 5888 339 Copyright 2002 Copyright 2002
LOCUS REPORT INDEX Section one: i. Statement of Agent Smith Section two: i. Locus Report Checklist (Exhibit AS1) Section three: i. Sketch showing directions of travel (Exhibit AS2) ii. Sketch showing dimensions (Exhibit AS2) iii. Sketch showing photograph positions (Exhibit AS2) iv. Photographs (Exhibit AS3) - 2012 Copyright 2002
SECTION ONE 2020 Investigations 17a High Park Place, Southport, Merseyside, PR9 7QP
Statement on behalf of: The Defendant Statement made by: Agent Smith No of Statement: First Exhibits: AS1, AS2, AS3 Date: 17 th July 2011 IN THE NO CLAIMS COUNTY COURT Claim No: NT3078P BETWEEN JOHN HENRY RHODE-CLAIMS -and- Claimant JOHN JONES Defendant WITNESS STATEMENT OF AGENT SMITH I, Agent Smith, on behalf of First Legal Support, 17a High Park Place, Southport, Merseyside, PR9 7QP will state as follows: - 1. I am 55 years of age having been born on 1 st November 1955 and I am employed as an Investigator/Process Server. 2. I make this statement in relation to a Locus Inspection that I conducted on behalf of Stop Claims Insurers, Stop Claims House, Liability Road, Defendit, Defendantshire, AA1 7AA. 3. I can confirm that I attended the accident location on Arundel Road junction with Liverpool Road, Southport, Merseyside, PR8 3 at 14.00 hours on 17 th July 2011. 4. At the time of my Locus inspection various photographs, measurements and information were recorded, which have been translated into the attached sketch plans and Locus Report Checklist. 5. The photographs mentioned are digital images and have not been altered in any way. 6. The Accident Locus Report Checklist mentioned herein is attached hereto, as exhibit AS1. 7. The measurements relating to the accident location have been detailed in the sketch plans attached to the report. 8. The sketch plans mentioned herein are attached hereto, as exhibit AS2. 9. The photographs taken at the Locus inspection are attached to the report
Continued Statement of Agent Smith Page 2 10. The photographs mentioned herein are attached hereto, as exhibit AS. STATEMENT OF TRUTH I believe that the facts stated in this witness statement are true. Dated: 17 th July 2011 Signed:.. Agent Smith
SECTION TWO
Statement on behalf of: The Defendant Statement made by: Agent Smith No of Statement: First Exhibits: AS1, AS2, AS3 Date: 17 th July 2011 IN THE NO CLAIMS COUNTY COURT Claim No: NT3078P BETWEEN JOHN HENRY RHODE-CLAIMS -and- Claimant JOHN JONES Defendant EXHIBIT This is the Exhibit marked AS1, referred to in the attached statement of Agent Smith Exhibit. Accident Locus Report Checklist Dated: 17 th July 2011 Signed:. Agent Smith
ACCIDENT LOCUS REPORT CHECK LIST Location: Arundel Road Junction with Liverpool Road Southport Merseyside PR8 3 Speed Limit: 30mph Traffic Conditions: Moderate Road Surface Type: Bitumen and chip Condition of road surface: Good Footpaths: Yes Road markings: Nil Condition of road markings: Nil Traffic signs: Nil Traffic Lights: Yes Pedestrian crossings: Yes Street Lighting: Yes Type of junction: Crossroads Type of area: Residential Visibility from accident location: Good Additional information: The traffic light phasing was studied for approximately 6 cycles. The traffic lights on Liverpool Road change from green to amber then red. When the lights on Liverpool Road change to red at the same time the lights for traffic on Arundel Road change to red and amber then green. There is no discernible all red phase with these auto traffic lights.
SECTION THREE
Statement on behalf of: The Defendant Statement made by: Agent Smith No of Statement: First Exhibits: AS1, AS2, AS3 Date: 17 th July 2011 IN THE NO CLAIMS COUNTY COURT Claim No: NT3078P BETWEEN JOHN HENRY RHODE-CLAIMS -and- Claimant JOHN JONES Defendant EXHIBIT This is the Exhibit marked AS2, referred to in the attached statement of Agent Smith Exhibit. Sketch Plans Dated: 17 th July 2011 Signed:. Agent Smith
Arundel Road Junction with Liverpool Road Southport Merseyside PR8 3 Ormskirk Not to scale Halsall Road Claimant s D.O.T. Defendant s D.O.T. Formby Liverpool Road Liverpool Road Area of impact Arrows are for information only to show directions of travel and do not show the exact position of each Party on the road at the point of impact Arundel Road Seafront Information Provided by Agent Smith 11 th July 2011
Arundel Road Junction with Liverpool Road Southport Merseyside PR8 3 Ormskirk Not to scale Halsall Road All measurements are in metres Formby Liverpool Road 17.7 20.9 Liverpool Road 19.9 3.8 7.6 Arundel Road Seafront Information Provided by Agent Smith 11 th July 2011
Arundel Road Junction with Liverpool Road Southport Merseyside PR8 3 Ormskirk Not to scale Halsall Road 9 Photograph Formby 18 Liverpool Road Liverpool Road 16 15 8 14 12 13 11 10 19 17 7 5 6 4 3 Arundel Road Seafront Information Provided by Agent Smith 11 th July 2011 2 1
Statement on behalf of: The Defendant Statement made by: Agent Smith No of Statement: First Exhibits: AS1, AS2, AS3 Date: 17 th July 2011 IN THE NO CLAIMS COUNTY COURT Claim No: NT3078P BETWEEN JOHN HENRY RHODE-CLAIMS -and- Claimant JOHN JONES Defendant EXHIBIT This is the Exhibit marked AS3, referred to in the attached statement of Agent Smith Exhibit. Photographs Dated: 17 th July 2011 Signed:. Agent Smith
1. Claimant s direction of travel along Arundel Road, 150m from the point of impact. 2. Claimant s direction of travel along Arundel Road, 125m from the point of impact.
3. Claimant s direction of travel along Arundel Road, 100m from the point of impact. 4. Claimant s direction of travel along Arundel Road, 50m from the point of impact.
5. Claimant s direction of travel along Arundel Road, 25m from the point of impact. 6. Claimant s cross view right from Arundel Road onto Liverpool, 25m from the point of impact.
7. Claimant s cross view right of from Arundel Road, 10m from the point of impact. 8. Claimant s direction of travel along Arundel Road towards Halsall Road, from the point of impact.
9. Looking back along Claimant s direction of travel on Arundel Road, 25m from the point of impact. 10. Defendant s direction of travel along Liverpool Road, 75m from the point of impact.
11. Defendant s direction of travel along Liverpool Road, 50m from the point of impact. 12. Defendant s direction of travel along Liverpool, 25m from the point of impact.
13. Defendant s cross view left from Liverpool Road into Arundel Road, 25m from the point of impact. 14. Defendant s cross view left of from Liverpool Road into Arundel Road Arundel Road, 10m from the point of impact.
15. Defendant s direction of travel along Liverpool Road, from the point of impact. 16. Looking back along Defendant s direction of travel on Liverpool Road, 25m from the point of impact.
17. View across the point of impact looking towards Halsall Road.. 18. View across the point of impact looking towards Arundel Road.
19. View of the point of impact.