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A huge housing complex in a suburb of Moscow, Russia. / Hatalmas lakótelep Moszkva egyik elővárosában.
Pictures taken from the fast Aeroexpress train between Sheremetyevo Airport and the Belorussky Railway Station in downtown Moscow, Russia. I could see a lot from Russia during the 35 minutes travel.
Képek a gyors Aeroexpressz vonat ablakából Moszkvában, a Seremetyevó reptér és a Belorusz pályaudvar között. A 35 perces úton nagyon sokat láthattam Oroszországból.
From the August 2016 return trip to Siem Reap and the Angkor complex:
I love the Angkor complex, Siem Reap, and the Cambodian people so much that I returned again for about a week to photograph as much of the “non-major” sites as I could. Some of them are slightly far from Angkor Wat (by that, I mean to say more than 10 kilometers away), and usually require a little more money to get to. Also, some of the sites (Beng Mealea, Phnom Kulen) are not included in the Angkor ticket price and have an additional admission fee.
I don’t know if there’s a set number of how many sites belong in the Angkor complex, though I’m sure it would vary. (Do you only count the major sites like Angkor Wat, Bayon, Ta Prohm? Do you add the sites that aren’t included in the standard “Angkor Pass,” but are clearly of the same era? Do you include sites that aren’t even named (as are one of the sites in this series)? All in all, I’ll put a very rough number at…50 sites in the Siem Reap area, and that includes the sites that are about 100 km away. Of those, I would say I’ve been to all but 5-10 now. All are included here with the exception, obviously, of the sites that I didn’t visit. (Off the top of my head, I can say they include Koh Ker & that respective group, which is about 120 km ENE of Siem Reap; Phnom Krom, one of the three “mountains” with temples; Ta Prohm Kel; and Mangalartha.)
In practical terms, I’m afraid that with the volume of shooting (about 1,500 frames in the past 7 days), photos will start to look redundant to those who don’t have the same interest in ancient/historical architecture or Angkor as I do. That being said, there are a few things besides temples here. The Old Market area (now Night Market/Pub Street) is represented – a little – and Phnom Kulen has a pretty nice waterfall which is also in this series. Also, I tried to catch a few people in here, though didn’t get as many as I would’ve liked.
I had my friend Mao (tuktuk driver) take me around for 5 of these 7 days this time around. As I mentioned last time, he may cost a little more than what you can arrange through a hotel/guesthouse, but he’s well worth the money (and, in the grand scheme of things, not too expensive; I paid less than $200 for the five days, two of which were “long” trips). He loves his country and heritage, he knows what he’s showing you, he’s flexible, he gives you enough ice water to keep you hydrated, and he’s just a good guy. (He even bought me a birthday cake for cryin’ out loud…) Anyway, I highly recommend Mao. You can find him here: www.facebook.com/mao.khvan (or on Trip Advisor: www.tripadvisor.com/Attraction_Review-g297390-d10726821-R... )
Now that shameless plugs and other assorted rhetoric are out of the way, it’s time to get on to the temples, ruins, and other miscellany.
The Roluos Group. It sounds an awful lot like an investment firm, no? It actually refers to a group of three temples: Lo Lei, Preah Ko, and Bakong. They are among the oldest of the Angkor temples, predating Angkor Wat.
The three are quite near each other (obviously, as this is a “group” in the physical sense). However, I’m only presenting Bakong and Preah Ko here. I did see Lo Lei, but it’s essentially a sanctuary – a single tower – and when I saw it, there were two things working against it photographically. First was the absolutely torrential downpour. (This is the rainy season in Cambodia, after all, and I saw some rather fantastic thunderstorms, almost every day, but only a few minutes each day as a rule.) The other is that it’s currently under restoration and completely covered with scaffolding right now and, frankly, that doesn’t make for a very attractive picture. But, it was nice to see, and move on.
As I mentioned, the Roluos group is rather old. The three temples here all date to the late 9th century. At the time, this was Indravarman I’s capital (called Hariharalaya). When this was the capital, the only temple (if I’m not mistaken) that was built around the Angkor Wat area was Phnom Bakheng, which was dedicated in 907 AD by Yasovarman I.
Lo Lei is the first of the three that we visited. (Mao & I were with two Dutch guys on this day trip.) I’m glad it was the first of the sites we saw. It’s supposedly four brick towers, though I only saw the one completely covered in scaffolding. When this was built by Yasovarman I, it was on an islet. Now, it’s just a hill since the surrounding land is rice fields.
The second of the three Roluos sites we visited was Bakong (considered one of the top places to see an Angkor sunset…though most people don’t come out here). Also, of the three, Bakong is the only one that resembles the bigger “temples.” It was built and dedicated to Shiva by Indravarman I. It has a central temple surrounded by three outer walls and, finally, a moat. At the time of this visit, it was just after a rain and, like Lo Lei, it’s also currently under restoration (though, fortunately, not the main structure). It’s a sandstone structure, so would actually look quite good in afternoon light, though there was certainly none to be had on this day.
The last, and my favorite of the three, sites is Preah Ko. (“Preah” means “sacred,” which I mention here because it features in the names of quite a few of the Angkor sites. “Ko” is “cow/ox,” and I can think of that in conjunction with one other site.) So, the Sacred Ox temple, which consists of six prasats (stone halls) in two rows of three, is a site that was dedicated by Indravarman I to his deified ancestors in 880 AD.
As always, I hope you enjoy this set. I appreciate you taking time to look. If you have any questions, please feel free to send me a message or leave it via comment.
Securing today’s connected enterprise is a race across many different terrains where we are often unsure or unaware of what lies ahead and who or where our opponents really are.As boundaries continue to erode between the physical and cyber worlds, between high and low-tech risks, between the human workforce and artificial intelligence, and as the valuation of digital compared to physical assets undergoes radical shifts, ASIS Europe 2018 tackles the most challenging issues.Cyber-physical threats in hyper-complex, connected environments are the core themes of the event.ASIS, as a global community of security practitioners tasked with the protection of assets – people, property, and information – is uniquely positioned to deal with enterprise-wide risks.
Transcription of plaque at the site:-
This chimney stack was originally part of the Old Lion Brewery and Malthouse erected for Bailey and Stanley.
The Calvert engraving above dated 1876 shows over thirty industrial stacks and one of only two remaining which appear to have survived is this stack at the Old Lion complex in North Adelaide. The demolition of industrial buildings in the city has been widespread in the 20th century and there are now few reminders of this aspect of nineteenth century Adelaide. This part of the Old Lion Apartments complex has been designed to complement the historical built setting of this industrial stack, the photographs also serve to illustrate this.
The Lion Brewery and Malthouse was erected for Bailey and Stanley, Daniel Garlick, architect, advertised for tenders for the construction of the malthouse, kiln and store in 1872. In 1873 Bailey sold his interest in the brewery to W H Beaglehole, Johnston, James and Gasquoine. Further alterations to the brewery were carried out in 1873 and 1875 to designs by James Cumming and in 1880 Cumming called tenders for the construction of the hotel at the corner of Jerningham and Melbourne streets. By 1883 the present form of the complex was largely achieved.
Beaglehole and Johnston continued operations until 1888 when the Lion Brewing and Malting Company Limited was formed. From 1914 the Walkerville Co-operative Brewing Company Limited supplied the Lion Hotel with beer, and the brewing section of the Lion complex ceased production, although the production of aerated water and cordials continued for some time.
This plaque was donated by John Culshaw from the Old Lion Apartments, January 1998.
Derde versie van het evenement, gepresenteerd door Studio Complex en Hangarrrrrr, met als thema Vier.
Tijdens het festival wordt onderzocht wat dit 'vieren' betekent en hoe het ook in kunstinhoudelijke vorm plaats vindt.
Met o.a. beeldende kunst, performancekunst, lekkere hapjes en drankjes, muziek, poëzie en (locatie)theater.
Vr 28 t/m zo 30 aug 2015, Cromhoffsbleekweg 75, 7513ET Enschede.
Op de foto David Scheidler met zijn muziekinstallatie.
The Orchha Fort complex, which houses a large number of ancient monuments consisting of the fort, palaces, temple and other edifices, is located in the Orchha town in the Indian state of Madhya Pradesh. The fort and other structures within it were built by the Bundela Rajputs starting from early 16th century by King Rudra Pratap Singh of the Orchha State and others who followed him.
LOCATION
The fort complex is located in the Tikamgarh district of Madhya Pradesh in the erstwhile state of Orchha. The fort complex is within an island formed by the confluence of the Betwa River and Jamni River in Orchha town. Approach to the complex from the eastern part of the market in the town is through a multiple arched bridge with 14 arches built in granite stones.
Orchha town is approximately 80 kilometres away from Tikamgarh town, which is the district headquarters of the district of the same name. Jhansi town is 15 kilometres away. Orchha is a rail head of the Central Railway on the Jhansi-Manikpur section.
HISTORY
The fort was built following the founding of the Orchha State in 1501 AD by Rudra Pratap Singh (r. 1501–1531), a Bundela rajput. The palaces and temples within the fort complex were built over a period of time by successive Maharajas of the Orchha State. Of these, the Raja Mandir or Raja Mahal was built by Madhukar Shah who ruled from 1554 to 1591. Jahangir Mahal and Sawan Bhadon Mahal were built during the reign of Vir Singh Deo (r. 1605–1627). The features of "pepper pots and domes" seen in the fort complex are believed to have inspired Lutyens in the architecture of the structures which he built in New Delhi.
MONUMENTS
The fort complex accessed from an arched causeway leads to a large gateway followed by a large quadrangular open space which is surrounded by palaces such as Raja Mahal or Raja Mandir, Sheesh Mahal, Jahangir Mahal, temple, gardens and pavilions. The fort walls have battlements, which have ornamentation. Notable architectural features seen in the fort complex consist of projected balconies, open flat areas and decorated latticed windows.
RAJA MAHAL
The Raja Mahal (King’s Palace) where the kings and the queens had resided till it was abandoned in 1783, was built in the early part of 16th century. Its exterior is simple without any embellishments but the interior chambers of the palace are elaborately royal in its architectural design, decorated with murals of social and religious themes of gods, mythical animals and people. In the upper floor of the palace there are traces of mirrors in the ceilings and walls. Its windows, arcaded passages and layout plan are designed in such a way that the "sunlight and shadow create areas of different moods and temperatures throughout the day". The interior walls of the Mahal have murals of Lord Vishnu. The Mahal has several secret passages.
A part of this Mahal was converted into a temple and named Rama Raja Temple in honour of the god Rama. There is legend associated with naming it as a temple. According to a local legend, the temple was built following Rani Ganeshkuwari, the queen getting a "dream visitation" by Lord Rama directing her to build a temple for Him; while Madhukar Shah was a devotee of Krishna, his wife's dedication was to Rama. Following this a new temple known as the Chaturbuj Temple was approved to be built, and the queen went to Ayodhya to obtain an image of Lord Rama that was to be enshrined in her new temple. When she came back from Ayodhya with the image of Rama, initially she kept the idol in her palace as the Chaturbuj Temple was still under construction. She was, however, unaware of an injunction that the image to be deified in a temple could not be kept in a palace. Once the temple construction was completed and the idol of the lord had to be moved for installation at the Chatrubhuj Temple, it refused to be shifted from the palace. Hence, instead of the Chaturbhuj Temple, the Rama's idol remained in the palace where as the Chaturbhuj Temple remained without an idol in its sanctum. As Rama was worshipped in the palace part of the palace was converted into the Rama Raja Temple; it is the only shrine in the country where Rama is worshipped as a king. The temple is guarded by a police force and the deity, Lord Rama, is considered as the king and is given a gun salute of honour every day.
SHEESH MAHAL
Sheesh Mahal is flanked on either side by the Raja Mahal and the Jahangir Mahal. This has royal accommodation, which was built for king Udait Singh. It has now been converted into a hotel. The interior of this edifice consists of a huge impressive hall with high ceiling, which is the dining hall. Its recent colour scheme renovations are an eyesore. But staying in two of its royal suites on the upper floor, which provide scenic view of the town, gives the guest a feeling of royalty.
JAHANGIR MAHAL
Jahangir Mahal is a palace that was exclusively built by Bir Singh Deo in 1605 to humor the Mughal emperor Jahangir who was a guest of the Maharaja for one night only. The palace is built in four levels with elegant architectural features of both Muslim and Rajput architecture. Its layout is a symmetrical square built in the inner courtyard of the fort and has eight large domes. It has a plethora of rooms with arcaded openings, projecting platforms and windows with lattice design work. The top floor roof of this Mahal is accessed through a steep stairway. It provides picture perfect views of the temples and the Betwa River outside the fort complex. The palace also houses a small archaeological museum.
The entrance gate from this palace, which was earlier the main gate and which has carved ornamentation, leads to the royal baths and then to an elegant small dwelling unit built within a garden in typical Mughal architectural style; this had been built exclusively for Rai Parveen, the female escort of the Raja Indramani (1672–76); her large-size portrait in a revealing and seductive attire adorns hall in this Mahal. She was a poet and musician. The building is a double storied structure built with bricks, rising to the height of the trees in the well tended garden called Anand Mahal. The garden is laid out with octagonal flower beds and has good network of water supply. There are niches in the Mahal which permit natural light to the main hall and smaller rooms.
It is said that Emperor Akbar (r. 1556–1605) who was enamored by Parveen's beauty had taken her to his palace in Agra to be his courtesan. But Parveen, who wanted to get out of the situation, composed a gazal or a couplet which stated her status as an already used woman not fit for an emperor, which enabled her to get release from Akbar's court and return to Orchha.
PHOOL BAGH
Phool Bagh is an elegantly laid out garden in the fort complex which has a line of water fountains that terminates in a "palace-pavilion" which has eight pillars. Below this garden is an underground structure which was used by the royalty as a cool summer retreat. This cooling system consists of water ventilation system that is linked to underground palace with "Chandan Katora", which is in the shape of a bowl from where fountains droplets trickle through the roof creating a rainfall.
WIKIPEDIA
(Day 3) Barton Community College and miscellaneous photos from the 2018 NJCAA Division I Outdoor Track & Field Championships held May 17-19, 2018 at BG Products Veterans Sports Complex in El Dorado, KS.
Photos by Todd Moore, Barton Sports Information Director.
These are the employees of Robertson & Company, the local catering company that is preparing the hot breakfasts and dinners for personnel on the Canyon Creek Complex. They are normally a fairly small company of seven people, but quickly were able to do all it takes to feed over 900 people, and have hired additional local community members to help out. They play music, are always smiling, and the meals have been great! At the Canyon Creek Complex Fire Camp, everyone truly appreciates this company and all they do, stepping it up during this time of need.
This project is part of the Ars Electronica Garden Buenos Aires.
In the post-coronavirus scenario, The Complex Thoughts Lab invites to think outside the box to put together a model of the new world after COVID-19. Are we willing to rethink our nature, the concept of well-being? Will we be able to commit ourselves to bequeath a better world to future generations?
For more informations please visit:
ars.electronica.art/keplersgardens/en/complex-thoughts-lab/
Credit: Emilia Galli
To see more photographs from this event, please visit: www.simoncallaghanphotography.com/London-Photographer/Eve...
Per Wikipedia:
"The headquarters of the United Nations is a complex in New York City. The complex has served as the official headquarters of the United Nations since its completion in 1952.
It is located in the Turtle Bay neighborhood of Manhattan, on grounds overlooking the East River. Its borders are First Avenue on the west, East 42nd Street to the south, East 48th Street on the north and the East River to the east. The term "Turtle Bay" is occasionally used as a metonym for the UN headquarters or for the United Nations as a whole.
The United Nations has three additional, subsidiary, regional headquarters, or headquarters districts. These were opened in Geneva (Switzerland) in 1946, Vienna (Austria) in 1980, and Nairobi (Kenya) in 2011."
Image taken of the mock-up in the UN Visitors Center (NY).
IMG_3537
This temple complex lies around 2.5km southeast of the egyptian city of Dendera and extends to around 40.000 square meters.
SHO Trio, Sandra Cuevas - Voz & Teclados, Juanjo López - Guitarra & Voz, Hernán Hecht - Batería & Voz, David Aguilar, Guitarra & Voz
Pisa, Italy.
The Piazza dei Miracoli (Square of Miracles), formally known as Piazza del Duomo (Cathedral Square), is a walled area located in Pisa, Tuscany, Italy, and recognized as an important center of European medieval art and one of the finest architectural complexes in the world. Considered sacred by the Catholic Church, the square includes Pisa Cathedral, the Pisa Baptistry, the Campanile, and the Camposanto Monumentale (Monumental Cemetery).
U.S. Army Specialist David Scharton and Staff Sergeant Alicia Sanders, both assigned to the Visual Information Support Center-Korea Region, Headquarters and Headquarter Detachment, 41st Signal Battalion, 1st Signal Brigade, interview U.S. Army Sergeant Kevin Halverson, assigned to Headquarters and Headquarters Troop, 4th Battalion, 7th Calvary, Medical Platoon, at Rodriguez Live Fire Complex, Dongducheon, Republic of Korea, on March 10, 2009. Spc. Scharton and Staff Sgt. Sanders conducted interviews of Noncommissioned Officers (NCO's) for a video as a tribute to the "Year of the NCO". (U.S Army photo by Pfc. Amanda Rigdon)
ASIS Europe 2023 – From Risk to Resilience
Today’s enterprise is connected, complex and global. Securing innovation and competitive advantage requires simultaneously protecting people, information, products, and property. Rapid, interconnected change, and shifting perceptions of risk and value are key challenges for security practi-tioners. ASIS Europe programme is designed to provide unique insights to help you, your teams and your organisation. We will examine evolving security challenges from the perspective of leaders tasked with protecting their organi-sation’s reputation and most precious assets in a manner that drives business, organisational and cultural goals. | Foto © Charles Batenburg
I must have seen this view more than any other single one, during the four days I spent wandering around Tucson with my friend Jim. I know I walked by it at least three times in one day, but I did not spend very much money there as there was not much of what I was looking for.
The twelfth day of my trip to Peru and Easter Island.
I spent my first full evening on Easter Island exploring the town and watching the sunset with the Moai's before having dinner at one of the many restaurants.
Hanga Roa is the main town, harbour and capital of the Chilean province of Easter Island. It is located in the southern part of the island's west coast, in the lowlands between the extinct volcanoes of Terevaka and Rano Kau.
The population of 3,304 (2002 census) comprises 87 percent of the total population of the island. For much of the twentieth century, the rest of the island was leased to the Williamson-Balfour Company and closed to the Rapanui; in 1914, the population of Hanga Roa was just 250 and the rest of the island was inhabited by large populations of sheep.
The island's main avenue, Avenida Atamu Tekena (formerly Avenida Policarpo Toro), is the heart of the town. Many stores, hotels, restaurants, and the island's only supermarket and pharmacy are found alongside this road. In 1998, the road was renamed after nineteenth century Rapanui hero Atamu Te Kena; it had previously been named after Captain Policarpo Toro, the Chilean Naval officer who annexed Easter Island to Chile in 1888.[1] The island's museum and also the Roman Catholic church, are located in the center of town. With the advent of the internet and the expansion of communication services by the Chilean government, many internet cafes and even an automated teller machine (ATM) have appeared in recent years.
Easter Island (Rapa Nui: Rapa Nui, Spanish: Isla de Pascua) is a Polynesian island in the southeastern Pacific Ocean, at the southeastern most point of the Polynesian triangle. A special territory of Chile annexed in 1888, Easter Island is widely famous for its 887 extant monumental statues, called moai, created by the early Rapanui people. It is a World Heritage Site (as determined by UNESCO) with much of the island protected within the Rapa Nui National Park. In recent times the island has served as a cautionary tale about the cultural and environmental dangers of overexploitation. Ethnographers and archaeologists now argue that the introduction of diseases carried by European colonizers and the slave raiding[4] that devastated the population in the 1800s had a much greater social than environmental impact.
To see my full travelblog from my trip to Peru and Easter Island visit: www.travelshorts.com/travel-blogs/peru-and-easter-island-...
© LAWRENCEcreative 2009
Wonderland Burlesque Show
Russell Industrial Complex, Detroit
April 3-4, 10-11, 2009
Theatre Bizarre/Roxi Delite
Shot for www.MOTORCITYBLOG.net
This temple complex not only serves as a religious site for the monks who live and worship there, but also features a maze of natural caves in an overgrown jungle valley where stone tools, pottery remains and the mold for making Buddha footprints have been excavated.
This cave is located at Ban Tham Suea, Tambon Krabi Noi, 9 kilometres from the provincial town of Krabi via Phetchakasem Road (Highway No. 4) and turning left onto Ratsadon Phatthana Road (Highway No. 4037). Tham Suea means tiger cave because the cave in front of Ao Luk Thanu Range or Khao Kaeo features natural rock impressions of tiger paws and real tigers once roamed this area. The surrounding area is covered with lush forest and enormous trees hundreds of years old, particularly in the Khiri Wong Valley. Mountains are on all sides and there are smaller caves in great numbers such as Tham Khonthan, Tham Lot, Tham Chang Kaeo, Tham Luk Thanu, and Tham Phra. Aside from being the site of a meditation centre, it is also a place of archaeological interest, dating from the prehistoric into proto-historic times. Stone tools, potsherds, and unbaked clay votive tablets have been found. In addition to this, there are trekking routes, and a trail of 1,272 steps leading to the lookout point for a bird's eye view of the place.
I know these are mallards but I've been waiting for an opportunity to mention the remarkable Argentine Lake Duck for ages ! Some info pinched from Wikipedia below, it's a bit saucy I should warn you : ) I didn't know about what it says in the last paragraph, quite relevant to these mallards. ' Complex Mating Geometry ' !?!?!?!
' The Argentine lake duck is notable for possessing, in relation to body length, the longest penis of all vertebrates; the penis, which is coiled up in flaccid state, can reach about the same length as the animal itself when fully erect, but more commonly is about half the bird's length. It is theorized that the remarkable size of the spiny penis with its bristled tip may have evolved in response to competitive pressure in these highly promiscuous birds, removing sperm from previous matings in the manner of a bottle brush.
Although most male birds have no penis, ducks have a long corkscrew penis, and the females have a long corkscrew vagina, which spirals in the opposite direction. The males often try to force copulation, but the complex mating geometry allows the females to retain control—most of the forced copulations do not result in successful fertilisation. '
Does that mean when they mate they have to spin in opposite directions and then back the other way when they're finished ?!?!?! Oh, hang on, that wouldn't work would it.............I'm gonna have to work this out on a bit of paper..................
Miami, Florida
Listed 10/16/2018
Reference Number: 100003017
The Bacardi Complex in was constructed in 1963 and served as the first United States headquarters for the Bacardi corporation, a Cuban company notable for its rum. The Bacardi complex consists of two prominent buildings, the main tower and the Bacardi Imports Administration Annex building that was completed in 1973. The buildings are iconic examples of mid-century modern International-style architecture, notable for their uses of steel and glass, each featuring imaginative cantilevered overhangs as the bulk of the building. They are each emblazoned with artistic products, with the tower decorated with over 28,000 azulejo tiles painted and assembled by Brazilian artist Francisco Brennand. The Annex building’s four walls are entirely defined by stained-glass windows manufactured by French artists Gabriel and Jacques Loire based upon a painting by German artist Johannes Dietz. The buildings are notable for the way they embrace international influences within architecture and art to create visually impressive works.
Since the establishment of the company in 1862 in Santiago de Cuba, the business has successfully expanded the branding, production, and headquarter sites outside of Cuba. Bacardi’s buildings in Miami have aimed to create and promote a visual identity for the corporation, one which is simultaneously past and forward-looking, with an appreciation of the natural and the man-made. Bacardi’s buildings are attempts to express concepts larger than mere business, combining art and architecture to tell a larger story.
National Register of Historic Places Homepage
via
Moss & Colella announces victory in Court of Appeals decision on complex no-fault motorcycle accident case
Court finds “no error” in attorney remarks to jury
Media contact: Barbara Fornasiero, EAFocus Communications, 248.260.8466; barbara@eafocus.com
Southfield, Mich. — January 3, 2019 — David M. Moss, founding partner of Southfield-based civil rights and personal injury law firm Moss & Colella, P.C., announced victory following a December 27, 2018 Michigan Court of Appeals decision in Frank Wojcik v AAA. This is the second victory in the complicated case, where David Moss and Moss & Colella associate attorney Ryan Piekarski previously won a jury trial.
Background:
This is a claim for Personal Injury Protection (“PIP”) benefits under the Michigan No-Fault Act. At 10:00 p.m. on July 28, 2013, Plaintiff Frank Wojcik and his girlfriend and passenger Tiffany Clarke, sustained injuries in a motorcycle accident while traveling northbound on a two-lane roadway in rural Bay County. Wojcik suffered a closed head injury and had no memory of the accident. Clarke testified that just prior to Wojcik losing control, a vehicle approached from behind, passed the bike, and re-entered the lane in front of them, causing Wojcik to lose control, fishtail and flip the bike.
According to Defendant AAA, Wojcik lost control of the motorcycle while entering a left-hand curve immediately prior to the intersection, and then the motorcycle ran off the right side of the road and crashed into a ditch. Defendant AAA further contended that alcohol may have been a factor. More importantly, AAA argued that “this was a single motorcycle accident with no other vehicle ‘involvement.'” The only “eye-witness” that had seen “headlights” for a split second before the crash admitted that a cornfield obscured his view of the straight part of the road. The witness testified “…[Wojcik] didn’t even come close to making the corner, just went straight” (suggesting that Wojcik was unable to control his bike as he entered the curve in the road). Motor vehicle involvement ultimately became the centerpiece of the trial and the issues presented for appeal.
A Michigan State Trooper arrived on scene and briefly interviewed both the eyewitness and Clarke. Three days later, the trooper interviewed Clarke again. During the interview, Clarke failed to mention another motor vehicle was involved in the accident. Later, she swore in an affidavit that “[a] car rapidly pulled up behind Frank’s motorcycle and then attempted to pass us by pulling around to our left. The car cut back in front of us causing [Wojcik] to brake to avoid contact, which resulted in [him] sliding on the gravel and losing control of the motorcycle.”
Approximately two months later, Clarke submitted a claim for no-fault PIP benefits, alleging it was the other vehicle that caused Wojcik to lose control. The claim was promptly denied by AAA, prompting Clarke and Wojcik to file their lawsuits. Contemporaneously in a separate filing, Clarke filed a negligence lawsuit against Wojcik, claiming that his actions and omissions caused the accident resulting in her injuries.
While the two cases were still separate, Wojcik filed a motion for summary disposition in his case on the issue of motor vehicle involvement, relying on Clarke’s affidavit and contending that no other evidence effectively countered it. The trial court granted the motion, but on Defendant’s interlocutory appeal, the Court of Appeals reversed, concluding that “Clarke’s credibility, in this case, is crucial to determining whether a motor vehicle was involved.” The case was remanded for trial and the jury ultimately rendered a verdict in favor of the plaintiffs. Damages for no-fault PIP benefits and penalty interest were awarded and separate judgments for Clarke and Wojcik were entered pursuant to the verdict.
The Court of Appeal Findings:
Following trial, AAA filed an appeal, arguing that the trial court erred (1) in precluding defense counsel from impeaching Clarke with the allegations she made against Wojcik in her third-party lawsuit, and (2) allowing plaintiff’s counsel to argue that “mere” evidence of motor vehicle involvement was sufficient to entitle the injured motorcyclist to collect no-fault benefits.
The Court of Appeals rejected both arguments. With respect to AAA’s claim that it was wrongfully denied an opportunity to introduce Clarke’s complaint, the court held, “[w]hile defendant claims that the exclusion of evidence regarding Clarke’s legal claims against Wojcik hindered its ability to challenge Clarke’s credibility, particularly with regard to whether an SUV caused the accident giving rise to these appeals, a thorough review of the record, particularly defense counsel’s cross-examination of Clarke, belies the claim.” As for AAA’s claim of “egregious” conduct on the part of Plaintiff’s counsel in suggesting a different standard of proof than that allowed by law, the Court found that the jury was instructed properly on the law. “Jurors are presumed to follow instructions and defendant is therefore hard-pressed to assert that it was prejudiced by any alleged errors or that the alleged errors impacted the outcome of the jury’s verdict.”
Moss & Colella responds:
David M. Moss, counsel for Wocjik, said the key to the trial victory was witness preparation.
“We always knew the case would rise or fall on the testimony of Clarke; therefore, we had to make certain that she was thoroughly prepared for a rigorous cross exam,” Moss said. “While establishing Clarke’s credibility was important, exposing the inexperience of the trooper and the inability of the eye-witness to have actually seen the accident were equally as influential.”
Ryan Piekarski argued the case before the Court of Appeals.
“From the start, the panel was troubled by AAA’s inability to cross-examine Clarke on the allegations in her negligence case; however, I was able to point to numerous places in the record where the defense had the opportunity to challenge her credibility before the jury,” Piekarski said. “Having a precise recollection of the record, in addition to being able to quickly cite to the legal standards and precedent, were crucial to flipping the panel.”
About Moss & Colella
Established in 1997, Moss & Colella represents the victims of personal injury, civil rights violations, discrimination, medical malpractice, and wrongful death. If you or a loved one is searching for a Michigan police brutality lawyer or a Michigan truck accident lawyer, look no further. The firm is recognized as a leader in complex tort litigation, including excess and deadly force, jail death, sexual abuse and harassment, auto and truck accidents, motorcycle accidents and other serious injury and wrongful death claims. To learn more about the firm and its diverse areas of practice, visit www.mosscolella.com.
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