blog

North Carolina Exhibits

NC1 Yellow-Light Flaw

Yellow-Light Flaw in One Page

Dec 2, 2018
NC2 American Traffic Solutions--All Citations Illegal -- One Page

American Traffic Solutions--All Citations Illegal in One Page

Dec 2, 2018
NC3 American Traffic Solutions - Engineering without a License

American Traffic Solutions (aka., Verra Mobility) -- Engineering without a License

On November 29, 2018, the North Carolina Board of Examiners for Engineers and Land Surveyors (NCBELS) declared that American Traffic Solutions (ATS) is guilty of practicing engineering without a license. By NCGS-160A(a1) (city) or NCGS 153A(a1) (county), not a single red light camera in Wilmington, Fayetteville and Greenville has been installed legally. Every citation issued by American Traffic Solutions in North Carolina has been illegal.

The red-light camera installation plans are engineering plans, but the plans are not certified by a licensed professional engineer and the firm producing the plans, American Traffic Solutions, is not licensed to practice engineering in North Carolina.

We know that American Traffic Solutions is also guilty of this same problem in New York and Louisiana. We know that Conduent (aka Xerox) is guilty in New York. The problem most likely extends to most States where red-light camera companies do business.

Nov 20, 2022
NC4 Redflex Practicing Engineering without a License - Cease and Desist

Redflex Practicing Engineering without a License - Cease and Desist - 2007

Apr 27, 2019
NC5 NC MUTCD 2012 Supplement

NC MUTCD 2012 Supplement

May 28, 2014
NC6 MUTCD Speed Limit should be 85th Percentile

MUTCD Speed Limit should be 85th Percentile

May 28, 2014
NC7 NCDOT Standard Practice for Signed and Sealed Signal Plans

NCDOT Standard Practice for Signed and Sealed Signal Plans

Oct 9, 2012
NC8 NCDOT Requirements for Signed and Sealed Signal Plans

NCDOT Guidelines for the Preparation of Signal and ITS Plans (includes certification requirements)

Apr 2, 2018
NC9 NCGS 153A-357(a1) Requires Engineering Plans to be Certified

21 NCAC 56-1103 Engineer Certification Requirements

Mar 22, 2018
NC10 NCGS 153A-357(a1) Requires Engineering Plans to be Certified

NCGS 153A-357(a1) Requires Engineering Plans to be Certified for county building permits.

Mar 9, 2018
NC11 NCGS 160A-417(a1) Requires Engineering Plans to be Certified

NCGS 160A-417(a1) Requires Engineering Plans to be Certified for city building permits.

Nov 20, 2022
NC12 Public Information NCGS 132

Public Information NCGS 132

Mar 23, 2018
NC13 NCDOT Yellow Change Interval Spec

NCDOT Transportation Systems Management and Operation (TSMO) Unit Design Manual, Signal Design Section Part 1, 2021

The yellow change interval spec is Std. No. 5.2.2 Sheet 5 of 5, on page 130

Mar 19, 2023
NC14 NCDOT Yellow Change Interval Spec

NCDOT Yellow Change Interval Spec, 2012

May 7, 2014
NC15 NCDOT ITSS Unit Design Manual

NCDOT ITS Unit Design Manual. Std 5-2-2, Sheet 4 of 4, 2012

The yellow change interval spec is Std. No. 5.2.2 Sheet 4 of 4, on page 100

May 7, 2014
NC16 NCDOT ITSS Unit Design Manual - 2017

NCDOT ITS Unit Design Manual - 2017

Feb 28, 2018
NC17 NCDOT Spec History Confuses All-Red Clearance With Yellow Change Intervals

NCDOT Spec History Confuses All-Red Clearance With Yellow Change Intervals

May 25, 2011
NC18 NCSITE Task Force Yellow Change Interval Communications

NCSITE Task Force Yellow Change Interval Communications

The smoking gun that the NCSITE Task Force does not know what their Formula means.

The NCSITE Task Force misapplies the Formula to left turning movements. In an explicit statement, NCSITE admits that they do not know how to model left turning movements. So instead of hiring a physicist to tell them how to model such a case, NCSITE guesses and guesses wrong. NCSITE uses the ITE Formula. But the ITE Formula does not provide enough yellow time for vehicular movements that require a vehicle to slow down before entering the intersection. The Formula only models straight-through movement vehicles that proceed unimpeded to and through the intersection at the maximum allowable speed (at least the speed limit).

On top of that error, NCSITE measures approach speed at the stop bar instead of at the critical distance thus violating a law of physics embedded in the Formula.

NCSITE invalidly assumes all vehicles in the left turn lane are in a queue. NCSITE assumes all these cars are going 22.9 mph. That assumption forces non-queued cars legally traveling unimpeded at > 22.9 mph at distances over 100 ft from the intersection with a green arrow in front of them, to run a red light.

NCSITE forces school buses to run red lights. By explicit design, NCSITE does not provide yellow durations which accommodate 'unique vehicle streams'. Vehicles with air-brakes, like school buses, are unique vehicle streams. By design, the yellow duration is 0.75 seconds too short for commercial truck drivers.

Oct 29, 2012
NC19 Application of the ITE Change and Clearance Interval Formulas in North Carolina, ITE NCSITE 2004 Task Force, 2008

Application of the ITE Change and Clearance Interval Formulas in North Carolina, ITE NCSITE 2004 Task Force, 2008

Sep 5, 2012
NC20 Old Cary Citation

New Cary Citation

Old Cary Citation New Cary Citation

Compare old and new pages 2 and 4.

After confronting Cary's issuing of fraudulent citations at our hearing in January 2012, Cary decided not to chance Judge Ridgeway's adding a third class of 50,000 plaintiffs to the already existing lawsuit. And so Cary corrected the wording on the citation to match the law. According to the 2001 Wake County law, if the owner gets a ticket but the owner was not driving, the owner neither has to pay nor identify the driver. Though Cary fixed its citations, Raleigh still issues fraudulent citations.

Oct 3, 2014
NC21 Accuser Issues Verdict

Accuser Controls Verdict

Oct 11, 2012
NC22 Charges Against the Town of Cary

Charges Against the Town of Cary

Feb 1, 2012
NC23 Cary Raw Red Light Camera Data

Cary Raw Red Light Camera Data

Nov 25, 2013
NC24 Cary Citations by Intersection Graphs

Cary Citations by Intersection Graphs

Jan 8, 2013
NC25 Cary Time into Red Graphs

Cary Time into Red Histograms

Graphs of 140,000 citations--the field proof that the laws of physics apply. The amount of time drivers need to react to the onset of a yellow light depends solely on physics. The length of the yellow time is irrelevant. The amount of time drivers run the red light equals the difference between the amount of time required for physics minus the on-the-ground yellow time. The difference is v/2(a +Gg).

May 18, 2014
NC26 Cary Citations Spreadsheet

Cary Citations Spreadsheet

Feb 20, 2011
NC27 Cary Short Yellows and Turns Spreadsheet

Cary Short Yellows and Turns Spreadsheet

Sep 17, 2012
NC28 Cary Red Light Camera Intersection Signal Plans

Cary Red Light Camera Intersection Signal Plans

Jan 18, 2011
NC29 Cary's Redflex Contract & Accounting Ledger

Cary's Redflex Contract & Accounting Ledger

Jan 8, 2011
NC30 Cary Controls Its Own Traffic Signals

Cary Controls Its Own Traffic Signals

Jun 28, 2012
NC30 Cary Towne Blvd Always 45 mph

Cary Towne Blvd is 45 mph Since 1984

Oct 2, 2012

 

Fayetteville

 

NCF1 NCBELS - ATS Practicing Engineering without a License

NCBELS: American Traffic Solutions Practicing Engineering Without a License

American Traffic Solutions is guilty of practicing engineering without a license not only in Fayetteville, but also in Wilmington and Greenville. All the cameras have been installed illegally. A company cannot construct a engineering work without first having plans for that work signed and sealed by a North Carolina licensed professional engineer--an engineer with responsible charge of the work. The company as well as the engineer must be licensed to practice engineering in North Carolina.

Dec 2, 2018
NCF2 Traffic Signal Plans

Traffic Signal Plans

Fayetteville restarted their red light camera program in July 2015. When we asked Fayetteville for the traffic signal plans, it sent these. From the plans we know that the NCDOT tampered with every intersection in the year before camera installation. The Fayetteville City Council also claimed that they had NCDOT's approval to install the cameras. The problem is, is that two of these signal plans are not signed by a professional engineer, and for the third one, some Fayetteville official went out of his to blot out the signature and seal of the engineer. Two of them have no legal approval, and Fayetteville intentionally is concealing the ID of the engineer who drew up the plans. We do not know what the City of Fayetteville is trying to hide, but our guess is that the City shortened the yellow lights.

Aug 27, 2015
NCF3 Illegal Citations

Illegal Citations

The citations the City of Fayetteville / American Traffic Solutions issue are illegal. They omit your legal rights. The city ordinances violates with the North Carolina enabling statute. The enabling statute violates the North Carolina Constitution and the federal Credit Reporting Act.

Mar 18, 2017
NCF4 Verra Mobility Terminates Fayetteville Contract

Verra Mobility Terminates Fayetteville Contract

Verra Mobility decided not to renew Fayetteville's contract. This may be the first time a red-light camera company, not the city council, chose to cancel its contract

Nov 16, 2022

 

Greenville

 

NCG1 NC Appellate Court Ruling - Fearrington, Malmrose vs City of Greenville

ACLU Friend of the Court Brief

To the NC Supreme Court. A brief against red-light cameras -- in favor of the plaintiffs. This brief describes many reasons why law enforcement for a profit is bad.

Aug 8, 2023
NCG2 NC Appellate Court Ruling - Fearrington, Malmrose vs City of Greenville

NCICL Friend of the Court Brief

To the NC Supreme Court. A brief against Greenville's attempt to pervert the NC Constitution, allowing government to divert funds from the public schools.

Aug 8, 2023
NCG3 NC Appellate Court Ruling - Fearrington, Malmrose vs City of Greenville

NC Appellate Court Ruling - Fearrington, Malmrose vs City of Greenville

Greenville lost.

Mar 15, 2022
NCG4 NCBELS - ATS Practicing Engineering without a License

NCBELS: American Traffic Solutions Practicing Engineering Without a License

American Traffic Solutions is guilty of practicing engineering without a license not only in Greenville, but also in Wilmington and Fayetteville. All the cameras have been installed illegally. A company cannot construct a engineering work without first having plans for that work signed and sealed by a North Carolina licensed professional engineer--an engineer with responsible charge of the work. The company as well as the engineer must be licensed to practice engineering in North Carolina.

Dec 2, 2018
NCG5 NCBELS:  Rennebaum illegally certifies red-light camera plans

NCBELS: Rennebaum Illegally Seals Red-Light Camera Installation Plans

Though Rennebaum is a licensed professional engineer in North Carolina, he did not oversee the work. The seal and signature for engineering plans must be those of the engineer in responsible charge of the work. NCBELS suspends Rennebaum's license over this.

May 29, 2019
NCG6 NCBELS:  Rennebaum illegally certifies red-light camera plans

NCBELS Suspends Rennebaum's Professional Engineering License

NCBELS suspends Rennebaum's license for rubberstamping American Traffic Solution's red-light camera installation plans.

Dec 5, 2019
NCG7 Traffic Signal Plans

Traffic Signal Plans

The accuser in red light camera cases is the traffic engineer who signed and sealed the traffic signal plan of record. You will find the name of your accuser on the traffic signal plan containing the Timing Chart for the intersection where you got the ticket. The engineer is ultimately responsible for any penalty or injury you sustain at his intersection due to his engineering malpractice. It is the traffic engineer who allows the red light camera to be placed at the intersection. Without the approval of the traffic engineer, there can be no red light camera.

To understand the traffic engineer's role, watch this 1967 episode of Star Trek. "Capt. Kirk" is you and "Finney" is the traffic engineer.

Oct 13, 2017
NCG8 Greenville Red Light Camera Installation Plans

Red Light Camera Installation Plans

Mar 28, 2018
NCG9 The Lawsuit

Complaint (Lawsuit)

Oct 13, 2017
NCG10 Press Release of Lawsuit

Press Release of Lawsuit

Oct 13, 2017
NCG11 Engineering Non-Conformance Affidavit

Engineering Non-Conformance Affidavit

Feb 5, 2018
NCG12 Unintentional Red Light Violation

Unintentional Red Light Violation (ring-barrier failure) Video 1 and Video 2

This American Traffic Solutions video is at Fire Tower Road at Arlington Road. Both the left turn and straight-through yellows are supposed to end at the same time. They don't. This creates an unexcepted trap for the driver. The left turn phase is compatible with the straight-through phase and must end simultaenously.

From NCDOT ITS Manual, definitions: "Dual-Ring Controller - A controller unit containing two interlocking rings which are arranged to time in a preferred sequence and to allow concurrent timing of compatible phases in both rings, subject to the restraint of the barrier. Each of the compatible phase groups must cross the barrier simultaneously to select and time phases in the phase group on the other side."

American Traffic Solutions has tainted the evidence. ATS has made the red lights look much brighter. ATS does this to incriminate the driver. But this is not what the driver sees. Also notice that the left-turn signal head are red, yellow and green arrows, but ATS has changed them to solid balls. Here are photos of what the driver actually sees: photo 1 and photo 2.

Apr 23, 2018

 

Knightdale

NCK1 Knightdale Fraud and Perjury Example

Knightdale Citation Fraud and Perjury Example-George Deaton's Ticket of the Midnight Sun

Oct 24, 2012
NCK2 The Problem at Knightdale Blvd at Wide Waters

The Problem at Knightdale Blvd at Wide Waters

According to the Knightdale Police Department, crashes increased 78% at Knightdale Blvd at Wide Waters from 2003 to 2012. The red light cameras went up in 2004.

This March 4, 2013 ticket shows you why. The driver turning left got the ticket. It looks like he is running a yellow light. It is the signal heads, the angle of the road and the number of lanes that pose a visual problem: 1) The signal heads do not have back plates to make the signal indication stand out against the background. 2) Knightdale Blvd is wide road and the signal heads are relatively far away. 3) Because of the acute angle Widewaters Parkway makes with Knightdale Blvd, the straight-through lane signal heads are directly in front of the left-turning driver. The left turn signal heads face the left-turning driver only after he begins his turn. 4) There are two left turn lanes and one through lane, but there are two straight-through signal heads.

It all combines to create a serious visual problem for the driver. The driver thought he had a green light or at least a yellow.

Though not evident in this picture, the NCDOT creates another problem by setting the left-turn yellow change interval to 3.0 seconds. By the laws of physics, a left turning driver entering the intersection from this 35 mph -2% grade at 24 mph requires at least 4.2 seconds to traverse the critical distance.

This signal plan was drafted by NE Burns and signed by William Hamilton on August 26, 2011.

Aug 23, 2013
NCK3 Knightdale Fraud and Perjury Example

Knightdale Committed Fraud

This exhibit is Safelight Knightdale red light camera citation issued December 21, 2012. It shows that Safelight Knightdale was issuing fraudulent tickets.

Mayor Russell Killen, Police Chief Jason Godwin, Town Attorney Clyde Holt and the Town Council of Knightdale, know that the Town of Knightdale committed fifty thousand of acts of fraud by sending out red light camera citations prohibiting vehicle owners their legal right to say, "I was not driving at the time and location on the citation." The owner does not have to pay, give up the driver or correct the time or location information on the citation. This legal right is granted by NC Session Law 2003-3(d)(1)c and Knightdale Town Code Section 74.03 (b)(3).

Beginning April 2013, the Town of Knightdale started wording its tickets legally though confusingly.

In November 2013, Knightdale terminated their red light camera program.

May 28, 2014
NCK4 Knightdale Traffic Signal Plans

Knightdale Traffic Signal Plans

Oct 29, 2012

 

Raleigh

NCR1 Raleigh Traffic Signal Plans

Raleigh Traffic Signal Plans

Sep 24, 2014
NCR2 Raleigh Red-Light Camera Installation Plans

Raleigh Red-Light Camera Installation Plans

May 29, 2018
NCR3 Raleigh/ACS Contract - 2008

Raleigh/ACS Contract - 2008

On page 18, under paragraph "Collections", ACS worked with the City of Raleigh to "re-design the notices for more impact and effectiveness to improve collection rates."

 

Mar 9, 2014
NCR4 Raleigh Ssfelight Portal - Oct 7, 2013

Raleigh Safelight Portal - Oct 7, 2013

Under "Adjudication Process", this version of Raleigh's website omits all wording and references that the owner of a vehicle, when not driving, neither has to pay nor give up the driver. Raleigh omits an owner's legal options in order to secure payment.

Mar 9, 2014
NCR5 Raleigh RLC Safety Effectiveness Study by AECOM - 2012

Raleigh RLC Safety Effectiveness Study by AECOM - 2012

Even though is study was authored by a large engineering firm, this study is typical of others. The study avoids the scientific method thus making its conclusions invalid.

August 7, 2014
NCR6 SafeLight Raleigh Citation

Raleigh Safelight Citation

Sep 21, 2014

 

Wilmington

NCW1 NCBELS - ATS Practicing Engineering without a License

NCBELS: American Traffic Solutions Practicing Engineering Without a License

American Traffic Solutions is guilty of practicing engineering without a license not only in Wilmington, but also in Fayetteville and Greenville. All the cameras have been installed illegally. A company cannot construct a engineering work without first having plans for that work signed and sealed by a North Carolina licensed professional engineer--an engineer with responsible charge of the work. The company as well as the engineer must be licensed to practice engineering in North Carolina.

Dec 2, 2018
NCW2 Wilmington Contract with ATS - 2009

Wilmington Contract with ATS - 2009

Sep 4, 2014
NCW3 Wilmington Contract with ATS

Wilmington Contract with ATS - Amendment 2012

Sep 4, 2014
NCW4 Wilmington Agreement with New Hanover County

Wilmington Agreement with New Hanover County - 2009

Sep 4, 2014
NCW5 Wilmington Agreement with New Hanover County

Wilmington Agreement Amendment with New Hanover County - 2014

Sep 4, 2014
NCW6 Wilmington Safelight Citation

Wilmington Safelight Citation

Sep 21, 2014
NCW7 Wilmington Traffic Signal Plans

Wilmington Traffic Signal Plans

Oct 13, 2017
NCW8 Wilmington Red Light Camera Installation Plans

Red Light Camera Installation Plans - 2018

Mar 28, 2018
NCW9 Wilmington Red Light Camera Installation Plans

Red Light Camera Installation Plans - 2023

The City of Wilmington redacted the PE certifications. One cannot tell whether these plans are certified. It is illegal to redact certification seals from engineering plans. Verra Mobility is still the name in the title block of the firm producing the plans. Verra Mobility is not licensed in the North Carolina to practice engineering.

I filed complaint V2023-060 with NCBELS for the unlicensed practice of engineering by a firm and, and for producing uncertified plans. There is no PE certification on the plans because redaction counts as non-existence. The PE's name in the title block, Essam Tawfik Ali Mansour, NC Lic. #050958, lives in Maryland. It appears that Verra Mobility may be repeating its Greenville transgression.


Aug 10, 2023
NCW10 Unsteady yellow light

Unsteady Yellow Light

This official red-light camera video shows the yellow and red signal lights dimming and brightening at the intersection of Market Street and 23rd. This dimming and brightening is most likely a result of Verra Mobility's image processing. It is a process which tampers with the evidence by brightening the signal lights in order to make drivers look reckless. In this case, the image processing algorithm is buggy.

The MUTCD 4D.26(01) requires that the yellow light be steady. It is unlawful for Wilmington (NCGS 160A-300.1) to send citations when the yellow lights are not steady.

By tampering with the evidence or by truly having an unsteady yellow at the intersection, it is unlawful for Wilmington to issue a citation.

Sep 21, 2023
NCW11 Wilmington Raw Red Light Camera Data (from ATS)

Wilmington Raw Red Light Camera Data (from ATS)

Sep 15, 2014

 

Ceccarelli vs. Town of Cary, Wake County Superior Court Case 10-CVS-019930

NC-CA Definitions of Engineering

Definitions of Engineering

Sep 12, 2012
NC-CB Arguments for the Prosecution

Arguments for the Prosecution

Oct 4, 2012
NC-CC Entrapment Regarding Beating the Light

Entrapment Regarding Beating the Light

Oct 18, 2012
NC-CD Motion for a New Trial

Motion for a New Trial

Mar 4, 2013
NC-CE Motion for a New Trial - Affidavit Brian Ceccarelli

Motion for a New Trial - Affidavit Brian Ceccarelli

Mar 4, 2013
NC-CF Order and Judgment

Order and Judgment

Mar 4, 2013
NC-CG Brian Ceccarelli's Court Outline

Brian Ceccarelli's Court Outline

Jan 12, 2013
NC-CH The People in the Classes

The People in the Classes

Jan 12, 2013
NC-CI Plaintiff's Pretrial Brief

Defendant's Motion to Strike Plaintiff's Expert Witnesses

Jan 10, 2013
NC-CJ Plaintiff's Pretrial Brief

Defendant's Motion for Summary Judgment

Jan 10, 2013
NC-CK Motion for Relief

Defendant's Motion for Relief from Order Denying Defendant's Motion for Summary Judgment

Jan 10, 2013
NC-CL Defendant's Affidavits Filed in Support of its Motion for Summary Judgement

Defendant's Affidavits Filed in Support of its Motion for Summary Judgment

Jan 10, 2013
NC-CM Plaintiff's Pretrial Brief

Plaintiff's Pretrial Brief

Dec 17, 2012
NC-CN Brian Ceccarelli's Pretrial Affidavit

Brian Ceccarelli's Pretrial Affidavit

Dec 17, 2012
NC-CO Johnnie Hennings, P.E., Pretrial Affidavit

Johnnie Hennings, P.E., Pretrial Affidavit

Dec 17, 2012
NC-CP Town of Cary's Pretrial Brief

Town of Cary's Pretrial Brief

Dec 17, 2012
NC-CQ Dr. Joseph Hummer's Pretrial Affidavit

Dr. Joseph Hummer's Pretrial Affidavit

Dec 17, 2012
NC-CR Daren Marceau, P.E.'s Pretrial Affidavit

Daren Marceau, P.E.'s Pretrial Affidavit

Dec 17, 2012
NC-CS Johnnie Henning's Critique of Marceau's Affidavit

Johnnie Henning's Critique of Marceau's Affidavit

Jan 11, 2013
NC-CT Gregory Fuller, P.E.'s Pretrial Affidavit

Gregory Fuller, P.E.'s Pretrial Affidavit

Dec 17, 2012
NC-CU Lisa Moon, P.E.'s Pretrial Affidavit

Lisa Moon, P.E.'s Pretrial Affidavit

Dec 17, 2012
NC-CV David Spencer P.E.'s Pretrial Affidavit

David Spencer, P.E.'s Pretrial Affidavit

Dec 17, 2012
NC-CW Gene Murr, P.E.'s Pretrial Affidavit

Gene Murr, P.E.'s Pretrial Affidavit

Dec 17, 2012
NC-CX Alfred Grandy's Pretrial Affidavit

Alfred Grandy's Pretrial Affidavit

Dec 17, 2012
NC-CY Sue Rowland Pretrial Affidavit

Sue Rowland Pretrial Affidavit

Dec 17, 2012
NC-CZ Plaintiff's Expert Witness Designation

Plaintiff's Expert Witness Designation

Oct 1, 2012
NC-CAA Deposition of Brian Ceccarelli

Deposition of Brian Ceccarelli

Plaintiff and Expert Witness. Though unusual, it is legal for the plaintiff to be an expert witness. Ceccarelli has a B.S. in Physics from the University of Arizona. Ceccarelli was also a consultant for the NCDOT.

Sep 4, 2012
NC-CAB Deposition of Lori Millette

Deposition of Lori Millette

Plaintiff

Sep 4, 2012
NC-CAC Deposition of Elizabeth George, Ph.D.

Deposition of Elizabeth George, Ph.D.

Plaintiff's Expert Witness. Dr. George is the head of the physics department at Wittenberg University in Springfield, Ohio. The video of this deposition is the next exhibit.

Sep 13, 2012
NC-CAD Deposition of Elizabeth George, Ph.D.

Video Deposition of Elizabeth George, Ph.D.

Starting at timestamp 7:37:25, the Town of Cary's lawyer, Elizabeth Martineau, objects to the laws of physics and moves to strike them. Plaintiff's Expert Witness. Dr. George is the head of the physics department at Wittenberg University in Springfield, Ohio.

Sep 13, 2012
NC-CAE Deposition of Joseph Shovlin, Ph.D.

Deposition of Joseph Shovlin, Ph.D.

Plaintiff's Expert Witness. Dr. Shovlin is a physicist at Cree in RTP. Dr. Shovlin received his Ph.D. in physics from Ohio University.

Sep 15, 2012
NC-CAF Deposition of Johnnie Hennings, P.E.

Deposition of Johnnie Hennings, P.E.

Plaintiff's Expert Witness. Mr. Hennings is a professional engineer at Accident Reconstruction Analysis, Inc. in Raleigh, NC.

Oct 30, 2012
NC-CAG Cary's Expert Witness Designation

Cary's Expert Witness Designation

Oct 4, 2012
NC-CAH Deposition of Lisa Moon, P.E.

Deposition of Lisa Moon, P.E.

Cary's Expert Witness. Ms. Moon is the Senior Project Manager for Atkins. Atkins is a private engineering firm that designs signalized intersections for the NCDOT. Ms. Moon has designed over 750 signals.

Oct 9, 2012
NC-CAI Deposition of Greg Fuller, P.E.

Deposition of Gregory Fuller, P.E.

Cary's Expert Witness. Mr. Fuller is the head of the Intelligent Traffic Systems and Signals Unit for the NCDOT

Oct 15, 2012
NC-CAJ Deposition of Joseph Hummer, Ph.D.

Deposition of Joseph Hummer, Ph.D.

Cary's Expert Witness. Dr. Hummer is a Professor of Civil Engineering. Dr. Hummer also wrote the pro-camera paper:

Evaluating the Use of Red Light Running Photographic Enforcement Using Collisions and Red Light Running Violations
Oct 17, 2012
NC-CAK Deposition of Daren Marceau, P.E.

Deposition of Daren Marceau, P.E.

Cary's Expert Witness. A former police officer, Mr. Marceau is now a professional engineer specializing in traffic crash reconstruction involving traffic control devices.

Oct 31, 2012
NC-CAM Public Notice of Class Action

Public Notice of Class Action

Aug 29, 2012
NC-CAN Class Action Certified

Class Action Certified

Jun 21, 2012
NC-CAO Plaintiff's Opposition to Cary's Motion to Dismiss

Plaintiff's Opposition to Cary's Motion to Dismiss

Jan 25, 2012
NC-CAP Affidavit of Brian Ceccarelli

Affidavit of Brian Ceccarelli

Dec 12, 2011
NC-CAQ Affidavit of Elizabeth George

Affidavit of Dr. Elizabeth George

Dec 5, 2011
NC-CAR Deposition of David Spencer Jr., P.E.

Deposition of David Spencer Jr., P.E.

Cary's witness. Traffic Engineer, Town of Cary. Deposition taken in Discovery Process

Jun 24, 2011
NC-CAS Deposition of TIm Bailey, P.E.

Deposition of Tim Bailey, P.E.

Cary's witness. Director of Engineering, Town of Cary. Deposition taken in Discovery Process

Jun 24, 2011
NC-CAT Deposition of Laura Cove, P.E.

Deposition of Laura Cove, P.E.

Cary's witness. Associate Director of Engineering, Town of Cary. Deposition taken in Discovery Process

Jun 24, 2011
NC-CAU Deposition of William Billings

Deposition of William Billings

Cary's witness. Traffic Operations Coordinator, Town of Cary. Deposition taken in Discovery Process

Jun 24, 2011
NC-CAV Cary's Motion to Dismiss

Cary's Motion to Dismiss

May 9, 2011
NC-CAW Spencer's Confession Spencer's Confession Spencer's Statement After Caught

Spencer's Confession: Punish the Driver for Cary's Engineering Mistakes

Cary Caught in Act of Lengthening Yellow

Spencer's Statement After Being Caught

Confession: Nov 30, 2009: Right after getting my red-light camera ticket, I notified the Towne of Cary of the math mistake. Cary's traffic engineer confers with the DOT and both admit the mistake. But Spencer and the DOT conceal the mistake and make me "deal with it."

Caught in the Act: March 17, 2010: My friends notify me that a cherry-picker truck just modified the traffic signal. I measure the yellow. It is now 0.5 seconds longer. Now the yellow is the length required by the NCDOT standard. (I would not have received a ticket. I ran the red by 0.3 seconds.) Now that I know that Cary tried to pull a fast one, Spencer needs to confer with his employer, the Towne of Cary, to give me an "appropriate response."

Statement After Being Caught: April 21, 2010: Spencer tells me, "Standards change over time." They did not change this time. A lie. This is what spurred me to sue the Town of Cary.

Nov 30, 2009

Mar 17, 2009

Apr 21, 2010

NC-CAX Cary Shortens Yellows in Full Knowledge That Increases Red Light Violations

Cary Knows That Decreasing Yellow Light Durations Increases Red Light Cameras Violations. Cary and the NCDOT Shorten the Yellows Anyway, p. 13

in February 2006, Dick Moore, Cary's Traffic Systems Manager, raised the issue to the NCDOT that Cary does want to decrease the yellow light durations to 3.0 seconds because that increases the number of red light camera violations and creates a safety hazard. But Cary does it anyway.

As early as January 13, 2006 (p.11), Cary is voicing concerns over lowering yellow light durations.

Nov 27, 2012
NC-CAY Court-Original-Complaint

Original Complaint

Dec 22, 2010
NC-CAZ Court-Original-Complaint

Consent Agreement - No appeal, No costs

Sep 1, 2013
NC-CBA NB Kildaire Farms at Cary Parkway Intro

NB Kildaire Farms at Cary Parkway Intro

The next several exhibits are movies showing the speed of cars entering the left turn bay. The speed limit on these roads is 45 mph. Cary and the NCDOT assert that all cars enter the left turn bay going 22.9 mph or less which Cary and NCDOT use to justify setting the yellow light to 3.0 seconds--the duration for a 22.9 approach speed. Therefore anybody traveling down the left turn bay faster than 22.9 mph will be faced with a type 1 dilemma zone. If the driver is in it when the light turns yellow, Cary will force that driver to run a red light.

The speeds of unimpeded left turn drivers in the Kildaire Farm Rd. videos: 34, 32, 35, 39, 35, 43, 37, 36 mph.

Nov 7, 2012
NC-CBB NB Kildaire Farms at Cary Parkway Part 1

NB Kildaire Farms at Cary Parkway Part 1

3 examples. First at 00:29

Nov 7, 2012
NC-CBC NB Kildaire Farms at Cary Parkway Part 2

NB Kildaire Farms at Cary Parkway Part 2

1 example at beginning

Nov 7, 2012
NC-CBD NB Kildaire Farms at Cary Parkway Part 3

NB Kildaire Farms at Cary Parkway Part 3

1 example at beginning

Nov 7, 2012
NC-CBE NB Kildaire Farms at Cary Parkway Part 4

NB Kildaire Farms at Cary Parkway Part 4

4 good examples starting at 00:51

Nov 7, 2012
NC-CBF NB Kildaire Farms at Cary Parkway Part 5

NB Kildaire Farms at Cary Parkway Part 5

1 great example starting at 04:40. A 36 mph driver pulling in the left turn bay a few feet before the stop bar.

Nov 7, 2012
NC-CBG Left Turn Bay Entry Speeds at Walnut Street at Meeting Pl. Intro

SB Walnut Street at Meeting Place Intro

Nov 7, 2012
NC-CBH Left Lane Speeds at Walnut Street at Meeting Place

SB Walnut Street at Meeting Place

The speeds of unimpeded left turn drivers in the Walnut and Meeting Place videos: 25, 31, 38, 36, 39, 32 mph.

At 4:50 there are good examples of unimpeded motorists.

At 7:45 there is a bicyclist.

Nov 7, 2012
NC-CBI NCHRP Report 731

NCHRP Report 731 - Guidelines for Timing Yellow and All-Red Intervals at Signalized Intersections

On page 41 (Table 21) and page 58, the report tells traffic engineers to plug speed limit - 5 mph into "v" for left-turn yellows in the yellow change interval formula. NCHRP measures "v" at the critical distance. The authors of this paper got this aspect of the formula correct. This aspect in itself nullifies the North Carolina DOT practice of using the stop bar speed (23 mph) for "v".

Three authors of this report are the same as the ones who criticized my paper, Derivation of the Yellow Light Equation. These authors plus the another author, Richard Retting, still misunderstand the use of the formula. The formula does not apply to any situation which requires a driver to decelerate before entering the section such as turning drivers. For turning drivers, the formula always cuts short the yellow duration by up to 80%. It is of no surprise that Richard Retting approves this paper. Retting is the "father of the red light camera in America."

 

Nov 2, 2010
NC-CBJ Intersection at Cary Towne Blvd at Convention Speed Signs on Eastbound Cary Towne Blvd After Maynard Speed Signs on Eastbound Cary Towne Blvd After Convention

Intersection of Cary Towne Blvd at Maynard, Old Speed Signs on Eastbound Cary Towne Blvd - After Maynard Rd, After Convention

Jan 28, 2010
NC-CBK New Speed Signs on Eastbound Cary Towne Blvd After Maynard

New Speed Signs on Eastbound Cary Towne Blvd After Maynard Rd

Oct 5, 2012
NC-CBL Old Cary Towne Blvd Signal Plan New Cary Towne Blvd Signal Plan

1991 Cary Town Blvd Signal Plan, 2009 Cary Towne Blvd Signal Plan

Sep 30, 2009
NC-CBM Cary Town Blvd is 45 mph Since 8/1/1984

NCDOT Says Cary Towne Blvd is 45 mph Since Aug 1, 1984

By affirmation of Lisa Avery, NCDOT Traffic Safety Project Engineer, Highway Traffic Ordinance Package 84-72, effective Aug 1, 1984, makes Cary Town Blvd a 45 mph road.

May 19, 2011
NC-CBN Mike Bajorek Letter

Mike Bajorek Letter

Mike Bajorek is the Assistant Town Manager for Cary. Bajorek is the first Town of Cary employee to admit that Cary Town Blvd is a 45 mph road.

Nov 24, 2009
NC-CBO Lori Millette's Citation

Lori Millette's Citation

Ms. Millette represents all turning drivers who paid the red light camera fine. Millette represents about 80,000 drivers. The Town of Cary assumes all turning drivers approaching the intersection approach at no greater than 22.9 mph from 294 feet back from the stop bar. Using that assumption Cary sets the yellow duration to 3.0 seconds. 3.0 seconds is for a 22.9 mph car. Nobody goes that slow that far back. Cary entraps them all.

May 7, 2010
NC-CBP The Citation That Started It All

Brian Ceccarelli's Citation

Ceccarelli runs the red light by 0.38 seconds. Literally the blink of an eye. The yellow duration at the intersection is at least 0.5 seconds short of North Carolina's legal requirement. The Town of Cary illegally punished over 8559 drivers just at this one intersection. Though the Town of Cary's traffic engineer admits the error and admits that it has been going on since 1991 (read Spencer's Confession above), Cary still denies it in court.

Nov 9, 2009
NC-CBQ The Photo of Ceccarelli's Car

Photo of Ceccarelli's Car

The speed limit in the photo says 45 mph. Cary maintains that the speed limit was 35 mph in order to justify Cary's short yellow light duration.

Nov 9, 2009

 

North Carolina and City Laws

NC-LA Cary Town Charter 2011.  Pages 18, 19

Cary Town Charter 2011. Pages 18, 19

Mar 28, 2011
NC-LB Cary Town Charter 2009.  Pages 22, 23

Cary Town Charter 2009. Pages 22, 23

Apr 4, 2011
NC-LC Cary Town Code Sec 34, 2011.  Pages 39, 40, 41

Cary Town Code Sec 34, 2011. Pages 39, 40, 41

Mar 4, 2011
NC-LD Cary Town Code Sec 34, 2010.  Pages 39, 40, 411

Cary Town Code Sec 34, 2010. Pages 39, 40, 41

Nov 11, 2010
NC-LE Fayetteville H1151

Fayetteville HB-1151

Aug 14, 2014
NC-LF Greenville H1126

Greenville HB-1126, Session Law 2016-64

Jun 12, 2017
NC-LG Greenville Ordinance Title 10

Greenville Ordinance Article X

Jun 12, 2017
NC-LH Knightdale Code, Sec 74, 2012

Knightdale Code, Sec 74, 2012

Aug 16, 2012
NC-LI Raleigh Ordinances, Sec 11, 2011.   Pages 21, 22

Raleigh Ordinances, Sec 11, 2011. Pages 21, 22

Aug 24, 2011
NC-LJ Wilmington Ordinance.  Sec 5-46

Wilmington Ordinance. Sec 5-46

Mar 15, 2022
NC-LK North Carolina Red Light Camera Session Laws

North Carolina Red Light Camera Laws

Aug 20, 2014
NC-LL NCAC Chapter 21

North Carolina Administrative Code - Engineers - Chapter 21

June 2, 2017
NC-LM North Carolina Constitution Article IX

North Carolina Constitution Article IX

Sec. 7: Clear proceeds . . . shall belong to and remain in the several counties, and shall be faithfully appropriated and used exclusively for maintaining free public schools.

Feb 1, 2012
NC-LN North Carolina General Statute 115C-437

North Carolina General Statute 115C-437

90% of gross penal fines must go to the schools.

Feb 1, 2012
NC-LO North Carolina Professional Engineers Statute, 89C

North Carolina Professional Engineers Statute, 89C

Feb 11, 2018
NC-LP North Carolina Professional Engineers Rules of Conduct

North Carolina Professional Engineers Rules of Conduct

Sep 16, 2014
NC-LQ North Carolina Professional Engineers Education Requirement

North Carolina Professional Engineers Education Requirement

The education is either an ABET curriculum or a science curriculum.

Nov 22, 2022
NC-LR ABET Education Curriculum

ABET Engineering Education Curriculum

The curriculum requires calculus-based physics.

Nov 22, 2022
NC-LS North Carolina Administrative Procedure Act

North Carolina Administrative Procedure Act

Feb 11, 2018
NC-LT North Carolina and Federal Entrapment Laws

North Carolina and Federal Entrapment Laws

Oct 19, 2012
NC-LU North Carolina DMV Handbook

North Carolina DMV Handbook

Oct 19, 2012
NC-LV North Carolina Commerical Drivers License Manual, 2009

North Carolina Commercial Drivers License Manual, 2014

The NCDOT declares that the minimum perception/reaction time for the average aware driver facing a hazard is 2.5 seconds (p 2-15) and the minimum air-brake lag time is at least 0.5 seconds (p. 5-9).

Nov 22, 2014
NC-LW North Carolina Commerical Drivers License Manual, 2009

North Carolina School Bus Drivers Handbook

Nov 22, 2014
NC-LX Setoff Debt Collection Act--NCGS 105A

Setoff Debt Collection Act--NCGS 105A

Oct 25, 2013

 

You are not Driver or Received Citation After 90 Days. Do not Pay. Do not Identify Driver.

NC-OA Affidavit of Non-Responsibility for Raleigh

Affidavit of Non-Responsibility for Raleigh

Oct 24, 2012
NC-OB Affidavit of Did-Not-Receive-Notice in 90 days for Wilmington

Affidavit of Did-Not-Receive-Notice in 90 Days from Wilmington

Mar 15, 2022
NC-OC Affidavit of Non-Responsibility for Fayetteville

Affidavit of Non-Responsibility for Fayetteville

Feb 11, 2018
NC-OD Affidavit of Did Not Receive Notice in 90 Days Greenville

Affidavit of Did-Not-Receive Notice in 90 Days from Greenville

Feb 11, 2018