STATEMENT

On the 30th of june 2017 my son (ADRIAN ALLEN) and I were commuting from Montego Bay to Savanna-
La-Mar as we have done on a daily basis to travel to and from work. At about 5 p.m we were travelling in
a line of traffic, on a section of the road way at the mountpelier bridge (approximately 40 feet from the
end of bridge rail) where it is clearly marked with unbroken white line lies a huge pot hole
approximately three feet in diameter, my son was in the process of negotiating around the pot hole as it
was clear of incoming traffic and safe to do so. While he was negotiating the obstacle a white Toyota
Hiace panel van choose to dis-obey the rules of the road by way of overtaking on the bridge and on the
unbroken white line hitting my son’s car on the right side and forcing him off the road in a nearby ditch.