I, Alexandru Iarca, in this my Proof of Evidence, will say as follows;
1) I have read and understood the content and assertions made by the prosecution in the report prepared by an officer from Thames Valley police. I do not agree with the assumptions made within that report. In the private CCTV footage exhibited by the police, my car is not specifically identified, i.e. registration number, other that it being referred to as a black car. 2) An expert collision report was prepared on my instruction by Simon Hall Associates, I have read this report and accept the calculations and conclusions within that report. 3) When the road straightened a bit more I was aware of more pedestrians in the immediate vicinity. 4) When I first saw these particular pedestrians they were on my right and walking in my direction. 5) As I got closer they started to run, both of them, one behind the other. First along the pavement, then into the road. They hesitated as if they were going to stop in the middle, and then ran again. One of them tried to pull the one in front back. 6) I had already slowed, but at the last minute when I was very close, they suddenly changed direction and ran from the middle again, I knew if I slammed on my brakes I would go straight into them and then right over them. So in a split second I took an avoiding maneuver by applying steady brake pressure and steering to my left. This was partly successful but they ran into the side of my car. 7) Both the police report and the report of Simon Hall Associates agree with my speed at the school gates, and I accept those findings. 8) At the point of collision, I was travelling between 30mph and 40mpg at most. 9) At no point was I racing or driving competitively with Cosmin Ion. 10) I have read my Defence Statement and authorize it to be served on the court. 11) I have read the report of Simon Hall Associates and authorise it to be served with my Defence Statement.
Richard N. Sunderland, Administrator of The Estate of Sherman E. Sunderland, Deceased v. Pittsburgh & Lake Erie Railroad Company, 319 F.2d 809, 3rd Cir. (1963)