The background to this matter is set out in the affidavit of Joseph A.
Zak made July 12, 2013. In his affidavit, Mr. Zak deposes as follows:1. I am counsel for Tammy Franzman, the plaintiff in
this action, and as such have direct knowledge of the information deposed to in
this Affidavit.A. The Claim2. This action was brought for the recovery of
damages for personal injury and loss suffered by the plaintiff as a result of a
head-on motor vehicle collision that occurred on October 16, 2008 on Westsyde
Road south of the hamlet of Black Pines near Kamloops, BC.3. In order to investigate the issue of liability,
establish the nature and extent of the plaintiffs injuries, the resulting
financial consequences and the cost of future care, it was necessary to retain
and consult with a number of experts. Attached as Exhibit 1 is a summary
of the expert reports that were commissioned on behalf of the plaintiff as well
as on behalf of the defence. The reports are voluminous and copies will be made
available for the assessment.B. Accident Circumstances4. At the location of the collision, Westsyde Road is
a paved two lane highway that runs in a north and south direction. The driving
lanes are separated by a single yellow centre line. The highway is flanked to
the east by a precipitous drop to the North Thompson River and to the west by a
long ditch. The posted speed limit is 80 kph.5. The plaintiff was driving her red 1999 Chevrolet
Venture van south to Kamloops for a medical appointment.6. The defendant, Shelley Maureen Munro (Munro),
was driving a white 1993 Ford Taurus (Taurus) north returning to her home
after driving her daughter and grandchildren to their home in Kamloops. The
Taurus was registered to Munros common-law husband, the defendant, Dag Alfred
Goddyn (Goddyn).7. The plaintiff had rounded a bend in the road when
she saw Munro driving toward her...
