It is not customary for our Company to analyze and evaluate PRODUCTS to determine their safeness, lack of defect, in litigation matters; however an EXCEPTION to this exists as pertains to products related to the construction of buildings and equipment associated therewith. The analysis and evaluation performed utilizes a nine step RISK-UTILITY SAFETY TEST encompassing the following factors:

1. Accident Causation and Failure Analysis
2. Product Defect Relevance
3. Safety Performance
4. Comparative Safety
5. Behavioral Safety Analysis
6. The Open, Obvious or Warned-Against Hazard
7. Hierarchy of Safeguarding Means
8. Technological Feasibility
9. Economic Feasibility

to determine whether or not the product was a dangerous instrumentality, defective, when it was placed into the stream of commerce.

These forensic construction services are performed under the direct supervision of a Certified Safety Manager, Senior Level, and Board Certified Forensic Engineer with over 60 years of construction experience; Stephen A. Estrin, and/or by a Certified Safety Manager and Board Certified Forensic Examiner with over 30 years of occupational safety and health experience, Karen-Stadtler Estrin.