Updated December 13, 2014 09:45 AM PST


Mats Järlström  -  Beaverton Oregon USA  -  503-671-0312  -  mats@jarlstrom.com


My goal is to improve traffic safety in USA.


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Jarlstrom v. Beaverton Federal Lawsuit

Case No. 3:14-cv-00783-AC



October 27, 2014 - The United States District Judge Michael H. Simon Dismissed the Lawsuit based on Prejudice.

Prior to Judge Simon's ruling United States Magistrate Judge John V. Acosta had issued Findings and Recommendations on this case on Aug. 26, 2014. Most legal documents filed in this case are chronologically listed below in the Legal Document section.



My Attorney Michael Haglund's Comments on the Ruling

"The Federal Court dismissal of the Jarlstrom case did not address the merits of the legal challenge to the City of Beaverton's yellow light intervals.  Instead, the case was dismissed on a technicality, specifically that the risk of injury to Mr. Jarlstrom from the too short yellow light intervals in Beaverton was too remote for Mr. Jarlstrom to have standing to pursue his claims as a civil rights case under federal law.  The decision in no way upholds the City of Beaverton's yellow light timing system, but dismisses the case purely on a procedural technicality."


Mats Jarlstrom's Comments


I say that the lawsuit should not have been dismissed for these key reasons:

  1. Shockingly Judge Acosta did not understand our Original Complaint showing Exhibit A. Judge Acosta ignored the pedestrian in Exhibit A and interjected a car instead which he says violates the law and which he then based his ruling on. Fact is, a car as in Judge Acosta's example is not the worst interference point in an intersection with crosswalks as Exhibit A clearly shows.

  2. Judge Acosta did not understand the wording of the Oregon Vehicle Code and how it and the laws of physics relates to a vehicle in motion traveling through a signalized intersection shown with his clear misinterpretation of the word "cautiously".

  3. Judge Simon did not understand that the evidence presented in the appeal was already part of our original complaint when he ignored the facts. In addition, his ruling showed that he covered for all of Judge Acosta's mistakes.

My conclusion: The Judges actions show that a Courtroom is not the place to discuss mathematics and the laws of physics.



The True Facts


Here are the IGNORED FACTS that tells an unbelievable but true story playing out at local, state and national levels.


Why the Lawsuit?

The point with this lawsuit was to explain the current misunderstanding of Oregon Vehicle Code and how the City of Beaverton is incorrectly and illegally setting the time of their traffic light's change intervals which is compromising traffic safety. Today the misunderstanding of Oregon Vehicle Code is wide spread and it involves state and local jurisdictions and agencies, including transportation engineers, board of engineers, city council members, mayors, law enforcement, city and district attorneys, municipal judges and now even federal judges which ALL are putting the public at risk due to their actions and inactions.



History of Oregon's Restrictive Yellow Light Law

I would like to begin presenting the misunderstandings of Oregon Vehicle Code for the Steady Yellow light by looking at its history. (Source: State of Oregon Law Library) 



In 1930 the Oregon Vehicle Code reads as follows (1935 Supplement To The 1930 Oregon Code.pdf):

“Yellow or "Caution," when shown alone following the green or "Go." Traffic facing the signal shall stop before entering the nearest crosswalk at the intersection unless so close to the intersection that a stop can not be made in safety.”


The 1940 Oregon Compiled Laws Annotated points to 1931 Oregon Laws chapter 360 section 12 (OCLA 115-312.pdf). Here the law added “… a vehicle may be driven cautiously through the intersection.”:

“Yellow alone or "Caution", when shown following the green or. "Go" signal. Vehicular traffic facing the signal shall stop before entering the nearest crosswalk at the intersection or at such other point as may be designated by the proper traffic authority, but if such stop cannot be made in safety a vehicle may be driven cautiously through the intersection. Pedestrians then starting to cross a roadway thereby are advised that there is insufficient time to cross the roadway, and no pedestrian facing such signal shall enter the roadway.”


The formula to calculate the timing of the steady yellow traffic light was first developed and presented in 1959 in the paper "The_Problem_Of_The_Amber_Signal_Light_In_Traffic_Flow" by Denos Gazis, Robert Herman and Alexei Maradudin from General Motors Corporation, Research Laboratories in Warren, Michigan.



Current restrictive vehicle codes for the steady yellow traffic lights in Oregon and Michigan:

State of Oregon Vehicle Code ORS 811.260(4):   State Of Michigan Vehicle Code MCL 257.612(b):
"A driver facing a steady circular yellow signal light is thereby warned that the related right-of-way is being terminated and that a red or flashing red light will be shown immediately. A driver facing the light shall stop at a clearly marked stop line, but if none, shall stop before entering the marked crosswalk on the near side of the intersection, or if there is no marked crosswalk, then before entering the intersection. If a driver cannot stop in safety, the driver may drive cautiously through the intersection."   "If the signal exhibits a steady yellow indication, vehicular traffic facing the signal shall stop before entering the nearest crosswalk at the intersection or at a limit line when marked, but if the stop cannot be made in safety, a vehicle may be driven cautiously through the intersection."


Oregon's Restrictive Yellow Light Law and the Link to the Original Formula

Oregon's law for the steady yellow light has been a restrictive yellow light law as far back as 1930. In 1940 the law added an important statement; “… a vehicle may be driven cautiously through the intersection.” This instruction allows the vehicle that had just entered the intersection (due to the vehicle was to close to stop safely) to drive through and clear the intersection during the yellow light. This instruction together with the phrase "shall stop" facing the yellow light is included in the wording for the restrictive yellow light laws. The restrictive yellow light law is when a driver is not allowed to enter the intersection during the full yellow light interval since the interval also includes the time it takes for a vehicle to travel through the intersection as introduced in the 1940 Oregon law. There are currently eight states with the restrictive yellow light laws in USA (see working report APPENDIX A). The remaining states use the permissive yellow light law. The permissive yellow law is when a driver is only "warned" that a red light is imminent and is thus allowed to enter an intersection during the full yellow light interval.

In 1959 the development of the yellow traffic light kinetic formula was authored in the State of Michigan. It is VERY IMPORTANT to understand that the State of Michigan is also a restrictive yellow light law state as is Oregon (therefore noted as seen above) when we study the formula and it use here in Oregon.


Understanding the links between Oregon, Michigan and the formula, the paper with the original kinetic formula becomes the complete instruction for how the restrictive yellow light law and how the current formula should legally be implemented to calculate the timing of the yellow change intervals in the State of Oregon:


Oregon's yellow change interval formula is thus equation (9) on page 118 of the original paper:

The original kinetic formula is presented in the current ITE Handbook with the addition of the intersection's approach grade and gravity. The ITE handbook also explains the differences between the permissive and the restrictive yellow light laws and how the formula differs for the two yellow light laws. The Federal Traffic Signal Manual presents the same information on pages 137-138 which is thus describing with formula 5-2 how Oregon's RESTRICTIVE yellow and all-red change intervals legally are calculated:


Please note also that the term "minimum" calculated time is missing in the current version of the kinetic formula compared to the original formula so the equal sign should rather be a greater than sign.

NOTE: By inserting "A driver facing a steady circular yellow signal light is thereby warned that the related right-of-way is being terminated and that a red or flashing red light will be shown immediately." in the current wording of ORS 811.260(4) does NOT make the yellow light law permissive. To make the law permissive we need to remove the words "A driver facing the light shall stop" and "If a driver cannot stop in safety, the driver may drive cautiously through the intersection." for the law describing the "Steady Yellow" traffic light.



The City of Beaverton, ODOT and the Legal Link to the Original Formula

Currently the ITE formula which is based on the original kinetic formula and is referenced by the City of Beaverton in their incorrectly dated memorandum (should say 2014) and also by ODOT in their policy and by doing so they are acknowledging the legal link between the formula itself and Oregon law. However, they are both incorrectly applying the formula to Oregon law. The reason they incorrectly apply the formula is that ODOT does not include the time it takes for a vehicle to travel THROUGH the intersection in the yellow light. Instead ODOT adds this time to an all-red change interval which is a time that is mandatory to use with the permissive yellow laws. The all-red change interval is a time when no traffic is allowed to enter the intersection since for a permissive yellow law a vehicle can legally be in the intersection during a red light and thus needs time to exit and clear.

The City of Beaverton acknowledge the key wording of Oregon Vehicle Code with their statement: “Only if a driver cannot safely stop, may the driver proceed through an intersection on a yellow light.” However, the City of Beaverton is neither adding the time it takes for a vehicle to travel THROUGH the intersection in the yellow light nor in an all-red clearance time thinking the important clearance time is OPTIONAL - thus putting crossing traffic and especially pedestrians in danger as presented in the lawsuit and Exhibit A. Beaverton's DANGEROUS change interval formula is thus:



Beaverton's change interval is thus MISSING the VERY IMPORTANT CLEARANCE TERM:



The City of Beaverton's confusion also shows the danger ODOT's PERMISSIVE POLICY versus Oregon's RESTRICTIVE LAW creates. 

In comparison, the City of Portland at least safely follows ODOT's permissive policy and is including the very important clearance time in the all-red change interval at Portland's many signalized intersections even though ODOT's timing policy is in violation of Oregon law.


* The all-red clearance time becomes OPTIONAL, if and only if, the clearance time is included in the yellow light as with the restrictive yellow light law. (The two yellow light laws and the formula are described in detail in my working report "An_investigation_of_the_ITE_formula_and_its_use_R14").


The Different Violation Points for the Restrictive and the Permissive Yellow Light Laws

The red light violation points are very different for the two yellow light laws. For Oregon's restrictive yellow light law, the RED light violation point is at the EXIT of the intersection and the YELLOW light violation point is at the ENTRY of the intersection. This is why a driver can get a citation entering an intersection on a YELLOW light in the State of Oregon but for this to be ENFORCEABLE, the yellow change interval has to also INCLUDE the time it takes for a vehicle to drive THROUGH the intersection per the wording of Oregon's restrictive law which is the formula's last clearance term:

Additionally we find this information describing the above facts:

From the Federal Highway Administrations website: Red-light running is defined legally as follows, based on whether the law in effect allows “permissive yellow” or “restrictive yellow”:

  • Under a “permissive yellow” rule (stated in the Manual on Uniform Traffic Control Devices (MUTCD) and Uniform Vehicle Code (UVC):
    • Driver can legally enter intersection during entire yellow interval
    • Violation occurs if driver enters intersection after onset of red
  • Under a “restrictive yellow” rule:
    • Driver can neither enter nor be in intersection on red
    • Violation occurs if driver has not cleared intersection after onset of red

The Institute of Transportation Engineers provide a “A History of the Yellow and All-Red Intervals for Traffic Signals” document on their website and on page 38 we find words directly linked to Oregon’s restrictive yellow law ORS.811.260(4) for the Steady Yellow Light and what the LEGAL REQUIREMENTS are:

"The following describes the legal requirements of vehicles approaching the steady yellow indication:

"Vehicular traffic facing the [yellow] signal shall stop before entering the nearest crosswalk at the intersection, but if such stop cannot be made in safety, a vehicle may be driven cautiously through the intersection."

Vehicles are permitted to enter the intersection on yellow but only if they cannot stop safely. Additionally, this excerpt defines the entry point into the intersection as the nearest crosswalk at the intersection.


There is no mention in this edition of the manual of the use of an all-red interval. Instead, the manual notes that when the length of the yellow interval is correct, the necessary functions of warning and clearing the intersection are performed by the yellow interval."


Enforcement of Oregon's Restrictive Yellow Law and the Red Light Camera Problems

Today every jurisdiction in the State of Oregon is timing their lights per the PERMISSIVE yellow light law due to ODOT's incorrect policy but all jurisdictions enforce the RESTRICTIVE yellow law. This conflicting illegal activity is also confusing for the many jurisdictions in our state which can put the public at risk as seen in the lawsuit.

The presented facts show that EVERY issued RED and YELLOW light citation past and present is thus in violation of Oregon law.


Once the public, law enforcement, politicians, law makers and even Governor Kitzhaber himself will understand what ORS811.260(4) truly means the red light camera manufacturers such as ATS/Xerox and Redflex will also have a tough future ahead. This is due to their current red light camera system design is not really applicable to our restrictive state. They have to either point their cameras to the exit of the intersections since they only trigger on a "RED light" or wait for a very long yellow light at the current intersection's entry point where very few violations will occur which will lead to less revenue.


My Research and Findings

My sworn declaration with exhibits, especially my working report (An_investigation_of_the_ITE_formula_and_its_use_R14) is an attempt to explain in great detail how the yellow light timing formula and the wording of two different yellow light laws relate to a vehicle in motion traveling through a signalized intersection. I wanted to use this report as an educational tool not just for the Federal Judges and the City of Beaverton but also for general education of transportation engineers around USA. However, the Court declined to consider all my research with fully referenced information.


Furthermore, I also developed visual tools graphing the motion of a vehicle presenting how velocity, time and distance all tie together. These graphs visually present the yellow light formula and how the minimum safe stopping distance changes with speed plus how the intersections size and vehicle speed effects the time needed for a vehicle to drive through an intersection. Exhibit 4 is one such graph presenting how these graphs can be used as visual tools showing how ORS 811.260(4) should be correctly implemented in the same intersection as Exhibit A.


The developed velocity versus time graphs can also be used to clearly show how dilemma zones are created by for instance not including the extra time needed for vehicles having any extra reaction delay due to different braking systems or vehicles having a lower maximum deceleration rate such as trucks on wet pavement or busses with unseated passengers. Elderly drivers with slower perception-reaction times also fall into this category. The dilemma zones are distances referenced from an intersection's entry point were the driver will be forced to run a red light since he can neither "stop" nor "go" (the very reason the original kinetic formula was developed in 1959). This in turn leads to that drivers are forced to drive much slower to avoid the engineered dilemma causing bottle necks - this is a poor engineering practice and is counterproductive for both safety and traffic flow.

As an example, here is a velocity versus time graph clearly showing the created dilemma zone by NOT INCLUDING a minimum 0.5 seconds delay in the yellow light needed for trucks and busses having air brakes: TruckBusAirBrakeDilemmaZone_RevA.pdf. The graph shows that the 0.5 seconds air brake delay forces trucks and busses to either violate the traffic light at the posted 30 mph speed (safety issue) or to reduce their speed to 23.2 mph to avoid the dilemma (traffic flow issue) or a combination. Also shown, is the INCREASED danger that the pedestrian is exposed to at ANY SPEED by NOT allowing busses and trucks the extra time needed to stop.


Neither ODOT nor Beaverton account for the air brake delay issue even though ODOT dedicates a full chapter on air brakes in their 2014-2015 "Oregon Commercial Driver Manual".


Judge Acosta and the Word "Cautiously"

To Judge Acosta I also wish to say that just because the word "cautiously" is inserted into the Oregon Vehicle Code it does not mean that a driver traveling at 30 mph in a vehicle can react and decelerate to a stop in 56 feet to avoid the pedestrian stepping into the crosswalk as shown in Exhibit A. Judge Acosta and Judge Simon both fail to understand that Exhibit A clearly presents emergency stopping distances for both dry and wet payments that are MUCH GREATER than 56 feet. A driver would not be able to even react to an unexpected event such as a pedestrian stepping into the crosswalk as presented in our example. Even if the driver unlikely could react in 1 second the emergency stopping distance would result in a deceleration rate of 2.5G or 80.6 ft/s2. This means that to be able to emergency stop in 56 feet the vehicle would have to violate the laws of physics. This is because emergency stopping is based on maximum friction between a vehicle's tires and the roadway which cannot be much higher than the Earth's gravitational pull (1G = 32.2 ft/s2). As a comparison, the Federal, State and Local safe and comfortable maximum deceleration rate is set to be 10 ft/s2 but even this rate is too high for tractor trailers.


However, we can actually stop "safely" at a 2.5G or 80.6 ft/s2 deceleration rate, but it would involve other forces besides gravity through friction. For example, it could involve crashing into an object such as another vehicle and the utilization of the vehicle's safety systems such as the deployment of its air bags. Massachusetts Institute of Technology (MIT) brings up the forces involved besides gravity for a vehicle's maximum deceleration rate when they explain why a Top-Fuel dragster can accelerate at a much higher rate than 1G in this informative web article.


If one study and understand the motion of a vehicle as both the inventor of the yellow light timing formula Dr. Alexei Maradudin did 55 years ago and my research now shows, the meaning of the yellow light vehicle code word "cautiously" becomes obvious and it simply means: Do not accelerate to try to reach the intersection's exit before the light turns RED (the exit is the restrictive yellow light law's RED light violation point). In addition, any acceleration trying to reach the intersection's exit would be unsafe and also violate the speed limit if the vehicle initially traveled at the posted speed limit.


Furthermore Dr. Alexei Maradudin's original paper "The_Problem_Of_The_Amber_Signal_Light_In_Traffic_Flow" is describing the true intent and wording of Oregon's restrictive yellow light law and we can also read that the formula ONLY solves the dilemma for a driver either stopping before entering or entering and driving straight through an intersection without needing to accelerate. This also explains why the ITE formula is not applicable for a vehicle slowing down making for instance a turning maneuver. Dr. Alexei Maradudin brings up the slowing down issue in this very important letter to the California Traffic Devices Committee July 23, 2013. Noted is also the many problems described in the original paper which are still prevalent 55 years later which tells me that this is an important technical area that really needs attention and much more research.



Safety and the Purpose of Red Light Camera Enforcement

I can propose already known scientific and engineering methods (see for example Exhibit 2) which will make the intersections much safer in the City of Beaverton and Oregon without any extra cost associated with maintaining any red light camera systems which by default need unsafe red light violators to pay for its existence;


a perverse and unethical relationship since less safety means more revenue.

The proof of the red light camera manufacturers perverse and unethical relationship is in the City of Beaverton's own report to the State of Oregon: "Photo Red Light Report to the Legislature Process and Outcome Evaluation February 2013". In this report we can see on PAGE 3 that the revenue income for both the City and the Redflex red light camera manufacturer dwindled from 2001 to 2010 so they introduce the "Right Turn on Red Enforcement" in 2011.


The very reason the "Right Turn on Red Enforcement" was introduced was to GENERATE MORE REVENUE, NOT SAFETY, since Redflex also understands the limitation of the ITE formula as Dr. Alexei Maradudin describes in his very important letter to the California Traffic Devices Committee July 23, 2013.


An email between Redflex and the City of Chesapeake, VA discusses "the violation calculator" on page 21-22 which is a "marketing tool" produced by Redflex so a City can predict how much revenue each Redflex red light camera system will generate.


Today 4 out of 5 issued red light camera citations are the "Right Turn on Red Enforcement" and it is a pure physics problem since the ITE formula inherent design does not allow enough time for a right hand turn maneuver.


The bottom line: Traffic lights should NOT be used to generate revenue!   


Beaverton Puts the Safety Burdon on ALL Drivers and Pedestrians

I explain in my sworn declaration that it does not work to blame the too short yellow light timing issues on all drivers traveling through Beaverton's intersections by bringing up Oregon's basic speed rule. It simply does not work per the inherent design of the yellow light formula since anyone facing a yellow light at the critical stopping distance and then slowing down before entering an intersection WILL violate the traffic signal and a slower vehicle will need more time clearing and exiting the intersection which both puts the pedestrian in Exhibit A at an even greater risk (Exhibit_3 shows these effects).


Another attempt by the City of Beaverton is to blame the pedestrian on the timing issues when a vehicle just entered and is in the intersection at the time the pedestrian gets a "walk" signal as shown in Exhibit A. We can read what the City of Beaverton states; "As every parent teaches her children, you must look both ways before crossing the street". Please understand that visually impaired children or adults relying on the audible "walk" signal tone used at Beaverton's signalized intersections will take little comfort in this statement made by a government entity whose highest priority and goal is to provide public safety as seen on their own website.

The sole purpose of a traffic control device, such as a traffic light, is to provide safe passage with high traffic flow through an intersection for many types of vehicles including pedestrians. The burden is obviously on the City of Beaverton to properly implement the timing of its traffic lights to comply with the applicable laws and well-known standards to provide safety for its citizens.

If Beaverton still fails to understand the presented yellow timing problems they should not be allowed to use traffic lights throughout the City and rather install the much safer all-way stop signs and round-a-bouts.



The Government, the Professional Engineer and the Politics

I find it alarming that there is ZERO Government oversight or accountability to enforce the obvious risks the pedestrians are currently exposed to due to the City of Beaverton's actions and inactions - it seems that I'm the only one that can and will correct the problem. I'm the messenger and author of all this collected and developed material and I hope it will make a difference saving lives.


As seen, the City of Beaverton also wish to discredit my engineering talents and my presented work but yet again the City misunderstands Oregon Law in regards to the "Professional Engineer". I do not claim to have a "Professional Engineer, PE" title but I am a capable experienced engineer with a formal electrical engineering degree from Sweden (see my declaration). However, I do not need to be a licensed "PE" since I am not directly responsible for any public safety with my performed engineering work which is one of the many exemptions to the "PE" law. On the other hand the City of Beaverton's engineers are directly responsible for public safety when they apply their "engineering judgments" determining, signing and sealing the documents for the yellow change interval's at the City's many traffic light intersections.

The too short yellow lights is clearly not a political issue as the City and the two federal Judges think, it is simply a legal and technical issue understanding and enforcing existing laws correctly. However, it is up to the City of Beaverton to make this a political issue if they wish to change the wording of the current law but for now that is all we have and it needs to be correctly understood and followed.


Final Thoughts

This is not all my comments and available information and the safety issues are not resolved so it is definitely not over. The investigation is ongoing but I wanted to take this opportunity to thank my family and especially my wonderful wife for putting up with me during this past year or so. I also want to thank Michael Haglund and Shenoa Payne for your great effort and work during this lawsuit. It was a pleasure working with you and since you now understand the yellow light law in Oregon, I hope any future Beaverton or Oregon red or yellow light runners wish to seek your advice and help. A very special thanks goes out to Brian Ceccarelli who is a physicist in North Carolina who has walked this path before me. Brian's advice and input has been extremely helpful and so has Jay Beeber in LA California. Thanks also for the kind words and support from UC Irvine Research Professor in Physics & Astronomy Dr. Alexei A. Maradudin, one of the authors of the original yellow light formula. I especially enjoyed when Dr. Maradudin responded with "Dear Dr. Jarlstrom" after reading my working report. I don't have a phD but it still put a BIG smile on my face! Joseph Rose with the Oregonian should also be recognized since he pointed me to study the Oregon Vehicle Code. Last but not least, I don't want to forget our neighbors, my friends and colleagues plus all others who has helped, called or emailed with support.


Thank you all!

Mats Järlström    


Feel free to contact me with any questions or comments.




I stand behind my work and provided information but I am not responsible for how it is used or misused similar to Dr. Alexei Maradudin's original paper with formula.



Reference Documents

    Ref. 1    Oregon Vehicle Code ORS.811.260(4): http://www.oregon.gov/ODOT/dmv/docs/vcb/vcb811.pdf

    Ref. 2    Source Document for Oregon's Vehicle Code and the ITE Formula: http://jarlstrom.com/PDF/The_Problem_Of_The_Amber_Signal_Light_In_Traffic_Flow.pdf

    Ref. 3    Important letter from Dr. Alexei Maradudin: http://jarlstrom.com/PDF/Yellow_Change_Interval_Dos_And_Donts_Alexei_Maradudin.pdf


    Ref. 4    The City of Beaverton's Self Assessment: http://jarlstrom.com/PDF/Photo%20Red%20Light%20Yellow%20Change%20Interval%20012713.pdf

    Ref. 5    ODOT's incorrect policy: http://www.oregon.gov/ODOT/HWY/TRAFFIC-ROADWAY/docs/pdf/odot_yellow_red_clear_policy_a1.pdf

    Ref. 6    Federal Traffic Signal Manual: http://ops.fhwa.dot.gov/publications/fhwahop08024/fhwa_hop_08_024.pdf (Important pages: 119, 137 & 138, see also below)

                  (Page 119, City of Portland "Safe Stopping Distance": http://jarlstrom.com/PDF/fhwa_hop_08_024_page119.pdf )

                  (Page 137-138, "Permissive & Restrictive Yellow Laws" and "One Safe Stopping Distance": http://jarlstrom.com/PDF/fhwa_hop_08_024_page137_138.pdf)



Lawsuit Documents

May 13, 2014

    Original Complaint: Jarlstrom v. City of Beaverton Complaint.pdf

    (Better Resolution of Exhibit A: Final_Exhibit A_30 MPH VEHICLE Speed - Current Beaverton Yellow Change Interval - EB SW Allen Blvd Beaverton.pdf)


June 6, 2014

    Plf's First Request for Production 6-6-14.pdf


June 16, 2014

    Beaverton's Motion to Dismiss: 20140622073235.pdf


July 3, 2014

    1. Pl's Memo in Opposition to Defendant's Motion to Dismiss.pdf

    2. Dec. of Mats Jarlstrom Pl's Memo in Opposition to Defendant's Motion to Dismiss.pdf

    3. Plaintiff's Motion for Leave to File First Amended Complaint.pdf

    4. Exhibit A to Motion for Leave to File First Amended Complaint.pdf

        (Better Resolution of Amended Exhibit A: Fig 1_30 MPH VEHICLE Speed Current Beaverton Yellow Change Interval EB SW Allen Blvd_R17.pdf)


July 17, 2014

    City's Reply to Plaintiff's Memorandum in Opposition to Defendant's Motion to Dismiss.pdf

    Defendant's Opposition to Plaintiff's Motion for Leave to File Amended Complaint.pdf


Aug 4, 2014

    Reply in Support of Plaintiff's Motion for Leave to File First Amended Complaint.pdf

    Declaration of Michael E. Haglund in Support.pdf


Aug 26, 2014

    Magistrate Judge Acosta, Findings and Recommendation: 20140826203409.pdf


September 10, 2014

    Plaintiff's Appeal of Magistrate Judge Acosta's, Findings and Recommendation:

    Jarlstrom-Plf's Objections to Findings & Recommendations.pdf

    Jarlstrom-Decl Payne.pdf

Declaration of Mats Jarlstrom with Exhibits.pdf

(Better Resolution of above Document):

  1. Declaration_of_Mats_Jarlstrom.pdf

  2. Exhibit_1_FINAL_An_investigation_of_the_ITE_formula_and_its_use_R14.pdf

  3. Exhibit_2_FINAL_Retting_RA_2002.pdf

  4. Exhibit_3_FINAL.pdf

  5. Exhibit_4_FINAL.pdf

    Df's Limited Objection to Magistrate's Findings and Recommendation.pdf


    Jarlstrom-Response to Def's Ltd Obj to Findings & Recomm.pdf


    Def's Response to Plf's Objections to Mag. Findings and Recommendations.pdf


October 27, 2014

    United States District Judge Simon: