Archie will focus on the fact that Marella did not have written records of the cheerleader’s performance readiness. Moreover, it is her opinion that a coach cannot supervise and spot more than one stunt group at a time and, on the day of the plaintiff’s injury, four to five groups were practicing at the same time. Archie will also base her opinion on what a reasonable coach should do as opposed to any rules or guidelines that were in place at the time of the plaintiff’s injury. Moreover, she will testify regarding “critical height” that is a certain, unspecified, height at which the risk of catastrophic head injuries become more likely. Archie will opine that the cause of the plaintiff’s injuries was that the group lacked experience, …show more content…
She will testify regarding the plaintiff’s skill and experience as a cheerleader and her skill and experience in the back spot position. She will testify that she worked with the plaintiff as a cheerleader on the high school team her sophomore and junior years as well as working with her on the GCA team and when she worked for GCA. She considered the plaintiff to be a skilled back spot, probably the best on the team. She was a great cheerleader, which is why Marella had made her a captain. Marella will also testify regarding her skill, training, experience as a coach, certifications and related course work. She will also testify regarding her coaching philosophy, use of conditioning an progressions in coaching. She believes that the plaintiff’s stunt group had mastered the stunt before September 6, 2011. Marella will testify regarding the skill and ability of the athletes in the plaintiff’s stunt group at the time of her injury. Particularly, she will testify that the cheerleaders that the plaintiff was working with were all experienced and had performed this particular stunt before. Also, she will testify that practice for the year had commenced in June 2011 and the team practiced approximately 3-4 times per week. She will testify on the day of the plaintiff’s injury she was properly supervising practice and that she was only four to five feet away from the group when the injury