SHORT MEMO IN SUPPORT OF DEMAND FACTS Mr. Xander was sitting behind one vehicle on the left turn lane of Perring Parkway when the green left-turn signal came one. The vehicle ahead of him proceed to make a left turn. Mr. Xander, still facing a green left-turn arrow entered the intersection. He had nearly completed his left turn when he struck on the passenger side by your insured, Impatient Doe. Your insured alleges he had a green light. ANALYSIS In a factually analogous case the Court of Special Appeals wrote that, “In the absence of a malfunction, common [***14] sense and everyday experience dictates that westbound traffic on Benfield Road would not have a green left-hand turn arrow simultaneous with a full green for the eastbound traffic. Not only would such an occurrence cause a multitude of accidents, but it would make the purpose of the left-hand turn arrow moot; turning under such circumstances would be the same as if the left-turning westbound traffic were doing so under a full green light. If the traffic signal controlling westbound traffic presented appellant with a green left-hand turn arrow, she had every reason to believe that the signals controlling eastbound traffic on Benfield Road and in both directions on Veteran's Highway would be red to allow her to proceed safely with her turn. Miller, 64 Md. App. at 216.” Kelbaugh v. Mills, 108 Md. App. 89, 98, 671 A.2d 41, 46 (1996) Hence, therefore, it is highly unlikely that Mr. Xander had a green left-turn signal and your insured had a green signal as well. That would require a malfunction of the traffic system. Therefore, the only other scenario is that your insured’s traffic light turned green after Mr. Xander had legally entred the intersection and was already completing his left turn. And if that is the case, “A green light does not give an operator of a motor vehicle the right to enter an intersection irrespective of traffic conditions. An automobile may lawfully be in the intersection at the time, and it may "be driven cautiously through the intersection". If this were not so, all traffic in the intersection when the light turns from green to amber would be trapped by oncoming traffic which had just been given the green light, or "Go" signal. An operator of an automobile, when given the green or "Go" signal at an intersection, is required to use due care and caution to see that traffic in the intersection is such that he can proceed with safety. He must regard and heed actual traffic conditions, even though [***10] he has a green or "Go" signal. If a motorist enters an intersection blindly, without anticipating traffic in the intersection, he is guilty of negligence.” Valench v. Belle Isle Cab Co., 196 Md. 118, 123, 75 A.2d 97, 99 (1950) As result, your insured should have paid attention to the traffic conditions and vehicles already in the intersection before entering the intersection. He failed to do so. He struck Mr. Xander’s vehicle causing the accident. Therefore, it is our view that your insured is solely responsible for this accident. He is liable for the harms and losses suffered by Mr. Xander. His loses include medical bills, property damage as well as pain and suffering. The medical records and bills are attached. As compensation for his harms and losses, Mr. Xander demands $150,000.00. Thank you for your assistance with this matter. I look forward to working with you.