Renee Conley v. Metropolitan Tulsa Transit Authority, d/b/a METROLINK, TULSA

IN THE DISTRICT COURT IN AND FOR TULSA COUNTY STATE OF OKLAHOMA RENEE CONLEY, individually, and as grandparent of KD, a minor, Plaintiffs, v. METROPOLITAN TULSA TRANSIT AUTHORITY, d/b/a METROLINK, TULSA, a public trust and political subdivision of the State of Oklahoma, Defendant. Case No.: CJ-2026-01182 Judge: William D. LaFortune Attorney Lien Claimed PETITION COME NOW the Plaintiffs, Renee Conley (hereinafter "Plaintiff Renee"), and KD, a minor (hereinafter "Plaintiff KD") and for their causes of action against the Defendant, Metropolitan Tulsa Transit Authority (hereinafter "Defendant"), state as follows: 1. Plaintiffs are residents of Tulsa, Tulsa County, State of Oklahoma. 2. At all times relevant hereto, Defendant was an independent public trust doing business in Tulsa County, State of Oklahoma, and is subject to the provisions of the Oklahoma Governmental Tort Claims Act, Title 51 O.S. Section 151 et seq. 3. On or about September 29, 2025, Plaintiffs were passengers on Defendant's public transportation bus operated by Defendant's employee. 4. At all times relevant hereto, Defendant's employee was in the course and scope of his employment with Defendant. 5. Defendant's employee was driving south on West Cheyenne Avenue and was approaching the intersection with West 2nd Street (hereinafter, "Intersection"), in Tulsa, Tulsa County, Oklahoma. 6. At 9:13:30 pm (according to the on-board camera of Defendant’s bus), Defendant’s employee stopped at a red light at the Intersection. See, 32.1 of Screenshots of Video Footage of Incident from 9.13.30.30 to 9.13.42 attached hereto as Marked Trial Exhibit 32. 7. At 9:13:34 pm, the light at the Intersection turned green. See, 32.2 of Screenshots of Video Footage of Incident from 9.13.30.30 to 9.13.42 attached hereto as Marked Trial Exhibit 32. 8. At 9:13:35 pm, Defendant’s employee started to proceed through the Intersection. See, 32.3 of Screenshots of Video Footage of Incident from 9.13.30.30 to 9.13.42 attached hereto as Marked Trial Exhibit 32. 9. Also at 9:13:35, an unknown vehicle is approaching the Intersection from the west. See, 32.3 of Screenshots of Video Footage of Incident from 9.13.30.30 to 9.13.42 attached hereto as Marked Trial Exhibit 32. 10. At 9:13:37 pm, Defendant’s employee is beginning to enter the Intersection. See, 32.4 of Screenshots of Video Footage of Incident from 9.13.30.30 to 9.13.42 attached hereto as Marked Trial Exhibit 32. 11. Defendant’s employee does not look left or right before entering the Intersection. See, 32.1-32.4 of Screenshots of Video Footage of Incident from 9.13.30.30 to 9.13.42 attached hereto as Marked Trial Exhibit 32. 12. Also at 9:13:37, an unknown vehicle is beginning to enter the Intersection from the west. See, 32.4 of Screenshots of Video Footage of Incident from 9.13.30.30 to 9.13.42 attached hereto as Marked Trial Exhibit 32. 13. Because Defendant’s employee does not look left or right before entering the Intersection, Defendant’s employee fails to see the unidentified vehicle approaching from the west. 14. At 9:13:38 pm, Defendant’s employee violently slammed on his brakes and honks his horn as the vehicle approaching from the west enters the Intersection. See, 32.5 of Screenshots of Video Footage of Incident from 9.13.30.30 to 9.13.42 attached hereto as Marked Trial Exhibit 32. 15. At 9:13:39 pm, there is more than five (5) feet between Defendant’s bus and the unidentified vehicle approaching from the west as it passes in front of Defendant’s bus in the Intersection. See, 32.6 of Screenshots of Video Footage of Incident from 9.13.30.30 to 9.13.42 attached hereto as Marked Trial Exhibit 32. 16. According to Oklahoma Driver Manual, updated 11/24/25, the following instruction is given for a Green Light: Green Light: Go—You can cross the intersection or turn except where turns are not allowed. Be sure the intersection is clear before you start and watch out for drivers who try to race through the intersection to beat a red light. See, p. 26 of Oklahoma Driver Manual attached hereto as Marked Trial Exhibit 33 (emphasis added). 17. In violation of the Oklahoma Driver Manual, Defendant’s employee failed, refused and neglected to ensure the Intersection was going to be clear before he started to proceed into the Intersection. 18. In violation of the Oklahoma Driver Manual, Defendant’s employee failed, refused and neglected to watch out for the unidentified vehicle approaching from the west who was trying to race through the Intersection to beat a red light. 19. According to Oklahoma Driver Manual, updated 11/24/25, the following instruction is given for a Crossing an Intersection: CROSSING AN INTERSECTION More collisions and injuries occur at intersections than at any other place. Always slow down, look both ways and look left again before you enter an intersection… See, p. 30 of Oklahoma Driver Manual attached hereto as Marked Trial Exhibit 33 (emphasis added). 20. In violation of the Oklahoma Driver Manual, Defendant’s employee failed, refused and neglected to look both ways before entering the Intersection. 21. Defendant’s employee violently slammed on the brakes causing Plaintiff Renee to be thrown from her seat onto the floor. See, 32.5, 32.6 and 32.7 of Screenshots of Video Footage of Incident from 9.13.30.30 to 9.13.42 attached hereto as Marked Trial Exhibit 32. 22. Defendant’s employee violently slammed on the brakes causing Plaintiff KD to be thrown forward from her seat. See, 32.5 and 32.6 of Screenshots of Video Footage of Incident from 9.13.30.30 to 9.13.42 attached hereto as Marked Trial Exhibit 32. 23. Defendant’s employee negligently failed to clear the Intersection before proceeding after the light turned green. 24. Defendant’s employee negligently applied the brakes in an excessive manner causing Plaintiff's to be thrown forward from their seats. 25. Defendant’s employee is at-fault for causing Plaintiffs to be thrown forward from their seats. 26. Defendant’s employee was negligent in the operation of Defendant’s bus in that: a. Defendant’s employee breached his duty to use ordinary care to prevent injury to others; b. Defendant’s employee failed to keep a proper lookout; c. Defendant’s employee started from a stopped position before it was safe to do so; d. Defendant’s employee failed to look left and right before entering an intersection; e. Defendant’s employee failed to ensure it was safe before proceeding into an intersection; f. Defendant’s employee reacted too aggressively by slamming on his brakes unnecessarily; g. Defendant’s employee drove carelessly; h. Defendant’s employee was inattentive; i. Defendant’s employee was driving too fast for conditions; j. Defendant’s employee was negligent per se; and k. Defendant’s employee was grossly negligent.1 27. On or about September 29, 2025, Defendant’s employee operated Defendant’s bus negligently, in reckless disregard for the safety of others, and in violation of state statutes and caused Plaintiffs to be violently thrown forward from their seats. 28. Defendant’s employee was negligent per se in that he violated the following statutes and ordinances: a. 47 O.S. § 11-603: Starting Parked Vehicle: No person shall start a vehicle which is stopped, standing or parked unless and until such movement can be made with reasonable safety. b. 47 O.S. § 11-801: Basic Rule – Maximum (Speed) Limits – Fines and Penalties: Any person driving a vehicle on a highway shall drive the same at a careful and prudent speed not greater than nor less than is reasonable and proper, having due regard to the traffic, surface and width of the highway and any other conditions then existing. No person shall drive any vehicle upon a highway at a speed greater than will permit the driver to bring it to a stop within the assured clear distance ahead. ______________________________ 1 “Slight negligence consists in the want of great are and diligence; ordinary negligence is in the want of ordinary care and diligence; and gross negligence in the want of slight care and diligence.” 25 O.S. § 6 (bold emphasis supplied). c. 47 O.S. § 11-901: Reckless Driving: It shall be deemed reckless driving for any person to drive a motor vehicle in a careless or wanton manner without regard for the safety of persons or property or in violation of the conditions outlined in Section 11-801 of this title. d. 47 O.S. § 11-901b: Full Time and Attention to Driving: The operator of every vehicle, while driving, shall devote their full time and attention to such driving. e. Tulsa Revised Ordinance Title 37 § 618: Conditions affecting speed: Notwithstanding the posted speed limits, any person driving a vehicle shall drive the same at a careful and prudent speed not greater than nor less than is reasonable and proper, having due regard to the traffic, surface and width of the roadway and any other condition then existing; and no person shall drive any vehicle upon a roadway at a speed greater than will permit him to bring it to a stop within the assured clear distance ahead. f. Tulsa Revised Ordinance Title 37 § 613: Starting and stopping: Before starting, stopping or turning, the driver of any vehicle upon a street, ally, highway or public or private roadway shall first assure himself that such movement can be made in safety without endangering other vehicles or pedestrian traffic. g. Tulsa Revised Ordinance Title 37 § 614: Drivers leaving parked position: A driver leaving a parked position shall yield the right-of-way to all other vehicles already in motion or so close as to constitute an immediate hazard. h. Tulsa Revised Ordinance Title 37 § 618: Conditions affecting speed: Notwithstanding the posted speed limits, any person driving a vehicle shall drive the same at a careful and prudent speed not greater than nor less than is reasonable and proper, having due regard to the traffic, surface and width of the roadway and any other condition then existing; and no person shall drive any vehicle upon a roadway at a speed greater than will permit him to bring it to a stop within the assured clear distance ahead. i. Tulsa Revised Ordinance Title 37 § 645: Inattentive driving: A. It shall be unlawful and an offense for any driver to fail to remain alert and give full attention to the safe operation of his vehicle while it is in motion. B. It shall be unlawful and an offense for any driver to engage in any activity while driving that interferes with the safe control of his vehicle. C. It shall be unlawful and an offense for any person to engage in any activity or to do any act which interferes with a driver's safe operation of a vehicle. j. Tulsa Revised Ordinance Title 37 § 647: Reckless driving: It shall be deemed reckless driving for any person to drive a vehicle in a careless or wanton manner without regard for the safety of persons or property or in violation of the conditions outlined in Section 618. 29. Oklahoma law defines the conveyance of persons from one place to another to be a contract for carriage. A contract of carriage is a contract for the conveyance of property, persons or messages from one place to another. See, 13 O.S. § 4 (bold emphasis supplied). 30. Defendant and its employee were engaged in a contract for carriage. 31. Oklahoma law defines a common carrier as: Everyone who offers to the public to carry person, property or messages is a common carrier of whatever he thus offers to carry. See, 13 O.S. § 4 (bold emphasis supplied). 32. Defendant is a common carrier of persons. 33. Oklahoma law requires a duty of "utmost care and diligence" by a common carrier of persons. A carrier of persons for reward must use the utmost care and diligence for their safe carriage, must provide everything necessary for that purpose, and must exercise to that end a reasonable degree of skill. See, 13 O.S. § 32 (bold emphasis supplied). 34. Defendant’s employee failed to provide Plaintiffs the “utmost care and diligence for their safe carriage” in violation of 13 O.S. § 32. 35. Upon information and belief and to be proven in discovery, Defendant’s policies and procedures require a bus driver to ensure the intersection is going to be clear before proceeding on a green light. 36. Upon information and belief and to be proven in discovery, Defendant’s policies and procedures require a bus driver to look out for drivers who are trying to race through an intersection to beat a red light. 37. In violation of Defendant’s policies and procedures, Defendant’s employee failed, refused and neglected to watch out for the unidentified vehicle approaching from the west who was trying to race through the Intersection to beat a red light. 38. In violation of Defendant’s policies and procedures, Defendant’s employee failed, refused and neglected to ensure the Intersection was going to be clear before he started to proceed into the Intersection. 39. Upon information and belief and to be proven in discovery, Defendant’s policies and procedures require a bus driver to look both ways before entering an intersection. 40. In violation of the Defendant’s policies and procedures, Defendant’s employee failed, refused and neglected to look both ways before entering the Intersection. 41. Defendant is responsible for the negligence of Defendant’s employee via the doctrine of respondent superior. 42. Defendant had a duty in hire, train, supervise, train and retain its employees to drive as a common carrier of persons. 43. Upon information and belief and to be proven in discovery, Defendant failed, refused and neglected its duty to hire, train, supervise and retain its employee driver. 44. Upon information and belief and to be proven in discovery, Defendant failed, refused and neglected its duty to hire, train, supervise and retain its employee driver on the higher duty owed by a common carrier of persons. 45. The seatbelts on Defendant’s bus were defective, inoperable, and/or missing. 46. Oklahoma law requires a common carrier of persons to provide safe vehicles. A carrier of persons is bound to provide vehicles safe and fit for the purposes to which they are put, and is not excused for default in this respect by any degree of care. See, 13 O.S. § 33 (bold emphasis supplied). 47. Defendant is negligent per se for violating 13 O.S. § 33 for failing to provide a safe vehicle to prevent Plaintiff's from being violently thrown forward out of their seats. 48. Defendant’s actions and inactions were without slight care and diligence, and therefore, constitute gross negligence pursuant 25 O.S. § 6.2 49. In a letter dated October 1, 2025, and received by Plaintiffs’ attorney on October 27, 2025, Defendant denied Plaintiffs’ tort claims. See, Defendant’s Denial Letter dated October 1, 2025, attached hereto as Marked Trial Exhibit 34. 50. Defendant’s letter dated 10/1/25, states Plaintiffs’ tort claims were made on September 30, 2025. See, Defendant’s Denial Letter dated October 1, 2025, attached hereto as Marked Trial Exhibit 34. 2 “Slight negligence consists in the want of great are and diligence; ordinary negligence is in the want of ordinary care and diligence; and gross negligence in the want of slight care and diligence.” 25 O.S. § 6 (bold emphasis supplied). 51. Pursuant to Defendant’s denial of Plaintiffs’ tort claims, this action is timely filed pursuant to 51 O.S. §§ 157. 52. Plaintiffs have complied with all the statutory requirements of the Oklahoma Governmental Tort Claims Act. 53. The bus driver’s negligence was the sole and proximate cause of the incident. 54. As a result of being thrown forward from their seats, Plaintiffs sustained injuries. 55. Defendant’s employee’s negligence was the sole and proximate cause of the injuries sustained by Plaintiffs. 56. Plaintiff Renee is 59 years of age (DOB: ##/##/1966) and according to life expectancy tables, she has a life expectancy of 28 more years. See, Life Expectancy Tables from IRS Publication 590-B (2023), attached hereto as Marked Trial Exhibit 61. 57. Plaintiff KD, a minor, is 10 years of age (DOB: ##/##/2015) and according to life expectancy tables, she has a life expectancy of 74.9 more years. See, Life Expectancy Tables from IRS Publication 590-B (2023), attached hereto as Marked Trial Exhibit 61. 58. As a result of this incident, Plaintiff Renee suffered personal injury to her body of a permanent and lasting nature, including but not limited to, severe headaches, injuries to her low back, neck, middle back, right arm and right knee, suffered physical pain, past and future; mental anguish, past and future; and has been forced to incur medical expenses, past and future, all in a sum in excess of the amount required for diversity jurisdiction pursuant to section 1332 of title 28 of the United States Code. 59. As a result of this incident, Plaintiff KD suffered personal injury to her body of a permanent and lasting nature, including but not limited to, injury to her head, suffered physical pain, past and future; mental anguish, past and future; and has been forced to incur medical expenses, past and future, all in a sum in excess of the amount required for diversity jurisdiction pursuant to section 1332 of title 28 of the United States Code. 60. Pursuant to 12 O.S. 3226(A)(2), Plaintiff Renee provides initial disclosures as follows: a. Plaintiff has a life expectancy of 28 more years. b. Physical Pain and Suffering Past: To be proven at time of trial Future: To be proven at time of trial c. Mental Anguish Past: To be proven at time of trial Future: To be proven at time of trial d. The Nature and Extent of her Injuries To be proven at time of trial e. Whether the Injuries are Permanent To be proven at time of trial f. The Physical Impairment: To be proven at time of trial g. The Reasonable Expenses of the necessary Care, Treatment, and Services of Plaintiff Renee Past: An amount in excess of $5,000.00 Future: Unknown h. The Reasonable Expenses of the necessary Care, Treatment, and Services of Plaintiff KD Past: An amount in excess of $5,000.00 Future: Unknown 61. Pursuant to 12 O.S. 3226(A)(2), Plaintiff KD provides initial disclosures as follows: a. Plaintiff has a life expectancy of 74.9 more years. b. Physical Pain and Suffering Past: To be proven at time of trial Future: To be proven at time of trial c. Mental Anguish Past: To be proven at time of trial Future: To be proven at time of trial d. The Nature and Extent of her Injuries To be proven at time of trial e. Whether the Injuries are Permanent To be proven at time of trial f. The Physical Impairment: To be proven at time of trial 62. Plaintiffs agree to make available for inspection and copying, at the office of Plaintiffs’ counsel, the documents or other evidentiary material, not privileged or protected from disclosure, on which the above computations are based, including materials bearing on the nature and extent of injuries suffered at a mutually agreed time for Defendants and Plaintiffs. WHEREFORE, Plaintiffs pray that they be granted judgment against Defendant for the total sum of Plaintiffs’ damages caused by or sustained as a result of Defendant’s employee’s negligence in a sum in excess of the amount required for diversity jurisdiction pursuant to section 1332 of title 28 of the United States Code, plus such costs, prejudgment interest, and other relief this court deems equitable and just. Respectfully submitted, Roben L. Rode, OBA #14307 Nathan W. Solomon, OBA #35237 The Rode Law Firm 6136 East 32nd Place Tulsa, OK 74135 918-599-8880 Fax: 918-599-8863 Attorneys for the Plaintiff 32.1 Screenshots of Video Footage of incident from 9:13:30 to 9:13:42 NO positioning available ADDITIONAL CHANNELS Map, Speed Graph GPS DATA Latitude: Longitude: Speed SENSORS VEHICLE ACCELERATION Acceleration (g) 09/28/12 15:09:13:34 PM 32.3 Screenshots of Video Footage of Incident from 9:13:30 to 9:13:42 NO positioning module 32.4 Screenshots of Video Footage of incident from 9:13:30 to 9:13:42 32.5 Screenshots of Video Footage of Incident from 9:13:30 to 9:13:42 No positioning module ADDITIONAL CHANNELS Map> Speed Graph> GPS DATA Latitude: Longitude: Speed: SENSORS VEHICLE ACCELERATION Acceleration (g) 32-6 Screenshots of Video Footage of Incident from 9:13:30 to 9:13:42 32.7 Screenshots of Video Footage of Incident from 9:13.30 to 9:13.42 EXHIBIT 33 SERVICE KLAHOMA OKLAHOMA DRIVER MANUAL CHAPTER 4 TRAFFIC SIGNALS TRAFFIC SIGNALS control the movement of vehicles and pedestrians at intersections. They eliminate the guesswork about who goes next by granting the right-of-way in each direction. You must obey traffic signals, except when an officer is directing traffic. Then you must obey the traffic officer at all times. Adjust your speed as you approach an intersection so that you can slow down or stop if the light changes. Even though you may have the green light, always put safety first and yield the right-of-way if yielding will prevent a collision, even if the other person is wrong. DID YOU KNOW? Color-blind people know the color by the position of the lights: Red on top—Yellow in the middle—Green on the bottom. Green Light: Go—You can cross the intersection or turn except where turns are not allowed. Be sure the intersection is clear before you start and watch out for drivers who try to race through the intersection to beat a red light. Yellow Light: Steady—Warning! The light is about to turn red! You must stop if you can stop safely before entering the crosswalk at the intersection. Adjust your speed as you approach so that you can come to a smooth stop if needed. Don’t speed up to beat the light. Enter the intersection carefully. Collisions often happen here. Red Light: Stop!—Come to a complete stop before entering the crosswalk or intersection. You must remain stopped until the light turns green. After coming to a complete stop, you may turn right on red and you may turn left from a one-way street into a one-way street unless there are signs forbidding the turn. When you turn, you must yield to all pedestrians and vehicles using the intersection, including bicycles. Green Arrows: Turn—When the green arrow is lit, you may turn in the direction of the arrow, even when the red light is still on. If you are in a turning-only lane, you must wait for the arrow. You can only make the turn indicated by the arrow unless there are signs with other information. If there are turning lanes, you must be in the proper lane to make the turn. Enter the intersection cautiously. You must yield to pedestrians in the crosswalk and to other vehicles legally in the intersection. Flashing Yellow Arrow: Left Turn – Reduce speed and cautiously proceed with left turn after yielding to oncoming traffic and pedestrians. Oncoming traffic has the right-of-way. Flashing Red Light: Stop!—Used at dangerous intersections where the crossing traffic may or may not stop. A flashing red light means the same as a stop sign: You may go when it’s safe to cross the intersection. Flashing Red Arrow: Stop! – In general, the red arrow means that all turns in the direction of the arrow are prohibited. You must wait for a green signal before turning. Flashing Yellow Light: Caution!—Slow down, look in both directions and drive slowly and carefully through the intersection. Be prepared to stop. Watch out for drivers who try to beat the light and race through the intersection! CHAPTER 5 CROSSING AN INTERSECTION More collisions and injuries occur at intersections than at any other place. Always slow down, look both ways and look left again before you enter an intersection. Slow down before you enter, then increase your speed until you've cleared the intersection. DO NOT slow down while you're turning or crossing! If your view is blocked so that you can't see traffic on the side street, slow down so that you can stop if a car is coming. If traffic is stopped and is blocking an intersection, stop before reaching the crosswalk and wait for the traffic to move. YIELD RIGHT-OF-WAY TO A SCHOOL OR CHURCH BUS Drive carefully and be ready to slow down and stop when you are near a school bus. If you approach a bus with flashing red lights and/or showing a red "STOP" sign, it means that children are getting on or off the bus and you must stop. You must stop and remain stopped until— ► the bus has started moving, OR ► the driver motions for you to proceed, OR ► the red flashing lights go off and/or the sign is pulled back. You DON'T have to stop for a school bus when— ► the bus is on a different roadway, OR ► the bus is stopped in a loading zone by a controlled-access highway where pedestrians are not allowed to cross. ► Approaching traffic not required to stop for School Bus on a divided highway It is mandatory revocation of driver license for one year for failing to stop for a school bus with red loading/unloading lights flashing. MOVE OVER LAW OR BERNARDO-MILLS LAW (47 O.S. § 11-314) When approaching any stationary vehicles with FLASHING LIGHTS pulled to the side of the road, drivers are REQUIRED to move over a lane, if safe to do so, or slow down and use caution. On a multi-lane road going in your direction: • Move over to a lane that isn't next to the stopped vehicle if it's safe to do so. • If you can't safely change lanes, slow down and drive carefully. On a smaller or two-lane road: • Slow down and drive carefully. It is important to move over or slow down around vehicles displaying flashing lights on the side of the road because it helps prevent secondary crashes. A Secondary Crash is any crash that occurs because of another crash or incident. Many times, secondary crashes happen because a driver becomes distracted by the sight of a crash and take their eyes off the road, causing another crash. MetroLink TULSA Robert Rode 6136 E. 32nd Pl Tulsa, OK 74135 CLAIM NO.: CLAIM00164 Insured: Metropolitan Tulsa Transit Authority CLAIMANT: Renee Conley DATE OF LOSS: 09/29/2025 ADJUSTER ASSIGNED: Kendel Haynes October 1, 2025 Dear Robert, This letter is to advise that MetroLink Tulsa denied the claim for Renee and her daughter Krisalyn. I received a call from Renee on 09/30/25 where she was presenting a claim. I asked the passenger if she was wearing a seatbelt and she stated yes, I advised per the video footage she was sitting on the seatbelt and not wearing the seatbelt at the time of the incident. Renee later called back and stated that she wanted to make a claim on her daughter because she had hit her head, I further advised that per the footage her daughter grabbed a hold of the seat in front of her and did not bump her head, her story changed to whiplash after I provided the details from the accident. Attached is a copy of MetroLink’s policies and procedures that indicate that all passengers assume the risks while MetroLink does not have any control over the actions of other drivers on the road. As a rider on MetroLink vehicles you assume the risks involved in the normal operation of a moving vehicle on public streets, such as sudden stops, evasive movements and turns. This incident was a non-preventable incident due to another vehicle cutting our MetroLink vehicle off causing the driving to suddenly stop. EXHIBIT 34 Sincerely, Kendel Haynes Kendel Haynes Liability Claims Adjuster P: 918-982-6882/ M:918-699-0275 [email protected] Appendix B. Life Expectancy Tables Table I (Single Life Expectancy) (For Use by Beneficiaries) <table> <tr> <th>Age</th> <th>Life Expectancy</th> <th>Age</th> <th>Life Expectancy</th> </tr> <tr><td>0</td><td>84.6</td><td>30</td><td>55.3</td></tr> <tr><td>1</td><td>83.7</td><td>31</td><td>54.4</td></tr> <tr><td>2</td><td>82.8</td><td>32</td><td>53.4</td></tr> <tr><td>3</td><td>81.8</td><td>33</td><td>52.5</td></tr> <tr><td>4</td><td>80.8</td><td>34</td><td>51.5</td></tr> <tr><td>5</td><td>79.8</td><td>35</td><td>50.5</td></tr> <tr><td>6</td><td>78.8</td><td>36</td><td>49.6</td></tr> <tr><td>7</td><td>77.9</td><td>37</td><td>48.6</td></tr> <tr><td>8</td><td>76.9</td><td>38</td><td>47.7</td></tr> <tr><td>9</td><td>75.9</td><td>39</td><td>46.7</td></tr> <tr><td>10</td><td>74.9</td><td>40</td><td>45.7</td></tr> <tr><td>11</td><td>73.9</td><td>41</td><td>44.8</td></tr> <tr><td>12</td><td>72.9</td><td>42</td><td>43.8</td></tr> <tr><td>13</td><td>71.9</td><td>43</td><td>42.9</td></tr> <tr><td>14</td><td>70.9</td><td>44</td><td>41.9</td></tr> <tr><td>15</td><td>69.9</td><td>45</td><td>41.0</td></tr> <tr><td>16</td><td>69.0</td><td>46</td><td>40.0</td></tr> <tr><td>17</td><td>68.0</td><td>47</td><td>39.0</td></tr> <tr><td>18</td><td>67.0</td><td>48</td><td>38.1</td></tr> <tr><td>19</td><td>66.0</td><td>49</td><td>37.1</td></tr> <tr><td>20</td><td>65.0</td><td>50</td><td>36.2</td></tr> <tr><td>21</td><td>64.1</td><td>51</td><td>35.3</td></tr> <tr><td>22</td><td>63.1</td><td>52</td><td>34.3</td></tr> <tr><td>23</td><td>62.1</td><td>53</td><td>33.4</td></tr> <tr><td>24</td><td>61.1</td><td>54</td><td>32.5</td></tr> <tr><td>25</td><td>60.2</td><td>55</td><td>31.6</td></tr> <tr><td>26</td><td>59.2</td><td>56</td><td>30.6</td></tr> <tr><td>27</td><td>58.2</td><td>57</td><td>29.8</td></tr> <tr><td>28</td><td>57.3</td><td>58</td><td>28.9</td></tr> <tr><td>29</td><td>56.3</td><td>59</td><td>28.0</td></tr> </table> EXHIBIT 61 Appendix B. (Continued) Table I (Single Life Expectancy) (For Use by Beneficiaries) <table> <tr> <th>Age</th> <th>Life Expectancy</th> <th>Age</th> <th>Life Expectancy</th> </tr> <tr> <td>60</td> <td>27.1</td> <td>91</td> <td>5.3</td> </tr> <tr> <td>61</td> <td>26.2</td> <td>92</td> <td>4.9</td> </tr> <tr> <td>62</td> <td>25.4</td> <td>93</td> <td>4.6</td> </tr> <tr> <td>63</td> <td>24.5</td> <td>94</td> <td>4.3</td> </tr> <tr> <td>64</td> <td>23.7</td> <td>95</td> <td>4.0</td> </tr> <tr> <td>65</td> <td>22.9</td> <td>96</td> <td>3.7</td> </tr> <tr> <td>66</td> <td>22.0</td> <td>97</td> <td>3.4</td> </tr> <tr> <td>67</td> <td>21.2</td> <td>98</td> <td>3.2</td> </tr> <tr> <td>68</td> <td>20.4</td> <td>99</td> <td>3.0</td> </tr> <tr> <td>69</td> <td>19.6</td> <td>100</td> <td>2.8</td> </tr> <tr> <td>70</td> <td>18.8</td> <td>101</td> <td>2.6</td> </tr> <tr> <td>71</td> <td>18.0</td> <td>102</td> <td>2.5</td> </tr> <tr> <td>72</td> <td>17.2</td> <td>103</td> <td>2.3</td> </tr> <tr> <td>73</td> <td>16.4</td> <td>104</td> <td>2.2</td> </tr> <tr> <td>74</td> <td>15.6</td> <td>105</td> <td>2.1</td> </tr> <tr> <td>75</td> <td>14.8</td> <td>106</td> <td>2.1</td> </tr> <tr> <td>76</td> <td>14.1</td> <td>107</td> <td>2.1</td> </tr> <tr> <td>77</td> <td>13.3</td> <td>108</td> <td>2.0</td> </tr> <tr> <td>78</td> <td>12.6</td> <td>109</td> <td>2.0</td> </tr> <tr> <td>79</td> <td>11.9</td> <td>110</td> <td>2.0</td> </tr> <tr> <td>80</td> <td>11.2</td> <td>111</td> <td>2.0</td> </tr> <tr> <td>81</td> <td>10.5</td> <td>112</td> <td>2.0</td> </tr> <tr> <td>82</td> <td>9.9</td> <td>113</td> <td>1.9</td> </tr> <tr> <td>83</td> <td>9.3</td> <td>114</td> <td>1.9</td> </tr> <tr> <td>84</td> <td>8.7</td> <td>115</td> <td>1.8</td> </tr> <tr> <td>85</td> <td>8.1</td> <td>116</td> <td>1.8</td> </tr> <tr> <td>86</td> <td>7.6</td> <td>117</td> <td>1.6</td> </tr> <tr> <td>87</td> <td>7.1</td> <td>118</td> <td>1.4</td> </tr> <tr> <td>88</td> <td>6.6</td> <td>119</td> <td>1.1</td> </tr> <tr> <td>89</td> <td>6.1</td> <td>120+</td> <td>1.0</td> </tr> <tr> <td>90</td> <td>5.7</td> <td></td> <td></td> </tr> </table>