Mock Trial - Henderson Witness - Direct

Good \[time of day\], Dr. Henderson. Could you please state your full name and spell your last name for the record?

My name is Dr. Bryce Henderson. H-e-n-d-e-r-s-o-n.

How old are you?

I am 71 years old. 

Are you employed?

Yes, I am still working.

What is your current occupation?

I run my own aircraft consulting business, LAM Consulting.

Could you briefly describe what you do at LAM Consulting?

Since 2004, I’ve been a consultant to the aircraft industry focusing in the technical areas of designing and manufacturing planes. I focus on Aircraft Stability and Control, Stress Analysis, and Strength/Fatigue Analysis.

Could you briefly describe your educational background?

I graduated with a Bachelor’s degree in Aeronautical Engineering from Worcester Polytechnic Institute. After that, I obtained a master’s degree and a Ph.D. in Aeronautical Engineering from MIT.

Could you briefly describe your employment background?

I worked at Boeing Aircraft for 25 years, and I held the position of chief engineer for 6 years.

I’m showing you what has been marked as Exhibit X for identification. Could you tell us what it is?

Yes. This is my curriculum vitae.

Who created this document?

I did.

Are the statements in this document true and accurate?

Yes.

Is it a fair and accurate copy of your most recent curriculum vitae?

Yes.

Dr. Henderson, could you briefly describe the field of aeronautical engineering?

Of course. Well, briefly, aeronautical engineering is the study of designing, testing, and building aircraft.

Does the field include reviewing aircrafts for safety?

Yes, of course.

How did you become involved with this case?

I was retained by the plaintiff.

What were you hired to do?

I was hired to determine the cause of the late John Jacob’s crash and to give an opinion regarding whether or not the design of the Model 2 played any role.

Are you being paid?

Yes, $800 per hour.

How did you begin your assignment?

I spoke with Bari/Barry Jacob and Martha/Matthew Dohll because they were eyewitnesses to the accident and I wanted to find out what they saw.

Were they helpful to your investigation?

Yes, very much so. I learned that Mr Jacob was performing the Triple Lindy in a way that did not appear to be out of the ordinary.

What did you do next?

After that, I went and inspected the wreckage firsthand.

Can you briefly tell us what you noticed about the wreckage?

I saw that the right wing had fully detached from the main body of the airplane because the spars, which are the metal beams holding the wing together and attaching it to the aircraft, of the right wing had broken off from the main body of the aircraft.

Why did you inspect the wreckage?

I wanted to see if I could eliminate any possible reasons for the wing detachment.

Were you able to do so?

Yes.

What did you rule out?

I ruled out construction defects, foul play, and metal fatigue.

What is metal fatigue?

Metal fatigue is the weakening of the metal of the wing due to repeated stresses being placed on it.

Why were you able to rule these out?

I was able to rule them out because there was no evidence of any of the factors which would have led to the wing detachment.

Were you able to observe any reasons to explain why the wing detached? 

Yes.

What did you observe?

I observed that the plane’s wing detached due to experiencing an excessive amount of g-force—g-force being the force that the plane experiences during flight due to acceleration or gravity.

What makes you say that?

I’ve seen this before. This happened because the plane experienced greater g-force than what it was designed to withstand.

What are the consequences of a wing detaching from a plane?

If a wing detaches in the air, the plane **will** crash.

Did that conclude your analysis of the accident?

No.

Why not?

Because I was asked to determine why the plane crashed—whether it was pilot error, or a design defect.

How did you continue your investigation? 

I used computer models that are regularly used by aircraft manufacturing companies such as Boeing to assess the safety of their aircraft.

Could you briefly describe what you did with the computer models?

I ran 10,000 randomly generated flight paths of a properly performed Triple Lindy in both the Model 1 and the Model 2 during conditions reported to be similar to those on July 3, 2021 on them to focus on the effect of the g-force.

What were the results?

I found that a properly flown Triple Lindy in the Model 1 is much safer than when performed in the Model 2. In the Model 1, the g-forces always remained safely below the Model 1’s load factor. However, in the Model 2, a properly performed Triple Lindy exceeded the plane’s load factor of 6 g’s nearly 5 times out of a 100.

What does that mean?

This means that the plane isn’t able to structurally withstand stunt pilots performing the Triple Lindy and, in my opinion, it should have been manufactured to withstand a lot more g-force than it can right now. This was not designed for any stunt pilot, especially those who are less experienced than John Jacob.

What do you mean by that?

Well, my tests show that those who are less experienced and perform an improper Triple Lindy are even more likely to exceed the plane’s load factor of 6 g’s and are therefore more at risk.

Were you able to determine, based on the records you reviewed, if Caborite took any action to increase the load factor of the Model 2, in addition to making it lighter?

Yes, I was able to determine that they did not take any action to increase the load factor.

Were there any considerations to increase the load factor?

The Caborite Model 2 was originally considered to have reinforced spars and seams, but the company chose not to do so. 

Would the reinforced spars and seams have made the Model 2 less dangerous?

Yes.

How so?

Well, strengthening and reinforcing the spars would make the wing more strongly attached to the main body of the aircraft because that would allow the wings to withstand a greater g-force.

Do you have an opinion on the cause of the plane crash?

Yes, I have an opinion on that.

And what is your opinion?

This was not pilot error. The Caborite Model 2 was defectively designed and it should have been made to withstand up to 7 g’s. Pilots flying stunts in it will often exceed 6 g’s, and that is what caused John Dymek Jacob’s crash and death in his Caborite Model 2.