Through my analysis of police reports, I determined that in the five years immediately preceding the assault on the decedent, 337 9-1-1 calls were made from the convenience store. Of those, 54 generated police incident reports, 13 of which were for violent crimes. Adapting this search to a half-mile radius, I determined that in the two years preceding the incident, there were 1,185 police reports generated, 330 of which were for violent offenses.

Breaking my search down even further, I determined that during those two years in a four-square-block radius there were 87 police incident reports, of which 57 were violent, while in a one-block radius there were 34 total police incident reports of which 25 were violent.

Based upon this empirical data, and the demographics of the surrounding area, it is my expert opinion that the convenience store was a high-crime location and was located in a high crime area. The convenience store knew or should have known that significant crime had occurred at its store and in the neighborhood surrounding the store, and that more such crimes were reasonably foreseeable.

Nevertheless, based upon my research and expertise in the field of criminal behavior and the conversations I have had with the perpetrator, it is my expert opinion that had the convenience store hired a security guard the assault on the decedent would not have occurred and he would still be alive today.