 In her response, filed in late October, Mallery appended the full report on the crash by the prosecution's expert, Brian Chase, which attributed it to "catastrophic brake failure" caused by neglect of the vehicle.Chase dismissed defense contentions that Mavis's alleged fraud left Hussain with the mistaken impression that the master cylinder had been replaced when it actually had not, since he had found the cylinder to be functional and recently installed.Mallery also explained that the Mavis security camera footage from April 2018 showed the manager who had alleged the fraud told an employee who had informed him that the Excursion's calipers, hoses and master cylinder all needed to be replaced that Hussain only needed a "temporary" repair since he planned to sell the vehicle; footage from the actual inspection in May shows the manager telling Hussain that "[it] brakes now and I'm hoping it stays that way because if it happens again you're gonna need the other three calipers."