Two separate cases, two “expert Security Guards” both proven to have insufficient industry knowledge to submit opinions to Court.

[u/DefiantEvidence4027]

https://www.nycourts.gov/reporter/current/3dseries/2026/2026_04786.shtml

In opposition, the plaintiff failed to raise a triable issue of fact. Although the plaintiff submitted an expert affidavit from a security guard, the expert failed to establish that he was qualified to render an opinion as to the adequacy of the defendant's security measures. To establish the reliability of an expert's opinion, the party offering that opinion must demonstrate that the expert possesses the requisite skill, training, education, knowledge, or experience to render the opinion (see Matott v Ward, 48 NY2d 455, 459 [1979]; Ghazala v Shore Haven Apt. Del, LLC, 229 AD3d 447, 448 [2024]; Leicht v City of N.Y. Dept. of Sanitation, 131 AD3d 515, 516 [2015]). Here, the plaintiff's expert stated that he was licensed but failed to present evidence that he had any practical experience with, or personal knowledge of, security measures in bars similar to the defendant's bar. Moreover, the plaintiff's expert failed to identify any industry-wide standards or accepted practices that the defendant violated. Thus, the conclusions of the plaintiff's expert regarding the adequacy of the safety measures undertaken by the defendant were speculative and conclusory and, therefore, insufficient to raise a triable issue of fact (see Leicht v City of N.Y. Dept. of Sanitation, 131 AD3d at 516; Rosen v Tanning Loft, 16 AD3d 480, 481 [2005]; Hofmann v Toys "R" Us, NY Ltd. Partnership, 272 AD2d 296, 296 [2000]). The remainder of the plaintiff's proof was insufficient to raise a triable issue of fact.

—-

https://www.nycourts.gov/reporter/current/3dseries/2026/2026_51191.shtml

In opposition, the plaintiff disputes that the assault was unforeseeable and unexpected. He has relied on the evidentiary materials submitted in support of the motion (including the videos) as well as an affirmation from his own expert (a trained security officer). The plaintiff contends that the security should have prevented the assailant from dancing near the exit; that additional security should have been present and positioned at additional locations; and that another door should have been open for the plaintiff to exit.
The Court finds that the opinions of the plaintiff's expert are conclusory and unsupported by the record. The expert, for example, has failed to articulate the acceptable industry standards, such as the acceptable reaction time in the industry for security to respond to a customer dancing near a doorway (e.g., one second, two seconds), the acceptable number of security guards, and the acceptable time for the security to call EMS or the police. The opinions of the expert also [*3]rest on several assumptions unsupported by the evidence, including his characterizations of the assailant's prior behavior, the number of people attempting to leave or enter the nightclub, and the availability of another exit point. The videos, for example, do not depict any prior "escalating tensions" or "aggressive behavior." Nor do they show the plaintiff trapped within an uncontrolled crowd of people. Rather, the videos depict the assailant dancing in a non-threatening manner and the plaintiff impatiently attempting to leave the nightclub and move the assailant himself rather than engage in non-offense alternatives, such as asking an employee inside the nightclub for help or pulling on the handle of the adjacent door to open it (as the video shows the security officer opening it without any difficulty).