Q.   Please state your name and address for the record. 
                  A.   Vincent Smith, Nassau County Department of Public 
             Works, Traffic Engineering Unit, 1550 Franklin Avenue, 
             Mineola, New York, 11501. 
                  Q.   Mr. Smith, good morning.  My name is Joan Doe.  I 
             represent the plaintiff, Brian Carmine, in this action. 
                       I'm just going to be asking you a short series of 
             questions this morning.  If there is anything about my 
             questions that you don't understand, just let me know.  I 
             will be happy to rephrase my questions for you.  Okay? 
                  A.   Okay. 
                  Q.   Are you currently employed? 
                  A.   Yes, I am. 
                  Q.   By whom are you employed? 
                  A.   By the County of Nassau. 
                  Q.   What is your position? 
                  A.   I'm a traffic engineer. 
                  Q.   What does that position entail?  What do you do? 
                  A.   Specifically I review and prepare plans for traffic 
             signal installations and review and modify their operation. 
                  Q.   How long have you been employed by the County of 
             Nassau in this position? 
                  A.   I was originally employed by Nassau County nineteen 
             years ago as a traffic technician, and I have become a 
             traffic engineer since then. 
                  Q.   Are you responsible for a specific area of the 
             County of Nassau or the entire County of Nassau? 
                  A.   The entire County. 
                  Q.   Can you just briefly tell me your educational 
             background? 
                  A.   I do not have an engineering degree.  I have had 
             numerous courses in traffic engineering given by the 
             Northwestern University, various traffic safety groups.  I 
             have backgrounds in electronics, through the military and 
             before that high school. 
                  Q.   Is the Village of Island Park in Nassau County? 
                  A.   Yes, it is. 
                  Q.   Do you know the size of Island Park? 
                  A.   No, I do not. 
                  Q.   Are you familiar with the roads and roadways in the 
             Village of Island Park?  Are you familiar with the roads that 
             intersect at Island Parkway, Jackson Place and Scully Place 
             in Island Park? 
                  A.   That specific intersection, no, I'm not. 
                  Q.   Does part of your job involve traffic light pattern 
             phasing sequences? 
                  A.   Yes, it does. 
                  Q.   In what way are you involved with that particular 
             function? 
                  A.   On new installations I would propose a sequence to 
             be installed at an intersection.  I would also at times 
             review the operation of existing signals. 
                  Q.   In addition to proposing sequences for new 
             installations, do you observe or inspect the sequence of 
             existing sequences?  Is that part of your job? 
                  A.   I don't quite understand exactly what you are 
             asking. 
                  Q.   Do you maintain records at your office regarding 
             phasing sequences of lights at intersections in Nassau 
             County? 
                  A.   Yes, we do. 
                  Q.   Is that for every intersection or just on new 
             installations? 
                  A.   Every signalized intersection. 
                  Q.   Did you make a search of your records for the 
             phasing sequence of lights at the intersection of Island 
             Parkway, Scully Place and Jackson Place? 
                  A.   No, I did not. 
                  Q.   At or near the intersection of Island Parkway and 
             Jackson Place and/or Scully Place, are you aware of whether 
             or not there were any traffic signals? 
                  A.   How close do you mean by "near"?
                  Q.   In the proximity of where Jackson Place and Scully 
             Place intersect with Island Parkway. 
                  A.   The nearest signal to that intersection would be at 
             the corner of Long Beach Road  and Island Parkway.
                  Q.   Let me just see, you brought with you a file today.  
             Can I ask you what that file is? 
                  A.   The file contains the result of the searches made 
             by different departments of the county in regard to the 
             intersection of Island Parkway and Scully Place. 
                  Q.   This file is maintained where? 
                  A.   By the Department of Public Works. 
                  Q.   For the record, can you please describe the 
             contents of Plaintiff's Exhibit 1? 
                  A.   We have an interdepartmental memo from the acting 
             Deputy Commissioner of Public Works to the administrative 
             section noting that Island Parkway is a county road and that 
             the following documents were found in the Department of 
             Public Works' records:   The MV-10 4 accident report, 
             pavement marking diagram and pavement marking record. 
                  Q.   The rest of the file contains items you just 
             referred to, sir? 
                  A.   Along with the copy of the notice of claim. 
                  Q.   Inside the file--just note that it's a green 
             hanging file--there are two maps or diagrams that are taped 
             to the inside.  Can you just describe what those are?
                  A.   This is a copy of a map showing the general area of 
             the matter that was copied from a Hagstrom. 
                  Q.   Was this file maintained for the purpose of this 
             litigation or is it maintained in the regular course of 
             business at the County of Nassau for this intersection?  Was 
             it put together because of this accident or is it maintained 
             in general for an intersection at that location? 
                  A.   This file is maintained because of this action. 
                  Q.   Is Island Parkway a county road? 
                  A.   Yes, it is. 
                  Q.   Is it maintained by the County of Nassau? 
                  A.   The roadway is maintained by Nassau County, that's 
             correct. 
                  Q.   Is Jackson Place a county road? 
                  A.   No, it is not. 
                  Q.   Do you know who owns and maintains Jackson Place? 
                  A.   No, I do not. 
                  Q.   Is Scully Place a county road? 
                  A.   No, it is not. 
                  Q.   Do you know who owns or maintains that road? 
                  A.   No, I do not. 
                  Q.   Is Long Beach Road a county road? 
                  A.   Yes, it is. 
                  Q.   Is the County of Nassau responsible for the traffic 
             signals and/or signals on Island Parkway? 
                  A.   Which one are you referring to, traffic signals or 
             traffic signs?
                  Q.   Traffic signals let's start with.
                  A.   Traffic signals, yes. 
                  Q.   How about traffic signs?  Is the County of Nassau 
             responsible for maintaining the traffic signs on Island 
             Parkway? 
                  A.   The Island does limit its signing on county roads.  
             The towns or village, whatever the case may be, also does 
             signing.
                  Q.   Are you aware of an accident that occurred at 
             approximately number 20 Island Parkway at or near the 
             intersection with Scully Place or Island Parkway on July 4, 
             1991? 
                  A.   I'm aware an accident did occur at that time, yes.
                  Q.   How did you become aware? 
                  A.   By looking at a copy of the MV-104 form. 
                  Q.   Can I just ask you when you first saw that? 
                  A.   Earlier today. 
                  Q.   Did you ever have any contact with any other 
             parties involved in the accident?