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?