BY MR. BROWN: Q. Deputy, you testified as to having observed certain skid or tire marks on the pavement, is that correct? A. Yes, sir. Q. Could you tell us what you mean by a skid mark? A. A skid mark is a residue left from the tire of the car upon the pavement of the highway. This is usually caused by either braking or skidding. Q. Is there a difference between a brush mark or a skid mark? A. Yes. Q. What is the difference, sir? A. I can't explain it, but I know there is a difference. Q. Based on your experience of having investigated accidents, is there anything that you can determine or draw a conclusion from with respect to one having seen a skid mark versus a brush mark? A. I don't understand the question. Would you rephrase or repeat it please? Q. With respect to your investigating accidents in the past, and having seen skid marks on the pavement, and knowing what the result of an automobile being in that position might have been, and similarly having investigated vehicle occurrences where you have observed brush marks on the pavement, would you know whether or not with respect to a skid mark a car is traveling straight ahead or with respect to a brush mark whether a car might be traveling sideways? A. I don't feel that I would be qualified to answer that. The skid marks we find usually go straight or off to an angle. Q. If a car is skidding or sliding sideways, is it likely that you would find four such skid or brush marks from each such tire? MS. LEE: I object to that question, your Honor, on the ground that the witness has stated he is not qualified to make that characterization. THE COURT: Sustained. MR. BROWN: This is not with respect to any conclusion. I am asking him with respect to any markings he would be likely to observe on the pavement. THE COURT: You are asking him for an expert opinion and it is quite obvious that you have not yet qualified him as such. BY MR. BROWN: Q. When the Judge was asking you questions with respect to the length of the skid marks, you stated that you were assisted by another deputy, is that correct? A. Yes, sir. Q. And that you had instructed the deputy to take measurements from a point at the rear of the Williams vehicle in its position of rest, extending in an easterly direction and then southerly to the point where those skid marks disappeared? A. I requested that he take them from the visible point to the last visible point, which would be either at the wheel of the vehicle or in close proximity to it. Q. The measurements which you gave, then, cover the apparent path of the Williams' vehicle in a northerly direction, as well as its path as it traversed those two southbound lanes going westerly? A. Yes, sir. THE COURT: May I interrupt you gentlemen at this point to determine for our scheduling process how much longer you expect to be with this witness. MR. BROWN: I do not expect, your Honor, that the balance of my examination would be very lengthy. I did inform, you, however, as you may remember, that Dr. Green is suffering from the flu and will not be available to testify until next Wednesday. THE COURT: Will you be resting, then, with the exception of the doctor? MR. BROWN: That is correct. THE COURT: In other words, you will have no further testimony to offer relative to the issue of liability? MR. BROWN: That's right, your Honor, at this time. THE COURT: You, I assume, will have testimony of a medical nature to offer, as you indicated to me in chambers, Mr. Lee? MS. LEE: Yes, your Honor. THE COURT: Very well, thank you, gentlemen. Please continue with your examination of the witness, Mr. Brown. BY MR. BROWN: Q. Did you talk to Mrs. Freedman on the day of the accident? A. No, I spoke to her the day after on the phone for the first time, as I remember. Q. Could you tell me how you got her name in order to talk to her on the telephone? A. Deputy Kelly on page 5 of his report supplied the accident diagram and the witness' names. Q. Did he indicate how he discovered the witness' name? A. No, sir, he did not. Q. Now, you told us that you did not take a statement from Mrs. Williams at the scene of the accident, is that correct? A. I don't believe I took any statement from anybody at the scene, sir. Q. Prior to her leaving the scene of the accident, did you observe any injuries that she might have sustained? A. From the report she had facial lacerations that I most likely saw, but I don't remember too vividly at this point. Q. Do you remember whether you spoke to her at the hospital room or in the emergency room that night? A. I believe it was the emergency room. Q. Now, you stated that the Williams vehicle left 110 feet of skid marks up to the point where it crossed the double line, is that right? MS. LEE: I object to that. THE COURT: He may answer that question. What did you state, Deputy? THE WITNESS: I don't know my exact words, sir. THE COURT: He may ask the officer. MS. LEE: As I was given to understand, your Honor, Deputy Kelly was the party who was responsible for the measurements. Perhaps I am wrong. If so, please forgive me. THE COURT: We will permit him to ask. It would be well to ascertain that. This witness is certainly competent to answer. A. Well, the diagram shows 110 feet. I would assume it is from where they first became visible to the front or rear tire of vehicle number 1, the Williams vehicle. Q. Vehicle number 2 left 36 feet of skid marks, is that correct? A. Yes. Q. And that was the Sullivan vehicle? A. Right. Q. Showing you Exhibit 10 for identification, and directing your attention to the line on the highway leading up to the right rear wheel of the Williams car, would that be part of the skid marks that you observed? A. Yes, sir, to the best of my recollection.