Q.   Deputy, you testified as to having observed 
                    certain skid or tire marks on the pavement, is that 
                            A.   Yes, sir.
                            Q.   Could you tell us what you mean by a skid 
                            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 
                            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 
                                 MR. BROWN:  That's right, your Honor, at this 
                                 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 
                            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, 
                                 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 
                            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.