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Frank H. Bidwell, for plaintiff, re-direct.
William L. Skinner, for plaintiff, direct.

A. I was down to his place twice; he didn't come

to my house; I went down there.

Q. That is the only medical treatment you have had?

A. Yes, sir.

Re-Direct Examination by Mr. Woods:

Q. Did you ever work on a brick building of this kind before?

A. No, sir.

WILLIAM L. SKINNER, a witness called on the part of the plaintiff, being duly sworn, testified as follows:

Examined by Mr. Woods:

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William L. Skinner, for plaintiff, direct.

A.

About 25 years.

Q. Have you worked in Fulton and Oswego and

the vicinity?

A. Yes, sir.

Q.

A.

For nearly your entire business career?
Yes, sir.

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Q. You know the usual and customary method of putting joists on brick buildings?

A. Yes, sir.

Q. Assuming that you have a brick building that is 9 or 10 feet from the ground, constructed of 12 inch tile, 2 inch air space and a 4 inch brick wall on the outside and the partition wall you have 4 inches of brick; you are putting on joists there, green Norway pine, 2 by 12 by 15 across from the outside to the partition wall; as I said, the wall is practically 15 feet across and the wall is somewheres from 9 and three-quarters to 11 feet high; do you know the usual and customary method of doing that work?

A. Yes, sir.

Mr. Cheney: That is objected to as not a matter for expert testimony.

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William L. Skinner, for plaintiff, cross.

The Court: Overruled.

Mr. Cheney: Exception.

A. We ordinarily use a scaffold on the inside of

the building made by high horses with plank reaching from one horse to the other on either side of the building, at either end of the joists.

Q. Is it customery and usual to do that work from the top of the walls?

A. No.

Q. To lay joists, with the persons laying them, standing on the top of the walls, would it be a proper and safe method to do this kind of work, in your opinion?

Mr. Cheney: That I object to as not the proper subject for expert testimony calling for the opinion of the witness on the matter which is for the jury to decide.

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Mr. Woods: I don't know about that myself.
The Court: I don't think that is competent..

Cross-Examination by Mr. Cheney:

Q. You say you are a contractor?

A. Yes, sir.

Q. And been building buildings in Oswego for how many years?

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William L. Skinner, for plaintiff, cross.

A. About 15 years.

Q. Can you tell some buildings that you have built here in Oswego?

A. I built the building at the corner of East Seneca and 9th.

Q. Was that a brick building?

A. No, sir.

Q. Tell some others.

A. I haven't built any brick buildings in Os wego.

Q. You haven't built any brick buildings in Oswego?

A. No, sir; that is, I haven't built them; they weren't built under my charge; I have worked on them.

Q. When have you worked on a brick building?

A.

I helped build the Ames Iron Works; worked

on that nearly two years.

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1770

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Q. You were a carpenter at that time?

A. Yes, sir.

Q. You were a carpenter working on that job?
A. Yes, sir.

Q. What part of the work did you do?

A. I helped on the wood work, putting up posts,

joists and all the rest of the parts.

Q.

Did you lay the joists on that job?

A. I helped.

Q. Were there any scaffolds laid up there on the first floor of that building when they laid the joists?

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William L. Skinner, for plaintiff, cross.

A. We used scaffolds made of horses, plank on the horses.

Q. When you laid the joists on that building?

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A.

The Oswego Machine Works, at the foot of West Schuyler.

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A. That was about, I should think, about 16 or

17 years ago; something about that.

Q. Did you work on any other?

A.

Not in Oswego.

Q.

ing?

Where did you work on any other brick build

A. I worked on the cottages at the Poughkeepsie Asylum; that is the asylum just out of Poughkeepsie.

A. How long ago did you work on them?

A. I think that was about 18 years ago; may be

a little longer; I couldn't say.

Q. You can't tell us of any brick building which has been constructed within 15 years that you either

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