A scene photograph with markings made or authorized by an eyewitness during his or her deposition to show the location of the impact involved in a motor vehicle accident is generally admissible in Hawaii and, even if the eyewitness does not remember the entire layout of the accident scene, the picture’s exclusion by a trial court is normally grounds for reversal. See, Samsom v. Nahalu, Hawai’i Supreme Court No. SCWC-10-0000102 (December 4, 2015).
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