A case in which an expert witness testified as to the genuineness of a handwritten separation agreement that the wife offered in evidence gave rise to quite an important ruling on trial practice matters by the Court of Appeals. The wife had a handwriting expert to back up her document when she offered it as controlling in an equitable distribution trial, and the husband’s lawyer wanted to cross-examine that expert and another of wife’s witnesses. Whether this agreement had in fact been signed by the husband was, the Court of Appeals said, the single most relevant fact in dispute, and cross-examination is a fundamental right. Accordingly, the trial court abused its discretion by refusing to allow any cross-examination. Apparently the court did this as a matter of time limitations to allow an exceedingly short E.D. trial. The Court of Appeals seems to say that the husband was not deprived of a constitutional right, but that an error of this type can never be harmless as it was arbitrary limitation of the right to cross examine on a relevant matter. These are fundamental common law and statutory procedural rights basic to the adversary system, and for that reason the husband’s error was saved even though he did not make a proffer of the anticipated testimony, and it is not necessary to make a finding of prejudicial error. This was abuse of trial court discretion as a matter of law. Campbell v. Campbell, ___ Va. App. ___, ___ S.E.2d ___, 21 VLW 1393 (4/10/07).