A dad-of-two was pulling on the steering wheel ahead of the car crash in which he lost his life, a court has heard.
Thomas Benson, Alicia Fairclough and their two children were in an Audi A8 driven by Fairclough three years ago.
Today, Wednesday, Manchester Crown Court has heard how the dad-of-two was pulling on the steering wheel from the passenger's seat.
Their daughter, who is 12 this weekend, said the two were arguing but she was not sure why the two were arguing in an interview this year.
Their daughter, who is not to be named, said: "My dad said 'let me out, let me out, let me out' and my mum said 'no, it is freezing, I do not want you to freeze'. My dad pulled the steering wheel to the side and it swerved us into a tree."
Fairclough said she had no recollection besides "the arm" and "the headlights" in a repeat of what she said in an interview after the incident.
She had a number of broken bones and a bleed on the brain resulting in a loss of memory both before the car crash and after the car crash.
Fairclough said: "I don't remember much of the last three years of my life. My memory is so scatty I don't remember what I did last week."
She did accept that her driving was below that of a careful driver but did not accept that her driving was far below that of a careful driver.
She was below the alcohol limit in the early hours after the collision but according to a calculation there is a chance she was over the alcohol limit on the evening of the collision, the court heard.
Fairclough said: "I can't comment on how much I had to drink so I can't comment on how much it affected me."
Previously, on Monday, Manchester Crown Court heard how Mr Benson and Fairclough had a day of drinking at a wedding at Rivington Barn.
A jury of six men and six women heard how Mr Benson decided not to drive but Fairclough decided to drive although one eyewitness said they were "equally as drunk as each other".
Prosecutor Joe Boyd said ahead of the car crash she drove at more than double the limit of 30 miles per hour on Lever Park Avenue.
Mr Boyd said: "Does the driving fall far below that of a careful, competent driver? That is the issue."
Mr Boyd said: "The car was going far too fast for the bend and this was the cause of the collision."
Fairclough, of Horwich, denies one charge of causing death by dangerous driving and one charge of causing death by uninsured driving.
The trial before Judge Patrick Field KC is ongoing.
This article was written by Jack Tooth. To contact him, email jack.tooth@newsquest.co.uk or follow @JTRTooth on Twitter.
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