Waldrup v. Baker

I do not believe the two documents were admissible as evidence themselves, in the circumstances here.

The first document was the “Confidential Patient Case History” sheet which plaintiff had filled out when she first went to chiropractor Dr. Barnett in March 1982, some five months after the collision. Dr. Barnett used it to refresh his recollection while testifying on direct examination about her coming to him. He was asked, “Tell us what history she gave you?” and he related quite precisely what was on the sheet. Then on cross-examination he testified further and accurately as to what…