Commonwealth v. Janovich

In this case of domestic violence involving the recantation in a final probation revocation hearing of prior testimony given at a preliminary surrender hearing, we determine that it was not error to admit a summary of the *43witness’s prior testimony as introduced by a probation officer in the Commonwealth’s direct case.

1. Procedural background. In 1998, the defendant pleaded guilty to violating a G. L. c. 209A protective order and threatening to commit a crime. At that time, he was sentenced to two years’ probation. During his probationary period, the defendant was charged with a probation…