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hi everyone Dave sugden of evidence at trial today weamp;#39;re going to talk about the challenge of witnesses with empty memories what do you do if itamp;#39;s either our witness an adverse witness and they canamp;#39;t recall certain facts we need to get admitted into evidence a lot of times this happens either in deposition or it happens at trial and weamp;#39;ll have some document that will do one of two things it may refresh the witnessamp;#39;s memory or regardless of whether itamp;#39;s refreshed it actually says the information we want admitted into evidence and so is it a past recollection recorded how do we do and this is an area we see lawyers often get confused so letamp;#39;s clear that up now letamp;#39;s suppose we have a witness and weamp;#39;re trying to establish what he or she was doing on May 8 2022 and we asked the witness and the answer is I have no idea I donamp;#39;t recall we then show the witness this screenshot and all of a sudden it floods a number