Adams v. The New York Central Railroad Co.

Adams (plaintiff) sued the New York Central Railroad Co. (defendant) for personal injuries. The Railroad sought to introduce a memorandum prepared by an employee of Adams's insurance company describing an interview with Adams about a prior, unrelated injury. The insurance employee could not recall the interview even after reviewing the memorandum.

Whether a document may be admitted as past recollection recorded where reviewing it fails to refresh the witness's recollection.