Scope of Employment
						To use a document, exhibit or previous testimony in order to help a witness recall an event or prior statement when the witness has responded to a question that he/she could not remember. to attempt to “refresh” the memory of a forgetful or reluctant witness, the witness must have denied remembering and the attorney must have the witness identify the document, exhibit or prior statement (lay a foundation showing it is genuine).

										






























						
					
						
					
						
						
						
						
					
					
					
				
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
									
					
					
	
	

				
				
				
				
				
				
				
				
	
				


