Summary of Baker v. State, 35 Md.App. 593 (1977)
Facts: Defense counsel asked the testifying officer to read the report to refresh his memory but the court didn’t allow it because the report was made by someone else.
Issue: Can a witness look at something, prepared by someone else, to refresh his memory?
Reasoning: In this case, the report was not being admitted as evidence but was merely to be used to refresh the memory of the officer. The Court confusion present memory revived with past recollection recorded. In the latter, much higher standards apply. But in the former, the report is merely being used as a stimulus and the officer is not admitting the truth of what is included in the report.