How Long is Too Long for Past Recollection Recorded?

Can someone in 2013 describe in writing what happened in a 2007 murder and then that writing from 2013 can be used to convict someone in 2018 if the witness is unavailable for trial? What should the judge evaluate in deciding whether such a six-year old memory is reliable as a past recollection recorded so it can be read to the jury in 2018? This interesting issue came up in a recent Fourth Appellate Court ruling. To read about this analysis, please click on the following link – https://www.greghillassociates.com/how-long-is-too-long-for-past-recollection-recorded_1.html