CREATING A MEMORY REFRESHER.....by Jesus Rabinowitz 
Friday, April 20, 2012, 02:19 PM
Posted by Administrator
Sometimes, it is a good idea to take notes...near to the time that the incident you are taking notes about happened....to refresh your recollection if, for instance, you sue and years later find yourself testifying. "Do you remember exactly what happened?", your lawyer will ask. "No.", you will say. "Do you have anything that will refresh your recollection?" "Yes, these notes I took right after it happened." The Court will let you look at your notes. The notes might read:

-2:22PM, Thursday, April 20, 2012. A's Jeep running poorly. Told B @ X repair shop that Advanced Auto's computer showed a bad distributor and reminded B that they had just replaced the distributor. Left car w/B @8:30AM. @1:32, B called and said it was fuel pump. Part cost $450 but w/labor would be under $500. B said couldn't cut part cost 'cause markup only 10-15% but wld "work w/me" on labor. Went to Advanced Auto. Told pump cost approx. $210. Went to mechanic OC, told his part cost was $193. OC & I agreed pump cld explain hard start but not rough idle. Really, OC had tested codes on 4/19 and said showed distributor....(I lied to B about who ran test so he wldn't think I was mechanic shopping. Had called B @ 1:46 and said I'd texted A who said she had no $ and would live w/Jeep as it is....also lie...had told B that we wld pick up car.) When I told B that A's friends had replaced pump, he said probably only pump and no "pump assembly". I confirmed with both Advanced and OC that pump price included everything usually installed w/pump replacement. Returned to office from OC @ 2:19.-

Get dates of phone calls from your phone. Write them down. Judges are impresed when someone knows the time that something happened. Remember exactly what was said? Write it down. Be upfront about white lies you told to spare feelings...or to avoid being unduly confrontational.

And make your notes as soon as you can because your memory will fade quickly

B's memory about his plan to make more money from A's car may fade ... Mine won't.

Note: Here's another example...

At 5:17, B called and left a message on my cellphone voicemail..."I found a cheaper pump.".......5:27PM 4-20

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