Are telephone records that are in the nature of a summary?

New Brunswick, Canada


The following excerpt is from Coor Nuclear Services Inc. v Mendes, 2016 NBQB 66 (CanLII):

The plaintiffs also refer R v. Oland [2015] N.B.J. No. 313 where telephone records were admitted that were in the nature of a summary. I think that case is distinguishable, however, because those telephone records, while they may have been summaries, were admitted because they were generated in the normal course of business the same way the original data in that case had been recorded. They were not summaries in the sense that we are dealing with in this case.

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