What is the test for obtaining a statement made by a witness in a civil case?
The following excerpt is from U.S. v. Michaels, 796 F.2d 1112 (9th Cir. 1986):
that the government produce upon demand any available statement made by the witness which relates to the subject matter of such witness's testimony at trial. The Act narrowly defines "statements" as: (1) writings made by the witness and "signed or otherwise approved or adopted" by him, or (2) accounts which are "a substantially verbatim recital" of the witness's oral statements "recorded contemporaneously with the making of
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United States v. Griffin, 659 F.2d 932, 936 (9th Cir.1981).
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