A party may read into evidence a memorandum or record when it is admitted, but no such memorandum or record is admissible as an exhibit unless offered by an adverse party. Polite correctly points out that Florida case law, as it stands currently, does not allow a written statement to qualify as a past recollection recorded unless the de-clarant lays the foundation for its admission with testimony at trial that he or she recorded the statement when the described events were fresh in his or her mind, and attests to the accuracy of the statement (either by testifying that he or she made an accurate record of the fact or event or that he or she is confident that the facts would not have been written unless they were true). E.g., Hernandez v. State, 31 So.3d 873 (Fla. 4th DCA 2010) (<HOLDING>); Smith v. State, 880 So.2d 730 (Fla. 2d DCA
holding the same holding past recollection recorded and prior inconsistent statement insufficient standing alone to establish central element of alleged offense holding that where witness was unable or unwilling to attest to the accuracy of the taped conversation the state could not introduce the same as a past recollection recorded holding audiotape recordings were inadmissible as past recollection recorded where witnesses did not testify that the recordings accurately reflected their memories of events when made holding that an fbi agents notes were not a witness statement within the act because there was no evidence that the witness adopted or approved what was recorded