consistent with this opinion. Coleman and Schindler, JJ., concur. 1 In applying a totality of the circumstances test to admit a past tape-recorded statement, a Vermont court reasoned: A number of courts have ruled statements inadmissible as past recollection recorded because the statements were not sworn, signed by the witness, or otherwise affirmed by the witness as accurate. Closer examination of those cases reveals, however, that the statements involved were not prepared by the witness, but by another person, usually a law enforcement agent. See, e.g., United States v. Schoenborn, 4 F.3d 1424, 1427 (7th Cir. 1993) (noting that witness “did not adopt... as his own” report prepared by FBI agent of interview with witness); People v. Hoffman, 205 Mich. App. 1, 518 N.W.2d 817, 825 (1994) (<HOLDING>); People v. Kubasiak, [98 Mich. App. 529,] 296
holding that a police officers notes were relevant as prior and possibly inconsistent statements made and recorded by the witness holding that police report of witnesss statement was inadmissible because witness had not adopted report as accurate when matter was fresh in his memory holding that witness statements in police report inadmissible holding that denying admission of police officers typewritten notes of witnesss statement was proper where witness never adopted statements as true and accurate 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