Rule 2:1006.SUMMARIES.

Rule 2:1006 addresses a practical problem the strict best-evidence rule would otherwise create: some records are too voluminous to hand to the fact-finder document by document. The rule lets a party represent the contents of such writings — records that, although admissible, cannot conveniently be examined in court — in the form of a chart, summary, or calculation instead of introducing every underlying page.

That convenience comes with a transparency condition. Reasonably in advance of offering the chart, summary, or calculation, the party must make the originals or duplicates available for examination, copying, or both, to the other parties, at a reasonable time and place. That advance access lets the opposing party check the summary’s accuracy against the underlying records and prepare any challenge before the summary is offered at trial.

The court retains its own oversight tool: it may order that the underlying writings be produced in court, regardless of whether a summary has been offered. That authority lets the court verify a summary’s accuracy directly, or require the underlying records if a dispute arises about what the summary represents.