Conn. R. Evid. 10-5
The contents of voluminous writings, recordings or photographs, otherwise admissible, that cannot be conveniently examined in court, may be admitted in the form of a chart, summary or calculation, provided that the originals or copies are available for examination or copying, or both, by other parties at a reasonable time and place.
Conn. Code. Evid. 10-5
COMMENTARY
Case law permits the use of summaries to prove the contents of voluminous writings that cannot be conveniently examined in court. Brookfield v. Candlewood Shores Estates, Inc., 201 Conn. 1, 12-13, 513 A.2d 1218 (1986); McCann v. Gould, 71 Conn. 629, 631-32, 42 A. 1002 (1899). Section 10-5 extends the rule to voluminous recordings and photographs in conformity with other provisions of Article X.
The summarized originals or copies must be made available to other parties upon request for examination or copying, or both, at a reasonable time and place. See Customers Bank v. Tomonto Industries, LLC, 156 Conn. App. 441, 445 n.3, 112 A.3d 853 (2015); see also McCann v. Gould, supra, 71 Conn. 632; cf. Brookfield v. Candlewood Shores Estates, Inc., supra, 201 Conn. 13.