An officer alleges a citizen violates a statute through means of an electronic device. The manner in which the officer operated the electronic device was improper per the electronic device's operator's manual (provided by the police department). The operator's manual contains passages, if considered by the judge, could raise reasonable doubt at trial Technically, an operator's manual is an out of court statement which takes us down hearsay avenue in pursuit of an exception.
Pennsylvania has not adopted federal rule 803(18): http://www.pacode.com/secure/data/225/chapter8/s803-18.html Pennsylvania permits direct/cross examination from a Learned Treatise, but only when the document is deemed authoritative by an expert or through judicial notice. The officer historically is not considered an expert in these particular cases. Barring stipulation, expert testimony, author subpoena, what remaining avenues, if any, are available to introduce these passages into evidence (get them before the judge)
The best way may be not trying to get the document admitted at all. You use the document to impeach the officer on cross examination. Sounds like you are talking about a speeding ticket and either the Vascar Plus Manual or the manual for the Radar gun. I would put questions to the officer such that I knew his answers demonstrate he did not follow the manual, and merely read the part of the manual back to him during follow up questions in a way that he has to agree with what you are telling him, and thereby admitting he didn't follow the procedure. For example, if it was Vascar, you might ask him "Your citation indicates that the lines you used as reference points for clocking my speed were 254 feet apart, correct.?" Answer, YES. Lets say the manual says the lines needed to be 250 feet exactly, or some other thing. You would follow that up by standing in front of him with him watching you read out of the manual and asking "Isn't it true that the Vascar manual says that the lines must be 250 feet apart in order for the machine to produce an accurate result?" If he agrees that the manual says that, he just acknowledged to the court that you have the manual and he didn't follow it. If he says "I don't know what it says off the top of my head?" you proceed to show him what you read. When he is forced to agree with that, he has just authenticated that what you showed him is the authoritative manual. So it is very easy to get your point across to the jury without having to worry about admitting the document. You can do it all through proper cross examination. Because you can impeach a witness with any document, regardless of admission, you can make all the points you need by merely giving the witness the impression you have the correct manual. In a famous case, Abraham Lincoln impeached a witness in a similar fashion by making the witness think he had a weather report from a newspaper, such that the witness changed his story about what the weather was like, when all Lincoln actually had in his hand was a blank piece of paper!
You will need a witness who can authenticate that the manual is the correct one for the device that was used. One way to do that is actually take the deposition of the officer and ask them if it is the correct document, or do so through written discovery. That will establish that the manual applies to the device, and it should be admissible. However, expect heavy resistance to this tactic. Another approach is an expert witness that has knowledge of the device and the operating manual.
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There are two ways of doing this
One is to,put the officer on the stand, ask if before he used the devise he received the Manuel and show it to him and ask him to identify it as the Manuel,he received. The risk is that he says he did not otr that the docu,met you hand him is not one he can identify as the Manuel he received
The other way is to subpoena the Manuel,from the police department a have it either identified on the witness stand or stipulated as the Manuel for the device
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