(b) Foundation: ... on cross‑examination
(traditional common law foundation: person, place, time, substance)
RULE 612 WRITING USED TO REFRESH MEMORY.
... uses a writing to refresh ...
(1) While testifying, [a right]
(2) Before testifying, [discretion]
opponent entitled to
PRODUCE at the hearing, to [in camera examination]
INSPECT it, to [sanctions for failure to turn over]
CROSS‑examine the witness thereon, and to
INTRODUCE ... portions