R v XY [2010] NSWCCA 181

Facts: The complainant (C) made statements concerning child sexual assault incidents occurring in 2003 and 2004 to parents (in 2009) and 4 years later to a friend (in 2007). The complaint evidence had been excluded by the trial judge (TJ) on the basis that it related to a series of representations that were not “fresh in the memory” of C. 

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