James Bray (defendant) and Robert Owczarzak (defendant) were post-office window clerks who embezzled money from the post office by stealing cash used to pay for stamps. Window clerks were required to record their cash and stamp inventory daily on a form, and a post-office supervisor conducted a regular audit of each window clerk to reconcile the cash and stamp inventory with the data recorded on the daily forms. To prevent the audit from uncovering their theft, Bray and Owczarzak would trade stamp inventory so that each of them would have stamp inventory that corresponded with the forms. During Bray’s trial, the prosecution presented exhibits of charts containing summaries of the data on the forms from the two years when Bray and Owczarzak were embezzling, as well as charts of summaries of the form data from after Bray and Owczarzak had been caught and new employees were working as the window clerks for comparison. The forms themselves were not admitted into evidence. Bray objected to the admission of the exhibits into evidence, arguing that the forms themselves should have been admitted into evidence and that the jury should have been instructed that the charts themselves were not evidence. Following his conviction, Bray appealed on that basis.