Complaints that are not made at the first reasonable opportunity cannot qualify as 'recent complaints' and must not be left to the jury on that basis. When a VATE tape is replayed to the jury during deliberations, the trial judge must at minimum warn the jury against giving disproportionate weight to the evidence-in-chief heard for a second time. A failure by trial counsel to take exception to erroneous directions does not preclude appellate intervention where the failure is attributable to counsel's inexperience and a miscarriage of justice has occurred.
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