the eyewitness passages found in the gospel narratives, the criteria for cross-examining that eyewitness testimony, and the claimed status of the gospels as competent evidence, have been relied on and restated by several American Christian apologists of the nineteenth and twentieth centuries, such as Clarence Bartlett (As A Lawyer Sees Jesus), Walter M. Chandler (The Trial of Jesus), Pamela Binnings Ewen (Faith on Trial), Francis J. Lamb (Miracle and Science), Irwin H. Linton (A Lawyer Examines the Bible), Josh McDowell (More Than A Carpenter, The Resurrection Factor), Howard Hyde Russell (A Lawyer's Examination of the Bible), Joseph Evans Sagebeer (The Bible in Court), and Stephen D. Williams (The Bible in Court or Truth vs Error). Critical assessment There are two examples of writers in recent years who have made critical assessments of Greenleaf's work, and of legal apologists who model their arguments on his book. Howard Richard Packham is a retired foreign language instructor and former part-time estate planning attorney who holds to an atheist worldview. He has written an internet article criticising the technical arguments set forth by Greenleaf and others. Packham holds that what Greenleaf submits as eyewitness testimony is technically hearsay and therefore does not comprise direct evidence to demonstrate the resurrection of Jesus. He also holds that the criteria for the "ancient documents rule" is not met by the gospel documents and that the force of Greenleaf's argument is thereby undermined. Packham argues that the ancient documents rule technically only applies to a limited genre of legal documents, such as wills and contracts and other specific legal instruments, to which the gospels do not belong. However, there are problems in Packham's argument. The Ancient Documents Rule is not limited to express legal instruments, but covers any type of documents. The criteria for the Ancient Documents Rule is simple and straightforward. According to legal authorities, documents of any type must meet three criteria in order to qualify for the Ancient Documents Rule: 1) that the document is at least 20 years old, 2) presumed to be genuine, 3) come from proper custody (cf. Black's Law Dictionary, FRE 901(b)(8)). Greenleaf, as a writer of highest legal authority, concluded that the Gospels should be received under the ancient documents rule. In §9 of his Testimony of the Evangelists, Greenleaf cites the legal reception by the British Record Commission of the Domesday Book and Ancient Statues of Wales, as well