fair and accurate representation Tag

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Laying the Foundation of Photographic Evidence

Photographs make good evidence as they illustrate what a witness is testifying about or conveying.   I want to show the witness a relevant photograph, but the witness did not take the photograph.   How do I get this photograph into evidence?  No different than any other evidence, the proper foundation needs to be laid to admit a photograph into evidence. Metropolitan Dade County v. Zapata, 601 So.2d 239, 244 (Fla. 3d DCA 1992). “[A]ny witness with knowledge that the photograph is a FAIR and ACCURATE REPRESENTATION may lay the necessary foundation for admission of a photograph.” Scarlett v. Ouellette, 948 So.2d 859, 863 (Fla....

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