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....