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Common Evidentiary Predicates to Authenticate Evidence 1 ...

Common Evidentiary Predicates to Authenticate Evidence 1. Photographs Rule 901. Identify and confirm that photograph is fair and accurate representation of what is depicted. See Huffman v. State, 746 212, 222 ( 1988). PHOTOGRAPHS GENERALLY Do you recognize this photograph? How are you able to do so? When were these photographs taken? Do these photographs accurately and fairly depict the scene as it appeared the day they were taken? Are there any material alterations or deletions to the photographs? [if photograph taken off Facebook or Instagram with digital touchup or editing, such as filters, have witness go through those] 2. Audio and video tapes a. Videos with No Sound Just like a photograph. The witness has personal knowledge of what is contained on the recording and can testify that the exhibit is a true and accurate copy of what is recorded.

Common Evidentiary Predicates to Authenticate Evidence 1. Photographs – Rule 901. Identify and confirm that photograph is fair and accurate representation of what is depicted. See Huffman v. State, 746 S.W.2d 212, 222 (Tex.Crim.App. 1988). PHOTOGRAPHS GENERALLY • Do you recognize this photograph? • How are you able to do so?

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