500
Steps to Enter Something into evidence under business record exception
1. Ask for the document to be marked as Plaintiff 1, 2, 3, etc. or as Defense A, B, C, etc. for identification.
“I ask this be marked as Plaintiff Exhibit 1 for identification.”
2. Show the document to opposing counsel.
“Let the record reflect I am now showing opposing counsel what has been marked as Plaintiff’s Exhibit 1 for identification.”
3. Hand the document to the witness.
“Now showing you what has been marked as Plaintiff Exhibit 1 for identification.”
4. Establish the necessary foundational questions.
Regular:
“Do you recognize this document?”
“What is it?”
“Is this a fair and accurate representation/depiction of the document/object?”