Questions to Lay Foundation for Introduction of email into evidence
(By Counsel)
I ask that this document be marked for identification.
Q. I show you this document and ask you if you can identify it?
A. Yes [1]
Q. What is it?
A. An email I received from the defendant on _________20__.
I offer it in evidence.
If there is an objection on the ground that a proper foundation has not been laid and the objection is sustained, then ask:
(By Counsel)
Q. How do you know this email was sent to you by the defendant?
Q. Have you ever communicated by email with the defendant?
Q. When did you communicate by email with the defendant?
Q. Did you obtain the defendant's email address?
Q. How did you obtain the defendant's email address?
Q. What is the defendant's email address?
Q. Did you receive an email from him bearing that email address?
Q. Did you send an email to him at that email address?
Q. Did he respond to that email by a reply email containing that email address?
I renew my offer
[1] Answers to the questions are for purposes of the example only.
(By Counsel)
I ask that this document be marked for identification.
Q. I show you this document and ask you if you can identify it?
A. Yes [1]
Q. What is it?
A. An email I received from the defendant on _________20__.
I offer it in evidence.
If there is an objection on the ground that a proper foundation has not been laid and the objection is sustained, then ask:
(By Counsel)
Q. How do you know this email was sent to you by the defendant?
Q. Have you ever communicated by email with the defendant?
Q. When did you communicate by email with the defendant?
Q. Did you obtain the defendant's email address?
Q. How did you obtain the defendant's email address?
Q. What is the defendant's email address?
Q. Did you receive an email from him bearing that email address?
Q. Did you send an email to him at that email address?
Q. Did he respond to that email by a reply email containing that email address?
I renew my offer
[1] Answers to the questions are for purposes of the example only.
The material on our website is from the New York Matrimonial Trial Handbook , by Joel R. Brandes of the New York Bar. It focuses on the procedural and substantive law, as well as the law of evidence, that an attorney must have at his or her fingertips when trying a New York matrimonial action or custody case. It is intended to be an aide for preparing for a trial and as a reference for the procedure in offering and objecting to evidence during a trial. There are numerous questions for the examination and cross-examination of witnesses.
Joel R. Brandes Consulting Services, Inc. publishes The New York Matrimonial Trial Handbook . It is available in Bookstores, and online in the print edition at Amazon, Barnes & Noble, Goodreads and other online book sellers.
The New York Matrimonial Trial Handbook is available in Kindle ebook editions and epub ebook editions for all ebook readers in our website bookstore and in hard cover at our Bookbaby Bookstore.
The New York Matrimonial Trial Handbook is available in Kindle ebook editions and epub ebook editions for all ebook readers in our website bookstore and in hard cover at our Bookbaby Bookstore.
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Joel R. Brandes Consulting Services, Inc.
2881 NE 33rd Court (At Dock) Ft. Lauderdale, Florida 33306. Telephone (954) 564-9883. email to:divorce@ix.netcom.com. Joel R. Brandes Consulting Services, Inc is a Florida corporation which is owned and operated by
Joel R. Brandes of The New York Law Firm of Joel R. Brandes. P.C. |
This website is published by Joel R. Brandes Consulting Services, Inc., and written by Joel R. Brandes of The Law Firm of Joel R. Brandes. P.C. Mr. Brandes has been recognized by the Appellate Division* as a "noted authority and expert on New York family law and divorce.” He is the author of the treatise Law and The Family New York, 2d (9 volumes),Law and the Family New York Forms 2d (5 Volumes), Law and the Family New York Forms 2019 Edition (5 volumes)(Thomson Reuters), and the New York Matrimonial Trial Handbook. Click here to visit New York Divorce and Family Law ™ the definitive site on the web for New York divorce and family law, presented by Joel R. Brandes of the Law Firm of Joel R. Brandes, P.C., 43 West 43rd Street, New York, New York 10036. (212) 859-5079.
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