Laying Foundation and Authenticating Evidence
Script, Email
Lawyer- Mrs. Jackson, do you have an email account?
Witness- Yes
Lawyer- Do you regularly send and receive emails with
this account?
Witness- Yes
Lawyer- Does Mr. Jackson have an email?
Witness- He does.
Lawyer- How do you know?
1 of 3
Witness- Well, we were married and emailed each other all
the time. In fact, by the end of our marriage it
seemed to be the only way we communicated.
Lawyer- Do you still email each other?
Witness- Yes
Lawyer- Do you know his email address?
Witness- Yeah it is MrCool@yahoo.com
Lawyer- Your honor, let the record reflect that I have
given opposing counsel a copy of Plaintiff’s Exhibit
10.
(Show to Opposing Counsel)
2 of 3
Lawyer- Your honor, may I approach the witness? Let the
record reflect that I am handing the witness a copy
of Exhibit 10.
(Show to Witness)
Lawyer- Do you recognize that document?
Witness- Yes. It’s a print out of an email from last month.
Lawyer- How do you know it came from him?
Witness- It is his email address and he is talking about the
kids.
Lawyer- Could it have come from someone else?
Witness- No. After 15 years of marriage, I know Mr.
Jackson. He was always secretive, even with me. He
3 of 3
never let people have his passwords and changed
them all the time. I also remember trying to send an
email from his account while we were married, and he
had to sign in for me.
Lawyer- Now, Mrs. Jackson, can you please read the
highlighted portion of the conversation out loud for
the court to hear?
4 of 3
Witness- “I don’t care what you say. I am going on this
Mexico vacation with my new girlfriend, and I am
taking the kids with me. It’s my right as a father to
take a vacation with my children, and there is nothing
you can do to stop me. I already purchased their
tickets. Besides, this isn’t the first time that I’ve done
it, and I was so good about watching over them that
you never even knew they had left the country. Good
luck stopping me this time!”
Lawyer- Your honor, we ask that exhibit 10 be entered in
as evidence
5 of 3