If you are trying to enter a picture of a cell phone that contains metadata to, for instance, show the time stamp when a recorded conversation occurred, the below is the proper predicate:

Screenshot of Recording Metadata

 

  1. I’m showing you what has been marked as Exhibit __. Do you recognize it? [yes]

 

  1. What is it? [screenshot/photograph of my phone showing information about a recording I made on my phone – [file name/Exhibit __].

 

  1. What kind of information about the recording does the photograph depict? [file name, date created, length, whatever it shows generated by the recording app]

 

  1. Is the file information generated by the app about the recording you made accurate? [yes]

 

  1. Is the information about the recording shown in the photograph the original information generated by the app? [yes]

 

  1. Have you changed, altered, or edited any of the information about the recording shown in the photograph? [no]

 

  1. When was the photo taken? [date]
  2. Where was the photo taken?

 

  1. Who took the photograph?

 

  • Did you see the photograph immediately after it was taken? [yes]

 

  • Has the photograph been edited, altered, changed since it was taken? [no]

 

  • Does this photograph fairly and accurately depict the original file [metadata] information generated by the app when you made the recording? [yes]

 

Offer