To lay the foundation for admission for a photograph into evidence, ask questions such as these:
Q. Mr. Witness, I'm handing you a photograph that's been marked Exhibit 2 for identification. What is depicted in that photograph?
A. A stoplight at the intersection of 4th and Pine.
Q. Is that photograph a fair and accurate representation of the stoplight at 4th and Pine as it existed on the day of the collision?
A. Yes, it is.
At this point, you can move for admission of the photograph into evidence.
What if something about the scene depicted in the photograph has changed since the date of the collision? In the example above, for example, what if the collision occurred on a snowy day, but the photograph was taken on a day without snow?
If you are using the photograph not to demonstrate the type of ground cover, but the position of the stoplight, ask the second question like this: "With the exception of absence of snow from the ground, is the photograph marked as Exhibit 2 for identification a fair and accurate representation of the intersection at 4th and Pine on the date of the collision?"
Source for post idea: James W. Jeans, Trial Advocacy p. 11.6 (West 1975).