If you are using requests for admissions to authenticate trial exhibits before trial, you'll have to attach the exhibits to your requests so that your opposing counsel can evaluate them one by one.
One method is to attach paper printouts of the documents, identified with exhibit stickers. Your request for admissions itself might look like this:
1. Admit that each of the following documents attached as an exhibit to these requests for admissions is a true and accurate reproduction of a genuine original.
(a) Exhibit 1: Letter from Joe Blutz to Margaret Hatz dated 1/1/01;
(b) Exhibit 2: Letter from Margarate Hatz to Jane Hertz dated 2/1/01.
In a large document-intensive case, you might have hundreds or thousands of multi-page documents you want to authenticate. Rather than print and attach each document, you can provide the documents on a CD-ROM. Here is an example of a request I used in a Missouri case, where the court rules also describe the evidentiary foundation necessary for business records:
1. Attached hereto as Exhibit 1 is a list of documents identified by Bates number, date, author, and subject matter. An image of each document in .tif format has been provided on the CD-ROM attached as Exhibit 2. Regarding each such document, an electronic version of which resides on Exhibit 2, please admit:
(a) The electronic version of each document identified by Bates Number in Exhibit 1 is a true, correct, and genuine copy;
(b) The genuineness and authenticity of the electronic version;
(c) The electronic version (or a printed copy thereof) is admissible as a business record pursuant to [Missouri Rule].
This method of combining electronic documents with requests to admit has worked well for me, but other suggestions are welcome in the comments.
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