May 25, 2015


Today’s Tip for Commercial Litigators: Have a Game Plan for Introducing Documents at Trial

When opposing counsel objects to the introduction of a document at trial, a good attorney will be able to respond by citing the evidentiary basis for why the objection should be overruled. This is the result of good preparation.

In advance of court, write out the evidentiary basis for every document you intend to offer into evidence. Juries need to be able to see the documents that support your case. Know how to lay the foundation for business records. Know when you need a custodian of records. Know by statutory reference when a document is self-authenticating. Know the particular exception to hearsay. You do not want the jury to be denied the ability to review documents because opposing counsel’s evidentiary objection is sustained. This mishap can, and should, be avoided.

© 2015 Odin, Feldman & Pittleman, P.C.


About this Author

Stephen Shannon, Commercial Litigation Attorney, Odin Feldman, Law Firm

Steve Shannon believes the key to being an effective litigator is to be thoroughly prepared and make the complex seem simple. He has the foresight to properly evaluate a case and to provide his clients with realistic strategies to reach their goals through litigation. Steve’s practice focuses on civil litigation, criminal litigation, and administrative law. He regularly appears in federal and state courts throughout Virginia and has handled over 1,000 cases during his legal career.

Steve’s civil litigation practice focuses on representing companies and individuals in...