Mr. Lackhart, the first thing we should do it to stipulate in writing an agreement with the defendants about what evidence is admissible under the provisions of the California Evidence Code § 451-452. In this case the evidence we want admitted are five substantial material things:

1. Defendants’ insurance policy;
2. Photograph of Sarah Jane Robertson’s face following dog-bite – Chin & Lip. [Figure 4.1]

3. Photograph of Sarah’s face – front view. [Figure 4.2]
4. Photograph of Sarah’s face – lower chin. [Figure 4.3]
5. Photograph of defendant’s dog known as “Bear.” [Figure 4.4]

Next we will need to a formal request to the court in order for it to take judicial notice, and then a copy of that request must be served on the opposing parties. …show more content…
Questions to be asked are: To all of the witness do you recognize the child in the four photos? Is this Sarah Robertson? Do agree that these injuries look the same as Sarah’s, and would you say that these injuries are located in the same place on her face? Do you know when and were these photos of Sarah were taken, and the approximate time?

Furthermore, we must request that the court take judicial notice that the collection of photographs of the defendants’ dog, the dog-bites, and the damages the bites caused to Sarah’s face. All of the photos other than the photograph of the dog and defendants insurance policy, Exhibits [4.1-4.2] were taken at the Children’s Medical Hospital during the operation. Which falls within the exception to the hearsay rule under the California, Evidence Code section 1280. In addition, with all of medical personals’ testimony who witnessed the taking of the photographs of Sarah’s face, “we would like for the court to admit each piece of evidence mentioned above and laid the foundation for it. What’s more, for the court to admit all exhibits that were introduced without objection (exhibit 4.4, and insurance