I have a question on this.  I remember I thought I heard a 100 years ago that when identifying photos on the index of exhibits that are marked for identification, that the reporter is just supposed to put "Photograph" or "Color photograph" or whatever the case may be.  It is not our job to interpret what's in the photograph. 

My scopist filled out exactly what's in each photo for the index.  I wanted to confirm that we're not supposed to do that.

Do any of you remember hearing that?  I have a number of color photographs in this expedite I'm doing and they're identifying what's in the photos and I just want to make sure that I do this correctly.  I think I'm correct.  I know what's in each photo, but I want to make sure I'm correct we don't put that in the exhibit description.  It does seem like it needs more description besides "Color photograph" though.

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I would just put in things like "photocopy of photograph" or "photograph" or "color photograph," not an interpretation of what is in the photograph.

That's what I thought.  Thanks, Janet.

I agree with Janet.  That's for the attorney to do on the record.

That's what I'd do too, "photograph".  That's all I've ever done.

Sometimes you can't even tell what the photograph is or what the point is that they're trying to make.

I go with color photograph or photograph.

I just put either black and white or color photocopy (if it's a copy) or black and white or color photograph and maybe a simple description like "accident scene" or  "intersection" or "vehicle".  But that's it.  If there's several shots of a damaged vehicle, I will just keep using the same description for all of them,
 "copy of vehicle."

When the attorney describes the photo in the transcript, I put the exact description on my index page, or if it's a picture of a car I put "Color photograph of vehicle."  That's how I was taught when I was a new reporter.


Yeah, but I was taught that it's not our job to interpret what's in the photo.  Just put "photograph" and move on. 

I don't remember what I was taught in school, it was a reporter/agency owner who wanted the reporters to do it that way, so I just automatically do it.  There were a lot of things she liked a certain way, which I no longer do.  It seems like there is not right or wrong answers (most of the times), it just depends on your own personal style.  For instance, if a letter with attachments was marked as an exhibit with Bates stamp numbers, I had to do it:  6-page 12/12/12 letter to so-and-so from so-and-so, Bates Stamps Nos. 00024-00029; 15-page attachment, Bates stamp Nos. 00030-00045. 

If you put the description of the photo as given by the attorney or the witness, you're not really interpreting what's in the photo, just using their interpretation as a description.  I'm comfortable doing that.  But if no one describes what's in the photo, "Color photograph" and a Bates number should suffice.


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