A general description of the equipment is sufficient. The presentation depicts a certain area, object, or notation. The witness is familiar with that area, object, or notation and explains the basis of his or her familiarity. In the witnesses opinion, the presentation is an accurate depiction of that area, object, or notation. Witness is familiar with the object, scene, etc.
Witness recognizes the object, scene, etc.
The differences must be identified and the testimony must identify the parts of the photograph which are irrelevant to the case. Southeastern Eng'r and Mfg. Remoteness in time alone, without changed conditions, does not affect admissibility. If a photograph is merely calculated to arouse passion or create prejudice, it should be excluded. The foundation witness, in addition to testimony regarding accuracy, must state what the photograph depicts.