United States v. Bertram

259 F.Supp.3d 638 (2017)

Facts

Ds objected to P's attempt to introduce emails between Defendants Bryan Wood and Brian Walters through Ms. Kaiser because Kaiser was not copied on those emails and presumably had never seen them before. The Court concluded the authenticity requirements were satisfied with respect to those emails. Despite Kaiser's lack of personal participation in the communication, she could speak to the authenticity of the emails under Rule 901(b)(4). They were admitted and Ds were found guilty and appealed.