Foundation is the preliminary showing required before a piece of evidence can be admitted proof that the evidence is what the offering party claims it is and that it is reliable enough for the court to consider.

Common foundation requirements include authenticating a document as genuine, establishing that a photograph accurately depicts what is portrayed, confirming that a record is a business record maintained in the ordinary course of business, or establishing that a witness has personal knowledge.

Preparing foundation testimony for every exhibit before trial prevents having key evidence excluded because foundation was not properly established. Know in advance how you will authenticate each exhibit.