https:// www. justice.gov/ usao/page/file/1030666/download
pg 127 paragraph 4
>Manning objected to Exhibit 109 as hearsay. In ruling on authentication during trial, the judge
found that Exhibit 109 was not a business record that could be self
-authenticated unde
r F
ED
.
R.
E
VID
.
902(11)
. However, the trial judge ruled that Exhibit 109 was relevant and admissible if the prosecution
brought the custodian of records from San Francisco to Maryland to provide live testimony to
authenticate it on other Rule 901 grounds. As the witness was about to depart S
an Francisco for
Maryland, the defendant stipulated to the authenticity of Exhibit 109.
The Manning case illustrates several issues common to authentication of electronic machine
generated information. First, in today’s electronic information world, authen
tication witnesses often live