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United States v. Rembert

United States Court of Appeals for the District of Columbia Circuit
863 F.2d 1023 (1988)


Rembert (defendant) was convicted of several crimes involving the robbery of three victims at knifepoint at ATMs. The ATMs had cameras and took videos and photographs of Rembert. At Rembert’s trial, Katie Wohlfarth, a supervisor of loss control at one of the banks involved, testified that a video recorder taped the view and took a photograph every three seconds, which imprinted the date and time of each picture. Wohlfarth identified a strip of photographs of Rembert as a fair and accurate depiction of what was on the videotape at the time that one of the victim’s cards was stolen. Wohlfarth testified about the loading of the cameras and the security of the film. Wohlfarth further testified that she had no personal knowledge of whether the photographs accurately depicted the scene around the ATM at that date and time. Rembert objected to the admission of the photographs as not being properly authenticated. Rembert’s objection was overruled, and he was convicted. Rembert appealed, arguing that the photographs were inadmissible.

Rule of Law


Holding and Reasoning (Sentelle, J.)

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