A picture is worth a thousand words. With stunning advances in technology, lawyers can now use videos, computer-generated images, and simulations to effectively convey an astonishing amount of information to jurors in a very short period of time. If properly used, lawyers can metaphorically transport jurors back in time to observe the key events that precipitated the lawsuit. Accordingly, technology-based evidence is now an indispensable weapon in the arsenal of most trial attorneys.

While technology-based evidence can be mesmerizing and often dominates pre-trial preparation, it is essential for litigators to fully understand the evidentiary hurdles that must be overcome before technology-based evidence is used or admitted into evidence at trial. Nothing is worse than painstakingly preparing technology-based evidence, only to have it excluded by the judge at trial.