Record references.

• Jurisdiction: United States

Section 80. Record references.—Remember, in connection with citing exhibits, that the rules of some courts require you to state, not only the page at which the exhibit appears in the record, but also the page at which it was offered in evidence.¹²⁵ The reason for this requirement is that, when the members of the court read an exhibit in the record—and exhibits are normally printed separately from the testimony—they want to know, without having to search a long record, what was said when that exhibit was offered, and whether it was admitted generally or only for a limited purpose.

At the risk of offensive repetition, I will emphasize again the matter discussed in Section 44, above: the imperative and absolute necessity for backing up every assertion of fact in your Statement of Facts with a record reference to show that what you say is established by the record and is not simply conjured up out of thin air, whole cloth, and similar material of spontaneous generation. It is well, too, to repeat the record references when you repeat the assertion in the Argument, certainly when the point is critical or even of substantial importance. At that latter juncture...