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Cal. Rules of Court, rule 1421
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Rule 1421 A writing may be authenticated by evidence that the writing refers to or states matters that are unlikely to be known to anyone other than the person …
ARTICLE 2. Means of Authenticating and Proving Writings
Rule Text
A writing may be authenticated by evidence that the writing refers to or states matters that are unlikely to be known to anyone other than the person who is claimed by the proponent of the evidence to be the author of the writing.
Enacted by Stats. 1965, Ch. 299.