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WASHINGTON v. STATE

No. 31, September Term, 2008.

961 A.2d 1110 (2008)

406 Md. 642

Rory Howard WASHINGTON v. STATE of Maryland.

Court of Appeals of Maryland.

December 12, 2008.

Attorney(s) appearing for the Case

Allison Pierce Brasseaux, Asst. Public Defender (Nancy S. Forster, Public Defender, Baltimore) on the brief, for Petitioner/Cross-Respondent.

Edward J. Kelley, Asst. Atty. Gen. (Douglas F. Gansler, Atty. Gen., Baltimore) on brief, for Respondent/Cross-Petitioner.

Argued Before BELL, C.J., HARRELL, BATTAGLIA, GREENE, MURPHY, JOHN C. ELDRIDGE, (Retired, specially assigned), and IRMA S. RAKER, (Retired, specially assigned), JJ.

IRMA S. RAKER, Judge, (Retired, specially assigned).

In this criminal case, we address the requirements of an adequate evidentiary foundation for the admission of a surveillance videotape. We shall reverse because the trial court erred in admitting the tape without an adequate foundation, and the error was not harmless beyond a reasonable doubt.

I.

Rory Washington was indicted by the Grand Jury for Baltimore City for the offenses of attempted murder...

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