Anyone who does automotive litigation has learned that car companies don't really manufacture things anymore. They are primarily an assembler of millions of components, systems, and sub-assemblies that they buy from other component part manufacturers. These component part suppliers are rarely down the street, and are often in foreign countries with both language and discovery barriers. Getting the documents you need from them to prove your case can be a challenge for both sides of a typical products liability case.
Federal Rules of Evidence 902(11) and (12) make your job of authenticating domestic and foreign records and laying an evidentiary foundation for them at trial much easier. To utilize the provisions under Rule 902(11) and (12), always include an affidavit or certification with your document requests, and make sure you comply with the other formal specifics set out in these rules. If you do, the documents will be automatically qualified as records of a regularly conducted activity under Federal Rule of Evidence 803(6) without the need for a records custodian's deposition. If you forget to do this until a few weeks before trial, you are going to have a hard time getting these records admitted.