Q: Proof of affiliation of the identified individuals at the relevant times.

A: Under California law, you can demand that the defendant authenticate any documents or evidence provided to establish the affiliation of the identified individuals at the relevant times by including a "Production Demand" in your discovery request. This is done in accordance with the California Evidence Code, specifically sections 1400-1454 which cover authentication of writings.

Here are some key points to ensure the authenticity of the documents:

1. In your Production Demand, specifically request that the defendant produce original documents or evidence, or true and correct copies thereof, to establish the affiliation of the identified individuals at the relevant times.

2. Cite California Evidence Code sections 1400-1454, which cover the authentication of writings. In particular, section 1401 states that authentication of a writing is required before it may be received in evidence.

3. Pursuant to California Evidence Code section 1410, request that the defendant produce a subscribing witness to authenticate any documents, if available. If a subscribing witness is not available, the defendant may need to provide other evidence of authenticity as outlined in sections 1410-1421.

4. If the defendant produces copies of documents, request that they be accompanied by a declaration under penalty of perjury stating that they are true and correct copies of the original documents, in accordance with California Evidence Code section 1521.

5. If the defendant objects to your Production Demand, you may need to file a motion to compel production of the requested documents and evidence, pursuant to the California Code of Civil Procedure.

Sample language for your Production Demand:

"Pursuant to California Evidence Code sections 1400-1454, Plaintiff hereby demands that Defendant produce original documents or true and correct copies thereof, authenticated by a subscribing witness or other admissible evidence, to establish the affiliation of the identified individuals at the relevant times. If Defendant produces copies of documents, each copy shall be accompanied by a declaration under penalty of perjury stating that it is a true and correct copy of the original document."