California, United States of America
The following excerpt is from Bohm v. Bonilla, G048212 (Cal. App. 2014):
The only evidence of the attorney's competence as a witness is the conclusory statement "I have personal knowledge of the following facts and if called as a witness in this matter could and competently [sic] testify thereto." The recitation of this formula, in the absence of facts showing a basis for personal knowledge, is not sufficient foundation. (Mamou v. Trendwest Resorts, Inc. (2008) 165 Cal.App.4th 686, 692, fn. 1; Snider v. Snider (1962) 200 Cal.App.2d 741, 754.)
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