Hearsay

A proper foundation for the admission of a business record must be provided by someone with personal knowledge of the maker's business practices and procedures. Computations based on a review of unidentified and unproduced business records constitute inadmissible hearsay and lack probative value.
Bank of Am., N.A. v. Barnett, NY Slip Op 04861 (2d Dep't September 10, 2025)