What is the common law common law rule on cross-dressing notes?

This common law rule evolved with Ares v. Venner 1970 CanLII 5 (SCC), [1970] S.C.R. 608, to include notes made contemporaneously by someone still living, with personal knowledge of what is recorded and who was under a duty to make the record. The factual situation in Ares was similar to that in this case, in the sense that it involved hospital records. Many of the statements in Ares with respect to necessity and reliability apply in this case.