California, United States of America
The following excerpt is from People v. J.D. (In re J.D.), G048287 (Cal. App. 2014):
Evidence Code section 1271 states, "Evidence of a writing made as a record of an act, condition, or event is not made inadmissible by the hearsay rule when offered to prove the act, condition, or event if: [] (a) The writing was made in the regular course of a business; [] (b) The writing was made at or near the time of the act, condition, or event; [] (c) The custodian or other qualified witness testifies to its identity and the mode of its preparation; and [] (d) The sources of information and method and time of preparation were such as to indicate its trustworthiness." "A trial court has broad discretion in determining whether a sufficient foundation has been laid to qualify evidence as a business record. On appeal, we will reverse a trial court's ruling on such a foundational question only if the court clearly abused its discretion." (People v. Hovarter (2008) 44 Cal.4th 983, 1011.)
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