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Appeals court hears challenge to admission of third‑party invoices as business records

Appeals Court Panel (Mead, Ditkoff, Toon) · November 4, 2025
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Summary

The court considered whether invoices and contractor records the plaintiff received from third parties were admissible under Massachusetts' business‑records statute (G.L. c. 233 §78) when introduced by the recipient rather than the document creator. Appellant argued the trial judge failed to make the statutory findings and that admitting such

The Appeals Court heard argument in 25P262, ADA Management Services v. Ho, over whether trial evidence admitting third‑party invoices as business records of ADA satisfied statutory foundation requirements.

Alan Aaron, arguing for the appellant Samuel Ho, urged reversal, saying the trial court allowed ADA’s representative to identify and admit invoices that were created by third‑party contractors without the testimony of the contractor or a custodian with personal knowledge. Aaron stressed the statutory…

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