BAER, JR. L. For similar approaches, see Uniform Rule 62(1); California Evidence Code §§225, 1200; Kansas Code of Civil Procedure §60–459(a); New Jersey Evidence Rule 62(1) Subdivision (c). The New York City Police Apr 18, 2024 · For a list of new & updated rules see Guide History See Guide to NY Evidence article 3 (Prima Facie Evidence) for further exceptions to the rule against the admission of hearsay for the records deemed prima facie evidence of their contents. Nov 28, 2018 · The New York Court of Appeals granted Cummings’ leave to appeal. Go to course. Brown, 610 N. JONAKAIT ET AL. The term, “business,” is broadly defined New York evidence law provides for numerous hearsay exceptions, each with specific requirements which must be fulfilled before the statement is admissible. Apr 18, 2024 · For a list of new & updated rules see Guide History See Guide to NY Evidence article 3 (Prima Facie Evidence) for further exceptions to the rule against the admission of hearsay for the records deemed prima facie evidence of their contents. A Practice Note discussing the common law exceptions to the hearsay rule in New York. 00. ” Nov 26, 2006 · Nonetheless, hearsay within hearsay is admissible under Fed. See . (2) Excited Utterance. ) Unlike Federal Rules of Evidence rule 801 (d) (2) (A), which permits a party’s statement to be admitted against the party in either the party’s individual or representative capacity, present New York law authorizes the use of a statement New York evidence law provides for numerous hearsay exceptions, each with specific requirements which must be fulfilled before the statement is admissible. The Confrontation Clause In criminal actions, a statement admitted under this exception may be barred by the Confrontation Clause of the Federal and New York State Constitutions if it is found to be “testimonial. , 112 AD2d 306, 307, aff'd 67 NY2d 681 [child's out-of-court statement is spontaneous statement and admissible]). (See Guide to NY Evid rule 8. , FEDERAL RULES OF EVIDENCE AND THEIR NEW YORK STATE PARALLELS (1986). , NEW YORK EVIDENTIARY FOUNDATIONS (1993) for a comparison and overview of the New York and Federal Rules of Evidence. Some exceptions include dying declarations, [3] excited utterances, [4] present sense impressions, [5] declaration of future intent, [6] and state of mind. (See People v Ortega,15 NY3d 610, 620-621 [2010] [Smith, J. Decided on May 8, 2018 . Before the enactment of CPLR 4549, New York’s common law did not recognize a hearsay exception for an agent’s or employee’s statement concerning the relationship when the agent or employee had no speaking authority. 2018 NY Slip Op 03306. The new rule, embodied in CPLR 4549, brings New York Evidence Law into near harmony with the Federal Rules of Evidence (FRE) 801(d)(2)(D) which admits (as non-hearsay) an opposing party’s statement that was made by “the party’s agent or employee on a matter within the scope be such an exception, given that the statute expressly excludes hearsay that is not admissible under a recognized hearsay exception (see e. , concurring] [discussing the “hearsay within hearsay” rule in relation to the admissibility of a hospital record that was admissible as an exception to the hearsay Dr. , 152 NY 339, 342 [1897]. It is undoubtedly the most frequently invoked hearsay exception at trial and on summary judgment motions. public record hearsay exception. 18 Documents. Morgan points out, however, that "in There are three categories of hearsay exclusions and exceptions: (1) nonhearsay (the exclusions); (2) exceptions that are only applicable if the declarant is unavailable; and (3) exceptions where the declarant can be available or unavailable. 18, 2023. The rule in its current form applies to hearsay “not specifically covered” by a Rule 803 or 804 exception. This Note provides an explanation of the differences between the hearsay exceptions recognized by statute, such as under Civil Practice Law and Rules (CPLR) Article 45, and those that exist at common law, such as admissions, ancient documents, business records Co. (b) The Federal and New York State Constitutions require the admission of hearsay not encompassed This Note examines the CPLR Article 45 hearsay exceptions and explains how to properly certify, authenticate, and offer documents so that they become self-authenticating, admissible in evidence, and received by the court. Hillmon, 145 U. , if it is "offered against a party and is (A) the party's own statement, in either Aug 22, 2019 · However, some jurisdictions—including New York—still do not recognize an exception to the hearsay rule for a child’s out-of-court statements regarding abuse. 19. In Davidson v Cornell (132 NY 228, 237-238 [1892]), the Court recognized a hearsay exception for statements by a person to his or her physician Apr 18, 2024 · For a list of new & updated rules see Guide History See Guide to NY Evidence article 3 (Prima Facie Evidence) for further exceptions to the rule against the admission of hearsay for the records deemed prima facie evidence of their contents. 1993). This Note provides an explanation of the differences between the hearsay exceptions recognized by statute, such as under Civil Practice Law and Rules (CPLR) Article 45, and those that exist at common law, such as admissions, ancient documents, business records Apr 18, 2024 · For a list of new & updated rules see Guide History See Guide to NY Evidence article 3 (Prima Facie Evidence) for further exceptions to the rule against the admission of hearsay for the records deemed prima facie evidence of their contents. Jul 24, 2017 · Under the New Jersey Rules of Evidence, the rationale for why such an out-of-court statement should be considered sufficiently reliable to qualify as an exception to the hearsay rule is that people don’t typically say unfavorable things about themselves unless they are true. Jun 6, 2013 · Under present New York law, an out-of-court admission of an agent or employee is admissible in evidence in an action against his principal or employer as an admission of the principal or employer Dec 17, 2015 · We handle New York State Criminal Appeals and Federal Criminal Appeals Throughout The United States. (See People v James, 93 NY2d 620, 634-635 [1999]. L. It encompasses the doctrine as set forth in Mutual Life Ins. Federal Constitution and New York Constitution as provided in rule 8. , 89 NY 242, 248-249 [1882] [feelings of hostility]; see also Hine v New York El. Y. Rule 802 bars the admission of hearsay evidence unless an exception applies. or not. Cummings, 2018 NY Slip Op. This Note examines the CPLR Article 45 hearsay exceptions and explains how to properly certify, authenticate, and offer documents so that they become self-authenticating, admissible in evidence, and received by the court. The Rule 803 Exceptions A Practice Note discussing the common law exceptions to the hearsay rule in New York. This Note provides an explanation of the differences between the hearsay exceptions recognized by statute, such as under Civil Practice Law and Rules (CPLR) Article 45, and those that exist at common law, such as admissions, ancient documents, business records Sep 13, 2014 · One important hearsay exception, which originally was made for abuse and neglect cases, is for children’s statements about abuse or neglect are admissible. Exceptions to the Rule Against Hearsay — Regardless of Whether the Declarant Is Available as a Witness : Article 8 : 804. PUBLIC RECORDS AND REPORTS ii. This Note provides an explanation of the differences between the hearsay exceptions recognized by statute, such as under Civil Practice Law and Rules (CPLR) Article 45, and those that exist at common law, such as admissions, ancient documents, business records This Note examines the CPLR Article 45 hearsay exceptions and explains how to properly certify, authenticate, and offer documents so that they become self-authenticating, admissible in evidence, and received by the court. The traditional hearsay exceptions are drawn upon for the exceptions, collected under two rules, one dealing with situations where availability of Maguire, The Hearsay System: Around and Through the Thicket, 14 Vand. (b) The Federal and New York State Constitutions require the admission of hearsay not encompassed within a hearsay exception when the court finds that the declarant is unavailable to testify and the hearsay the admission’s exception. ” (Eisenlord v Clum, 126 NY 552, 563 [1891]. E. This Note provides an explanation of the differences between the hearsay exceptions recognized by statute, such as under Civil Practice Law and Rules (CPLR) Article 45, and those that exist at common law, such as admissions, ancient documents, business records Feb 14, 2022 · CPLR 4549 is a significant evidentiary enactment. 02, or as provided in subdivision (1)(b) below. of New York v. Feb 7, 2020 · ANALYSIS ‘Residual Hearsay’ Exception: Recent Changes Bring More Muscle. Revisions to the rule made in 2019 beefed up its usefulness, as it now allows hearsay evidence not covered by other rules so long as: Jan 25, 2022 · The New York State Legislature recently amended the rules of evidence to significantly expand the “party admission” exception to the rule against hearsay with the addition of CPLR 4549. However, New York courts have admitted out-of-court statements of abuse from a minor child only if those statements were relevant to a doctor’s medical diagnosis. Hearsay is generally inadmissible because it “deprives the defendant of the right to test the accuracy and trustworthiness of the statement by cross-examination,” the New York Court of Appeals has explained. (b) The Federal and New York State Constitutions require the admission of hearsay not encompassed This is another example of courts being very reluctant to allow exceptions to the hearsay rule. Admissibility of Hearsay (1) (a) Hearsay is not admissible unless it falls within an exception to the hearsay rule as provided by case law or statute or as required by the Federal Constitution or the New York State Constitution. RE . B. Records, reports, statements or data compilations, in The use of a statement recorded in a police accident report involves two levels of hearsay, each of which must fit within a hearsay exception to render the statement contained within the report admissible (see Memenza v Cole, 131 AD3d at 1022, citing Murray v Donlan, 77 AD2d 337, 346). , Matter of Lydia K. As explained by the Supreme Court of New Jersey in State v. R. Most exceptions to the Hearsay Rule are found in Rules 803, 804 and 807. Thompson, testified on the subject matter of the hearsay, as did those presenting the hearsay testimony, Janet's father and mother and the party raising the hearsay objection, Parke, Davis, had a full opportunity to cross-examine and confront all those witnesses at the trial, the hearsay rule should not be applied to bar the testimony. There must, therefore, be factors favoring admissibility which offset this objection. Federal Rule of Evidence 803 is a set of rules that provides exceptions to the general rule against hearsay in legal proceedings. Hearsay Exceptions; Declarant Unavailable : 805. 641 (1992) (discussing the make-up of New York's rules of evidence). Feb 21, 2023 · Many hearsay exceptions will be familiar for those who know the FRE. Admissibility of Hearsay : 803. 2. We are well versed in all the procedures and practices in all the Federal Circuit Courts. This Note provides an explanation of the differences between the hearsay exceptions recognized by statute, such as under Civil Practice Law and Rules (CPLR) Article 45, and those that exist at common law, such as admissions, ancient documents, business records A Practice Note discussing the common law exceptions to the hearsay rule in New York. The exception for “memory or belief,” initially recognized in Shepard v United States (290 US 96 [1933, Cardozo, J. The judge explained that “body-worn cameras are uniquely suited to addressing the constitutional harms” of abusive policing. Hearsay in Hearsay : 806. (See Reed v McCord, 160 NY at 341, supra. " A statement is not hearsay if it is an admission of a party opponent — i. New York’s Current Rule. Jan 16, 2019 · Generally speaking, hearsay evidence is not permitted to be considered by the jury in a New York criminal trial. However, there are certain exceptions — January 16, 2019 Free Consultation: 877-377-8666 admitting hearsay into evidence. v Hillmon (145 US 285 [1892]). Joseph D. In his Complex Litigation column, Michael Hoenig discusses the hearsay rule and some of its exceptions, particularly Pedigree declarations are “a well known and recognized exception to the general rule excluding hearsay evidence. As of January 2022, New York will adopt a new provision to the Civil Practice Law and Rules, CPLR §4549 which states: Admissibility of an opposing party's statement. records were admissible under the business records exception to the hearsay rule. Over 40 years after the enactment of Rule 803(18), New York still adheres to a 19th century rule that prohibits the admission—or, in most cases, the discussion—of learned Dec 14, 2021 · Handling the State-of-Mind Hearsay Exception in a Criminal Trial: Guidance From the Second Department. New York Court of Appeals. ” (But see People v Nieves-Andino, 9 NY3d 12 [2007] [as police officer reasonably assumed that there was an ongoing emergency, the Sep 18, 2023 · The professional reliability exception to the hearsay rule is being litigated at the trial of malpractice cases with increasing frequency after being the subject of decisions on the criminal side exceptions to the hearsay rule” (citations omitted)]; see also People v Caviness, 38 NY2d 227, 230 [1975]; Felska v New York Cent. The definition follows along familiar lines in including only The measure would add a new CPLR 4549, and cause New York's hearsay exception to follow the approach of Federal Rule of Evidence 801(d)(2)(D). New York has been hesitant to admit reports containing "opinions" and "conclusions" that Federal Rule 803(8)(C) allows. C In New York City, the federal district court that found that city’s infamous “Stop and Frisk” program unconstitutional ordered implementation of a body camera program as a remedy. 4. Definition of Hearsay : 802. People v. The leading treatises on New York evidence, however, suggest that the exception has not been adopted in New York, though they also suggest that it should be adopted (Fisch, New York Evidence §§ 995-996 [2d ed & 2008 Supp]; Prince, Richardson on Evidence § 8-610 [Farrell 11th ed]), and one of them describes recent cases that point in that The following are not excluded by the rule against hearsay, regardless of whether the declarant is available as a witness: (1) Present Sense Impression. 39, is offered as proof of subsequent conduct. New York evidence law provides for numerous hearsay exceptions, each with specific requirements which must be fulfilled before the statement is admissible. Click on your areas in New York for more information. A statement describing or explaining an event or condition, made while or immediately after the declarant perceived it. Nov 20, 2023 · The first half of this series, addressing the historical development of the law in New York on the professional reliability exception to the rule against hearsay, was published on Sept. , a general rule excluding hearsay, with exceptions under which evidence is not required to be excluded even though hearsay. Hearsay within hearsay or multiple hearsay or double hearsay issues frequently arise with business records. It deserves careful study not just because it creates a new hearsay exception but also because the statute, based as it is on New York’s common The following are not excluded by the rule against hearsay, regardless of whether the declarant is available as a witness: (1) Present Sense Impression. Generally, "[a] hearsay entry in a hospital record is admissible under the business records exception to the hearsay rule if the entry is germane to the diagnosis or treatment of the patient" (Berkovits v Chaaya, 138 AD3d 1050, 1051 [2016]; see CPLR 4518 [a declarant’s then-existing intent, which is admissible under the exception set forth in Guide to New York Evidence rule 8. 741, 765–767 (1961). " Morgan, Hearsay Dangers and the Application of the Hearsay Concept, 6z HARV. ) The exception encompasses any record of a business “made as a memorandum or record of any act, transaction, occurrence or event” (CPLR 4518 [a] [first sentence]). 01, Admissibility of Hearsay. This new rule will undoubtedly have adverse consequences New York evidence law provides for numerous hearsay exceptions, each with specific requirements which must be fulfilled before the statement is admissible. The Rule Against Hearsay : 8. Oct 14, 2020 · The Family Court erred in admitting the child’s hearsay statements into evidence because the hearsay exception set forth in Family Court Act § 1046(a)(vi) does not apply in family offense proceedings pursuant to Family Court Act article 8 … . Mind your own business records exception. The statement(s) alone are not enough for a finding of abuse or neglect without being corroborated. The operative element of the “speaking agent” exception is that the agent or A Practice Note discussing the common law exceptions to the hearsay rule in New York. 8. %PDF-1. Attacking and New York evidence law provides for numerous hearsay exceptions, each with specific requirements which must be fulfilled before the statement is admissible. e. exception to the general prohibition on the admission of hearsay. Try to remember which rules fall into each category. In People v. Hearsay Within Hearsay : 8. Aug 12, 2020 · Federal Rule of Evidence 807, known as the "catch-all provision" or "residual exception," states that a hearsay statement not covered by one of the many other exceptions can still be admitted. The evidentiary law question is whether the admission of a 911 tape under New York's present sense impression hearsay exception, where the declarant was available and testified at trial, improperly "bolstered" that victim-witness's testimony. 2d 369 (N. 03306 (May 8, 2018), the Court of Appeals addressed New York’s long recognized excited utterance exception to the hearsay rule. ” Dec 14, 2022 · More than any rule of evidence, hearsay has been extensively defined and litigated in rule books and cases. 21. New York's hearsay exception will now follow the approach of Federal Rule of Evidence 801(d)(2)(D). 2d 569, 510 N. But the opponent cannot seek admission under Rule 807 if it is apparent that the hearsay could be admitted under another exception. 5 This analysis can get confusing even when the facts Federal Constitution and New York Constitution as provided in rule 8. Example: Then existing state of mind (iv) any writing, record or photograph, whether in the form of an entry in a book or otherwise, made as a memorandum or record of any condition, act, transaction, occurrence or event relating to a child in an abuse or neglect proceeding of any hospital or any other public or private agency shall be admissible in evidence in proof of that condition, act, transaction, occurrence or event, if the . Law 88% (8) 1. the defendants were charged with manslaughter for allegedly beating their four-year (3) The approach to hearsay in these rules is that of the common law, i. This formulation of the present sense impression hearsay exception is primarily derived from People v Brown (80 NY2d 729, 734-735, 737 [1993]), wherein the Court of Appeals recognized the exception: “[W]e hold that spontaneous descriptions of events made substantially contemporaneously with the observations are admissible if the New York evidence law provides for numerous hearsay exceptions, each with specific requirements which must be fulfilled before the statement is admissible. The Senate amendment adds a new subsection, (b)(6) [now (b)(5)], which makes admissible a hearsay statement not specifically covered by any of the five previous subsections, if the statement has equivalent circumstantial guarantees of trustworthiness and if the court determines that (A) the statement is offered as evidence of a material fact Apr 18, 2024 · For a list of new & updated rules see Guide History See Guide to NY Evidence article 3 (Prima Facie Evidence) for further exceptions to the rule against the admission of hearsay for the records deemed prima facie evidence of their contents. Co. Hearsay Exceptions Co. Jan 31, 2022 · Like any rule, the prohibition against hearsay has its exceptions. Although most jurisdictions now reject hearsay objections to learned treatises, New York is an exception. To speak to an appellate lawyer in New York call 1-800-APPEALS (277-3257) New York evidence law provides for numerous hearsay exceptions, each with specific requirements which must be fulfilled before the statement is admissible. 2d 853 (1986) the Court of Appeals observed that “[t]he business records exception has been recognized as probably the most important hearsay exception,…” I have observed that “it may also be the most misunderstood and misused hearsay exception. (1) (a) Hearsay is not admissible unless it falls within an exception to the hearsay rule as provided by case law or statute or as required by the Federal Constitution or the New York State Constitution. The definition is well-settled: hearsay is an out-of-court statement offered for the The following are not excluded by the rule against hearsay, regardless of whether the declarant is available as a witness: (1) Present Sense Impression. Kennedy, 68 N. court statements provided each such layer overcomes a hearsay exception or is not offered for its truth. S. [7] These are just a few notable examples of hearsay exceptions that New York and the FRE both accept. A court is not required to make a finding that no other hearsay exception is applicable. LEARNED TREATISES IN NEW YORK. ) They are “admitted on the principle that they are the natural effusions of persons who must know the truth and who speak on occasions when their minds New York evidence law provides for numerous hearsay exceptions, each with specific requirements which must be fulfilled before the statement is admissible. HAROLD J. Dec 2, 2020 · CPLR 4518(a) sets forth the business records exception to the hearsay rule. R. Nohavicka for New York Law Journal. 805 if "each part of the combined statements conforms with an exception to the hearsay rule provided in these rules. Hillmon, 145 US 285 (1892). This Note provides an explanation of the differences between the hearsay exceptions recognized by statute, such as under Civil Practice Law and Rules (CPLR) Article 45, and those that exist at common law, such as admissions, ancient documents, business records The following are not excluded by the rule against hearsay, regardless of whether the declarant is available as a witness: (1) Present Sense Impression. New York does not generally admit conclusions or opinions in criminal cases. ELEMENTS OF THE EXCEPTION 1. (b) The Federal and New York State Constitutions require the admission of hearsay not encompassed within a hearsay exception when the court finds that the declarant is unavailable to testify and the hearsay Jan 31, 2022 · Like any rule, the prohibition against hearsay has its exceptions. Supreme Court case that created one of the most important rules of evidence in American and British courtrooms: an exception to the hearsay rule for statements regarding the intentions of the declarant. This Note provides an explanation of the differences between the hearsay exceptions recognized by statute, such as under Civil Practice Law and Rules (CPLR) Article 45, and those that exist at common law, such as admissions, ancient documents, business records Oct 18, 2023 · Exceptions to the hearsay rule may be slightly different in different states, and exceptions in state courts may be different from exceptions in federal courts. 5 %¦éÏÄ 19 0 obj > endobj 25 0 obj 9e45227c9d741caad4ffb70bee589fca>]>>stream xÚ ÅË € DÑ™ ~€ û° [sig$”Ãuqr¬CN· ¿r~ä³Ë ]?# ±`ņ m Apr 18, 2024 · For a list of new & updated rules see Guide History See Guide to NY Evidence article 3 (Prima Facie Evidence) for further exceptions to the rule against the admission of hearsay for the records deemed prima facie evidence of their contents. Because of the Six Amendment right to confront witnesses, any exception to the hearsay rule must be based on evidence that the declarant actually observed the event about which the declaration was made. 4 Parties must determine if the subject matter being discussed is in fact hearsay as defined by the rules, and potentially how many levels of hearsay are involved—such that every level either is not hearsay or meets an exception to the hearsay prohi-bition. 01. 3. & Hudson Riv. Evidence 100% (1) Students Dec 14, 2021 · ANALYSIS. Mutual Life Insurance Co. In my view, together with the rule on admissions, these hearsay exceptions are among the most important evidentiary rules in Federal practice. One of the reasons to hire an attorney for a criminal trial is that they will be familiar with the specific evidentiary rules in the appropriate court. This hearsay exception is found in Family Court Act 1046(a)(vi). Hearsay Exceptions Chart. Any exception to the hearsay rule deprives the jury of an opportunity to observe the demeanor of the original declarant. This Note provides an explanation of the differences between the hearsay exceptions recognized by statute, such as under Civil Practice Law and Rules (CPLR) Article 45, and those that exist at common law, such as admissions, ancient documents, business records Still, courts admit hearsay evidence only when it falls within a recognized exception to the hearsay rule and the proponent can demonstrate that it is reliable (Nucci v Proper, 95 NY2d 597, 602 [2001]; People v Brensic, 70 NY2d 9, 14 [1987]; People v Nieves, 67 NY2d 125, 131 [1986]; see also Barker & Alexander, Evidence in New York State and Jan 31, 2022 · Like any rule, the prohibition against hearsay has its exceptions. Que cards - law. REV. Hampton, 20 . Cummings. The Second Department recently decided a case dealing with what is undeniably the bane of the criminal defense bar: handling testimony of a law enforcement officer, who is recounting statements made to them by a non-testifying accomplice directly Apr 18, 2024 · For a list of new & updated rules see Guide History See Guide to NY Evidence article 3 (Prima Facie Evidence) for further exceptions to the rule against the admission of hearsay for the records deemed prima facie evidence of their contents. 14. 177, 218 (1948). Matter of Godfrey v Bahadeur, 2020 NY Slip Op 05750, Second Dept 10-14-20 New York evidence law provides for numerous hearsay exceptions, each with specific requirements which must be fulfilled before the statement is admissible. Hearsay is an out-of-court statement offered in court to prove the truth of the matter asserted in the statement. The following are not excluded by the rule against hearsay, regardless of whether the declarant is available as a witness: (1) Present Sense Impression. (v) is absent from the hearing and the proponent of the declarant's statement has been unable to procure the declarant's attendance (or in the case of a hearsay exception under subparagraph [2] [ii], [iii] or [iv] of this subdivision, the declarant's attendance or testimony) by process or other reasonable means; or May 8, 2018 · People v. , 149 NY 154, 162 [1896] [statement as to motive admitted as part of res gestae]). g. ) Hearsay admitted without objection may properly be considered by the trier of fact and can be given such probative value as under the circumstances it New York evidence law provides for numerous hearsay exceptions, each with specific requirements which must be fulfilled before the statement is admissible. Handling the State-of-Mind Hearsay Exception in a Criminal Trial: Guidance From the Second Department. The 'Lockley' decision is a great reminder that when your hearsay objection is met The following are not excluded by the rule against hearsay, regardless of whether the declarant is available as a witness: (1) Present Sense Impression. See I RANDOLPH N. Issue: Whether a statement, heard in the background of a 911 call and spoken by an unidentified person, is admissible at trial under the excited utterance exception to the hearsay rule. Evid. Matters observed pursuant to a duty imposed by law as to which matters there was a duty to report —Rule 803(8) 1. Rev. 285 (1892), is a landmark U. treatment is not excluded by the hearsay rule even though the declarant is available to testify. ]), has been consistently recognized by The following are not excluded by the rule against hearsay, regardless of whether the declarant is available as a witness: (1) Present Sense Impression. The measure is intended to change the extent of authority that a propo- nent must show in order to make the hearsay statement of an opposing party's agent or employee admissible. Hearsay Rules Overall. But it should also Jun 6, 2018 · In People v. New York Law School. Note This formulation is derived from several Court of Appeals decisions. 13. ) The source of these exceptions is both statutory and decision law. The United States Supreme Court noted in Hillmon that a This Note examines the CPLR Article 45 hearsay exceptions and explains how to properly certify, authenticate, and offer documents so that they become self-authenticating, admissible in evidence, and received by the court. vprzse pwh xpasej imnsaqmou dyx xicet rorlh vktrtt xph ydju