Pacific Gas & E. Co. v. G. W. Thomas Drayage Etc. Co

In Pacific Gas & E. Co. v. G. W. Thomas Drayage Etc. Co. (1968) 69 Cal.2d 33, the court held that repair invoices, offered to prove certain repairs of a steam turbine had actually been made, were (1) hearsay, and (2) not admissible under the business records exception because "no qualified witness was called to testify that the invoices accurately recorded the work done by the company that purportedly made the repairs, and there was no other evidence as to what repairs were made." ( Id. at p. 43.) Invoices of this sort, however, stand on a different footing than common cash register receipts.