Hahnemann Univ. Hosp. v. Dudnick

In Hahnemann Univ. Hosp. v. Dudnick, 292 N.J. Super. 11, 678 A.2d 266 (App.Div.1996), defendant argued that the trial court erred by admitting into evidence computer printout records detailing her outstanding hospital bill. The hospital's witness had testified in order to establish a foundation for the documents. The Court disagreed, recognizing that "computers are universally used and accepted, have become part of everyday life and work and are presumed reliable." Id. at 16, 678 A.2d 266. "There is no reason to believe that a computerized business record is not trustworthy unless the opposing party comes forward with some evidence to question its reliability." Id. at 18, 678 A.2d 266. The authenticity of the demand note contained in the record was never disputed and defendants admitted that monies were due on the loan. John Giangrossi, Summit's credit manager, certified that prior to the transfer of the note to Summit, GSB ran an accounting of the balance due. He provided computer printouts detailing the loan information, indicating a balance of $ 14,973.87 as of the last review on December 15, 1995, subsequent payments of $ 3899.78 made to GSB, leaving a balance forward of $ 11,074.09 as of July 12, 1996 when the loan was transferred to the new Summit Bank system, and an itemized list of the three payments made to Summit through the date of default. Not only is Giangrossi competent to lay a foundation for the records in that respect, but his position renders him "sufficiently familiar with the record system used" and enables him to "establish that it was the regular practice of Summit to make the record." Hahnemann, supra, at 18, 678 A.2d 266.