State v. Petzoldt

In State v. Petzoldt, 172 Ariz. 272, 275, 836 P.2d 982, 985 (App. 1991), the Court accepted business records with "ample testimony by the foundation witness that records were entered contemporaneously by scriveners with first-hand knowledge." The Court addressed the claim that a scrivener must be identified for the information to be reliable, stating: "'There is no requirement that the person whose first-hand knowledge was the basis of the entry be identified, so long as it was the business entity's regular practice to get information from such a person.'" Id.