In Duncan Dev., Inc., v. Haney, 634 S.W.2d 811, 812-13 (Tex. 1982) the records at issue were invoices submitted to Duncan from its subcontractors.
The Texas supreme court held that the invoices were admissible as Duncan's records because "Duncan utilized a reliable method of confirming the accuracy of the submitted invoices through its site supervisors who had personal knowledge of activities at its construction sites." Id. at 813.