In GT & MC, Inc. v. Tex. City Ref., Inc., 822 S.W.2d 252 (Tex. App.-Houston 1st Dist. 1991, writ denied), the witness proving up the business records exception testified that the third-party documents were marked and processed by the receiving business, including indicating the date of receipt, the identity of the recipient, whether the invoices were approved for payment, and who approved the payment.
The Court held the evidence was sufficient to show the records had been made by the receiving business, despite the fact that the documents were initially created by a third party. Id.