Taylor v. Maritime Overseas Corp
In Taylor v. Maritime Overseas Corp., 224 Va. 562, 565, 299 S.E.2d 340, 341 (1983), the Supreme Court of Virginia held that a Coast Guard "Boiler Inspection Book" was not admissible because it had not been properly authenticated by both the custodian and the person to whom the custodian reported.
In reaching its decision, the Court noted as follows:
Although each page of the proffered exhibit bore a stamp with the signature of a Coast Guard lieutenant certifying that the page was a "True Copy," nothing in the exhibit or the papers attached showed that this officer was the custodian of the disputed records.
And, while the exhibit was accompanied by a letter of transmittal signed by "T. Wood, Captain, U.S. Coast Guard, Officer in Charge, Marine Inspection," nothing even suggested that Captain Wood was the person to whom the custodian reported. Id. at 565, 299 S.E.2d at 342.