Tbe motion must be supported by an affidavit by a person having knowledge of the facts, pursuant to CPLR § 3212[b]. An affidavit that is not based on the affiant's personal knowledge may serve to authenticate a document for its admissibility as a business record, as long as the affiant demonstrates sufficient personal knowledge of the document in question, and the affidavit sufficiently establishes that the document falls within the business record exception to the hearsay rule.
Muslar v. Hall, NY Slip Op 01063 (1st Dep't February 28, 2023)