A witness may read into the record from the contents of a document that has been admitted into evidence, but, if the document has not been admitted into evidence, the witness's description of the document is inadmissible hearsay. It is the business record itself, not the foundational affidavit, that serves as proof of the matter asserted.
Christiana Trust v. Corbin, NY Slip Op 04298 (2d Dep't August 16, 2023)
