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Defendant offers payroll records with a signed certification from the company's records custodian reciting the elements of the business-record foundation. Defendant gave Plaintiff written notice and a copy of the records before trial. Plaintiff objects that the custodian must appear live to authenticate the records.
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Business records are self-authenticating only if notarized by the opposing party. Certified domestic records of a regularly conducted activity can be self-authenticating if accompanied by a proper certification and reasonable written notice to the adverse party before trial. Business records are never self-authenticating. Business records are self-authenticating without any certification or notice.

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