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DRAFT FOR ATTORNEY REVIEW — NOT FINAL

Egleston Physical Therapy, Inc. v. Progressive Direct Ins. Co., 123 N.E.3d 801 (2019)

Citation
Egleston Physical Therapy, Inc. v. Progressive Direct Ins. Co., 123 N.E.3d 801 (2019)
Parent Document
Egleston Physical Therapy, Inc. v. Progressive Direct Ins. Co., 123 N.E.3d 801 (2019)
Jurisdiction
Massachusetts (state)
Effective Date
2019-02-13

Full Text

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Egleston contends, however, that the evidence was insufficient to establish that Gelibert had notice of the scheduled EUOs since the notices went to Malloy and not to Gelibert. Recognizing that notice to Gelibert's attorney was notice to her, see Flynn v. Wallace, 359 Mass 711, 717 (1971), Egleston further contends that Molloy's letter of representation was hearsay and therefore insufficient to establish that Molloy was, in fact, Gelibert's attorney. Contrary to Egleston's claim, Molloy's letter of representation was properly admitted in evidence under the business records exception to the hearsay rule. See Beal Bank, SSB v. Eurich, 444 Mass. 813, 815 (2005) ("a document is admissible as a business record if ... it was (1) made in good faith; (2) made in the regular course of business; (3) made before the action began; and (4) the regular course of business to make the record at or about the time of the transaction or occurrences recorded").