In order for hospital records to be qualified for admission into evidence under Ares v. Venner, the court must be satisfied: (a) that the entry or record was made contemporaneously with the events then being recorded; (b) that the maker of the record had personal knowledge of the matters being recorded; (c) that the maker was under a duty to make the entry or record; and (d) that the maker of the record has been identified and is available to be called as a witness.
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