American Express Travel Related Services Co. v. Vinhnee (In Re Vinhnee)

OPINION

KLEIN, Bankruptcy Judge.

This appeal involves the elements of the evidentiary foundation for introducing electronic business records and whether a trial court is entitled to insist upon a complete foundation, even in the absence of an objection.

The court declined to admit plaintiffs computerized business records as inadequately authenticated at a bench trial, but gave plaintiff a chance to cure the foundational defects in a post-trial submission. When the ensuing submission proved unsatisfactory to the court, it entered judgment for defendant and added salt to the wound by noting that…