Jazayeri v. Mao

In this action brought by appellants for breach of contract and fraud, the trial court excluded the bulk of appellants? documentary evidence on grounds of lack of authentication and hearsay. Concluding that appellants had failed to meet their burden of proof, the court then entered judgment for respondents. We conclude that the blanket exclusion was error, and that much of the evidence offered was adequately authenticated and was not subject to any legitimate hearsay objection. As set forth in greater detail below, certain documents qualified for admission as official records under Evidence Code section 1280, others as business records under Evidence Code section 1271, and still others as admissions under Evidence Code section 1220 or adoptive admissions under Evidence Code section 1221.