CitiMortgage, Inc. v McKinney, 2016 NY Slip Op 08037 (2d Dept. 2016)
“Stringer further asserted that she was personally familiar with the plaintiff’s record-keeping practices and procedures, the records were made in the regular course of business, it was the regular course of the plaintiff’s business to make them, and the records were made at or near the time of the occurrence of the matters set forth in the records. This was sufficient to establish, prima facie, that the plaintiff was the holder of the note at the time the action was commenced (see CPLR 4518[a];”
Business records play a much less prominent role nowadays in our realm of practice.
