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A hospital sues an insurer for unpaid claims. The hospital offers a chart summarizing 12,000 claim records and made the underlying electronic records available to the insurer for two months before trial. The insurer objects that the best evidence rule requires each claim record to be introduced individually.
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A summary of writings is admissible only in bench trials. A summary of writings is admissible only if the opposing party prepared it. A summary of writings is admissible only if every underlying document is separately read to the jury. The proponent may use a summary, chart, or calculation to prove the contents of voluminous writings that cannot be conveniently examined in court, if the originals or duplicates are made available for examination or copying at a reasonable time and place.

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