This section contains the nature of the case and procedural background.

The Duncans (D) and others purchased numerous hospitalization insurance policies, and on several occasions sought hospitalization for injuries which never occurred or after staged accidents. D appeal their convictions, arguing that the trial court erroneously admitted the insurance companies' records because, among other things, they were improperly authenticated. Although the records were introduced through the testimony of the insurance companies' employees, D argues that the records contained unauthenticated medical records and hearsay statements by doctors; thus the reports should not have been admitted.

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