Jenzack Partners, LLC v. Stoneridge Associates, LLC
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The Supreme Court reversed in part the judgment of the Appellate Court reversing the judgment of the trial court ordering strict foreclosure, holding that the Appellate Court erred in concluding that an initial entry into a record of debt was not admissible under the business records exception to the hearsay rule when that entry was provided by a third party in the course of the sale of the debt.
Specifically, the Court held that the Appellate Court (1) did not err in concluding that Jenzack Partners, LLC (Jenzack) had standing to foreclose a mortgage executed in support of a personal guarantee of a promissory note given by a third party even though the guarantee was not explicitly assigned to the foreclosing party; and (2) erred in determining that the business records exception did not apply to Jenzack's calculation of the debt owed on the promissory note where the initial entry into the record of the debt was provided by a third party.
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