A person's handwriting may be authenticated by a lay witness -- i.e., a lay witness may identify the author of handwriting -- if the witness is personally familiar with the putative author's handwriting and the witness did not acquire such familiarity for purposes of the litigation.

McMorrow v. Schweiker, 561 F. Supp. 584, 589 (D.N.J. 1982) (holding, in plaintiff's claim for widow's insurance benefits, that the Secretary properly denied the claim because "[n]one of the forms of preferred evidence....Federal Rule of Evidence 803(13) creates a hearsay exception for statements of fact concerning personal or family history contained in family Bibles, genealogies, charts, engravings on rings, inscriptions on family portraits, engravings on urns, crypts, or tombstones, or the like.

Fed. R. Evid. 104(b) ("When the relevancy of evidence depends upon the fulfillment of a condition of fact, the court shall admit it upon, or subject to, the introduction of evidence sufficient to support a finding of the fulfillment of the condition.").The evidence for a condition upon which the relevance of evidence depends must be sufficient to support a finding by the trier of fact that the condition exists.

United States v. Goodchild, 25 F.3d 55, 61-62 (1st Cir. 1994) (upholding trial court's admission into evidence of the telephone statement memos as business records because "[the statement memos met] the strictures of the....The hearsay exception for "business records" created by Federal Rule of Evidence 803(6) or a comparable State rule applies only (i) the record is based on the personal knowledge of an entrant with a business duty to record the event or other such matter or (ii) if the record of the event is based on the personal knowledge of a person who had a business duty to transmit the information about the event or other matter to the person or persons who made the record and had a business duty to do so. A person has a "business duty" if the person has a duty to an organization by reason of law, contract, employment relationship, or other such matter to record or report an event, condition, opinion, or other matter to which the business records exception to the hearsay rule may apply.