Must transcripts of audio recordings be authenticated?

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.

United States v. Johnson, 297 F.3d 845, 862-864 (9th Cir. 2002) (upholding trial court's admission of the tapes and sales orders as business records because "AEA employees, acting in the ordinary course of business, were....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.

United States v. Johnson, 439 F.3d 947, 953 (8th Cir. 2006) (upholding trial court's admission of witness's testimony about his past crack cocaine dealings with the accused which was offered to show accused's knowledge, intent, or absence of mistake, where his past drug dealings were (1) "relevant to the...Evidence of a criminal or wrongful act apart from the act that at issue at trial Is not barred by the prohibition against circumstantial use of character if intent, knowledge, mistake, or accident is a legally-material factual issue, the opposing party suggests the non-existence of knowledge or urges mistake or accident as a defense, and evidence of another crime, wrong, or act is offered to prove the knowledge or the absence of mistake or accident by a criminal defendant or other person.