Can a massage therapist be found to have bias in their records?

The exception to the hearsay rule set out in Ares v. Venner varies from the business record provisions of s. 42 of the Evidence Act in that the recorder must be ". . . under a duty to make the entry or record . . .". Without having to decide whether the entries made in the records of a massage therapist can be brought within the principles laid out in Ares v. Venner, I am satisfied that there is no evidence upon which I could conclude that the records were kept by the massage therapist in the usual or ordinary course of her business, that the entries were recorded contemporaneously or within a reasonable time thereafter, that the statements were made by the plaintiff to the massage therapist at a time when it could be said that they were made without bias ". . . on account of the existence of a dispute or litigation which the declarant might be supposed to favour" or that the evidence was difficult to obtain otherwise.