Angel Business Catalysts v. Bank of the Ozarks

CourtCourt of Appeals of Georgia
DecidedJune 15, 2012
DocketA12A0343
StatusPublished

This text of Angel Business Catalysts v. Bank of the Ozarks (Angel Business Catalysts v. Bank of the Ozarks) is published on Counsel Stack Legal Research, covering Court of Appeals of Georgia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Angel Business Catalysts v. Bank of the Ozarks, (Ga. Ct. App. 2012).

Opinion

THIRD DIVISION MIKELL, P. J., MILLER and BLACKWELL, JJ.

NOTICE: Motions for reconsideration must be physically received in our clerk’s office within ten days of the date of decision to be deemed timely filed. (Court of Appeals Rule 4 (b) and Rule 37 (b), February 21, 2008) http://www.gaappeals.us/rules/

June 15, 2012

In the Court of Appeals of Georgia A12A0343. ANGEL BUSINESS CATALYSTS, LLC et al. v. BANK OF THE OZARKS.

MILLER, Judge.

Bank of the Ozarks (the “Bank”), as successor to the original lender, pursued

an action to recover the outstanding balance on a promissory note guaranteed by

Charles Merrill, III, Lee D. Gaskins, III, and Eric Fitchner (the “Guarantors”).1 The

Bank moved for summary judgment, which the trial court granted. On appeal, the

Guarantors contend that the trial court erred in granting the Bank’s motion for

summary judgment because the Bank failed to show that a supporting affidavit and

the attached documents were admissible as business records, and that the attached

1 The complaint also named as a defendant Angel Business Catalysts, LLC, which had executed the underlying note. The Bank received a default judgment against Angel Business Catalysts. The Guarantors do not challenge the entry of the default judgment against Angel Business Catalysts. documents did not establish the amounts they owed. For the reasons set forth below,

we affirm.

“Summary judgment is proper when there is no genuine issue of material fact

and the movant is entitled to judgment as a matter of law. We review the grant of

summary judgment de novo, construing the evidence in favor of the nonmovant. “

(Citation and punctuation omitted.) Kensington Partners v. Beal Bank Nevada, 311

Ga. App. 196 (715 SE2d 491) (2011).

So viewed, the evidence shows that on October 4, 2006, Angel Business

Catalysts executed a promissory note in favor of Unity National Bank (“Unity”), in

the principal sum of $440,943. The Guarantors executed individual guarantees of the

note. In March 2010, after Angel Business Catalysts failed to meet its repayment

obligations under the note, Unity filed suit against Angel Business Catalysts and the

Guarantors to recover the outstanding balance on the note. Unity was subsequently

closed, and the Federal Deposit Insurance Corporation (“FDIC”) was appointed as

receiver for Unity.

Through a purchase agreement, FDIC assigned its interest in the note, the

individual guarantees, and other related loan agreements to the Bank. The Bank was

subsequently substituted as the party plaintiff. Thereafter, the Bank moved for

2 summary judgment. In support of its summary judgment motion, the Bank submitted

the affidavit of its special assets manager, which set forth the parties’ contracts, debt

obligations, and amounts due. Following a hearing, the trial court granted the Bank’s

motion.

1. The Guarantors contend that the trial court erred in granting the Bank’s

motion for summary judgment because the Bank failed to show that the affidavit and

the attached documents were admissible as business records . We disagree.

Creating an exception to the hearsay rule, the Business Records Act provides: Any writing or record . . . made as a memorandum or record of any act, transaction, occurrence, or event shall be admissible in evidence in proof of the act, transaction, occurrence, or event, if the trial judge shall find that it was made in the regular course of any business and that it was the regular course of such business to make the memorandum or record at the time of the act, transaction, occurrence, or event or within a reasonable time thereafter.

(Punctuation omitted.) OCGA § 24-3-14 (b).

However, before such a writing or record is admissible, a foundation must be laid through the testimony of a witness who is familiar with the method of keeping records and who can testify thereto and to facts which show that the entry was made in the regular course of a business at the time of the event or within a reasonable time thereafter.

3 (Footnote omitted.) Ishak v. First Flag Bank, 283 Ga. App. 517, 519 (642 SE2d 143)

(2007). “A trial court’s decision to admit evidence as an exception to the hearsay rule

will not be disturbed absent an abuse of discretion.” (Footnote omitted.) Id.

Here, the Bank’s special assets manager, who previously held the same position

for Unity, averred that he was the custodian of records for the Bank; that the business

records relating to the note were transferred and delivered to the Bank from the FDIC

as the receiver for Unity; that these documents included the original note and

individual guaranties; that the records were obtained in the regular course of business;

and that the Bank relied upon information provided by the FDIC regarding the

payment history of the note. Although the Guarantors claimed that any documents

transferred to the Bank were inadmissible since the special assets manager failed to

state that he had personal knowledge as to how the documents were prepared and

maintained by Unity,2 “where routine, factual documents made by one business are

2 Contrary to the Guarantors’ claim, this Court’s decision in Arrow Financial Svcs.v. Wright, 311 Ga. App. 319 (715 SE2d 725) (2011), does not squarely support their argument that the Bank’s affidavit was inadmissible since the affiant did not state that he had personal knowledge of the manner in which Unity’s documents were created. In Arrow, the trial court found that the witness did not have the requisite personal knowledge to authorize admission of documents sent from the original lender to the assignee regarding the debt’s origins. Arrow, supra, 311 Ga. App. at 319-320. Although the assignee appealed the trial court’s ruling, this Court did not reach the issue of whether the trial court erred by excluding the documents as

4 transmitted and delivered to a second business and there entered in the regular course

of business of the receiving business, such documents are admissible under OCGA

§ 24-3-14 (b).” (Footnote and punctuation omitted.) Boyd v. Calvary Portfolio Svcs.,

285 Ga. App. 390, 391 (1) (646 SE2d 496) (2007). Interpreting and applying OCGA

§ 24-3-14 (b) liberally,3 we hold that the Bank established that the affidavit and

attached exhibits were admissible as business records. See id. at 391-392 (1)

(business documents attached to affidavit, which stated that the business acquired

documents through purchase in regular course of its business, were admissible);

Walter R. Thomas Assoc. v. Media Dynamite, 284 Ga. App. 413, 416 (1) (a) (643

SE2d 883) (2007) (invoices sent to company can be considered the company’s

business record if kept in the ordinary course of business, notwithstanding absence

of testimony from a representative who prepared the invoice, since the company’s

president testimony was sufficient to lay foundation). Consequently, the trial court

did not abuse its discretion in admitting these documents pursuant to the Business

Records Act.

business records. Id. at 322 (1). 3 “[T]he General Assembly has instructed that the Business Records Act ‘shall be liberally interpreted and applied.’” (Footnote and punctuation omitted.) Ishak, supra, 283 Ga. App. at 519; see also OCGA § 24-3-14 (d).

5 2. The Guarantors next contend that the documents attached to the affidavit did

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Boyd v. Calvary Portfolio Services, Inc.
646 S.E.2d 496 (Court of Appeals of Georgia, 2007)
Wickes Lumber v. Energy Efficient Homes, Inc.
277 S.E.2d 298 (Court of Appeals of Georgia, 1981)
Walter R. Thomas Associates, Inc. v. Media Dynamite, Inc.
643 S.E.2d 883 (Court of Appeals of Georgia, 2007)
Gerben v. BENEFICIAL GEORGIA, INC.
642 S.E.2d 405 (Court of Appeals of Georgia, 2007)
Kensington Partners, LLC v. Beal Bank Nevada
715 S.E.2d 491 (Court of Appeals of Georgia, 2011)
ARROW FINANCIAL SERVICES, LLC v. Wright
715 S.E.2d 725 (Court of Appeals of Georgia, 2011)
Melman v. FIA Card Services, N.A.
718 S.E.2d 107 (Court of Appeals of Georgia, 2011)
Ishak v. First Flag Bank
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Angel Business Catalysts v. Bank of the Ozarks, Counsel Stack Legal Research, https://law.counselstack.com/opinion/angel-business-catalysts-v-bank-of-the-ozarks-gactapp-2012.