Smoot v. Smoot

1 Citing case

  1. Braggs v. Dunn

    CIVIL ACTION NO 2:14cv601-MHT (WO) (M.D. Ala. Feb. 17, 2017)   Cited 2 times

    Defendants were not required to disclose the HSAs in order to submit their declarations for the sole purpose of authenticating records. See Smoot v. Smoot, No. CV 213-040, 2015 WL 2340822, at *6 (S.D. Ga. Mar. 31, 2015) (Wood, C.J.) (holding affidavits admissible in spite of nondisclosure of affiants because they were only used to authenticate documents at issue in the case). Furthermore, the HSAs and the general subjects of their knowledge were sufficiently disclosed to plaintiffs in the course of discovery, and, to the extent they were not, the failure was harmless.