Defendants also assert that the Court should ignore Brooks's affidavit testimony regarding certain account balances allegedly owed to NMAC by Mr. Doll and several of his companies under promissory notes and related guaranties, as well as amounts due to NMAC for certain contractor expenses. Citing Taquechel v. Chattahoochee Bank, 260 Ga. 755, 756, 400 S.E.2d 8, 9 (1991), Defendants argue that the affidavit is insufficient because NMAC failed to attach "account statements" to the affidavit. Defs.' Resp. to Pl.'s Mot. for Summ. J. 4, ECF No. 58. Even if Taquechel were applicable to this federal evidentiary issue, it does not stand for the proposition that "account statements" must be attached in support of an affidavit regarding outstanding loan balances. It stands for the proposition that an affidavit is insufficient if records relied on and referred to in the affidavit are not attached to the affidavit or included in the record.

"Where records relied upon and referred to in an affidavit are neither attached to the affidavit nor included in the record and clearly identified in the affidavit, the affidavit is insufficient." Taquechel v. Chattahoochee Bank , 260 Ga. 755, 756 (2), 400 S.E.2d 8 (1991) (citation and punctuation omitted). "Since the records were not attached to the [expert's] affidavit or otherwise identified by their location in the evidence admitted of record, the references to these records cannot be used to contest the summary judgment motion."

Likewise, "[w]here records relied upon and referred to in an affidavit are neither attached to the affidavit nor included in the record and clearly identified in the affidavit, the affidavit is insufficient. [Cit.]" Taquechel v. The Chattahoochee Bank, 260 Ga. 755, 756 (2) ( 400 SE2d 8) (1991). Here, however, the Mastro affidavit relates to Cox's default on the loan owed to U.S. Markets, a fact of which Mastro as general manager of the company would have personal knowledge.

Dreger's affidavit, which identified the complete file of the department, was sufficient. Taquechel v. Chattahoochee Bank, 260 Ga. 755, 756 (2) ( 400 S.E.2d 8) (1991) (citations and punctuation omitted); Pratt v. Tri City Hosp. Authority, 193 Ga. App. 473, 474 ( 388 S.E.2d 69) (1989); see generally OCGA § 9-11-56 (e) ("[s]worn or certified copies of all papers or parts thereof referred to in an affidavit shall be attached thereto or served therewith"). Nevertheless, the claim fails for want of proximate cause.

The promissory note became in default by its terms when Pruett and Groover failed to pay the defaulted real estate note under their personal guarantees. Appellants claim that two affidavits supporting summary judgment which were relied upon to establish the amounts due on the notes were insufficient because no bank records were attached. See Taquechel v. Chattahoochee Bank, 260 Ga. 755 ( 400 S.E.2d 8) (1991) (affidavit which relied upon and referred to bank records was insufficient to support summary judgment where the records were not attached to the affidavit). The affidavits here do not refer to or rely upon bank or other records. Rather, they show that the affiant is personally familiar with both notes, the repayment history, default, and amounts due. Since this testimony was based on personal knowledge of the facts, it was sufficient, without attachment of records from which the facts may have been generated, to establish a prima facie case in support of summary judgment.