O.C.G.A.
O.C.G.A.

O.C.G.A. § 24-10-1006 (2019)

Summaries

✓ O.C.G.A. — 2019 edition (Public.Resource.Org Release 73)
Code text and O.C.G.A. statutory annotations on this page reflect the 2019 Official Code of Georgia Annotated (Public.Resource.Org Release 73, 2019-08-21; public domain per Georgia v. Public.Resource.Org, 2020). The Syfert case-law annotations in Notes of Decisions, below, are current.
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The contents of otherwise admissible voluminous writings, recordings, or photographs which cannot conveniently be examined in court may be presented in the form of a chart, summary, or calculation. The originals, or duplicates, shall be made available for examination or copying, or both, by other parties at a reasonable time and place. The court may order that the contents of such writings, recordings, or photographs be produced in court.

History

Code 1981, § 24-10-1006, enacted by Ga. L. 2011, p. 99, § 2/HB 24.

Annotations

Cross references. Summaries to prove content, Fed. R. Evid. 1006.

JUDICIAL DECISIONS Editor’s notes. - In light of the similarity of the statutory provisions, decisions under former Code 1933, §§ 38-203, 38-205, and former O.C.G.A. § 24-5-29 are included in the annotations for this Code section. Summary of accounting book entries. - When pertinent and essential facts can be ascertained only by an examination of a large number of entries in books of account, an auditor or an expert accountant who has made an examination and analysis of the books and figures may testify as a witness and give summarized statements of what the books show as a result of the investigation, provided the

books themselves are accessible to the court and the parties. Jackson v. Meadows, 157 Ga. App. 569, 278 S.E.2d 8, 1981 Ga. App. LEXIS 1917 (1981). For a discussion of the admissibility of summaries of business records, see Tyner v. Sheriff, 164 Ga. App. 360, 297 S.E.2d 114, 1982 Ga. App. LEXIS 2801 (1982) (decided under former O.C.G.A. § 24-5-29). Loan history report properly admitted. - Trial court properly admitted the bank’s loan history report as a business record because the report provided a description of each transaction relating to the estate’s loan from the loan’s inception,

along with a corresponding posting date for each transaction, the transaction amount, and any change to the principal balance resulting from the transaction, and was not a summary. Roberts v. Cmty. & S. Bank, 331 Ga. App. 364, 771 S.E.2d 68, 2015 Ga. App. LEXIS 149 (2015). Bank’s computer screen shot insufficient proof of damages in loan case. - In an action on a loan, a bank did not submit sufficient evidence to prove the

bank’s damages because a printout of the bank’s electronic records reflecting the amounts then owed, without a detailed transaction history, was a summary requiring evidence that the underlying records were too voluminous to examine in court pursuant to O.C.G.A. § 24-10-1006, not a business record under O.C.G.A. § 24-8-803(6). D’Agnese v. Wells Fargo Bank, N.A., 335 Ga. App. 659, 782 S.E.2d 714, 2016 Ga. App. LEXIS 58 (2016).

RESEARCH REFERENCES ALR. Requirement of notice as condition for

admission in evidence of summary of voluminous records, 80 A.L.R.3d 405.

Notes of Decisions
Cited in 10 cases (2 in the last 5 years), 2015–2024 · leading case: Tafel v. Lion Antique Cars & Investments, Inc.; & Vice Versa, 773 S.E.2d 743 (Ga. 2015).
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Tafel v. Lion Antique Cars & Investments, Inc.; & Vice Versa, 773 S.E.2d 743 (Ga. 2015). · cites it 8× “The trial court excluded this summary from evidence, 2 and Tafel contends that this was error, saying that the summary was admissible under OCGA § 24-10-1006 of our new Evidence Code.”
Roberts v. Cmty. & S. Bank, 771 S.E.2d 68 (Ga. Ct. App. 2015). · cites it 4× “OCGA § 24-10-1006 provides in relevant part: The contents of otherwise admissible voluminous writings, recordings, or photographs which cannot conveniently *370 be examined in court may be presented in the form of a chart, summary, or calculation.”
D’agnese v. Wells Fargo Bank, N.A., 782 S.E.2d 714 (Ga. Ct. App. 2016). · cites it 7× “; OCGA § 24-10-1006. Wells Fargo argues that the screen shot is a “data compilation,” one of the types of documents specifically included within Georgia’s business records exception to the hearsay rule.”
Lyman Et Al. v. Cellchem Int'l, LLC, 779 S.E.2d 474 (Ga. Ct. App. 2015). · cites it 2× “See OCGA § 24-10-1006. Compare Lawhorn v. State, 200 Ga.”
Tafel v. Lion Antique Cars & Investments, Inc., A/K/A Lion Antique Investments & Consulting Servs., Inc. (Ga. 2015). · cites it 6× “The trial court excluded this summary from evidence,2 and Tafel contends that this was error, saying that the summary was admissible under OCGA § 24-10-1006 of our new Evidence Code.”
Costa Et Al. v. Hamilton State Bank, 802 S.E.2d 80 (Ga. Ct. App. 2017). · cites it 2× “See OCGA § 24-10-1006 (“The contents of otherwise admissible voluminous writings, recordings, or photographs which cannot conveniently be examined in court may be presented in the form of a chart, summary, or calculation.”
Christian Sherritt v. Sb Paulding Commons, LLC (Ga. Ct. App. 2024). · cites it 2× “OCGA § 24-10-1006; see also Roberts v. Community & Southern Bank, 331 Ga.”
Laterrell Marique Alexander v. State (Ga. Ct. App. 2024). · cites it 2× “Nor did the State argue, pursuant to OCGA § 24-10-1006, that the line sheets were not closely related to a controlling 9 issue, or that the summaries were necessary because the original audio recordings, covering 47 days, were voluminous.”
Oscar Roberts III v. Cmty. & S. Bank (Ga. Ct. App. 2015). · cites it 2× “OCGA § 24-10-1006 provides in relevant part: The contents of otherwise admissible voluminous writings, recordings, or photographs which cannot conveniently be examined in court may be presented in the form of a chart, summary, or calculation.”
Dale E. Lyman v. Cellchem Int'l, LLC (Ga. Ct. App. 2015). · cites it 2× “See OCGA § 24-10-1006. Compare Lawhorn v. State, 200 Ga.”
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