Bank of New York Mellon v. Roulston

Citations

• 2017 Ohio 8400

Syllabus

Summary judgment foreclosure authentication of business records. The court erred by granting summary judgment to the holder of a note and mortgage, because the plaintiff was not qualified to testify as a witness regarding another company's previous loan servicing documents. The witness was qualified to authenticate documents created by the loan servicing company for whom she worked and the bank whose loans she serviced. However, her affidavit failed to aver that she had personal knowledge or familiarity of the record-keeping system that the previous loan serving company used.