Paul D’Agnese appealed a deficiency judgment awarded to Wells Fargo after a loan to his company. He did not contest liability but argued that the bank had not supplied competent evidence of the amount of damages. The Court of Appeals of Georgia affirmed the judgment on liability and reversed the damages award. The bank’s only damages evidence was a screen capture, and the court held that the bank had not shown that the underlying records were so voluminous that they could not conveniently be examined in court, a necessary condition for using a summary under the evidence rules. The trial court therefore abused its discretion by considering the screen capture as proof of damages. The case was remanded for further proceedings; the court left open the possibility that the damages could later be established by admissible evidence.