Hodges, Judge. In this latest chapter of an ongoing dispute between a taxpayer and DeKalb County government, Edward Williams challenges the manner in which the DeKalb County Board of Commissioners introduced and passed a 2018 salary increase in alleged violation of the Open Meetings Act. See OCGA § 50-14-1 et seq. Following a prior appearance in, and remand to the trial court from, the Supreme Court of Georgia, see Williams v. DeKalb County, 308 Ga. 265 (840 SE2d 423) (2020) (“Williams I“), Williams filed a third amended complaint and now appeals an order from the Superior Court of DeKalb County granting DeKalb County CEO Michael Thurmond’s motion to dismiss that amended complaint and granting a motion for judgment on the pleadings filed by present and former DeKalb County commissioners (“the commissioners”).[1] Williams argues that the trial court erred in: (1) concluding that he lacked taxpayer standing to pursue claims against Thurmond; (2) finding that official and legislative immunity barred his claims under the Open Meetings Act against the commissioners in their individual capacities; and (3) failing to conduct an in camera review of certain e-mails between the commissioners and the DeKalb County attorney. For the following reasons, we affirm the trial court’s judgment in part, vacate the judgment in part, and remand this case for further proceedings consistent with this opinion. Factual Background. In Williams I, the Supreme Court recited the following facts: At about 2:00 p.m. on January 18, 2018, the DeKalb County Board of Commissioners announced that it would hold a “special call” meeting at 9:00 a.m. the following morning. The printed meeting agenda did not include a proposed pay increase for the commissioners or the Chief Executive Officer, but the commissioners discussed the desire for a pay increase at the meeting. The meeting minutes did not record the discussion, nor did they record any vote to take official action based on the discussion. The minutes also did not reflect the reason for calling the meeting on less than 24 hours’ notice. About a week later, in an email exchange with the subject line “Salary Meeting FollowUp,” the Board’s presiding officer asked the Board’s attorney to contact the Champion Newspaper, the legal organ of the county, and place an advertisement giving statutorily required notice of the intent to increase the salaries of the governing authority. The Board’s attorney arranged for the notice to be published on three consecutive Mondays, February 8, 15, and 22, 2018, giving notice of the County’s intent to increase the salary and other compensation of the governing authority at the regular meeting of the Board to be held on February 27, 2018, with the fiscal impact of the change estimated to be approximately $229,660.22 per year. The agenda published for the February 27 meeting, however, did not list the proposed salary ordinance or otherwise mention increasing the Chief Executive Officer’s or commissioners’ pay. Well into the February 27 meeting, a commissioner moved to add the proposed salary increase to the agenda as a “walkon” resolution, and the commissioners voted unanimously to add the salary ordinance to the agenda. The fiscal impact statement for the ordinance reflected that the Chief Executive Officer’s pay would be set at 90 percent of a DeKalb County superior court judge’s total compensation, and that the commissioners’ base salary would increase from $40,530.55 to $65,000, effective January 2, 2019. Six commissioners voted in favor of the resolution, and one voted against it. (Footnote omitted.) 308 Ga. at 267-268 (1). Williams’ Claims and the Prior Appeal. In general,[2] Williams argued that the commissioners violated the Open Meetings Act by failing to provide proper notice of their intent to pass a salary ordinance increasing their pay. Williams I, 308 Ga. at 268 (1). As a result, Williams filed a complaint against Thurmond and the commissioners seeking mandamus relief, declaratory judgment concerning the alleged illegality of the commissioners’ actions, injunctive relief to prevent payment of the increased salaries, civil and criminal penalties under the Open Meetings Act, and litigation expenses and attorney fees. Id. The trial court denied Williams’ mandamus petition, dismissed Williams’ claims for declaratory judgment and injunctive relief against Thurmond and the commissioners because he lacked standing as a citizen or taxpayer, and dismissed his cause of action for civil penalties against the defendants in their individual capacities for violations of the Open Meetings Act for failure to state a claim. Id. at 266. On appeal, our Supreme Court affirmed the dismissal of Williams’ causes of action for declaratory relief against Thurmond and the commissioners and injunctive relief against the commissioners because, as to the declaratory judgment claim, Williams alleged no uncertainty with regard to his future conduct, and because he lacked citizen or taxpayer standing to support his request for injunctive relief. Williams I, 308 Ga. at 270-274 (3). The Supreme Court also vacated the dismissal of the claim for injunctive relief against Thurmond and remanded the case to the trial court to properly analyze whether Williams had standing to raise such a claim. Id. at 274 (3) (b) (ii). Finally, the Supreme Court reversed the dismissal of Williams’ claim for civil penalties against the commissioners in their individual capacity for violations of the Open Meetings Act upon finding that Williams, as a private person, had standing to enforce the civil penalty provisions of that act; that the allegations of Williams’ complaint raised a claim for violation of the Open Meetings Act for which official immunity would not require dismissal; and that the commissioners were not entitled to legislative immunity. Id. at 274-279 (4). Current Claims and the Present Appeal. On remand, Thurmond and the commissioners filed a joint motion to dismiss Williams’ claims for lack of subject matter jurisdiction due to lack of standing. The defendants included with their motion three affidavits that primarily outlined the circumstances requiring addition of the salary legislation as a “walk-on” agenda item on short notice: generally, the affiants averred that the commissioners did not expect to add the ordinance to the February 20 agenda because a bill to raise the commissioners’ salaries was progressing in the General Assembly. The legislation stalled, however, and when the commissioners learned that the bill would not receive a vote, they were forced to add the item to the February 27 agenda out of necessity in order to comply with guidelines requiring that salary ordinances must be passed before the beginning of the qualifying period for the next primary election — in this case, March 5, 2018. The affiants included: (1) Dan Baskerville, a senior policy director with Dentons, LLP, who provided “the DeKalb County Board of Commissioners with Weekly Legislative Updates, which include updates on meetings of interest including the meetings of the DeKalb County House and Senate Delegations, and updates and analysis on bills of potential impact and interest to DeKalb County[;]” (2) Dionne McKenzie, an administrative support manager for the DeKalb County Board of Commissioners, who testified that the commissioners approved an agenda for the February 27, 2018 regular meeting on February 20, 2018, but added the salary ordinance as a “ walk on” item during the February 27 meeting; and (3) Erica Hamilton, the director of the DeKalb County Department of Voter Registration and Elections, who testified that the earliest qualifying date for candidates in the May 22, 2018 primary election was March 5, 2018. In response, Williams filed a 90-page third amended complaint with over 2,000 pages of attachments in an attempt to bolster his causes of action. The commissioners filed responsive pleadings, to which they also attached the three supporting affidavits, and a motion for judgment on the pleadings. Relevant to this appeal, the trial court granted Thurmond’s motion to dismiss, finding that Williams did not have taxpayer standing to pursue injunctive relief against Thurmond because he did not: (1) demonstrate that he suffered any particularized harm (alleging only that he “lost trust and faith that they would be able to follow the law”); (2) show an unlawful expenditure of public funds; and (3) demonstrate an illegal act by Thurmond, as the salary ordinance passed and has not been declared unconstitutional. The trial court also granted the commissioners’ motion for judgment on the pleadings, finding that: (1) the Open Meetings Act had not been violated; and (2) official and legislative immunity shielded the commissioners from Williams’ suit. Finally, the trial court rejected Williams’ request for an in camera inspection of certain e-mails between the county attorney and various commissioners that had been redacted for attorney-client privilege, concluding that Williams had not alleged that the e-mails had not been validly redacted pursuant to privilege. The trial court denied Williams’ motion for reconsideration, and this appeal follows. At the outset, we note that the only claims remaining for adjudication[3] are Williams’ claims for injunctive relief against Thurmond, for civil penalties against the commissioners in their individual capacities for violations of the Open Meetings Act, and for an in camera inspection of certain e-mails between the county attorney and various commissioners (which was added as part of Williams’ third amended complaint). 1. Williams first contends that the trial court erred in finding that he lacked standing to enjoin Thurmond from issuing payments pursuant to the salary increase ordinance. In particular, Williams asserts that he sufficiently demonstrated taxpayer standing because he was not required to show a particularized injury. We find no error. Under Georgia law, [w]e apply a de novo standard of review to a trial court’s grant of a motion to dismiss. A motion to dismiss for failure to state a claim should not be sustained unless (1) the allegations of the complaint disclose with certainty that the claimant would not be entitled to relief under any state of provable facts asserted in support thereof; and (2) the movant establishes that the claimant could not possibly introduce evidence within the framework of the complaint sufficient to warrant a grant of the relief sought. (Citations omitted.) Stewart v. Johnson, 358 Ga. App. 813, 818 (4) (856 SE2d 401) (2021). In Williams I, the Supreme Court vacated the trial court’s order dismissing Williams’ claims for injunctive relief against Thurmond and remanded the case to the trial court with instruction that it first consider whether Williams had taxpayer standing to raise claims against Thurmond.[4] 308 Ga. at 274 (3) (b) (ii). The injunctive relief Williams now seeks is to enjoin Thurmond from enforcing the salary ordinance or from issuing salary payments authorized by the ordinance. In reaching its conclusion, the Supreme Court in Williams I observed that Williams broadly asserted in his complaint that Thurmond “has a clear legal duty to supervise, direct and control the administration of the county government” as well as to “execute and enforce all ordinances.” All of Williams’ specific allegations, however, relate to Thurmond’s role in the ordinance’s passage, primarily his alleged failure to sign or to veto the ordinance passed by the commissioners. In his complaint, Williams did not focus on Thurmond’s executive and administrative duties, and he made no specific allegations that those duties include the power to control the disbursement of funds paid as salaries once the ordinance had been enacted. 308 Ga. at 274 (3) (b) (ii). On remand, in partial response to the Supreme Court’s observations, Williams filed the third amended complaint in which he alleged that Thurmond performed official acts related to the disbursement of salaries to the commissioners, including allegations that Thurmond “controls the disbursement and expenditure of funds once the [salary ordinance] was adopted” and that the “DeKalb County director of finance is not permitted to disburse funds under the salary ordinance . . . without [Thurmond's] approval.” Nevertheless, the trial court concluded that Williams did not have taxpayer standing “because he has not shown any particularized harm;” instead, Williams’ only harm was a “lost trust and faith that they would be able to follow the law.” The trial court also found that Williams lacked taxpayer standing because he did “not put forward any facts that would show the unlawful expenditure of public funds” because the salary ordinance had not been declared unconstitutional and lawfully became effective eight days after its passage. (Emphasis in original.) As our Supreme Court has explained, “the question of standing is a jurisdictional issue.” (Citation and punctuation omitted.) Williams I, 308 Ga. at 271 (3). To that end, a citizentaxpayer has standing in equity to restrain public officers from performing acts which the law does not authorize. However, absent expenditures of public revenue or performance of a duty owed to the public, a citizentaxpayer has no standing in equity unless he or she has special damages not shared by the general public. (Citation and punctuation omitted.) Id. at 271 (3) (b). Williams’ lack of citizen standing was resolved in Williams I, see id. at 271 (3) (a), leaving only an inquiry into his taxpayer standing, for which Williams argues that he need not demonstrate any specific harm resulting from passage of the ordinance. This is incorrect. At first glance, there does not appear to be a universal “specific harm” component of taxpayer standing.[5] See generally Savage v. City of Atlanta, 242 Ga. 671, 671-672 (251 SE2d 268) (1978) (taxpayer had standing to request that the City of Atlanta’s commissioner of finance be enjoined from paying out public funds under the authority of certain ordinances); see also Williams I, 308 Ga. at 272-273 (3) (b) (ii) (“Under Georgia law, Williams’ status as a taxpayer generally affords him standing to seek to enjoin the unlawful expenditure of public funds.”); King v. Herron, 241 Ga. 5, 6 (1) (243 SE2d 36) (1978) (concluding that a “taxpayer of a municipality has standing to question the legality of the expenditure of public funds of the municipality”). However, there is at least some authority from our Supreme Court that such a requirement exists. See Morris v. City Council of Augusta, 201 Ga. 666, 669-670 (1) (40 SE2d 710) (1946) (“[t]his court has many times held that citizens and taxpayers of both counties and municipalities have such interest as will authorize them to maintain actions to enjoin the unlawful distribution of the public funds of counties and municipalities” where “the party suing as a taxpayer was in danger of injury through loss of public funds or property“) (emphasis supplied); see also Black Votes Matter Fund v. Kemp, 313 Ga. 375, 391, 395-396 (870 SE2d 430) (2022) (noting “lack of clarity” in taxpayer standing jurisprudence and discussing “a lessindividualized kind of injury as satisfying [taxpayer] standing requirement,” including that taxpayer standing requires “a showing of a kind of injury, even though that showing may be more relaxed than in other contexts”) (emphasis suppled) (Peterson, J., concurring). This conclusion is buttressed by Gaddy v. Ga. Dept. of Revenue, in which the Supreme Court noted during a discussion of taxpayer standing that “[a]s a general rule, a litigant has standing to challenge the constitutionality of a law only if the law has an adverse impact on that litigant’s own rights.” (Citation and punctuation omitted.) 301 Ga. 552, 555 (1) (a) (802 SE2d 225) (2017).[6] Therefore, our first inquiry must be whether Williams made “a showing of a kind of injury” or demonstrated a “danger of injury through loss of public funds or property.”[7] We conclude that he did not. In fact, the only showing of a purported injury by Williams is not itself actionable. During an April 14, 2021 hearing, the trial court pressed Williams for a description of how he had been harmed by “the Open Meetings record” and “as a result of the actions that they took with regard to the February 27th meeting[.]” Williams ultimately replied that he “ lost trust and faith that [the defendants] would be able to follow the law.” While these statements appear to apply mostly to Williams’ Open Meetings Act claims against the commissioners, rather than Thurmond’s enforcement of the salary ordinance for which Williams claims standing, Williams’ statements highlight the dearth of evidence of harm he suffered. As a result, we agree with the trial court’s conclusion that Williams did not have taxpayer standing “because he has not shown any particularized harm.”[8] See, e.g., Gaddy, 301 Ga. at 555 (1) (a); Morris, 201 Ga. at 670 (1); see also Black Votes Matter Fund, 313 Ga. at 395-396 (Peterson, J., concurring). Therefore, we find no error.[9] 2. Next, Williams argues that the trial court erred in granting the commissioners’ motion for judgment on the pleadings as to Williams’ Open Meetings Act violation claims. Resolving this issue requires that we address multiple distinct questions, including whether the trial court properly considered the affidavits attached to the commissioners’ answer to Williams’ third amended complaint as “written instruments,” see OCGA § 9-11-10 (c), in evaluating the commissioners’ motion for judgment on the pleadings; if it did not, whether the commissioners’ motion was properly converted to a motion for summary judgment; and, if so, whether the trial court correctly granted the motion. For the following reasons, we conclude that the affidavits are not “written instruments” and that, as a result, they represent matters outside the pleadings. Accordingly, the trial court converted the commissioners’ motion for judgment on the pleadings into a summary judgment motion, but failed to notify the parties of the conversion. On appeal, we review de novo the trial court’s decision on a motion for judgment on the pleadings to determine whether the undisputed facts appearing from the pleadings entitle the movant to judgment as a matter of law. The grant of a motion for judgment on the pleadings under OCGA § 91112 (c) is proper only where there is a complete failure to state a cause of action or defense. For purposes of the motion, all wellpleaded material allegations by the nonmovant are taken as true, and all denials by the movant are taken as false. But the trial court need not adopt a party’s legal conclusions based on these facts. (Citation and punctuation omitted; emphasis supplied.) City of Albany v. GA HY Imports, 348 Ga. App. 885, 887 (825 SE2d 385) (2019). Generally, Williams’ argument is based upon the commissioners’ publication of an agenda on February 20 that did not include the salary ordinance, followed by the commissioners’ addition of the ordinance to the agenda during the February 27 meeting as a “walk on” item out of necessity. OCGA § 50-14-1 (e) (1) provides that [p]rior to any meeting, the agency or committee holding such meeting shall make available an agenda of all matters expected to come before the agency or committee at such meeting. . . . Failure to include on the agenda an item which becomes necessary to address during the course of a meeting shall not preclude considering and acting upon such item. (Emphasis supplied.) In Williams I, the Supreme Court found that Williams’ complaint contains clear allegations that the commissioners expected to take up the proposed salary ordinance at the February 27, 2018 meeting; that the ordinance was intentionally omitted from the posted agenda; that the commissioners voted, while the meeting was in progress, to add the salary ordinance to the agenda as a “walkon item”; and that nothing had occurred after the matter was omitted from the agenda that made it necessary to take up the ordinance at that meeting. The complaint also alleges that the commissioners voted on the salary ordinance without public discussion or debate. Williams’ complaint, therefore, alleges a violation of the agenda requirements of OCGA § 50141 (e) (1). 308 Ga. at 277 (4) (b). As a result, the Supreme Court determined that Williams, as a private person, had standing to request that civil penalties be imposed against the commissioners, 308 Ga. at 276-277 (4) (a); that Williams’ complaint sufficiently alleged a violation of the agenda requirements of the Open Meetings Act and that civil penalties could be imposed against the commissioners, id. at 277-278 (4) (b); that Williams’ complaint sufficiently alleged actual malice in violating the Open Meetings Act to preclude official immunity as a ground for dismissing the complaint, id. at 278 (4) (c); and that the commissioners were not entitled to legislative immunity. Id. at 279 (4) (d). On remand, after Williams filed his third amended complaint, the commissioners filed an answer to which they attached the three affidavits, including exhibits, that largely explained the commissioners’ actions in approving the salary ordinance in an effort to demonstrate that there was no Open Meetings Act violation, claiming that the need to address the salary ordinance at the meeting was not evident when the agenda was published. As we have noted, the affidavits stated that the commissioners did not expect to add the salary ordinance to the February 20 agenda because a similar bill to raise the commissioners’ salaries was progressing in the General Assembly. When the commissioners learned that the bill would not receive a vote, however, they were forced to add the item to the February 27 agenda to comply with guidelines requiring that salary ordinances must be passed before March 5, 2018, the date the qualifying period for DeKalb County’s next primary election began. The commissioners also filed a motion for judgment on the pleadings, relying upon the affidavits attached to their answer and asserting that Williams’ Open Meetings Act violation claims should be dismissed because the commissioners did not violate the Act or act with actual malice or bad faith. The trial court agreed, concluding that the commissioners had alleged “additional facts” demonstrating that they did not violate the Open Meetings Act when they added the salary ordinance to the agenda for the February 27, 2018 meeting out of necessity, that official immunity shielded the commissioners because Williams did not suffer any injury or harm, that legislative immunity likewise protected the commissioners because Williams offered no showing of bad faith, and that Williams did not state a claim for an Open Meetings Act violation based upon the publication of legal advertisements in the county legal organ and the availability of meeting minutes. (a) Motion for Judgment on the Pleadings. In this appeal, Williams contends that the trial court erred in granting the commissioners’ motion for judgment on the pleadings because the Supreme Court has already found Williams’ argument sufficient to withstand the commissioners’ prior motion to dismiss and that neither official nor statutory immunity barred his claims. Williams’ position is based on the premise that, despite both parties filing amended pleadings on remand, the operative facts have not changed. In contrast, the commissioners point to new facts presented by the three affidavits, and argue that there was no Open Meetings Act violation because the addition of the ordinance to the agenda was proper,[10] and that both official and statutory immunity were available to them. (i) Law of the Case. It is well settled that “any ruling by the Supreme Court or the Court of Appeals in a case shall be binding in all subsequent proceedings in that case in the lower court and in the Supreme Court or the Court of Appeals as the case may be.” OCGA § 9-11-60 (h). In this case, Williams’ third amended complaint did not alter his allegations against the commissioners, which our Supreme Court has already reviewed and concluded that it “alleges a violation of the agenda requirements of OCGA § 50141 (e) (1).” Williams I, 308 Ga. at 277 (4) (b). Therefore, unless the commissioners are able to demonstrate, through a proper exhibit to the pleadings, that Williams is not entitled to judgment on the pleadings, their motion would fail. (ii) “Written Instruments.” At the core of the commissioners’ motion for judgment on the pleadings are facts contained in the three affidavits, and the exhibits attached to them, by which the commissioners attempt to show that their addition of the salary ordinance as a “walk-on” agenda item did not violate the Open Meetings Act. It is clear the trial court considered these affidavits in reaching its conclusion that the Open Meetings Act was not violated and that “official and statutory immunity appl[y] to this case,” going so far as to cite to them frequently throughout its order. For the following reasons, we conclude that the trial court erred in considering the affidavits in the context of a motion for judgment on the pleadings, and further conclude that the trial court’s consideration of the affidavits converted the commissioners’ motion into a summary judgment motion. (A) Rules of Construction and Plain Meaning. Our analysis begins with the Civil Practice Act generally and OCGA § 9-11-10 (c) specifically. “When we consider the meaning of a statute, we must presume that the General Assembly meant what it said and said what it meant. Thus if the language of the statute is plain and unambiguous, we simply apply the statute as written.” (Citations and punctuation omitted.) DeKalb County Bd. of Tax Assessors v. Astor Atl, LLC, 349 Ga. App. 867, 869 (826 SE2d 865) (2019). “In construing a statute, we must afford the statutory text its plain and ordinary meaning, we must view the statutory text in the context in which it appears, and we must read the statutory text in its most natural and reasonable way, as an ordinary speaker of the English language would.” (Citation and punctuation omitted.) Smith v. Northside Hosp., 302 Ga. 517, 521 (1) (807 SE2d 909) (2017). Moreover, “it is an elementary rule of statutory construction that statutes relating to the same subject matter are in pari materia and must be construed together and harmonized whenever possible.” (Citation and punctuation omitted.) Long v. Dev. Auth. of Fulton County, 352 Ga. App. 815, 821 (3) (b) (835 SE2d 717) (2019); see also Mornay v. Natl. Union Fire Ins. Co. of Pittsburgh, PA., 331 Ga. App. 112, 115 (3) (769 SE2d 807) (2015) (“[C]ourts may look to other provisions of the same statute to determine the meaning of a particular statutory provision. Context is a primary determinant of meaning.”) (citation and punctuation omitted). Relevant to this case, Georgia law makes clear that pleadings under the Civil Practice Act consist of a complaint and an answer; a thirdparty complaint . . .; and a thirdparty answer . . . . There may be a reply to a counterclaim denominated as such and an answer to a crossclaim, if the answer contains a crossclaim. No other pleading shall be allowed, except that the court may order a reply to an answer or a thirdparty answer. OCGA § 9-11-7 (a). “A copy of any written instrument which is an exhibit to a pleading is a part thereof for all purposes.” OCGA § 9-11-10 (c). There does not appear to be any relevant authority in Georgia defining the term “written instrument.”[11] Therefore, we turn to dictionaries to define the plain meaning of this term. See generally Smith, 302 Ga. at 521 (1) (consulting dictionaries as part of statutory construction); Abdel-Samed v. Daley, 294 Ga. 758, 763 (2) (755 SE2d 805) (2014) (same). In that regard, “instrument” is defined as “[a] written legal document that defines rights, duties, entitlements, or liabilities, such as a contract, will, promissory note, or share certificate.” Black’s Law Dictionary 801 (7th ed. 1999). Therefore, it does not appear that the plain meaning of “instrument” includes affidavits, but that does not necessarily end our analysis. (B) Persuasive Authority. Because OCGA § 9-11-10 (c) is based upon Federal Rule of Civil Procedure 10 (c), we also look to federal authority for guidance. See, e.g., Watts v. Brittian, 362 Ga. App. 93, 96 (1), n. 3 (866 SE2d 631) (2021) (“Because Georgia’s Civil Practice Act is modeled on the Federal Rules of Civil Procedure, decisions of the federal courts interpreting the federal rules are persuasive authority.”) (citation and punctuation omitted). Our review reveals something of a split among the authority. On one hand, the Second and Third Circuits have concluded that an affidavit is not a “written instrument” as that term is used in Federal Rule of Civil Procedure 10 (c). See Smith v. Hogan, 794 F3d 249, 254 (I) (2d Cir. 2015); Rose v. Bartle, 871 F2d 331, 339 (II), n. 3 (3rd Cir. 1989). The courts reasoned that such an interpretation “is consistent with the general understanding of what a legal or a written instrument is, i.e., a ‘legal document that defines rights, duties, entitlements, or liabilities, such as a statute, contract, will, promissory note, or share certificate[.]‘” (Citation omitted.) Smith, 794 F3d at 254 (I). Furthermore, Smith added that an affidavit, which merely presents “a personal, narrative summary[,]“ bears no resemblance to instruments such as contracts, registration statements, deeds or indentures. It is not a document that evidences legal rights or duties or sets forth the legal basis for his claims and therefore does not satisfy the definition of “written instrument.” Id. Of particular note, Rose observed that including affidavits in the definition of “written instrument” would “further blur the distinction between summary judgment and dismissal for failure to state a claim upon which relief could be granted.” 871 F2d at 339 (II), n. 3.[12] See also Flowers-Carter v. Braun Corp., 2019 U.S. Dist. LEXIS 40225, *5 – *7 (I) (C) (D. Ariz. 2019) (holding that consideration of a party’s “selfserving affidavit that it was responsible for injecting into the record” would be “improper and would defeat the whole point of [motions for judgment on the pleadings]“); Murry v. Ocwen Loan Servicing, 2017 U.S. Dist. LEXIS 23869, *1, n. 1 (D. Colo. 2017) (finding that plaintiff’s affidavits “are not ‘documents’ that are ‘central to’ his claims; instead, they provide unnecessary evidentiary material that is inappropriate at the pleadings stage”); cf. Summerour v. City of Monroe, 2022 Ga. App. LEXIS 150, *19 – *21 (2), 2022 WL 764967 (870 SE2d 848, 853-856 (2)) (2022) (finding that a video recording is not a “written instrument”). In contrast, in a line of cases exemplified by Northern Ind. Gun & Outdoor Shows v. City of S. Bend, 163 F3d 449, 452-453 (III) (A) (7th Cir. 1998), the Seventh Circuit embraced a broader definition of “written instrument” that included affidavits and letters, although the court offered little analysis for its decision.[13] Similarly, the Eighth Circuit summarily held that, in view of Rule 10 (c), an “accompanying affidavit should be considered as part of the complaint” on a motion to dismiss. (Emphasis supplied.) Rasidescu v. Globe College, 105 Fed. Appx. 121, 123 (8th Cir. 2004); see also Chapman v. The Chronicle, 2009 U.S. Dist. LEXIS 4260, *5 (A) (N. D. Cal. 2009) (holding that, on motion to dismiss, “a court may consider an affidavit attached to a complaint as part of the complaint”). Finally, federal district courts suggest that the Fifth Circuit has adopted a hybrid appro
