There is “something of a split” in federal precedent on whether an affidavit qualifies as a “written instrument” under Federal Rule of Civil Procedure 10(c), the Georgia Court of Appeals explained in a case where the defendants used three affidavits attached to their answer to score judgment on the pleadings.A Georgia rule — like FRCP 10(c) and Illinois Code of Civil Procedure Sec. 2-606 — says a “written instrument” attached to a pleading as an exhibit is part of the pleading “for all purposes.” Official Code of Georgia …