CINCINNATI - A federal judge in Michigan did not err in awarding summary judgment to Wells Fargo Bank after considering a letter that attached as an exhibit to its reply brief in support of its motion, a Sixth Circuit U.S. Court of Appeals panel ruled Sept. 6 (Teresa Matthews, et al. v. Wells Fargo Bank, No. 12-2554, 6th Cir.; 2013 U.S. App. LEXIS 18770).