There are a couple of useful nuggets on evidentiary issues within the Limato decision:
"Affidavits by attorneys of facts [e.g. those acting under a power of attorney]" not based upon their personal knowledge but related to them by and within the primary knowledge of their clients constitute objectionable hearsay. See Murray v. Allstate Ins. Co., 209 N.J. Super. 163, 169 (App. Div. 1986). The requirement of the rule also are not met by affidavits containing argument, other forms of hearsay and general factual or legal conclusion. Pressler & Verniero, Current NJ Court Rules, comment on R. 1:6-6 (2011). Where hearsay is admissible under an exception to the hearsay rule which requires specific conditions have been satisfied, hearsay eveidence cannot be deemed competent unless it is first determined that those conditions have been satisfied. Jeter v. Stevenson, 284 N.J. Super. 229 (App. Div. 1995). Merely appending relevant documents to the motion brief does not constitute compliance with R. 1:6-6; such documents must be incorporated by reference in an appropriate affidavit or certification, which properly authenticates material which is otherwise admissible. See Celino v. General Acc. Ins., 211 N.J. Super. 538 (App. Div. 1986)."
Do these arguments sound familiar?