Here, Ill first distinguish between federal statutes, federal regulations, and Federal Rules such as the Federal Rules of Civil Procedure (FRCP). Unlike before, a scintilla of evidence or evidence raising the slightest doubt is no longer sufficient to create a disputed material fact. b. Words: may/must, key terms/language, and squishifiers. Charles B. Jimerson Local Rule 5.03 WebCiv Pro Rules Flow Chart - ! Sometimes the cases illustrate the application of a statute or rule, or provide meaning to indeterminate terms, or discuss splits in legal authority. Do it before you read the assigned cases. Rules ( 1.010 1.900) Forms ( 1.914) Appendix I - STANDARD INTERROGATORIES FORMS. Previously, a party could submit an affidavit as to why it could not adequately respond to summary judgment, including the need to conduct additional discovery. When the claimant prevails at the conclusion of the forfeiture proceeding, if the seizing agency decides not to appeal, the seized property shall be released immediately to the person entitled to possession of the property as determined by the court. {width:40px; R. Civ. % g<3uZgs1qp044p KH2 QRGY@ "xN 0F3y+(R DP4 Skip to Navigation | Skip to Main Content | Skip to Site Map. Fed. hb```W;@(p4,:G@ZE@*\r;;884/X]|w.HvGmLl@:H10/ \@d|xX w In Orange county, this includes all cases assigned to the Business Court division. 82-239; s. 2, ch. If no person entitled to notice requests an adversarial preliminary hearing, as provided in s. The court shall require any claimant who desires to contest the forfeiture to file and serve upon the attorney representing the seizing agency any responsive pleadings and affirmative defenses within 20 days after receipt of the complaint and probable cause finding. 28 U.S.C. Rule 1.010 - SCOPE AND TITLE OF RULES. Based on 2019 Proposed Amendments to the 1997 Rules of Civil Procedure (A.M. No. The seizing agency shall also publish, in accordance with chapter 50, notice of the forfeiture complaint once each week for 2 consecutive weeks in a newspaper of general circulation, as defined in s. The complaint must, in addition to stating that which is required by s. The seizing agency shall be obligated to make a diligent search and inquiry as to the owner of the subject property, and if, after such diligent search and inquiry, the seizing agency is unable to ascertain any person entitled to notice, the actual notice requirements by mail shall not be applicable. Florida cases discussing what facts are material to a claim or defense remain applicable since the materiality goes to the elements of that claim or defense. WebThe Florida Rules of Civil Procedure shall govern forfeiture proceedings under the Florida Contraband Forfeiture Act unless otherwise specified under the Florida Contraband 85-316; s. 1, ch. Fed. Third, they may reveal splits in legal authority, where different courts (such as the federal Courts of Appeals) may view the law differently. If it should appear at any time that an action is pending in the wrong court of any county, it may be transferred to P. 8 3d 555 (Fla. 2010). Courts can now order a party who submits an affidavit in bad faith or solely for delay to pay the other partys reasonable expenses, including attorneys fees, incurred as a result. Administrative Procedures for Electronic Filing (PDF), Handbook for Trial Jurors Serving in the United States District Courts (PDF), Plan for Qualification and Selection of Grand and Petit Jurors (PDF), Guide for Proceeding without a Lawyer (PDF), Notice of a Lawsuit and Request to Waive Service of a Summons (AO 398), Waiver of the Service of Summons (AO 399). 89-307; s. 6, ch. When the claimant prevails, at the close of forfeiture proceedings and any appeal, the court shall award reasonable trial attorneys fees and costs to the claimant if the court finds that the seizing agency has not proceeded at any stage of the proceedings in good faith or that the seizing agencys action which precipitated the forfeiture proceedings was a gross abuse of the agencys discretion. It is the policy of this state that law enforcement agencies shall utilize the provisions of the Florida Contraband Forfeiture Act to deter and prevent the continued use of contraband articles for criminal purposes while protecting the proprietary interests of innocent owners and lienholders and to authorize such law enforcement agencies to use the proceeds collected under the Florida Contraband Forfeiture Act as supplemental funding for authorized purposes. Webmust be specifically pled (Rule 1.140(h), Fla. R. Civ. All rights reserved. Other types of IP: Misappropriation, Trade Secrets, Right of Publicity, Other: Misappropriation, Trade Secrets, Right of Publicity, - Other types of IP: Misappropriation, Trade Secrets, Right of Publicity, - Other: Misappropriation, Trade Secrets, Right of Publicity. 119 0 obj <> endobj Instead, the FRCP is drafted by an Advisory Committee. R. Civ. 1.510., No. Federal regulations. P. 9 Form 1.944(a) Mortgage Foreclosure includes the verification sentence, Under penalties of perjury, I declare that I have read the foregoing, and the facts alleged therein are true and correct to the best of my knowledge and belief. Therefore, a plaintiff must appropriately investigate and confirm that the allegations in their foreclosure complaint are accurate or they may face criminal liability. Ann. The first year of law school is not just about learning the law. 685 0 obj <>/Filter/FlateDecode/ID[<45A814CF07DF17489869128E9C53E63C>]/Index[677 17]/Length 59/Prev 115724/Root 678 0 R/Size 694/Type/XRef/W[1 2 1]>>stream No claim to original U.S. Government Works. P. 15 1 In re: Amendments to Fla. Rule of Civil Proc. When verification of a document is required, the document filed shall include an oath, affirmation, or the following statement: Under penalties of perjury, I declare that I have read the foregoing, and the facts alleged therein are true and correct to the best of my knowledge and belief.. Fed. Add comments and case names, etc., after you read the assigned cases, and after class discussion. 1. Fed. 74-385; s. 4, ch. Skip to document Ask an Expert Sign inRegister Sign inRegister Home Ask an ExpertNew My Library Discovery Institutions endstream endobj startxref R. Civ. P. 3, 4(a)(1)(A)(B) Webpursuant to Florida Rule of Civil Procedure 1.540(b)(4), which authorizes a court to relieve a party from a void judgment or decree. The Defendant appealed arguing that Rule 1.540(b)(4) applies only to a void judgment or decree and not to a void final order. Statutes, Video Broadcast Fla. R. Civ. R. Civ. At least annually, each state or local law enforcement agency that seizes property for the purpose of forfeiture shall review such seizures, any settlements, and any forfeiture proceedings initiated by the law enforcement agency to determine whether they comply with the Florida Contraband Forfeiture Act and the guidelines adopted under this subsection. The seizing agencys legal counsel must be notified as soon as possible of all seizures and shall conduct a review to determine whether there is legal sufficiency to proceed with a forfeiture action. Under the new rule, if the nonmoving party must prove X to prevail [at trial], the moving party at summary judgment can either produce evidence that X is not so or point out that the nonmoving party lacks the evidence to prove X.1. Any trial on the ultimate issue of forfeiture shall be decided by a jury, unless such right is waived by the claimant through a written waiver or on the record before the court conducting the forfeiture proceeding. Previously, a party had to serve its motion for summary judgment (MSJ) 20 days before a hearing and respond 5 days before the hearing, if service was by mail, or by 5:00 p.m., 2 business days before the hearing, if service was by email. WebRevised Civil Procedure Flow Chart (2019 Amendment) - Free download as PDF File (.pdf) or read online for free. Fed. Some rules may be more current, see credits for details. 92.525(3). In 2010, the Florida Supreme Court explained the purpose of a verified complaint in foreclosure actions as follows: (1) to provide incentive for the plaintiff to appropriately investigate and verify its ownership of the note or right to enforce the note and ensure that the allegations in the complaint are accurate; (2) to conserve judicial resources that were being wasted on inappropriately pleaded lost note counts and inconsistent allegations; (3) to prevent the wasting of judicial resources and harm to defendants resulting from suits brought by plaintiffs not entitled to enforce the note; and. Any matter admitted under this rule is conclusively established unless the court on motion In 2014, Rule 1.110(b) was amended to remove the pleading requirement for certain mortgage foreclosure actions and incorporated the language in new Rule 1.115. 92-54; s. 4, ch. The complaint shall be styled, In RE: FORFEITURE OF. ATTORNEYS FEES FOR BAD FAITH AFFIDAVITS. 90-17; s. 4, ch. hZm6+`P6@5I{ 8($9iD'e"#y8/IIJIR(%p~*|4 ADeHgI 4(lk]P @6%+T 20zRd HR. %PDF-1.6 % The motion shall be filed within a reasonable time, and for reasons (1), (2), and (3) not more than 1 year after the judgment, decree, order, or proceeding was entered or taken. When reading a statute or rule, identify the structure and key language. To help ensure that property is not wrongfully held after seizure, each law enforcement agency must adopt written policies and procedures ensuring that all asserted claims of interest in seized property are promptly reviewed for potential validity. Hover your cursor over the rectangles on the flowchart to learn more about the steps involved in a civil case. width:40px !important; SIDEBAR: Be aware that the word rules is used both to refer to the rules of the FRCP, as well as in a broader sense regarding rules of law. Some students like to keep a separate list of questions with written answers, or to pencil in a ? in the margin of the statutes book that can be erased after resolving questions. Veterans Financial Literacy Program goes Statewide! The Department of Law Enforcement, in consultation with the Florida Sheriffs Association and the Florida Police Chiefs Association, shall develop guidelines and training procedures to be used by state and local law enforcement agencies and state attorneys in implementing the Florida Contraband Forfeiture Act. %PDF-1.5 % P. 7, Fed. If the claimant prevails on appeal, the seizing agency shall immediately release the seized property to the person entitled to possession of the property as determined by the court, pay any cost as assessed by the court, and may not assess any towing charges, storage fees, administrative costs, or maintenance costs against the claimant with respect to the seized property or the forfeiture proceeding. Fed. In response to the directive of the Florida Supreme Court Administrative Order 20-23, (Amendment 12), the Ninth Judicial Circuit established the Courts active, differentiated Case Management program effective April 30, 2021. Proceedings for a civil action commenced in federal district court (or removed to federal court from state court) are governed by the Federal Rules of Civil Procedure (FRCP). The individual district courts also have local rules, and sometimes judge-specific rules, which counsel must consult and follow carefully. 19-10-20-SC) Revised Civil Procedure Flow Chart (2019 Amendment) Uploaded by Joms Altomea. }, by Jocelyne A. Macelloni, Barakat + Bossa. P.; and Rule 8(c), Fed. What Are Actual Damages Under the FCCPA and the FDCPA? endstream endobj 678 0 obj <. When property is seized for forfeiture, the probable cause supporting the seizure must be promptly reviewed by supervisory personnel. 0 Fed. Sometimes the cases illustrate the application of a statute or rule, or provide meaning to indeterminate terms, or discuss splits in legal authority. The cases and other assigned readings are important in several ways. When the claimant prevails at the conclusion of the forfeiture proceeding, any decision to appeal must be made by the chief administrative official of the seizing agency, or his or her designee. Others might type up the statute or rule, breaking it up and restructuring it in a way that highlights its logical structure. P. 3853 Each seizing agency shall adopt and implement written policies and procedures promoting the prompt release of seized property as may be required by the act or by agency determination when there is no legitimate basis for holding seized property. Fed. With thanks to Prof. Elizabeth Pendo, whose materials I used in putting the first version of this document together in 2006. 1441, the general removal statute. Now, the burden on summary judgment lies with the party that has the burden at trial. 2021-04-02, outlines the process for determining whether a case requires a Case Management Plan and Order and, if so, the timeline and form of order required. 3. Local Rules Ch. County Court: Other Civil Non Monetary, Any Replevin, Any Foreclosure, Personal Injury Protection (and other first party insurance claims), and Small Claims (if the rules of civil procedure have been invoked). View on Westlaw or start a FREE TRIAL today, Rule 1.540. WebFlorida Rules of Civil Procedure. Florida Supreme Court Administrative Order 20-23, (Amendment 12), AOSC 21-17 Emergency Measures for Florida Trial Courts, For cases filed on or after April 30, 2021 the parties are required to file the. The determination as to whether to seize currency must be made by supervisory personnel. P. 73 Current with amendments received through 3/15/2023. R. Civ. The complaint The Case Management program,Ninth Judicial Circuit Administrative Order No. Use consistent marks to identify such components of statutes or rules. R. Civ. hbbd``b`$;AG "$8~@Bf9dd100&` Zv R. Civ. 80-68; s. 1, ch. First, they illustrate some (but not all) of the functioning of the statutes or rules we read. endstream endobj 1082 0 obj <>/Metadata 16 0 R/OCProperties<>/OCGs[1103 0 R]>>/Outlines 121 0 R/PageLayout/SinglePage/Pages 1079 0 R/StructTreeRoot 126 0 R/Type/Catalog>> endobj 1083 0 obj <>/Font<>/Properties<>>>/Rotate 0/StructParents 0/Tabs/S/Type/Page>> endobj 1084 0 obj <>stream The first time you read a statute or rule you should read it slowly and carefully. Federal regulations arent enacted by Congress, but are instead issued by an administrative agency, such as the Federal Communications Commission (FCC). I also liked to add blurbs about cases and explanatory hypotheticals to my typed-up version of a statute or rule. } Read the entire statute or rule slowly and carefully. Rule 1.070 - PROCESS. The final order of forfeiture by the court shall perfect in the law enforcement agency right, title, and interest in and to such property, subject only to the rights and interests of bona fide lienholders, and shall relate back to the date of seizure. Appendix II - The first time you read a statute or rule you should read it slowly and carefully. Law enforcement agency personnel involved in the seizure of property for forfeiture shall receive basic training and continuing education as required by the Florida Contraband Forfeiture Act. If the review suggests deficiencies, the state or local law enforcement agency shall promptly take action to comply with the Florida Contraband Forfeiture Act. 133 0 obj <>/Filter/FlateDecode/ID[<758726BDE5476F48AAAFE400A68C5EAB><2AAF1B096287E341A09DBE857E74BA28>]/Index[119 22]/Info 118 0 R/Length 75/Prev 51727/Root 120 0 R/Size 141/Type/XRef/W[1 2 1]>>stream Read the cases and annotate the flowchart or diagram. The court shall award reasonable attorneys fees and costs, up to a limit of $2,000, to the claimant at the close of the adversarial preliminary hearing if the court makes a finding of no probable cause. P. 12 P. 54 For those litigating in federal courts, the rule is nothing new; in fact, Rule 1.510 of the Florida Rules of Civil Procedure adopts Prof. Pendo notes in her materials that portions were in turn inspired or borrowed from materials in GERALD F. HESS & STEVEN FRIEDLAND, TECHNIQUES FOR TEACHING LAW 337-38 (1999). R. Civ. 29, 2021)(citing Bedford v. Doe, 880 F.3d 993, 996-97 (8th Cir. 2010-117; s. 3, ch. Therefore, cases cannot substitute for careful reading and consideration of the statutes or rules language. Fla. Stat. What Exposure Does a Business Have to Attorneys Fees Under the FCCPA and the FDCPA? Theyre not regulations because theyre not issued by a federal administrative agency. VDOMDHTMLtml> Florida Rules of Civil Procedure - Florida Rules of Civil Procedure Home Probate Rules Family Law Rules VIDEO Procedural Appeals Criminal Law Probate Family Law Florida Rules of Civil Procedure Rule 1.010 Scope and Title of Rules Rule 1.040 One Form of Action Rule 1.061 Choice of Forum Rule 1.080 Service and Filing of Rule 1.110 If you are interested in speaking to a Jimerson Birr lawyer or want general information about the firm, our practice areas, lawyers, publications, or events, please contact us via email or telephone for assistance at (904) 389-0050. If the Supreme Court adopts the changes, they are then submitted to Congress. endstream endobj 120 0 obj <. P. 1.370(a). Fed. Although the evidence attached to a summary judgement motion is no longer specifically defined in the rule, it still includes, depositions, documents, electronically stored information, affidavits or declarations, stipulations (including those made for purposes of the motion only), admissions, interrogatory answers, or other materials as would be admissible in evidence. However, a party can renew its MSJ under the new rule. Read the cases and annotate the flowchart or diagram. Rule 1.540. The original panel assigned to the case agreed with the Defendant and { The determination as to whether an agency will file a civil forfeiture action is the sole responsibility of the head of the agency or his or her designee. Unlicensed Practice - Florida Rules of Court Procedure The Florida The rules govern civil actions and apply to all special statutory 9, Timothy J. Corrigan, Chief United States District Judge Elizabeth Warren, Clerk of Court. R. Civ. The following overview provides 10 major changes that every busy practitioner should know about. Generally, verification means that the person signing a document swears that they have read the document, and confirms that the facts therein are true and correct based on personal knowledge and belief. Local Rule 1.05, Local Rule 1.07 Relief from Judgment, Decrees, or Orders Currentness (a) In re Amendments To The Fla. R. Civ. In each judicial circuit, all civil forfeiture cases shall be heard before a circuit court judge of the civil division, if a civil division has been established. Flowchart or diagram. P. 3 Banking & Financial Services Industry Legal Blog. As always, be a. On April 29, 2021, the Florida Supreme Court adopted a new summary judgment standard. Some people are visual and work best with hand-written flowcharts. The new rule requires judges to make explicit findings for both an award and a denial of an MSJ. Copyright 2008-2023 Jimerson Birr, P.A. WebAs amended through February 1, 2023. Instead, there must be evidence on which a jury could reasonably find for the nonmoving party. The trial court shall also require the seizing agency to pay to the claimant any loss of income directly attributed to the continued seizure of income-producing property during the trial or appellate process. 2018)). P. 5 677 0 obj <> endobj Importantly, keep in mind that few cases explain every aspect of a statute or rule. In response to the new legislation, the Florida Supreme Court created a new rule for governing foreclosure complaints, Rule 1.115, which includes a new verification requirement. 1102 0 obj <>/Filter/FlateDecode/ID[<04CEEC705CD7A64B82482CEFE19B2D4C>]/Index[1081 133]/Info 1080 0 R/Length 116/Prev 151055/Root 1082 0 R/Size 1214/Type/XRef/W[1 3 1]>>stream On the commencement of the action, summons or other process authorized by RULE 1.010 SCOPE AND TITLE OF RULE. R. Civ. The agencys legal counsel must be notified as soon as possible after a determination is made. Business Law Section of the Florida Bar | Hosting & Maintenance by, Electronic Discovery & Digital Evidence Committee, State & Federal Court Judicial Liaison Committee, CTL Committee work on proposed legislation, Corporations, Securities & Financial Services Committee, Guidance for Business Owners Impacted by COVID19, Antitrust & Trade Regulation Subcommittee, Chapter 617 Task Force (Corporations Not For Profit Statute), Proposed Amendments to Florida Rules of Civil Procedure Task Force, Restrictive Covenant (542.335) Task Force, Uniform Commercial Real Estate Receivership Act Task Force, Uniform Voidable Transactions Act Task Force, Veterans Financial Literacy Program Goes State Wide, April is now known as FINANCIAL LITERACY MONTH In Florida. P., 44 So. The employment, salary, promotion, or other compensation of any law enforcement officer may not be dependent on the ability of the officer to meet a quota for seizures. The Florida Rules of Civil Procedure shall govern forfeiture proceedings under the Florida Contraband Forfeiture Act unless otherwise specified under the Florida Contraband Forfeiture Act. No express deadline has been set for filing a reply. WebUnited States District Court Middle District of Florida Civil Case Flowchart Definitions COMPLAINT: The complaint is the written document that begins a lawsuit. hbbd``b`$W- $~ D%&t(GNLl@#V?co F A motion under this subdivision does not affect the finality of a judgment, decree, or order or suspend its operation. Please keep this in mind if you use this service for this website. hb```EaBV_$ 'fMdp444tp5 510l yl+7|'yfMU@| c>[cNR0 2! If the claimant is unrepresented, the settlement agreement must include a provision that the claimant has freely and voluntarily agreed to enter into the settlement without benefit of counsel. P. 58 P. 11 R. Civ. Erie III. R. Civ. Jimerson Birr welcomes inquiries from the media and do our best to respond to deadlines. - All Rights Reserved, Community Advocacy & Social Responsibility, Hiring for Florida Banks and Credit Unions: A Summary of Background Checks and Other Information Required to Comply With Various Regulatory Schemes, Overview of a Trust Beneficiarys Remedies Under the Florida Trust Code for Breach of Trust. Chapter 2 Rules of General Practice and Judicial Administration; updated October 4, 2022 Chapter 4 Rules of Civil Procedure for Involuntary Commitment of Sexually Violent Predators Florida Courts Technology Standards provides guidance and specific technical information about court document filings. The seizing agency shall promptly proceed against the contraband article by filing a complaint in the circuit court within the jurisdiction where the seizure or the offense occurred, paying a filing fee of at least $1,000 and depositing a bond of $1,500 to the clerk of the court. Flowchart or diagram the statute or rule. The new Rule 1.510 took effect on May 1, 2021 and applies to MSJs adjudicated on or after May 1, 2021. 2016-179. Each agency shall maintain records demonstrating each law enforcement officers compliance with this requirement. Links to the rules referenced within the flowchart 87-77; s. 4, ch. 2. Do it before you read the assigned cases. Read the entire statute or rule slowly and carefully. Fed. 85-304; s. 2, ch. Copyright 2000- 2023 State of Florida. These rules apply to all actions of a civil nature and all special statutory proceedings in the The settlement of any forfeiture action must be consistent with the Florida Contraband Forfeiture Act and the policy of the seizing agency. RULE 1.490. Schedule. a. Amended July 16, 1992, effective Jan. 1, 1993 (, West's F.S.A. Committee A seizing agency shall adopt and implement written policies, procedures, and training to ensure compliance with all applicable legal requirements regarding seizing, maintaining, and the forfeiture of property under the Florida Contraband Forfeiture Act. If your hearing is set less than 20 days from when you filed the MSJ and the nonmoving party has not yet filed a Response, you should reschedule your hearing. Search Within. Therefore, cases cannot substitute for careful reading and consideration of the statutes or rules language. Res - Studocu On Studocu you find all the lecture notes, summaries and study guides you need to pass your exams with better grades. .scid-1 img The court may order the seizing agency to pay the awarded attorneys fees and costs from the appropriate contraband forfeiture trust fund. Links to the rules referenced within the flowchart are immediately below it in the Resources section. R. Civ. (4) to give trial courts greater authority to sanction plaintiffs who make false allegations. RCP Rule 1.540, FL ST RCP Rule 1.540. Myself, I fall into the latter category: as a student, I would cut & paste the statute or rule into a new document and shift its text around to illustrate its logical structure in ways that made sense to me. Local Rule 3.05 Previously, the moving party had the burden of establishing, conclusively, that there was no genuine issue of material fact as to the claim or case, in its entirety, including disproving the other partys theory of the case. 718, Condominium Association Lawsuit, Any Constitutional Challenge, Distress, Replevin, Any Foreclosure, and Any Other Real Property Actions. All civil cases other than complex and streamlined cases. The rule provides that if a party fails to respond to a request for admissions within thirty days of service of the request, the matter is deemed admitted. For instance, the plaintiff would not only have to establish their own case (for which they had the burden of proving at trial), but also disproving the defendants affirmative defenses. Publications, Help Searching This website uses Google Translate, a free service. The potential for obtaining revenues from forfeitures must not override fundamental considerations such as public safety, the safety of law enforcement officers, or the investigation and prosecution of criminal activity. Florida Rules of Civil Procedure Rules Rule 1.280 - GENERAL PROVISIONS GOVERNING DISCOVERY Fla. R. Civ. Javascript must be enabled for site search. Civil Procedure Review I. Unless otherwise expressly agreed to in writing by the parties, the bond shall be payable to the claimant if the claimant prevails in the forfeiture proceeding and in any appeal. WebFlorida Rule of Civil Procedure 1.370 governs requests for admissions. Florida Statutes Definitions Index (2022), Table Tracing Session Laws to Florida Statutes (2022), Index to Special and Local Laws (1971-2022), Index to Special and Local Laws (1845-1970). This rule does not limit the power of a court to entertain an independent action to relieve a party from a judgment, decree, order, or proceeding or to set aside a judgment, decree, or order for fraud upon the court. 2006-2021 Ira Steven Nathenson (Hey, Copyright students: see 17 U.S.C. R. Civ. WebCivil Case Flowchart Hover your cursor over the rectangles on the flowchart to learn more about the steps involved in a civil case. When the claimant and the seizing law enforcement agency agree to settle the forfeiture action prior to the conclusion of the forfeiture proceeding, the settlement agreement shall be reviewed, unless such review is waived by the claimant in writing, by the court or a mediator or arbitrator agreed upon by the claimant and the seizing law enforcement agency. endstream endobj startxref 0 SC20-1490, 2021 Fla. LEXIS 682, at *10 (Apr. Identify the structure and key language of the statute or rule. P. 72 County Court: Other Civil Non Monetary, Any Replevin, Any Foreclosure, Personal Injury Protection (and other first party insurance claims), and Small Claims (if Ms. Macelloni can be reached at jmacelloni@b2b.legal or (305) 444-3114. Fed. 1081 0 obj <> endobj On April 29, 2021, the Florida Supreme Court adopted a new summary judgment standard. Jocelyne Macelloni is a partner at the Coral Gables law firm of Barakat + Bossa and an adjunct professor of law at Nova Southeastern University Shepard Broad College of Law.
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