CITIZENS PROPERTY INSURANCE CORPORATION
v.
MARTHA PROL

Fla. 3d DCA | 2024-08-28
No. 2023-0158
Logue, C.J., Emas, J., Bokor, J., Miller, J.
2024 FL 10543 Florida District Court of Appeal, Third District (2024)

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Holding

A party seeking to vacate a default judgment must provide sworn evidence of exceptional circumstances to demonstrate due diligence, and absent such competent substantial evidence, the party fails to show due diligence as a matter of law.


Headnotes

[1] Evidence supporting a claim of due diligence in moving to vacate a default judgment must be sworn, and absent competent substantial evidence of exceptional circumstances…

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Key Quotes

“evidence supporting due diligence 'must be sworn' and explaining that '[a]bsent competent substantial evidence of some exceptional circumstance explaining the delay' a party does not show due diligence as a matter of law where a sworn motion to vacate was filed six weeks after discovery of the default”

Citation to Lazcar Int'l, Inc. v. Caraballo establishing the evidentiary standard for demonstrating due diligence

Facts & Procedural History

Citizens Property Insurance Corporation appealed a trial court decision regarding a default judgment in a case against Martha Prol. The appellant soug…

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Opinion of the Court
Logue

Third District Court of Appeal State of Florida Opinion filed August 28, 2024. Not final until disposition of timely filed motion for rehearing. ________________ No. 3D23-0158 Lower Tribunal No. 21-15785 ________________ Citizens Property Insurance Corporation, Appellant, vs. Martha Prol, Appellee. An Appeal from the Circuit Court for Miami-Dade County, David C. Miller, Judge. Link & Rockenbach, P.A., and Kara Rockenbach Link and Daniel M. Schwarz (West Palm Beach); Williams Leininger & Cosby, P.A., and James O. Williams and Morgan T. Gieser (North Palm Beach), for appellant. The Law Firm of Arianna M. Mendez, PLLC, and Arianna M. Mendez; Cooke Carbonell LLP, and Jorge L. Carbonell, for appellee. Before LOGUE, C.J., and EMAS and BOKOR, JJ.

PER CURIAM.

2

Affirmed. See Lazcar Int’l, Inc. v. Caraballo, 957 So. 2d 1191, 1192– 93 (Fla. 3d DCA 2007) (noting that evidence supporting due diligence “must be sworn” and explaining that “[a]bsent competent substantial evidence of some exceptional circumstance explaining the delay” a party does not show due diligence as a matter of law where a sworn motion to vacate was filed six weeks after discovery of the default); see also Elliott v. Aurora Loan Servs., LLC, 31 So. 3d 304, 306 (Fla. 4th DCA 2010) (setting forth abuse of discretion standard).


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