VICTORIA DOMBROWER, ET AL.
v.
JENNIFER JINGCO, ET AL.
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A defendant's motion for disqualification based on inadvertent disclosure of protected information need not demonstrate prejudice to succeed.
[1] A motion for disqualification based on inadvertent disclosure of protected information does not require the moving party to demonstrate prejudice; demonstration of the ef…
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Join FLexlaw to unlock all legal intelligence“Defendants' motion adequately set forth the requirements for disqualification. This case demonstrates the effects of the inadvertent disclosure, the plaintiffs' recalcitrance in rectifying the disclosure, and the unfair tactical advantage gained from such disclosure. There was no requirement to demonstrate prejudice.”
The court cited Abamar Housing to support the principle that disqualification based on inadvertent disclosure does not require proof of prejudice.
Victoria Dombrower and others appealed a non-final order from the Circuit Court for Miami-Dade County involving a dispute with Jennifer Jingco and oth…
The full statement of facts, procedural history, and disposition for this case are member content.
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Third District Court of Appeal
State of Florida
Opinion filed October 29, 2026. Not final until disposition of timely filed motion for rehearing.
No. 3D26-1572 Lower Tribunal No. 25-19713-CA-01
Victoria Dombrower, et al., Appellants,
VS.
Jennifer Jingco, et al., Appellees.
An Appeal from a non-final order from the Circuit Court for Miami-Dade County, Migna Sanchez-Llorens, Judge.
Darius Asly; Glenn R. Goldstein & Associates, PLLC, and Glenn R. Goldstein, for appellants.
Coffey Burlington, P.L., and Paul J. Schwiep and George Kyriakopoulos, for appellees.
Before MILLER, GORDO and BOKOR, JJ.
PER CURIAM.
Affirmed. See Abamar Hous. & Dev., Inc. v. Lisa Daly Lady Decor, Inc., 724 So. 2d 572, 574 (Fla. 3d DCA 1998) (“Defendants' motion adequately set forth the requirements for disqualification. This case demonstrates the effects of the inadvertent disclosure, the plaintiffs' recalcitrance in rectifying the disclosure, and the unfair tactical advantage gained from such disclosure. There was no requirement to demonstrate prejudice.").