JANE DOE, ET AL
v.
IASMINA PENCOV
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A trial court must apply the Venetian Salami standard for personal jurisdiction and the Kinney Systems standard for forum non conveniens, making express findings on the required factors.
[1] When affidavits and sworn materials regarding personal jurisdiction cannot be harmonized, a trial court must conduct a limited evidentiary hearing to resolve material jur…
[2] A trial court must make express findings on the adequacy of an alternative forum, private interest factors, public interest factors, and whether a plaintiff may reinstate…
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Join FLexlaw to unlock all legal intelligenceJane Doe and other appellants filed suit against Iasmina Pencov. The trial court denied appellants' motions to dismiss for lack of personal jurisdicti…
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DISTRICT COURT OF APPEAL OF THE STATE OF FLORIDA
FOURTH DISTRICT
JANE DOE, an individual, JUNE DOE, an individual, and JOHN DOE, an individual, Appellants,
V.
IASMINA PENCOV, Appellee.
No. 4D2026-0831
[September 2, 2026]
Appeal of a nonfinal order from the Circuit Court for the Fifteenth Judicial Circuit, Palm Beach County; Gerard Joseph Curley Jr., Judge; L.T. Case No. 502024CA003264XXXAMB.
Danielle Marie Bianculli and Khari James of National Center on Sexual Exploitation, Washington, D.C., for appellants.
Thomas Maniotis of Equity Legal, PLLC, Miami, for appellee.
PER CURIAM.
We reverse the portion of the circuit court's order denying Jane Doe's motion to dismiss for lack of personal jurisdiction and remand for the court to apply Venetian Salami Co. v. Parthenais, 554 So. 2d 499 (Fla. 1989). On remand, the court should determine whether the affidavits and sworn materials can be harmonized. If the affidavits and sworn materials cannot be harmonized, the circuit court should conduct a limited evidentiary hearing to resolve the material jurisdictional facts.
We reverse the portion of the circuit court's order denying appellants' motions to dismiss for forum non conveniens and remand for the court to conduct the analysis required by Kinney Systems, Inc. v. Continental Insurance Co., 674 So. 2d 86 (Fla. 1996), and Florida Rule of Civil Procedure 1.061. The circuit court should make express findings on the adequacy of the alternative forum, the private interest factors, the public interest factors, if applicable, and whether appellants may reinstate their suit in the alternative forum without undue inconvenience or prejudice.
Reversed and remanded.
GROSS, LEVINE AND SHEPHERD, JJ., concur.
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