CARMEN MEDINA
v.
CITIZENS PROPERTY INSURANCE CORPORATION

Fla. 3d DCA | 2021-11-17
No. 21-0328
Carter, McKusick, Nichols, Nick, Roberts, Wer
Florida District Court of Appeal, Third District (2021)

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Holding

A qualified witness with personal knowledge of an organization's regular business practices relating to creating and retaining records may lay the foundation for business records under the hearsay exception.


Headnotes

[1] A qualified witness who has personal knowledge of an organization's regular business practices relating to the creation and retention of records may testify to the founda…

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Key Quotes

“The records custodian or any person who has the requisite knowledge to testify as to how the record was made can lay the necessary foundation.”

United Auto. Ins. Co. v. Affiliated Healthcare Ctrs., Inc., 43 So. 3d 127, 130 (Fla. 3d DCA 2010)

Facts & Procedural History

Carmen Medina appealed a circuit court decision in Miami-Dade County involving a dispute with Citizens Property Insurance Corporation. The case involv…

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Opinion of the Court

PER CURIAM.

Affirmed. See Jackson v. Household Fin. Corp. III, 298 So. 3d 531, 536 (Fla. 2020) (setting forth hearsay exception for business records and noting that a qualified witness is “anyone with personal knowledge of the organization’s regular business practices relating to creating and retaining the record(s) at issue,” stemming from that witness’s training or experience); United Auto. Ins. Co. v. Affiliated Healthcare Ctrs., Inc., 43 So. 3d 127, 130 (Fla. 3d DCA 2010) (“The records custodian or any person who has the requisite knowledge to testify as to how the record was made can lay the necessary foundation.”) (internal quotations and citations omitted); Umana v. Citizens Property Insurance Corp., 282 So. 3d 933, 935 (Fla. 3d DCA 2019) (finding no abuse of discretion in the trial court’s denial of a motion for rehearing based on new evidence, but noting that “a trial court also has broad discretion to grant a rehearing of a summary judgment when the party seeking rehearing submits matters that would have created an issue precluding summary judgment if they had been raised prior to the hearing on the motion").


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