Case Reversed and Remanded

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Leonor Sarmiento Camperos v. Thomas Andres Vazquez Estrella, 38 Fla. L. Weekly D855b, Case No. 3D12-1749, issued on April 17, 2013: A non-final order denying motion to dismissed based on forum non conveniens was reversed and remanded for failure of the trial court to articulate the Kinney factors during the hearing. See: Kinney Sys., Inc. v. Cont'l Ins. Co., 674 So. 2d 86 (Fla. 1996), now codified in Fla. R. Civ. P. 1.061.         
(From RPPTL Subcommittee)

Trenton H. Cotney
Florida Bar Certified Construction Lawyer
Trent Cotney, P.A.
1211 N Franklin St
Tampa, FL 33602

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