3d 251, 253-254 (Fla. Dist. You already receive all suggested Justia Opinion Summary Newsletters. 75-9; s. 933, ch. GENERAL ASSIGNMENTS. In Tanenbaum, the Supreme Court specifically declined to "adopt by judicial action the doctrine of promissory estoppelas sort of a counteraction to the legislatively created Statute of Frauds." 190 So.2d at 7 79. Dionne v. Columbus Mills, 311 So.2d 681 (Fla. 2d DCA 1975). Publications, Help Searching Section 725.01 - Promise to pay another's debt, etc. The transfer was of substantially all the debtors assets. 227, 294, ch. 97-102; s. 60, ch. There are 3 statutes meant for goods exceeding $500, $1000 and $5000. It was specifically created to protect people from dishonest conduct by mandating that certain contracts be made in writing. 725.01, Fla. Stat. Javascript must be enabled for site search. Copyright 2000- 2023 State of Florida. (2014). In limited circumstances, partial performance of an oral contract will defeat a statute of frauds defense. The Florida Statute of Frauds is codified at Florida Statute section 725.01 which provides, in pertinent part: No action shall be brought whereby to charge the defendant upon any special promise to answer for the debt, default or miscarriage of another person or upon any agreement that is not to be performed within the space of 1 year from the making thereof unless the agreement or . Contracts which cannot be performed within one year. However, the statute of frauds is an affirmative defense, and cannot be asserted as a grounds for a motion to dismiss. The state law requires a written agreement regardless of the time when the contract will be performed. 170;Winfield v. Bowen, 65 N.J.Eq. STATUTE OF FRAUDS, FRAUDULENT TRANSFERS, AND GENERAL ASSIGNMENTS. Committee 725.01 Promise to pay another's debt, etc.--No action shall be brought whereby to charge any executor or administrator upon any special promise to answer or pay any debt or damages out of her or his own estate, or whereby to charge the defendant upon any special promise to answer for the debt, default or miscarriage of another person or to charge any person upon any agreement made upon consideration of marriage, or upon any contract for the sale of lands, tenements or hereditaments, or of any uncertain interest in or concerning them, or for any lease thereof for a period longer than 1 year, or upon any agreement that is not to be performed within the space of 1 year from the making thereof, or whereby to charge any health care provider upon any guarantee, warranty, or assurance as to the results of any medical, surgical, or diagnostic procedure performed by any physician licensed under chapter 458, osteopathic physician licensed under chapter 459, chiropractic physician licensed under chapter 460, podiatric physician licensed under chapter 461, or dentist licensed under chapter 466, unless the agreement or promise upon which such action shall be brought, or some note or memorandum thereof shall be in writing and signed by the party to be charged therewith or by some other person by her or him thereunto lawfully authorized. The journals or printed bills of the respective chambers should be consulted for official purposes. PDF. This provision covers prenuptial agreements. 2d 518 (Fla. 3d DCA 1975); Rowland v. Ewell, 174 So. No action shall be brought whereby to charge any executor or administrator upon any special promise to answer or pay any debt or damages out of her or his own estate, or whereby to charge the defendant upon any special promise to answer for the debt, default or miscarriage of another person or to charge any person upon any agreement made upon consideration of marriage, or upon any contract for the sale of lands, tenements or hereditaments, or of any uncertain interest in or concerning them, or for any lease thereof for a period longer than 1 year, or upon any agreement that is not to be performed within the space of 1 year from the making thereof, or whereby to charge any health care provider upon any guarantee, warranty, or assurance as to the results of any medical, surgical, or diagnostic procedure performed by any physician licensed under chapter 458, osteopathic physician licensed under chapter 459, chiropractic physician licensed under chapter 460, podiatric physician licensed under chapter 461, or dentist licensed under chapter 466, unless the agreement or promise upon which such action shall be brought, or some note or memorandum thereof shall be in writing and signed by the party to be charged therewith or by some other person by her or him thereunto lawfully authorized. 97-102; s. 60, ch. 97-102. 91-224; s. 1265, ch. (1) Except as otherwise provided in this section a contract for the sale of goods for the price of $500 or more is not enforceable by way of action or defense unless there is some writing sufficient to indicate that a contract for sale has . The debtor transferred the essential assets of the business to a lienor who transferred the assets to an insider of the debtor. 672.201 Formal requirements; statute of frauds.. STATUTE OF FRAUDS, FRAUDULENT TRANSFERS, AND GENERAL ASSIGNMENTS. 29737, 1955; s. 41, ch. Evictions: Residential Tenant Must Provide Supporting Documentation with Motion to Determine Rent, Eviction Law- Residential Tenant Files for Bankruptcy Protection. History.--s. The Florida Statutes are updated annually after the conclusion of a regular legislative session, typically published in July/August. This is Attorney Advertising. Statutes, Video Broadcast 725.01. Outright Purchase of Real Estate Property In Florida. What do you do now? 98-166. TITLE XLI Florida Corporate; Search Statutes; Search Tips; Florida Constitution; Acts of Florida . 97-264; ss. (5)This section does not affect contracts or agreements entered into before the effective date of this section. & Dev., Inc., 97 So. 725.08 Design professional contracts; limitation in indemnification.--. Andrew Douglas, P.A. (4)"Design professional" means an individual or entity licensed by the state who holds a current certificate of registration under chapter 481 to practice architecture or landscape architecture, under chapter 472 to practice land surveying and mapping, or under chapter 471 to practice engineering, and who enters into a professional services contract. LaRue v. Kalex Constr. Jurisdiction of proceedings and venue. (2019). 725.06 Construction contracts; limitation on indemnification. Contacting Andrew Douglas, P.A. 725.04 Voluntary payment; pleading.--When a suit is instituted by a party to a contract to recover a payment made pursuant to the contract and by the terms of the contract there was no enforceable obligation to make the payment or the making of the payment was excused, the defense of voluntary payment may not be interposed by the person receiving payment to defeat recovery of the payment. Skip to Navigation | Skip to Main Content | Skip to Site Map. In determining actual intent under paragraph (1)(a), consideration may be given, among other factors, to whether: The transfer or obligation was to an insider. The 2021 Florida Statutes (including Special Session B) Title XLI STATUTE OF FRAUDS, FRAUDULENT TRANSFERS, AND GENERAL ASSIGNMENTS: Chapter 727 GENERAL ASSIGNMENTS: View Entire Chapter: CHAPTER 727. (1)Any portion of any agreement or contract for or in connection with, or any guarantee of or in connection with, any construction, alteration, repair, or demolition of a building, structure, appurtenance, or appliance, including moving and excavating associated therewith, between an owner of real property and an architect, engineer, general contractor, subcontractor, sub-subcontractor, or materialman or any combination thereof wherein any party referred to herein promises to indemnify or hold harmless the other party to the agreement, contract, or guarantee for liability for damages to persons or property caused in whole or in part by any act, omission, or default of the indemnitee arising from the contract or its performance, shall be void and unenforceable unless the contract contains a monetary limitation on the extent of the indemnification that bears a reasonable commercial relationship to the contract and is part of the project specifications or bid documents, if any. 98-166. Corp., 872 F.2d 36, 39 (3d Cir. 162, 164 (S.D.N.Y 1991); H.R. What is the Statute of Frauds? Any person who knowingly violates this section shall be punished as follows: If the value of the property sold, secreted, withheld, or disposed of or the proceeds from the sale or disposition of the property is $300 or more, such person is guilty of a felony of the third degree, punishable as provided in s. If the value of the property sold, secreted, withheld, or disposed of or the proceeds obtained from the sale or disposition of the property is less than $300, such person is guilty of a misdemeanor of the first degree, punishable as provided in s. s. 1, ch. 227, 294, ch. 75-9; s. 933, ch. 2d 556, 558 (Fla. 4th DCA 1992) (noting the distinction that where the contract is for the sale of land and the relief sought is for specific performance, partial performance may remove the contract from the statute of frauds); see also Collier v. Brooks, 632 So. Notwithstanding the foregoing, the monetary limitation on the extent of the indemnification provided to the owner of real property by any party in privity of contract with such owner shall not be less than $1 million per occurrence, unless otherwise agreed by the parties. COUNTY ORGANIZATION AND INTERGOVERNMENTAL RELATIONS, TEACHERS' RETIREMENT SYSTEM; HIGHER EDUCATIONAL FACILITIES BONDS, NATURAL RESOURCES; CONSERVATION, RECLAMATION, AND USE, REGULATION OF PROFESSIONS AND OCCUPATIONS, REGULATION OF TRADE, COMMERCE, INVESTMENTS, AND SOLICITATIONS, AGRICULTURE, HORTICULTURE, AND ANIMAL INDUSTRY, - INTERNATIONAL TRUST COMPANY REPRESENTATIVE OFFICES, - QUALIFIED LIMITED SERVICE AFFILIATES OF INTERNATIONAL TRUST ENTITIES, STATUTE OF FRAUDS, FRAUDULENT TRANSFERS, AND GENERAL ASSIGNMENTS, Florida Statutes Definitions Index (2022), Table Tracing Session Laws to Florida Statutes (2022), Index to Special and Local Laws (1971-2022), Index to Special and Local Laws (1845-1970). 728;Ayres v. Short, 142 Mich. 501, 105 N.W. 1994); In re Texscan Corp., 976 F.2d 1269 (9th Cir. 2022 Florida Statutes (including 2022C, 2022D, 2022A, and 2023B) The Florida Statutes are updated annually after the conclusion of a regular legislative session, typically published in July/August. Skip to Navigation | Skip to Main Content | Skip to Site Map. A construction contract for a public agency or in connection with a public agencys project may require a party to that contract to indemnify and hold harmless the other party to the contract, their officers and employees, from liabilities, damages, losses and costs, including, but not limited to, reasonable attorneys fees, to the extent caused by the negligence, recklessness, or intentional wrongful misconduct of the indemnifying party and persons employed or utilized by the indemnifying party in the performance of the construction contract. s. 10, Nov. 15, 1828; RS 1995; GS 2517; RGS 3872; CGL 5779; s. 10, ch. Florida Statutes Definitions Index (2022), Table Tracing Session Laws to Florida Statutes (2022), Index to Special and Local Laws (1971-2022), Index to Special and Local Laws (1845-1970). The journals or printed bills of the respective chambers should be consulted for official purposes. 725.05 Satisfaction for less than amount due.--When the amount of any debt or obligation is liquidated, the parties may satisfy the debt by a written instrument other than by endorsement on a check for less than the full amount due. 98-166. The statute applies to land sales and most purchases of goods over $500.. 2019 Florida Statutes Title XLI STATUTE OF FRAUDS, FRAUDULENT TRANSFERS, AND GENERAL ASSIGNMENTS Chapter 725 UNENFORCEABLE CONTRACTS Entire Chapter SECTION 01 Promise to pay another's debt, etc. The court noted that since the case was at a motion to dismiss stage, that the reasonable inferences arising from the complaint suggested that the oral contract was for an indefinite time and could be performed within a year. 725.01 Promise to pay another's debt, etc. Relying upon this rule, the court in Terzis v. Pompano Paint and Body Repair, Inc., 4D11-2155, 2012 WL 6601316 (Fla. 4th DCA 2012), ruled that where the complaint did not allege that the parties agreed on a time for performance of the oral contract or that the parties intended that it should be for longer than a period of one year, the oral contract fell outside the purview of the statute of frauds. Co. v. First Indus. 227, 294, ch. v. WEGMAN. 2d 928, 929 (Fla. 1st DCA 1990) (It is now well established that partial performance of a contract for personal services is not an exception to the provisions of the Statute of Frauds. (citing Tobin & Tobin Ins. 97-264; ss. The actions that are restricted . However, such indemnification shall not include claims of, or damages resulting from, gross negligence, or willful, wanton or intentional misconduct of the indemnitee or its officers, directors, agents or employees, or for statutory violation or punitive damages except and to the extent the statutory violation or punitive damages are caused by or result from the acts or omissions of the indemnitor or any of the indemnitor's contractors, subcontractors, sub-subcontractors, materialmen, or agents of any tier or their respective employees. (3)"Professional services contract" means a written or oral agreement relating to the planning, design, construction, administration, study, evaluation, consulting, or other professional and technical support services furnished in connection with any actual or proposed construction, improvement, alteration, repair, maintenance, operation, management, relocation, demolition, excavation, or other facility, land, air, water, or utility development or improvement. - Andrew Douglas, P.A. Joint Administrative Procedures Committee (JAPC), Joint Committee on Public Counsel Oversight(JCPO), Joint Legislative Auditing Committee (JLAC), Joint Legislative Budget Commission (JLBC), Joint Select Committee on Collective Bargaining (JSCB), Office of Program Policy Analysis & Government Accountability (OPPAGA), Florida Legislative Committee on Intergovernmental Relations (LCIR), Joint Legislative Committee on Everglades Oversight (JCEO), Joint Legislative Sunset Committee (JCSC), Copyright 1995-2023 The Florida Legislature . 95-595, 95th Cong., 1st Sess. 636, 56 A. 98-166. 72-52; s. 935, ch. You can explore additional available newsletters here. The statute of frauds is a legal tenet set forth in 725.01, Fla. Stat. 2000-372; s. 10, ch. Statutes, Video Broadcast Download . Forms of action and technical forms for seeking relief and of pleas, pleadings, or motions are abolished. Get free summaries of new opinions delivered to your inbox! Contracts that cannot be performed within a one (1) year time period. 725.03 Newspaper subscription.--No person shall be liable to pay for any newspaper, periodical or other like matter, unless the person shall subscribe for or order the same in writing. A. Notwithstanding the foregoing, the monetary limitation on the extent of the indemnification provided to the owner of real property by any party in privity of contract with such owner shall not be less than $1 million per occurrence, unless otherwise agreed by the parties. Tech. 2021 Florida Statutes (Including 2021B Session) Title XLI STATUTE OF FRAUDS, FRAUDULENT TRANSFERS, AND GENERAL ASSIGNMENTS Chapter 725 UNENFORCEABLE CONTRACTS Entire Chapter SECTION 01 Promise to pay another's debt, etc. (1) As used in this section, the terms "proceeds," "security agreement," "security interest," and "secured party" shall be given the meanings prescribed for them in chapter 679. 2000-162; s. 11, ch. (2)Except as specifically provided in subsection (1), a professional services contract entered into with a public agency may not require that the design professional defend, indemnify, or hold harmless the agency, its employees, officers, directors, or agents from any liability, damage, loss, claim, action, or proceeding, and any such contract provision shall be void as against the public policy of this state. Statutes, Video Broadcast This includes the sale of land, easements, and mortgages. The journals or printed bills of the respective chambers should be consulted for official purposes. (2)Any violation of this section may be brought in the courts of this state by the individual upon whom the discrimination has been perpetrated in a civil action, and said individual shall be entitled to collect, not only compensatory damages, but, in addition thereto, punitive damages and reasonable attorney fees for a violation of this section. Additionally, the statute of frauds "should be strictly construed . Indemnification provisions in any such agreements, contracts, or guarantees may not require that the indemnitor indemnify the indemnitee for damages to persons or property caused in whole or in part by any act, omission, or default of a party other than: (b)Any of the indemnitor's contractors, subcontractors, sub-subcontractors, materialmen, or agents of any tier or their respective employees; or. Disclaimer/No Attorney Client Relationship: The hiring of an attorney is an important decision that should not be based solely upon advertisements. 1-2) Title II STATE ORGANIZATION (Ch. (1) No estate or interest of freehold, or for a term of more than 1 year, or any uncertain interest of, in, or out of any messuages, lands, tenements, or hereditaments shall be created, made, granted, transferred, or released in any manner other than by instrument in writing, signed in the presence of two subscribing witnesses by the party Florida Statutes Definitions Index (2022), Table Tracing Session Laws to Florida Statutes (2022), Index to Special and Local Laws (1971-2022), Index to Special and Local Laws (1845-1970). Chapter 725 Section 01 - 2022 Florida Statutes 2022 Florida Statutes < Back to Statute Search Title XLI STATUTE OF FRAUDS, FRAUDULENT TRANSFERS, AND GENERAL ASSIGNMENTS Chapter 725 UNENFORCEABLE CONTRACTS SECTION 01 Promise to pay another's debt, etc. The statute of frauds is a common law concept that requires written contracts for certain agreements to be binding. Corp. v. International Ladies Garment Workers Union, 734 F.2d 1020, 1021 (4th Cir. 725.01 Promise to pay another's debt, etc. Intended to incur, or believed or reasonably should have believed that he or she would incur, debts beyond his or her ability to pay as they became due. Disclaimer: These codes may not be the most recent version. Committee 857;Clark & Lewis v. Gardner, 91 Fla. 1059, 109 So. (1)Notwithstanding the provisions of s. 725.06, if a design professional provides professional services to or for a public agency, the agency may require in a professional services contract with the design professional that the design professional indemnify and hold harmless the agency, and its officers and employees, from liabilities, damages, losses, and costs, including, but not limited to, reasonable attorneys' fees, to the extent caused by the negligence, recklessness, or intentionally wrongful conduct of the design professional and other persons employed or utilized by the design professional in the performance of the contract. The journals or printed bills of the respective chambers should be consulted for official purposes. 227, 294, ch. As it relates to the time for performance, the general rule is that an oral contract for an indefinite time is not necessarily time barred by the Statute of Frauds; only if a contract could not possibly be performed within one year would it fall within the statute. No action shall be brought whereby to charge any executor or administrator upon any special promise to answer or pay any debt or damages out of her or his own estate, or whereby to charge the defendant upon any special promise to answer for the debt, default or miscarriage of another person or to charge any person upon any agreement made upon consideration of marriage, or upon any contract for the sale of lands, tenements or hereditaments, or of any uncertain interest in or concerning them, or for any lease thereof for a period longer than 1 year, or upon any agreement that is not to be performed within the space of 1 year from the making thereof, or whereby to charge any health care provider upon any guarantee, warranty, or assurance as to the results of any medical, surgical, or diagnostic procedure performed by any physician licensed under chapter 458, osteopathic physician licensed under chapter 459, chiropractic physician licensed under chapter 460, podiatric physician licensed under chapter 461, or dentist licensed under chapter 466, unless the agreement or promise upon which such action shall be brought, or some note or memorandum thereof shall be in writing and signed by the party to be charged therewith or by some other person by her or him thereunto lawfully authorized. However, such indemnification shall not include claims of, or damages resulting from, gross negligence, or willful, wanton or intentional misconduct of the indemnitee or its officers, directors, agents or employees, or for statutory violation or punitive damages except and to the extent the statutory violation or punitive damages are caused by or result from the acts or omissions of the indemnitor or any of the indemnitors contractors, subcontractors, sub-subcontractors, materialmen, or agents of any tier or their respective employees. Chapter 726 FRAUDULENT TRANSFERS. Florida Law Review Volume 44 Issue 5 Article 3 December 1992 Limiting Lender Liability in Florida: The Application of a Statute of Frauds to Credit Agreements Jeffrey A. Tochner Follow this and additional works at: https://scholarship.law.ufl.edu/flr Part of the Law Commons Publications, Help Searching Copyright 2000- 2023 State of Florida. Fla. Stat. 998. Therefore, do not convey any privileged or confidential information to Andrew Douglas, P.A. 1989); In re Speck, 798 F.2d 279, 279-80 (8th Cir. However, the doctrine of partial performance does not remove the bar of the statute of frauds for actions seeking damages based on the breach of an oral contract. History.--s. 1, ch. (3)Except as specifically provided in subsection (2), a construction contract for a public agency or in connection with a public agency's project may not require one party to indemnify, defend, or hold harmless the other party, its employees, officers, directors, or agents from any liability, damage, loss, claim, action, or proceeding, and any such contract provision is void as against public policy of this state. SECTION 105 Transfers fraudulent as to present and future creditors. The state of Florida has variations of the statute of frauds - a different one for varying transaction types. The transfer or obligation was disclosed or concealed. Having under the security agreement no right of sale or other disposition of the property, he or she knowingly secretes, withholds, or disposes of such property in violation of the security agreement. 725.05 Satisfaction for less than amount due. Under Florida Law, some common contracts where the statute of frauds applies are as follows: Contracts involving real estate transactions. P. 1.110 Download PDF As amended through February 1, 2023 Rule 1.110 - GENERAL RULES OF PLEADING (a) Forms of Pleadings. Schedule. According to the applicable case law, the statute of frauds cannot be used as a defense when an oral agreement has been fully performed by the other party. History.--s. 725.06 The materials contained within DouglasFirm.com, provide general information about the law and the law firm of Andrew Douglas, P.A. 67-254. 1, 2, ch. Florida Courts have consistently held that, despite the non-performing partys asserted defense, Florida law provides the performing party with possible counterarguments to the statute of frauds. Statutes, Video Broadcast (1) Except as otherwise provided in this section a contract for the sale of goods for the price of $500 or more is not enforceable by way of action or defense unless there is some writing sufficient to indicate that a contract for sale has been made between the parties and signed by the party against whom enforcement is sought or by his or her The State of Frauds is a common law defense which has been incorporated into statute in Florida. 2d 149, 153 (Fla. 1st DCA 1994) (holding that the doctrine of partial performance is not available in an action solely for damages at law); Miller Constr. 1020; 101 A.L.R. Corp. of Am. 2012). Florida Statutes. s. 1, ch. Javascript must be enabled for site search. DPBR Complaint: You received a Uniform Complaint. The indemnitee or its officers, directors, agents, or employees. 725.01 Promise to pay another's debt, etc. 192;Demps v. Hogan, 57 Fla. 60, 48 So. 192. (2014). Committee s. 10, Nov. 15, 1828; RS 1995; GS 2517; RGS 3872; CGL 5779; s. 10, ch. 86-161; s. 196, ch. 2001-211. 727.102. 1, ch. 2001-211. Copyright 2000- 2023 State of Florida. This web site is designed for general information only. All materials and services provided through this website are provided without warranty, for informational purposes only, and are to be used at the users own risk. 725.07 Discrimination on basis of sex, marital status, or race forbidden.--. Florida may have more current or accurate information. 2d 748, 750 (Fla. 3d DCA 1991) (holding that the doctrine of partial performance does not apply to personal service contracts); Johnson v. Edwards, 569 So. 2019 Florida Statutes Title XLI STATUTE OF FRAUDS, FRAUDULENT TRANSFERS, AND GENERAL ASSIGNMENTS Chapter 725 UNENFORCEABLE CONTRACTS Entire Chapter CHAPTER 725 UNENFORCEABLE CONTRACTS 725.01 Promise to pay another's debt, etc. Traditionally, the Statute of Frauds requires a signed writing in the following circumstances: Contracts in consideration of marriage. The statute of frauds applies only to executory and not to executed contracts. The rule thatthe rendition of services by the promisee in consideration of the promisors oral pledge to convey an interest in land is ordinarily treated as equivalent to payment of the consideration of the contract, and, while this is not in itself sufficient part performance, the rendition of services together with possession of the property to which the contract relates is a sufficient part performance to take the contract out of the statute. Skip to Navigation | Skip to Main Content | Skip to Site Map. The attorneys at Schecter Law have the knowledge and experience to tackle complex contractual disputes and can assist you or your business with all of your business contract litigation needs. 97-264; ss. Contracts which cannot be performed within one year. Fullperformanceof an oral agreement, however,mayremove the agreement from thestatuteoffraudsif the agreement is capable of being performed within a year and was, in fact, performed within one year. The statute of frauds requires that (1) "the contract must be a writing signed by the party against whom enforcement is sought," and (2) "the writing must contain all of the essential terms of the sale and these terms may not be explained by resort to parol evidence.". Intent of chapter. See, W.B.D., Inc. v. Howard Johnson Co., 382 So.2d 1323, 1327 (Fla. 1st DCA 1980); see also, Venditti-Siravo, Inc. v. City of Hollywood, Fla., 418 So.2d 1251, 1253 (Fla. 4th DCA 1982). In Florida, the answer is fairly straightforward, largely because the "Statute of Frauds" specifies which contracts must be in writing (and signed by the party facing enforcement, or the representative for said party) to be enforceable. v. Assocs. 1989); Sharon Steel Corp. v. National Fuel Gas Distrib. SECTION 201 Formal requirements; statute of frauds. 725.07 Discrimination on basis of sex, marital status, or race forbidden. Statute of Frauds in Florida. Justia Free Databases of US Laws, Codes & Statutes. STATUTE OF FRAUDS, FRAUDULENT TRANSFERS, AND GENERAL ASSIGNMENTS. 21902, 1943; s. 1, ch. Florida Statutes Definitions Index (2022), Table Tracing Session Laws to Florida Statutes (2022), Index to Special and Local Laws (1971-2022), Index to Special and Local Laws (1845-1970). Sign up for our free summaries and get the latest delivered directly to you. 97-102; s. 31, ch. 2005 florida code - statute of frauds, fraudulent transfers, and general assignments unenforceable contractschapter 725. title xli statute of frauds, fraudulent transfers, and general assignments. II. Five Types of Deeds to Transfer Real Estate Properties in Florida, Mortgage Vs.
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