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4th DCAJune 3, 2026Reversed and Remanded⭐ Notable

Abraham Bachtiar and Lian Lai v. Giselle Leonardo

Case No. 2024-2621

The Fourth DCA reversed a specific performance and damages judgment against sellers in a residential real estate contract dispute, holding that no enforceable oral modification or automatic extension existed because the buyer failed all three elements of the Okeechobee mutual-assent test and had not obtained final loan approval by the April 28 closing date. Because the buyer—not the sellers—was in default on the operative closing date, specific performance was unavailable.

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