David Sasser v. Joleen Sasser
The Sixth District reversed an award of prejudgment interest, holding that a witness with no independent recollection cannot have her recollection 'refreshed' and may not testify from a third party's documents that were excluded as hearsay. Because the movant's testimony was not based on personal knowledge and the underlying documents were inadmissible, there was no competent substantial evidence supporting the amounts, and the court reversed without remand for additional evidence, directing entry of judgment removing the interest award.
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