Martinez v. Weinstein
The Fourth DCA reversed the dismissals, holding that the August 2024 supplemental complaints asserting Chapter 726 fraudulent-transfer claims related back to the June 2021 motion to commence proceedings supplementary for statute-of-limitations purposes. Because a proceeding supplementary is a special statutory proceeding under Rule 1.010 commenced by motion and affidavit, the motion to commence functions as the equivalent of a pleading to which the later supplemental complaints relate back under Rule 1.190(c).
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