Mesa v. Citizens Property Insurance Corp.
In a first-party property insurance trial, the trial court allowed Citizens' corporate representative — who lacked personal knowledge — to testify about the contents and opinions in a field adjuster's report that was never admitted as a business record. The Third DCA held this was inadmissible hearsay, rejected the argument that Rule 1.310(b)(6) corporate-representative designation creates a trial hearsay exception, and found the error was not harmless because the adjuster's findings were the sole basis for the coverage denial.
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