Osher Khteeb and Erez Khteeb v. Helcim USA, Inc., et al.
The Fourth District reversed default final judgments entered in proceedings supplementary that made two alleged fraudulent transferees jointly and severally liable for a judgment creditor's entire unsatisfied judgment. Because FUFTA damages are unliquidated and section 726.109(2) caps recovery at the lesser of the value of the asset transferred or the amount needed to satisfy the creditor's claim, the trial court was required to hold an evidentiary hearing on the amount attributable to each transferee. Nothing in section 56.29(9) authorizes joint and several liability for the full outstanding judgment.
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