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3rd DCAMarch 15, 2023Affirmed🔬 Novel Issue

Parisi v. Quadri de Kingston

Case No. 3D2022-0793

A decedent executed a special power of attorney in Argentina, notarized and apostilled but without two subscribing witnesses; her agent then used it to quitclaim her Miami condominium to her boyfriend's LLC for no consideration three days before she died. The Third District affirmed partial summary judgment quieting title in the estate, holding that section 709.2105(2), Florida Statutes, requires strict compliance — including two subscribing witnesses — so the POA was invalid and the deed executed under it void.

Key facts

  • Decedent executed a special power of attorney in Argentina that was notarized and apostilled but lacked the two subscribing witnesses required by Florida law.
  • The agent used the defective power of attorney to quitclaim the decedent's Miami condominium to her boyfriend's LLC for no consideration three days before the decedent died.
  • +2 more key facts with a free trial

Why it matters

This is the Third District's clear statement that Florida's Power of Attorney Act demands strict, not substantial, compliance with the two-subscribing-witness requirement, and that the statutory portability rule does… — full analysis with a trial

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