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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 \u2014 including two subscribing witnesses \u2014 so the POA was invalid and the deed executed under it void.

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