Perdomo Vindel v. Stewart
In a dissolution appeal, the Third District held that Honduran bank records were improperly admitted as business records where the only 'certification' was a letter from the bank's Coral Gables international representative office that failed to recite any of the three foundational elements of section 90.902(11) and affirmatively showed the records were made and kept by the head office in Honduras. The court also reversed the denial of prejudgment interest on the equitable distribution award (noting express conflict with the First District's Iarussi decision) and the denial of attorney's fees for lack of need/ability-to-pay findings under section 61.16.
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