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.
Key facts
- Husband and wife disputed equitable distribution of assets in a dissolution case, with wife alleging husband concealed foreign assets in Honduras bank accounts.
- Trial court admitted Honduran bank records via a letter from the bank's Coral Gables representative office certifying the records as 'authentic copies' and awarded equitable distribution based on those records; trial court also denied prejudgment interest on the distribution award and denied wife's request for attorney's fees.
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Why it matters
The authentication analysis is directly transferable to any civil case seeking to admit foreign or out-of-state business records via certification under sections 90.803(6) and 90.902(11) \ letlanguage will not suffice… — full analysis with a trial
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