UBS Financial Services, Inc. v. Efron
Efron sued UBS's U.S. entity for an accounting and a pure bill of discovery to obtain records of accounts his parents opened with UBS's Swiss affiliate. Undisputed trial testimony showed the U.S. firm did not possess, access, or routinely use the Swiss firm's records and the two were separate corporate entities. The Third District reversed, holding that mere membership in the same global corporate family and shared brand name is insufficient to compel a domestic corporation to produce a foreign affiliate's records.
Key facts
- Efron sued UBS Financial Services, Inc. (U.S. entity) seeking an accounting and bill of discovery to obtain records of accounts his parents opened with UBS's Swiss affiliate.
- Undisputed trial testimony established that the U.S. entity and Swiss affiliate were separate corporate entities, and the U.S. firm did not possess, access, or routinely use the Swiss firm's records.
- +2 more key facts with a free trial
Why it matters
The opinion supplies a clear Florida standard for cross-border, affiliate-based discovery and accounting demands: control plus a legal right to obtain the records, proven by evidence of regular access — not corporate… — full analysis with a trial
🔒 Read the full opinion, holding & search the library
The full opinion PDF, the rules the court applied, our significance analysis, the background facts, and full-text search across every tracked Florida decision are available to members. Start a free 30-day trial — no credit card.
Not ready to sign up? Get the free Friday digest — the week's key Florida decisions by email, no login required.
Florida Court Tracker provides summaries of publicly available court opinions for informational and research purposes only. This is not legal advice and does not create an attorney–client relationship. Always verify holdings against the official opinion.