Whitney Bank v. Grant, Case No. 1D16-5112 (Fla. 1st DCA 2017).
The five-year statute of limitations period in Florida Statute section 95.11(2)(b), and not the one-year statute of limitations of Florida Statute section 95.11(5)(h), applies in actions for deficiency proceedings arising out a short sale (as opposed to deficiency actions arising out of a foreclosure sale).
(courtesy of FL Bar Business Law Section)
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