BROWN v. BANK TRUST AS TRUSTEE FOR LS11 MASTER PARTICIPATION TRUST (2021)

Affirmed. See F.M.W. Props., Inc. v. Peoples First Fin. Sav. & Loan Ass'n, 606 So. 2d 372, 377–78 (Fla. 1st DCA 1992) (“We note, however, that the failure to organize arguments under cogent and distinct issues on appeal presents sufficient reason for an appellate court to decline consideration of a matter.”); cf. Redditt v. State, 84 So. 2d 317 (Fla. 1955); see also Faretta v. California, 422 U.S. 806, 834 n. 46, 95 S.Ct. 2525, 45 L.Ed.2d 562 (1975) (“The right of self-representation is not a license ․ not to comply with relevant rules of procedural and substantive law.”); Applegate v. Barnett Bank of Tallahassee, 377 So. 2d 1150, 1152 (Fla. 1979) (explaining that “[i]n appellate proceedings the decision of a trial court has the presumption of correctness and the burden is on the appellant to demonstrate error,” so “the lack of a trial transcript or a proper substitute” results in a record that is “inadequate to demonstrate reversible error” and requires affirmance); Schmidt v. Reyes, 274 So. 2d 242, 245 (Fla. 1st DCA 1973) (explaining that in absence of trial transcript and record of evidence adduced, we will assume “that the evidence adduced before the court was sufficiently competent and substantial to support the action taken”).

Per Curiam.

Rowe, C.J., and Roberts and Tanenbaum, JJ., concur.