DOE v. PENCOV (2026)

We reverse the portion of the circuit court's order denying Jane Doe's motion to dismiss for lack of personal jurisdiction and remand for the court to apply Venetian Salami Co. v. Parthenais, 554 So. 2d 499 (Fla. 1989). On remand, the court should determine whether the affidavits and sworn materials can be harmonized. If the affidavits and sworn materials cannot be harmonized, the circuit court should conduct a limited evidentiary hearing to resolve the material jurisdictional facts.

We reverse the portion of the circuit court's order denying appellants’ motions to dismiss for forum non conveniens and remand for the court to conduct the analysis required by Kinney System, Inc. v. Continental Insurance Co., 674 So. 2d 86 (Fla. 1996), and Florida Rule of Civil Procedure 1.061. The circuit court should make express findings on the adequacy of the alternative forum, the private interest factors, the public interest factors, if applicable, and whether appellants may reinstate their suit in the alternative forum without undue inconvenience or prejudice.

Reversed and remanded.

Per Curiam.

Gross, Levine and Shepherd, JJ., concur.