Florida Statutes
Fla. Stat. § 90.956 (2025)
Summaries.
✓ 2025 Florida Statutes — current through the 2025 Regular Session
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90.956 Summaries.—When it is not convenient to examine in court the contents of voluminous writings, recordings, or photographs, a party may present them in the form of a chart, summary, or calculation by calling a qualified witness. The party intending to use such a summary must give timely written notice of his or her intention to use the summary, proof of which shall be filed with the court, and shall make the summary and the originals or duplicates of the data from which the summary is compiled available for examination or copying, or both, by other parties at a reasonable time and place. A judge may order that they be produced in court.
History.—s. 1, ch. 76-237; s. 1, ch. 77-77; s. 22, ch. 78-361; s. 1, ch. 78-379; s. 503, ch. 95-147.
Notes of Decisions
Cited in 25
cases (1 in the last 5 years), 1982–2025 · leading case: Cayea v. Citimortgage, Inc., 138 So. 3d 1214 (Fla. 4th DCA 2014).
Cayea v. Citimortgage, Inc., 138 So. 3d 1214 (Fla. 4th DCA 2014). “See § 90.956, Fla. Stat. (2012) (“When it is not convenient to examine in court the contents of voluminous writings, recordings, or photographs, a party may present them in the form of a chart, summary, or calculation by calling a qualified witness”).”
Tallahassee Hous. v. Unemp. Appeals Com'n, 483 So. 2d 413 (Fla. 1986). “Although *415 section 90.956, Florida Statutes (1983), permits the introduction of a summary into evidence when it is impractical to examine the records upon which it is based, that section provides that [t]he party intending to use such a summary must give timely written notice…”
HEALTH OPTIONS v. Palmetto Pathology Servs., 983 So. 2d 608 (Fla. 3d DCA 2008). “Specifically, HOI contends that PPS did not provide "timely written notice" of an intention to use the revised summary, and that PPS did not make the revised summary available at a "reasonable time and place.”
Batlemento v. Dove Fountain, Inc., 593 So. 2d 234 (Fla. 5th DCA 1991). “EVIDENTIARY ISSUES Appellants also complain that the trial court, in violation of the requirements of section 90.956, Florida Statutes (1989), permitted appellees to introduce a written damage summary consisting of all sums spent by the Maniacis on the Casa Mia restaurant.”
T/f Sys., Inc. v. Malt, 814 So. 2d 511 (Fla. 4th DCA 2002). “We find that the trial court properly admitted exhibit 23 under section 90.956, Florida Statutes (2000), as a summary of the invoices prepared by appellants and furnished to Malt.”
Moore v. Gillett, 96 So. 3d 933 (Fla. 2d DCA 2012). “Plaintiffs’ counsel proposed to use the summary at trial in accordance with section 90.956, Florida Statutes (2010). At the beginning of the trial, plaintiffs’ counsel filed a notice dropping a number of Mrs.”
S. Kornreich & Sons v. Titan Agencies, Inc., 423 So. 2d 940 (Fla. 3d DCA 1982). “NOTES [1] § 90.956, Fla. Stat. (1977) provides: When it is not convenient to examine in court the contents of voluminous writings, recordings, or photographs, a party may present them in the form of a chart, summary, or calculation by calling a qualified witness.”
Stokus v. Phillips, 651 So. 2d 1244 (Fla. 2d DCA 1995). “He urged the notion that those statements were, in effect, "summaries" of evidence, reliance upon which offended section 90.956, Florida Statutes (1991). His contention was bottomed on the claim that the proponent of a summary is required to serve timely written notice upon the…”
McKown v. State, 46 So. 3d 174 (Fla. 4th DCA 2010). “5th DCA 2003), the admission into evidence of a compilation of checks written on a victim’s bank account was reversed because “[n]o evidence was adduced identifying who had made the compilation, nor was any further predicate shown that would render it admissible as a summary…”
Brake v. Murphy, 736 So. 2d 745 (Fla. 3d DCA 1999). “See generally § 90.956, Fla. Stat. (1997) (evidence code provision governing summaries).”
Zanja Walters v. Richard Petgrave, 248 So. 3d 1202 (Fla. 4th DCA 2018). “As for the mother’s other arguments on appeal, we note that, on remand, the mother may renew her attempt to use charts and summaries to establish the father’s income, provided that the mother complies with section 90.956, Florida Statutes (2017), and provided that the summaries…”
Marks v. Marks, 576 So. 2d 859 (Fla. 3d DCA 1991). “Equally misplaced is the wife's reliance on section 90.956, Florida Statutes (1989). The requirements pertaining to expert testimony are those found in sections 90.”
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