|
|
The 2025 Florida Statutes
|
|
|
|
|
F.S. 895.05895.05 Civil remedies.—(1) Any circuit court may, after making due provision for the rights of innocent persons, enjoin violations of the provisions of s. 895.03 by issuing appropriate orders and judgments, including, but not limited to:(a) Ordering any defendant to divest himself or herself of any interest in any enterprise, including real property. (b) Imposing reasonable restrictions upon the future activities or investments of any defendant, including, but not limited to, prohibiting any defendant from engaging in the same type of endeavor as the enterprise in which the defendant was engaged in violation of the provisions of s. 895.03. (c) Ordering the dissolution or reorganization of any enterprise. (d) Ordering the suspension or revocation of a license, permit, or prior approval granted to any enterprise by any agency of the state. (e) Ordering the forfeiture of the charter of a corporation organized under the laws of the state, or the revocation of a certificate authorizing a foreign corporation to conduct business within the state, upon finding that the board of directors or a managerial agent acting on behalf of the corporation, in conducting the affairs of the corporation, has authorized or engaged in conduct in violation of s. 895.03 and that, for the prevention of future criminal activity, the public interest requires the charter of the corporation forfeited and the corporation dissolved or the certificate revoked. (2)(a) All property, real or personal, including money, used in the course of, intended for use in the course of, derived from, or realized through conduct in violation of ss. 895.01-895.05 is subject to civil forfeiture to the state. (b) An investigative agency may, on behalf of the state, institute a civil proceeding for forfeiture in the circuit court for the judicial circuit in which real or personal tangible property, as described in paragraph (a) is located. An investigative agency may, on behalf of the state, institute a civil proceeding for forfeiture in a circuit court in the state regarding intangible property as described in paragraph (a). (c) Upon the entry of a final judgment of forfeiture in favor of the state, the title of the state to the forfeited property shall relate back:1. In the case of real property or a beneficial interest, to the date of filing of the RICO lien notice in the official records of the county where the real property or beneficial trust is located; if no RICO lien notice is filed, then to the date of the filing of any notice of lis pendens under s. 895.07(5)(a) in the official records of the county where the real property or beneficial interest is located; and if no RICO lien notice or notice of lis pendens is filed, then to the date of recording of the final judgment of forfeiture in the official records of the county where the real property or beneficial interest is located. 2. In the case of personal property, to the date the personal property was seized by the investigating agency. (d) If property subject to forfeiture is conveyed, alienated, disposed of, diminished in value, or otherwise rendered unavailable for forfeiture, the investigative agency may, on behalf of the state, institute an action in any circuit court against the person named in the RICO lien notice or the defendant in the civil proceeding or criminal proceeding, and the court shall enter final judgment against the person named in the RICO lien notice or the defendant in the civil proceeding or criminal proceeding in an amount equal to the fair market value of the property, together with investigative costs and attorney fees incurred by the investigative agency in the action. In the alternative, the court may order the forfeiture of any other property of the defendant up to the value of the property subject to forfeiture. If a civil proceeding is pending, such action shall be filed only in the court where the civil proceeding is pending. (e) The state shall dispose of all forfeited property as soon as commercially feasible. If property is not exercisable or transferable for value by the state, it shall expire. All forfeitures or dispositions under this section shall be made with due provision for the rights of innocent persons. The proceeds realized from such forfeiture and disposition shall be promptly distributed in accordance with the provisions of s. 895.09. (3) Property subject to forfeiture under this section may be seized by a law enforcement officer upon court process. Seizure without process may be made if:(a) The seizure is incident to a lawful arrest or search or an inspection under an administrative inspection warrant. (b) The property subject to seizure has been the subject of a prior judgment in favor of the state in a forfeiture proceeding based upon this section. (4) In the event of a seizure under subsection (3), a forfeiture proceeding shall be instituted promptly. Property taken or detained under this section shall not be subject to replevin, but is deemed to be in the custody of the law enforcement officer making the seizure, subject only to the order of the court. When property is seized under this section, pending forfeiture and final disposition, the law enforcement officer may:(a) Place the property under seal. (b) Remove the property to a place designated by court. (c) Require another agency authorized by law to take custody of the property and remove it to an appropriate location. (5) The Department of Legal Affairs, any state attorney, or any state agency having jurisdiction over conduct in violation of a provision of this act may institute civil proceedings under this section. In any action brought under this section, the circuit court shall proceed as soon as practicable to the hearing and determination. Pending final determination, the circuit court may at any time enter such injunctions, prohibitions, or restraining orders, or take such actions, including the acceptance of satisfactory performance bonds, as the court may deem proper. (6) Any aggrieved person may institute a proceeding under subsection (1). In such proceeding, relief shall be granted in conformity with the principles that govern the granting of injunctive relief from threatened loss or damage in other civil cases, except that no showing of special or irreparable damage to the person shall have to be made. Upon the execution of proper bond against damages for an injunction improvidently granted and a showing of immediate danger of significant loss or damage, a temporary restraining order and a preliminary injunction may be issued in any such action before a final determination on the merits. (7) The state, including any of its agencies, instrumentalities, subdivisions, or municipalities, if it proves by clear and convincing evidence that it has been injured by reason of any violation of the provisions of s. 895.03, shall have a cause of action for threefold the actual damages sustained and shall also recover attorneys’ fees in the trial and appellate courts and costs of investigation and litigation, reasonably incurred. In no event shall punitive damages be awarded. The defendant shall be entitled to recover reasonable attorneys’ fees and court costs upon a finding that the claimant raised a claim which was without substantial factual or legal support.(a) Either party may demand a trial by jury in any civil action brought pursuant to this subsection. (b) Any prevailing plaintiff under this subsection or s. 772.104 shall have a right or claim to forfeited property or to the proceeds derived therefrom superior to any right or claim the state has in the same property or proceeds. (8) A final judgment or decree rendered in favor of the state in any criminal proceeding under this act or any other criminal proceeding under state law shall estop the defendant in any subsequent civil action or proceeding under this act or under s. 772.104 as to all matters as to which such judgment or decree would be an estoppel as between the parties. (9) The Department of Legal Affairs may bring an action for a violation of s. 895.03 to obtain injunctive relief, civil penalties as provided in this subsection, attorney fees, and costs incurred in the investigation and prosecution of any action under this chapter.(a) A natural person who violates s. 895.03 is subject to a civil penalty of up to $100,000. Any other person who violates s. 895.03 is subject to a civil penalty of up to $1 million. Moneys recovered for civil penalties under this paragraph shall be deposited into the General Revenue Fund. (b) Moneys recovered by the Department of Legal Affairs for attorney fees and costs under this subsection shall be deposited into the Legal Affairs Revolving Trust Fund, which may be used to investigate and enforce this chapter. (c) In a civil action brought under this subsection by the Department of Legal Affairs, any party to such action may petition the court for entry of a consent decree or for approval of a settlement agreement. The proposed decree or settlement shall specify the alleged violations, the future obligations of the parties, the relief agreed upon, and the reasons for entering into the consent decree or settlement agreement. (10) The Department of Legal Affairs may, upon timely application, intervene in any civil action or proceeding brought under subsection (6) or subsection (7) if it certifies that, in its opinion, the action or proceeding is of general public importance. In such action or proceeding, the state shall be entitled to the same relief as if the Department of Legal Affairs had instituted the action or proceeding. (11) Notwithstanding any other provision of law, a criminal or civil action or proceeding under this chapter may be commenced at any time within 5 years after the conduct in violation of this chapter terminates or the cause of action accrues. If a criminal prosecution or civil action or other proceeding is brought, or intervened in, to punish, prevent, or restrain any violation of this chapter, the running of the period of limitations prescribed by this section with respect to any cause of action arising under subsection (6), subsection (7), or subsection (9) which is based in whole or in part upon any matter complained of in any such prosecution, action, or proceeding shall be suspended during the pendency of such prosecution, action, or proceeding and for 2 years following its termination. (12) The application of one civil remedy under any provision of this chapter does not preclude the application of any other remedy, civil or criminal, under this chapter or any other provision of law. Civil remedies under this chapter are supplemental, and not mutually exclusive. (13)(a) In addition to the authority to file a RICO lien notice set forth in s. 895.07(1), the Department of Legal Affairs, the Office of Statewide Prosecution, or the office of a state attorney may apply ex parte to a criminal division of a circuit court and, upon petition supported by sworn affidavit, obtain an order authorizing the filing of a RICO lien notice against real property upon a showing of probable cause to believe that the property was used in the course of, intended for use in the course of, derived from, or realized through conduct in violation of ss. 895.01-895.05. If the lien notice authorization is granted, the department shall, after filing the lien notice, forthwith provide notice to the owner of the property by one of the following methods:1. By serving the notice in the manner provided by law for the service of process. 2. By mailing the notice, postage prepaid, by certified mail to the person to be served at his or her last known address and evidence of the delivery. 3. If neither of the foregoing can be accomplished, by posting the notice on the premises. (b) The owner of the property may move the court to discharge the lien, and such motion shall be set for hearing at the earliest possible time. (c) The court shall discharge the lien if it finds that there is no probable cause to believe that the property was used in the course of, intended for use in the course of, derived from, or realized through conduct in violation of ss. 895.01-895.05 or if it finds that the owner of the property neither knew nor reasonably should have known that the property was used in the course of, intended for use in the course of, derived from, or realized through conduct in violation of ss. 895.01-895.05. (d) No testimony presented by the owner of the property at the hearing is admissible against him or her in any criminal proceeding except in a criminal prosecution for perjury or false statement, nor shall such testimony constitute a waiver of the owner’s constitutional right against self-incrimination. (e) A lien notice secured under this subsection is valid for a period of 90 days from the date the court granted authorization, which period may be extended for an additional 90 days by the court for good cause shown, unless a civil proceeding is instituted under this section and a lien notice is filed under s. 895.07, in which event the term of the lien notice is governed by s. 895.08. (f) The filing of a lien notice, whether or not subsequently discharged or otherwise lifted, shall constitute notice to the owner and knowledge by the owner that the property was used in the course of, intended for use in the course of, derived from, or realized through conduct in violation of ss. 895.01-895.05, such that lack of such notice and knowledge shall not be a defense in any subsequent civil or criminal proceeding under this chapter. History.—s. 5, ch. 77-334; s. 301, ch. 79-400; s. 2, ch. 81-141; s. 1, ch. 84-38; s. 5, ch. 84-249; s. 6, ch. 86-277; s. 3, ch. 87-139; s. 5, ch. 90-269; s. 76, ch. 95-211; s. 1447, ch. 97-102; s. 2, ch. 2016-84. Note.—Former s. 943.464.
| |
Annotations, Discussions, Cases:
Cases Citing Statute 895.05
Total Results: 52
605 So. 2d 56, 1992 WL 158189
Supreme Court of Florida | Filed: Jul 9, 1992 | Docket: 847019
Cited 75 times | Published
course of racketeering activity in violation of section 895.05(2)(a), Florida Statutes (1989). The trial court
750 F. Supp. 1109, 1990 U.S. Dist. LEXIS 15044, 1990 WL 176026
District Court, M.D. Florida | Filed: Oct 11, 1990 | Docket: 1041824
Cited 30 times | Published
Florida RICO claims is five years. Florida Statutes, § 895.05(10). The statute of limitations for Federal RICO
570 So. 2d 257, 1990 WL 154236
Supreme Court of Florida | Filed: Oct 11, 1990 | Docket: 1350025
Cited 27 times | Published
(making racketeering a first-degree felony) and § 895.05(2), Fla. Stat. (1989) (authorizing forfeitures
570 So. 2d 257, 1990 WL 154236
Supreme Court of Florida | Filed: Oct 11, 1990 | Docket: 1350025
Cited 27 times | Published
(making racketeering a first-degree felony) and § 895.05(2), Fla. Stat. (1989) (authorizing forfeitures
667 F. Supp. 802, 1987 U.S. Dist. LEXIS 7642
District Court, M.D. Florida | Filed: Aug 14, 1987 | Docket: 2028919
Cited 26 times | Published
The relevant limitation period is expressed in § 895.05(10), which states:
Notwithstanding any other provision
934 So. 2d 1238, 31 Fla. L. Weekly Supp. 461, 2006 Fla. LEXIS 1476, 2006 WL 1837930
Supreme Court of Florida | Filed: Jul 6, 2006 | Docket: 1461223
Cited 20 times | Published
the forfeiture is not governed by the FCFA. See § 895.05, Fla. Stat. (2005); Ruth v. Dep't of Legal Affairs
81 B.R. 119, 1987 U.S. Dist. LEXIS 12319, 1987 WL 31665
District Court, S.D. Florida | Filed: Dec 1, 1987 | Docket: 2511490
Cited 20 times | Published
to Marill's civil remedy pursuant to Fla.Stat. § 895.05(7), which mandates an award of treble damages
490 So. 2d 976
District Court of Appeal of Florida | Filed: May 7, 1986 | Docket: 976346
Cited 20 times | Published
Influenced and Corrupt Organizations) Act, Section 895.05(6), Florida Statutes (1983). Both statutes
684 So. 2d 181, 1996 WL 681383
Supreme Court of Florida | Filed: Nov 27, 1996 | Docket: 1482229
Cited 17 times | Published
CIVIL FORFEITURE ACTION BROUGHT PURSUANT TO SECTION 895.05(2), FLORIDA STATUTES?
2. DOES A CIRCUIT COURT
635 F. Supp. 582, 1986 U.S. Dist. LEXIS 25765
District Court, M.D. Florida | Filed: May 7, 1986 | Docket: 1614201
Cited 17 times | Published
for its injured citizens. See e.g., Fla.Stat. § 895.05(6), (7) (1985). In other words, RICO is not concerned
929 F. Supp. 2d 1255, 2013 WL 935432, 2013 U.S. Dist. LEXIS 33045
District Court, M.D. Florida | Filed: Mar 11, 2013 | Docket: 65989379
Cited 12 times | Published
72(a); see also Fla. Bar Rule 5-1.1(f); Fla. Stat. § 895.05; see Network Services, 617 F.3d at 1144-45 (requiring
781 So. 2d 1187, 2001 Fla. App. LEXIS 5048, 2001 WL 359272
District Court of Appeal of Florida | Filed: Apr 12, 2001 | Docket: 1293251
Cited 12 times | Published
initiated a civil suit which sought relief under section 895.05, Florida Statutes (1995).[1] Pursuant to a
727 So. 2d 199, 23 Fla. L. Weekly Supp. 485, 1998 Fla. LEXIS 1824, 1998 WL 650595
Supreme Court of Florida | Filed: Sep 24, 1998 | Docket: 1438077
Cited 10 times | Published
of alleged criminal activities pursuant to section 895.05 of the RICO statute, which states in pertinent
521 So. 2d 135, 1988 WL 1068
District Court of Appeal of Florida | Filed: Jan 14, 1988 | Docket: 578975
Cited 10 times | Published
Chapter 895 is known as the Florida RICO Act. Section 895.05, Florida Statutes, provides for forfeiture
461 So. 2d 265, 10 Fla. L. Weekly 107
District Court of Appeal of Florida | Filed: Jan 2, 1985 | Docket: 464651
Cited 10 times | Published
merit. Punitive damages, which are permitted in section 895.05(7), are appropriate where fraudulent conduct
570 So. 2d 1319, 1990 WL 66204
District Court of Appeal of Florida | Filed: May 18, 1990 | Docket: 2307529
Cited 9 times | Published
in nature, designed to correct problems in section 895.05(7), Florida Statute (1985), and that while
701 So. 2d 1170, 1997 Fla. App. LEXIS 11137, 1997 WL 609982
District Court of Appeal of Florida | Filed: Oct 3, 1997 | Docket: 1424935
Cited 6 times | Published
Florida Statutes ("RICO"),[1] in particular section 895.05, Florida Statutes ("civil RICO"), and section
647 So. 2d 1022, 1994 WL 706302
District Court of Appeal of Florida | Filed: Dec 21, 1994 | Docket: 437251
Cited 6 times | Published
without substantial fact or legal support." Section 895.05(7), Florida Statutes (1993), contains a virtually
683 F. Supp. 795, 1988 U.S. Dist. LEXIS 7944, 1988 WL 32647
District Court, S.D. Florida | Filed: Apr 12, 1988 | Docket: 2121397
Cited 6 times | Published
and Fernandez.
Count X: Florida RICO (Fla.Stat. § 895.05)
This count is the Florida counterpart to the
618 F. Supp. 513, 1984 U.S. Dist. LEXIS 21925
District Court, N.D. Florida | Filed: Nov 16, 1984 | Docket: 1367380
Cited 6 times | Published
Statutes § 943.462 and § 943.464, now § 895.03 and § 895.05, the Florida RICO Act, and demands treble damages
620 So. 2d 757, 1993 WL 184570
Supreme Court of Florida | Filed: Jun 3, 1993 | Docket: 1387569
Cited 5 times | Published
insurance claims include investigative expenses); § 895.05(7), Fla. Stat. (1989) (State may recover damages
590 So. 2d 437, 1991 WL 181928
District Court of Appeal of Florida | Filed: Sep 11, 1991 | Docket: 1512672
Cited 5 times | Published
of the crime as to the racketeering charge, section 895.05(10), Florida Statutes (1987), and four years
713 F. Supp. 1420, 1989 U.S. Dist. LEXIS 6148, 1989 WL 59098
District Court, M.D. Florida | Filed: May 19, 1989 | Docket: 1619945
Cited 4 times | Published
statutes applicable to this lawsuit, Fla.Stat. § 895.05(7) (1984), 812.035(7) (Supp.1984), track the federal
541 So. 2d 1324, 1989 WL 36170
District Court of Appeal of Florida | Filed: Apr 18, 1989 | Docket: 470681
Cited 4 times | Published
which was the first judicial treatment of section 895.05(6), Florida Statutes (1985). With due deference
145 So. 3d 133, 2014 WL 2755838, 2014 Fla. App. LEXIS 9214
District Court of Appeal of Florida | Filed: Jun 18, 2014 | Docket: 60242632
Cited 3 times | Published
governed by a five-year statute of limitations. § 895.05(10), Fla. Stat. (2003).
ANALYSIS
The question
614 So. 2d 632, 1993 WL 46125
District Court of Appeal of Florida | Filed: Feb 24, 1993 | Docket: 449407
Cited 3 times | Published
their further prosecution for violation of section 895.05(3), Florida Statutes (1991), known as Florida
583 So. 2d 347, 1991 WL 110461
District Court of Appeal of Florida | Filed: Jun 21, 1991 | Docket: 1684158
Cited 3 times | Published
forfeiture of the appellant's homestead pursuant to section 895.05(2)(a), Florida Statutes (1989), on grounds
699 F. Supp. 271, 1988 U.S. Dist. LEXIS 15256, 1988 WL 120806
District Court, S.D. Florida | Filed: Jun 27, 1988 | Docket: 885156
Cited 3 times | Published
V, 18 U.S.C. § 1962(c) (the federal RICO Act); § 895.05 of the Florida Statutes (Florida RICO); Count
828 F.2d 686
Court of Appeals for the Eleventh Circuit | Filed: Sep 28, 1987 | Docket: 66228619
Cited 3 times | Published
statute of limitations had expired. See Fla.Stat. § 895.-05(10); Agency Holding Corp. v. MalleyDuff & Assoc
661 So. 2d 901, 1995 WL 599987
District Court of Appeal of Florida | Filed: Oct 13, 1995 | Docket: 1163014
Cited 2 times | Published
*903 during the pendency of this action, under Section 895.05(5), Florida Statutes;
2. Order forfeiture of
617 So. 2d 753, 1993 WL 116702
District Court of Appeal of Florida | Filed: Apr 16, 1993 | Docket: 458021
Cited 2 times | Published
resulting from including its RICO predecessor, section 895.05, in the criminal statutes, was remedial, and
576 So. 2d 870, 1991 WL 35356
District Court of Appeal of Florida | Filed: Mar 19, 1991 | Docket: 1242809
Cited 2 times | Published
court to issue a temporary injunction under section 895.05(6), even though the common law elements of
576 So. 2d 870, 1991 WL 35356
District Court of Appeal of Florida | Filed: Mar 19, 1991 | Docket: 1242809
Cited 2 times | Published
court to issue a temporary injunction under section 895.05(6), even though the common law elements of
937 So. 2d 1211, 2006 WL 2683294
District Court of Appeal of Florida | Filed: Sep 20, 2006 | Docket: 459715
Cited 1 times | Published
criminal attorney's fees and costs pursuant to section 895.05(7), Florida Statutes. The Department of Legal
576 So. 2d 864, 1991 WL 35330
District Court of Appeal of Florida | Filed: Mar 19, 1991 | Docket: 1242705
Cited 1 times | Published
him, or seek a cease and desist order under section 895.05, Florida Statutes (1989), to prevent further
68 B.R. 399, 1986 Bankr. LEXIS 4684
United States Bankruptcy Court, S.D. Florida. | Filed: Dec 30, 1986 | Docket: 1100535
Cited 1 times | Published
herein have a civil remedy pursuant to Fla.Stat. § 895.05(7) which mandates an award of treble damages and
District Court of Appeal of Florida | Filed: Apr 3, 2024 | Docket: 68307144
Published
realized through
racketeering activity under section 895.05(2)(a), Florida Statutes (2022).
• The
District Court of Appeal of Florida | Filed: Jun 1, 2022 | Docket: 63352036
Published
that the five-year statute of limitations in section
895.05(10), Florida Statutes (2003), barred his conviction
District Court of Appeal of Florida | Filed: Sep 29, 2021 | Docket: 60496868
Published
Influenced and Corrupt
Organization) Act. See § 895.05, Fla. Stat. (2015) (setting forth the
civil remedies
270 So. 3d 447
District Court of Appeal of Florida | Filed: Mar 28, 2019 | Docket: 14824711
Published
Influenced and Corrupt Organizations Act (“RICO”), section
895.05, Florida Statutes. The property seized is alleged
172 So. 3d 450, 2015 Fla. App. LEXIS 1800, 2015 WL 543365
District Court of Appeal of Florida | Filed: Feb 11, 2015 | Docket: 2633391
Published
prior incident of racketeering conduct
Section 895.05(2)(a) provides a forfeiture remedy for violations
135 So. 3d 402, 2014 WL 470721, 2014 Fla. App. LEXIS 1611
District Court of Appeal of Florida | Filed: Feb 7, 2014 | Docket: 60239615
Published
violations of [the gambling laws] is found within F.S. 895.05(3) and F.S. 932.702. Florida Statute *405932
987 So. 2d 173, 2008 Fla. App. LEXIS 10896
District Court of Appeal of Florida | Filed: Jul 16, 2008 | Docket: 64855252
Published
or disposition or execution of a court order.” § 895.05(18). It does not necessarily mean “secure” detention
902 So. 2d 187, 2005 Fla. App. LEXIS 2470, 2005 WL 475412
District Court of Appeal of Florida | Filed: Mar 2, 2005 | Docket: 64838386
Published
counsel.
Viragen also sought fees pursuant to section 895.05(7), for bringing a frivolous civil RICO claim
791 So. 2d 1197, 2001 Fla. App. LEXIS 11481, 2001 WL 929827
District Court of Appeal of Florida | Filed: Aug 17, 2001 | Docket: 64807589
Published
against the appellants. “The civil remedies of section 895.05 are available for violations of chapter 895
766 So. 2d 356, 2000 WL 985883
District Court of Appeal of Florida | Filed: Jul 19, 2000 | Docket: 64800151
Published
temporary injunction is affirmed.
Affirmed.
. Section 895.05(6), Florida Statutes, (1999) states, in
pertinent
692 So. 2d 933, 1997 Fla. App. LEXIS 3221, 1997 WL 163009
District Court of Appeal of Florida | Filed: Apr 9, 1997 | Docket: 64773089
Published
of racketeering are subject to forfeiture under § 895.05(2)(a).
In the case sub judice, the promissory
50 F.3d 908, 1995 WL 146496
Court of Appeals for the Eleventh Circuit | Filed: Apr 20, 1995 | Docket: 64020265
Published
prevailing Florida RICO defendants under Fla.Stat. § 895.05(7). On June 9, 1992, a magistrate judge’s Report
13 F.3d 1493
Court of Appeals for the Eleventh Circuit | Filed: Feb 10, 1994 | Docket: 64016018
Published
Caggiano concerned a state forfeiture statute, § 895.05(2)(a), Florida Statutes (1989). The question here
595 So. 2d 1073, 1992 Fla. App. LEXIS 2503, 1992 WL 45703
District Court of Appeal of Florida | Filed: Mar 13, 1992 | Docket: 64666113
Published
notices against appellees’ properties pursuant to section 895.05(12), Florida Statutes (1989). On October 3
939 F.2d 1472, 1991 WL 154275
Court of Appeals for the Eleventh Circuit | Filed: Aug 30, 1991 | Docket: 66265468
Published
reasonable attorney’s fee.” Former Fla.Stat.Ann. § 895.05(7), applicable to this law suit, tracked the federal
578 So. 2d 335, 1991 Fla. App. LEXIS 2969, 1991 WL 45212
District Court of Appeal of Florida | Filed: Apr 2, 1991 | Docket: 64658236
Published
appellant. This lien notice was authorized under section 895.05(12)(a), Florida Statutes (1989), of the RICO
