Carter Development ofMassachusetts, LLC v. Howard, Case No. 1D18-3075 (Fla. 1st DCA 2019).

An escrow agent only owes a duty per his escrow agreement and does not owe a fiduciary duty to non-parties to the escrow agreement.Magnolia Court, LLC v. Moon, LLC, Case No. No. 3D18-722 (Fla. 3d DCA 2019).

An unregistered foreign limited liability company is subject to service under Florida Statute section 605.0904(6),and such service is “personalservice” so that plaintiff does not have to comply with the personal service requirements of Florida Statutes Chapter 48.The Allegro at Boynton Beach, L.L.C. v. Pearson, Case No. 4D18-3387 (Fla. 4th DCA 2019).

A party may “deliver” a contract subject to a right of first refusal through discovery in pending litigation.