Edward Saadi, a judgment creditor, obtained a $90,000 defamation judgment against Pierre Maroun in 2009. For nine years, Saadi could not collect the judgment. In 2018, Saadi initiated proceedings supplementary under Florida law, alleging that Maroun fraudulently transferred funds to a company he owned, Maroun's International, USCA11 Case: 22-11020 Document: 55-1 Date Filed: 10/27/2025 Page: 1 of 23 2 Opinion of the Court 22-11020 LLC, to evade payment. Saadi sought to void the transfer, seize a condominium purchased with those funds, and obtain a money judgment against the company. The district court granted summary judgment in favor of Maroun and the company, ruling that Saadi's claims were time-barred under Florida's fraudulent transfer statutes. The district court also denied Saadi's motion for discovery sanctions after the company failed to produce a representative for deposition. Saadi appealed, arguing that the district court misapplied Florida's fraudulent transfer laws and limitation periods.
The Eleventh Circuit determined that controlling precedent from the Florida Supreme Court was lacking on several dispositive issues, necessitating certification. The court identified a conflict between Florida's intermediate appellate courts regarding the remedies available under Florida Statute section 56.29. The Fourth District Court of Appeal held that section 56.29(3)(b) only allows for the voiding of transfers of personal property, while the Third District Court of Appeal held that money judgments are available under that section. The Eleventh Circuit certified questions on whether money judgments are available under section 56.29(3)(b), whether transferred funds must be identifiable, and whether the 2014 and 2016 amendments to the statute apply retroactively to claims accrued before the amendments. Additionally, the court certified questions on whether the Florida Uniform Fraudulent Transfer Act is subject to statutory tolling provisions under section 95.051 and whether fraudulent concealment of the tortfeasor's identity tolls the statute of limitations. The court found these questions determinative of the case because the answers would dictate whether Saadi's claims were time-barred.
The appeal is stayed pending the Florida Supreme Court's decision on the certified questions. If the Florida Supreme Court answers the questions in Saadi's favor, the case will be remanded to the district court to proceed on the merits of the fraudulent transfer claims. If the answers are unfavorable, the summary judgment in favor of Maroun and the company will likely stand. The district court's ruling on discovery sanctions is deferred until the state law questions are resolved.