Sudano v. Collier County Sheriff’s Office / FSRMF

JCC Weiss (Ft. Myers)
(Tim Stanton) (10-1-2025) – Granted E/C’s request for reimbursement of reasonable costs.

The E/C sought costs of $8,761.65 as the prevailing party from a final compensation order in 2023. However, the claimant challenged the validity of the verified motion as well as the adjuster’s affidavit, arguing that neither was properly verified under section 92.525 since they were not notarized. The adjuster and both Rex Hurley and Tim Stanton chose to self-authenticate by properly signing in accordance with 92.525(2), while counsel for the claimant provided an oath or affirmation before a notary and signed the written declaration. The JCC overruled most of the claimant’s objections to charges in the verified motion except for a $500.00 charge for a doctor deposition, as it exceeded the $200.00 per hour cap under 440.13(10). The deposition exceeded an hour by eight minutes, and the claimant’s counsel argued that an additional $50.00 was proper, which the JCC accepted. Of note, the claimant objected to a charge for review of additional records as excessive but only raised this objection at final hearing, which was untimely. As such, the JCC awarded E/C reasonable costs in the amount of $8,511.65. Click here to view Order