Merrill Lynch & Co. v. Valat International Holdings, Ltd.

Merrill Lynch & Co., Inc. (“MLC”) appeals from a final default judgment in favor of Valat International Holdings, Ltd. (“Valat”), and a non-final order denying its Florida Rule of Civil Procedure 1.540(b) motion for relief from the default judgment. We reverse.

In a separate proceeding, Valat obtained money judgments against three foreign corporations from El Salvador that failed to repay loans made by Hamilton Bank, Valat’s predecessor in interest. The three corporate loans were personally guaranteed by four individual members of the Safie family (“the Safie defendants”) who, along with the…