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Florida: Divided 1st DCA Creates “Virtual” MMI Date for Those Suffering Lengthy Periods of TTD

In a split (8 to 3) decision, the full First District Court of Appeal of Florida recently withdrew its earlier panel opinion in Westphal v. City of St. Petersburg , 2013 Fla. App. LEXIS 3203 (Fla. 1st DCA Feb. 28, 2013), and receded from its previous en banc opinion in Matrix Employee Leasing, Inc. v...