As we have previously noted, every new default on a monthly installment presents a new cause of action for statute of limitations purposes. See U.S. Bank Nat'l Ass'n v. Bartram, 140 So.3d 1007, 1014 (Fla. 5th DCA 2014). The Florida Supreme Court agreed with our reasoning on this point. See Bartram v. U.S. Bank Nat'l Ass'n, 211 So.3d 1009, 1019 (Fla. 2016). "Therefore, with each subsequent default, the statute of limitations runs from the date of each new default providing the mortgagee the right, but not the obligation, to accelerate all sums then due under the note and mortgage." Id.
U.S. Bank, N.A. v. Diamond, ___ So. 3d ___, Case No. 5D16–3609, 2017 WL 3795319, at *1 (Fla. 5th DCA Sept. 1, 2017).
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