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The full case caption appears at the end of this opinion.

We have for review Auto-Owners Insurance Co. v. Cannella, 737 So. 2d 1129 (Fla. 2d DCA 1999), which expressly and directly conflicts with the opinions in Liszka v. Silverado Steak & Seafood Co., 703 So. 2d 1226 (Fla. 5th DCA 1998), and Wong v. Gonzalez & Kennedy, Inc., 719 So. 2d 937 (Fla. 4th DCA 1998), review dismissed, 743 So. 2d 508 (Fla. 1999) (case voluntarily dismissed). We have jurisdiction. See Art. V, � 3(b)(3), Fla. Const. For the reasons expressed herein, we approve the decision of the Second District below.

 
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