is uncertain whether Mr. Porcaro is actually dead. Great Southern presented deposition evidence from which a jury could reasonably determine that Mr. Porcaro may have fled to avoid prosecution and, thus, still be alive. Furthermore, the probate court’s ruling does not constitute prima facie evidence of Mr. Porcaro’s death. While a death certificate obtained through probate proceedings provides some evidence of death, death certificates no longer have prima facie evidentiary value outside the context of probate proceedings. See Ch. 97-287, § 106, at 4169, Laws of Fla. (eliminating provision in section 382.025(5), Florida Statutes, that provided for such prima facie evidentiary value in “all courts and cases”); Branca by Branca v. Sec. Benefit Life Ins. Co., 773 F.2d 1158 (11th Cir.1985) (<HOLDING>). Therefore, the burden was on Mrs. Porcaro to
holding that a plaintiff must merely make out a prima facie case to withstand a motion to dismiss for lack of personal jurisdiction where there has been no evidentiary hearing holding that a prima facie case is subject to independent review recognizing confusion caused by prima facie language holding the plaintiff satisfies the burden of a prima facie case by a preponderance of the evidence holding section 731103 florida statutes providing for prima facie evidentiary value upon the presentation of enumerated evidence of death applies only in probate proceedings