• Tenancy by Entirety: in absence of fraud, deed conveying 2% undivided interest to wife and husband created tenancy by entirety in such interest even though that phrase not used in deed -- Roberts-Dude v. JP Morgan Chase Bank, N.A., No. 13–CV–80240–ROSENBAUM (S.D. Fla. Sept. 25, 2013) (affirming Bankruptcy Court’s order)