Topic: Sanctions

Dismissal for Fraud on the Court Not Available to Resolve Jury Questions – Herman v. Silver

In this medical malpractice case, a husband sued after his wife died allegedly from kidney failure after the defendant doctor performed surgery. At the trial, the husband testified about various issues, including his wife’s active lifestyle before the surgery, and date of the onset of kidney problems. After the trial, the husband quarrelled with his… Read more

Record Evidence Did Not Support Finding of Fraud on the Court – Ford v. Stimpson

In this products liability case, final judgment  was entered in favor of the defendant following a four-week jury trial.  The plaintiff alleged that the defendant had committed fraud on the court and sought to set aside the final judgment pursuant to Fla. R. Civ. P. 1.540(b)(3). The trial court granted plaintiff’s motion finding that the defendant (1) had destroyed… Read more

Court May Not Strike Plaintiff’s Voluntary Dismissal Unless Plaintiff Obtained Affirmative Relief – PINO V. THE BANK OF NEW YORK

 In this contentious foreclosure case, the lender filed multiple complaints that allegedly attached an inauthentic mortgage and assignment.  After receiving a sanctions motion by defense counsel, the lender dismissed the action without prejudice.  The lender then filed a second lawsuit in which it submitted yet another purported assignment with a different date and signed by… Read more

Rules Updates – New E-discovery and E-mail Service Rules Effective September 1st

Per the Florida Supreme Court’s Order amending the Florida Rules of Civil Procedure to implement service by email, the following rules have been updated: 1.080 Service of Pleadings, Orders, and Documents 1.170 Counterclaims and Crossclaims 1.351 Production of Documents and Things Without Deposition 1.410 Subpoena 1.440 Setting Action for Trial 1.442 Proposals for Settlement 1.510… Read more

Effective Teleservices, Inc. Et Al. v. Smith, 34 Fla. L. Weekly D1692b (Fla. 4th DCA Aug. 19, 2009)

In this case, appellee received an attorneys’ fee judgment based upon a sanction award for discovery violations by appellants.  The award, however, reflected an hourly rate that exceeded the rate actually billed to the client.  The court found this to be error and reversed. Effective Teleservices, Inc. et al. v. Smith, 34 Fla. L. Weekly D1692b… Read more