• Homeowners Association: court may consult references commonly relied upon to supply accepted meanings of words not defined in agreement – The Grove at Harbor Hills Homeowners v. Harbor Hills Dev., L.P., No. 5D12-4542 (Fla. 5th DCA Dec. 13, 2013) (affirmed in part; reversed in part; remanded)
  • Default by Court: default by court improper under Fla. R. Civ. P. 1.500 where defendant’s answer, athough not filed within time required by court order, was served prior to entry of default – Thompson v. Hancock Bank, No. 5D13-1828 (Fla. 5th DCA Dec. 13, 2013) (reversed and remanded)
  • Clerk’s Default: clerk’s default improper where verification of service of process not sworn and notarized as required by Fla. Stat. § 48.194 – Chigurupati v. Progressive Am. Ins. Co., No. 4D13-2363 (Fla. 4th DCA Dec. 11, 2013) (affirmed in part and reversed in part)