• Attorneys’ Fees: trial court did not abuse its discretion in awarding attorneys’ fees and costs of $74,429 against bank following dismissal of foreclosure action as sanction for bank’s failure to comply with discovery orders – HSBC Bank USA, N.A., v. Williams, No. 3D12-1784 (Fla. 3rd DCA July 31, 2013) (affirming order of attorneys’ fees)
  • Failure to Prosecute: any filing made after receiving notice for failure to prosecute constitutes record activity precluding dismissal for failure to prosecute – JPMorgan Chase Bank v. Sarmiento, No. 3D12-2766 (Fla. 3rd DCA July 31, 2013) (reversing order of dismissal)