How does Plaintiff bring a partial motion [ on just the substantive counts] for default by Circuit Court whilst simultaneously preserving the right to make discovery and continue the reserved rights to later apply to Court for leave to bring punitive damages claim. Is it permissible to obtain default by Court on substantive counts and not on the reservation retained under Fl stat. §786.72 ?
If sufficient evidence is obtained on discovery to warrant an application for leave to seek punitive damages I will at that point appoint an attorney.
Please take it as read that I have elected not to hire an attorney and it is not necessary to warn me of the dangers faced by acting pro se.
If you have elected not to hire an attorney, and expect lawyers to tell you how to handle specific matters in a litigation case, then your question would violate the TOS which specifically provides that your not to rely upon the response from lawyers as actual legal advice as this would be the intent of your inquiry. This stated, regardless of your game plan to the contrary, doing a bunch of litigation and THEN hiring a lawyer later is typically not only counter-productive it will typically damage your case. This is particularly true when when you don't have an experienced litigator handling the discovery process, as pro-se litigants are easily stonewalled, and this would usually result in you NOT getting the evidence necessary to support punitive damages let alone the actual damages.
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