Milton v. Reyes
22 So. 3d 624 (Fla. 3rd DCA 2009) (October)
The defendant appealed a judgment for the plaintiff. The district court limited its reversal to the
fact that the jury was not given Florida Standard Jury Instruction 6.10, which instructs the jury to reduce future economic damages to present value. The plaintiff also cross appealed, challenging the trial court’s denial of attorney’s fees. The district court affirmed this ruling,
holding that his proposal for settlement did not include a certificate of service as required by
the Florida Rules of Civil Procedure 1.442.