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PIERRE RICHARD STANICLAS v. DERIC L. BOGRAN

Citation: Not availableDocket: 22-0820

Court: District Court of Appeal of Florida; February 7, 2023; Florida; State Appellate Court

Original Court Document: View Document

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The opinion of the Third District Court of Appeal of Florida, filed on February 8, 2023, addresses appeals in cases numbered 3D22-820 and 3D22-1284, originating from the Circuit Court for Miami-Dade County under Judge Antonio Arzola. The appellant, Pierre Richard Staniclas, contests decisions involving appellees, including Deric L. Bogran and Alexander Gamarnik. The court affirmed the lower court's decisions, referencing the precedent set in Dade County v. Lambert, which establishes that a default by one defendant does not imply an admission of allegations against a co-defendant who contests them, even when liability is vicariously tied to the defaulting party. 

Additionally, the court ruled that the doctrine of collateral estoppel is inapplicable when the underlying case remains unresolved, emphasizing that for estoppel to apply, the matter must have been fully litigated with a final decision rendered by a competent jurisdiction. Furthermore, the opinion cited Section 768.72 of the Florida Statutes, which mandates that trial courts act as gatekeepers against claims for punitive damages lacking a reasonable evidentiary basis. The court's ruling is not final until the disposition of any timely filed motion for rehearing.