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Pleading, Proof, and Preservation of Punitive Damages Claims: Tips for Florida Trial Lawyers and Appellate Attorneys

June 19, 2025

We’re excited to share that Partners Mihaela Cabulea, B.C.S., and William Linero, Jr., will join Kimberly K. Berman, B.C.S., Shareholder at Marshall Dennehey, to present at the 2025 FDLA Florida Liability Claims Conference at Lake Buena Vista, FL on Thursday, June 19, 2025.

Their presentation will dive into the evolving standard for leave to amend pleadings to assert punitive damages claims in light of the 2022 amendment to Florida Rule of Appellate Procedure 9.130(a)(3). Attendees will gain valuable insights into:

  • The current split among Florida’s district courts of appeal
  • The level of proof plaintiffs must offer to amend pleadings
  • Best practices for navigating varying district standards
  • How to preserve arguments while the issue is under review by Florida’s highest court