Pulles v. Onorato
The Third DCA affirmed the denial of a jury trial demand served more than a year after the answer, holding the trial court properly weighed the prejudice to the opposing party (discovery conducted in preparation for a bench trial, an unavailable witness, added expense) against the movant's interest. Judge Gooden specially concurred to untangle the competing 'abuse of discretion' and 'clearly erroneous' standards that have persisted in this line of cases since Wertman v. Tipping.
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