Schmidt v. Stokes McMillan Antúnez Martinez-Lejarza P.A.
The Third DCA granted certiorari and quashed the portion of the post-judgment order compelling the petitioners to produce Rule 1.560(c) financial discovery, holding that full payment of the liquidated Confirmation Judgment within the rule's 45-day period 'satisfied' the judgment and eliminated any basis for the fact-information-sheet discovery. Because the fee entitlement was not yet liquidated, the paid judgment was reduced to a non-final, non-executable fee-entitlement order, making Rule 1.560 discovery premature.
Key facts
- The trial court entered a Confirmation Judgment confirming an AAA arbitration award, imposing a $176,833.59 money judgment against the petitioners, finding entitlement to attorney's fees under the parties' contract and section 682.15(3), and reserving jurisdiction to set the fee amount; it also ordered the petitioners to complete a Form 1.977 Fact Information Sheet under Rule 1.560(c).
- Forty-two days after entry, and within Rule 1.560(c)'s 45-day window, the petitioners paid the full money judgment plus accrued interest ($178,787.67).
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Holdings
- Once a judgment debtor pays the full liquidated amount of a judgment within Rule 1.560(c)'s 45-day period, the judgment is 'satisfied' as contemplated by the rule and the trial court…
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Why it matters
This opinion is a practical win for judgment debtors and clarifies that timely full payment of a liquidated judgment defeats a creditor's demand for Rule 1.560(c) fact-information-sheet discovery, even when the judgment… — full analysis with a trial
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