overy could possible implicate punitive damages in excess of Epstein's offer to stipulate.. Ward v. Estaleiro Itaiai S/A. 541 F.Supp.2d 1344. 1357 (S.D. Fla. 2008)(The court caunot apply Rule 26 and allow Plaintiff to obtain discovery she seeks without any prior showing of a reasonable basis for recovery). See C