7 So. 2d at 685 ("[T]he legislature is presumed to know the meaning of words and the rules of grammar[.]"); see also Gaffney v. Riverboat Servs. of Ind., Inc., 451 F.3d 424, 459 (7th Cir. 2006) (stating that use of the participle "including" generally implies an illustrative application) (citing Black's L

ON MALICIOUS PROSECUTION (App. 32, 41) (original emphasis). The footnote in question did not, and could not, raise a point on appeal. See Simkins Ind., Inc. v. Lexington Ins. Co., 714 So. 2d 1092, 1093 (Fla. 3d DCA 1998) ("an argument in a footnote does not elevate the matter to a point on appeal."); R.J