harm); and (2) a departure from the essential requirements of the law." Nader v. Fla. Dep't of Highway Safety & 7 Epstein simultaneously filed his Motion for Default Against Defendant Rothstein on the Second Amended Complaint. (App. 17). Pursuant to Rule 1.440, the "action" will be at issue 20 days after the circuit cou

Media, LLC v. Bollea, 170 So. 3d 125, 131 (Fla. 2d DCA 2015). The petitioner need demonstrate only that (1) the 3 Epstein simultaneously filed his Motion for Default Against Defendant Rothstein on the Second Amended Complaint. (App. 17). Pursuant to Rule 1.440, the "action" will be at issue 20 days after the circuit cou

uit court denied the motion. (App. 18). The court recognized the case was not at issue at the time the motion to 5 Epstein simultaneously filed his Motion for Default Against Defendant Rothstein on the Second Amended Complaint. (App. 17). Pursuant to Rule 1.440, the "action" will be at issue 20 days after the circuit cou