sue and rule on Edwards's request that it be precluded. See Tomlinson-McKenzie v. Prince, 718 So. 2d 394, 396 (Fla. 4th DCA 1998); Aguila-Rojas v. City Management Group Corp., 606 So.2d 765, 766 (Fla. 3d DCA 1992). In the case at hand, Edwards has engaged in a systematic effort to avoid any discovery into his own conduct