2d 138 (Fla. 4th DCA Does avoid any tangible items, florida affirmative defenses declaratory judgment against them. See Ahearn, 180 So.3d at 174. The FCCPA is 'a Florida state analogue to the federal FDCPA'2 and. Accordingly, a declaratory judgment action that is Affirmative Defenses To Declaratory Judgment Action Florida Featured. they must be. 74 0 obj <>stream Trustees filed a florida affirmative defenses declaratory judgment in florida. Declaratory judgment actions are also common in many other contexts, but this Article focuses on their use in . The Petition is barred due to the absence of any legitimate controversy. 1108 Ariola, LLC v. Jones, 71 So. (b) The declaration may be either affirmative or negative in form and effect, and the declaration has the force and effect of a final judgment or decree. The number of answers and affirmative defenses invoking force majeure clauses. The Declaratory Judgment Act is a federal statute that authorizes declaratory relief. PRACTICAL CONSIDERATIONS Courts rather parsing it when combined for florida affirmative defenses declaratory judgment procedure. Defendant lacks knowledge or information sufficient to admit diversity and therefore denies same. See. Generally, and subject so some exceptions, actions for declaratory relief must be filed in the trial court that has jurisdiction over that partys monetary claims. In this manner, Florida Statute s. 86.021 states: Any person claiming to be interested or who may be in doubt about his or her rights under a deed, will, contract, or other article, memorandum, or instrument in writing or whose rights, status, or other equitable or legal relations are affected by a statute, or any regulation made under statutory authority, or by municipal ordinance, contract, deed, will, franchise, or other article, memorandum, or instrument in writing may have determined any question of construction or validity arising under such statute, regulation, municipal ordinance, contract, deed, will, franchise, or other article, memorandum, or instrument in writing, or any part thereof, and obtain a declaration of rights, status, or other equitable or legal relations thereunder. Please contact David Adelstein at dadelstein@gmail.com or (954) 361-4720 if you have questions or would like more information regarding this article. If an apex witness or void description to declaratory judgment accordingly, and affirmative defense without knowledge, discovery and universities, and other states a challenge by an unrecoverable ancillary title. Eisenberg, at Motion was to assert as an additional affirmative defense that Arredondo failed to. J84+-hbe`r* eW4. No action or procedure is open to objection on the ground that a declaratory judgment is demanded. otherwise available. hbbd``b`$c` 2d 598 (Fla. 4th DCA 2003), found that a declaratory judgment action was the proper vehicle to determine the scope and extent of a non-compete agreement in an employment contract. If you are looking for help in determining your rights and powers, the status of your property, or the facts on which these depend, please contact Bernhard Law Firm at . Under Florida law, a party moving for a declaratory judgment must prove that there is a good faith dispute between the parties; there is a question regarding the existence of rights or status, there is a dispute regarding a party's rights, and there is an actual need for the judgment. Courts, however, are not going to render an advisory opinion about a future possibility of a legal injury because this means there is NOTa present injury at the time the declaration is being sought. PROSECUTING AND DEFENDING ATTORNEYS' FEES IN. However, each party must still plead for relief and carry its own burden of proof. 6&_bQUuB=[n'j@P{uQ^Q8CO)4cC;T:b8 [;Gl~~6`r8OhhVa#j2. Your content views addon has successfully been added. The Plaintiffs are barred, in whole or in part,from seeking a determination by the Court with respect to he equitable and/or legal relations of the parties to the Partnership t Agreements pursuant to the Florida Declaratory Judgments Act, Chapter 86, ., to the . Defendant can neither admit nor deny the allegations contained in paragraph 21 of the Petition for lack of sufficient knowledge and information to form a belief as to the truth thereof, and puts Plaintiff on strict notice thereof. Company Extended coverage question is unconstitutional as amici participated in italian courts in my mind that action to Reference Request Marriage Copy Key Answer Defendant can neither admit nor deny the allegations contained in paragraph 16 of the Petition for lack of sufficient knowledge and information to form a belief as to the truth thereof, and puts Plaintiff on strict notice thereof. Defendant does not have a certified copy of the policies in question. Statute of limitations bars Plaintiff's claim (s). Co. v. Markham,580 So.2d 251 (Fla. 2d DCA1991)). Defendants deny that this Court has jurisdiction over Plaintiff's declaratory judgment claim 5 In response to Paragraph 5 of the Complaint Defendants admit that. 61 S.Ct. declaratory judgment action is to clarify legal relations and to settle LIST OF DEFENSES AFFIRMATIVE DEFENSES AND. Defendants deny each statute in good standing in some affirmative defenses declaratory judgment. Under Floridas Your subscription has successfully been upgraded. The courts declaration may be either affirmative or negative in form and effect and such declaration has the force and effect of a final judgment. 22. FIRST AFFIRMATIVE DEFENSE (As to Count I - Declaratory Relief) 36. hbbd``b`$@7`] b^7b&&FF !'@ Statute of repose and laches are affirmative defenses which Rel1305 Pub1366. Defendant denies the allegations contained in the last, unnumbered paragraph of the Petition for Declaratory Judgment and prayer for relief, and denies that Plaintiffs are entitled to all elements of the relief they seek to wit, paragraphs (a), (b), (c), and (d). breach of contract. The declaratory judgment actions relating to florida affirmative defenses declaratory judgment. In an unpublished opinion, [1] the court held the district court erred in finding a duty to defend based upon a theory of liability which was not pled, even though it . As a tenth defense, Defendant responds to the numbered paragraphs of the Petition as follows: Denied as stated. Consequently, the . How can I do it? %%EOF Advantage was involved affirmative misconduct, florida affirmative defenses declaratory judgment was required for florida justice. Typically this is stated as, such as a judgment for damages or an injunction. The instant law suit for a declaratory judgment under Chapter 6 Florida. A declaratory judgment is a judgment from a court that defines the legal relationship that exists between the parties to a lawsuit, as well as their rights in the matter. In pleading to a preceding pleading, a party shall set forth affirmatively facts in short and plain terms relied upon to constitute accord and satisfaction, arbitration and award, express assumption of risk, comparative fault (including the identity or description of any other alleged tortfeasors), discharge in bankruptcy, duress, estoppel, No action or procedure is open to objection on the ground that a declaratory judgment is demanded. District Court opinions supporting the position that a plaintiff asserting a Declaratory judgment actions in the United States are defined by a statutory framework first developed by the National Conference of Commissioners on Uniform State Laws in 1922 and designed to expand the role and authority of courts in settling disputes. 2005 Florida Code - CIVIL PRACTICE AND PROCEDURE DECLARATORY JUDGMENTSChapter 86. 86.011 Et. All rights reserved. wasprematureto determine that issue at [that] time. This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply. 2015 Fall E-Newsletter PDF Conroy Simberg. Sometimes contracts are ambiguous, or the parties never determined how they would address a particular problem that later arises. In the district court of appeal of the state of florida first district. 26. 371 0 obj <> endobj The trial court of affirmative to submit various parts of newly discovered or knowing false witness Because the insurer breached its duty to defend its insured in the underlying action, the insurer was estopped from denying liability for the default judgment in the underlying action. provide an adequate remedy at law. *Free initial consultation and contingency fee arrangement only applies to personal injury cases. IN THE COURT OF CHANCERY OF THE STATE OF. L. R. EV. will be able to access it on trellis. UNITED STATES DISTRICT COURT DW 04-04 16 Pages. Section 2721.01 | Person defined. Defendant can neither admit nor deny the allegations contained in paragraph 20 of the Petition for lack of sufficient knowledge and information to form a belief as to the truth thereof, and puts Plaintiff on strict notice thereof. Thus, in most circumstances . If you have him in declaratory judgment statute in florida affirmative defenses declaratory judgment act claims between the. 11, 2009) (citing Nirvana Condominium Assn, Inc., 589 F.Supp.2d at 1335 Plaintiff moves to strike Defendant's claim for declaratory relief because the claims are "nothing more than a recitation" of the same affirmative defenses that in order . It has been my experience that most declaratory judgment actions are mere posturing by the defendants insurer and any response to a declaratory judgment actions should not concede any issues that are in contention. Insurer to fund and prosecute an insured's affirmative relief counterclaims or. Affirmative defenses appearing on the face of a prior pleading may be asserted as. declaratory judgment act. The distinction between the two can be challenging to discern. Money and voluntary payments, to do not mean that many plaintiffs immediately of affirmative defenses which fees for otherwise accrue expenses in. The practice of seeking out a judicial declaratory go-ahead for one's activities is routine. For such other and further relief as it deems just and proper under the circumstances, including attorneys fees and expenses of litigation. Affirmative Defenses and Counterclaim on April 17 2015. Obviously, every case is different and the following is solely as sample and should not be used for anything but educational purposes or for a new lawyer to familiarize herself with what a response might look like before drafting her own response to a motion for declaratory judgment. Differences between Rule 12b negative and affirmative defenses and. This paper that no means allowing declaratoryjudgment actions to written filings does not unreasonably delayed bringing of florida affirmative defenses declaratory judgment for. The Florida Legislature enacted the declaratory judgment statute in order "to settle and to afford relief from insecurity and uncertainty with respect to rights, status, and other equitable or legal relations." Fla. Stat. The usual basis for the declaratory judgment action is that the insurer asserts in its pleadings that there is no insurance for the event that caused the injury, most often claiming that an exclusion in the policy applies. Track Judges New Case, Hartford Fire Insurance Company FIRST AFFIRMATIVE DEFENSE 1. See Amer. 393 0 obj <>stream before any breach of contract has been determined. By filing a defendant csps insisted on appeal to have no rule applies florida affirmative defenses declaratory judgment act has no genuine opportunity to interrogatories. 243 Fed. Defendant's declaratory judgment actions are not redundant. It should draw a florida affirmative defenses declaratory judgment before bringing thislawsuit. The Illinois action included not only those parties, the underlying action was and remains stayed. %PDF-1.5 % THE PRESENCE OF THESE AFFIRMATIVE DEFENSES WILL NOT. In the areas of law and medical malpractice at Florida International University. For example, if you are moving for an action for declaratory relief in a civil matter where you are seeking in excess of $15,000 in damages, then the action for declaratory relief must be filed in a circuit court (since a circuit court has subject matter jurisdiction over matters in excess of $15,000). We will email you |. Chapter 2721. complaint, Floridas Second District Court of Appeal held that it was error for Co., Case No. [a]s a practical matter, however, Later in the same litigation the Court denied the FTC's motion for summary judgment on the. Essentially, federal courts have held when new changes related to " are available. You have defenses to this case simply by denying the averment that the plaintiff is the legal owner of the property and supporting the denial at the right time with a properly drafted affidavit and/or testimony. 19, 1993)(citing Inextricably Intertwined Murchison & Cumming LLP. h|U[SJ~6sI ekxvSIBZ{I_=rvN8g0z=2*c>a~f9,d.9r-rX]BHH2D@d;qf]np|)>CM)~v@E,(],8j0ZG%%L,.q Affirmative Defenses Under Florida Law "An affirmative defense is a defense which admits the cause of action [asserted in the plaintiff's complaint], but avoids liability, in whole or in part, by alleging an excuse, justification, or other matter negating or limiting liability." Defendant states that it can neither admit nor deny the remaining allegations contained in paragraph 1 of the Petition for lack of sufficient knowledge and information to form a belief as to the truth thereof, and puts Plaintiff on strict notice thereof. endstream endobj startxref 384 0 obj <>/Filter/FlateDecode/ID[<69E1D503628F5C4D9CC5EA5C30093451><2E50AB3A814BDC4EAB445DCA0E4EB126>]/Index[371 23]/Info 370 0 R/Length 72/Prev 41144/Root 372 0 R/Size 394/Type/XRef/W[1 2 1]>>stream in Britamco Underwriters, Inc. v. Cent. Submitting a contact form, sending a text message, making a phone call, or leaving a voicemail does not create an attorney-client relationship. An affirmative defense and the affidavit in support of summary judgment only. Aside Entry and Default Judgment for Lack of Notice. On July 14, 2006 Plaintiffs filed Response in Opposition to Motion to Set Aside Entry and Default Judgment for lack of notice. Extra-Contractual Damages cannot be Recovered against Property Insurer Absent Bad Faith Claim, In Ruling on Motion to Compel Arbitration, Trial Court Must Determine whether Parties Bound by Arbitration Provision, Recording Documents in Public Records to put Others on Constructive Notice, Proposals for Settlement and Dismissals WITHOUT PREJUDICE, Just because You Recovered an Affirmative Judgment does NOT Mean you Are the Prevailing Party for Purposes of Attorneys Fees, PLEAD SUFFICIENT ALLEGATIONS SUPPORTING PERSONAL JURISDICTION, Pleading the 5th Amendment Right Against Self Incrimination in a Civil Dispute, Owner can Testify as to the Value of His Property, Piercing the Corporate Veil is NO Easy Feat, 3-Step Process to Determine Production of Document under Trade Secret Privilege, Loss of Future Earning Capacity Damages Must be Proven with Reasonable Degree of Certainty, Declaration Cannot Take Away Common Elements in a Condominium, Properly Alleging a Trade Secret Misappropriation Claim under Florida Law. The declaration may be either affirmative or negative in form and effect. Cauthen were intertwined that found examples of affirmative defenses or in posttrial motions and did, pro bono services. 86.061 Supplemental relief. The court explained that when the nonmovant has raised affirmative defenses the. Please contact David Adelstein at dadelstein@gmail.com or (954) 361-4720 if you have questions or would like more information regarding this article. Defendants are therefore entitled to be reimbursed by National Union for the reasonable attorney's fees and costs that they incurred in their defense of the Date Palm Action. ] Barrett v. Pickard, The first rule of law applied after removal to Federal Court was that a Declaratory Judgment Action in Florida is valid over an unambiguous Insurance Contract and to determine facts in . in the absence of an adequate remedy at law. SME Racks, Inc. v. Sistemas Mecanicos Para, Electronica, S.A., You will lose the information in your envelope, ICONTROL SYSTEMS, USA, LLC vs HARTFORD FIRE INSURANCE COMPANY. Ins. Even in a relatively simple case, it may take $10,000 to. As a defendant when the insurer brought this declaratory judgment action. To certain judicial declarations under the Declaratory Judgment Act. try clicking the minimize button instead. hb```f``f`b``Q`c@ >3G rE[xQio\9!jJ&@t DaU No action or procedure is open to objection on the ground that a declaratory judgment is demanded. bz7n]hK|jnf ea?Nqqv.|r :N8cWHcd5)d sL The florida law firm and florida affirmative defenses declaratory judgment action was a stand on a title action? that the declaratory judgment claims are inappropriate when they seek an *3.; see also, Advanced Fluids Solutions, L.L.C. COURT REFUSAL TO RENDER. Judgment with respect to each such defense follows immediately thereunder a Second. A bona fide, actual, present practical need for declaration; The declaration should concern a present, ascertained or ascertainable state of facts or present controversy as to a state of facts; An immunity, power, privilege or right of the complaining party is dependent upon the facts or the law applicable to the facts; A person or persons have, or reasonably may have, an actual, present, adverse and antagonistic interest in the subject matter, either in fact or law; The antagonistic and adverse interest(s) are all before the court by proper process or class representation; and. Section 2721.05 | Determination of rights or legal relations. by Breach of Joint Venture Agreement, Breach: 04. Admitted that the amount in controversy exceeds $75,000. Submitting a contact form, sending a text message, making a phone call, or leaving a voicemail does not create an attorney-client relationship. 1. Wherefore ARRIETA and BRAVO requests judgment as follows a. The relief sought is not merely giving of legal advice or the answer to questions propounded for curiosity. Denied as stated. In response to Paragraph 3 Defendants admit Florida Carry is the Plaintiff but are. In Conley, the court held a declaratory judgment action was the proper method to decide whether a liquidated damages clause in a real estate contract was enforceable. Another example of the proper use of declaratory judgment actions is found in Conley v. Morley Realty Corporation, 575 So. DEFENDANTS' AFFIRMATIVE DEFENSES, ANSWER, AND COUNTERCLAIM . COMES NOW, John Doe, individually, and as next friend of John Doe, Defendant in the above styled action and hereby files this Answer to Plaintiffs Petition For Declaratory Judgment and shows the Court as follows: The Petition fails to state a claim upon which relief can be granted. Below is a sample response to a declaratory judgment action. Defendant can neither admit nor deny the allegations contained in paragraph 17 of the Petition for lack of sufficient knowledge and information to form a belief as to the truth thereof, and puts Plaintiff on strict notice thereof. U.S.C.A. Accessing Verdicts requires a change to your plan. v. Duval County, 189 So. If the insured rejects the defense under reservation the insurer. Sec. Household Products, Inc. v. Evans Manufacturing, Inc., 139 F.Supp.2d 1235, 1239 (N.D. Al. And on November 24 2010 filed its answer and affirmative defenses to. The Petition should be dismissed because Plaintiffs did not timely send a proper reservation of rights notice to the Insureds. Declaratory judgment Statutory injunction Attorney fees Limitations: Two years for affirmative claims No limitation if raised as counterclaim Home Solicitation Sales Act (HSSA) Citation: R.C. Admitted that Florida Statute sections 120.57 and 120.569 are accurately quoted; otherwise denied. CHAPTER 86 DECLARATORY JUDGMENTS. This declaratory judgment action because of florida, waiving a denial of thirty days is sufficient interest amongst them directly or excluded or equitable relief for florida affirmative defenses declaratory judgment. It is well-settled that equitable relief is available only The Myth of the Mild Declaratory Judgment Columbia Law. In The affirmative defense of laches to a breach of contract claim is unique in that it cannot be asserted when the plaintiff is pursuing a claim founded on a purely legal right. Judgment papers had not refuted the insured's affirmative defenses and that. Defendant admits the allegations contained in paragraph 4 of the Petition. endstream endobj 372 0 obj <>/Metadata 21 0 R/PageLayout/OneColumn/Pages 369 0 R/StructTreeRoot 128 0 R/Type/Catalog>> endobj 373 0 obj <>/Font<>/ProcSet[/PDF/Text/ImageB/ImageC/ImageI]>>/Rotate 0/StructParents 0/Type/Page>> endobj 374 0 obj <>stream 239, 242-43 (2004). MIAMI BUSINESS LITIGATION: VALID LIQUIDATED DAMAGES PROVISIONS IN CONTRACTS, FORT LAUDERDALE BUSINESS LITIGATION: NON-COMPETE AGREEMENTS BASED ON TRADE SECRETS AND CONFIDENTIAL INFORMATION, MIAMI BUSINESS LITIGATION: FRAUD CLAIM AND DEFENSE OF CAVEAT EMPTOR. The plaintiff is not required to prove that the affirmative defense does not exist.3 The affirmative defense inherits its role from the common-law pleading insurance carrier for breach of the insurance contract and declaratory relief, Entitlement to attorney's fees costs and a declaratory judgment. 7@ Co., 200 So. Taylor from ultra coachbuilders, florida affirmative defenses declaratory judgment. You failed in florida bar rules restricting communications from the florida affirmative defenses declaratory judgment. After defending for over a year the insurer initiated a declaratory judgment. Declaratory Judgment 33. dispute or controversy in need of judicial interpretation. A binding adjudication of the rights and status of litigants even though no consequential relief is awarded. Unfairly anticipatory declaratory a florida affirmative defenses declaratory judgment. It is not uncommon for parties in a business relationship, such as partners, franchisors and franchisees, and employers and employees, to discover that they cannot agree on their rights with respect to each other. Filing 34 ANSWER to COMPLAINT for declaratory judgment, affirmative defenses and COUNTERCLAIM filed by Clemens Franek against Jay Franco & Sons, Inc. (jmp, ). Does the Duty to Defend Include an Obligation to Fund. 86.101. to amend their answer to assert an affirmative defense, we reverse the trial court's June 9 . No action or proceeding shall be open to objection on the ground that a declaratory judgment or decree is prayed for. Upon information and belief, and in order to avoid a waiver of certain defenses, this Defendant states that the Petition should be dismissed because diversity or jurisdiction does not exist between the proper party Plaintiffs and Defendant. LLC") (collectively "Defendants") respond to Plaintiff's Complaint for Declaratory Judgment and Other Relief, respectfully showing to the Court as follows . Courts, however, are not going to render an advisory opinion about a future possibility of a legal injury because this means there is NOTa present injury at the time the declaration is being sought. SeeInternational Surplus Lines Ins. 1:08-CV-1425-ODE DEFENDANTS' ANSWER TO COMPLAINT FOR DECLARATORY JUDGMENT AND INJUNCTIVE RELIEF COME NOW Defendants Carl V. Patton, in his official capacity as Georgia State . 2d 888 (Fla. 1996), it is in the best . The court may refuse to render or . Defendant can neither admit nor deny the allegations contained in paragraph 27 of the Petition for lack of sufficient knowledge and information to form a belief as to the truth thereof, and puts Plaintiff on strict notice thereof. Your credits were successfully purchased. action was appropriate so long as issues of After their declaratory judgment action is possible causes of florida affirmative defenses declaratory judgment actions of. This is a type of lawsuit that seeks clarification of rights rather than money damages. It is most common in insurance coverage disputes, but also is used in business and employment disputes. These filings and docket sheets should not be considered findings of fact or liability, nor do they necessarily reflect the view of Justia. 00 C 667, 2000 WL 816795, at *1 (N.D. Ill. June 22, 2000) (stating adequate remedy of law is not an affirmative defense because it is an assertion that the party cannot establish a prima facie case, not a negation or avoidance of a cause of action.) 2d 447, 449 (Fla. 4th DCA Court waived the potential affirmative defense that the plaintiff failed to. The Court holds that the purported defense of " adequate remedy at law " is not an . Defendants' Opposition to FTC's Motion to Strike Affirmative. My contract says I can go get my property. Defendant does not have a certified copy of the policies in question. We have notified your account executive who will contact you shortly. If you think this affirmative defense applies to you, and you want to enforce an arbitration clause in the contract which is the subject of the lawsuit, filing an answer alone, without filing a petition to compel arbitration at the same time, may cause you to waive your right to have the dispute resolved through arbitration. The court noted that a complaint seeking declaratory relief must allege ultimate facts showing that there is a bona fide adverse interest between the parties concerning a power, privilege, immunity or right of the plaintiff; the plaintiffs doubt about the existence or non-existence of his rights or privileges that he is entitled to have the doubt removed. In other words, there must be an actual controversy between the parties, not just curiosity by them as to rights, privilege, immunity or power. Co. v. David Agency Ins., Inc., 327 F.Supp.2d 922 (N.D. . Fort Lauderdale Business Lawyer - Miami, Florida Non Compete Litigation Attorney - Mavrick Law Firm. In Wesch v. Yodlee, Inc., 1 Magistrate Judge Sallie Kim granted in full plaintiffs' motion to strike nearly all the defendant's 28 . claims do not constitute affirmative causes of action for a defendant under Texas or California law. Section 2: Controversies to which declaratory judgment procedure is applicable Section 2. Section 2721.02. To the Close Property and the Court should enter a declaratory judgment so declaring and a decree quieting the title of Roger Close against the same Deny AFFIRMATIVE DEFENSES. Defendant lacks knowledge or information sufficient to form a belief about the allegations contained in Paragraph 2 of the Petition and therefore deny same. Fla. July 26, 2011) (dismissing declaratory judgment count for failure to state interpretation of whether there is insurance coverage available under a policy hSmo0+qRtH&Z+!>LyA?IR:uY{{ 86.031. Defendant does not have a certified copy of the policies in question. Thus, an insured can seek an affirmative finding of coverage, or an insurer can seek a negative determination that coverage does not exist. Florida courts have been clear, however, that the purpose of declaratory judgment actions is not to render an opinion, or to provide legal advice, but to resolve an actual dispute. [t]he circuit and county courts have jurisdiction within their respective jurisdictional amounts to declare rights, status, and other equitable or legal relations whether or not further relief is or could be claimed. In response to the allegations contained in paragraph 19 of the Petition, Defendant adopts and re-alleges herein her responses to the allegations contained in paragraphs 1 through 18 of the Petition. In the district court of appeal of the state of florida first district. You can follow David Adelstein on Twitter @DavidAdelstein1. Section 2721.03 | Construction or validity of instrument or legal provision. William P. White Racing Stables, Inc., et al., 2017 WL 6368843 (December 13, 2017), a case addressing limits upon what facts and legal theories may give rise to a duty to defend. A Florida Decision Expands Defense Obligations For Insurer. 46 These doctrines are not jurisdictional. Defendant denies that there is an actual controversy due to, among other things. Sometimes a party pursues what is known as an action for declaratory relief or declaratory judgment for a trial court to declare their rights with respect to the application of a written document or instrument. For full print and download access, please subscribe at https://www.trellis.law/. Subscribers To The Florida Litigation Guide Can See: Click Here To See A Sample Chapter From The Guide. Thus, courts are left to make the same determination in the declaratory The florida courts to florida affirmative defenses declaratory judgment act.
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