Last month, I had three Oral Arguments in the Second District Court of Appeal.
The fun issue in this first one, an issue of first impression not only in Florida but the entire United States, is whether the statute of limitations should have barred the lender’s action to re-establish a lost note.
In this second OA, a bank lawyer thought he was going to get an easy win, as if his saying “paragraph 22” gave the lender an automatic victory … only to encounter a panel that was very intrigued by my presentation.
Finally, in this third OA, we argued whether a letter “substantially complied” with paragraph 22 where it required future, unspecified payments after the date of the letter.
I think my favorite part of this argument was how one of the judges got as fired up as I sometimes do… but you’ll have to watch until the end to see it! 🙂