Karina I. Perez, of the Tampa office, recently prevailed on a motion to dismiss for fraud on the court, with prejudice. The case involved a moderate impact rear end collision with clear liability for causing the accident. Plaintiff was diagnosed with bulging and herniated discs and had racked up significant past medical bills plus a future surgical recommendation. On the eve of mediation, the defense discovered a prior PIP claim brought by a medical provider, as assignee of the Plaintiff, which suggested a prior accident and injuries which had not been disclosed in discovery. At Plaintiff’s deposition, Karina pinned Plaintiff down as to whether he had any prior claims or injuries, which he repeatedly and emphatically denied. At the hearing on the motion to dismiss for fraud, Plaintiff’s counsel tried to minimize the non-disclosures of three prior accidents and six medical providers as forgetfulness but the Court was not convinced. The client has asked us to proceed to seek fees under a proposal for settlement.