Attorney’s fees — Justiciable issues — Safe harbor notice — Service — E-mail — Trial court erred in granting motion to strike defendant’s section 57.105 motion because defendant’s safe harbor notice did not comply with Florida Rule of Judicial Administration 2.516’s e-mail service requirements — Based on supreme court’s holding in Wheaton v. Wheaton, the court recedes from its decisions in Matte v. Caplan and Estimable v. Prophete — Rule 2.516’s e-mail service requirements do not apply to service of a section 57.105 safe harbor notice
45 Fla. L. Weekly D265a
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