LAW.coLAW.co

Piero Salussolia, P.A. v. Gianni Nunnari

2026-08-26

Summary

Holding. The trial court did not abuse its discretion in denying withdrawal of technical admissions and granting summary judgment in Nunnari's favor; the appellate court affirmed this ruling on appeal and reversed in part on cross-appeal to allow entry of an amended final judgment properly reflecting the summary judgment in Nunnari's favor on the counterclaim.

Piero Salussolia, a professional corporation, sued Gianni Nunnari over a contract dispute. Salussolia failed to timely respond to Nunnari's requests for admissions, causing numerous facts—including non-performance and disputed payments—to be deemed admitted. The trial court denied Salussolia's motion to withdraw these technical admissions and granted summary judgment in Nunnari's favor based on them. Salussolia appealed, arguing the trial court should have allowed withdrawal of the admissions so the case could proceed on its merits. Nunnari cross-appealed, claiming the final judgment dismissing the case did not properly reflect the entry of summary judgment in his favor on his counterclaim.

The appellate court upheld the trial court's denial of withdrawal. Although Florida law favors deciding cases on the merits rather than technical defaults, the court found no abuse of discretion here. Salussolia's attempt to withdraw the admissions came in 2025—eleven years after filing the complaint and two years after the requests for admissions were served in 2023. The verified response opposing summary judgment relied only on a statement made "to the best of [counsel's] knowledge and belief" without citation to any admissible evidence demonstrating a genuine dispute of material fact. The court noted the significant delay in prosecution and the lack of evidentiary support distinguishing this case from prior decisions favoring withdrawal.

Summary generated by law.co from the public-domain opinion. The opinion text itself is public domain.

Key issues

  • Whether a trial court abuses discretion by denying withdrawal of technical admissions obtained through failure to timely respond to requests for admissions
  • Whether admissible evidence must support a claim of genuine disputed material fact to overcome summary judgment based on technical admissions
  • Whether delay in prosecuting an action and tardiness in seeking relief from admissions affects the trial court's discretionary decision

Procedural posture

Salussolia appealed the trial court's order denying his motion to withdraw technical admissions and granting summary judgment in Nunnari's favor; Nunnari cross-appealed to challenge an order dismissing the case that failed to reflect final summary judgment on his counterclaim.

Authorities cited

Opinion

majority opinion

Third District Court of Appeal

State of Florida

Opinion filed August 26, 2026.

Not final until disposition of timely filed motion for rehearing.

No. 3D25-1868

Lower Tribunal No. 14-26490-CA-01

Piero Salussolia, P.A.,

Appellant/Cross-Appellee,

vs.

Gianni Nunnari, et al.,

Appellees/Cross-Appellants.

An Appeal from the Circuit Court for Miami-Dade County, Vivianne del Rio, Judge.

Armstrong Teasdale LLP, and Glen H. Waldman and Richard G. Cole, III, for appellant/cross-appellee.

Todd R. Friedman, P.A., and Todd Friedman, for appellees/crossappellants.

Before SCALES, C.J., and LOBREE and BOKOR, JJ.

BOKOR, J.

Piero Salussolia, P.A., the plaintiff below, appeals the trial court’s order

denying his motion to withdraw technical admissions deemed admitted due

to his failure to timely respond to requests for admissions and granting

summary judgment in favor of the defendant, Gianni Nunnari, based on those

admissions. Nunnari cross-appeals to challenge a subsequent order

purporting to dismiss the case with prejudice following entry of final summary

judgment in Nunnari’s favor on his counterclaim. For the reasons that follow,

we affirm the issues on appeal and reverse as to the cross-appeal to permit

entry of final judgment in favor of Nunnari on the counterclaim.

Florida Rule of Civil Procedure 1.370(b)(2) provides a trial court with

discretion to permit withdrawal or amendment of an admission “when the

presentation of the merits of the action will be subserved by it and the party

who obtained the admission fails to satisfy the court that withdrawal or

amendment will prejudice that party in maintaining an action or defense on

the merits.” We review such ruling for abuse of discretion. See Clemens v.

Namnum, 233 So. 3d 1146, 1148 (Fla. 4th DCA 2017). Although “[t]he liberal

standard for relief under this rule reflects the strong preference that genuinely

disputed claims be decided upon their merits rather than technical rules of

default,” Pennymac Corp. v. Labeau, 180 So. 3d 1216, 1219 (Fla. 3d DCA

2

2015), based on the facts of this case we conclude that the trial court did not

abuse its discretion in denying the motion for relief.

We have held many times that summary judgment and dismissal are

inappropriate when based solely on technical admissions obtained through

a failure to timely answer a request for admissions when a disputed issue of

fact exists. See, e.g., Ruiz v. De Varona, 785 So. 2d 508, 509 (Fla. 3d DCA

2000) (“[D]ismissal based solely on the failure to timely answer a request for

admissions would be inappropriate when the pleadings make clear the

opposing party’s position and the existence of disputed facts.” (emphasis

added)); Sher v. Liberty Mut. Ins. Co., 557 So. 2d 638, 639 (Fla. 3d DCA

1990) (reversing summary judgment where “circumstances presented an

issue of material fact for decision, and the withdrawal of the technical

admissions and acceptance of the belated response would serve to facilitate

the presentation of the case on its evidentiary merits” (quotation omitted;

emphasis added)); Wells Fargo Bank, N.A., v. Donaldson, 165 So. 3d 40, 42

(Fla. 3d DCA 2015) (“Here, like in Sher and Ruiz, the record supports the

denial of Wells Fargo’s technical admissions. The allegations contained in

the verified complaint contradicted the technical admissions.”). But the

record here reflects no evidence of disputed issues of fact.

3

Here, the technical admissions included numerous facts directly

relevant to liability under the contract at issue, including admitting nonperformance and issuance of disputed payments. Salussolia’s verified

response to the motion for summary judgment sought to withdraw the

admissions and contained allegations directly contradicting the admissions.

But the verified motion cited to no record evidence, merely relying on the

signature of the corporate counsel for Salussolia at the end of the filing that

“under penalty of perjury . . . the facts stated in [the foregoing document] are

true to the best of my knowledge and belief.” (emphasis added). And stating

something is true to the best of one’s knowledge and belief is not providing

admissible evidence that creates a triable issue of fact. See, e.g., Thompson

v. Citizens Nat’l Bank of Leesburg, Fla., 433 So. 2d 32, 33 (Fla. 5th DCA

1983) (“An affidavit based on information and belief rather than personal

knowledge is not admissible into evidence and should not be considered by

the trial court on a motion for summary judgment.”).

Furthermore, the complaint dates to October 2014, based on an

agreement executed in February 2011. We will not recount in detail the

actions between 2014 and the filing of the requests for admission in 2023,

other than to say that a charitable description would be that prior counsel did

not diligently prosecute this matter. Based on the record, the belated effort

4

to withdraw admissions—in 2025—after the filing of summary judgment and

the inability to cite any admissible evidence supporting such withdrawal or

showing a genuine issue of material fact supports the trial court’s decision.

As our sister court explained, “[w]hile decisions on the merits are preferred,

there is a point at which the opposing party is prejudiced by a tardy request

for relief from admissions. We think this is such a case.” Asset Mgmt.

Consultants of Va., Inc. v. City of Tamarac, 913 So. 2d 1179, 1181 (Fla. 4th

DCA 2005) (noting also that other than proposed answers to the technical

admissions, “there is nothing in this record . . . showing evidence that would

contradict the technical admissions”); see also Pennymac Corp., 180 So. 3d

at 1220 n.2 (explaining that the “test of reasonableness” of the trial court’s

discretionary decision “requires a determination of whether there is logic and

justification for the result” (quotations omitted)); cf. Sher, 557 So. 2d at 639

(“Here, the record is replete with evidence contradicting the admissions

created by Sher’s failure to file a timely response.”). We therefore affirm as

to the issues on appeal.

On cross-appeal, Nunnari explains that the trial court’s final judgment

dismissing the case with prejudice inadvertently failed to reflect the entry of

final summary judgment in Nunnari’s favor. We accordingly reverse in part

5

to allow the trial court to enter an amended final judgment reflecting its

granting of final summary judgment in Nunnari’s favor on the counterclaim.

Affirmed in part, reversed in part, and remanded.

6