Task: Text Completion
Input (English): of appeal. A trial court has the discretion to order dismissal or default against a party for that party’s failure to comply with discovery requirements. See Fla. R. Civ. P, 1.380(b)(2)(C); Commonwealth Fed. Sav. & Loan Ass’n v. Tubero, 569 So.2d 1271 (Fla.1990). However, “the striking of pleadings or entering a default for-noncompliance with an order compelling discovery is the most severe of all sanctions which should be employed only in extreme circumstances.” Mercer v. Raine, 443 So.2d 944, 946 (Fla.1983). Before striking a party’s pleadings and entering a default, the trial court must make a finding that the party’s nonappearance was willful or done in bad faith. In re Forfeiture of Twenty Thousand Nine Hundred Dollars ($20,900) U.S. Currency, 539 So.2d 14 (Fla. 4th DCA 1989) (<HOLDING>); Trupei v. City of Lighthouse Point, 506 So.2d 
 Holding statements: (A) holding trial court did not abuse its discretion in finding violation was willful and substantial (B) holding that dismissal for failure to appear at a deposition is on the merits (C) holding that defendants general objection to states specific questions regarding defendants failure to appear before grand jury was sufficient to put trial court on notice of objection based on defendants constitutional right to remain silent (D) holding that the defendants oral promise to appear was insufficient to amount to a required appearance within the meaning of the failure to appear statute (E) holding that the trial court was required to make a finding or recital that defendants failure to appear for deposition was willful or contumacious prior to striking the defendants pleadings
Output (English): (E)