This is a diversity jurisdiction case, where award of attorney's fees was made under the Florida State "offer of judgment" procedure rule, in derogation of the Federal "offer of judgment" rule (Rule 68).

1. In a diversity jurisdiction case, did the lower court err in awarding attorney's fees under a Florida procedural rule regarding an offer of judgment, in contravention of the Federal offer of judgment rule?

2. Did the lower court fail to defer to controlling State Supreme Court precedent and certification (referral) in the construction of Florida's offer of judgment procedural rule?

In a diversity jurisdiction case, did the lower court err in awarding attorney's fees under a state procedural rule that conflicts with the federal offer of judgment rule?