and committed perjury” on a central and material issue, nor competent substantial evidence .that any such misconduct was “undertaken with intent to deceive, constituted a deliberate scheme to subvert the judicial process, [or] amounted to a fraud upon the court.” Faddis, 121 So.3d at 1135. Accordingly, we determine that under these circumstances, the trial court abused its discretion in striking Martinez’s pleadings and entering default final judgment against her as a sanction. In addition, the trial court’s refusal to allow Martinez’s counsel to call Martinez or any other witnesses to the stand regarding the “lies and perjury” his client allegedly committed, or even to allow counsel to make a complete proffer to the court, was a denial of, due process, See Fernandes, 149 So.3d at 750 (<HOLDING>); Kilnapp v. Kilnapp, 140 So.3d 1051 (Fla. 4th
holding sanctions were appropriate due to prejudice imposed on other party from failure to disclose subject matter of expert testimony holding that default and dismissal were proper sanctions in view of partys willful destruction of documents and records that deprived the opposing party of the opportunity to present critical evidence on its key claims to the jury holding reversal required where party lacked an opportunity to present evidence on the issue before sanctions imposed holding that where the issue of sanctions was not before the court of appeals when the appeal was filed the district court retained jurisdiction holding that due process requires notice and an opportunity to respond before imposition of rule 11 sanctions