Little Jimmy O'Leary, lives in Birmingham, Alabama and works as a law clerk for a federal judge in Mississippi. While Little Jimmy O'Leary hates the humidity of Florida, he owns a vacation home in Marco Island, Florida which he rents out. Over the summer break, Little Jimmy O'Leary decides to visit his father who lives in Marco Island, Florida. While driving on Interstate 75 in Florida, Little Jimmy O'Leary gets into a car accident with Sally Johnson, who owns a vacation home in Florida, but is a resident of New Jersey. As a result of the accident, Little Jimmy O'Leary suffers serious injuries and a totaled car. In addition to severe brain injuries, Little Jimmy O'Leary loses all use of his right arm. Sally Johnson suffers no serious medical injuries, but her Fiat 500 suffers over $5,000 in damages. After recovering from his injuries, Little Jimmy O'Leary returns home to Alabama. Because Little Jimmy O'Leary cannot type with his right hand, he loses his job as a law clerk.

Please consider the following questions. Let's assume that Sally did not file a motion to dismiss in Alabama, but instead threw the complaint in the garbagebecause she thought it was junk mail. Because Sally did not respond after proper service, the court in Alabama entered judgment against Sally. After she receives notice of the default judgment, Sally goes to an attorney. What type of motion should Sally's attorney file?Next let's assume that the judge in Florida federal court granted the motion to vacate the default judgment, but then denied the motion to dismiss. After that, and after denying a series of motions to reconsider the judge's denial of the motion to reconsider the denial of the motion to dismiss based on lack of subject matter jurisdiction, a trial takes place. After the trial, the judge enters judgment against Sally for over one million dollars based on the jury's verdict. Throughout the trial, Sally's attorney made a seriesof errors, i.e., he allowed hearsay evidence in, did not properly challenge Little Jimmy's medical experts, and did not challenge the authenticity of the medical records entered by Little Jimmy. Sally was furious because with proper representation a verdict of one million would have never been entered against her.Moreover, Sally believes that Little Jimmy has produced forged medical records that overstate his injuries. Soon after the trial, Sally visits another attorney. What type of motion or action should Sally's attorney file?