Unger

INTRODUCTION

Respondent Aaron Unger loaned appellant Laura Gottlieb1 $600,000 in three installments between November 2013 and January 2014. Gottlieb made some interest payments on the loan, then stopped making payments. Unger sued Gottlieb in December 2016 for breach of contract, common counts, and fraud. A jury found in Unger’s favor, awarded him actual damages, and awarded punitive damages of one million dollars. Gottlieb appealed, and asserts four arguments. She contends her agreement with Unger was oral, and therefore his causes of action for breach of contract and common counts were barred by the two-year statute of limitations. Gottlieb also asserts Unger failed to prove the element of reliance for his fraud claim. Gottlieb further contends the court erred in denying her request to bifurcate the punitive damages portion of the trial. Finally, she argues there was insufficient evidence to support the award of punitive damages. We affirm. Substantial evidence supports the jury’s findings regarding the written nature of the parties’ agreement, Unger’s reliance on Gottlieb’s statements, and the amount of the punitive damages award. We also find no error in the court’s denial of…