PIP claim dismissed because injury victim had history of failing to comply with discovery

State Farm secured the summary dismissal of William Jefferson's No Fault PIP claim after he repeatedly failed to meet deadlines for answering discovery. He was apparently institutionalized or incarcerated, or both, during the period the case was pending and failed to promptly respond to State Farm's update requests related to his treatment, and later failed to file a joint final pretrial order seven days before the trial. 

The Court of Appeals held that given his history, it was not an abuse of the trial judge's discretion to hold Jefferson solely accountable for the failure to produce the joint pre-trial order a week before trial.  Although it is axiomatic that a court "speaks by its written order," the court also held that in this case the court's failure to enter an actual signed, written order compelling the injury victim to file the pretrial order was not relevant.