Response to Interrogatories in Florida Circuit Court – At A Glance

Use this At A Glance Guide to learn the Florida Rules of Civil Procedure related to responding to interrogatories in Florida Circuit Courts. For more detailed information, please see the SmartRules Response to Interrogatory Guide for the court where your action is pending.

Response to Interrogatory Rules:

The scope of inquiry allowable in interrogatories is “any matter, not privileged, that is relevant to the subject matter of the pending action, whether it relates to the claim or defense of the party seeking discovery or the claim or defense of any other party, including the existence, description, nature, custody, condition, and location of any books, documents, or other tangible things and the identity and location of persons having knowledge of any discoverable matter.” Fla. R. Civ. P. 1.280(b); Fla. R. Civ. P. 1.340(b).

An interrogatory may ask for an opinion or contention that relates to fact or the application of law to fact, or that asks for information not within the personal knowledge of the party. Fla. R. Civ. P. 1.340(b).

A party may propound to another party thirty (30) interrogatories, including those from the official forms or custom drafted ones. The total number of interrogatories to be propounded without leave of court must not exceed thirty (30), including all subparts. Fla. R. Civ. P. 1.340(a).

“Each interrogatory shall be answered separately and fully in writing under oath unless it is objected to, in which event the grounds for objection shall be stated and signed by the attorney making it.” Fla. R. Civ. P. 1.340(a).

If an interrogatory seeks information that is not within the personal knowledge of the responding party, that party must provide any information that it has “and the source on which the information is based.” Fla. R. Civ. P. 1.340(b).

A party who responded to an interrogatory with a response that was complete when made is under no duty to supplement the response to include after-acquired information. Fla. R. Civ. P. 1.280(e).

Interrogatories may contain specially defined terms, as long as these definitions are reasonable and not subject to misinterpretation.

Answers made by a party are not binding on a co-party. Fla. R. Civ. P. 1.340(d).

When an answer to an interrogatory may be derived from records and the burden of deriving the information would be the same for either party, the party who received the interrogatory has the option to identify and produce or make available the records from which the answer may be derived. Fla. R. Civ. P. 1.340(c).

The authorities cited in this At A Glance Guide are current as of the publication date. For authorities updated in real time, please see the SmartRules Guide for the litigation document you are drafting.

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