Motion to Compel Responses to Written Discovery (FL)

by Practical Law Litigation

A Standard Document that provides a model short-form motion to compel for use in Florida circuit court civil litigation. This Standard Document is designed for routine discovery disputes where a party fails to meet its obligations under the Florida Rules of Civil Procedure. It addresses common issues such as a party's failure to timely respond to written discovery, providing inadequate or evasive responses, or raising improper objections related to scope, privilege, or burdensomeness. This resource outlines the grounds for seeking court intervention after exhausting out-of-court options, focusing on compelling responses to interrogatories and requests for production. It also addresses crucial procedural elements, including the requirement for a certificate of conferral under Florida Rule of Civil Procedure 1.202 and the potential to request reasonable expenses incurred in bringing the motion. This Standard Document is intended for disputes that can be heard on a court's uniform motion calendar, as opposed to more complex discovery matters requiring a long-form motion.