Responses and Objections to Subpoena Duces Tecum (FL)

by Practical Law Litigation

A Standard Document that provides a sample response that a nonparty can use to respond and object to a subpoena duces tecum in Florida civil litigation. This resource is designed for nonparties subpoenaed for the production of documents, either with or without a deposition. This Standard Document outlines the strategic options available to a nonparty, such as serving written objections, filing a motion to quash or modify the subpoena, or seeking a protective order. It includes examples of common general and specific objections that counsel can tailor to their case, covering grounds like attorney-client privilege, the work product doctrine, unreasonable or oppressive requests, and issues surrounding electronically stored information (ESI). This resource also includes integrated notes that address critical procedural requirements under the Florida Rules of Civil Procedure, offering guidance on proper formatting and service. These notes provide valuable drafting tips and explanations to help counsel effectively challenge a subpoena while complying with their legal obligations.