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Drafting Discovery Responses Tips
Summary
When drafting discovery responses in Florida, answer each question fully and truthfully, object to overly broad or irrelevant questions, and ensure compliance with Florida Rules of Civil Procedure. For interrogatories, provide complete answers and seek clarification if needed. For requests for production, identify and produce documents, stating reasons for withholding any privileged documents. Use a generic format for responses, tailoring specifics to your case.Full Conversation
Sure thing, Bailey! Below is a generic format for responding to discovery questions. You'll need to tailor the specifics to your case:
Interrogatories
*. Question: Describe the accident in detail.
Answer: The accident occurred on [date] at [location]. [Provide a detailed description of the events leading up to and following the accident].
*. Question: List all witnesses to the accident.
Answer: Witnesses include [Name, Address, Contact Information].
*. Question: Identify any documents related to the accident.
Answer: Relevant documents include [list documents such as police reports, medical records, etc.].
*. Question: Describe the accident in detail.
Answer: The accident occurred on [date] at [location]. [Provide a detailed description of the events leading up to and following the accident].
*. Question: List all witnesses to the accident.
Answer: Witnesses include [Name, Address, Contact Information].
*. Question: Identify any documents related to the accident.
Answer: Relevant documents include [list documents such as police reports, medical records, etc.].
Requests for Production
*. Request: Produce all medical records related to your injury.
Response: Attached are the medical records from [Doctor/Hospital Name], dated [date].
*. Request: Produce any photographs of the accident scene.
Response: Attached are photographs taken on [date] at [location].
*. Request: Produce all medical records related to your injury.
Response: Attached are the medical records from [Doctor/Hospital Name], dated [date].
*. Request: Produce any photographs of the accident scene.
Response: Attached are photographs taken on [date] at [location].
Objections
*. Overly Broad or Vague: "Objection. This request is overly broad and vague as it fails to specify [reason]. Without waiving this objection, [provide a limited response if applicable]."
Is there a particular type of interrogatory or request for production you need more help with?
*. Overly Broad or Vague: "Objection. This request is overly broad and vague as it fails to specify [reason]. Without waiving this objection, [provide a limited response if applicable]."
Is there a particular type of interrogatory or request for production you need more help with?
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