Legal content overseen by Nathan Walter, Esq., attorney licensed in California (State Bar No. 313299).

Florida requests for production ordinarily require a written response within 30 days after service. Under Florida Rule 1.350(b)(3), a defendant may respond within 45 days after service of process and the initial pleading; the court may shorten or extend the period.

For each item or category, permit inspection as requested or state specific objection grounds and reasons. An objection must disclose whether responsive materials are withheld on that basis (Rule 1.350(b)(4), (b)(6)).

This guide covers deadlines, responses, objections, production, and pre-signing review for defense firms in Florida state civil litigation. It distinguishes required response language from optional practices for matching responses to records. For federal cases, use our federal requests for production guide; this article addresses Florida state procedure.

What do Florida requests for production cover?

Florida Rule 1.350(a)(1) permits a party to request designated documents, including electronically stored information (ESI), that are within the scope of Rule 1.280(c) and in the possession, custody, or control of the party to whom the request is directed. Rule 1.280(c)(1) limits that scope to nonprivileged matter relevant to a claim or defense and proportional to the needs of the case. See Rules 1.350(a)(1) and 1.280(c)(1) in the Florida Bar’s October 1, 2026 official rules compilation.

A request for production (RFP) is a written discovery request served on another party. The responding party answers in writing and then makes the records available for inspection and copying. Those are two steps: the written response says what will be permitted, objected to, or withheld, and the production is the delivery or inspection that follows.

Is there a numerical limit on Florida requests for production?

Rule 1.350 does not state a numerical cap on requests for production. Rule 1.280(b) addresses frequency of discovery methods subject to court orders and its stated qualifications, while Rule 1.280(c)(1) limits scope through relevance and proportionality. A lack of a numerical cap does not remove those limits.

Which records are involved in a defense file?

The examples in this guide are invented. Suppose a customer sues a grocery operator after a fall in an aisle. A request for production might ask for incident photographs, inspection logs, and emails about the incident. Whether any of those records is discoverable, privileged, or protected depends on the request, the facts, and Rule 1.280. Our request for production examples show general request formats; they are not Florida authority.

When is a Florida Rule 1.350 response due?

Under Florida Rule 1.350(b)(3), the ordinary written-response period is 30 days after service of the request. A defendant may serve its response within 45 days after service of the process and initial pleading on that defendant, and the court may allow a shorter or longer time. The 45-day period is tied to service of process and the initial pleading, not to every later request.

Florida requests for production: quick reference

These are rule periods, not a case-specific deadline calculation. Confirm the applicable service rules and court orders before calendaring.

Which date starts which period?

Track four dates separately for each request: the date the request was served, the date the defendant was served with process and the initial pleading, any court order that changes the time, and the inspection date stated in the request. Rule 1.350(b)(3) also requires the request to specify a reasonable time, place, and manner of inspection.

If a request is served with the summons and complaint, examine the 45-day period measured from service of process and the initial pleading. Rule 1.280(f)(1) also bars a party from seeking discovery before that party’s initial disclosures are served on the other party, unless authorized by stipulation or court order. For a later request, review both the ordinary 30-day period and whether the defendant’s initial 45-day window remains relevant; service of another request does not restart that window. Rule 1.350(b)(3) permits the court to shorten or extend the response time.

What must each written response say?

Florida Rule 1.350(b)(4) requires a response for each item or category that either states inspection and related activities will be permitted as requested or states with specificity the grounds for objecting, including the reasons. Rule 1.280(j) also requires the responding party to state each discovery request in full as numbered, followed by the answer, objection, or other response. Rule 1.350(b)(4) also requires responses to be served on all parties. See Rules 1.350(b)(4) and 1.280(j) in the official Florida rules compilation.

Rule 1.280(j) expressly includes requests for production or inspection served under Rule 1.350. In practice, that means the response document repeats each request word for word, with its number, before the response. Our examples of discovery production responses show generic response layouts; check them against the Florida requirements above.

How can a defense team structure the response?

A workable firm-practice format, not an official court form, is to reproduce the request, state permitted inspection or the specific objection with reasons, state whether materials are withheld, and identify the records produced by request number or Bates range.

How must objections identify withheld materials?

An objection to a Florida request for production must state whether any responsive materials are being withheld on the basis of that objection (Fla. R. Civ. P. 1.350(b)(6)). If the objection reaches only part of a request, the response must specify that part and permit inspection of the rest, and the objection must state its grounds with specificity, including the reasons (Rule 1.350(b)(5)–(6)).

The Florida Supreme Court added language on specificity to Rules 1.340 and 1.350 in its civil case-management amendments, effective January 1, 2025. The Florida Bar’s report says the court acted “[t]o avoid discovery objections that just generally cite proportionality without any further explanation,” and quotes the added Rule 1.350 sentence that “[a]n objection must state whether any responsive materials are being withheld on the basis of that objection.” See The Florida Bar News report on the amendments.

Our discovery objections cheat sheet catalogs common objections across jurisdictions; it is not authority for Florida’s specific requirements.

What does a partial-objection response look like?

The following example involves a request for inspection records. The bracketed reason must come from the actual case facts, and the example does not suggest any objection will succeed.

The response names the challenged part, gives a reason, says what is withheld, and permits inspection of the remainder. A partial objection does not excuse silence about the rest of the request.

How must documents and ESI be produced?

Florida Rule 1.350(b)(7) requires a producing party to produce documents as they are kept in the usual course of business or to identify them to correspond with the categories in the request. Under Rule 1.350(b)(8), a party must state the form or forms of ESI it intends to use if it objects to a requested form or if the request specifies none. When the request does not specify a form, the party must produce in a form in which the information is ordinarily maintained or in a reasonably usable form. See Rule 1.350(b)(7)–(8) in the official Florida rules compilation.

Organization under (b)(7) concerns how documents are arranged; form under (b)(8) concerns the electronic format of ESI. In the premises-liability file, an inspection-log spreadsheet and incident photographs raise the form question.

The rule does not say native files are always required, that PDFs always suffice, or that Bates numbering satisfies every production duty. Those questions turn on the request, any agreement or order, and the (b)(8) standards. Our guide to Bates numbering explains this method of assigning page identifiers. Rule 1.350 does not itself require Bates numbering.

How can the response stay connected to the production?

A request-to-record index, built as a firm practice, lets the reviewing attorney match each numbered response to the records produced and check the Bates ranges before signing. Briefpoint Autodoc finds responsive documents and adds page-level Bates citations. The attorney still decides whether the production matches the response.

Is a withholding statement enough for privileged documents?

A Rule 1.350(b)(6) withholding statement addresses whether an objection caused responsive materials to be withheld. When Rule 1.280(c)(6) applies to otherwise discoverable information withheld as privileged or protected trial-preparation material, the party must also make the claim expressly and describe the nature of the withheld documents, communications, or things so other parties can assess the privilege or protection without learning the protected information. See Rule 1.280(c)(6) in the official Florida rules compilation.

The withholding statement answers one question: is anything being held back because of this objection? The privilege description answers another: what is the withheld material, described well enough for the other side to evaluate the claim? A privilege log can organize that description as a firm practice. Rule 1.280(c)(6) itself does not prescribe log fields or a fixed log deadline; this does not address any case-specific order.

What should defense counsel check before signing?

Florida Rule 1.280(k) requires every discovery request, response, or objection made by a represented party to be signed by at least one attorney of record, with the attorney’s address, e-mail address, and telephone number. By signing, the attorney certifies, to the best of the attorney’s knowledge, information, and belief formed after a reasonable inquiry, that the response or objection meets the rule’s conditions. See Rule 1.280(k) in the official Florida rules compilation.

Under Rule 1.280(k)(2)(A)–(C), the certification covers consistency with the rules and support in existing law or a good-faith argument for extending, modifying, or reversing existing law. It also covers the absence of an improper purpose, such as harassment, unnecessary delay, or needless increased litigation cost. The response must not be unreasonable or unduly burdensome or expensive, considering the needs of the case, discovery already had, the amount in controversy, and the importance of the issues at stake.

The signature does not replace checking the response against the records. A final-review checklist:

• The deadline trigger and any court order are confirmed.
• Each request is reproduced in full and numbered.
• Each objection states specific grounds and reasons.
• Each objection states whether materials are withheld.
• Any partial objection specifies the part and addresses the rest.
• Production is organized as kept in the usual course of business or identified to the request categories.
• The ESI form statement is included where (b)(8) calls for one.
• Any privilege claim is made expressly and described under Rule 1.280(c)(6).
• The signature block has the attorney’s address, e-mail address, and telephone number.

What can the requesting party do about an objection?

Rule 1.350(b)(9) permits the requesting party to move for an order under Rule 1.380 concerning any objection, failure to respond, or failure to permit inspection as requested. A request-to-record index and a note of the searches run are firm practices, not rule requirements. This guide does not cover motion procedure or sanctions.

How can Briefpoint help defense firms draft responses?

Briefpoint drafts responses and objections to requests for production, with editable Microsoft Word output and attorneys retaining final review. Autodoc finds responsive documents, adds page-level Bates citations, and builds a Bates-numbered production package.

Defense counsel still assesses the grounds for each objection, whether the withholding statement accurately describes the result, and whether the response matches the proposed production. Review the editable Word response alongside the proposed production before approving either.

Client Bridge sends clients plain-language questions through a secure link so they can answer and upload documents for attorney review. That supports collecting the information a response needs, though a client’s upload is not a finished production.

Explore discovery workflows for defense firms when evaluating how these features fit your team.

Book a demo to explore Briefpoint for your defense firm’s discovery workflow.

Watch the Briefpoint demo:

FAQs about Florida requests for production: what else?

The recurring Florida Rule 1.350 questions concern response deadlines, withheld materials, production format, and partial objections. The answers below address Florida state civil practice, not the federal rules.

How long do I have to respond to a request for production in Florida?

The ordinary period is 30 days after service of the request. A defendant may instead respond within 45 days after service of process and the initial pleading on that defendant, and the court may allow a shorter or longer time (Fla. R. Civ. P. 1.350(b)(3)). The 45-day period does not restart for later requests. Check the service date and any court order before calendaring.

Do I have to say whether I am withholding documents?

Yes. An objection must state whether any responsive materials are being withheld on the basis of that objection (Rule 1.350(b)(6)). A statement that some records are being produced does not answer that question. If an objection covers only part of a request, the response must specify that part and permit inspection of the rest.

Can a Florida request for production specify an electronic format?

Yes. A request for ESI may specify the form or forms of production (Rule 1.350(b)(8)). If the responding party objects to the requested form, or the request specifies none, the response must state the form or forms it intends to use. If no form is specified, production must be in an ordinarily maintained or reasonably usable form.

Can I object to part of a request and produce the rest?

Yes, if the objection states its grounds with specificity, including the reasons (Rule 1.350(b)(5)). The response must also specify the part objected to and permit inspection of the rest (Rule 1.350(b)(6)). It must state whether responsive materials are being withheld on the basis of the objection, so the requesting party knows what remains outstanding.

Must I organize produced documents by request number?

Not necessarily. Rule 1.350(b)(7) allows the producing party to produce documents as they are kept in the usual course of business or to identify them to correspond with the categories in the request. A request-to-Bates index is a useful practice for matching records to responses, but the quoted rule does not add it as a separate format requirement.

The information provided on this website does not, and is not intended to, constitute legal advice; instead, all information, content, and materials available on this site are for general informational purposes only. Information on this website may not constitute the most up-to-date legal or other information. This website contains links to other third-party websites. Such links are only for the convenience of the reader, user or browser. Readers of this website should contact their attorney to obtain advice with respect to any particular legal matter. No reader, user, or browser of this site should act or refrain from acting on the basis of information on this site without first seeking legal advice from counsel in the relevant jurisdiction. Only your individual attorney can provide assurances that the information contained herein – and your interpretation of it – is applicable or appropriate to your particular situation. Use of, and access to, this website or any of the links or resources contained within the site do not create an attorney-client relationship between the reader, user, or browser and website authors, contributors, contributing law firms, or committee members and their respective employers.