Florida Supreme Court Standard Interrogatories: Forms and Deadlines

Florida’s standard interrogatories are pre-written discovery questions approved by the Florida Supreme Court and published as appendices to the Florida Rules of Civil Procedure. Under Rule 1.340, if an approved form exists for your type of case, your first set of written questions to the other side has to draw from that form before you add anything of your own. The rule exists so both parties cover the basic facts every case of that type requires without drafting from scratch.

Which Case Types Have Approved Forms

Not every case has a standard form. The Supreme Court has approved forms for specific categories, and the two most commonly used cover personal injury negligence:

Form 1: general personal injury negligence interrogatories directed to the plaintiff
Form 2: general personal injury negligence interrogatories directed to the defendant

Family law cases use a separate set of standard interrogatories under the Florida Family Law Rules of Procedure. Form 12.930(b) covers original or enforcement proceedings such as divorce and child custody disputes.¹ The family law forms follow a somewhat different structure because they operate under their own procedural rules, but the underlying idea is the same.

If no approved form exists for your case type, you draft your interrogatories from scratch. The other rules below still apply.

How to Use the Forms When Drafting

When a form exists, your first round of interrogatories must draw from it.² You are not required to use every question on the form. Pick only the ones that fit your case. But whatever standard questions you use come first, before any custom questions you add.

You can add your own questions without asking the court, so long as the total number of interrogatories, counting the standard ones and every subpart, stays at or below 30.² Subparts count. A single question with five sub-questions uses five of your 30. If you need more, file a motion explaining why and get the court’s permission.

Initial Disclosures Come First

Before anyone serves interrogatories, Florida now requires an exchange of initial disclosures. The requirement took effect January 1, 2025, under an amended Rule 1.280. Each party must provide these disclosures within 60 days of service of the complaint, without waiting for a request.³

Four categories are required:

Witnesses likely to have relevant information, with name, address, phone number, email, and the subjects they know about
Documents, electronically stored information, and tangible things in the party’s possession that may support its claims or defenses, either produced or described
A computation of each category of damages claimed, with supporting documents; noneconomic damages do not require a computation, but the party must identify the categories claimed and provide supporting materials
Any insurance policy that could cover all or part of a judgment

Cases listed under Rule 1.200(a), which covers certain expedited or specialized proceedings, are exempt unless a court orders otherwise.⁴ Parties also have a continuing duty to update their disclosures as new information becomes available.

Deadlines and How to Answer

Most parties have 30 days from service to answer interrogatories and state any objections. A defendant who is served with interrogatories along with the original complaint gets 45 days.² The court can shorten or extend either deadline, and the parties can agree to extensions between themselves.

Each question is answered separately and completely, in writing. The person answering signs the responses under oath, which makes them a sworn statement usable as evidence at trial.² Sworn answers that contradict later testimony will be used against you.

Objecting Instead of Answering

If a particular question is improper, you can object rather than answer it. The objection replaces the answer for that question only. Every other non-objectionable question still has to be answered on time. Objections have to state a specific legal basis, not a generic complaint. Common grounds include:

Attorney-client privilege or work-product protection
Relevance to any claim or defense in the case
Undue burden, where the effort to answer is disproportionate to the value of the information
Vagueness, where the question is too broad or unclear to answer

Any objection ground not raised in a timely response is waived unless the court excuses the failure for good cause.² Raising an objection months later almost never works. The attorney who signs the objection is responsible for its legal basis.

Serving and Filing

Florida requires electronic service for nearly all documents after the initial complaint. Under Rule 2.516, documents are served by email, and filing through the Florida Courts e-Filing Portal satisfies the requirement automatically because the Portal delivers the document to all designated email addresses. Attorneys designate a primary email address when they appear in a case, and every document they file or serve has to include it.

Self-represented litigants who have not designated an email address are served by other means allowed under the rules, such as hand delivery or mail.

The interrogatory document itself is not filed with the court. Only a certificate of service is filed, recording the date sent and the party served.² The answers also stay off the docket unless a party needs to file them for a pending motion or the court orders otherwise.

What Happens If You Ignore Interrogatories

Ignoring interrogatories is one of the quickest ways to lose ground in a Florida lawsuit. Under Rule 1.380, the party who served the questions can file a motion to compel, asking the court to order answers. If you still do not comply after that order, the consequences escalate:

The court can treat the facts underlying the unanswered questions as established in favor of the other side
The court can bar you from supporting your claims or defenses on the topics you refused to answer, or prohibit you from introducing certain evidence at trial
The court can strike part or all of your pleadings, stay the case until you comply, dismiss your claims, or enter default judgment against you
The court can treat the failure as contempt

On top of any of those sanctions, the court is required to order the non-compliant party to pay the other side’s reasonable expenses caused by the failure, including attorney’s fees, unless the failure was substantially justified or an expense award would be unjust. The expense award is the default, not a discretionary add-on.

Producing Records Instead of Writing Out an Answer

Rule 1.340 includes a shortcut worth knowing. When the answer to an interrogatory can be found in your business records, and pulling the answer would take the same effort for either side, you can make those records available for inspection instead of writing out a detailed answer. You have to specify which records contain the information so the other party can locate it without a hunt. This works well for questions about financial history, transaction records, or any area where the raw data tells the story more efficiently than a written summary.

1
Florida Courts. Standard Family Law Interrogatories for Original or Enforcement Proceedings
2
The Florida Bar. Proposed Amendments to Rules of Civil Procedure 1.340, 1.350, and 1.380
3
The Florida Bar. Amendments to Florida Rule of Civil Procedure 1.280
4
Fastcase. Florida Rule of Civil Procedure 1.280 General Provisions Governing Discovery