Interrogatories in Florida civil cases are written questions one party sends to another that must be answered in writing and under oath. Rule 1.340 of the Florida Rules of Civil Procedure caps each party at 30 questions, counting subparts, and gives the recipient 30 days to respond. Amendments that took effect in January 2025 added mandatory initial disclosures and tightened the rules on objections and supplementation, so the way lawyers use interrogatories today looks different from even a year ago.
The 30-Question Limit and When the Clock Starts
Rule 1.340(a) limits each party to 30 interrogatories, and subparts count.1The Florida Bar. Proposed Amendments to Florida Rules of Civil Procedure 1.340, 1.350, and 1.380 A single question that asks for a witness’s name, address, phone number, and employer is not one question; courts tally each subpart against the cap. To exceed 30, you must file a motion showing good cause and give the other side notice.
Where the Florida Supreme Court has approved a standard interrogatory form for a case type, that form is your starting point. You can use fewer questions than the form contains and add your own, but the combined total still cannot exceed 30. Approved form questions and their subparts count too.
Timing depends on who is receiving them. Interrogatories can be served on a plaintiff as soon as the case is filed. For other parties, they can be served with or after the initial process and pleading. The responding party then has 30 days to serve answers or objections. A defendant served with interrogatories along with the initial complaint gets 45 days.
The scope of any question is governed by Rule 1.280(c)(1), which limits discovery to nonprivileged matters relevant to a party’s claims or defenses and proportional to the needs of the case.2Fastcase. Florida Rules of Civil Procedure 1.280 – General Provisions Governing Discovery Proportionality weighs the amount in controversy, each side’s resources, and whether the burden of answering outweighs the likely benefit. Questions outside those boundaries can be struck.
Service after the initial pleading runs through the Florida Courts E-Filing Portal under Rule of Judicial Administration 2.516. When the Portal sends notice to the other parties by email, service is complete on the date of filing.3Florida Courts. Rule 2.516 – Service of Pleadings and Documents The filer is responsible for confirming that the Portal has correct email addresses for all parties.
What You Have to Turn Over Without Being Asked
Before 2025, Florida litigants had to request virtually everything through discovery tools. Amended Rule 1.280 now requires each party to provide certain core information within 60 days after service of the complaint, without waiting for a request.4Seventeenth Judicial Circuit of Florida. 2025 Amendments to the Rules of Civil Procedure
Initial disclosures include the name and contact information of individuals likely to have discoverable information, copies or descriptions of documents the party may use to support its claims or defenses, a computation of each category of damages claimed (except noneconomic damages), and a copy of any insurance agreement that could cover a judgment.4Seventeenth Judicial Circuit of Florida. 2025 Amendments to the Rules of Civil Procedure A party cannot skip these disclosures on the ground that the case is not fully investigated or that the other side has not made its own disclosures yet.
This changes how you should draft your 30 questions. Much of the material that lawyers once chased with interrogatories now arrives automatically. Use your questions to fill the gaps that initial disclosures leave open rather than to duplicate what the other side already has to hand over.
How to Answer Interrogatories
Answers must be in writing, separate, full, and under oath, served within 30 days of receipt (45 if served with the initial complaint). The party signs the answers, swearing to their truthfulness. Any objections are signed by the party’s attorney, not the party. A court can shorten or extend the deadline for good cause.
“Full” answers draw on all information reasonably available, not just what the person happens to remember. A corporate officer served with interrogatories directed at the company is expected to gather information from across the organization. Answers that plead ignorance about facts a reasonable inquiry would have uncovered draw little sympathy.
The Business Records Option
When the answer can be derived from a party’s own records, and the burden of pulling it out is roughly the same for either side, Rule 1.340(c) lets the responding party point to specific records instead of writing the answer out. The catch is specificity: you must identify the records in enough detail that the other side can find the answer as easily as you could. A vague reference to “our files” does not qualify. Electronic records must be produced in the format they are ordinarily kept in or in a reasonably usable format.
Duty to Supplement
Discovery answers are not a one-time obligation. Under Rule 1.280(g), a party who learns that a prior answer is incomplete or incorrect must supplement or correct it in a timely manner, unless the new information has already been shared through other discovery or in writing.2Fastcase. Florida Rules of Civil Procedure 1.280 – General Provisions Governing Discovery This duty runs the length of the case. Sitting on new facts that contradict an earlier answer is the kind of conduct that draws sanctions.
Objections and What Waives Them
Not every question deserves an answer, but the rule for pushing back is strict. Each objection must state its grounds with specificity and include the reasons. Boilerplate lines like “objection: overly broad” without further explanation do not satisfy the rule. Any ground not raised in a timely response is waived, unless the court excuses the failure for good cause. Missing the 30-day window can cost you the right to object at all.
Common grounds fall into a few categories:
- Irrelevance. The question has no reasonable connection to a claim or defense. Courts read relevance broadly, so this only works when the disconnect is clear.
- Undue burden. Answering would take disproportionate effort. You need to show your work: how many records would need to be searched, and why that effort outweighs the value of the answer.
- Privilege. The question seeks attorney-client communications or work product protected under Rule 1.280(c)(4). A privilege objection requires a privilege log that describes the withheld material in enough detail for the other side to test the claim, without revealing the protected content.2Fastcase. Florida Rules of Civil Procedure 1.280 – General Provisions Governing Discovery
When the problem is broader than a single bad question, a party can seek a protective order under Rule 1.280(d). A court can block discovery entirely, limit it to certain topics, restrict who may be present, or impose conditions on how information is shared. The moving party must show good cause, such as annoyance, embarrassment, oppression, or undue expense.
If the Other Side Won’t Answer
When a party gives evasive answers, refuses to respond, or misses the deadline, the party who sent the interrogatories can move to compel under Rule 1.380(a). The motion must include a certification that the movant tried in good faith to resolve the dispute without court involvement. Skip that step and the court can deny the motion and refuse to award expenses. Judges take this meet-and-confer requirement seriously.
If the motion is granted, the noncompliant party typically pays the other side’s reasonable expenses, including attorney’s fees, for having to bring the motion. The court can decline to shift fees if it finds the opposition was substantially justified or the award would be unjust.
When a party defies a court order compelling discovery, Rule 1.380(b) opens up harder sanctions. The court can:
- Deem facts established. Treat the matters covered by the unanswered interrogatories as proven in favor of the other side.
- Exclude evidence. Prohibit the disobedient party from supporting or opposing certain claims or introducing designated evidence at trial.
- Strike pleadings or enter default. Dismiss claims, strike defenses, or enter default judgment.
- Hold the party in contempt.
- Order payment of the reasonable expenses caused by the failure, including attorney’s fees.
Default judgment and claim dismissal are unusual on a first offense, but willful, repeated noncompliance makes them realistic.
Family Law Cases Work Differently
Divorce, paternity, and other family cases follow Florida Family Law Rule 12.340, not Rule 1.340. The Florida Supreme Court has approved standard family law interrogatory forms, including Form 12.930(b) for original or enforcement proceedings, covering the financial and personal background information common to nearly every family case.5Florida Courts. Standard Family Law Interrogatories for Original or Enforcement Proceedings Beyond the standard form, each party may serve up to 10 additional questions, subparts included, without court permission. That is a much tighter budget than the 30-question cap in general civil cases, so each added question has to earn its place.