Both sides show cards without being asked
Initial Disclosures — the Mandatory Layer
In covered Florida civil actions, each party generally must disclose — within 60 days of service or joinder — its supporting witnesses, supporting documents and ESI, a damages computation with backup, and applicable insurance. Serving yours is commonly what opens your right to send discovery.
The package has four parts: people (witnesses you may use, with the subjects they know about), paper (documents and ESI by category and location), money (the damages computation — 'a lot' is not a computation), and coverage (insurance that may satisfy a judgment).
The duty is continuing: as facts change, disclosures and discovery responses generally must be supplemented. A witness or document never disclosed is commonly a witness or document you may be barred from using.
The other side's package is your first enforcement target: a thin, late, or evasive disclosure invites exclusion motions — attorneys commonly deficiency-scan it the day it arrives.
Do it, don't just read it
Common questions
What if I don't know my damages exactly yet?
Disclose the computation you can make today, category by category, with its supporting records — and supplement as it firms up. A stale or absent number at trial is commonly a struck number.
Do I have to disclose harmful documents?
Initial disclosures generally cover what you may USE to support your claims or defenses. Harmful material commonly surfaces through the other side's requests instead — but never destroy it, and never hide what a request covers.
What happens if they just don't serve disclosures?
Their discovery rights commonly stay gated and yours ripen into enforcement: exclusion of undisclosed witnesses and documents is the standard consequence under the rules.
The governing text — verbatim, never paraphrased
This guide is editorial; the linked pages carry the verbatim, hash-pinned text with its verification state. When a guide and the rule text could ever differ, the rule text wins — that is the whole doctrine.
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