Documents, ESI, and things
Requests for Production — the Paper Offensive
The workhorse instrument: written demands for documents, electronically stored information, and tangible things, generally answered in writing within 30 days with production to follow.
Precision is armor: attorneys commonly draft custodian-named, date-bounded, subject-specific requests, because 'any and all documents relating to' invites the overbreadth objection that stalls everything.
The 2026 response rules add teeth: objections generally must state their specific grounds, say whether anything is being withheld, and the unobjected portion must still be produced. Hold every response to all three.
For ESI, form matters: specify how electronic records should be produced (native files, metadata) when you have a reason — or accept whatever arrives, which is commonly a wall of flat PDFs.
Do it, don't just read it
Common questions
They said 'will produce' weeks ago and nothing came — normal?
'Will produce' with no date is a classic evasion. The commonly effective move: a deficiency letter demanding a date certain, then the compel ladder if silence continues.
Can I get records from someone who isn't a party?
Generally yes — Florida provides a notice-and-subpoena procedure for non-party records (with a 10-day objection window for other parties), and depositions with subpoenas for the rest. Records from the source are immune to opponent editing.
What does production actually look like?
Documents are generally produced as kept in the usual course of business or organized and labeled to correspond to the request categories — a disorganized dump is itself a deficiency.
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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