Free intelligence first, paper second, people last
Planning Discovery Like a Campaign
The sequence attorneys commonly run: public records and mandatory disclosures first (free), identification and preservation second, element-targeted paper third, contradiction work fourth, depositions last — so every witness arrives already committed by their own documents.
Wave zero costs nothing: Florida's public-records law (ch. 119) reaches every state and local agency record without a lawsuit or a lawyer, and the mandatory initial disclosures force both sides to show witnesses, documents, damages computations, and insurance without being asked.
The middle waves are aimed, not sprayed: every instrument commonly ties to a specific element of a specific claim or defense. A request that proves nothing pleaded is burden without payoff — which is exactly what the proportionality rules punish.
Depositions come last on purpose: a witness deposed before the documents and sworn answers exist is a fishing trip; deposed after, they are boxed in by their own paper. The expensive instrument is saved for when it can close, not explore.
Do it, don't just read it
Common questions
When can I start sending discovery?
In covered Florida civil actions, a party generally may not seek discovery until its own initial disclosures are served — the disclosure-first sequence. Wave-zero moves (public records, preservation letters, client materials) are commonly available immediately. Verify your case's posture and any court order.
How many interrogatories and admissions do I get?
Both interrogatories and requests for admission are generally capped at 30 including all subparts, absent a stipulation or court permission — so each one is spent like ammunition, not scattered like confetti.
What's the single cheapest move?
Commonly the ch. 119 public-records demand: government-held evidence (permits, inspections, citations, 911 audio, licensing files) obtainable by any person, no case number required, while the opponent still thinks discovery hasn't started.
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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