Fla. R. Civ. P. 1.340

Interrogatories to Parties

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RULE 1.340. 	INTERROGATORIES TO PARTIES
(a) 	Procedure for Use.
(1) 	Without leave of court, any party may serve on any
other party written interrogatories to be answered:
(A) 	by the party to whom the interrogatories are
directed; or
(B) 	if that party is a public corporation, private
corporation, partnership, association, or governmental agency, by
any officer or agent, who must furnish the information available to
that party.

(2) 	Interrogatories may be served on the plaintiff after
commencement of the action and on any other party with or after
service of the process and initial pleading on that party.
(3) 	The interrogatories must not exceed 30, including
all subparts, unless the court permits a larger number on motion
and notice and for good cause.
(4) 	If the supreme court has approved a form of
interrogatories for the type of action, the initial interrogatories on a
subject included within must be from the form approved by the
court.
(5) 	A party may serve fewer than all of the approved
interrogatories within a form.
(6) 	Other interrogatories may be added to the approved
forms without leave of court, so long as the total of approved and
additional interrogatories does not exceed 30.
(7) 	Each interrogatory must be answered separately
and fully in writing under oath unless it is objected to, in which
event the grounds for objection must be stated and signed by the
attorney making it.
(8) 	The grounds for objecting to an interrogatory must
be stated with specificity, including the reasons. Any ground not
stated in a timely objection is waived unless the court, for good
cause, excuses the failure.
(9) 	The party to whom the interrogatories are directed
must serve the answers and any objections within 30 days after the
service of the interrogatories, except that a defendant may serve
answers or objections within 45 days after service of the process
and initial pleading on that defendant. The court may allow a
shorter or longer time.
(10) 	The party submitting the interrogatories may move
for an order under rule 1.380(a) on any objection to or other failure
to answer an interrogatory.

(b) 	Scope; Use at Trial.
(1) 	Interrogatories may relate to any matters that can
be inquired into under rule 1.280(c), and the answers may be used
to the extent permitted by the rules of evidence except as otherwise
provided in subdivision (b).
(2) 	An interrogatory otherwise proper is not
objectionable merely because an answer to the interrogatory
involves an opinion or contention that relates to fact or calls for a
conclusion or asks for information not within the personal
knowledge of the party.
(3) 	A party must respond to an otherwise proper
interrogatory by giving the information the party has and the source
on which the information is based.
(4) 	A qualified answer may not be used as direct
evidence for or impeachment against the party giving the answer
unless the court finds it otherwise admissible under the rules of
evidence.
(5) 	If a party introduces an answer to an interrogatory,
any other party may require that party to introduce any other
interrogatory and answer that in fairness ought to be considered
with it.
(c) 	Option to Produce Records.
(1) 	When the answer to an interrogatory may be derived
or ascertained from the records (including electronically stored
information) of the party to whom the interrogatory is directed or
from an examination, audit, or inspection of the records or from a
compilation, abstract, or summary based on the records and the
burden of deriving or ascertaining the answer is substantially the
same for the party serving the interrogatory as for the party to
whom it is directed, then an answer to the interrogatory specifying
the records from which the answer may be derived or ascertained
and offering to give the party serving the interrogatory a reasonable
opportunity to examine, audit, or inspect the records and to make

copies, compilations, abstracts, or summaries is a sufficient
answer.
(2) 	An answer must be in sufficient detail to permit the
interrogating party to locate and to identify, as readily as can the
party interrogated, the records from which the answer may be
derived or ascertained, or must identify a person or persons
representing the interrogated party who will be available to assist
the interrogating party in locating and identifying the records at the
time they are produced.
(3) 	If the records to be produced consist of
electronically stored information, the records must be produced in a
form or forms in which they are ordinarily maintained or in a
reasonably usable form or forms.
(d) 	Effect on Co-Party. Answers made by a party are not
binding on a co-party.
(e) 	Service and Filing.
(1) 	Interrogatories must be served on the party to
whom the interrogatories are directed and copies must be served on
all other parties.
(2) 	A certificate of service of the interrogatories must be
filed, giving the date of service and the name of the party to whom
they were directed.
(3) 	The answers to the interrogatories must be served
on the party originally propounding the interrogatories and a copy
must be served on all other parties by the answering party.
(4) 	The answers to interrogatories may be filed in
compliance with Florida Rule of General Practice Judicial
Administration 2.425 and rule 1.280(h) by any party when the
court should consider the answers to interrogatories in determining
any matter pending before the court.

(5) 	The court may order that the answers to
interrogatories be filed at any time when the court determines that
examination of the answers to interrogatories is necessary to
determine any matter pending before the court.
Committee Notes
1972 Amendment. Subdivisions (a), (b), and (c) are derived
from Federal Rule of Civil Procedure 33 as amended in 1970.
Changes from the existing rule expand the time for answering,
permit interrogatories to be served with the initial pleading or at
any time thereafter, and eliminate the requirement of a hearing on
objections. If objections are made, the interrogating party has the
responsibility of setting a hearing if that party wants an answer. If
the interrogatories are not sufficiently important, the interrogating
party may let the matter drop. Subdivision (b) covers the same
matter as the present rule 1.340(b) except those parts that have
been transferred to rule 1.280. It also eliminates the confusion
between facts and opinions or contentions by requiring that all be
given. Subdivision (c) gives the interrogated party an option to
produce business records from which the interrogating party can
derive the answers to questions. Subdivision (d) is former
subdivision (c) without change. Former subdivision (d) is repealed
because it is covered in rule 1.280(e). Subdivision (e) is derived from
the New Jersey rules and is intended to place both the
interrogatories and the answers to them in a convenient place in
the court file so that they can be referred to with less confusion.
The requirement for filing a copy before the answers are received is
necessary in the event of a dispute concerning what was done or
the appropriate times involved.
1988 Amendment. The word “initial” in the 1984 amendment
to subdivision (a) resulted in some confusion, so it has been
deleted. Also the total number of interrogatories which may be
propounded without leave of court is enlarged to 30 from 25. Form
interrogatories which have been approved by the supreme court
must be used; and those so used, with their subparts, are included
in the total number permitted. The amendments are not intended to
change any other requirement of the rule.

2011 Amendment. A reference to Florida Rule of General
Practice and Judicial Administration 2.425 and rule 1.280(f) is
added to require persons filing discovery materials with the court to
make sure that good cause exists prior to filing discovery materials
and that certain specific personal information is redacted.
2012 Amendments. Subdivision (c) is amended to provide for
the production of electronically stored information in answer to
interrogatories and to set out a procedure for determining the form
in which to produce electronically stored information.
Court Commentary
1984 Amendment. Subdivision (a) is amended by adding the
reference to approved forms of interrogatories. The intent is to
eliminate the burden of unnecessary interrogatories.
Subdivision (c) is amended to add the requirement of detail in
identifying records when they are produced as an alternative to
answering the interrogatory or to designate the persons who will
locate the records.
Subdivision (e) is changed to eliminate the requirement of
serving an original and a copy of the interrogatories and of the
answers in light of the 1981 amendment that no longer permits
filing except in special circumstances.
Subdivision (f) is deleted since the Medical Liability Mediation
Proceedings have been eliminated.
2024 Amendment. Any use of standard interrogatories must
be adjusted for proportional discovery.

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