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The privilege log, appendix and accompanying memorandum of law must be sufficient to establish a prima facie case to support assertion of each privilege or protection. No party may submit documents for the Court's in camera review, unless the Court issues a subsequent order requesting such submissions.

Can I Refuse to Answer a Deposition Question? You must answer all questions you are asked during a deposition, even if you feel they are too personal. Just like refusing to give a deposition altogether, refusal to answer a question will also result in being held in contempt of court.

Any party may request any other party (1) to produce and permit the party making the request, or someone acting in the requesting party's behalf, to inspect and copy any designated documents, including electronically stored information, writings, drawings, graphs, charts, photographs, audio, visual, and audiovisual ...

Unless so stipulated by the parties, no deposition shall be taken before a person who is a relative, employee, attorney, or counsel of any of the parties, is a relative or employee of any of the parties' attorney or counsel, or is financially interested in the action.

Rule 1.360 - EXAMINATION OF PERSONS (a)Request; Scope. (1) A party may request any other party to submit to, or to produce a person in that other party's custody or legal control for, examination by a qualified expert when the condition that is the subject of the requested examination is in controversy.

Rule 1.370 Requests for Admission can be a powerful tool to narrow the disputed facts and issues in litigation. A request for admission may be utilized to conclusively establish the truth of any fact, opinion of fact, or application of law to fact.

1.270(a), “(w)hen actions involving a common question of law or fact are pending before the court, it may order a joint hearing or trial of any or all the matters in issue in the actions; it may order all the actions consolidated; and it may make such orders concerning proceedings therein as may tend to avoid ...

Rule 1.450 - EVIDENCE (a) Record of Excluded Evidence. In an action tried by a jury if an objection to a question propounded to a witness is sustained by the court, the examining attorney may make a specific offer of what the attorney expects to prove by the answer of the witness.

Florida Rule of Civil Procedure 1.38,0 Failure to Make Discovery, Sanctions, informs in which court to enforce a litigator's discovery right, what orders to seek from the trial court, and sanctions that may eventually be available.