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The Florida Bar's Civil Procedure Rules Committee proposes amending Florida Rule of Civil Procedure 1.351 (Production of Documents and Things Without Deposition) to extend the period of time to object to a subpoena to 45 days when a notice of non-party production is served simultaneously with a complaint.
When you receive a Request for Production, the other side is asking you to hand over a document or item, usually to be copied. Sometimes, this is called a Demand for Inspection. You have 30 days to respond to a Request for Production.
Your response to a request for production consists of two parts: One part is a written response to the requests, in which you state under penalty of perjury that you will produce the requested items; that you will not produce and why; or that you object to a request on legal grounds.
Use a Request for Production when you want the other side to produce documents and things as well as a statement under oath that they have provided the documents or things requested, or what they haven't produced and why.
Notice of Production from Nonparty, Florida Supreme Court Approved Family Law Form 12.931(a), is used to notify the other party in your case that in 10 days you are going to subpoena documents from a nonparty.
Common objections to requests for production or inspection include: The request is overly broad or unduly burdensome. ... The request is vague, ambiguous, or unintelligible. ... The request is not reasonably calculated to lead to the discovery of relevant, admissible evidence.
If a request asks for a document, make a copy of the document; in your response, describe the document and say that a copy is attached; and attach a copy of the document to the responses you send back to the other side.
Responses to requests for production are due within 30 days after service, except that a defendant may serve a response within 45 days after service of the initial pleading and process on that defendant. Fla.