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In ordering discovery of such materials when the required showing has been made, the court shall protect against disclosure of the mental impressions, conclusions, opinions, or legal theories of an attorney or other representative of a party concerning the litigation.
An attorney can issue a subpoena without a court file being opened, but if the clerk issues a blank subpoena, a court file must be opened and will collect a $50 fee. Rule 1.1702(5). A court file will also be opened for any motions relating to the subpoena and the clerk will collect a $50 fee then as well.
Unless otherwise ordered by the court, no deposition, notice of deposition, interrogatory, request for production of documents, request for admission, or response, document or thing produced, or objection thereto shall be filed with the clerk.
Unless the court upon motion orders otherwise for the convenience of parties and witnesses and in the interests of justice, or the parties stipulate, methods of discovery may be used in any sequence and the fact that a party is conducting discovery, whether by deposition or otherwise, shall not operate to delay any ...
Rule 1.303 - Time for motion or answer to petition 1. 303(1) Unless otherwise provided, the defendant, respondent, or other party shall serve, and within a reasonable time thereafter file, a motion or answer within 20 days after the service of the original notice and petition upon such party.
You must electronically file this Appearance and Answer using EDMS at unless you obtain from the court an exemption from electronic filing requirements.
In addition, rule 1.943 allows for voluntary dismissal of the plaintiff's petition without prejudice once as a matter of right. Id. r. 1.943.
1. 504(3) A motion for protective order must include a certification that the movant has in good faith personally spoken with or attempted to speak with other affected parties in an effort to resolve the dispute without court action.