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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.
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.
A party or attorney responsible for issuing and serving a subpoena must take reasonable steps to avoid imposing undue burden or expense on a person subject to the subpoena.
1.972(2) Application. . . . No default shall be entered unless the application contains a certification that written notice of intention to file the written application for default was given after the default occurred and at least ten days prior to the filing of the written application for default.
Rule 1.910 - Motions for continuance 1. 910(1) Motions for continuance shall be filed without delay after the grounds therefor become known to the party or the party's counsel. Such motion may be amended only to correct a clerical error.
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.
A party desiring to take the deposition of any person upon oral examination by telephonic means shall give reasonable notice thereof in writing to every other party to the action.
Rule 16.401(2). This rule adds a layer of protection for parties. Registered filers' computer filters may occasionally filter out an emailed discovery request or response. Rule 16.401(2) ensures that registered filers will at least know they should have received a discovery document.