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Types of Discovery in a Florida Business Litigation

Written on July 14, 2021

No matter what side you occupy in a Florida business litigation matter, it is highly likely that the parties will take advantage of discovery tools as part of preparing for trial. Despite its negative reputation as being an invasion of privacy, the process is essential for fairness and trial efficiency. Information is the basis for doing justice between parties to a business-related lawsuit. Under the Florida Rules of Civil Procedure, the scope of discovery is quite expansive, so it is important for stakeholders to know what they may need to turn over – and what details they will want to seek from the opposing side.

Your Clearwater business litigation lawyer tackles these relevant concepts on a regular basis and will handle the specifics regarding discovery. Still, an overview will give you a better idea of what to expect and how you can support your attorney’s efforts.

  1. Requests for Production of Documents
  2. Despite the term, this most common discovery tool extends far beyond information in document form. Parties can request a plethora of information in various formats, including:

    • Electronic information and data;
    • Drawings, graphs, and charts;
    • Information captured in photo, audio, or video form; and
    • Any details from which information can be accessed.

    In addition, requests for documents can be used for purposes of inspection, measuring, and testing, when doing so is an appropriate approach for assessing a tangible item.

  3. Written Interrogatories
  4. This type of discovery is a set of questions that one party poses to another to obtain additional details, so a corporate officer or other stakeholder is typically in the position to provide answers. Note that answers to interrogatories are required to be given under oath, so there can be consequences for making false or misleading statements.

  5. Depositions
  6. In some cases, stakeholders may be required to appear for a deposition. This proceeding is basically an in-person interview where one attorney asks the deponent questions about the case. Your lawyer will also be present, and a court reporter will record the deposition. Answers are also given under oath and penalty of perjury.

  7. Requests for Admission
  8. With this discovery tool, the point is to get a party to admit that certain facts are true or state that they are false. Requests for admission are effective in narrowing down the issues for trial, since there may be no disputes over certain facts. The critical point with these requests is that inaction can be devastating: If you do not respond by the deadline, the facts will be deemed as admitted.

  9. Physical and Mental Examinations
  10. Medical exams may be necessary when a party’s health is a factor in a business lawsuit, such as cases involving workplace injuries, disability, discrimination, and related disputes.

Our Clearwater, FL Business Litigation Attorneys Will Handle Discovery Tasks

This summary of discovery in Florida business lawsuits is useful, but you can count on our team at Clearwater Business Law to apply these tools to support your company’s interests. To learn more about the process, please call (727) 785-5100 to set up a consultation with a Pinellas County business law attorney today.


I strongly endorse Andrew Mongelluzzi. He is a very skilled and able business attorney focused on customer service and results. On the front end, Andrew deftly advises new businesses on organizing properly, acquiring necessary licenses, contracting with vendors & customers, and dealing with various compliance issues that may arise. On the back end when things go south, Andrew counsels and navigates businesses through complex commercial disputes and aggressively represents them in negotiations, mediation, arbitration, and in litigation so that businesses can legally move on and get back to business. Andrew’s ability to identify legal issues and approaches to resolve business-related issues is a strength that I have learned from and professionally relied upon in approaching the business matters and cases that I handle. I regularly refer business to Andrew knowing that he will diligently represent his business clients and their best interests.
Relationship: worked together on matter

- Frank N. Genco, Florida Bar No. 440086

Attorney Mongelluzzi and his team provided excellent and quality service. I always felt that my needs were met and that the firm was invested in me and my case. The quality services I received at Mongelluzzi’s firm were remarkable. From the initial meeting they were responsive to my calls, questions and concerns. All issues were handled professionally and timely, easily accessible, got back to me quickly, aggressive and got me the results that I wanted. Attorney Mongelluzzi and his staff all gave my case their personal attention and provided the quality of work that anyone would want when hiring an attorney.

- Client

Andrew is very thorough defining the outcome expectations. In my case, it was setting up a new corporate entity. He advised me on the most beneficial option and he then executed on that path. Andrew is a very pleasant person to work with. He is determined, skilled and committed to his client’s success.

- Gil Pinney

Andrew helped me through a difficult situation with American Express and we won the case. A great job by Andrew! He also helped me with T&C’s in my company. I would recommend Andrew highly as an attorney.

- John Sams

As a business owner for 12 years I have seen my fair share of ups and downs. Some of the downs would include landlord/tenant disputes and creditors that may have not been fulfilled to agreement. Andrew has met both of these situations for me in a timely, positive, and affordable manner.

- Rich Mattes

It was very nice to have a lawyer who not only is fierce in negotiations but has been successful in business. This is a lethal combination. I was glad he was on my side.

- Nigel Castanheiro

Andrew helped me with a contract litigation case. The lawyers battled it out for over a year and we finally got a reasonable settlement offer. Then the other side tried to back out. Andrew figured out how to force the other side to honor the deal and really knows his way around the court system. Definitely feel comfortable using him again.

- John Ellis


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