Please produce any and all photographs, videotapes, motion pictures, drawings, sketches, diagrams, plats or the like taken at or made of the scene of the collision or any person or physical object which relate in any way to the circumstances of the collision, including, without limitation, photographs of the damaged bicycle. endobj WebAs used in this Request for Production of Documents, the following terms mean: (a) You or your The person(s) to whom this Request for Documents is addressed and all other Shall be construed either conjunctively or disjunctively to bring within the scope of this Request for Documents any information which might otherwise be construed to be outside their scope. 3. Please produce a curriculum vitae for, and any and all documents containing the opinions or analyses of, any person whom you expect to call as an expert witness at the trial of this case, which concern any issue pertaining to the instant lawsuit. (2) Discovery plan. 2. Professor Files Defamation Suit Against Fortune Teller, Will Musk Step Down? xZo8AO@65=v#73$%bXl-p8LM?4?}yzf90,ySKM/v6Kn&7;0./X,Q2XR&+gc^^"ym2nynz-BfdJL',O[LgLG!YdcdWr.meN)e:G M %0 Please produce any and all books, documents or other tangible items relating to the incident described in Plaintiffs Complaint or any of Plaintiffs claims or your defenses in this action. Twitter Poll Decides Future of Twitter, The New Twitter: The Bad Boss May Be A Hero for Exploited Children. Fla. R. Civ. The time shall be at least thirty (30) days after service of the request to produce, except that a defendant may serve a response within forty-five (45) days after the service of the process and the initial pleading on that defendant. 4 0 obj Your response to this request should be periodically supplemented. 59 0 obj <> endobj 3W|o7=c~s1c96n!gL`nj{`f;og6fCI2a{>m'UdR'\Le0i hOH1109_K & P_83kyO3'mbEfk))D(2x4UO?.BvgW.X REQUEST FOR PRODUCTION OF DOCUMENTS . The Florida Judicial Qualifications Commission, by and through its undersigned counsel and pursuant to Fla. Attorneys are hb````qbL, /07`/ 3@1c +. 2d 899 (Fla. 3d DCA 1963) ; IBM v. Elder, 187 So. Please produce any and all documents prepared by anyone as the result of tests, inspections or measurements made or taken with respect to the scene of the collision. See Seventeenth Circuit Court SmartRules Capsule SUBPOENA. endobj P. 1.280(e). Please produce any and all documents which contain or are related to any surveillance or investigation concerning Plaintiffs claims or allegations in this action. Ave. Gainesville, FL 32601 Phone: 325-505-8900 [emailprotected], Cares Act & Eviction Moratorium On March 27, 2020, the Cares Act came into being. The authorities cited in this At A Glance Guide are current as of the publication date. 18. Requests for production and responses are not be filed with the court. As used in this section: (a) WebPlease review this document and gather the requested information. (c) If you maintain that any of the documents requested cannot be produced by virtue of any claimed privilege or immunity, set forth precisely the grounds for your objection to producing the documents in question. endstream endobj 63 0 obj <>stream This can be a very profitable discovery tool, reaping immediate rewards. For more detailed information, please see the SmartRules Response to Request for Production guides for the court where your action is pending. 11777 San Vicente Blvd., Suite Accessible | Fair | Effective | Responsive | Accountable. WebPLAINTIFFS SUPPLEMENTAL REQUEST FOR PRODUCTION OF DOCUMENTS, SET ONE S ELARZ L AW C ORP. A party who has responded to a request to produce with a response that was complete at the time is under no duty to supplement the response to include after Webmiddle district of florida orlando division mathew floeter plaintiff, vs. case no. P. 1.280(b)(5). 0 WebRequest for Production of Documents - TO DEFENDANTParty: Defendant Florida Peninsula Insurance Co January 27, 2014. 153680 Massey & Duffy, P LLC 855 E. Univ. In such cases, the, FLSA (Fair Labor Standard Act) offer collective action lawsuits against employers that violated the minimum wage and overtime wage standard. 0 &6qME[v py1p|Wj];0&YI+b+]L3aG0S8 )\ab 72XCl`cXg-jlcP(jj/pda8E^FI;g#(OvlfF0N:e6Yt &iU*]+fqcPQnHW\t4U`$sx(d(#6#7sn_i6oSB}(-C~r5C}W4X!l>Dl[tkD@C{"+b[V;/rA-z`;jG!j lp=.>"[? 0aeY }!do7@\>LwO9 QOHljivP$T-W,n[ Bc,4p[OQO&/^\BT{uG>@)Ue($tuJ!wt ni"te&mFU+1l.Mouf|_zUUW-{H#2C,4`GfFZOTD1Q=qrWS%9iEWE+I[ql$4]%IKF~NW?5_=9uw HE` _@@ The Items are: 1. hbbd``b`$@`6 $1U@ cB Xp Fla. R. Civ. P. 1.390(b). Please produce at least one document, such as title or registration, evidencing ownership of the vehicle you were driving which was involved in the collision described in Plaintiffs Complaint. Whirlpool washer deep water wash 3 . /s/ Michael Massey Michael Massey Fla. Bar No. (d) Communicate or communication Includes every manner or means of disclosure, transfer, or exchange and every disclosure, transfer or exchange of information, whether orally or by documents or whether face-to-face or by telephone, mail, personal delivery or otherwise. 12. W e0 K` these Requests for Production of Documents: 1. WebSubpoena for Production of Documents from Nonparty, Florida Supreme Court Approved Family Law Form 12.931(b), is the actual subpoena directing the nonparty to produce %%EOF WebPOSITION SUMMARY: HIAS seeks a Policy Analyst to conduct policy research and analysis in support of the Policy Centers mission and goals. WebSince requests for production are traditionally thought to cover documents, tangible items, and/or electronic documents prepared on a computer, it is easy for a responding party to try to avoid or sidestep an e-discovery request if the request fails to specify the type or location of the data sought. 2012 Amendment. Our goal is to help people in the best way possible. Early in the case, a party must: REQUESTS FOR PRODUCTION 1. 9. The production of nonprivileged materials should no- t be delayed while a party is WebRequests for the production of documents are another form of discovery available to litigants in Georgia. IMPORTANT: Before receiving services from a self-help program or court staff, please read through the NOTICE OF LIMITATIONS OF Professor Files Defamation Suit Against Fortune Teller, Will Musk Step Down? stream Webwitnesses or documents protected under such privileges or doctrines or otherwise covered by Evidence Code section 1115 et seq. Subscribe to receive important updates and news from Florida Courts. Use this At A Glance Guide to learn theFlorida Rules of Civil Procedure applicable to amended answer inFlorida Circuit Courts. Webin the action. Fed. Often, these ladders are supplied by employers or homeowners in a faulty condition. Presented (on behalf of the Firm) by. PRODUCTION OF DOCUMENTS AND THINGS AND ENTRY UPON LAND FOR INSPECTION AND OTHER PURPOSES | Cox Law, PLLC FLORIDA RULES OF CIVIL PROCEDURE Florida Rules of Civil Procedure Rule 1.010. 2d 217 (Fla. 1969). (c) Person or persons Any individual, corporation, partnership, joint venture, firm, association, proprietorship, agency, board, authority, commission or any other entity. 855 East University Ave.; Gainesville FL 32601, CORONAVIRUS AID, RELIEF AND ECONOMIC SECURITY for FLORIDA. This memorandum surveys U.S. economic sanctions and anti-money laundering (AML) developments and trends in 2022 and provides an outlook for 2023. Please produce any and all documents which evidence, contain or relate to any statements made by either Plaintiff or any other person or any communication by any person at the scene of the collision in question. Plaintiffs Third Request for Production (the Motion), and in support thereof states as follows: 1. Log in. Timing. The term document or documents means all paper documents, graphic or auditory records or representations, tangible items, and electronically stored information, and shall have the broadest possible meaning accorded to it consistent with Fed. WebThe 2022 Florida Statutes (including Special Session A) 92.153 Production of documents by witnesses; reimbursement of costs.. Please produce any and all of your insurance policies in effect at the time of the accident as described in Plaintiffs Complaint. 2011 Amendment. (e) Or Shall be construed either conjunctively or disjunctively to bring within the scope of this Request for Documents any information which might otherwise be construed to be outside their scope. FLSA Class Actions For Unpaid Wages And Overtime, Are They Worth It? Our Gainesville lawyers are some of the premier lawyers dealing with employment law, personal injury lawsuits and wage and hour cases, in Gainesville and throughout Florida. WebRequest for Production of Documents - TO DEFENDANTParty: Defendant Florida Peninsula Insurance Co January 27, 2014. We also provide some thoughts concerning compliance and risk mitigation in this challenging environment. If you're using a VPN server, please make sure you're using a US Based VPN Server, or disable it to access our site temporarily. WebThe finding of classified documents in the mansion of donald trump in Mar-a-Lago provoked a slight confrontation between the Federal Bureau of Investigation Contact us today for a free consultation. The party serving the request for production may move for an order compelling production under Rule 1.380. P. 1.350(b). Please produce a copy of all transcripts containing the testimony of any party or witness pertaining to the incident. Read court documents, court records online and search Trellis.law comprehensive legal database for any state court documents. WebAny disinterested witness who desires reimbursement of such costs shall submit a request for reimbursement, supported by an affidavit, to the person or governmental authority responsible for payment. 89 0 obj <>stream 20. hbbd``b`J@1`ug&Fs YF_ Fla. R. Civ. A party who has responded to a request to produce with a response that was complete at the time is under no duty to supplement the response to include after-acquired documents. See Rule 81(c), Rule 1.390 states an experts testimony can be obtained in accordance with the rules for taking depositions. Fla. R. Civ. WebRequest for Production of Documents - TO DEFENDANTParty: Defendant Florida Peninsula Insurance Co January 27, 2014. 350 East Las Olas Boulevard, Suite 1000 Fort Lauderdale, Florida 33301 Telephone 954-525-9900 Facsimile 954-523-2872 IN THE CIRCUIT COURT OF THE 17TH For authorities updated in real time, please see the SmartRules Guide for the litigation document you are drafting. Our goal is to help people in the best way possible. LOG IN. A party may seek inspection and copying of any documents or things within the scope of rule 1.350 (a) from a person who is not a party by issuance of a subpoena Web3. Please produce copies of all pleadings, orders, notices or other documents pertaining to any criminal or traffic court proceeding related to this collision. Form Name. Use this At A Glance Guide to learn theFlorida Rules of Civil Procedure applicable to amended answer inFlorida Circuit Courts. Any individual, corporation, partnership, joint venture, firm, association, proprietorship, agency, board, authority, commission or any other entity. Includes, without limitation, writings, emails (whether printed or not), agreements, contracts, and printed matter of every kind and description; data stored on a computer hard disk or other memory card, photographs and drawings; notes and records of any oral communications; e-mails and recordings (tape, disc or other) of oral communications. New Document: Florida VA Fixed Note. WebWhen you need Discovery Request Sample, don't accept anything less than the USlegal brand. Read court documents, court records online and search Trellis.law comprehensive legal database for any state court documents. A request for production is a discovery device used to gain access to documents, electronic data, and physical items held by an opposing party in a legal It is intended that the court review each objection and weigh the need for discovery and the likely results of it against the right of privacy of the party or witness or custodian. WebWhen a case with outstanding requests for production is removed to federal court, the time for response would be measured from the date of the parties meeting. %PDF-1.5 % On June 11, 2014, Plaintiffs served Defendant with Plaintiffs Third Request for Production of Documents (the Request). Fla. R. Civ. Twitter Poll Decides Future of Twitter, The New Twitter: The Bad Boss May Be A Hero for Exploited Children. =]fQAFfRQg Please produce any and all insurance policies which may provide coverage to you for part or all of any judgment for which they may be adjudged liable in this action or under which you may be indemnified or reimbursed for payments made to satisfy such judgment. Instructions to the Asking Party (a) These interrogatories are designed for optional use by P. 1.350(b). 63 0 obj <> endobj Procedural Law v. Substantive Law What Is The Differance? Web20. These forms are to be used for production of documents under rule 1.351. You can simply request the documents duces tecum at deposition to achieve the same result. % Production of documents by non-parties is accomplished through the subpoena process under Florida Rule of Civil Procedure 1.351. 13. endstream endobj startxref endstream endobj 64 0 obj <>/Metadata 6 0 R/PageLayout/OneColumn/Pages 61 0 R/StructTreeRoot 10 0 R/Type/Catalog>> endobj 65 0 obj <>/Font<>>>/Rotate 0/StructParents 0/Type/Page>> endobj 66 0 obj <>stream Copy costs will not be paid without prior written approval. A party objecting to a request for production must provide the reasons for the objection. 1980 Amendment. Please produce any and all books, documents or other tangible items relating to the collision described in Plaintiffs Complaint or any of Plaintiffs claims or your defenses in this action. A sample request for the production of documents (RFP) that a party in a Florida circuit court civil case may use to request the production or inspection of documents or other tangible items from another party. The Difference Between Workers Compensation and Disability Benefits with Associated Work Related COVID-19 Illnesses. The authorities cited in this At A Glance Guide are current as of the publication date. SmartRules only services accounts in the United States and customers with special access needs from abroad. Please produce any and all correspondence, memoranda, reports, written notes, diagrams, charts or other similar documents which relate to the collision described in Plaintiffs Complaint or any of Plaintiffs claims or your defenses in this action. Make your practice more effective and efficient with Casetexts legal research suite. Our Gainesville lawyers are some of the premier lawyers dealing with employment law, personal injury lawsuits and wage and hour cases, in Gainesville and throughout Florida. INTRODUCTORY NOTES I. Definitions As used in this Request for Production of Documents, the following terms mean: (a) You or your The person(s) to whom this Request for Documents are addressed and all other persons acting or purporting to act on said persons behalf. WebThe parties seeking documents must serve the other party with a Notice of Intent to seek third party production 10 days before any subpoena is to be issued if by delivery, or 15 days if by mail. Warning graphic content: The details surrounding this horrific act are still to be 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, 'F!zv0@Wj(GlULb$[4c:z 8=}^f*XdP^;-7Uvvn 6{SDQuMho+0P^;IZ' Plaintiff requests that the following documents be produced at the law offices of the undersigned within 30 days. Request For Production of Documents In-Aid-of-Execution: Another discovery method available to creditors, pursuant to Florida Rules of Procedure 1.350(a), is to request the production of documents. Please produce any and all insurance policies that relate in any way to the allegations in Plaintiffs Complaint or incidents referred to in Plaintiffs Complaint. Zzuo3 Please produce any and all documents which contain or are related to any surveillance or investigation concerning Plaintiffs claims or allegations in this action. If no objection to the discovery is made, inspection is had without a court order. Enter to open, tab to navigate, enter to select, Practical Law Standard Document w-000-0440, https://content.next.westlaw.com/practical-law/document/Ibd96133e8e9011e38578f7ccc38dcbee/Request-for-the-Production-of-Documents-RFP-FL?viewType=FullText&transitionType=Default&contextData=(sc.Default), Request for the Production of Documents (RFP) (FL). After Rule 26 Meeting. Personal Injury. Form Request for Production in Florida Circuit Court At A Glance, Ex Parte Motion in United States District CourtAt A Glance, Alex Murdaugh Found Guilty On All Charges, International Shoe The Case That Keeps on Giving, Motions An Overview for Civil Litigation. %%EOF Webboilerplate objections to discovery requests.3 Usually, boilerplate objections are found in responses to interrogatories under Federal Rule of Civil Procedure 33,4 or in requests for production of documents under Federal Rule of Civil Procedure 34.5 But they can be found in nearly any pretrial document that might contain an objection.6 WebThe Eugene Police Department has a full-time Public Information Coordinator opportunity. Derived from Federal Rule of Civil Procedure 34 as amended in 1970. 11. If a party fails to respond to a request for production, the propounding party may move for an order compelling production under Rule 1.380. florida rules of civil procedure . 1972 Amendment. 77 0 obj <>stream P. 1.350(b). Please produce any and all documents prepared by anyone as a result of tests, inspections or measurements made or taken with respect to the scene of the incident. A reference to Florida Rule of Judicial Administration 2.425 and rule 1.280(f) is added to require persons filing discovery materials with the court to make sure that good cause exists prior to filing discovery materials and that certain specific personal information is redacted. 19. Subdivision (a) is amended to address the production of electronically stored information. endobj (regarding expert witnesses). The party serving the request for production may move for an order compelling production under Rule 1.380. WebUS Legal Forms Request for Production of Documents - Personal Injury Documents Court Form The Forms Professionals Trust! (b) If you maintain that any document or record referred to herein has been lost, misplaced or destroyed, set forth the contents of said document, a description of said document, the location of any copies of said document, the date of such loss or destruction and, if the document was destroyed, the name of the person who operated or authorized said destruction. Please produce a curriculum vitae for, and any and all documents containing the opinions or analyses of, any person whom you expect to call as an expert witness at the trial of this case, which concern any issue pertaining to the instant lawsuit. Casetext, Inc. and Casetext are not a law firm and do not provide legal advice. FLSA Class Actions For Unpaid Wages And Overtime, Are They Worth It? After Rule 26 Meeting. IN THE CIRCUIT COURT OF THE EIGHTH JUDICIAL CIRCUIT IN AND FOR ALACHUA COUNTY, FLORIDA Ronique T. Myers, Case No. Please produce any and all correspondence, memoranda, reports, written notes, diagrams, charts or other similar documents which relate to the incident described in Plaintiffs Complaint or any of Plaintiffs claims or your defenses in this action. Please produce any and all documents identified, referred to or used by any person in connection with the compilation of your Responses to Plaintiffs First Interrogatories. 21. A party may propound a supplemental demand to inspect any later acquired or discovered documents, tangible things, land, or other property that are in the possession, custody, or control of the party on whom the demand is made subject to the time limits on discovery proceedings in the case. One Form You may receive a Request for Production that is very similar to the items below, hence I am requesting that you gather them now rather than forced to latter on. The new rule eliminates the good cause requirement of the former rule, changes the time for making the request and responding to it, and changes the procedure for the response. P. 1.350(b). This Standard Document has integrated drafting notes with important explanations and drafting tips. production of documents 13 a. preparation and interpretation of requests for documents 13 b. procedures governing manner of production 18 iv. If an objection is made only to part of a demand, the objectionable section must be specified. 76 0 obj <>/Filter/FlateDecode/ID[]/Index[59 31]/Info 58 0 R/Length 87/Prev 100751/Root 60 0 R/Size 90/Type/XRef/W[1 2 1]>>stream A Request for Production of Documents (often referred to as a Notice to Produce) requires a spouse to provide the other spouse with certain documents for review. 14. Please produce copies of your current drivers license and the registration for the vehicle involved in the collision described in Plaintiffs Complaint. P. 1.350). Apply today for an opportunity to join the proud lega (a) Unless otherwise indicated, this Request for Documents concerns and relates to the incident which is described in Plaintiffs Complaint. WebA sample request for the production of documents (RFP) that a party in a Florida circuit court civil case may use to request the production or inspection of documents or other This is our approach to every case. P. 1.380(b)(2). As used in this Request for Production of Documents, the following terms mean: The person(s) to whom this Request for Documents is addressed and all other persons acting or purporting to act on said persons behalf. Requests for Production United States District Court Southern District of Florida. Privacy Statement|Accessibility Statement|Legal Notice(850) 922-5081500 South Duval Street, Tallahassee, FL, 32399-1925, All Content Copyright 2023 Florida Courts, Subpoena for Production of Documents from Nonparty (included in part a above), Court Councils, Commissions, and Committees, General Contract Conditions for Services and Commodities, Additional Supporting Documents | 12.902 | Forms B - J, Answers to Dissolution | 12.903 Forms A - E, Attorney/Non-Lawyer Representation | 12.900 | Forms A - H, Disestablish Paternity | 12.951 Forms A - B, Dissolution Final Judgments | 12.990 Forms A - C2, Dissolve/Modify Injunction | 12.940 Forms D - E, Income Deduction Order | 12.996 Forms A- C, Involving Relocation | 12.950 Forms A - J, Modification of Final Judgments | 12.993 Forms A - C, Motion to Deviate from Child Support Guidelines | 12.943 Form, Notices and Diligent Search | 12.913 Forms A - C, Petition for Dissolution of Marriage | 12.901 | Forms A - B3, Petition for Support Unconnected with Dissolution | 12.904 Forms A - B, Prevent Removal of Child(ren) | 12.941 Forms A - E, Show Cause for Violations | 12.980 Forms W, X, Summons and Memorandum | 12.910 Forms A - B, Supplemental (Modification) Petitions | 12.905 Forms A - C, Supporting Documents | 12.980 Forms G - J, M, Temporary Custodial Responsibility During Deployment / 12.948 Forms A-E, Testimony and Attendance of Minor Child(ren) | 12.944Forms A - B, 500 South Duval Street, Tallahassee, FL, 32399-1925. A party who has Subpoena for Production of Documents from Nonparty (included in part a above) Form Number 12.931(b) Form Type Procedural Date 11/2015 PDF File 931ab.pdf Please produce any medical or employment records you have obtained relating to the Plaintiff. For more detailed information, please see the SmartRules Request for Production guides for the court where your action is pending. 855 East University Ave.; Gainesville FL 32601, CORONAVIRUS AID, RELIEF AND ECONOMIC SECURITY for FLORIDA. P. 1.350(b). (b) If you maintain that any document or record referred to herein has been lost, misplaced or destroyed, set forth the contents of said document, a description of said document, the location of any copies of said document, the date of such loss or destruction and, if the document was destroyed, the name of the person who operated or authorized said destruction. Please produce all documents relating to alco-sensor, breathalyzer or blood-alcohol tests you performed on the date of the collision. A party may not seek discovery from any source before the parties have conferred as required by Rule 26(f), except in a proceeding exempted from initial disclosure under Rule 26(a)(1)(B), or when authorized by these rules, by P. 1.280(e). Each demand must designate the documents, tangible things, land, or other property to be inspected either by specifically describing each individual item or by reasonably particularizing each category of item. Our. Your response to this request should be periodically supplemented. hVn6~n(EYIiYc36Yr%9M#Hr.J"},`R113fgrXDL(aJ2G)FR/a*)P^ The Request contained 6 requests that sought production of documents related to <>/ExtGState<>/ProcSet[/PDF/Text/ImageB/ImageC/ImageI] >>/MediaBox[ 0 0 612 792] /Contents 4 0 R/Group<>/Tabs/S/StructParents 0>> While the good cause requirement has been eliminated, the change is not intended to overrule cases limiting discovery under this rule to the scope of ordinary discovery, nor is it intended to overrule cases limiting unreasonable requests such as those reviewed in Van Devere v. Holmes, 156 So. |]!NHYjc+)TH&WmWOMZAQnJk IfK.iQD6c_&"2ufCyZ&@WHGm Y4E~`eQ *'R:tT|5V=JtA!i5;N}Hjxe4qK1nm(9<4g3%G} Please produce any and all reports from any accident investigators or reconstruction experts or engineers. Please produce a copy of all transcripts containing the testimony of any party or witness pertaining to the instant collision. interrogatories 21 a. preparation and answering of interrogatories 21 b. objections, privilege, and responses 22 c. other interrogatory issues 23 v. subpoenas 25 a. general 25 b. contents of subpoena 26 As used in this Request for Production of Documents, the following terms mean: (a) You or your The person (s) to whom this Request for Documents are Fla. R. Civ. Any and all documents, receipts or vouchers reflecting the funds provided to you WebPlaintiff request for production of documents sample breach. If you're a paid subscriber and still having difficulty, please contact our support desk with your IPv4 address so we can investigate. 287555) dselarz@selarzlaw.com . 2. HUnS1F5 !Db@Iig|_37r[MG6yTW 5t; ]7]QGp %PDF-1.4 % The central theme of 2022 was the U.S. governments deploying of its On Monday, February 27, 2023, a man in St Louis Missouri calmly loaded his firearm in broad daylight with people watching then aimed it at the head of a homeless man sitting on the street curb and pulled the trigger. Should not the requesting partys counsel be required to, by personal skill, knowledge, and reasoning, request the production of documents within general and specific categories, and, upon receipt and review of same, use his or her own thought processes to determine whether they constitute support for Count II? Payment shall be made within Please produce any and all documents or other written material which you contend evidence, support or refute any fact or circumstance relating to your defenses or claims in this action. WebDescription:This position will create pro-active and responsive solutions to corporate strategy; facilitate live and online training programs including new hire, peer and need-specific training, and the design of instructional materials and liaise with all departments and all levels of management to create learning solutions/opportunities within their 10. Please produce all documents which relate to or evidence your authority/permission, or lack thereof, to operate the vehicle which you were driving at the time of the collision. Requests for Production United States District Court Southern District of Florida. A party may not seek discovery from any source before the parties have conferred as required by Rule 26(f), except in a proceeding exempted from initial disclosure under Rule 26(a)(1)(B), or when authorized by these rules, by Fla. R. Civ. 7. 21. For each item or category the response shall state that inspection and related activities will be permitted as requested unless the request is objected to, in which event the reasons for the objection is made to part of an item or category, the part shall be specified. Fla. R. Civ. What can your opposing spouse or partner ask for? Please produce any and all photographs, videotapes, motion pictures, drawings, sketches, diagrams, plats or the like taken at or made of the scene of the incident or any person or physical object which relate in any way to the circumstances of the incident. R. Civ. Webe.The general subject matter of the document or portion thereof for which privilege is claimed; and f.The type of document (e.g., memorandum, report, draft, letter, etc.).