Objections and Responses to Notice of Deposition
(FL)

Summary

This template is a set of objections and responses that can be used in a Florida state court case to object to a notice of deposition. It contains practical guidance and drafting notes. A party who wants to take an oral deposition must give reasonable notice in writing to every other party to the action. Fla. R. Civ. P. 1.310. You may object to the notice if it does not state the required information, such as when, where, and how the examination will take place. While these objections are not required, they memorialize your positions and can facilitate a resolution prior to the deposition. These sample objections assume that the plaintiff is the deposing party. For more on deposition and depositions generally, see Depositions: Drafting and Serving a Notice of Deposition (FL), Depositions: Preparing for and Taking an Individual's Deposition (FL), Depositions: Defending an Individual's Deposition (FL), and Depositions: Handling Unexpected Situations at a Deposition (FL). For related templates, see Deposition Notice (FL) and Deposition Notice (Organizational Representative) (FL). For a full listing of key content covering fundamental civil litigation tasks throughout a Florida state court litigation lifecycle, see Civil Litigation Fundamentals Resource Kit (FL).