Fla. Fam. L. R. P. 12.340

RULE 12.340

INTERROGATORIES TO PARTIES

(a) Procedure for Use. Without leave of court, any party

may serve on any other party written interrogatories to be answered

by the party to whom the interrogatories are directed, or if that

party is a public or private corporation or partnership or association

or governmental agency, by any officer or agent, who must furnish

the information available to that party. Interrogatories may be

served on the petitioner after commencement of the action and on

any other party with or after service of the process and initial

pleading on that party. A party may serve fewer than all of the

approved interrogatories within a form.

(1) Initial Interrogatories. Initial interrogatories to

parties in original and enforcement actions must be those set forth

in Florida Family Law Rules of Procedure Form 12.930(b). Parties

governed by the mandatory disclosure requirements of rule 12.285

may serve the interrogatories set forth in Florida Family Law Rules

of Procedure Form 12.930(b).

(2) Modification Interrogatories. Interrogatories to

parties in cases involving modification of a final judgment must be

those set forth in Florida Family Law Rules of Procedure Form

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12.930(c). Parties governed by the mandatory disclosure

requirements of rule 12.285 may serve the interrogatories set forth

in Florida Family Law Rules of Procedure Form 12.930(c).

(b) Additional Interrogatories. Ten interrogatories,

including subparts, may be sent to a party, in addition to the

standard interrogatories contained in Florida Family Law Rules of

Procedure Form 12.930(b) or Florida Family Law Rules of Procedure

Form 12.930(c). A party must obtain permission of the court to

send more than 10 additional interrogatories. The expert

interrogatories authorized by rule 12.280 are not included within

the limitation of ten additional interrogatories to a party prescribed

by this rule.

(c) Service of and Objections to Interrogatories. Each

interrogatory must be answered separately and fully in writing

under oath unless it is objected to, in which event the grounds for

objection must be stated and signed. The party to whom the

interrogatories are directed must serve the answers and any

objections within 30 days after the service of the interrogatories,

except that a respondent may serve answers or objections within 45

days after service of the process and initial pleading on that

respondent. The court may allow a shorter or longer time. The party

submitting the interrogatories may move for an order under rule

12.380(a) on any objection to or other failure to answer an

interrogatory.

(d) Serving of Responses. Parties must serve responses to

interrogatories on the requesting party. Responses must not be filed

with the court unless they are admitted into evidence by the court

and are in compliance with Florida Rule of General Practice and

Judicial Administration 2.425. The responding party must file with

the court Florida Family Law Rules of Procedure Form 12.930(d),

Notice of Service of Answers to Standard Family Law

Interrogatories.

(e) Scope; Use at Trial. Interrogatories may relate to any

matters that can be inquired into under rule 12.280(b), and the

answers may be used to the extent permitted by the rules of

evidence except as otherwise provided in this subdivision. An

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interrogatory otherwise proper is not objectionable merely because

an answer to the interrogatory involves an opinion or contention

that relates to fact or calls for a conclusion or asks for information

not within the personal knowledge of the party. A party must

respond to such an interrogatory by giving the information the

party has and the source on which the information is based. Such a

qualified answer may not be used as direct evidence for or

impeachment against the party giving the answer unless the court

finds it otherwise admissible under the rules of evidence.

(f) Option to Produce Records. When the answer to an

interrogatory may be derived or ascertained from the records

(including electronically stored information) of the party to whom

the interrogatory is directed or from an examination, audit, or

inspection of the records or from a compilation, abstract, or

summary based on the records and the burden of deriving or

ascertaining the answer is substantially the same for the party

serving the interrogatory as for the party to whom it is directed, an

answer to the interrogatory specifying the records from which the

answer may be derived or ascertained and offering to give the party

serving the interrogatory a reasonable opportunity to examine,

audit, or inspect the records and to make copies, compilations,

abstracts, or summaries, production of the records in lieu of a

written response is a sufficient answer. An answer must be in

sufficient detail to permit the interrogating party to locate and to

identify, as readily as can the party interrogated, the records from

which the answer may be derived or ascertained, or must identify a

person or persons representing the interrogated party who will be

available to assist the interrogating party in locating and identifying

the records at the time they are produced. If the records to be

produced consist of electronically stored information, the records

must be produced in a form or forms in which they are ordinarily

maintained or in a reasonably usable form or forms.

(g) Effect on Other Parties. Answers made by a party are

not binding on any other party.

(h) Service. Interrogatories must be arranged so that a

blank space is provided after each separately numbered

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interrogatory. The space must be reasonably sufficient to enable the

answering party to insert the answer within the space. If sufficient

space is not provided, the answering party may attach additional

pages with answers and refer to them in the space provided in the

interrogatories. Interrogatories must be served on the party to

whom the interrogatories are directed and copies must be served on

all other parties. A certificate of service of the interrogatories must

be filed, giving the date of service and the name of the party to

whom they were directed. The answers to the interrogatories must

be served on the party originally propounding the interrogatories

and a copy must be served on all other parties by the answering

party. The original or any copy of the answers to interrogatories

may be filed in compliance with Florida Rule of General Practice

and Judicial Administration 2.425 and rule 12.280(j) by any party

when the court should consider the answers to interrogatories in

determining any matter pending before the court. The court may

order a copy of the answers to interrogatories filed at any time when

the court determines that examination of the answers to

interrogatories is necessary to determine any matter pending before

the court.

1995 Adoption. For parties governed under the disclosure

requirements of rule 12.285(d) (income or expenses of $50,000 or

more), the answers to the interrogatories contained in Form

12.930(b) must be automatically served on the other party. For

parties governed under the disclosure requirements of rule

12.285(c) (income and expenses under $50,000), the service of the

interrogatories contained in Form 12.930(b) is optional as provided

in Florida Rule of Civil Procedure 1.340. Additionally, under this

rule, 10 additional interrogatories, including subparts, may be

submitted beyond those contained in Florida Family Law Rules of

Procedure Form 12.930(b). Leave of court is required to exceed 10

additional interrogatories. The provisions of Florida Rule of Civil

Procedure 1.340 are to govern the procedures and scope of the

additional interrogatories.

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1997 Amendment. The rule was amended to conform to the

changes made to rule 12.285, Mandatory Disclosure.