Florida Rule 1.280 Initial Disclosures Checklist

What must be disclosed

Without waiting for a discovery request, each party must give the other parties the following, unless privileged or protected from disclosure (Rule 1.280(a)):

• Witnesses: the name and, if known, the address, telephone number and email address of each individual likely to have discoverable information the party may use to support its claims or defenses, along with the subjects of that information. Witnesses used solely for impeachment are excluded.
• Documents and things: a copy, or a description by category and location, of all documents, electronically stored information and tangible things in the party's possession, custody or control that the party may use to support its claims or defenses, again excluding impeachment-only use.
• Damages: a computation of each category of damages claimed and a copy of the documents or other evidentiary material on which each computation is based, including materials bearing on the nature and extent of injuries. A computation is not required for noneconomic damages, but the categories must be identified with supporting documents.
• Insurance: a copy of any insurance policy or agreement under which an insurance business may be liable to satisfy all or part of a possible judgment or to indemnify or reimburse payments made to satisfy it.

Timing and exemptions

• Disclosures are due within 60 days after service of the complaint or joinder, unless the court sets a different time.
• Actions and claims listed in Rule 1.200(a) are exempt unless the court orders otherwise. That list includes actions and proceedings initiated under chapters 731 through 736, 738 and 744, Florida Statutes, which covers probate and guardianship.
• A party discloses based on the information reasonably available to it. It is not excused because it has not fully investigated the case, because it challenges another party's disclosures or because another party has not made its own.
• A party who formally objects to providing certain information must still make all the other required disclosures on time.

What follows from disclosure

• Discovery sequence: a party may not seek discovery from any source before that party's own initial disclosures are served, except by stipulation or court order.
• Supplementing: a party must supplement or correct a disclosure in a timely manner if it learns that it is materially incomplete or incorrect and the additional information has not otherwise been made known to the other parties.
• Signature: each disclosure must be signed by at least one attorney of record with the attorney's address, email address and telephone number. The signature certifies the disclosure is complete and correct as of the time it is made, after reasonable inquiry.
• Filing: information obtained in discovery is not filed with the court unless there is good cause, which is satisfied only when another rule or a court order allows or requires it.

Scope and proportionality

Discovery generally reaches any nonprivileged matter relevant to a party's claim or defense and proportional to the needs of the case, considering the importance of the issues, the amount in controversy, the parties' relative access to information, their resources, the importance of the discovery in resolving the issues and whether the burden or expense outweighs the likely benefit. See the civil litigation deadlines cheat sheet for how this fits with other deadlines.

This page reflects Rule 1.280 as published with its June 19, 2025 amendment. General information for Florida practitioners, reviewed in October 2026. It is not legal advice. Rules change, so confirm against the current text before relying on it.

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