Topic: Discovery

Vorbeck v. Betancourt – Dismissal of Pure Bill of Discovery

In this case, the plaintiffs filed a complaint for a “pure bill of discovery” to obtain information attempting to confirm plaintifffs’ suspicions that a 50% owner of the subject company had misappropriated corporate assets.  The trial court dismissed the complaint, and the appellate court affirmed, on the basis that “the bill of discovery was improper because the [plaintiffs]… Read more

Rescission of Settlement Agreement for Discovery Misconduct – Garvin v. Tidwell

In this case, the plaintiff was injured when she fell off of a horse, named “Buster,” who had behaved obstreperously while plaintiff tried to ride him.  Defendant claimed that Buster never exhibited any dangerous behavior.  The case settled.  After the settlement, plaintiff’s counsel received an unmarked advertisement quoting the defendant as saying that she decided… Read more

In camera review required for discovery records protected by constitutional right of privacy – James v. Veneziano

In this car accident case, the plaintiff sought defendant’s medical records for the past 10 years based on the belief that the defendant’s medical problems caused the car accident.  The trial court ordered the defendant to produce the records.  The Defendant objected to producing the records on the basis that he had a right of… Read more

Error to enter Summary Judgment while discovery pending – Almond Entertainment, Inc. v. Bayview Loan Servicing, LLC

Bayview Loan filed a commercial foreclosure action against Almond and later moved for summary judgment.  At some point, it is not clear whether it is before or after the MSJ was filed, Almond moved to compel the deposition of Bayview’s corporate representative.  It is also unclear whether that motion to compel was ever ruled on.… Read more

Rules Updates – New E-discovery and E-mail Service Rules Effective September 1st

Per the Florida Supreme Court’s Order amending the Florida Rules of Civil Procedure to implement service by email, the following rules have been updated: 1.080 Service of Pleadings, Orders, and Documents 1.170 Counterclaims and Crossclaims 1.351 Production of Documents and Things Without Deposition 1.410 Subpoena 1.440 Setting Action for Trial 1.442 Proposals for Settlement 1.510… Read more

Florida Supreme Court implements e-discovery amendments – Effective September 1st

The amendment covers seven civil procedure rules: 1.200 (Pretrial Procedure); 1.201 (Complex Litigation); 1.280 (General Provisions Governing Discovery); 1.340 (Interrogatories to Parties); 1.350 (Production of Documents and Things and Entry Upon Land for Inspection and Other Purposes); 1.380 (Failure to Make Discovery; Sanctions); and 1.410 (Subpoena). The amendment largely mirrors the Federal Rules, but does not require… Read more

NAN H. MULLINS, D.M.D. v. ALICE TOMPKINS, 34 Fla. L. Wkly D1456a (Fla. 1st DCA July 21, 2009)

In this dental malpractice case, the trial court denied the defendant’s motion for protective order requesting non-disclosure of work-product and attorney-client documents sent to a testifying expert.  The plaintiff claimed that the defendant waived any privilege when his counsel sent the documents to the expert.  The defendant claimed that no waiver occurred because the expert never read the… Read more