Two workhorses of divorce discovery arrive together in most contested Florida cases: interrogatories (written questions you must answer under oath) and requests to produce (demands for documents). Less dramatic than depositions, they do more of the case’s heavy lifting — and how you answer them shapes your credibility for the duration. Here is how both work, from The Law Office of John Vernon Moore, P.A. in Melbourne.
Interrogatories: Sworn Answers in Writing
Florida provides standard family law interrogatories covering the predictable ground — employment and income history, assets and how they were acquired, debts, monthly expenses, claims about the marriage and children — and permits additional tailored questions within court limits. Answers are due in 30 days, signed under oath. Their power is permanence: your written answers function like deposition testimony, fixed and usable for impeachment. An answer drafted carelessly in month two becomes the exhibit that undercuts you in month nine.
Requests to Produce: The Documents Themselves
Requests for production reach the underlying records: account statements, tax filings, business books, loan applications, titles and deeds, texts and emails on relevant topics, pay records, and anything else reasonably calculated to lead to admissible evidence. The response — also due in 30 days — either produces the documents, states they do not exist or are not in your possession, or objects with specific legal grounds. Boilerplate objections and document-dumps of disorganized paper are both sanctionable games; Florida expects organized, responsive production. These requests extend what mandatory disclosure started, and subpoenas to banks and employers verify that what was produced is what exists.
Answering Well: The Defensive Craft
Our approach with clients is consistent. Answer what is asked, precisely — no volunteering, no essays. Anchor every number to a document; where your financial affidavit already answered, keep the answers consistent. Object where the law supports it — privilege, overbreadth, harassment — but never as a reflex, because reflexive objections invite motions you will lose. Meet the deadline. Late responses waive objections you were entitled to make; ignored ones bring motions to compel, fee awards against you, and in escalating cases the Rule 12.380 sanctions ladder — up to exclusion of evidence and adverse inferences. Thirty days passes faster than anyone expects; start the week they arrive.
Asking Well: The Offensive Craft
Drafted lazily, these tools produce paper. Drafted purposefully, they produce a map: interrogatories that force an inventory of every account and income source, production requests sequenced to test that inventory, and follow-up aimed at the gaps between the two. The comparison work is where cases turn — the loan application claiming income the interrogatory answers deny, the account produced in year-old statements but missing from the affidavit, the Venmo history that contradicts the claimed budget. When answers stonewall, the escalation is standard and effective: conferral, motion to compel, fees — and a judge whose patience for the evasive spouse is now spent.
Proportionality, Again
Every request costs review time on both sides of the case. We scale written discovery to what the dispute is actually about — a W-2 marriage with two bank accounts needs a fraction of what a self-employed spouse with three LLCs requires. Spending $5,000 in fees to chase $2,000 in questions is a loss even when you find them; strategy is knowing the difference. That judgment is a large part of keeping divorce costs proportionate.
Frequently Asked Questions
Do I have to answer every single question?
You must respond to every question — with an answer or a proper objection your attorney asserts. Silence on any item is what draws motions.
What if the true answer changes later?
Florida imposes a duty to supplement: material changes (new job, new account) require updated responses. Supplementing promptly reads as candor; getting caught instead reads as concealment.
Can they really demand my text messages?
Relevant ones, yes — and courts enforce it. Delete nothing once litigation begins; spoliation sanctions outlast any embarrassment a message could cause.
The requests feel invasive and endless. Any limits?
Yes — courts limit numbers of interrogatories, require relevance, and entertain protective orders for genuine overreach. The line between thorough and harassing is real, and we hold it from both directions.
Paper Wins Cases — Handle It Like It Matters
Our team brings over 89 years of combined experience to written discovery that builds cases and answers that protect them. Call (321) 529-7777 or contact us online for a free 30-minute consultation.