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Each party may file no more than one motion for summary judgment under rule 1.981. The motion may include more than one ground authorized under rule 1.281(3)(b)(1). (3) Deadline. Motions for summary judgment under rule 1.981 must be filed no later than 90 days before trial.
In ordering discovery of such materials when the required showing has been made, the court shall protect against disclosure of the mental impressions, conclusions, opinions, or legal theories of an attorney or other representative of a party concerning the litigation.
1. 504(3) A motion for protective order must include a certification that the movant has in good faith personally spoken with or attempted to speak with other affected parties in an effort to resolve the dispute without court action.
Unless the court upon motion orders otherwise for the convenience of parties and witnesses and in the interests of justice, or the parties stipulate, methods of discovery may be used in any sequence and the fact that a party is conducting discovery, whether by deposition or otherwise, shall not operate to delay any ...
Unless otherwise ordered by the court, no deposition, notice of deposition, interrogatory, request for production of documents, request for admission, or response, document or thing produced, or objection thereto shall be filed with the clerk.
An attorney can issue a subpoena without a court file being opened, but if the clerk issues a blank subpoena, a court file must be opened and will collect a $50 fee. Rule 1.1702(5). A court file will also be opened for any motions relating to the subpoena and the clerk will collect a $50 fee then as well.
Rule 1.303 - Time for motion or answer to petition 1. 303(1) Unless otherwise provided, the defendant, respondent, or other party shall serve, and within a reasonable time thereafter file, a motion or answer within 20 days after the service of the original notice and petition upon such party.
In addition, rule 1.943 allows for voluntary dismissal of the plaintiff's petition without prejudice once as a matter of right. Id. r. 1.943.