The 60-Day Countdown: Navigating Florida’s New Mandatory Initial Disclosures

Effective January 1, 2025, Florida has moved closer to the federal model. Under the amended Rule 1.280(a), parties must now exchange initial discovery disclosures within 60 days of the complaint, without waiting for a request.

The New Timeline

The 60-day clock starts at service of the complaint. Within that window, parties must disclose witnesses with discoverable information, copies (or descriptions) of relevant documents, computations of damages, and any applicable insurance policies. There is no need to wait for a discovery request, the rule is self-executing.

The Strategic Opportunity for Mediation

At Alvarez ADR, we view this as a structural advantage for ADR. By day 60, parties have a meaningful basis for risk assessment. Smart counsel are scheduling mediations within days 60-90, before depositions add tens of thousands of dollars to the cost without adding much to the merits picture.

Common Pitfalls

We are already seeing motion practice over “adequacy” of disclosures. The most common challenges involve incomplete damages computations and missing insurance policies. Counsel should treat these initial disclosures as substantive filings, not boilerplate.

Recommended Workflow

Calendar a mediation date at the same time you receive service of process. Aim for day 75-90. Use the 60-day disclosure window to drive both your demand letter and your mediation memo. The result: settlement before discovery becomes the case.