In 2021, The Supreme Court of Florida adopted the “apex rule” pertaining to attempts to depose corporate and government officials. In re Amend.to Fla. R. Civ. Proc. 1.280, 324 So.3d 459, 461 (Fla. 2021). Rule 1.280(h) now...more
Cases in which plaintiffs advance a claim for imposition of punitive damages are among the most likely to keep a defense lawyer up at night. Several recent cases from Florida district courts of appeal have reinforced the...more
The Apex Deposition Doctrine (“ADD”) provides powerful protection against abusive discovery practices to high-ranking officials in public service and in private industry. ADD was designed and developed in Florida to prevent...more
Defending corporate representative depositions in the new reality. If there is one lesson all trial lawyers have learned over the last year, it’s that life and the practice of law must go on, even in the face of upheavals...more