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3rd DCADecember 21, 2018Petition Granted; Discovery Order Quashed⭐ Notable

Iacono v. Santa Elena Holdings, LLC

Case No. 18-2165

The Third DCA granted certiorari and quashed a trial court order compelling the depositions of opposing counsel and their paralegal, which had been granted orally at a brief motion calendar status conference without allowing opposing counsel to respond. The court held the movant failed to carry its burden under the three-factor Shelton test, and the trial court departed from the essential requirements of law by not considering all Shelton factors.

Key facts

  • Iacono sought to depose opposing counsel and their paralegal at Santa Elena Holdings, LLC in a pending case.
  • The trial court orally granted the motion to compel depositions at a brief motion calendar status conference without allowing opposing counsel an opportunity to respond.
  • +2 more key facts with a free trial

Why it matters

This is a clean, citable reaffirmation that Florida's Third DCA applies the federal Shelton test before opposing counsel may be deposed, and that certiorari lies to review such orders. Practitioners facing subpoenas… — full analysis with a trial

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