Before filing the motion for a summary judgment, the lender’s attorney and the homeowner’s foreclosure defense attorney, if they have one, may engage in a discovery period. This is where both sides put out requests for documents, responses, admissions and depositions among other items. For the lender, they want to make sure that the important facts in their case are not disputable. For the foreclosure defense attorney, they want to find out if there’s anything the lender has done that would give the homeowner a case if it can be brought to trial. In general, the discovery deposition is not common in foreclosure processes in Florida.