Court Rules

Limits & Logistics

Courtesy Copies

Courtesy copies

  • Email
  • No Later Than Three Business Days Before Hearing or Trial
  • Three Business Days Before Hearing

Exhibits

  • For Voluminous Exhibits

Memorandum, Case Law

  • Email • At Least Three Business Days Before Hearing

Motion, Petition, Court Order Response

Adjournments

  • Unless good cause is shown, a continuance motion must be signed by the party requesting it.
  • A continuance motion must specifically state the basis for the request, when that basis became known, and whether the motion is opposed.

Request must include

Reason for RequestAdversary Position

Communication

Email

Chambers

denise.moffitt@flcourts1.gov
Scheduling
Email
ada.escambia@flcourts1.gov
Phone

Chambers

850-595-4453
Scheduling
Phone
(850) 595-4400
Phone
(850) 595-4533
Fax
(850) 595-0360
Filters:

Document Format Requirements3 rules

FormattingMandatory

All attorneys and self-represented litigants must bring sufficient copies of each exhibit for the clerk, the Court, and each party to review during the hearing or trial.

Fl First:47f1860898c3110f5fd66145
|SectionG. Exhibits for Evidentiary Proceedings
FormattingMandatory

All proposed orders must be submitted in Microsoft Word format.

File type
Word
Applies to
  • Proposed order
Fl First:47f1860898c3110f5fd66145
|SectionD. Submission of Orders and Judgments
FormattingNote

Copies can be submitted in PDF or Word format.

Fl First:47f1860898c3110f5fd66145
|SectionE. Courtesy Copies of Case Law and Other Documents

Document Filing Requirements17 rules

Filing RequirementsMandatory

The proposed order must be accompanied by a cover letter certifying that all parties agree to the contents/language of the order or in the body of the email, or a statement identifying any disagreement of the parties as to the proposed order.

Fl First:47f1860898c3110f5fd66145
|SectionD. Submission of Orders and Judgments
Filing RequirementsMandatory

As to discovery dispute motions in particular, the Court may sua sponte deny motions that fail to include an appropriate and complete Certificate of Compliance.

Fl First:47f1860898c3110f5fd66145
|SectionB. Scheduling Procedures
Filing RequirementsMandatory

A hearing will not be set without the required certificate.

Fl First:47f1860898c3110f5fd66145
|SectionB. Scheduling Procedures
Filing RequirementsMandatory

If a party believes there is a factual basis for setting an emergency hearing, a detailed motion setting forth the following must be filed: (1) the issues to be resolved, (2) reasons why an emergency hearing is necessary, and (3) the amount of time needed for each party’s presentation.

Fl First:47f1860898c3110f5fd66145
|SectionF. Emergency and Other Urgent Matters
Filing RequirementsMandatory

The Notice of Hearing must be filed and served immediately after reserving hearing time with a courtesy copy to the judicial assistant.

Fl First:47f1860898c3110f5fd66145
|SectionB. Scheduling Procedures
Filing RequirementsImportant

Please notate in your email if this hearing is time sensitive due to an upcoming trial date.

Fl First:47f1860898c3110f5fd66145
|SectionB. Scheduling Procedures
Filing RequirementsImportant

Hearing notices must contain the Americans with Disabilities Act (ADA) notification required by Florida Rule of General Practice and Judicial Administration 2.540.

Fl First:47f1860898c3110f5fd66145
|SectionB. Scheduling Procedures
Filing RequirementsImportant

You must cancel hearings by notifying the judicial assistant immediately via email with a courtesy copy of the Notice of Cancellation attached and a proposed order, if the hearing is cancelled due to a resolution of the pending matter.

Fl First:47f1860898c3110f5fd66145
|SectionB. Scheduling Procedures
Filing RequirementsImportant

Other proposed orders must be accompanied by a separate cover letter advising that all parties agree to their contents and language.

Court's wording

All other proposed orders should be e-filed through the proposed order portion of the Florida Courts E-Filing Portal with a cover letter under separate cover advising that all parties agree to the contents/language of the proposed order.

Fl First:47f1860898c3110f5fd66145
|SectionD. Submission of Orders and Judgments
Filing RequirementsImportant

A party will file a Notice for Trial or Motion for Case Management Conference.

Fl First:47f1860898c3110f5fd66145
|SectionI. Setting Case for Trial
Filing RequirementsImportant

The proposed orders must include the names and email addresses of all parties who will need to receive e-service of same.

Fl First:47f1860898c3110f5fd66145
|SectionD. Submission of Orders and Judgments
Filing RequirementsImportant

It is the responsibility of attorneys and self-represented litigants to update their contact information using Form 2.603 any time there is a change in the email account registered for electronic service.

Fl First:47f1860898c3110f5fd66145
|SectionA. Communications with the Judicial Office
Filing RequirementsImportant

Notice of Hearings must include the date, time, type of hearing, and location (in-person at the courthouse or Zoom teleconference).

Fl First:47f1860898c3110f5fd66145
|SectionB. Scheduling Procedures
Filing RequirementsImportant

Your email must include the following: Case Number Party Names Type of Hearing (Motion(s) to be set) Length requested for hearing (make certain you request enough time for both sides to be heard)

Fl First:47f1860898c3110f5fd66145
|SectionB. Scheduling Procedures
Filing RequirementsImportant

The subject line of any email must contain the case number and case name (e.g., 2024 CA 001234 – Doe v. Doe).

Fl First:47f1860898c3110f5fd66145
|SectionA. Communications with the Judicial Office
Filing RequirementsImportant

All matters to be considered by the Court should be in the form of a motion or pleading, filed and served on all parties.

Fl First:47f1860898c3110f5fd66145
|SectionA. Communications with the Judicial Office
Filing RequirementsImportant

If the parties agree on a Motion, the moving party shall submit a proposed order in Microsoft Word format.

Filing & Service rules

Electronic Filing Rules

All other proposed orders should be e-filed through the proposed order portion of the Florida Courts E-Filing Portal with a cover letter under separate cover advising that all parties agree to the contents/language of the proposed order.

All other proposed orders should be e-filed through the proposed order portion of the Florida Courts E-Filing Portal with a cover letter under separate cover advising that all parties agree to the contents/language of the proposed order.

Page 1 | D. Submission of Orders and Judgments

Filing Timing and Cure Windows

Proposed orders must be submitted within the time set by separate court order or stated at the hearing, and the submission period should never exceed 30 days.

Propose orders must be submitted within the time provided by the Court in a separate order or verbally at the hearing. In no event should the time for submission exceed thirty (30) days.

Page 1 | D. Submission of Orders and Judgments

Memoranda or case law for the judge’s consideration before a hearing should be emailed or e-filed at least three business days in advance.

Any memorandum and/or case law that parties wish for the judge to consider prior to a hearing should be emailed or e-filed at least three business days before the hearing.

Page 1 | G. Exhibits for Evidentiary Proceedings

Service and Proof of Service Rules

The Notice of Cancellation must be served on opposing counsel and any self-represented litigant.

The Notice of Cancellation must be served upon opposing counsel and any self-represented litigant.

Page 1 | B. Scheduling Procedures

The notice of hearing must be served immediately after hearing time is reserved.

The Notice of Hearing must be filed and served immediately after reserving hearing time with a courtesy copy to the judicial assistant.

Page 1 | B. Scheduling Procedures

All matters to be considered by the Court should be in the form of a motion or pleading, filed and served on all parties.

All matters to be considered by the Court should be in the form of a motion or pleading, filed and served on all parties.

Page 1 | A. Communications with the Judicial Office

Attorneys and self-represented litigants must provide an email address for electronic receipt of signed orders.

All attorneys and self-represented litigants must provide an email address to receive signed orders electronically.

Page 1 | A. Communications with the Judicial Office

Courtesy Copy Requirements

Courtesy copies must reach the court no later than three business days before a hearing or trial unless the court specifies otherwise.

Courtesy copies must be submitted to the court no later than three (3) business days before any hearing or trial. Unless otherwise specified by the court.

Page 1 | E. Courtesy Copies of Case Law and Other Documents

Because the court is not notified when documents are e-filed, the moving party must send the judicial assistant a courtesy copy of a motion or petition and of documents filed in response to a court order.

The Court is not notified when documents are e-filed. To bring a motion or petition to the Court’s attention, the moving party shall send a courtesy copy to the judicial assistant. The same is true when documents are filed in response to a court order.

Page 1 | E. Courtesy Copies of Case Law and Other Documents

Memoranda or case law a party wants considered at a hearing should be emailed to the judicial assistant at least three business days before the hearing.

If a party wishes the Court to consider a memorandum or case law for a hearing, the same should be submitted to the judicial assistant, via email, at least three business days in advance of the hearing.

Page 1 | E. Courtesy Copies of Case Law and Other Documents

If said documents are voluminous, please submit binders three business days before the hearing.

If said documents are voluminous, please submit binders three business days before the hearing.

Page 1 | B. Scheduling Procedures

Voluminous courtesy-copy documents should be submitted in binders.

If said documents are voluminous, please submit binders.

Page 1 | E. Courtesy Copies of Case Law and Other Documents

A courtesy copy of the notice of hearing must be provided to the judicial assistant when the notice is filed and served after hearing time is reserved.

The Notice of Hearing must be filed and served immediately after reserving hearing time with a courtesy copy to the judicial assistant.

Page 1 | B. Scheduling Procedures

Memoranda or case law for the judge’s consideration before a hearing should be emailed to the judicial assistant at least three business days beforehand.

Any memoranda and/or case law that parties wish for the judge to consider prior to a hearing should be emailed to the judicial assistant at denise.moffitt@flcourts1.gov at least three business days before the hearing.

Page 1 | B. Scheduling Procedures

Courtesy copies may be emailed to the court at the listed address.

Copies can be submitted to the court by email to denise.moffitt@flcourts1.gov.

Page 1 | E. Courtesy Copies of Case Law and Other Documents

Bindering is strongly encouraged for voluminous exhibits, which should be delivered or mailed to the judge’s office.

For voluminous exhibits, binders are strongly encouraged and should be submitted via hand delivery or mail to the judge’s office.

Page 1 | G. Exhibits for Evidentiary Proceedings

Pre-Motion Conference Requirements

A meet-and-confer requires a substantive, good-faith in-person or telephone conversation aimed at resolving the motion; an exchange of written ultimatums or an unsuccessful attempt alone is insufficient.

MEET AND CONFER: The term "confer" requires a substantive conversation, in person or by telephone, in a good faith effort to resolve the motion without court action and does not envision a written exchange of ultimatums. Counsel who merely attempt to confer have not conferred.

Page 1 | B. Scheduling Procedures

The court strongly encourages parties to meet and confer when possible, in addition to complying with Florida Rule of Civil Procedure 1.202.

In addition to complying with the terms of Fla. R. Civ. P. 1.202, the Court strongly encourages the parties to meet and confer when possible.

Page 1 | B. Scheduling Procedures

Adjournment & Extension Requirements

A continuance motion must specifically state the basis for the request, when that basis became known, and whether the motion is opposed.

Continuance Procedure: Motions for continuance must state with specificity: (1) the basis of the need for the continuance, including when the basis became known to the movant and (2) whether the motion is opposed.

Page 1 | B. Scheduling Procedures

Unless good cause is shown, a continuance motion must be signed by the party requesting it.

Except for good cause shown, the motion must be signed by the party requesting the continuance, as required by Florida Rule of General Practice and Judicial Administration 2.545(e).

Page 1 | B. Scheduling Procedures

Chambers Communication Rules

A hearing cancellation must be emailed to the judicial assistant immediately with a courtesy copy of the cancellation notice attached and, if cancellation follows resolution, a proposed order.

You must cancel hearings by notifying the judicial assistant immediately via email with a courtesy copy of the Notice of Cancellation attached and a proposed order, if the hearing is cancelled due to a resolution of the pending matter.

Page 1 | B. Scheduling Procedures

Communications about pending or impending proceedings must comply with Canon 3’s restrictions on ex parte communications unless authorized by law.

All communications with the judicial office must comply with Canon 3 of the Code of Judicial Conduct, which prohibits a judge from initiating, permitting, or considering ex parte communications and other communications outside the presence of the parties concerning a pending or impending proceeding, unless authorized by law.

Page 1 | A. Communications with the Judicial Office

After coordinating dates with opposing counsel, the parties must email the judicial assistant, and the hearing is not set until the assistant confirms it.

After obtaining available dates, coordinate with opposing counsel to select dates that work for all parties. Once the parties have agreed on the potential date(s), please inform the judicial assistant via email, and she will reply to confirm that the time slot is still available, and the hearing is being set. The hearing is not considered set until you receive confirmation from the judicial assistant.

Page 1 | B. Scheduling Procedures

Emails to the judicial office must copy all parties unless law authorizes otherwise.

All parties must be copied on any email directed to the judicial office, unless authorized by law.

Page 1 | A. Communications with the Judicial Office

If a hearing is scheduled within 24 hours, the judicial assistant must also be notified by phone at the listed number.

If the hearing is scheduled to occur within 24 hours, a phone call to the judicial assistant at 850-595-4453 is also required.

Page 1 | B. Scheduling Procedures

Additional motions may not be added to an existing hearing without prior coordination, and the court will not hear motions that were not properly scheduled and noticed.

No additional motions should be added to the existing hearing time without first coordinating with the judicial assistant and other counsel/parties. The Court will not hear motions that have not been properly scheduled and noticed.

Page 1 | B. Scheduling Procedures

Communications to the judicial office must be emailed to the listed address with opposing counsel or the self-represented litigant copied.

Method of Communication: All communications to the judicial office must be submitted by email to denise.moffitt@flcourts1.gov with copy to opposing counsel or self-represented litigant.

Page 1 | A. Communications with the Judicial Office

If no objection to the Notice of Readiness for Trial is filed, the moving party must schedule a case management or status conference using the hearing instructions.

If no objection is filed to the Notice of Readiness for Trial, the moving party must schedule the CMC or status conference through the hearing instructions outlined above.

Page 1 | H. Pretrial Procedures and Conferences

A hearing-scheduling email must include opposing counsel and any self-represented litigant.

Opposing counsel and any self-represented litigant must be included in the email.

Page 1 | B. Scheduling Procedures

The court will not consider unsolicited communications from non-parties.

Unsolicited communications from non-parties will not be considered by the court.

Page 1 | A. Communications with the Judicial Office

Proposed orders relating to a hearing should be emailed to the judicial assistant in Microsoft Word format.

All proposed orders relating to a hearing should be emailed to the judicial assistant at denise.moffitt@flcourts1.gov in Microsoft Word format.

Page 1 | D. Submission of Orders and Judgments

A hearing date is not protected or final until the judge’s office is notified that the parties coordinated it.

Dates will not be protected/final until the judge’s office is notified that the hearing date has been coordinated.

Page 1 | B. Scheduling Procedures

The judicial assistant must not be included in parties’ conferrals about availability or discussion of the case.

Moreover, the judicial assistant shall not be included in conferrals between the parties regarding availability or otherwise discussing the case.

Page 1 | A. Communications with the Judicial Office

Parties must not use email to argue substantive issues.

Attempts to argue substantive issues through email will not be tolerated.

Page 1 | A. Communications with the Judicial Office

A hearing may be scheduled by conference call with the judicial assistant and opposing counsel or by emailing the assistant.

Hearings may be scheduled by conference call with the judicial assistant with opposing counsel on the telephone or by emailing the judicial assistant at denise.moffitt@flcourts1.gov.

Page 1 | B. Scheduling Procedures

Email should be used to schedule hearings involving more than two parties and for routine non-case-related matters.

Email shall be utilized for scheduling hearings with more than two parties and routine non-case related matters.

Page 1 | A. Communications with the Judicial Office

For an interpreter needed at a hearing or trial, contact the listed phone number.

If an interpreter is needed for a hearing or trial, please contact (850) 595-4533.

Page 1 | K. Other Division Procedures

To schedule a case management conference, contact the judicial assistant by phone or email at the listed details.

Scheduling: Contact the judicial assistant via phone at (850) 595-4453 or via email at denise.moffitt@flcourts1.gov.

Page 1 | H. Pretrial Procedures and Conferences

Parties may call the judicial assistant at the listed number for assistance with proposed orders.

You may contact the judicial assistant at (850) 595-4453 if you need assistance.

Page 1 | D. Submission of Orders and Judgments

For ADA accommodations, contact the Escambia County Court Administration ADA Liaison using the listed phone, fax, email, or address.

If you need ADA accommodations, please contact: Court Administration, ADA Liaison Escambia County 190 Governmental Center, 5th Floor Pensacola, FL 32502 Phone (850) 595-4400 Fax (850) 595-0360 ADA.Escambia@flcourts1.gov

Page 1 | K. Other Division Procedures

Court-wide rules

Applies court-wide

These 2 rules apply across First Judicial Circuit of Florida, Escambia, Okaloosa, Santa Rosa and Walton Counties. Where this judge's own standing orders above address the same topic, the judge's requirement controls.

Pre-Motion Conferences

All 2
  • The first sample certificate attests that counsel with authority to resolve the matter conferred in person or by telephone in good faith before the motion was noticed for hearing.

  • The second sample certificate attests that counsel made three good-faith attempts to contact opposing counsel to discuss resolving the motion without a hearing but could not speak with them.

Common questions about Judge Paul Bailey's rules

Are courtesy copies required for Judge Paul Bailey?

Courtesy-copy rule applies for motions, petitions, and court order responses. Because the court is not notified when documents are e-filed, the moving party must send the judicial assistant a courtesy copy of a motion or petition and of documents filed in response to a court order.

View ruleSource: page 1, section E. Courtesy Copies of Case Law and Other Documents

Does Judge Paul Bailey require a pre-motion conference or letter before filing a motion?

The court strongly encourages parties to meet and confer when possible, in addition to complying with Florida Rule of Civil Procedure 1.202.

View ruleSource: page 1, section B. Scheduling Procedures

What formatting rules apply to filings before Judge Paul Bailey?

Judge Paul Bailey's formatting rule includes file format docx. All proposed orders must be submitted in Microsoft Word format.

View ruleSource: page 1, section D. Submission of Orders and Judgments

What must be included with hearing request filings before Judge Paul Bailey?

The rule requires certificate of conference. A hearing will not be set unless the required certificate is provided.

View ruleSource: page 1, section B. Scheduling Procedures

What must be included with discovery motion filings before Judge Paul Bailey?

The court may sua sponte deny a discovery-dispute motion that lacks an appropriate and complete Certificate of Compliance.

View ruleSource: page 1, section B. Scheduling Procedures

How may parties contact Judge Paul Bailey's chambers?

Communications about pending or impending proceedings must comply with Canon 3’s restrictions on ex parte communications unless authorized by law.

View ruleSource: page 1, section A. Communications with the Judicial Office

How do I request an adjournment or extension before Judge Paul Bailey?

Unless good cause is shown, a continuance motion must be signed by the party requesting it.

View ruleSource: page 1, section B. Scheduling Procedures

Is electronic filing required before Judge Paul Bailey?

Yes. Electronic filing is required for the covered filings. All other proposed orders should be e-filed through the proposed order portion of the Florida Courts E-Filing Portal with a cover letter under separate cover advising that all parties agree to the contents/language of the proposed order.

View ruleSource: page 1, section D. Submission of Orders and Judgments

What filing deadlines does Judge Paul Bailey set?

Proposed orders must be submitted within the time set by separate court order or stated at the hearing, and the submission period should never exceed 30 days.

View ruleSource: page 1, section D. Submission of Orders and Judgments

What rule applies to service for notice of hearing before Judge Paul Bailey?

Details: recipient: all parties. The notice of hearing must be served immediately after hearing time is reserved.

View ruleSource: page 1, section B. Scheduling Procedures
Complete rules summary for Judge Paul Bailey

Unless good cause is shown, a continuance motion must be signed by the party requesting it.

Communications to the judicial office must be emailed to the listed address with opposing counsel or the self-represented litigant copied.

Emails to the judicial office must identify the case number and case name in the subject line.

Communications about pending or impending proceedings must comply with Canon 3’s restrictions on ex parte communications unless authorized by law.

Emails to the judicial office must copy all parties unless law authorizes otherwise.

The court will not consider unsolicited communications from non-parties.

Attorneys and self-represented litigants must provide an email address for electronic receipt of signed orders.

Attorneys and self-represented litigants must update their contact information on Form 2.603 whenever their registered electronic-service email changes.

Email should be used to schedule hearings involving more than two parties and for routine non-case-related matters.

All matters to be considered by the Court should be in the form of a motion or pleading, filed and served on all parties.

All matters to be considered by the Court should be in the form of a motion or pleading, filed and served on all parties.

Parties must not use email to argue substantive issues.

The judicial assistant must not be included in parties’ conferrals about availability or discussion of the case.

The court strongly encourages parties to meet and confer when possible, in addition to complying with Florida Rule of Civil Procedure 1.202.

A hearing will not be set unless the required certificate is provided.

A meet-and-confer requires a substantive, good-faith in-person or telephone conversation aimed at resolving the motion; an exchange of written ultimatums or an unsuccessful attempt alone is insufficient.

The court may sua sponte deny a discovery-dispute motion that lacks an appropriate and complete Certificate of Compliance.

A hearing may be scheduled by conference call with the judicial assistant and opposing counsel or by emailing the assistant.

A hearing-scheduling email must include opposing counsel and any self-represented litigant.

A hearing-scheduling email must identify the case number, party names, hearing type, and requested hearing length sufficient for both sides.

A hearing-scheduling email should identify when the hearing is time sensitive because of an upcoming trial date.

After coordinating dates with opposing counsel, the parties must email the judicial assistant, and the hearing is not set until the assistant confirms it.

A hearing date is not protected or final until the judge’s office is notified that the parties coordinated it.

Immediately after reserving hearing time, the notice of hearing must be filed and served, and a courtesy copy must go to the judicial assistant.

The notice of hearing must be served immediately after hearing time is reserved.

A courtesy copy of the notice of hearing must be provided to the judicial assistant when the notice is filed and served after hearing time is reserved.

A notice of hearing must state the hearing’s date, time, type, and location, including whether it is in person or by Zoom.

Hearing notices must include the ADA notification required by Florida Rule of General Practice and Judicial Administration 2.540.

Additional motions may not be added to an existing hearing without prior coordination, and the court will not hear motions that were not properly scheduled and noticed.

Memoranda or case law for the judge’s consideration before a hearing should be emailed to the judicial assistant at least three business days beforehand.

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