Limits & Logistics
Document Limits
Courtesy Copies
Exceptions Objections Pleading
Pre Summary Judgment Hearing Stipulation
- 1 copy • Email • No Later Than 3 Days Before Hearing
Proposed Order
Trial Brief
- At Least 3 Business Days Before Trial
Adjournments
- An inability to obtain a hearing date within the expected period generally is not grounds to extend deadlines or continue trial.
- Unless good cause is shown, a continuance motion must be written, signed by the requesting party, include a Certificate of Good Faith, and detail efforts to move the case and resolve discovery.
- A continuance stipulation must contain the same information as a continuance motion and will be reviewed individually.
- +7 more
Request must include
Communication
Page & Word Limits2 rules
All Statements of Material Facts (whether filed by the movant or the non-movant) shall be filed and served as separate documents and not as exhibits or attachments. In addition, the Statements of Material Facts shall: (A) Not exceed ten (10) pages;
- Statement of material facts
- Up to 10 pages
The additional facts shall be separately titled “Additional Facts” and may not exceed seven (7) pages (beyond the ten (10) page limit for the movant’s Statement of Material Facts.
- Additional facts
- Up to 7 pages
- Movant statement of material facts
- Up to 10 pages
Document Format Requirements15 rules
In order to have a clear record, counsel using a demonstrative aid shall be prepared to have the aid marked as an exhibit and entered into the record, regardless of whether or not the aid will be introduced into evidence.
All exhibits must be marked in advance of trial using consecutive numbers (for the Plaintiff) and letters (for the Defendant).
All exhibits shall be pre-marked for identification.
Each jury instruction must be on a separate page, in the desired order, include supporting-authority citations where applicable, and identify opposition and any concise objection.
Court's wording
Each instruction shall be on a separate page; shall be in the order the parties desire it to be presented to the jury; shall contain citations of supporting authorities where applicable; and shall designate whether the instruction is being opposed and, if so, the opposing party shall provide a concise objection to the instruction.
If opposing counsel has an objection, the aid shall not be displayed or played before a jury before the Court has ruled on the objection.
a courtesy copy of the filed respective proposed orders must be emailed to the Court’s Judicial Assistant in Word format by the same deadline as the filing of the proposed orders;
F. If you are to be sworn in, you must appear via video.
All proposed orders must include a cover letter in .pdf format.
- File type
- Cover letter
All proposed orders must be submitted in the appropriate format.
B. Once you enter the Zoom Room, mute your line until your case is called. C. Please ensure you have connected to audio. If you have not connected to audio, the Court will not be able to hear you. D. Please ensure you have logged in with a display name that identifies who you are. E. As a reminder, being in the Zoom Room is the same as being in the courtroom and as such, proper courtroom decorum should be adhered to. You should wear proper attire (no hats), no smoking or vaping is allowed, and it is best if you are in a place as free of noise and distractions as possible.
Formatting
- •Connect to audio so the Court can hear you.
Participants should use their name or firm name, not a nickname or other phrase, as their Zoom screen name.
Court's wording
So that Judge Goodman can identify which persons in the waiting room are associated with a particular hearing, please set your Zoom user/screen name to your name or your firm’s name (as opposed to a nickname or other phrase).
Exhibits submitted for an evidentiary hearing should be pre-marked and identify the party intending to introduce each exhibit.
Court's wording
d. If documents being submitted include exhibits for an evidentiary hearing, please pre-mark the exhibits and identify the party intending to introduce the exhibit.
c. Please label the documents submitted to the drop box so that they can be easily identified
Proposed orders do not need to include the addresses or email addresses of recipients of the order at the end.
A. You may log in three (3) minutes before the scheduled start time of the hearing.
Document Filing Requirements68 rules
Said filing must separately list all exhibits the party intends to introduce into evidence at trial. Each item/exhibit must be listed by number for Plaintiff and letter for Defendant and contain a description of the exhibit. Generic descriptions of exhibits are subject to being stricken.
Any witness not disclosed as described herein shall not be permitted to testify at trial without an order of the Court.
The trial witness list must be alphabetical and include witness contact details, type, expected testimony, and, for experts, specialties and a curriculum vitae.
Court's wording
Said list shall contain the names and addresses of all witnesses intended to be called in trial in alphabetical order. The list must also designate the type of witness (“expert,” “rebuttal,” “impeachment,” “general fact,” etc.). It must also include a brief description of the substance and scope of the testimony to be elicited from each witness. All expert witness designations must also include the expert’s specialties on the list and attach a copy of the expert’s curriculum vitae.
The motion shall state with particularity the grounds upon which it is based and the substantial matters of law to be argued and identify any evidence or supporting materials on which the movant relies.
The attorneys for all parties are directed to meet by agreement, initiated by counsel for the Plaintiff, no later than 7 days before the Pretrial Conference to:
A Daubert-related motion or objection must state its grounds and legal issues with particularity and identify supporting evidence or materials.
Court's wording
Any Daubert-related motion or objection shall state with particularity the grounds upon which it is based and the substantial matters of law to be argued and shall specifically identify any evidence or supporting material on which the movant relies.
Prior to opening statements, counsel for each party shall deliver to the trial clerk an Exhibit List that contains an itemized list of all exhibits to be introduced during trial.
Plaintiff’s expert disclosure must include the listed expert information and two alternate deposition dates no later than 85 days before trial.
Court's wording
a. the name, address and telephone number of the expert witness; b. the area of expertise of the witness (i.e., “accident reconstruction,” “economist,” “orthopedic physician,” etc.) and the subject matter of the expected testimony; c. a complete and updated curriculum vitae; d. a summary of the opinions and grounds on which the opinions of the expert witness will be based; e. all other information as required by Florida Rule of Civil Procedure 1.280(c)(5); and f. two (2) alternate dates of availability of each expert witness for the purpose of taking the expert’s deposition, which dates shall be no later than 85 days prior to the trial date.
Any submitted verdict form must also be designated as “agreed to” or “disputed,” and when “disputed,” each party shall cite supporting authorities where applicable.
Defendant’s expert disclosure must include two alternate deposition dates no later than 70 days before trial.
Court's wording
This notice shall also include two (2) alternate dates of availability of each expert witness for the purpose of taking their deposition, which dates shall be no later than 70 days prior to the trial date.
A list of proposed exhibits shall be submitted directly to chambers by each of the parties by the deadline established in the Court’s Trial Order.
The movant and nonmovant must cite particular parts of materials in the record in the motion and response.
Affidavits or declarations supporting or opposing a motion must be based on personal knowledge, state admissible facts, and show the affiant or declarant is competent to testify.
Court's wording
If affidavits or declarations are being used to support or oppose a motion, the rule states that they must be “made on personal knowledge, set out facts that would be admissible in evidence, and show that the affiant or declarant is competent to testify on the matters stated.” Fla. R. Civ. P. 1.510(c)(4) (emphasis added).
All materials referenced in support of or opposition to the motion must be in the record and filed in the docket.
If a deposition transcript is referenced, a complete copy must be filed in the docket which includes all exhibits.
Movants and nonmovants must file a Pre-Summary Judgment Hearing Stipulation before the hearing.
Court's wording
In an effort to complete most summary judgment hearings within the presumptive scheduled 30-minute hearing time without such inefficiencies, delay, objections, and continuances the Court is requiring the movant(s) and nonmovant(s) to satisfy a Pre-Hearing Meeting Requirement and file a Pre-Summary Judgment Hearing Stipulation prior to the hearing as more specifically described below.
The movant’s Statement of Material Facts shall list the material facts that the movant contends are not genuinely disputed.
The movant shall respond to any additional facts asserted in the opponent’s Statement of Material Facts even if the movant does not serve a reply memorandum.
A non-movant’s Statement of Material Facts shall clearly challenge any purportedly material fact asserted by the movant that the non-movant contends is genuinely in dispute.
A motion for summary judgment and the opposition to it shall each be accompanied by a separate and contemporaneously filed and served Statement of Material Facts.
- Document
- Summary judgment motion and opposition
Must include
- •Statement of Material Facts
All Statements of Material Facts (whether filed by the movant or the non-movant) shall be filed and served as separate documents and not as exhibits or attachments.
The movant’s statement must use separately numbered paragraphs, limit each paragraph as far as practicable to one material fact, and support each fact with specific pinpoint citations; general exhibit citations without a page number or pincite are non-compliant when specific support is required.
Court's wording
(B) Consist of separately numbered paragraphs, limited as far as practicable to a single material fact, with each fact supported by specific, pinpoint references or citations as to particular parts of record material, including depositions, documents, electronically stored information, affidavits, stipulations (including those made for purposes of the motion only), admissions, and interrogatory answers (e.g., Docket Line 20, Exhibit D, Smith Affidavit, ¶; Exhibit 3, Jones deposition, p. 12/lines 4-9). When a material fact requires specific evidentiary support, a general citation to an exhibit without a page number or pincite (e.g., “Smith Affidavit” or “Jones Deposition” or “Exhibit A”) is non-compliant.
The non-movant’s statement must follow the movant’s order and paragraph numbering without repeating the movant’s paragraph text.
Court's wording
(A) In addition to complying with the requirements of sub-section (b)(1), a non- movant’s Statement of Material Facts shall correspond with the order and paragraph numbering format used by the movant, but it shall not repeat the text of the movant’s paragraphs.
When disputing a fact, the non-movant’s supporting citations must be limited to evidence specific to that dispute.
Court's wording
(C) If a non-movant’s Statement of Material Facts disputes a fact in the movant’s Statement of Material Facts, then the evidentiary citations supporting the nonmovant’s position must be limited to evidence specific to that particular dispute.
(B) A non-movant’s Statement of Material Facts shall use, as the very first word in each paragraph-by-paragraph response, the word “DISPUTED” or “UNDISPUTED.”
The non-movant’s additional material facts must follow its responses, continue the movant’s paragraph numbering, and be separately titled “Additional Facts.”
Court's wording
(D) Any additional facts that a non-movant contends are material to the motion for summary judgment shall be numbered and placed immediately after the non-movant’s response to the movant’s Statement of Material Facts. The additional facts shall use separately numbered paragraphs beginning with the next number following the movant’s last numbered paragraph. The additional facts shall be separately titled “Additional Facts”
The reply statement must follow the non-movant’s additional-fact order and numbering, begin each paragraph with “disputed” or “undisputed,” and provide particular record citations for disputed facts.
Court's wording
(B) The Reply Statement of Material Facts shall correspond with the order and paragraph numbering format used in the non-movant’s additional facts, identifying with the very first word in each as “disputed” or “undisputed” at the beginning of each paragraph in the statement, and if disputed, citing to particular parts of materials in the record in the same manner as required by subsections (b)(1) and (b)(2).
The stipulation must contain the required items, beginning with a section on the time to file a summary judgment motion and response under Rule 1.510(b) and (c)(5).
Court's wording
Counsel for the moving and non-moving parties shall prepare a Pre-Summary Judgment Hearing Stipulation (“Stipulation”) which shall be filed with the Court no later than 3 days prior to the summary judgment hearing with a courtesy copy emailed to the Court’s Judicial Assistant and must contain the following: 1. Time to File a Summary Judgment Motion and Response Rule 1.510 (b) and (c)(5):
Any such showing shall be reduced to an appropriate motion incorporating the nonmovant’s affidavit or declaration to be filed and heard prior to the summary judgment hearing in the event the issue cannot be resolved by a consent or agreed order.
The Stipulation shall confirm whether the nonmovant will be showing by affidavit or declaration that it cannot present facts essential to justify its opposition to the summary judgment motion.
If relied-on materials are not in the record, the parties must prepare a Consent or Agreed Order to add them or, if they cannot resolve the issue, file an appropriate motion.
Court's wording
To the extent such materials supporting the parties respective factual positions are not in the record, the parties shall either prepare a Consent or Agreed Order setting forth provisions to file such materials and make them part of the record to be considered by the Court or, in the event the parties are unable to resolve the issue(s), file an appropriate motion for the matter to be heard prior to or during the scheduled summary judgment hearing.
The Stipulation must identify any timing issues with filing or serving the summary-judgment motion, response, or supporting factual positions.
Court's wording
The Stipulation shall confirm whether there are any timing issues with the filing and service of the motion for summary judgment, including the movant’s supporting factual position, and the filing and service of the nonmovant’s response, including the nonmovant’s supporting factual position.
The Stipulation must confirm whether all materials relied on for the parties’ factual positions have been filed and are in the record.
Court's wording
The Stipulation shall confirm whether all materials, including depositions, documents, electronically stored information, affidavits or declarations, stipulations (including those made for purposes of the motion only), admissions, interrogatory answers, or other materials the moving and non-moving parties are relying on in support of their factual positions have been filed and, therefore, are in the record.
The Stipulation must state specific admissibility objections, including their legal grounds and reasons.
Court's wording
The Stipulation shall contain a statement reflecting specific objection(s) stating legal grounds and specific reasons why the material cited to support a dispute of fact cannot be presented in a form that would be admissible in evidence or why an affidavit or declaration to support or oppose a motion was not made on personal knowledge, did not set out the facts that would be admissible in evidence, and did not show that the affiant or declarant is competent to testify on the matters stated.
The Stipulation must identify any allegation that a party submitted an affidavit or declaration in bad faith or solely for delay.
Court's wording
The Stipulation shall confirm whether any of the parties are alleging that another party submitted an affidavit or declaration under this rule in bad faith or solely for delay, requiring the Court to retain jurisdiction following the entry of the order on the motion to hold a subsequent hearing to consider whether to order the submitting party to pay the other party the reasonable expenses, including attorney’s fees, it incurred as a result, or impose any other appropriate sanctions.
file the respective proposed orders as exhibits attached to a “Notice of Filing Plaintiff’s/Defendant’s Proposed Order on Defendant’s/Plaintiff’s Motion for Summary Judgment” cover pleading;
counsel, or the party if pro se, shall file a certification that they have read and agree to abide by this Standing Order and the presiding judge's Administrative Procedures, which may be found on the 14th Judicial Circuit's website, www.jud14.flcourts.org.
The hearing-request email must identify the case, include the motion and requested hearing details, copy all parties or counsel, and certify receipt and a good-faith effort to resolve the dispute.
- Document
- Hearing request email
Must include
- •Case number
Court's wording
Your email communication must be copied to all parties or counsel of record and must include a reference to the clerk’s assigned case number, a copy of the motion, a request for hearing date, names of counsel for parties, and the length of hearing requested. Further counsel shall certify that the disputed motion has been received by the opposing counsel/party and that the requestor has conferred with the opposing counsel/party in a good faith effort to resolve the matter without a hearing.
All proposed hearing times will be in the Central Time Zone, and all notices of hearing must set a hearing with reference only to Central Time Zone.
After written confirmation that the selected date remains available, the requester must provide a filed and served written Notice of Hearing identifying the motion by title and its filing date.
Court's wording
If this office confirms in writing that the selected date is still available, then the requesting party must provide this office with written Notice of Hearing which has been filed with the Clerk of Court and served to all parties or counsel of record. The Notice of Hearing must identify the specific motion by title and the date that the motion was filed with the Clerk of Court.
The requesting party or counsel of record must file a Notice that the action is at issue and ready to be set for trial pursuant to Rule 1.440, Fla. R. Civ. P.
All proposed orders must include a cover letter in .pdf format.
The cover letter must specify the opposing party’s agreement or failure to respond after at least seven days to object, and identify the relevant hearing and date if any.
Court's wording
The cover letter shall state with specificity that opposing counsel/party agrees to the proposed order or that the opposing counsel/party was given at least seven (7) days to object to the proposed order but failed to respond. The cover letter shall also reference the particular hearing and hearing date that the proposed order stems from, if any.
Counsel for all parties shall ensure that said Order is filed and shall review the Order in its entirety.
SHOULD AN ATTORNEY/PARTY REQUEST FOR A NON-EVIDENTIARY HEARING TO BE CONDUCTED IN-PERSON, THEY SHALL MAKE SUCH A REQUEST IN WRITING AND SHALL SET FORTH THE BASIS FOR THE REQUEST WITH SPECIFICITY.
Any proposed order not complying with the above instructions will not be entered.
When a case includes a pro se party not registered for e-portal service, the proposed order must include the prescribed service-responsibility statement as its last paragraph before “DONE AND ORDERED.”
Court's wording
If the case involves a pro se party who is not registered to receive filings from the e-portal, the proposed order shall include as the last paragraph (before DONE AND ORDERED) the following statement: The party who submitted this proposed order to the Court for approval is required to serve a copy of the signed order upon any person(s) not registered to receive service via the e-portal. Counsel receiving the served copy of an order entered is then charged with responsibility for serving (via U.S. mail or email) a copy of the signed order on any party not registered to receive service via the e-portal.
Witness lists must include telephone numbers and email addresses.
Court's wording
A. Five (5) Days Prior to Hearing: Exchange all evidence to be presented at the hearing and exchange witness lists, which shall include telephone numbers and email addresses.
If you plan on calling witnesses, you must file a Witness List which includes their telephone numbers and email addresses.
All email communications to the Court must be copied to all parties or counsel of record and must include a reference to the clerk’s assigned case number in the subject line.
Motions to substitute counsel must comply with Fla. R. Gen. Prac. & Jud. Adm. 2.505 and contain the client’s written consent.
Parties may not cancel a trial without first having filed a fully executed settlement agreement.
The motion shall set forth the reasons for withdrawal and the client’s last known address.
Filing & Service rules
Electronic Filing Rules
All proposed orders must be submitted via the 14th Judicial Circuit’s e-filing portal.
All proposed orders must be submitted via the 14th Judicial Circuit’s e-filing portal.
Page 3 | 3. SUBMISSION OF PROPOSED ORDERS
If the proposed order is contested, the order should not be submitted via the e-portal and you should contact this office to schedule a hearing on the contested matter.
If the proposed order is contested, the order should not be submitted via the e-portal and you should contact this office to schedule a hearing on the contested matter.
Page 3 | 3. SUBMISSION OF PROPOSED ORDERS
Disputed proposed orders must not be filed through the e-filing portal.
Said disputed proposed orders shall be submitted to the email of Mira Phillips and shall not be filed via the e-filing portal.
Page 3 | 3. SUBMISSION OF PROPOSED ORDERS
In lieu of sending an email with attachments or hard copies of hearing materials, all hearing materials should be submitted via Microsoft OneDrive drop box. The procedures of obtaining the drop box are: a. Any counsel or party that desires to provide hearing materials shall contact the judicial assistant and request a OneDrive drop box for the case. The email request shall be copied to all other counsel or parties. The judicial assistant will send out an email to all parties with a link to the drop box. b. Either the movant or party opposing the motion may submit documents to the drop box
In lieu of sending an email with attachments or hard copies of hearing materials, all hearing materials should be submitted via Microsoft OneDrive drop box. The procedures of obtaining the drop box are: a. Any counsel or party that desires to provide hearing materials shall contact the judicial assistant and request a OneDrive drop box for the case. The email request shall be copied to all other counsel or parties. The judicial assistant will send out an email to all parties with a link to the drop box. b. Either the movant or party opposing the motion may submit documents to the drop box
Page 6 | 5. EVIDENCE & WITNESSES
Do not email copies of hearing documents to the judicial assistant.
DO NOT email copies of hearing documents to the judicial assistant.
Page 7 | 4. HEARING PROCEDURE
Use the OneDrive drop box as the preferred method for submitting hearing materials; if it is unavailable, materials may be mailed in hard copy.
Use of the OneDrive drop box is the preferred method to submit materials to the Court in advance of a hearing. If it is impossible to use the drop box, materials may be submitted in hard copy format, to be mailed so that the documents are received at least three (3) business days prior to the hearing.
Page 7 | 4. HEARING PROCEDURE
Filing Timing and Cure Windows
After the parties’ meeting, the designated attorney must prepare and present the joint stipulation and checklist, file them, and file and email a copy to the judge’s assistant no later than 5 days before the conference.
Following the meeting by the parties prior to the Pretrial Conference, Plaintiff’s attorney (or Defendant’s attorney if Plaintiff is unrepresented) shall prepare and present to the opposing party a Joint Pretrial Conference Stipulation and Pretrial Conference Checklist. The aforementioned documents shall be filed, and a copy shall be filed and emailed directly to the Judge’s judicial assistant no later than 5 days prior to the Pretrial Conference.
Civil cases
Page 1 | Joint Pretrial Conference Stipulation and Pretrial Conference Checklist
Defendant must file a separate trial witness list no later than 45 days before trial.
Defendant must file a witness list (this list is different than the above-referenced fact witness disclosure) no later than 45 days prior to the trial date.
Civil cases
Page 1 | Trial Witness Lists
After discussion, proposed jury instructions and verdict forms must be filed and emailed to the judge’s assistant in Microsoft Word format no later than 3 days before the Pretrial Conference.
After discussing the matter, the proposed jury instructions and verdict forms shall be filed, and a copy shall be emailed to the Judge’s judicial assistant (in Microsoft Word format) no later than 3 days prior to the Pretrial Conference.
Civil cases
Page 1 | Jury Instructions and Verdict Form
Depositions, paper discovery, and related reports must be completed at least 75 days before trial.
All depositions and paper discovery and any report related thereto must be completed at least 75 days prior to the trial date.
Civil cases
Page 1 | Discovery Deadlines
Case-specific motions in limine must be filed no later than 70 days and heard no later than 30 days before trial.
All case-specific motions in limine shall be filed no later than 70 days prior to the trial date and must be heard no later than 30 days prior to the trial date.
Civil cases
Page 1 | Motions in Limine
Plaintiff must file a separate trial witness list no later than 55 days before trial.
Plaintiff must file a witness list (this list is different than the above-referenced fact witness disclosure) no later than 55 days prior to the trial date.
Civil cases
Page 1 | Trial Witness Lists
The objecting party must request a hearing within 3 days after filing the CME objection.
The objecting party shall have 3 days from the filing of the objection to request a hearing on the objection.
Civil cases
Page 1 | Discovery Deadlines
All dispositive motions, including summary-judgment motions, must be heard no later than 40 days before trial.
All dispositive motions, including motions for summary judgment, must be heard no later than 40 days prior to the trial date.
Civil cases
Page 1 | Dispositive Motions
A covered Daubert challenge must be raised by a specific motion filed no later than 65 days before trial.
Any challenge to the admissibility of evidence at trial asserted to be “novel scientific evidence” or based on a contention that anticipated expert testimony does not meet the requirements of section 90.702, Florida Statutes, and seeking a ruling in accordance with the decision in Daubert v. Merrell Dow Pharmaceuticals, 509 U.S. 579 (1993), must be raised by a specific motion which shall be filed no later than 65 days prior to the trial date.
Civil cases
Page 1 | Daubert Motions and Hearings
Mediation must commence no later than 65 days before trial.
Mediation must commence no later than 65 days prior to the trial date.
Civil cases
Page 1 | Mediation
Motions to amend pleadings must be filed no later than 100 days before trial.
All motions to amend the pleadings, however, shall be filed no later than 100 days prior to the trial date.
Civil cases
Page 1 | Non-Dispositive Motions
A CME objection must be filed within 30 days after service, subject to the stated service-of-process condition, and must state specific reasons.
Objections to the CME request shall be filed no later than 30 days after the service of the request (assuming that service of process has occurred at least 15 days prior to the request being served) and shall state specific reasons for the objection.
Civil cases
Page 1 | Discovery Deadlines
The parties must file and serve fact-witness lists no later than 120 days before trial, including names, addresses, and a brief description of testimony.
3. Fact Witness Disclosure: No later than 120 days prior to the trial date, the parties must file and serve a list of names and addresses of all fact witnesses who may testify at trial, including witnesses expected to be called for impeachment or rebuttal. Each party’s fact witnesses must include a brief description of the substance and scope of the testimony to be elicited from such witnesses at trial.
Civil cases
Page 1 | Fact Witness Disclosure
CME examinations must be completed and examiner reports issued no later than 45 days before trial.
CMEs shall be completed, and written reports issued by the examiner, no later than 45 days prior to the trial date.
Civil cases
Page 1 | Discovery Deadlines
Plaintiff must serve and file expert disclosures no later than 130 days before trial.
No later than 130 days prior to the trial date, Plaintiff shall serve on all other parties and file with the Court a notice containing the following information regarding each expert Plaintiff believes will testify at trial:
Civil cases
Page 1 | Expert Witness Disclosure- Plaintiff
A Daubert-related motion must be set for an evidentiary hearing and heard no later than 40 days before trial.
Any Daubert-related motion shall be set for an evidentiary hearing and heard no later than 40 days prior to the trial date.
Civil cases
Page 1 | Daubert Motions and Hearings
A written CME request complying with Rule 1.360 must be made no later than 120 days before trial.
Requests for compulsory medical examinations (CME) shall be made in writing and in compliance with Rule 1.360, no later than 120 days prior to the trial date.
Civil cases
Page 1 | Discovery Deadlines
Discovery-related and other non-dispositive motions must be filed at least 75 days and heard at least 30 days before trial.
All motions related to discovery and other non-dispositive motions shall be filed no later than 75 days prior to the trial date and must be heard no later than 30 days prior to the trial date.
Civil cases
Page 1 | Non-Dispositive Motions
Each Defendant must serve and file expert disclosures no later than 110 days before trial, with the required expert information and two alternate deposition dates.
Expert Witness Disclosure- Defendant: No later than 110 days prior to the trial date, each Defendant shall serve on all other counsel, and file with the Court, a notice containing the same information as set forth in sections (a)-(f) above regarding each expert witness who will testify at trial on behalf of Defendant.
Civil cases
Page 1 | Expert Witness Disclosure- Defendant
If the parties cannot agree on a mediator or location, counsel must notify the Court by 90 days before trial, and each party must provide two preferred mediators and a proposed appointment order.
If the parties are unable to agree on a mediator and/or a place for the mediation, counsel shall notify the Court no later than 90 days prior to the trial date and each party shall provide the Court with two (2) preferred mediators and a proposed order appointing a mediator.
Civil cases
Page 1 | Mediation
Each party must file an exhibit list, including rebuttal exhibits, no later than 45 days before trial.
Each party must file an exhibit list no later than 45 days prior to the trial date, which reflects all exhibits intended to be offered at trial, including rebuttal exhibits.
Civil cases
Page 1 | Exhibit Lists
Trial exhibits, briefs, proposed jury instructions, and proposed verdict forms must be filed in the record within 5 business days after the verdict.
All trial exhibits, briefs, proposed jury instructions and proposed verdict forms are to be filed in the record within five (5) business days of the verdict.
Civil cases
Page 1 | Filing Exhibits
A defendant may file a summary judgment motion 20 days after the Complaint is filed, but the Court will not hear a premature motion.
The rule states a party can move for summary judgment as soon as 20 days “from the commencement of the action.” Fla. R. Civ. P. 1.510(b). Rule 1.050 states that an action “shall be deemed commenced when the Complaint or Petition is filed.” Technically, a defendant can file a motion for summary judgment 20 days after the Complaint is filed; however, the Court will not hear premature motions (see below).
Civil cases
Page 3 | The Summary Judgment Timeline
The Reply Statement of Material Facts is due on the same date as the reply memorandum.
The due date for the Reply Statement of Material Facts is the due date for the reply memorandum below.
Civil cases
Page 6 | STATEMENT OF MATERIAL FACTS REQUIREMENT
The parties must prepare and file the stipulation no later than three days before the hearing and email a courtesy copy to the Court’s Judicial Assistant.
Counsel for the moving and non-moving parties shall prepare a Pre-Summary Judgment Hearing Stipulation (“Stipulation”) which shall be filed with the Court no later than 3 days prior to the summary judgment hearing with a courtesy copy emailed to the Court’s Judicial Assistant and must contain the following:
Civil cases
Page 8 | Requirements of the Pre-Summary Judgment Hearing Stipulation
The Reply Statement of Material Facts and any Reply Memorandum of Law are due at least seven days before the hearing.
(D) The due date for the Reply Statement of Material Facts and Reply Memorandum of Law is at least 7 days before the time fixed for the hearing.
Civil cases
Page 8 | Reply Statement of Material Facts
Any timing issues must be raised by written motion filed and heard before the summary-judgment hearing.
Any timing issues shall be reduced to an appropriate written motion to be filed and heard prior to the summary judgment hearing.
Civil cases
Page 9
Specific admissibility objections must be raised in a written objection or motion filed and heard before the summary-judgment hearing.
Any such specific admissibility objections shall be reduced to an appropriate written objection or motion to be filed and heard prior to the summary judgment hearing.
Civil cases
Page 9 | Admissible Evidence Fla. R. Civ. P. 1.510(c)(2) and (4)
These rules and procedures apply to summary judgments filed on or after May 1, 2024.
The aforementioned rules and procedures shall apply to all summary judgments filed in this Court on, or after, MAY 1, 2024.
Civil cases
Page 11 | EFFECTIVE DATE
The plaintiff must file the Standing Order along with the summons and complaint.
Plaintiff shall file and serve this Standing Order upon all named Defendant(s) along with the summons and complaint.
Page 1 | STANDING CIVIL CASE MANAGEMENT ORDER: ESTABLISHING GENERAL CASE TRACK DEADLINES
Deadlines in the Order will be strictly enforced unless a later court order alters or modifies them.
All deadlines established by this Order shall be strictly enforced unless specifically altered or modified by a subsequently issued order of this Court.
Page 1 | CASE TRACK ASSIGNMENT DEADLINES
Civil actions, except those covered by Rule 1.200(a), must be assigned a case management track within 120 days after filing.
All civil actions, except those enumerated in Fla. R. Civ. P. 1.200(a), must be assigned one of three case management tracks within 120 days after the action is filed.
Page 1 | STANDING CIVIL CASE MANAGEMENT ORDER: ESTABLISHING GENERAL CASE TRACK DEADLINES
Pretrial motions must be filed 45 days before the Pre-Trial Conference.
Filing and Resolution of All The filing shall be 45 days before the Pre-Trial Pretrial Motions Conference.
Page 2 | CATEGORY: "GENERAL" CASE TRACK DEADLINES
A motion for summary judgment must be filed 75 days before the initially set Pre-Trial Conference.
Filing and service of motion for 75 days before the initially set Pre-Trial Conference
Page 2 | CATEGORY: "GENERAL" CASE TRACK DEADLINES
Filing and Resolution of All The filing shall be 120 days from the date of the service of Objections to Pleadings the complaint.
Filing and Resolution of All The filing shall be 120 days from the date of the service of Objections to Pleadings the complaint.
Page 2 | CATEGORY: "GENERAL" CASE TRACK DEADLINES
New parties must be added within 180 days from the filing of the complaint.
Adding New Parties 180 days from the filing of the complaint
Page 2 | CATEGORY: "GENERAL" CASE TRACK DEADLINES
Plaintiff must file the required certification within 30 days after entry of the Standing Order; each Defendant or Third-Party Defendant must file it within 30 days after filing an appearance, whether represented or pro se.
Within thirty (30) days of entry of this Standing Order for Plaintiff, and within thirty (30) days of filing an appearance in this case for each Defendant/Third-Party Defendant, counsel, or the party if pro se, shall file a certification that they have read and agree to abide by this Standing Order and the presiding judge's Administrative Procedures, which may be found on the 14th Judicial Circuit's website, www.jud14.flcourts.org.
Page 3 | ADDITIONAL REQUIREMENTS
The Notice of Hearing must be filed within five business days after the office confirms the hearing date.
The Notice of Hearing shall be filed within five (5) business days of confirmation of the hearing date by this office.
Page 2 | 1. SCHEDULING A HEARING.
Do not file a Notice of Hearing until the judicial assistant confirms by email that the hearing has been set.
DO NOT file a Notice of Hearing before receiving a confirmation email from the judicial assistant confirming that the hearing has been set.
Page 2 | 1. SCHEDULING A HEARING.
Hearing materials the party wants the Court to review must be submitted at least three business days before the hearing, except for additional copies of accessible documents already in the court file.
B. Three (3) Days Prior to Hearing: Any documentation being used or relied upon at a hearing that a party wants the Court to review and consider must be submitted at least three (3) business days prior to the date of the hearing. This includes: a. Exhibits b. Memoranda not previously filed with the clerk c. Copies of case law, statutes, or other citations d. Any demonstrative aides e. Any other documentation that a party intends to use at the hearing. However, additional copies of motions, memoranda already filed with the clerk or other documents which are in the court file (unless attached to or incorporated in other filings and not easily accessible or identifiable) do not need to be submitted again prior to the hearing.
Page 6 | 5. EVIDENCE & WITNESSES
The Witness List must be emailed to the Court three days before the hearing.
shall be emailed to the Court at phillipsm@jud14.flcourts.org three (3) days before the hearing.
Page 7 | 4. HEARING PROCEDURE
Mailed hard-copy hearing materials must be received at least three business days before the hearing when the drop box cannot be used.
If it is impossible to use the drop box, materials may be submitted in hard copy format, to be mailed so that the documents are received at least three (3) business days prior to the hearing.
Page 7 | 4. HEARING PROCEDURE
Covered civil actions must be assigned a case-management track within 120 days after filing.
All civil actions, except those enumerated in Fla. R. Civ. P. l.200(a), must be assigned one of three case management tracks within 120 days after the action is filed.
Page 1 | STANDING CIVIL CASE MANAGEMENT ORDER: ESTABLISHING STREAMLINED CASE TRACK DEADLINES
Expert discovery must be completed 30 days before the initially set Pre-Trial Conference.
Completion of Expert 30 days before the initially set Pre-Trial Conference
Page 2 | CATEGORY: "STREAMLINED" CASE DEADLINES
Fact discovery must be completed 45 days before the initially set Pre-Trial Conference.
Completion of Fact Discovery 45 days before the initially set Pre-Trial Conference
Page 2 | CATEGORY: "STREAMLINED" CASE DEADLINES
Hearings on all pretrial motions must occur before the Pre-Trial Conference.
The hearing thereon shall occur before the Pre-Trial Conference
Page 2 | CATEGORY: "STREAMLINED" CASE DEADLINES
Objections to pleadings must be filed within 120 days from service of the complaint.
The filing shall be 120 days from the date of the service o1 the complaint.
Page 2 | CATEGORY: "STREAMLINED" CASE DEADLINES
The summary-judgment motion must be filed and served 75 days before the initially set Pre-Trial Conference.
Filing and service of motion for 75 days before the initially set Pre-Trial Conference. summary judgment
Page 2 | CATEGORY: "STREAMLINED" CASE DEADLINES
The anticipated trial date is tied to the earlier of 12 months after service of initial process on the last defendant or 120 days after commencement of the action, through final disposition.
Twelve (12) months from the date of service of initial process on the last defendant or 120 days after commencement of the action as provided in rule 1.050, whichever occurs first to final disposition.
Page 2 | CATEGORY: "STREAMLINED" CASE DEADLINES
The filing shall be 30 days before the Pre-Trial Conference.
The filing shall be 30 days before the Pre-Trial Conference.
Page 2 | CATEGORY: "STREAMLINED" CASE DEADLINES
New parties must be added within 165 days after the complaint is filed.
Adding New Parties 165 days from the filing of the complaint
Page 2 | CATEGORY: "STREAMLINED" CASE DEADLINES
The hearing on objections to pleadings must occur before 180 days from service of the complaint.
The hearing thereon shall occur before 180 days from the date of the service of the complaint.
Page 2 | CATEGORY: "STREAMLINED" CASE DEADLINES
Alternative dispute resolution, including non-binding arbitration and mediation, must be completed 45 days before the Pre-Trial Conference.
Completion of Alternative Dispute Resolution, including Non-Binding Arbitration and 45 days before the Pre-Trial Conference Mediation
Page 2 | CATEGORY: "STREAMLINED" CASE DEADLINES
The certification is due within 30 days of entry of the Standing Order for Plaintiff and within 30 days of filing an appearance for each Defendant or Third-Party Defendant.
Within thirty (30) days of entry of this Standing Order for Plaintiff, and within thirty (30) days of filing an appearance in this case for each Defendant/Third-Party Defendant, counsel, or the party if pro se, shall file a certification that they have read and agree to abide by this Standing Order and the presiding judge's Administrative Procedures, which may be found on the 14th Judicial Circuit's website, www.jud l4.f1courts.org.
Page 3 | ADDITIONAL REQUIREMENTS
Parties should request needed hearings well in advance of the deadlines in the order.
Thus, each party should request any needed hearing well in advance of the deadlines set forth herein.
Civil cases
Page 1 | Hearing Time Anticipation
Parties should anticipate at least 15 days to obtain a hearing lasting under 30 minutes and at least 30 days for a longer hearing.
Each party should expect a period of at least 15 days between requesting a hearing date and the actual hearing date for a hearing lasting less than thirty (30) minutes and should expect a period of at least 30 days between requesting a hearing date and the actual hearing date for a hearing lasting longer than thirty (30) minutes.
Civil cases
Page 1 | Hearing Time Anticipation
The movant and nonmovant are expected to provide all materials supporting their positions well in advance of the hearing.
The movant and nonmovant are supposed to provide everything they are relying upon in support of or opposition to the motion well in advance of the hearing based upon the timing considerations within Rule 1.510.
Civil cases
Page 3 | The Court Generally Only Looks at Things “In the Record”
Deadlines for filing and hearing summary judgment motions are generally set by the trial-and-pretrial order or later orders modifying it.
The deadline for filing and hearing motion(s) for summary judgment are generally set forth in this Court’s Order Setting Case for Trial and Pretrial Conference and any subsequent orders modifying or amending the same.
Civil cases
Page 6 | Scheduling a Summary Judgment Hearing
The Court generally will set a reasonable deadline for filing any pleading stating exceptions or objections to the form of opposing counsel’s proposed order within 5 days after the proposed orders are filed; this is not an additional briefing requirement.
not as an additional written argument or legal briefing requirement, but to provide counsel an opportunity to plead any exceptions or objections to the form of opposing counsel’s proposed order (i.e., citing materials not in the record or citing to materials in the record, but not previously cited in the factual positions supporting the motion/response), generally, the Court will establish a reasonable deadline for filing the exceptions/objections pleading within 5 days following the filing of the proposed orders;
Civil cases
Page 10 | PROPOSED ORDERS FOLLOWING HEARING
The Court generally will set a reasonable deadline for filing proposed orders within 20 days after the hearing.
generally, the court will establish a reasonable deadline for filing the proposed orders within 20 days following the hearing;
Civil cases
Page 10 | PROPOSED ORDERS FOLLOWING HEARING
If a prior Uniform Order Scheduling Trial applies, its dates and deadlines supersede those in this Order.
If this action is subject to a previously entered Uniform Order Scheduling Trial (Bench or Jury), all dates and deadlines contained in the Uniform Order Scheduling Trial shall supersede any dates and deadlines contained in this Standing Civil Case Management Order.
Page 1 | CASE TRACK ASSIGNMENT DEADLINES
The order's deadlines are strictly enforced unless a later court order specifically alters or modifies them.
All deadlines established by this Order shall be strictly enforced unless specifically altered or modified by a subsequently issued order of this Court.
Page 1 | CASE TRACK ASSIGNMENT DEADLINES
A previously entered Uniform Order Scheduling Trial supersedes conflicting dates and deadlines in this Standing Order.
If this action is subject to a previously entered Uniform Order Scheduling Trial (Bench or Jury), all dates and deadlines contained in the Uniform Order Scheduling Trial shall supersede any dates and deadlines contained in this Standing Civil Case Management Order.
Page 1 | Footnote 1
Service and Proof of Service Rules
All parties must identify, disclose, and exchange anticipated trial impeachment materials no later than 30 days before trial.
No later than 30 days prior to the trial date, pursuant to the holding in Northup v. Acken, 865 So. 2d 1267 (Fla. 2004), all parties shall identify, disclose and exchange all materials reasonably expected or intended to be used at trial for witness impeachment, including, but not limited to: deposition and trial transcripts of testimony given in unrelated actions; medical literature; articles; learned treatises; video or audio recordings; and publications.
Civil cases
Page 1 | Exhibit Lists
Expert reports and relied-upon data intended for trial or deposition must be provided electronically to the opposing party at least 7 days before the deposition.
All reports or other data compiled by or relied upon from each disclosed expert and intended to be used by the expert at trial or deposition shall be provided electronically to the opposing party at least 7 days prior to the date of the deposition.
Civil cases
Page 1 | Expert Witness Reports
Each party must serve objections to an opposing party’s counter-designations no later than the trial date.
No later than the trial date, each party shall serve its objections to counter designations served by an opposing party.
Civil cases
Page 1 | Deposition Designations
The opposing party must serve counter-designations and objections to the original deposition designations no later than 10 days before trial.
No later than ten (10) days prior to the trial date in this matter, the opposing party shall serve its counter (or “fairness”) designations to portions of depositions designated, together with objections to the depositions, or portions thereof, originally designated.
Civil cases
Page 1 | Deposition Designations
Each party must make all intended trial exhibits available to the opposing party for inspection.
Each party shall make available to the other party for inspection all exhibits that party intends to introduce at trial.
Civil cases
Page 1 | List of Exhibits
Each party must serve its deposition designations for its case-in-chief testimony no later than 20 days before trial.
No later than twenty (20) days prior to the trial date in this matter, each party shall serve its designation of depositions, or portions of depositions, which it intends to offer as testimony in its case in chief.
Civil cases
Page 1 | Deposition Designations
Each party must submit proposed jury instructions and verdict forms to opposing counsel no later than 10 days before the Pretrial Conference.
No later than 10 days prior to the Pretrial Conference, each party shall submit to opposing counsel proposed jury instructions and verdict forms.
Civil cases
Page 1 | Jury Instructions and Verdict Form
Counsel must confer with opposing counsel and show any demonstrative aid at least 10 days before trial.
At least 10 days prior to trial, counsel shall confer with opposing counsel and show opposing counsel the demonstrative aid.
Civil cases
Page 1 | Demonstrative Aids
Discovery requiring an adverse party’s response must be served early enough for the response to be due before the discovery deadline.
Any discovery requiring a response from an adverse party must be served in time for the response to be due prior to the deadline date established herein.
Civil cases
Page 1 | Discovery Deadlines
The moving party must serve its summary judgment motion at least 40 days before the hearing.
The rule also states the moving party “must serve the motion for summary judgment at least 40 days before the time fixed for the hearing.” Fla. R. Civ. P. 1.510(b).
Civil cases
Page 4 | 40 Days
When filing a summary judgment motion, the movant must serve its supporting factual position.
At the time of filing a motion for summary judgment, the movant must serve the movant’s supporting factual position. Fla. R. Civ. P. 1.51(c)(5).
Civil cases
Page 4 | 40 Days
The non-moving party must serve a response that includes its supporting factual position at least 20 days before the hearing.
A non-moving party “must serve a response that includes the nonmovant’s supporting factual position” at least 20 days before the time fixed for the hearing. Fla. R. Civ. P. 1.510(c)(5).
Civil cases
Page 4 | 20 Days
The Statement of Material Facts accompanying a summary judgment motion or opposition must be served contemporaneously with filing.
A motion for summary judgment and the opposition to it shall each be accompanied by a separate and contemporaneously filed and served Statement of Material Facts.
Civil cases
Page 6 | STATEMENT OF MATERIAL FACTS REQUIREMENT
If the non-movant includes additional facts, the movant must respond to each in a separately served Reply Statement of Material Facts.
(A) If a non-movant’s Statement of Material Facts includes additional facts, then the movant shall respond to each additional fact in a separately served Reply Statement of Material Facts.
Civil cases
Page 8 | Reply Statement of Material Facts
The plaintiff must serve the Standing Order on all named defendants along with the summons and complaint.
Plaintiff shall file and serve this Standing Order upon all named Defendant(s) along with the summons and complaint.
Page 1 | STANDING CIVIL CASE MANAGEMENT ORDER: ESTABLISHING GENERAL CASE TRACK DEADLINES
The complaint must be served within 120 days after the action is filed.
Service of Complaint 120 days after the action is filed. See Fla. R. Civ. P. 1.070U)
Page 2 | CATEGORY: "GENERAL" CASE TRACK DEADLINES
A motion for summary judgment must be served 75 days before the initially set Pre-Trial Conference.
Filing and service of motion for 75 days before the initially set Pre-Trial Conference
Page 2 | CATEGORY: "GENERAL" CASE TRACK DEADLINES
Motions must be filed with the Clerk and served on all parties or counsel of record.
A motion must be filed with the Clerk of Court and served to all parties or counsel of record.
Page 1 | 1. SCHEDULING A HEARING.
The written Notice of Hearing must be served on all parties or counsel of record.
If this office confirms in writing that the selected date is still available, then the requesting party must provide this office with written Notice of Hearing which has been filed with the Clerk of Court and served to all parties or counsel of record.
Page 2 | 1. SCHEDULING A HEARING.
The Notice must be filed with the Clerk of Court and served on all parties or counsel of record.
The Notice must be filed with the Clerk of Court and served to all parties or counsel of record.
Page 3 | 2. SCHEDULING A TRIAL
A copy of the signed order will be served through the e-portal on all counsel and parties registered for service there.
A copy of the signed order will be served on all counsel/parties registered for service via the e-portal.
Page 4 | 3. SUBMISSION OF PROPOSED ORDERS
The submitting party must serve the signed order on persons not registered for e-portal service, and counsel receiving the entered order must serve unregistered parties by U.S. mail or email.
The party who submitted this proposed order to the Court for approval is required to serve a copy of the signed order upon any person(s) not registered to receive service via the e-portal. Counsel receiving the served copy of an order entered is then charged with responsibility for serving (via U.S. mail or email) a copy of the signed order on any party not registered to receive service via the e-portal.
Page 4 | 3. SUBMISSION OF PROPOSED ORDERS
Five days before the hearing, parties must exchange all hearing evidence and witness lists.
A. Five (5) Days Prior to Hearing: Exchange all evidence to be presented at the hearing and exchange witness lists, which shall include telephone numbers and email addresses.
Page 6 | 5. EVIDENCE & WITNESSES
The OneDrive drop-box request email must be copied to all other counsel or parties.
The email request shall be copied to all other counsel or parties.
Page 6 | 5. EVIDENCE & WITNESSES
The parties must exchange the Witness List five days before the hearing.
The Witness List shall be exchanged between the parties five (5) days prior to the hearing
Page 7 | 4. HEARING PROCEDURE
Email communications to the Court must copy all parties or counsel of record.
All email communications to the Court must be copied to all parties or counsel of record
Page 8 | 8. MISCELLANEOUS
Notice of a withdrawal motion must be provided to all parties and the withdrawing attorney’s client.
Notice must be provided to all parties and the withdrawing attorney’s client.
Page 8 | 7. MOTIONS TO WITHDRAW & SUBSTITUTE
The complaint must be served within 120 days after the action is filed.
Service of Complaint 120 days after the action is filed. See Fla. R. Civ. P. l .070U)
Page 2 | CATEGORY: "STREAMLINED" CASE DEADLINES
The summary-judgment motion must be served 75 days before the initially set Pre-Trial Conference.
Filing and service of motion for 75 days before the initially set Pre-Trial Conference. summary judgment
Page 2 | CATEGORY: "STREAMLINED" CASE DEADLINES
The judge’s office will not mail copies of orders.
The judge’s office will not mail out copies of any orders.
Page 4 | 3. SUBMISSION OF PROPOSED ORDERS
Courtesy Copy Requirements
Trial briefs are optional, but if submitted, courtesy hard copies must be delivered to Judge Goodman’s chambers at least 3 business days before trial.
Trial Briefs are not required, however, do the parties understand that if you choose to submit them, courtesy hard copies must be delivered to Judge Goodman’s chambers at least three (3) business days before trial to allow adequate time for review?
Civil cases
Page 1 | Pretrial Conference Checklist
Counsel for the moving and non-moving parties shall prepare a Pre-Summary Judgment Hearing Stipulation (“Stipulation”) which shall be filed with the Court no later than 3 days prior to the summary judgment hearing with a courtesy copy emailed to the Court’s Judicial Assistant and must contain the following:
Counsel for the moving and non-moving parties shall prepare a Pre-Summary Judgment Hearing Stipulation (“Stipulation”) which shall be filed with the Court no later than 3 days prior to the summary judgment hearing with a courtesy copy emailed to the Court’s Judicial Assistant and must contain the following:
Civil cases
Page 8 | Requirements of the Pre-Summary Judgment Hearing Stipulation
A courtesy copy of any filed exceptions or objections pleading must be emailed to the Court’s Judicial Assistant by the filing deadline.
a courtesy copy of any such filed exceptions/objections pleading must be emailed to the Court’s Judicial Assistant by the same deadline as the filing of the same;
Civil cases
Page 10 | PROPOSED ORDERS FOLLOWING HEARING
A courtesy copy of each filed proposed order must be emailed to the Court’s Judicial Assistant by the filing deadline.
a courtesy copy of the filed respective proposed orders must be emailed to the Court’s Judicial Assistant in Word format by the same deadline as the filing of the proposed orders;
Civil cases
Page 10 | PROPOSED ORDERS FOLLOWING HEARING
Pre-Motion Conference Requirements
Movants and nonmovants must satisfy the Pre-Hearing Meeting Requirement and file a Pre-Summary Judgment Hearing Stipulation before the hearing.
In an effort to complete most summary judgment hearings within the presumptive scheduled 30-minute hearing time without such inefficiencies, delay, objections, and continuances the Court is requiring the movant(s) and nonmovant(s) to satisfy a Pre-Hearing Meeting Requirement and file a Pre-Summary Judgment Hearing Stipulation prior to the hearing as more specifically described below.
Civil cases
Page 6 | Scheduling a Summary Judgment Hearing
Counsel for both parties must meet no later than ten days before the summary judgment hearing to confer, prepare the stipulation, review the record, and narrow hearing issues; moving-party counsel must schedule the meeting.
No later than 10 days prior to the summary judgment hearing, counsel for the moving and non-moving parties must meet together to: confer regarding the summary judgment motion and response; discuss and cooperate with each other to prepare a Pre-Summary Judgment Hearing Stipulation to be filed with the Court no later than 3 days prior to the summary judgment hearing with a courtesy copy emailed to the Court’s Judicial Assistant; review the materials in the record, including depositions, documents, electronically stored information, affidavits or declarations, stipulations (including those made for purposes of the motion only), admissions, interrogatory answers, or other materials supporting the factual position(s) contained in the motion and the factual position(s) contained in the response, or that otherwise may be referred to during the hearing; and complete all other matters which may narrow the issues for the summary judgment hearing and facilitate an efficient use of the scheduled and available hearing time. It is the responsibility of counsel for the moving party to schedule this meeting.
Civil cases
Page 8 | Pre-Hearing Meeting Requirement
Parties must attempt to resolve disagreements over a proposed order before seeking court intervention.
If there are disagreements over a proposed order, the parties shall attempt to work them out before seeking court intervention.
Page 3 | 3. SUBMISSION OF PROPOSED ORDERS
The movant may file and serve a reply memorandum of law, which is separate from the required Reply Statement of Material Facts.
(C) The movant may file and serve a reply memorandum of law, which is separate and distinct from the required Reply Statement of Material Facts addressing the nonmovant’s additional facts.
Civil cases
Page 8 | Reply Statement of Material Facts
Adjournment & Extension Requirements
Continuances requested within 7 days of trial generally will not be granted.
Subject to the aforementioned, continuances requested within seven (7) days of trial will generally not be granted.
Civil cases
Page 1 | Continuances
A continuance stipulation must contain the same information as a continuance motion and will be reviewed individually.
Stipulations for continuance shall contain the same information as a motion for continuance and will be reviewed by the court on a case-by-case basis.
Civil cases
Page 1 | Continuances
Unless good cause is shown, a continuance motion must be written, signed by the requesting party, include a Certificate of Good Faith, and detail efforts to move the case and resolve discovery.
Unless good cause is shown, all motions for continuance must be in writing, signed by the requesting party, contain a Certificate of Good Faith, and specify all efforts made to move the case and resolve discovery issues.
Civil cases
Page 1 | Continuances
An inability to obtain a hearing date within the expected period generally is not grounds to extend deadlines or continue trial.
The inability of a party to obtain a hearing time in accordance with the expectations set forth herein will generally not constitute grounds for an extension of the deadlines, nor will it constitute grounds for a continuance of the trial.
Civil cases
Page 1 | Hearing Time Anticipation
If a party asks to address a new issue raised by materials not cited in the motion or response, the Court will consider the objecting party’s request for more time but does not promise to grant it.
In the event any party advocates the Court consider such things not cited in the motion or response, the Court will consider the objecting party’s request for more time to address the new issue based upon the following language of Rule 1.510(e):
Civil cases
Page 3 | The Court Generally Only Looks at Things “In the Record”
Where the party opposing the summary judgment informs the court that its diligent efforts to obtain evidence from the moving party have been unsuccessful, “a continuance of a motion for summary judgment for purposes of discovery should be granted almost as a matter of course.”
Where the party opposing the summary judgment informs the court that its diligent efforts to obtain evidence from the moving party have been unsuccessful, “a continuance of a motion for summary judgment for purposes of discovery should be granted almost as a matter of course.”
Civil cases
Page 5 | Premature Summary Judgment Motions
The court may proceed to rule on a summary judgment motion without further discovery if the proposed discovery is unlikely to produce relevant evidence.
The court reasoned that, “[i]f the additional discovery will not likely generate evidence germane to the summary judgment motion, the district court may, in its discretion, proceed to rule on the motion without further ado.”
Civil cases
Page 5 | Premature Summary Judgment Motions
If a nonmovant makes the specified showing by affidavit or declaration, the court may defer or deny the motion, allow time for affidavits or discovery, or issue another appropriate order.
If a nonmovant shows by affidavit or declaration that, for specified reasons, it cannot present facts essential to justify its opposition, the court may: (1) defer considering the motion or deny it; (2) allow time to obtain affidavits or declarations or to take discovery; or (3) issue any other appropriate order. Fla. R. Civ. P. 1.510(d) (emphasis added).
Civil cases
Page 5 | Premature Summary Judgment Motions
Extensions to serve process are discretionary, and parties generally should not expect an extension longer than 180 days from the complaint filing date.
Deadlines for extensions to serve process upon defendants will be at the discretion of the trial judge. Generally, parties should not expect an extension of longer than 180 days from the filing of the complaint to execute service.
Page 2 | CATEGORY: "GENERAL" CASE TRACK DEADLINES
Extensions to serve process are within the trial judge’s discretion, and parties generally should not expect an extension longer than 180 days from filing the complaint.
Deadlines for extensions to serve process upon defendants will be at the discretion of the trial judge. Generally, parties should not expect an extension of longer than 180 days from the filing of the complaint. See Fla. R. Civ. P. l.070U).
Page 2 | CATEGORY: "STREAMLINED" CASE DEADLINES
Chambers Communication Rules
At least 7 days before the Pretrial Conference, attorneys must notify the Court Technology Officer by email or telephone of trial technology they intend to reserve.
No later than seven (7) days prior to the Pretrial Conference, attorneys for all parties must notify the Court Technology Officer via email or telephone at hagang@jud14.flcourts.org or (850) 747-5410 as to any audio-visual equipment or other multi-media technology they intend to reserve for use at trial.
Civil cases
Page 1 | Technology Needs
Counsel must email the Court’s Judicial Assistant about pending hearings that will be canceled because of settlement.
Counsel shall also notify the Court of any pending hearings that will be canceled as a result of the settlement by contacting the Court’s Judicial Assistant by email.
Civil cases
Page 1 | Settlement
Counsel must immediately notify the Court of settlement or dismissal and submit a stipulation for an order of dismissal.
All counsel shall immediately notify this Court in the event of settlement or dismissal and shall submit a stipulation for an order of dismissal.
Civil cases
Page 1 | Settlement
The moving party must contact the presiding judge's office within 20 days after filing a motion for which a hearing is requested to schedule the hearing.
Within 20 days of filing any motion for which a hearing is requested, the moving party must contact the presiding judge's office to set the motion for hearing. Failure to seek such hearing may result in the motion being denied.
Page 3 | ADDITIONAL REQUIREMENTS
After filing and serving a motion, the requesting party must email the judicial assistant to request a hearing, copy all parties or counsel, provide the specified information and certifications, and must not call the judge’s office to request a hearing time.
After your motion has been filed and served, you must email Mira Phillips at phillipsm@jud14.flcourts.org. DO NOT call Judge Goodman’s office to request a hearing time. Your email communication must be copied to all parties or counsel of record and must include a reference to the clerk’s assigned case number, a copy of the motion, a request for hearing date, names of counsel for parties, and the length of hearing requested. Further counsel shall certify that the disputed motion has been received by the opposing counsel/party and that the requestor has conferred with the opposing counsel/party in a good faith effort to resolve the matter without a hearing.
Page 1 | 1. SCHEDULING A HEARING.
After clearing a proposed date with all parties or counsel, the requester must confirm it by email to the judicial assistant, copy all parties or counsel, and do so within three business days or the date is waived.
After the requesting party has cleared a selected date with all parties or counsel of record, the requesting party must confirm the selected date with Mira Phillips by email communication. This email must be copied to all parties or counsel of record. Any proposed hearing date which is not confirmed via email within 3 business days will be deemed waived by the requestor.
Page 2 | 1. SCHEDULING A HEARING.
After filing and serving the Notice, email Mira Phillips to request pre-trial and trial dates, copy all parties or counsel, include the specified information, and do not call Judge Goodman’s office for dates.
After your Notice has been filed and served, you must email Mira Phillips at phillipsm@jud14.flcourts.org. DO NOT call Judge Goodman’s office to request a hearing date or trial date. Your email communication must be copied to all parties or counsel of record and must include in the subject line a reference to the clerk’s assigned case number, a copy of the Notice, a request for pre-trial conference date and trial date, and names of counsel for parties. A case management conference is not required to schedule a pre-trial/trial date with the Court.
Page 3 | 2. SCHEDULING A TRIAL
Disputed proposed orders must be emailed to Mira Phillips and must not be filed through the e-filing portal.
Said disputed proposed orders shall be submitted to the email of Mira Phillips and shall not be filed via the e-filing portal.
Page 3 | 3. SUBMISSION OF PROPOSED ORDERS
A counsel or party intending to provide hearing materials must contact the judicial assistant to request a case-specific OneDrive drop box.
a. Any counsel or party that desires to provide hearing materials shall contact the judicial assistant and request a OneDrive drop box for the case.
Page 6 | 5. EVIDENCE & WITNESSES
Email the Witness List to the Court at the specified address.
shall be emailed to the Court at phillipsm@jud14.flcourts.org three (3) days before the hearing.
Page 7 | 4. HEARING PROCEDURE
Notify the judicial assistant promptly by email of hearing cancellations and trial settlements, even if a Notice of Cancellation is filed.
Notify the judicial assistant of all hearing cancellations and trial settlements by email as promptly as possible to open the time slot for other matters. Even if parties file a Notice of Cancellation, they are still expected to notify the judicial assistant promptly.
Page 8 | 6. CANCELLATIONS
The moving party must contact the presiding judge’s office to schedule a requested motion hearing within 20 days after filing the motion; failure may result in denial.
Within 20 days of filing any motion for which a hearing is requested, the moving party must contact the presiding judge's office to set the motion for hearing. Failure to seek such hearing may result in the motion being denied.
Page 3 | ADDITIONAL REQUIREMENTS
A person needing a disability accommodation must contact the ADA Coordinator by mail or phone at least 7 days before the appearance, or immediately if notified less than 7 days beforehand.
Please contact the ADA Coordinator by mail at Post Office Box 1089, Panama City, FL 32402 or by phone at (850) 767-3550 at least seven (7) days before your scheduled court appearance, or immediately upon receiving this notification if the time before the scheduled appearance is less than seven (7) days.
Civil cases
Page 1 | Americans with Disabilities Act
A person with a disability who needs an accommodation must contact the ADA Coordinator by mail or phone at least seven days before the scheduled appearance, or immediately upon receiving the notification if fewer than seven days remain.
Please contact the ADA Coordinator by mail at P. 0. Box 1089, Panama City, FL 32402 or by phone at (850) 747-5338 at least seven (7) days before your scheduled court appearance, or immediately upon receiving this notification if the time before the scheduled appearance is less than seven (7) days.
Page 4 | AMERICANS WITH DISABILITIES ACT
Do not call Judge Goodman’s office to request a hearing time.
DO NOT call Judge Goodman’s office to request a hearing time.
Page 1 | 1. SCHEDULING A HEARING.
If the requester cannot clear a hearing date with all parties or counsel, a five-minute telephone conference will be scheduled with Judge Goodman to select a date and time.
If a requesting party or attorney encounters difficulty clearing a hearing date with all parties or counsel of record, then a five (5) minute telephone conference will be scheduled during which time Judge Goodman will clear an appropriate hearing date and time.
Page 2 | 1. SCHEDULING A HEARING.
Use email to the judicial assistant only to request hearing dates or confirm the Court’s proposed final date, and do not copy the assistant on counsel’s availability discussions.
Only email the judicial assistant to request hearing dates and to confirm the final date proposed by the Court. Do not include the judicial assistant in email communication between counsel/staff relative to dates when each, or the other, are available.
Page 2 | 1. SCHEDULING A HEARING.
A hearing-impaired person may call 711 for assistance.
If you are hearing impaired, please call 711
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Mira Phillips may be contacted by phone at 850-747-5320 with questions about or requests for clarification of the procedures.
Mira Phillips can be reached at 850-747-5320 should you have any questions or need clarification about the procedures outlined above.
Page 8 | 8. MISCELLANEOUS
Until further notice, non-evidentiary hearings will be held by telephone or Zoom; attorneys attending by telephone must call one of the listed numbers before the hearing and enter the conference ID.
ALL NON-EVIDENTIARY HEARINGS WITH JUDGE GOODMAN WILL BE CONDUCTED VIA TELEPHONE OR ZOOM UNTIL FURTHER NOTICE. FOR TELEPHONIC HEARINGS, THE ATTORNEYS SHALL CALL INTO THE FOLLOWING NUMBER PRIOR TO THE HEARING: 1-312-626-6799# OR 1-646-558-8656# AND insert Conference ID: 615 900 6238#. FOR ZOOM HEARINGS, THE ATTORNEYS SHOULD USE THE ZOOM INSTRUCTIONS BELOW.
Page 4 | 4. HEARING PROCEDURE
A hearing-impaired person may email the listed ADA address for assistance.
If you are hearing impaired, please ... email ADAReguest@iud14.flcourts.org.
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