Fourteenth Judicial Circuit of Florida, Bay, Calhoun, Gulf, Holmes, Jackson and Washington Counties Document Filing Requirements

CRITICALCivil cases

Applies to

Pretrial stipulation

The pretrial stipulation must include an updated child support guidelines worksheet when child support is at issue and a party intends to rely on guidelines not previously attached to the catalogue.

An updated child support guidelines worksheet attached if child support is an issue and if a party intends to rely on the child support guidelines not previously attached to the pretrial catalogue in this case.

CRITICALCivil cases

Applies to

Pretrial stipulation

The pretrial stipulation must include an updated financial affidavit if the existing affidavit was filed more than 90 days before the pretrial conference.

An updated financial affidavit attached if the existing financial affidavit filed in the court file was filed more than 90 days prior to the pretrial conference in this matter.

CRITICALCivil cases

Applies to

Settlement agreement

Parties must file a written settlement agreement before the final hearing is canceled and within five days after notifying the Court of settlement.

The parties shall file a written settlement agreement prior to the cancellation of the final hearing and within five (5) days of notifying the Court of settlement.

CRITICALCivil cases

Applies to

Pretrial stipulation

The pretrial stipulation must state that the parties completed the listed good-faith discussions, stipulations, exhibit review, and updates.

A statement that the parties have met in good faith and discussed settlement, have stipulated to as many facts as possible, have included these facts within this stipulation, have examined all exhibits and documents that may be used at trial and have provided a list of any updated documents and witness names and addresses pursuant to paragraph 6.

CRITICAL

Applies to

Hearing notice

3. Include Zoom instructions above in any notices for hearing

3. Include Zoom instructions above in any notices for hearing

CRITICAL

Applies to

Non dispositive motion

Must include

certificate of conference

When both sides have attorneys, each non-dispositive motion must include a Certificate of Good Faith Conferral showing a good-faith effort to resolve the requested relief before seeking court intervention.

If your case has attorneys on both sides, every non-dispositive motion filed must include a Certificate of Good Faith Conferral demonstrating that the moving party made a good faith effort to resolve the relief requested in the motion prior to seeking the Court’s intervention.

CRITICAL

Applies to

Cover letter

The cover letter should indicate whether the proposed order is agreed to by opposing counsel/party or not.

The cover letter should indicate whether the proposed order is agreed to by opposing counsel/party or not.

CRITICALCivil cases

Applies to

Exhibits

Attorneys submitting exhibits certify that they contain no confidential or sensitive information or that such information has been properly protected under the cited rules.

By submitting exhibits into evidence at the final hearing, the attorneys certify that the document contains no confidential or sensitive information, or that any such confidential or sensitive information has been properly protected by complying with the provisions of Rule 2.420 and Rule 2.425, Florida Rules of Judicial Administration.

CRITICAL

Applies to

Proposed order

After the final hearing date is confirmed, the requesting party or counsel must prepare a proposed order setting the hearing and stating proposed disclosure and other deadlines.

Once the final hearing date is confirmed, the party/counsel requesting the final hearing will prepare a proposed order setting final hearing, which will contain proposed disclosure and other deadlines.

CRITICAL

Applies to

Proposed order

If a pro se party is not registered to receive e-portal filings, the proposed order must include the specified service statement as its last paragraph before “DONE AND ORDERED.”

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: Counsel 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.

CRITICAL

Applies to

Proposed order

A proposed order that does not comply with the stated instructions will not be entered.

9. Any proposed order not complying with the above instructions will not be entered.

CRITICALCivil cases

Applies to

Pretrial stipulation

The pretrial stipulation must include a proposed parenting plan and timesharing schedule if parenting is at issue.

A proposed parenting plan and timesharing schedule attached if parenting is at issue.

CRITICAL

Applies to

Hearing time request email

A hearing-time request email must state the petition or motion to be heard, the time needed for argument except for matters covered by item 5, and the names of attending attorneys or parties.

Provide the following information in the hearing time request email: a. Type of petition(s)/motion(s) to be heard b. Actual amount of time needed for counsel to argue petition(s)/motion(s) – other than matters specified under #5. c. Names of attorneys/parties that will attend hearing

CRITICAL

Applies to

Notice of hearing

Include the Zoom instructions in any notice for a hearing conducted via Zoom.

If the hearing is being conducted via Zoom include the Zoom instructions in any notices.

CRITICALCivil cases

Applies to

Trial exhibit list

Impeachment materials must appear on the parties’ trial exhibit lists, and anticipated transcript excerpts from unrelated actions must have page-and-line designations.

Such impeachment materials shall be included on the parties’ respective Trial Exhibit Lists. The disclosure of such Northup impeachment materials shall include, as it concerns deposition and trial transcripts of testimony given in unrelated actions, page and line designations of such transcripts reasonably expected or intended to be used at trial for witness impeachment.

CRITICALCivil cases

The parties must submit the Pretrial Conference Checklist required by the Court’s Uniform Order Setting Trial.

12. The parties shall also submit a Pretrial Conference Checklist as required in the Court’s Uniform Order Setting Trial .

CRITICAL

Applies to

Notice of trial readiness

The requesting party or counsel of record must file a notice stating that the action is at issue and ready to be set for trial under Rule 1.440.

A. 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. The Notice must be E-filed with the Clerk and served to all parties or counsel of record.

CRITICAL

Applies to

Stipulated order

A party’s failure to object after receiving a proposed stipulated order is not consent; a hearing must be scheduled in that circumstance.

Verification that an opposing party or counsel has been provided a copy of the proposed Order, but has failed to object, does not constitute approval or consent to the proposed stipulated Order. In that event, a hearing must be scheduled following the procedures set forth in Paragraph 1, above.

CRITICALCivil cases

Applies to

Witness list

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. Any witness not disclosed as described herein shall not be permitted to testify at trial without an order of the Court.

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. Any witness not disclosed as described herein shall not be permitted to testify at trial without an order of the Court.

CRITICALCivil cases

Applies to

Proposed jury instructions

Each proposed jury instruction must be on a separate page, arranged in the desired presentation order, cite supporting authorities where applicable, and indicate whether it is opposed, with a concise objection from the opposing party.

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.

CRITICALCivil cases

Applies to

Exhibit list

The exhibit list must separately identify each intended exhibit, use numbers for Plaintiff and letters for Defendant, and describe each exhibit; generic descriptions may be stricken.

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 be stricken.

CRITICALCivil cases

Applies to

Demonstrative aid

Counsel using a demonstrative aid must be prepared to have it marked as an exhibit and entered into the record, whether or not it will be introduced into evidence.

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.

CRITICALCivil cases

Applies to

Trial witness list

The trial witness list must provide witnesses’ names and addresses alphabetically, identify each witness’s type, summarize expected testimony, and include experts’ specialties and curricula vitae.

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.

CRITICALCivil cases

Applies to

Request for judicial notice

A party requesting judicial notice must follow sections 90.201–90.207 of the Florida Evidence Code.

NOTE: ANY PARTY REQUESTING JUDICIAL NOTICE MUST FOLLOW THE EVIDENCE CODE, Section 90.201-90.207, Florida Statutes.

CRITICALCivil cases

Applies to

Pretrial checklist

For jury trials, attach a copy of the statement of the case to be read to the venire for reference at the Pre-Trial Conference.

Jury Trials Only: Statement of the case to be read to venire: Yes No ATTACH A COPY HERETO FOR REFERENCE AT PTC

CRITICALCivil cases

Each party must attach a complete exhibit list, and counsel must confer before the conference and initial exhibits agreed to be admitted.

5. COMPLETE LIST OF EXHIBITS (Each Party Attach Hereto) (Counsel shall confer prior to the conference and initial the ones agreed to being admitted into evidence):

CRITICALCivil cases

Applies to

Trial exhibit list

Before opening statements, each party’s counsel must deliver an itemized trial exhibit list to the trial clerk.

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.

CRITICALCivil cases

Applies to

Exhibits

The party raising an objection must bring the challenged exhibit to the Pretrial Conference for discussion.

All exhibits which are the subject of any objection raised in the pretrial stipulation phase shall be brought to the Pretrial Conference for discussion by the party raising the objection.

CRITICAL

Applies to

Certification

Plaintiff and each appearing Defendant or Third-Party Defendant, through counsel or pro se, must file a certification stating that they have read and agree to abide by the Standing Order and the presiding judge's Administrative Procedures.

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.

CRITICALCivil cases

Instructions and verdict forms must be submitted as required by the Court’s Uniform Order Setting Trial.

11. Instructions and verdict forms shall be submitted as set forth in this Court’s Uniform Order Setting Trial.

CRITICAL

Applies to

Standing order

The plaintiff must file the Standing Order with the summons and complaint.

Plaintiff shall file and serve this Standing Order upon all named Defendant(s) along with the summons and complaint.

CRITICALCivil cases

Applies to

Motion in limine

Motions in limine must concern specific evidence to be offered at trial.

All motions in limine must relate to specific evidence to be offered at trial.

CRITICALCivil cases

Applies to

Motion in limine

A motion in limine must specify its grounds and legal issues and identify the evidence or supporting materials relied upon.

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.

CRITICAL

Applies to

Standing case management order

The plaintiff must file the Standing Order with the summons and complaint.

Plaintiff shall file and serve this Standing Order upon all named Defendant(s) along with the summons and complaint.

CRITICALCivil cases

Applies to

Proposed verdict form

Each verdict form must be marked “agreed to” or “disputed”; for a disputed form, each party must cite supporting authorities where applicable.

Any submitted verdict form must also be designated as “agreed to” or “disputed,” and when “disputed,” each party shall cite supporting authorities where applicable.

CRITICAL

Applies to

Notice of hearing

A Notice of Hearing must identify each motion by title and state the date it was electronically filed with the Clerk.

The Notice of Hearing must identify the specific Motion(s) by title and the date that the Motion(s) was E-filed with the Clerk.

CRITICAL

Applies to

Stipulated order

A stipulated order must be accompanied by a cover letter informing the judge that all necessary parties or counsel reviewed and consented to it.

All stipulated Orders shall be E-filed and provided to all opposing parties or counsel of record with an explanatory cover letter informing Judge Young that all necessary parties or counsel have reviewed and consented to the proposed Order.

CRITICALCivil cases

Applies to

Stipulation for order of dismissal

Counsel must submit a stipulation for an order of dismissal after settlement or dismissal; a mediation report alone does not remove the case from the docket.

All counsel shall immediately notify this Court in the event of settlement or dismissal and shall submit a stipulation for an order of dismissal. 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. A copy of the mediation report is not sufficient to remove the case from the docket.

CRITICALCivil cases

Applies to

Stipulations admissions agreements waivers

Stipulations, admissions, agreements, and waivers must be in writing to be enforced by the Court.

NOTE: STIPULATIONS, ADMISSIONS, AGREEMENTS AND WAIVERS MUST BE IN WRITING IF SEEKING COURT ENFORCEMENT.

CRITICALCivil cases

Applies to

Motion for continuance

A motion for continuance must be written, signed by the requesting party, contain a Certificate of Good Faith, and specify efforts to move the case and resolve discovery issues.

all motions for continuance must be in writing, signed by the requesting party, contain a Certificate of Good Faith, specify all efforts made to move the case and resolve discovery issues

CRITICALCivil cases

Applies to

Exhibit list

Only exhibits properly included on the exhibit list may be offered into evidence at trial.

At trial, only those exhibits properly listed may be offered into evidence.

CRITICALCivil cases

Applies to

Expert witness disclosure

Plaintiff’s expert-witness disclosure must contain the specified identifying, expertise, opinion, supporting, and deposition-availability information.

2. Expert Witness Disclosure- Plaintiff: No later than 130 days prior to the trial date, Plaintiff shall serve on all other counsel and file with the Court, a notice containing the following information regarding each expert Plaintiff believes will testify at trial: 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(b)(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 80 days prior to the trial date.

CRITICALCivil cases

Applies to

Witness list

Expert witness designations must state each expert’s specialties and attach the expert’s curriculum vitae.

All expert witness designations must also include the expert’s specialties on the list and attach a copy of the expert’s curriculum vitae.

CRITICALCivil cases

Applies to

Special damages statement

An itemized statement of the Plaintiff’s special damages must be submitted.

Submit an itemized statement of special damages Plaintiff

CRITICAL

Applies to

Certification

Plaintiff’s counsel or pro se party, and counsel or each pro se Defendant or Third-Party Defendant, must file a certification stating that they have read and agree to abide by the Standing Order and the judge’s Administrative Procedures.

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.

CRITICALCivil cases

Applies to

Motion

A covered Daubert challenge must be raised by a specific motion that states its grounds and legal issues and identifies the supporting evidence or materials.

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 75 days prior to the trial date. 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.

CRITICALCivil cases

Applies to

Fact witness disclosure

The fact-witness disclosure must list each witness’s name and address, include impeachment and rebuttal witnesses, and briefly describe the testimony expected from each witness.

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 witness.

CRITICALCivil cases

Applies to

Mediator selection submission

Must include

proposed order

If the parties cannot agree on a mediator or location, counsel must notify the Court by 120 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 120 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.

CRITICAL

Applies to

Case management order

A case management order must specify at least the listed service, party-joinder, discovery, motion, pleading-objection, and alternative-dispute-resolution deadlines.

Pursuant to Rule 1.200, the case management order must specify, at a minimum, the following deadlines: service of complaints; service under extensions; adding new parties; completion of fact discovery; completion of expert discovery; filing and service of motions for summary judgment; filing and resolution of all objections to pleadings; filing and resolution of all pretrial motions; and completion of alternative dispute resolution.

CRITICAL

Applies to

Certification

Plaintiff’s counsel or pro se party must file the certification within 30 days of entry of the order, and each defendant or third-party defendant’s counsel or pro se party must file it within 30 days of filing an appearance.

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. Failure to comply with this Standing Order or any Administrative Procedures may result in denial of hearing time, denial of a motion or other requested relief, an award of attorney's fees and/or costs, striking of pleadings, dismissal of claims, a finding of contempt, or other potential actions.