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

CRITICALCivil cases

Applies to

Certification

Counsel or a party proceeding 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.judl4.f1courts.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.

CRITICALCivil cases

Applies to

Statement of material facts

A Statement of Material Facts must cite specific references to the listed materials on file with the Court.

A statement of material facts must be supported by specific references to pleadings, depositions, answers to interrogatories, admissions, and affidavits on file with the Court.

CRITICALCivil cases

Applies to

Index of cited exhibits

The responding party must separately file an index naming each cited exhibit and identifying its docket entry within 24 hours after filing the response.

Within twenty-four (24) hours of filing a response to the motion for summary judgment, the responding party shall separately file an index of the cited exhibits which names each exhibit and references the docket entry at which that exhibit may be found.

CRITICALCivil cases

Applies to

Exhibits

Exhibits referenced in the motion or Statement of Material Facts must be on the docket, but previously docketed exhibits need not be refiled.

Each exhibit referenced in the motion for summary judgment and/or in the statement of material facts must be filed on the docket. Exhibits which have already been filed on the docket need not be refiled.

CRITICALCivil cases

Applies to

Statement of material facts

An opponent’s Statement of Material Facts must clearly challenge each asserted material fact that the opponent contends is genuinely disputed.

An opponent’s Statement of Material Facts shall clearly challenge any purportedly material fact asserted by the movant that the opponent contends is genuinely in dispute.

CRITICALCivil cases

Applies to

Response

A nonmovant’s response must include the nonmovant’s supporting factual position under subdivision (1).

At least 20 days before the time fixed for the hearing, the nonmovant must serve a response that includes the nonmovant's supporting factual position as provided in subdivision (1) above.

CRITICALCivil cases

Applies to

Exhibits

Exhibits referenced in a summary-judgment response or opposing statement must be filed on the docket, unless already filed.

Each exhibit referenced in the response to the motion for summary judgment and/or in the opposing statement of material facts must be filed on the docket. Exhibits which have already been filed on the docket need not be refiled.

CRITICALCivil cases

Applies to

Statement of material facts

The movant’s Statement of Material Facts must list the material facts the movant contends are not genuinely disputed.

The movant’s Statement of Material Facts shall list the material facts that the movant contends are not genuinely disputed.

CRITICALCivil cases

Applies to

Summary judgment motion

A summary judgment motion must be filed with a statement of material facts under the attached Modified Rule 56.1.

A statement of material facts shall be filed with the motion for summary judgment as provided in the attached Modified Rule 56.1.

CRITICALCivil cases

Applies to

Opponent statement of material facts

When disputing a fact, the opponent’s supporting evidentiary citations must be specific to that dispute.

If an opponent’s Statement of Material Facts disputes a fact in the movant’s Statement of Material Facts, then the evidentiary citations supporting the opponent’s position must be limited to evidence specific to that particular dispute.

CRITICALCivil cases

Applies to

Statement of material facts

The moving party must file its Statement of Material Facts separately from its summary judgment motion.

The moving party shall file a statement of material facts as a separate filing from a motion for summary judgment.

CRITICALCivil cases

Applies to

Deposition transcript

A relied-upon deposition transcript must be filed in complete form with all exhibits.

If a deposition transcript is relied upon, a complete copy must be filed which includes all exhibits.

CRITICALCivil cases

Applies to

Opposing statement of material facts

A responding party may file an opposing statement, and if it does, must reproduce each numbered paragraph and detail its response or opposition after each one.

The responding party may file an opposing statement of material facts which responds to the moving party’s statement of material facts. A responding party’s opposing statement of material facts must specifically respond to each statement in the movant’s statement by setting forth each of the individually numbered paragraphs contained in the movant’s statement and after each paragraph, detail respondent’s response or opposition.

CRITICAL

Applies to

Certification

Counsel or a self-represented party must file a certification stating that they have read and agree to abide by the Standing Order and the judge’s Administrative Procedures.

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

Index of cited exhibits

The movant must separately file an index naming each cited exhibit and its docket entry within 24 hours after filing the summary judgment motion.

Within twenty-four (24) hours of filing a motion for summary judgment, the movant shall separately file an index of the cited exhibits which names each exhibit and references the docket entry at which that exhibit may be found.

CRITICALCivil cases

Applies to

Statement of material facts

Statements of Material Facts must use separately numbered paragraphs, each limited as far as practicable to one material fact and supported by specific pinpoint references to record material.

B. Consist of separately numbered paragraphs, limited as far as practicable to a single material fact, with each fact supported by specific, pinpoint references 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., Exhibit D, Smith Affidavit, ¶2; Exhibit 3, Jones deposition, p. 12/lines 4-9).

CRITICALCivil cases

Applies to

Reply statement of material facts

The movant must respond to additional facts in the opponent’s Statement of Material Facts even if it does not serve a reply memorandum.

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.

CRITICALCivil cases

Applies to

Standing order

The plaintiff must file and 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.

CRITICALCivil cases

Applies to

Opponent statement of material facts

An opponent’s Statement of Material Facts must follow the movant’s order and paragraph numbering without repeating the movant’s text.

(A) In addition to complying with the requirements of sub-section (b)(1), an opponent’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.

CRITICALCivil cases

Applies to

Deposition transcript

A referenced deposition transcript must be filed as a complete copy including all exhibits.

If a deposition transcript is referenced, a complete copy must be filed which includes all exhibits.

CRITICALCivil cases

Applies to

Affidavit or declaration

A nonmovant relying on unavailable facts must show by affidavit or declaration the specified reasons it cannot present facts essential to its opposition.

If a nonmovant shows by affidavit or declaration that, for specified reasons, it cannot present facts essential to justify its opposition, the court may:

CRITICALCivil cases

Applies to

Summary judgment motion and opposition

Each summary judgment motion and opposition must be accompanied by a separate Statement of Material Facts.

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.

CRITICALCivil cases

Applies to

Statement of material facts

Each fact requiring evidence must appear in its own numbered paragraph with a specific citation to exhibit pages and applicable paragraph or line numbers; general exhibit citations without pincites are prohibited.

Each material fact in the statement that requires evidentiary support shall be set forth in an individually numbered paragraph and supported by a specific citation. This specific citation shall reference pages (and paragraph or line numbers, if applicable) of the cited exhibit(s). When a material fact requires evidentiary support, a general citation to an exhibit, without a page number or pincite, is not permitted.

CRITICALCivil cases

Applies to

Supporting factual position

A party asserting that a fact is undisputed or genuinely disputed must support the assertion by citing record materials or by showing that the cited materials do not establish the dispute or that the adverse party cannot produce admissible evidence.

A party asserting that a fact cannot be or is genuinely disputed must support the assertion by: A. citing to particular parts of 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; or B. showing that the materials cited do not establish the absence or presence of a genuine dispute, or that an adverse party cannot produce admissible evidence to support the fact.

CRITICALCivil cases

Applies to

Affidavit or declaration

An affidavit or declaration supporting or opposing a motion must be based on personal knowledge, state admissible facts, and show the affiant or declarant is competent to testify.

An affidavit or declaration used to support or oppose a motion 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.

CRITICALCivil cases

Applies to

Opponent statement of material facts

Each paragraph-by-paragraph response in an opponent’s Statement of Material Facts must begin with “disputed” or “undisputed.”

An opponent’s Statement of Material Facts shall use, as the very first word in each paragraph-by-paragraph response, the word “disputed” or “undisputed.”

CRITICALCivil cases

Applies to

Reply statement of material facts

If the opponent includes additional facts, the movant must respond to each in a Reply Statement of Material Facts.

If an opponent’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.

CRITICALCivil cases

Applies to

Statement of material facts

Statements of Material Facts must be filed and served as separate documents, not as exhibits or attachments.

All Statements of Material Facts (whether filed by the movant or the opponent) shall be filed and served as separate documents and not as exhibits or attachments.

CRITICALCivil cases

Applies to

Opponent statement of material facts

An opponent’s additional material facts must immediately follow its responses, continue the movant’s numbering, and appear under a separate “Additional Facts” title.

Any additional facts that an opponent contends are material to the motion for summary judgment shall be numbered and placed immediately after the opponent’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 as “Additional Facts”

CRITICALCivil cases

Applies to

Reply statement of material facts

The Reply Statement must follow the opponent’s additional-fact order and numbering, begin each paragraph with “disputed” or “undisputed,” and cite particular record materials for disputes.

The Reply Statement of Material Facts shall correspond with the order and paragraph numbering format used in the opponent’s additional facts, identifying with the very first word in each fact 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).

CRITICAL

Applies to

Certification

Counsel or a pro se party must file a certification stating that they have read and agree to abide by the Standing Order and the presiding judge's Administrative Procedures.

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.

CRITICAL

Applies to

Certification

A certification stating that the filer has read and agrees to abide by the Standing Order and the judge’s Administrative Procedures must be filed.

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.

CRITICALCivil cases

Applies to

Exhibit list

Exhibit lists must separately identify each proposed exhibit by the required party-specific number or letter and include a description; 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 being stricken.

CRITICAL

Applies to

Notice of readiness for trial

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

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.

CRITICAL

Applies to

Request for in person hearing

An attorney or party requesting an in-person non-evidentiary hearing must submit the request in writing and state its basis specifically.

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.

CRITICAL

Applies to

Notice of hearing

Proposed hearing times and Notices of Hearing must refer only to the Central Time Zone.

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.

CRITICALCivil cases

Applies to

Trial witness list

An undisclosed witness may not testify at trial without a court order.

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

Pre summary judgment hearing stipulation

Movants and nonmovants must 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.

CRITICALCivil cases

Applies to

Trial witness list

The trial witness list must be alphabetical and include witness contact details, type, expected testimony, and, for experts, specialties and a curriculum 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

Motion in limine

A motion in limine must state its grounds and legal issues with particularity and identify supporting evidence or materials.

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

Proposed order

Every proposed order must include a cover letter in PDF format.

All proposed orders must include a cover letter in .pdf format.

CRITICAL

Applies to

Proposed order

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

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

CRITICALCivil cases

Applies to

Movant statement of material facts

The movant’s Statement of Material Facts must list the material facts the movant contends are not genuinely disputed.

The movant’s Statement of Material Facts shall list the material facts that the movant contends are not genuinely disputed.

CRITICALCivil cases

Applies to

Reply statement of material 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.

(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).

CRITICALCivil cases

Applies to

Summary judgment motion and response

The motion and response must cite particular parts of materials in the record.

The movant and nonmovant must cite particular parts of materials in the record in the motion and response.

CRITICALCivil cases

Applies to

Affidavit or declaration

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.

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).

CRITICALCivil cases

Applies to

Statement of material facts

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.

(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.

CRITICALCivil cases

Applies to

Pretrial conference preparation

All parties’ attorneys must meet by agreement, initiated by Plaintiff’s counsel, no later than 7 days before the Pretrial Conference.

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:

CRITICAL

Applies to

Cover letter

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.

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.

CRITICAL

Applies to

Proposed order

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.”

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.