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

CRITICALCivil cases

Applies to

Motion

If the issue cannot be resolved by consent or agreed order, the nonmovant’s showing must be made in a motion incorporating its affidavit or declaration, filed and heard before the summary-judgment hearing.

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.

CRITICALCivil cases

Applies to

Pre summary judgment hearing stipulation

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).

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):

CRITICALCivil cases

Applies to

Notice of filing

Proposed orders must be filed as exhibits attached to a Notice of Filing cover pleading.

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;

CRITICALCivil cases

Applies to

Stipulation

The Stipulation must confirm whether the nonmovant will rely on an affidavit or declaration to show that it cannot present facts essential to its opposition.

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.

CRITICAL

Applies to

Email communication to court

Email communications to the Court must include the clerk-assigned case number in the subject line.

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.

CRITICAL

Applies to

Hearing request email

Must include

case number, certificate of conference

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.

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.

CRITICAL

Applies to

Standing order

The plaintiff must file and serve the Standing Order on all named defendants 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

Daubert motion

A Daubert-related motion or objection must state its grounds and legal issues with particularity and identify supporting evidence or materials.

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

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

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

Consent or agreed order

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.

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.

CRITICAL

Applies to

Witness list

A party planning to call witnesses must file a Witness List containing each witness’s telephone number and email address.

If you plan on calling witnesses, you must file a Witness List which includes their telephone numbers and email addresses.

CRITICALCivil cases

Applies to

Expert disclosure

Plaintiff’s expert disclosure must include the listed expert information and two alternate deposition dates no later than 85 days before 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(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.

CRITICAL

Applies to

Substitution of counsel motion

A motion to substitute counsel must comply with the cited rule and include the client’s written consent.

Motions to substitute counsel must comply with Fla. R. Gen. Prac. & Jud. Adm. 2.505 and contain the client’s written consent.

CRITICALCivil cases

Applies to

Statement of material facts

The non-movant’s statement must follow the movant’s order and paragraph numbering without repeating the movant’s paragraph text.

(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.

CRITICAL

Applies to

Trial cancellation

A trial may not be canceled until a fully executed settlement agreement has been filed.

Parties may not cancel a trial without first having filed a fully executed settlement agreement.

CRITICALCivil cases

Applies to

Statement of material facts

When disputing a fact, the non-movant’s supporting citations must be limited to evidence specific to that dispute.

(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.

CRITICALCivil cases

Applies to

Verdict form

Each submitted verdict form must be labeled agreed or disputed, and parties must cite supporting authority for disputed forms 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.

CRITICALCivil cases

Applies to

Statement of material facts

Each paragraph-by-paragraph response in the non-movant’s statement must begin with “DISPUTED” or “UNDISPUTED.”

(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.”

CRITICALCivil cases

Applies to

Expert disclosure

Defendant’s expert disclosure must include two alternate deposition dates no later than 70 days before trial.

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.

CRITICALCivil cases

Applies to

Summary judgment supporting materials

Materials referenced in support of or opposition to a summary judgment motion must be in the record and filed in the docket.

All materials referenced in support of or opposition to the motion must be in the record and filed in the docket.

CRITICAL

Applies to

Trial setting order

Counsel for all parties must ensure the trial-setting Order is filed and review it in its entirety.

Counsel for all parties shall ensure that said Order is filed and shall review the Order in its entirety.

CRITICALCivil cases

Applies to

Stipulation

The Stipulation must identify any timing issues with filing or serving the summary-judgment motion, response, or supporting factual positions.

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.

CRITICALCivil cases

Applies to

Stipulation

The Stipulation must confirm whether all materials relied on for the parties’ factual positions have been filed and are in the record.

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.

CRITICAL

Applies to

Notice of hearing

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.

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.

CRITICAL

Applies to

Withdrawal motion

A withdrawal motion must state the reasons for withdrawal and the client’s last known address.

The motion shall set forth the reasons for withdrawal and the client’s last known address.

CRITICALCivil cases

Applies to

Deposition transcript

If a deposition transcript is referenced, a complete copy including all exhibits must be filed in the docket.

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

CRITICALCivil cases

Applies to

Nonmovant statement of material facts

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

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.

CRITICALCivil cases

Applies to

Exhibit list

Each party must submit its proposed exhibit list directly to chambers by the deadline in the Trial Order.

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.

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 filed and served contemporaneously.

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

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 non-movant) shall be filed and served as separate documents and not as exhibits or attachments.

CRITICALCivil cases

Applies to

Stipulation

The Stipulation must state specific admissibility objections, including their legal grounds and reasons.

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.

CRITICALCivil cases

Applies to

Statement of material facts

The non-movant’s additional material facts must follow its responses, continue the movant’s paragraph numbering, and be separately titled “Additional Facts.”

(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”

CRITICAL

Applies to

Witness list

Witness lists must include telephone numbers and email addresses.

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.

CRITICALCivil cases

Applies to

Stipulation

The Stipulation must identify any allegation that a party submitted an affidavit or declaration in bad faith or solely for delay.

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.

CRITICALCivil cases

Applies to

Trial request email

A trial request email must attach the filed trial notice if available, identify whether the trial is jury or non-jury, and state the required trial time; jury-trial time excludes jury selection, and a non-jury trial exceeding one day requires a CMC.

Provide the following information in the trial request email: a. Attach a copy of the filed notice for trial, if done b. Specify whether it is a jury trial or non-jury trial c. If a jury trial – specify the number of days needed, exclusive of jury selection d. If non-jury trial – specify the amount of time needed. If more than one day, a case management conference is needed.

CRITICALCivil cases

Applies to

Response

The non-movant must file a response within 10 days and include at least a brief memorandum of law in it.

Thereafter, the non-movant shall file a response within 10 days which shall include at least a brief memorandum of law as part of the response.

CRITICALCivil cases

Applies to

Trial request email

Use Bay or Gulf County case number and style of case as your subject line.

Use Bay or Gulf County case number and style of case as your subject line.

CRITICAL

Applies to

Proposed order

After the final hearing date is confirmed, the requesting counsel or party must prepare a proposed order containing proposed disclosure and other deadlines and obtain opposing counsel’s consent to its form and deadlines.

Once the final hearing date is confirmed, the counsel/party requesting the final hearing will prepare a proposed order setting final hearing, which will contain proposed disclosure and other deadlines. Obtain opposing counsel’s consent to the form of the order and deadlines included therein.

CRITICAL

Applies to

Proposed order

All proposed orders must include a cover letter in .pdf format. The cover letter should indicate whether the proposed order is agreed to by opposing counsel/party or not.

All proposed orders must include a cover letter in .pdf format. The cover letter should indicate whether the proposed order is agreed to by opposing counsel/party or not.

CRITICAL

Applies to

Proposed order

If a case includes a pro se party not registered for e-portal filings, the proposed order must include the specified service statement as its final 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 shall serve a copy of this Order on any party not registered to receive service via the Court’s e- portal.

CRITICAL

Applies to

Hearing notice

Hearing notices must include Zoom instructions when applicable.

Include Zoom instructions, if applicable, in any notices for hearing.

CRITICAL

Applies to

Notice

For notices, list the location as Judge Jarred Patterson’s Chambers rather than a room number and include Zoom instructions when applicable.

Address: Bay County: 300 E. 4th Street, Panama City, Florida 32401; Gulf County 1000 Cecil G Costin Sr. Blvd, Port St. Joe, Florida 32456. There are no room numbers – just list as Judge Jarred Patterson’s Chambers. Include Zoom instructions (if applicable) in any notices.

CRITICALCivil cases

Applies to

Certification

Counsel and pro se parties must file a certification agreeing to abide by the Standing Order and Administrative Procedures, substantially in the stated form.

Pursuant to the Standing Civil Case Management Order entered in most cases, counsel for all parties are required to file a certification that they have read and agree to abide by the Standing Order and these Administrative Procedures. The Certification shall be in substantially the following form: I, ____________________, on behalf of myself, my client and my firm, have read the Standing Civil Case Management Order entered in this case as well as the presiding Judge’s Administrative Procedures found on the 14th Judicial Circuit’s website and agree to abide by such requirements, procedures and deadlines. I understand that failure to comply with any of the requirements, procedures or deadlines may result in sanctions against me and/or my client, including, but not limited to, an award of attorney’s fees and costs, denial of motions or hearing time, striking of pleadings, dismissal of claims, finding of contempt or other sanctions. The Certification shall be filed by counsel or pro se parties pursuant to the time periods contained in the Standing Order entered in a case.

CRITICALCivil cases

Applies to

Motion

A motion subject to the good-faith requirement must include a certification that the movant made a good-faith attempt to resolve the issues before filing.

the moving party is required to include a certification in the motion that the movant made a “good faith attempt” to resolve the issue(s) raised in the motion with the opposing counsel or party (whether represented or pro se) prior to filing the motion.

CRITICALCivil cases

Applies to

Proposed order

Each proposed order must include a PDF cover letter stating whether opposing counsel or the party agrees to the proposed order.

All proposed orders must include a cover letter in .pdf format. The cover letter should indicate whether the proposed order is agreed to by the opposing counsel/party or not.

CRITICAL

Applies to

Proposed order

The service portion designated for the judicial assistant must be omitted from proposed orders.

All proposed orders must be in DJCMA format (see #6 & 7 below), but counsel/parties are directed to omit the service portion for the judicial assistant to sign and certify service of the order (the M and A portions of the DJCMA format).

CRITICALCivil cases

Applies to

Motion

For a motion the parties stipulate to have decided without a hearing, the movant must include at least a brief memorandum of law with the motion or in a supplemental filing.

The parties may stipulate to having a motion decided without the necessity of a hearing. If such is the case, the movant shall include at least a brief memorandum of law as part of the motion being filed or as a supplemental filing on the motion.

CRITICALCivil cases

Applies to

Proposed order

If a pro se party is not registered to receive e-portal filings, include the specified service statement as the proposed order’s 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 on any party not registered to receive service via the Court’s e-portal.

CRITICALCivil cases

Applies to

Agreed proposed order

If the parties resolve the issue before a Court-scheduled hearing, they must submit an agreed proposed order more than one business day before the hearing to avoid appearing.

If the parties resolve the issue prior to the Court-Scheduled hearing, they shall submit an agreed upon proposed order more than one (1) business day prior to hearing date to avoid the requirement for appearance at the Court-scheduled hearing.