Fourteenth Judicial Circuit of Florida, Bay, Calhoun, Gulf, Holmes, Jackson and Washington Counties Filing Timing and Cure Windows

CRITICAL

Fact discovery must be completed 60 days before the initially set Pre-Trial Conference.

| Completion of Fact Discovery | 60 days before the initially set Pre-Trial Conference |

CRITICALCivil cases

Alternative dispute resolution, including non-binding arbitration and mediation, must be completed 45 days before the Pre-Trial Conference.

45 days before the Pre-Trial Conference

CRITICALCivil cases

Summary judgment motions must be filed no later than 60 days before trial.

ALL motions for summary judgment must be filed and served no later than 60 days before the trial to allow sufficient time for consideration by the Court.

CRITICAL

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 Mediation | 45 days before the Pre-Trial Conference |

CRITICALCivil cases

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 of the complaint.

CRITICAL

New parties must be added within 180 days after filing the complaint.

| Adding New Parties | 180 days from the filing of the complaint |

CRITICAL

A motion for summary judgment must be filed and served 75 days before the initially set Pre-Trial Conference.

| Filing and service of motion for summary judgment | 75 days before the initially set Pre-Trial Conference |

CRITICALCivil cases

The motion for summary judgment must be filed and served 75 days before the initially set Pre-Trial Conference.

75 days before the initially set Pre-Trial Conference.

CRITICALCivil cases

Plaintiff’s counsel or pro se party, and each Defendant or Third-Party Defendant’s counsel or pro se party, must file the required certification within 30 days of the applicable triggering event.

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.

CRITICAL

Expert discovery must be completed 45 days before the initially set Pre-Trial Conference.

| Completion of Expert Discovery | 45 days before the initially set Pre-Trial Conference |

CRITICAL

The Plaintiff must file the required certification within 30 days after entry of the Standing Order.

Within thirty (30) days of entry of this Standing Order for Plaintiff

CRITICALCivil cases

Deadline

24 hours

The cited-exhibit index is due within 24 hours after the summary judgment motion is filed.

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

Hearings on all pretrial motions must occur before the Pre-Trial Conference.

The hearing thereon shall occur before the Pre-Trial Conference

CRITICAL

Each Defendant or Third-Party Defendant must file the required certification within 30 days after filing an appearance.

within thirty (30) days of filing an appearance in this case for each Defendant/Third-Party Defendant

CRITICALCivil cases

The Reply Statement of Material Facts is due within 10 days of the opponent’s response.

The due date for the Reply Statement of Material Facts is within 10 days of opponent response.

CRITICALCivil cases

The moving party must contact the presiding judge’s office within 20 days after filing a motion for which a hearing is requested.

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.

CRITICALCivil cases

Fact discovery must be completed 45 days before the initially set Pre-Trial Conference.

45 days before the initially set Pre-Trial Conference

CRITICAL

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.

CRITICALCivil cases

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.

CRITICALCivil cases

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.

CRITICALCivil cases

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.

CRITICAL

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

CRITICAL

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

CRITICAL

Deadline

5 business days

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.

CRITICALCivil cases

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.

CRITICALCivil cases

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.

CRITICALCivil cases

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.

CRITICAL

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.

CRITICALCivil cases

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.

CRITICALCivil cases

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.

CRITICALCivil cases

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.

CRITICALCivil cases

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).

CRITICAL

Hearings on all pretrial motions must occur before the Pre-Trial Conference.

The hearing thereon shall occur before the Pre-Trial Conference

CRITICALCivil cases

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.

CRITICAL

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.

CRITICAL

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.

CRITICALCivil cases

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:

CRITICAL

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.

CRITICAL

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.

CRITICAL

Deadline

3 business days

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.

CRITICAL

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

CRITICAL

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

CRITICAL

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.

CRITICALCivil cases

Mediation must commence no later than 65 days before trial.

Mediation must commence no later than 65 days prior to the trial date.

CRITICALCivil cases

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.

CRITICALCivil cases

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.

CRITICALCivil cases

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.

CRITICAL

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.

CRITICAL

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.

CRITICALCivil cases

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.