Fourth Judicial Circuit of Florida, Clay, Duval and Nassau Counties Document Filing Requirements

Applies to

Motion

Any issue submitted for decision should be presented by a motion filed with the clerk, with copies provided to all parties of record.

As a result, any issue to be considered by the Court should be in the form of a Motion filed with the Clerk of Court and copies provided to all parties of record.

Applies to

Motion

Merely filing a motion does not present it to the judge; counsel must provide the judge a copy with a cover letter or email stating the time needed to hear the matter and whether evidence will be presented.

However, the mere filing of a Motion with the Clerk’s Office does not bring the matter before the judge. A copy must be provided to the judge with a cover letter or email explaining how much time is necessary for the matter to be heard. The letter should also include information regarding whether evidence (i.e. – testimony) will need to be considered at the time of the hearing.

Applies to

Motion

Requests for relief must be submitted as a motion or formal pleading filed with the clerk.

Requests for relief must be in the form of a motion or formal pleading and filed with the Clerk of the Court.

Applies to

Motion

Counsel must place a good-faith conferral certification at the end of any motion not agreed upon by the parties, using either of the two stated certification alternatives.

At the end of any motion not agreed upon by the parties, counsel for the moving party shall certify either: (A) that counsel for the movant has conferred with all parties or non-parties who may be affected by the relief sought in the motion in a good faith effort to resolve the issues raised in the motion and has been unable to do so; or (B) that counsel for the movant has made reasonable efforts to confer with all parties or non-parties who may be affected by the relief sought in the motion, which efforts shall be identified with specificity in the statement, but has been unable to reach the other parties or non-parties whose input is necessary.

Applies to

Motion

When some issues have been resolved by agreement, the conferral certification must identify both the resolved issues and the unresolved issues.

If certain of the issues have been resolved by agreement, the certification shall specify the issues so resolved and the issues remaining unresolved.

Applies to

Proposed order

After approval or a reasonable opportunity to object, the hearing or motion proponent must email the proposed order to the court for signature.

Once approved or after a reasonable period of time has elapsed for a party to voice an objection to the proposed Order, it shall be the responsibility of the proponent of the hearing/motion to submit the proposed Order to the Court via email for signature.

Applies to

Agreed order

Before submitting an agreed or consent order, the preparing office must provide an advance copy to the opposing side and confirm no objection to the order's form.

Before submitting an Order to the Court as “Agreed,” or “Consent,” the office preparing the Agreed/Consent Order must provide an advance copy to the opposing side and confirm there is no objection to the form of the Order prior to submitting it to the judge.

Applies to

Agreed order

The judge must be notified when an agreed or consent order is submitted that the opposing side agrees or has no objection or position on the requested relief, with the agreement shown in the order title or cover letter.

When submitting such an Order, notification shall be given to the judge that the opposing side either agrees to the Order and/or has no objection/position to the relief being ordered. Such agreement can be indicated in either the title of the Order and/or the cover letter accompanying the submission.

Applies to

Proposed order

Must include

proposed order

A copy of the motion must be included when submitting a proposed agreed or consent order.

When submitting such proposed Orders, please include a copy of the Motion.

Applies to

Hearing

No additional matters may be added to a hearing unless the Court approves the addition.

No add-ons of any hearing is permitted at any time, unless approved by the Court.

Applies to

Designation of current mailing and email address

Every unrepresented party must complete and read the instructions for Family Law Form 12.915, designating the party's current mailing and email address.

All unrepresented parties shall complete the Designation of Current Mailing and E-Mail Address Family Law Form 12.915 and read its instructions thoroughly.

Applies to

Uncontested dissolution filing package

The uncontested-dissolution checklist calls for an answer and waiver, financial affidavit, UIFSA affidavit, counsel completion, a certificate concerning children, and a child-support-guideline worksheet to have been filed with the clerk.

1. Have the following documents been frled with the Clerk of Court? (enter check marks or docket number) I Answer and,Waiver I Financial Alfidavit I UeeJEA Affidavit" .. I Counse completion I Children certificate for I First in Divorce I :'i':t' ; I Child Support Guideline I Worksheet I

Applies to

Financial affidavit

Each party must provide a current financial affidavit.

A. Mandatory UP-TO-DATE Financial Affidavits of each of the parties.

Applies to

Attorney fee statement

A party seeking attorney’s fees at or after the final hearing must file a verified statement describing the time spent and a detailed list of costs.

NOTE: All parties seeking attorney’s fees at the time of final hearing or subsequent thereto must file a verified statement as to the manner of time spent, along with a detailed list of costs.

Applies to

Certificate of counsel

Uncontested-dissolution filings must include counsel's certification that the court file and information were reviewed and the required pleadings were filed with the clerk.

Certilicate of Counsel I, the undersigned attorney, do hereby certiff that I have reviewed the above court file and the above information and the required pleadings are filed with the Clerk of Court.

Applies to

Affidavit of diligent search

A case in which the respondent was served by publication must include the applicable affidavit of diligent search.

Service by Publication: Cases wherein the Respondent has been served by publication must include an affidavit of diligent search, pursuant to Family Law Form 12.913(b) (for dissolution cases) or 12.913(c) (for paternity cases).

Applies to

Motion

When a motion may require a hearing, the filing party must state that the parties met and conferred without resolution or that the other party could not be contacted after due diligence and list all contact attempts.

In the event that a hearing is required, the party filing the motion(s) shall indicate that the parties met and conferred, and no resolution was reached or that the other party was unable to be contacted after due diligence, listing all attempts to contact the opposing party(s).

Applies to

Notice of hearing

A notice of hearing for contempt must contain the quoted warning about a writ of bodily attachment and possible detention for up to 48 hours.

Pursuant to Rule 12.615(b), the notice of hearing must contain the following language: “FAILURE TO APPEAR AT THE HEARING MAY RESULT IN THE COURT ISSUING A WRIT OF BODILY ATTACHMENT FOR YOUR ARREST. IF YOU ARE ARRESTED, YOU MAY BE HELD IN JAIL UP TO 48 HOURS BEFORE A HEARING IS HELD.”

Applies to

Notice of hearing

Every notice of hearing must contain the ADA notification required by Florida Rule of General Practice and Judicial Administration 2.540.

All notices of hearing will contain the ADA notification required by Florida Rule of General Practice and Judicial Administration 2.540.

Applies to

Trial set memorandum

For trial-setting, the attorneys must jointly coordinate the ex parte hearing, serve the Notice of Ex Parte Hearing on all parties, and complete the Trial Set Memorandum Form.

Jointly the attorneys must: (1) coordinate a date and time certain with the Judicial Assistant for the ex parte hearing, (2) serve the Notice of Ex Parte Hearing on all parties (out-of-town attorneys may appear by zoom by requesting to do so), and (3) complete and submit to the Judicial Assistant the Trial Set Memorandum Form found on the web at https://www.jud4.org/ex-parte-dates-judge-s-procedures/duval-judges.

Applies to

Proposed order

Each proposed order must have a cover letter certifying unanimous agreement or identifying any disagreement about the order.

All proposed Orders must be accompanied by a cover letter either: (1) certifying that all parties agree to the order, or (2) containing a statement identifying any disagreement of the parties as to the proposed Order.

Applies to

Proposed order

A consent order must include “Consent” or “Agreed” in its caption.

All consent Orders shall include the word “Consent” or “Agreed” in the caption of the proposed Order.

Applies to

Proposed order

The proposed order's DONE AND ORDERED clause and the court's signature line must appear on the same page.

The DONE AND ORDERED clause, along with the Court’s signature line, shall be on the same page.

Applies to

Emergency motion

An emergency-hearing motion must identify the issues, explain the need for emergency relief, and state each party's required presentation time.

If a party believes there is a factual basis for setting an emergency hearing, a detailed motion setting forth the following must be filed: (1) the issues to be resolved, (2) reasons why an emergency hearing is necessary, and (3) the amount of time needed for each party’s presentation.

Applies to

Emergency motion

An emergency motion must be verified or sworn by the movant and signed by counsel when represented.

All such motions must be verified/sworn by the movant & signed by counsel, if applicable.

Applies to

Division forms

Division forms must be used for all relevant filings.

Division forms must be used for all relevant filings.

Applies to

Trial motion set memorandum

The trial/motion set memorandum must list the pleadings to be heard, their docket numbers, and the associated issues.

Pleadings to be heard and a list of issues (MUST LIST THE PLEADINGS AND DOCKET NUMBERS).:

Applies to

Pretrial stipulation

If personal property remains unresolved before the final hearing, each party must submit and attach to the pretrial stipulation a list of assets sought, including descriptions, ownership interests, debt balances, and fair market values or present balances.

NOTE: If the issue of personalty is not settled prior to final hearing, each party shall submit to the Court a list of assets sought by each party, stating the specific description of such asset, the nature of the party’s interest, the amount of debt encumbering any asset (i.e., lien balance), and the fair market value or present balance of such asset. ATTACH LIST TO PRE-TRIAL STIPULATION.

Applies to

Verified attorney fee statement

Any party seeking attorney’s fees at the final hearing or afterward must file a verified statement describing the time spent and a detailed list of costs.

NOTE: All parties seeking attorney’s fees at the time of final hearing or subsequent thereto must file a verified statement as to the manner of time spent, along with a detailed list of costs.

Applies to

Remote pretrial conference checklist

The completed remote pretrial conference checklist must be brought to the pretrial conference and should not be filed.

Bring (do not file) completed checklist to Pre-Trial Conference (“PTC”)

Applies to

Exhibit list

All exhibits must be pre-marked or assigned stipulated admission numbers, correspond to the Exhibit List, and be provided to the Clerk and Court with that list.

All Exhibits to be identified, introduced, or offered into evidence have been pre-marked for identification or given numbers for admission into evidence by stipulation, corresponding to the Exhibit List and have been provided to the Clerk and Court along with the Exhibit List.

Applies to

Pre evidentiary hearing preparation materials

Must include

proposed order

At least seven days before the conference, counsel for each party must meet at the movant’s initiative and prepare the stipulation, checklist, proposed order, and related evidentiary-hearing materials.

No later than seven (7) days prior to the Pre-Evidentiary Hearing Case Management Conference, attorneys for each party shall meet together by agreement instigated by counsel for the Movant(s), to discuss the possibility of resolving the Motion or cause by Agreed Order; stipulate to as many facts and issues as possible; discuss and cooperate with each other to prepare a Pre-Evidentiary Hearing Stipulation; complete the Division CV-E “Pre-Evidentiary Hearing Case Management Conference Checklist” to be submitted to the Court at the Pre-Evidentiary Hearing Case Management Conference; draft a proposed “Pre-Evidentiary Hearing Case Management Conference Order” to be submitted to the Court at the Pre-Evidentiary Hearing Case Management Conference or immediately thereafter; examine all exhibits and documents that may be used at the evidentiary hearing; confirm for opposing counsel the names and addresses of all witnesses who may testify at the evidentiary hearing; review all video depositions or exhibits to be used at the evidentiary hearing; and complete all other matters which may expedite both the Pre-Evidentiary Hearing Case Management Conference and the evidentiary hearing.

Applies to

Pre evidentiary hearing stipulation

The parties must file a Pre-Evidentiary Hearing Stipulation at the conference containing specified factual, pleading, witness, exhibit, objection, and unresolved-matter information.

Counsel for the parties shall prepare a Pre-Evidentiary Hearing Stipulation which shall be filed with the Court at the Pre-Evidentiary Hearing Conference and shall contain the following: (a) a concise statement of the factual issues to be resolved in the Motion, which shall include the date and place of accrual, identity of the parties as they relate to the action, and a brief general statement of each party’s case or contention. The statement shall be in such form and contain such necessary information for the Court to apprise itself of the issues to be heard; (b) a concise statement of those facts which are admitted and will require no proof at the hearing; (c) a concise statement of those issues or facts which remain to be litigated; (d) any proposed amendments to the relevant pleadings; (e) a complete list of witnesses, including anticipated impeachment witnesses, specifying the name and address of each from whom testimony may be presented at trial – the list shall identify whether each witness is expected to testify live, in-person or by Zoom, or by deposition; (f) a complete list of exhibits, including, but not limited to, exhibits to be used for demonstrative purposes only, as set forth in paragraph 7 below; (g) a statement reflecting any remaining issues or objections to specific portions of video depositions, testimony, or video exhibits which may be offered in evidence at the hearing shall be filed with the stipulation (the depositions with objections noted on each page of designations, shall be timely filed and provided to the Court as set forth in paragraph 21 below to the parties and the Court for timely review and ruling); and (h) a list of any undisposed matters to be heard at the Pre-Evidentiary Hearing Case Management Conference.

Applies to

Pre evidentiary hearing stipulation

The stipulation must list all potential evidentiary-hearing exhibits, state objections, identify the evidentiary status of each item, and bring objected exhibits to the conference.

The Pre-Evidentiary Hearing Stipulation shall contain a list of all exhibits that may be offered in evidence at the evidentiary hearing, together with a statement of objections, if any, to exhibits offered by the opposing party. With respect to each item, the Pre-Evidentiary Hearing Stipulation shall reflect whether or not the evidence will be stipulated into evidence, stipulated as to authenticity, with objection reserved for relevancy and materiality, or objected to in its entirety and the ground therefor. All exhibits which are the subject of any objection raised in the Pre-Evidentiary Hearing Stipulation shall be brought to the Pre-Evidentiary Hearing Case Management Conference.

Applies to

Exhibit list

Before the evidentiary hearing, each party’s counsel must deliver an itemized Exhibit List to the court.

Prior to commencement of the evidentiary hearing, counsel for each party shall deliver to the Court an Exhibit List that contains an itemized list of all exhibits to be introduced during the hearing.

Applies to

Preliminary fact witness list

Each preliminary fact-witness list must state each witness’s name, address, and expected mode of testimony and be in a format suitable for filing and service.

Each list shall contain the name and address of each witness and it shall identify whether each witness is expected to testify live or by deposition. Such written disclosure of preliminary fact witnesses shall be in a format that can be filed with the Court and served on all respective opposing counsel. Any witness not disclosed herein shall not be permitted to testify at the evidentiary hearing without an order of the Court.

Applies to

Final evidentiary hearing witness list

Movant and non-movant must each provide a final court-fileable and serviceable witness list stating names, addresses, and testimony modes by the specified pre-conference deadline.

Movant(s) shall disclose to non-movant(s) a final written list or notice of all witnesses expected to testify at the evidentiary hearing, including any rebuttal witnesses, no later than (enter number) days prior to the Pre-Evidentiary Hearing Conference. Non-movant(s) shall disclose to Movant(s) a final written list or notice of all witnesses expected to testify at the evidentiary hearing, including any rebuttal witnesses, no later than (enter number) days prior to the Pre-Evidentiary Hearing Conference. Each list shall contain the name and address of each witness, and shall identify whether each witness is expected to testify live, in-person or by Zoom, or by deposition. Such written disclosure of a final list of all witnesses expected to testify at the evidentiary hearing shall be in a format that can be filed with the Court and served on all respective opposing counsel.

Applies to

Expert witness motion or objection

Must include

legal argument

Expert-related motions and objections must state their grounds and legal arguments with particularity and identify the movant’s supporting evidence or material.

Any expert witness related motions or objections shall state with particularity the grounds upon which they are based and the substantial matters of law to be argued and shall identify any evidence or supporting material on which the movant relies.

Applies to

Evidentiary hearing exhibit list

Northup impeachment materials must be included on each party’s Evidentiary Hearing Exhibit List.

Such impeachment materials shall be included on the parties’ respective Evidentiary Hearing Exhibit Lists.

Applies to

Proposed jury instructions and verdict forms

Typed proposed jury instructions and verdict forms must be filed with the Remote Trial Clerk and submitted to the court in hard-copy form at the pretrial conference.

Will typed proposed Jury Instructions and Verdict Forms be filed with the Remote Trial Clerk and submitted to the Court in hard copy form at the Pre-Trial Conference? Yes No

Applies to

Certificate

Must include

certificate of conference

The certifying lawyer must state that an authorized firm lawyer had a substantive good-faith discussion with opposing counsel before the motion was noticed for hearing, but no agreement was reached.

I HEREBY CERTIFY that a lawyer in my firm with full authority to resolve this matter had a substantive conversation in person, by telephone, or by communication technology with opposing counsel on [enter date] in a good faith effort to resolve this motion before the motion was noticed for hearing but the parties were unable to reach an agreement.

Applies to

Certificate

Must include

certificate of conference

As an alternative, the party noticing a motion for hearing must provide a certificate listing good-faith attempts to contact opposing counsel because the authorized lawyer was unable to speak with opposing counsel.

I HEREBY CERTIFY that a lawyer in my firm with full authority to resolve this matter attempted in good faith to contact opposing counsel in person, by telephone, or by communication technology on:

Applies to

Motion

Must include

certificate of conference

A certificate of conferral must state that relief was discussed with the opposing party before filing and, if no response occurred, describe the efforts made to initiate dialogue.

Certificate of Conferral Prior to Filing Motion Pursuant to Rule 1.202, Fla. R. Civ. P. I certify that prior to filing this motion, I discussed the relief requested in this motion by [enter method of communication i.e. telephone, Zoom videoconferencing technology, or in-person meeting] on [enter date] with the opposing party and [the opposing party (agrees or disagrees) on the resolution of all or part of the motion] OR [the opposing party did not respond (describing all of the efforts undertaken to accomplish dialogue with the opposing party prior to filing the motion)].

Applies to

Release or settlement agreement

A copy of the release and any settlement agreements requiring the minor or guardian's signature must be provided, together with assurances of counsel's review and written agreement that the release applies only to the settling party and its insurers.

A copy of the release, and any settlement agreements to which the minor, or his guardian on behalf of the minor, will need to sign and assurances that it has been reviewed by counsel and that all parties agree, in writing, that it is only intended to release the settling party and their insurers as insurers of this particular settling party, and is not intended to release any other defendant or non-party.

Applies to

Release or settlement agreement

When a release or settlement agreement includes defense, indemnity, or hold-harmless obligations, the submission must state whether the obligations bind the minor child or only the guardian and identify the legal authority for binding the minor child.

If the release and/or settlement agreement contain a duty to defend, indemnify and hold harmless, is such agreement intended to bind and ===== PAGE 4 ===== apply to the minor child or just the guardian. If it is intended to apply to the minor child, by what legal authority can the minor child be bound to defend, indemnify and hold harmless this party.

Applies to

Confidentiality agreement

When a release or settlement agreement requires confidentiality, the submission must address whether the minor is bound, the authority for that obligation, the consequence of a violation, and the party responsible for seeking appropriate sealing under Florida Rule 2.420(d).

If the release and/or settlement agreement require a confidentiality agreement, is the minor child meant to be bound by such agreement and by what authority? What is the anticipated consequence to the minor child for violation of this confidentiality agreement? Which party will take responsibility to seek, and obtain, the appropriate measure to seal the limited documentation in the Court file pursuant to Florida Rules of Judicial Administration, Rule 2.420(d)?

Applies to

Trial set memorandum

When the parties agree or disagree about the need for an evidentiary hearing, they must prepare a Trial Set Memorandum for hearings estimated to exceed one hour and a proposed CMO scheduling the evidentiary hearing.

meet and confer shall prepare the following: a Division CV-E Trial Set Memorandum estimating the time for any motion hearing estimated to require more than 1 hour to be emailed to the Court’s Judicial Assistant; and an appropriate proposed Case Management order (“CMO” scheduling the evidentiary hearing on the motion or matter.

Applies to

Pretrial stipulation

Counsel must prepare, sign, and file a written Pretrial Stipulation.

Pursuant to Rule 1.200(k)(2), Fl. R. Civ. Pr., counsel for the parties have prepared, signed and filed a written Pretrial Stipulation, the contents of which are incorporated herein by reference.

Applies to

Pretrial conference checklist

Counsel must prepare, sign, and submit a written Pretrial Conference Checklist for filing, and it must be attached to the order as Exhibit A.

Pursuant to this Court’s procedures and the Order Setting Case for Trial, counsel for the parties have prepared, signed and submitted to the Court for filing with the Clerk, a written Pretrial Conference Checklist that will be attached to this Pretrial Conference Order as Exhibit A.

Applies to

Pretrial stipulation

Counsel must prepare, sign, and file a written Pretrial Stipulation under Florida Rule of Civil Procedure 1.200(k)(2).

Pursuant to Rule 1.200(k)(2), Fl. R. Civ. Pr., counsel for the parties have prepared, signed and filed a written Pretrial Stipulation.

Applies to

Pretrial conference checklist

Counsel must prepare, sign, and submit a written Remote Pretrial Conference Checklist to the Court for filing with the Clerk.

Pursuant to this Court’s procedures and the Order Setting Case for REMOTE JURY Trial, counsel for the parties have prepared, signed and submitted to the Court for filing with the Clerk, a written REMOTE Pretrial Conference Checklist.

Applies to

Proposed jury instructions and verdict forms

A complete set of proposed jury instructions and verdict forms must be filed with the Clerk and submitted to the Court at the Pretrial Conference.

A complete set of proposed jury instructions and verdict forms were filed with the Clerk and submitted to the Court in hard copy form at the Pretrial Conference.

Applies to

Proposed jury instructions and verdict forms

If proposed jury instructions and verdict forms were not submitted at the Pretrial Conference, the plaintiffs must file and submit a complete set in hard copy form by the stated 9:00 a.m. deadline.

The Plaintiff(s) shall file with the Clerk and submit to the Court in hard copy form a complete set of proposed jury instructions and verdict forms by no later than 9:00 a.m. on ___________________________, 20_____.

Applies to

Proposed jury instructions and verdict forms

A complete set of proposed jury instructions and verdict forms must be filed with the Clerk and submitted to the Court at the Pretrial Conference.

A complete set of proposed jury instructions and verdict forms were filed with the Clerk and submitted to the Court in hard copy form at the Pretrial Conference.

Applies to

Proposed jury instructions and verdict forms

If the proposed jury instructions and verdict forms were not submitted at the Pretrial Conference, plaintiffs must file them with the Clerk and submit hard copies to the Court by 9:00 a.m. on the stated date.

The Plaintiff(s) shall file with the Clerk and submit to the Court in hard copy form a complete set of proposed jury instructions and verdict forms by no later than 9:00 a.m. on ___________________________, 20_____.

Applies to

Certificate

Must include

certificate of service

Movant must file a certificate confirming service of the order on the client.

Movant shall serve a copy of this order to CLIENT by United States Postal Service and email, and file a certificate of service confirming the same for the Court.

Applies to

Motion

Must include

certificate of conference

The motion must include a filed statement certifying that counsel conferred with opposing counsel and that the dispute remains unresolved.

shall file with the court at the time ol filing of the motion a statement certifying that he or she has so conferred with opposing counsel and that counsel have been unable to resolve the disPute.

Applies to

Notice of motion

The notice of hearing on a motion to compel must include the specified certification concerning good-faith conferral and the restriction on cancelling the hearing without the judge's consent.

The moving parly's notice of hearing on a motion to compel shall include the following statement

Applies to

Statement of material facts

Statements of Material Facts must be filed and served as separate documents rather than 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.

Applies to

Joint case management report

If the parties determine that the 150-day conference is necessary, they must prepare and file a signed joint case management report and a single proposed order and email both to the Judicial Assistant before the conference.

This Division CV-E order scheduling the 150 day CMC will require the parties to meet to discuss and confer whether this CMC is necessary for the Court to fix the actual trial period, pretrial conference, and pretrial deadlines for the action, and, if so, to prepare and file a joint signed “Division CV-E Uniform Case Management Report” and a single proposed “Order Following 150 Day Case Management Conference to Set Actual trial Period” utilizing the Court’s forms published on the Fourth Judicial Circuit’s website, to be submitted to the Court via email to the Court’s Judicial Assistant prior to the 150 day CMC.

Applies to

Trial set memorandum

When the parties agree the 150-day conference is unnecessary, a party may seek cancellation by filing a Notice for Trial or motion to set the case for trial and emailing a completed Division CV-E Trial Set Memorandum to the Judicial Assistant.

If the parties agree that the 150 day CMC is not necessary to set the actual trial period, the Court will enter an order canceling the CMC hearing upon a party filing a Notice for Trial or Motion to Set the action for an actual trial period pursuant to Rule 1.440(b), Fla. R. Civ. P., and emailing to the Court’s Judicial Assistant a completed Division CV-E Trial Set Memorandum pursuant to the division’s procedures set forth below.

Applies to

Revised or supplemental expert report

If an expert's opinions or conclusions change based on new information, opposing counsel must be notified immediately and provided with a revised or supplemental report and updated deposition dates.

Any changes of opinions or conclusions based on new information must be made known to opposing counsel immediately, a revised or supplemental report provided and dates for updated depositions must also be provided.

Applies to

Summary judgment supporting or opposing materials

All materials referenced in support of or opposition to a summary-judgment motion must be in the record and filed on the docket, although previously filed materials need not be refiled.

All materials referenced in support of or opposition to the motion must be in the record, filed on the docket. Materials which have already been filed on the docket need not be refiled.

Applies to

Exhibit list

Counsel must deliver an itemized Exhibit List to the Trial Clerk at least 5 days before trial.

No later than FIVE (5) DAYS prior to the Trial, 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.

Applies to

Motion for trial

A motion to set the action for trial must include all minimum information required by Florida Rule of Civil Procedure 1.440(b).

Any party may file and serve a motion to set the action for trial pursuant to rule 1.440(b), Fla. R. Civ. P. which includes all of the minimum information required by said rule.

Applies to

Trial set memorandum

A party filing a motion for trial must provide the Judicial Assistant with a completed Division CV-E Trial Set Memorandum by email.

The party filing the motion for trial must email to the Court’s Judicial Assistant a courtesy copy of the motion for trial together with a completed Division CV-E Trial Set Memorandum to schedule the action for trial pursuant to the division’s procedures (See Section II.) infra.

Applies to

Trial set memorandum

When the parties agree by email to set the case for trial, the movant must include a fully completed Division CV-E Trial Set Memorandum in the email to the Judicial Assistant.

If the parties agree to set the case for trial via e-mail, the movant must e-mail a copy of the filed Motion for Trial and a fully completed Division CV-E Trial Set Memorandum to the Court’s Judicial Assistant.

Applies to

Notice of hearing

The movant must file a Notice of Ex Parte Hearing for the agreed trial date.

The movant then must file a a Notice of Ex Parte Hearing for the agreed-upon date.

Applies to

Trial set memorandum

An in-person movant at an ex parte hearing about a disputed trial date must present a fully completed Division CV-E Trial Set Memorandum.

If an ex parte hearing is being held to resolve a disagreement regarding the trial date, the in-person movant must present to the Court a fully completed Division CV-E Trial Set Memorandum form.

Applies to

Trial set memorandum

A movant appearing by telephone or Zoom must email the Trial Set Memorandum to the Court.

If the movant is appearing via telephone or Zoom, then the Trial Set Memorandum form shall be e-mailed to the Court.

Applies to

Motion

Must include

proposed order

A motion to use telephone or Zoom at a non-evidentiary hearing lasting more than thirty minutes must set forth good cause and include a proposed consent order provided to the Court by email.

Should counsel desire to attend a non-evidentiary hearing scheduled for more than thirty (30) minutes via telephone or Zoom, counsel must seek leave of Court by filing a written Motion and providing a courtesy copy of the Motion setting forth good cause to grant the Motion pursuant to Rule 2.530, Fla. R Gen. Prac. &. Jud. Admin. and proposed consent Order to the Court via electronic mail.

Applies to

Motion

Must include

proposed order

A motion to present testimony remotely at an evidentiary hearing or trial must state good cause and include a proposed consent order provided to the Court by email.

Should counsel desire to participate in an evidentiary hearing or trial and present testimony through telephone, Zoom, or other communication technology, regardless of the duration of the hearing, counsel must seek leave of Court by filing a written motion setting forth good cause to grant the motion pursuant to Rule 2.530(b)(2), Fla. R Gen. Prac. & Jud. Admin. and providing a courtesy copy of the Motion and a proposed Consent Order to the Court via electronic mail.

Applies to

Notice of hearing

Must include

certificate of conference

A certificate of conferral substantially conforming to either option in Exhibit B must appear immediately above the Notice of Hearing signature block.

of conferral substantially in the form provided in Exhibit “B”, either First Option or Second Option, attached to these “Policies and Procedures” set forth directly above the signature block of the Notice of Hearing for the motion.

Applies to

Motion

Must include

local rule certificate, certificate of conference

A substantially Rule 1.202-compliant certificate of conferral must be filed with the motion, and the Court will accept it above the motion’s signature block.

Pursuant to Fla. R. Civ. P. 1.202(b), the movant must file with the motion a “certificate of conferral, prior to filing the motion,” substantially in the form provided in quotation marks within Rule 1.202(b). The Court will accept a certificate of conferral substantially in the form provided within Rule 1.202(b) set forth directly above the signature block of the motion.

Applies to

Notice of hearing

Must include

local rule certificate, certificate of conference

After three good-faith attempts to reach opposing counsel, the noticing attorney must use the second-option certificate and report the dates and times of those attempts.

If counsel who notices the hearing is unable to reach opposing counsel to conduct the conference after three (3) good faith attempts, counsel who notices the hearing must identify in the Certificate of Conferral Prior to Scheduling the Motion for Hearing the dates and times of the efforts made to contact opposing counsel (attached hereto as “Exhibit B” “Second Option”).

Applies to

Notice of hearing

Must include

local rule certificate, certificate of conference

The Notice of Hearing must include a certificate confirming whether the conference occurred and, if not, documenting good-faith scheduling attempts; it must also state the conference date, participating attorneys, and specific results.

Counsel must file with the Notice of Hearing a “Certificate of Conferral Prior to Scheduling the Motion for Hearing” certifying that the meet and confer occurred (or did not occur and setting out the good faith attempts to schedule the conference) and identifying the date of the conference, the names of the participating attorneys, and the specific results obtained.

Applies to

Discovery motion

Must include

certificate of conference

Discovery motions and motions to compel must include the required certification of a good-faith attempt.

All such discovery motions must comply with the Florida Rules of Civil Procedure including, but not limited to, a certification of a good faith attempt

Applies to

Dismissal papers

Must include

caption

Parties settling or dismissing a case must file appropriate dismissal papers, including the Final Disposition Form.

Parties are directed to file appropriate dismissal papers including the Final Disposition Form (see Form 1.998) as required by the Florida Rules of Civil Procedure (Rule 1.545).

Applies to

Notice of settlement

The parties must immediately file a Notice of Settlement when a case settles.

In the event of settlement, the parties shall immediately file a Notice of Settlement.

Applies to

Agreed case management order regarding settlement

The parties must immediately meet and confer, prepare the settlement case-management order using the court’s Word template, and submit it to the court with the anticipated final-disposition timeline.

The parties shall immediately meet and confer to prepare an Agreed Case Management Order Regarding Settlement (template found on the Court’s website in Word format) to be submitted to the Court detailing the anticipated timeline for final disposition of the action pursuant to Rule 1.545 Fla. R. Civ. P.

Applies to

Dismissal

After settlement, the parties must submit a stipulated dismissal order or file a dismissal with prejudice.

Additionally, the parties shall submit a stipulation for an order of dismissal or shall file a dismissal with prejudice.

Applies to

Attorney fees order

When attorney-fee entitlement has not already been found, an entitlement hearing must be scheduled before any reasonableness hearing.

If entitlement has not been found, a hearing on entitlement must be set first.

Applies to

Attorney fees procedures

The parties must comply with the published attorney-fee procedures before the court’s evidentiary hearing on reasonableness.

The parties shall comply with said procedures prior to the Court holding an evidentiary hearing on reasonableness.

Applies to

Notice of hearing

Must include

certificate of conference

The Notice of Hearing for a motion in limine must include the Certificate of Conferral Prior to Scheduling the Motion for Hearing.

and a Certificate of Conferral Prior to Scheduling the Motion for Hearing (attached as “Exhibit B”) in the Notice of Hearing filed with the Court.

Applies to

Proposed order

Every proposed order submitted after a hearing must include a cover letter.

ALL PROPOSED ORDERS PRESENTED FOLLOWING HEARING, whether submitted to the Court in writing or via email as contemplated supra, MUST INCLUDE A COVER LETTER INDICATING:

Applies to

Motion in limine

A motion in limine must state its grounds with particularity, identify the substantial legal matters to be argued, and identify supporting evidence or material.

The MIL shall state with particularity the grounds upon which it is based and the substantial matters of law to be argued and shall identify any evidence or supporting material on which the movant relies.

Applies to

Proposed order

Must include

proposed order

The party filing a motion in limine must prepare a proposed order reflecting the Court’s rulings after a contested hearing.

The party filing the MIL will prepare the proposed order on any contested hearing reflecting the Court’s ruling(s).

Applies to

Proposed order

Every order must identify the subject and the Court’s ruling in its caption.

All orders must describe, in the caption, the subject and ruling of the court

Applies to

Proposed order

The proposed-order cover letter must identify the case, motion heard, hearing date and time, and order title.

What the Order is for (i.e. the case, the motion heard, including date and time, the title of the Order, etc.); and

Applies to

Proposed order

The proposed-order cover letter must state that opposing counsel and unrepresented parties received the same materials and whether they agree with the proposed order.

That all opposing counsel/unrepresented parties have been provided with the same materials being provided to the Court, and whether the parties agree with the language of the proposed Order.

Applies to

Proposed order

A proposed consent order must identify itself as “Consent” or “Agreed” in the caption and describe the court's subject and ruling there.

All consent Orders shall include the word “Consent” or “Agreed” in the caption of the proposed Order, and must describe in the caption, the subject and ruling of the court, i.e., “Agreed Order Granting Plaintiff’s Motion for Partial Summary Judgment on Liability.”

Applies to

Motion to withdraw

Every motion to withdraw must state the reasons for withdrawal.

All Motions to Withdraw must set forth reasons for withdrawal and be set for hearing, with proper notice to the client, in accordance with Fla. R. Gen. Prac. & Jud. Admin. 2.505(f)(l), and all parties/attorneys.

Applies to

Proposed order

If withdrawal is granted, the moving attorney must prepare a written order stating the client’s last known address, telephone number, and email address.

If the motion is granted, the attorney moving to withdraw shall prepare a written order setting forth the client’s last known address, telephone number, and email address.

Applies to

Filing or submission

Must include

ai disclosure

Any filing or submission containing AI-generated content must disclose the AI use on its face and include the Court’s prescribed certification directly above the signature block.

If a lawyer or pro se party submits to the court any filing or submission containing AI generated content, that lawyer or pro se party must disclose the use of AI on the face of the document and must include a certification that the lawyer or pro se party has personally reviewed and verified the content’s accuracy set forth directly above the signature block of the filing or submission in the form provided by this Court as Exhibit “C” to these “Policies and Procedures” together with the same template artificial intelligence certificate in Word format published on the Court’s website for the lawyer or pro se party to copy and insert above the signature block of the filing or submission.

Applies to

Motion

Must include

certificate of conference

Before filing a motion, counsel must certify prior discussion of the requested relief with the opposing party, including the communication method and date, and state either the opposing party’s position or the efforts made to obtain a response if the party did not respond.

Certificate of Conferral Prior to Filing Motion Pursuant to Rule 1.202, Fla. R. Civ. P. I certify that prior to filing this motion, I discussed the relief requested in this motion by [enter method of communication i.e. telephone, Zoom videoconferencing technology, or in-person meeting] on [enter date] with the opposing party and [the opposing party (agrees or disagrees) on the resolution of all or part of the motion] OR [the opposing party did not respond (describing all of the efforts undertaken to accomplish dialogue with the opposing party prior to filing the motion)].

Applies to

Certificate

Must include

certificate of conference

The certifying lawyer must state that a fully authorized firm lawyer made a good-faith effort to resolve the motion with opposing counsel before it was noticed for hearing, but no agreement was reached.

I HEREBY CERTIFY that a lawyer in my firm with full authority to resolve this matter had a substantive conversation in person, by telephone, or by communication technology with opposing counsel on [enter date] in a good faith effort to resolve this motion before the motion was noticed for hearing but the parties were unable to reach an agreement.

Applies to

Certificate

Must include

certificate of conference

As an alternative when opposing counsel cannot be reached, counsel seeking to notice a motion for hearing must provide a certificate listing good-faith contact attempts and confirming that opposing counsel could not be reached.

I HEREBY CERTIFY that a lawyer in my firm with full authority to resolve this matter attempted in good faith to contact opposing counsel in person, by telephone, or by communication technology on: 1. ___ (Date)_____________ at ____(Time)________; 2. ___ (Date)_____________ at ____(Time)________; 3. ___ (Date)_____________ at ____(Time)________; to discuss resolution of this motion without a hearing and the lawyer in my firm was unable to speak with opposing counsel.

Applies to

Ai certificate

Must include

ai disclosure

A filing using AI-generated content or AI-assisted research must include a certificate identifying the affected sections or topics, confirming pre-filing review and verification, and verifying all AI-derived citations and quotations.

I certify that I have used artificial intelligence (“AI”) to generate content or conduct research as follows [identify sections or topics] and that prior to filing this document, I have reviewed and verified the accuracy of the artificial intelligence, and the Court may consider and rely upon that content generated by artificial intelligence when ruling. I have confirmed as genuine all citations and quotations from AI outputs.

Applies to

Expert written report

The examining physician or healthcare provider must issue a detailed written report and provide it to all counsel within 30 days after the examination.

Pursuant to Fla. R. Civ. P. 1.360(b) a “detailed written report” will be issued by the examining physician or healthcare provider and provided to all counsel no later than 30 days after the day of the examination.

Applies to

Case status report

At least 10 days before the Final Case Management Conference, the parties must confer and prepare a case status report for filing and provide a courtesy copy to the Court.

At least ten (10) days prior to the Final Case Management Conference, the parties shall confer to prepare a case status report, which shall be filed with the Clerk of the Court and a courtesy copy of the same provided to the Court either prior to or at the time of the Final Case Management Conference.

Applies to

Deposition transcript

A complete copy of any referenced deposition transcript, including all exhibits, must be filed on the docket.

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

Applies to

Summary judgment motion and response

The movant and nonmovant must cite the particular portions of record materials in their summary-judgment motion and response.

The movant and nonmovant must cite to particular parts of materials in the record in the motion and response. Fla. R. Civ. P. 1.510(c)(1)(A).

Applies to

Affidavit or declaration

Affidavits or declarations used to support or oppose a summary-judgment motion must be based on personal knowledge, set out admissible facts, and establish the declarant's competence 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.”

Applies to

Summary judgment evidence

At summary judgment, evidence need not be submitted in trial-admissible form, but its content or substance must be admissible.

At the summary judgment stage, the parties need not submit evidence in a form admissible at trial. However, the content or the substance of the evidence must be admissible.

Applies to

Summary judgment motion

Must include

statement of facts

A motion for summary judgment must be accompanied by a separate Statement of Material Facts that is contemporaneously filed and served.

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.

Applies to

Pre summary judgment hearing stipulation

Movants and nonmovants must satisfy the Pre-Hearing Meeting Requirement and file a Pre-Summary Judgment Hearing Stipulation before the summary judgment hearing.

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.

Applies to

Statement of material facts

Statements of Material Facts must use separately numbered paragraphs and support each material fact with specific pinpoint citations to record materials.

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 additions, the Statements of Material Facts shall: (A) Not exceed ten (10) pages; (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

Applies to

Statement of material facts

A general exhibit citation without a page number or pincite is noncompliant when specific evidentiary support is required.

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.

Applies to

Non movant statement of material facts

Each paragraph-by-paragraph response in the non-movant’s Statement of Material Facts must begin with either “disputed” or “undisputed.”

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.”

Applies to

Reply statement of material facts

When the non-movant asserts additional facts, the movant must respond to each additional fact in a separately served Reply Statement of Material Facts.

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.

Applies to

Reply statement of material facts

The Reply Statement of Material Facts must follow the non-movant’s additional-fact numbering, begin each paragraph with “disputed” or “undisputed,” and provide record citations for disputed facts.

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).

Applies to

Reply statement of material facts

The movant must respond to additional facts in the opponent’s Statement of Material Facts even without serving 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.

Applies to

Pre summary judgment hearing stipulation

Both parties' counsel must prepare and file a Pre-Summary Judgment Hearing Stipulation no later than five days before the hearing and email a courtesy copy to the 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 five (5) days prior to the summary judgment hearing with a courtesy copy emailed to the Court’s Judicial Assistant and must contain the following:

Applies to

Pre summary judgment hearing stipulation

The stipulation must identify timing issues concerning filing and service of the summary judgment motion, supporting facts, response, and response facts, and unresolved timing issues must be presented in an appropriate written motion before the hearing.

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. Any timing issues shall be reduced to an appropriate written motion to be filed and heard prior to the summary judgment hearing.

Applies to

Pre summary judgment hearing stipulation

The stipulation must confirm whether all materials relied upon to support the parties’ factual positions have been filed and placed 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.

Applies to

Pre summary judgment hearing stipulation

The stipulation must state specific admissibility objections, including the legal grounds and reasons why cited material is inadmissible or why an affidavit or declaration fails personal-knowledge, admissibility, or competency requirements.

The Stipulation shall contain a statement reflecting specific objection(s) stating legal grounds and specific reasons3 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.

Applies to

Pre summary judgment hearing stipulation

The stipulation must confirm whether the nonmovant will show by affidavit or declaration that essential facts supporting its opposition cannot be presented.

The Stipulation shall confirm whether nonmovant will be showing by affidavit or declaration that it cannot present facts essential to justify its opposition to the summary judgment motion.

Applies to

Proposed order

Proposed summary judgment orders should contain detailed sections summarizing the facts and record citations, stating applicable law, and presenting legal conclusions and reasons for the disposition.

the proposed orders granting/denying the summary judgment motion should contain at, a minimum the following three well-defined sections: (1) summary of facts with citations to particular parts of materials in the record supporting each fact with such specificity the Court could readily locate the portion of the materials supporting such factual positions in the record (i.e., depositions page(s)/line(s), location of materials, records, affidavits, and pleadings in the record by docket/line Revised January 2025 ===== PAGE 12 ===== number together with page and paragraph number), (2) Applicable Law (i.e., general summary judgment standard caselaw, case specific caselaw relevant to any summary judgment issues or legal issues inherent to the cause of action/theory of liability), (3) Legal Conclusions (containing the application of the law to the facts, summary judgment analysis, and specific reasons for granting or denying the motion); and

Applies to

Privilege log

A party withholding discoverable information as privileged must expressly claim the protection by filing an adequate privilege log identifying, at minimum, the sender, recipients, title or type, date, and subject matter.

A party withholding information otherwise discoverable by claiming it is privileged shall make the claim expressly by preparing and filing an adequate privilege log compliant with Rule 1.280(c)(6), Florida Rules of Civil Procedure and the 2024 Florida Handbook on Civil Discovery Practice to “include at a minimum (for documents), sender, recipients, title or type, date and subject matter”

Applies to

Deposition availability dates

The party requesting the examination must provide opposing counsel with at least three examiner availability dates when the examination is scheduled.

The party requesting the examination shall also provide to opposing counsel, at the time the examination is scheduled, no less than three dates when the examiner will be available for oral deposition.

Applies to

Expert deposition

The examiner must be available for deposition within 10 days after rendering the report.

The witness shall be available to be deposed within ten (10) days of rendering the report.

Applies to

Expert written report

When a deposition date falls within 30 days of the examination, the CME written report must be provided to deposing counsel at least 5 days before the deposition.

Should any of the dates be within 30 days of the examination, the above referred to CME written report shall be provided to deposing counsel no later than 5 days before the deposition date.

Applies to

Expert written report

A Rule 1.360 report is inadmissible at trial unless the parties stipulate to its admission.

No report under Fla. R. Civ. P. 1.360 will be admissible at trial absent a stipulation by the parties.

Applies to

Notice of compliance

Counsel must jointly prepare and file a short notice confirming compliance with paragraphs 1 and 2 of the order.

Counsel for the Parties shall jointly prepare and file a short Notice of Compliance confirming they have met the requirements of paragraphs 1 and 2 of this order.

Applies to

Expert disclosure

Each expert witness disclosure must be accompanied by a written expert report.

At the time the expert witnesses are disclosed, the disclosure shall be accompanied by a written report.

Applies to

Expert report

The written expert report must contain the specified opinions, basis, subject matter, supporting data, exhibits, qualifications, compensation, prior testimony, and at least two deposition availability dates produced within 10 days of disclosure.

The report shall contain a complete statement of all opinions to be expressed and the basis and reasons therefore; the subject matter upon which the expert is expected to testify; the substance of the facts and opinions to which the expert is expected to testify; a summary of the grounds for each opinion; the data or other information relied upon by the witness in forming the opinions; any exhibits to be used as a summary of or support for the opinions; the qualifications of the witness, including a list of all publications authored by the witness within the preceding ten (10) years; the compensation paid and/or to be paid to the expert; a list of any other cases in which the witness has testified as an expert at trial or by deposition within the preceding four (4) years, and a list of at least two (2) dates on which the expert witness is available for deposition shall be produced within ten (10) days of the expert’s disclosure.

Applies to

Joint pretrial stipulation

The original Joint Pretrial Stipulation must be filed and one copy mailed or delivered to the Court at least 15 days before the Pretrial Conference.

The original shall be filed with the Clerk and one copy shall be mailed or delivered to the Court no later than fifteen (15) days prior to the pretrial conference.

Applies to

Proposed jury instructions and verdict form

Each party must file and submit an original and copy of proposed jury instructions and verdict form at least 10 days before the Jury Instruction Charge Conference.

At least ten (10) days prior to this conference with the Court each party shall file and submit to the Court an original and copy of that party's Proposed Jury Instructions and Verdict Form.

Applies to

Case status report

The case status report must contain the listed case-management, witness, exhibit, jury, and trial-impact information in separately numbered paragraphs.

The case status report shall contain the following in separately numbered paragraphs: A list of all pending motions requiring action by the Court and the date these motions are set for hearing. Any change regarding the estimated trial time. The names of the attorneys who will try the case. A list of the names and addresses of all non-expert witnesses ... A list of all exhibits intended to be offered at trial. Certification that copies of witness and exhibit lists will be filed with the Clerk of the Court at least 48 hours prior to the date and time of the Final Case Management Conference. A deadline for the filing of amended lists of witnesses and exhibits ... An agreed, or red-line ... draft Juror Questionnaire ... Any other matters which could impact the timely and effective trial of the action.

Applies to

Privilege log

Each privilege-log entry must describe the document’s subject matter, production purpose, and the specific basis for privilege or immunity with enough detail for the court to assess the claim, and generic descriptions are insufficient.

describe the document’s subject matter, purpose for its production, and a specific explanation of why the document is privileged or immune from discovery. These categories, especially this last category, must be sufficiently detailed to allow the court to determine whether the discovery opponent has discharged its burden of establishing the requirements expounded upon in the foregoing discussion. Accordingly, descriptions such as ‘letter re claim,’ ‘analysis of claim,’ or ‘report in anticipation of litigation’-with which we have grown all too familiar-will be insufficient.

Applies to

Notice of request for in camera review

A party seeking judicial in camera review must file a Notice of Request for In Camera Review.

The party requesting the in camera review of documents asserted to be privileged must file a Notice of Request for In Camera Review.

Applies to

Notice of request for in camera review

The notice must identify each requested document by reproducing the complete corresponding information from the objecting party’s privilege log.

The notice shall identify the documents requested for review by excerpting the complete information provided in the objecting party’s privilege log for each document.

Applies to

Order scheduling evidentiary hearing

When an evidentiary record is needed for in camera review, the parties must meet and confer and prepare an order scheduling the evidentiary hearing and setting appropriate pretrial deadlines for disclosure, discovery, and completion.

If any of the parties determine that an evidentiary record must be developed for the Court to consider during its in camera review, then the parties must meet and confer to prepare an appropriate Order scheduling the evidentiary hearing to develop a relevant evidentiary record for consideration during the in camera review and establishing appropriate deadlines for matters to be disclosed, discovered, and completed prior to the hearing.

Applies to

Cover letter

The cover letter must state that the enclosed documents are submitted for in camera inspection under the Court’s order.

The cover letter will advise the documents are being provided for an in camera inspection pursuant to this Court’s order.

Applies to

Cover letter

The cover letter must not contain argument or other information beyond the stated submission notice.

No argument or other information shall be included in the cover letter.

Applies to

Privilege log

When necessary, the objecting party must prepare, file, and serve an adequate privilege log within thirty days after receiving subpoenaed documents, identifying each privacy, privilege, confidentiality, or trade-secret objection.

If necessary, within thirty (30) days of the objecting party’s receipt of documents produced by any subpoenaed non-party, the party opposing such discovery shall prepare and file and serve on the party seeking discovery an adequate privilege log compliant with the guidelines regarding privilege logs set forth on page 1 supra, which log shall set forth each objection, if any, to production of any document (in full or in part) based on Florida’s Constitutional right to privacy or other privilege, confidentiality, or trade secret (the “Privilege Log” and “Privilege Logged Documents”).

Applies to

Discovery response

For each requested item or category, a discovery response must permit inspection or state specific grounds and reasons for objecting.

(B) Responding to Each Item. For each item or category, the response must either state that inspection and related activities will be permitted as requested or state with specificity the grounds for objecting to the request, including the reasons.

Applies to

Discovery response

A response offering document production instead of inspection must specify completion by the requested inspection time or another reasonable time stated in the response.

The responding party may state that it will produce copies of documents or of electronically stored information instead of permitting inspection. The production must then be completed no later than the time for inspection specified in the request or another reasonable time specified in the response.

Applies to

Discovery objection

Every discovery objection must state whether responsive materials are withheld on the basis of that objection.

(C) Objections. An objection must state whether any responsive materials are being withheld on the basis of that objection.

Applies to

Discovery objection

An objection applying only part of a discovery request must identify the disputed part and permit inspection of the remainder.

An objection to part of a request must specify the part and permit inspection of the rest.

Applies to

Discovery response

Discovery responses must specify objection grounds, disclose whether responsive materials are withheld, and state the production time and any rolling-production beginning and ending dates.

responses to discovery requests must: • State grounds for objections with specificity; • An objection must state whether any responsive materials are being withheld on the basis of that objection; and • Specify the time for production and, if a rolling production, when production will begin and when it will be concluded.

Applies to

Discovery response

A producing party need not describe or log every withheld document, but must notify other parties that documents are withheld based on the objection.

The producing party does not need to provide a detailed description or log of all documents withheld, but does need to alert other parties to the fact that documents have been withheld and thereby facilitate an informed discussion of the objection.

Applies to

Brief

Must include

legal argument

Each response brief had to address whether the listed discovery responses violated the cited rule or abused discovery and, if so, what sanctions would be appropriate.

1. Whether each of the discovery responses by that party identified in the table ... is or is not a violation of the rule cited or otherwise an abuse of discovery, and 2. If any responses identified in the table ... are discovery abuses, the appropriate sanction or combination of sanctions that is appropriate for an offending attorney.

Applies to

Privilege based discovery objection

A privilege log must accompany any privilege-based objection to discovery.

Thus, Rule 26(b)(5)(A)’s requirement of a privilege log as part of any privilege-based objection to discovery is nothing new.

Applies to

Joint statement

Attorneys and pro se parties must confer, prepare a joint statement containing a discovery plan and specified case-management information, and file it with the clerk at least 14 days before the initial case management conference.

At least 20 days prior to the date of the initial case management conference, attorneys for the parties as well as any parties appearing pro se shall confer and prepare a joint statement, which shall be filed with the clerk of the court no later than 14 days before the conference, outlining a discovery plan and stating:

Applies to

Discovery production

A producing party must either produce documents as kept in the usual course of business or identify them to correspond with the request categories.

When producing documents, the producing party shall either produce them as they are kept in the usual course of business or shall identify them to correspond with the categories in the request.

Applies to

Notice of compliance

The parties must jointly prepare and file a short Notice of Compliance confirming completion of the ordered meet-and-confer requirements.

Counsel for the Parties shall jointly prepare and file a short Notice of Compliance confirming they have met the requirements of Para. 1 and 2 of this Order.

Applies to

Privilege summary log

A producing party must prepare a privilege or work-product summary log containing available file, system, and application metadata for each document withheld or redacted, but excluding full text.

In an effort to avoid unnecessary expense and burden, the parties agree that, for documents redacted or withheld from production on the basis of attorney-client privilege, work product doctrine and/or any other applicable privilege, the producing party will prepare a summary log containing the file, system and application metadata information set forth herein, for each document, record, etc. (except for full text), to the extent such information exists.

Applies to

Medical examination report

The examining physician must prepare a detailed written report stating the examination findings, tests performed, diagnoses, and conclusions.

The examining physician shall prepare a detailed written reporting setting forth all of the examining physician’s findings, including all tests made, diagnoses and conclusions.

Applies to

Daubert motion

A proper Daubert motion must identify the source, substance, and methodology of the challenged expert testimony.

A proper Daubert motion must identify the source, substance, and methodology of the challenged testimony.

Applies to

Daubert motion

A Daubert objection must identify the specific opinion challenged and state a substantive basis for the objection rather than merely asserting that a Daubert objection is being raised.

“Daubert objections must be directed to specific opinion testimony and ‘state a basis for the objection beyond just stating [the party] was raising a Daubert objection, in order to allow opposing counsel an opportunity to have the [expert] address the perceived defect in his testimony.’”

Applies to

Notice of hearing

Must include

local rule certificate

The Notice of Hearing filed with the court must include a Certificate of Compliance showing that the required meet-and-confer conference occurred.

Pursuant to said “Meet and Confer” Requirements provisions a “Certificate of Compliance” (See Exhibits “A” and “B” to “Division CV-E Policies and Procedures”) that the conference has occurred shall be included in the Notice of Hearing filed with the Court.

Applies to

Pre evidentiary hearing stipulation

If the expert-witness dispute remains unresolved after the meet-and-confer, the attorneys must jointly provide the court with a pre-evidentiary hearing stipulation containing the specified basic information for the Daubert hearing.

If the expert witness matter is not resolved at the meet and confer, the attorneys for the parties shall discuss and provide the Court the following basic information30 within a joint pre-evidentiary hearing stipulation31 for the Daubert hearing.

Applies to

Proposed order

Must include

proposed order

Counsel must prepare a proposed order scheduling the Daubert evidentiary hearing and setting deadlines for disclosure, discovery, and completion of matters before the hearing.

During the above referenced meet and confer or a subsequent meet and confer, Counsel must prepare an appropriate proposed Order scheduling the evidentiary hearing on the Daubert Motion and establishing appropriate deadlines for matters to be disclosed, discovered and completed prior to the hearing.

Applies to

Agreed case management order regarding settlement

Upon settlement, the parties must meet and confer and submit an Agreed Case Management Order Regarding Settlement describing the anticipated final-disposition timeline.

the parties shall immediately meet and confer to prepare an Agreed Case Management Order Regarding Settlement1 to be submitted to the Court detailing the anticipated timeline for final disposition of this action pursuant to Rule 1.545 Fla. R. Civ. P.

Applies to

Pretrial conference checklist

Counsel must complete and submit the Pretrial Conference Checklist and submit a proposed Pretrial Conference Order at or immediately after the conference.

complete the Division CV-E “Pretrial Conference Checklist”1 to be submitted to the Court at the Pretrial Conference; draft a proposed “Pretrial Conference Order”1 to be submitted to the Court at the Pretrial Conference or immediately thereafter

Applies to

Pretrial stipulation

Counsel must prepare and file a Pretrial Stipulation at the Pretrial Conference.

Counsel shall prepare a Pretrial Stipulation2 which shall be filed with the Court at the Pretrial Conference and shall contain the following:

Applies to

Trial exhibits

Trial exhibits must be exhibited to opposing counsel 30 days before the Pretrial Conference.

All exhibits intended to be offered, published, or utilized in any way at trial, including, but not limited to, evidence, demonstrative purposes, impeachment, and rebuttal, shall be exhibited to all opposing counsel THIRTY (30) DAYS prior to the Pretrial Conference.

Applies to

Exhibit list

Before opening statements, each party’s counsel must give the Trial Clerk an itemized Exhibit List.

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.

Applies to

Expert witness notice

Each party must serve opposing counsel and file the court with an expert-witness notice containing the required expert information.

each party shall serve on all opposing counsel and file with the Court a notice containing the following information regarding each expert witness who will testify at trial and present evidence under §§90.702, 90.704 and 90.705, Florida Statutes

Applies to

Expert witness notice

An expert not included in the required notice may not testify without a court order.

Any expert witness not included on the Notice as provided herein will not be allowed to testify without an order of the Court.

Applies to

Trial witness list

Final trial-witness lists must identify each witness’s name and address and whether the witness will testify live or by deposition.

Each list shall contain the name and address of each witness and shall identify whether each witness is expected to testify live or by deposition.

Applies to

Trial witness list

A trial witness not disclosed as required may not testify 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.

Applies to

Jury instructions

Typed proposed jury instructions and verdict forms must be filed with the court at the Pretrial Conference.

Typed proposed jury instructions and verdict forms shall be filed with the Court at the Pretrial Conference

Applies to

Jury instructions

Plaintiffs must prepare the complete set of jury instructions and verdict forms and serve opposing counsel by the pretrial attorney meeting.

The Plaintiff(s) shall be responsible for preparing a complete set of instructions and verdict forms and serving them upon opposing counsel at or before the pre-trial meeting of attorneys contemplated by paragraph 5.

Applies to

Dismissal

After settlement, the parties must submit a stipulated dismissal order or file a dismissal with prejudice.

the parties shall submit a stipulation for an order of dismissal or shall file a dismissal with prejudice.

Applies to

Exhibit list

At least 7 calendar days before an evidentiary hearing, the parties must exchange exhibit lists identifying potential exhibits by Bates number.

At least 7 calendar days in advance of an evidentiary hearing, the parties must exchange exhibit lists that specifically identify by Bates number potential exhibits to be used at the hearing.

Applies to

Exhibit list

No later than 5 calendar days before the evidentiary hearing, the parties must meet and confer by telephone or video conference about exhibit authenticity, admissibility, and presentation.

Within 5 calendar days in advance of the evidentiary hearing, the parties must meet and confer by telephone or video conference to stipulate to as much as practicable regarding authenticity and admissibility and to agree on the format and manner in which evidence will be presented at the hearing.

Applies to

Exhibit index

The parties must jointly prepare an index of all exhibits to be used at the hearing.

During the meet and confer after the exchange of exhibit lists, the parties shall prepare jointly an index of all exhibits that will be used at the hearing.

Applies to

Exhibit index

The movant is primarily responsible for preparing the exhibit index and providing its final copy to the court and clerk’s office.

The movant shall be primarily responsible for preparing this index and for providing the final copy of the index to the court and clerk’s office.

Applies to

Exhibit index

The exhibit index must identify any objections to each exhibit and the party making each objection.

This index shall also specifically identify what objections exist, if any, to each exhibit and which party is making the objection.

Applies to

Proposed exhibits

By the exhibit-list meet-and-confer meeting, the parties must exchange previously unexchanged proposed exhibits, except exhibits solely for impeachment.

The parties shall exchange copies of any proposed exhibits that have not previously been ex- changed no later than this meeting, except for exhibits solely to be used for impeachment.

Applies to

Witness list

At least 10 business days before an evidentiary hearing, the parties must exchange witness lists containing witness names and known email addresses and telephone numbers.

At least 10 business days in advance of an evidentiary hearing, the parties shall exchange witness lists that include the witnesses’ names and, if known, email addresses and telephone numbers.

Applies to

Witness list

The witness list must identify witnesses needing an interpreter or ADA accommodation and include the names of all interpreters.

The parties shall also identify any witness for whom an interpreter or an accommodation under the Americans with Disabilities Act will be required, and include the names of all interpret- ers on the witness list.

Applies to

Witness list

The court-filed witness list must omit witnesses’ email addresses and phone numbers and be filed at least 10 business days before the evidentiary hearing.

Witness lists shall also be filed with the Court without the witnesses’ email addresses or phone numbers at least 10 business days in advance of an evidentiary hearing.

Applies to

Deposition notice

A notice for a remote deposition must identify the virtual video conference platform.

The deposition notice for any remote deposition shall identify the virtual video conference platform.

Applies to

Deposition notice

A remote-deposition notice must generally explain how participants can access the proceeding.

The notice shall also contain a general description of how deposition participants may access the remote deposition.

Applies to

Certificate

Must include

ai disclosure

A document containing AI-generated content or AI-assisted research must include an Artificial Intelligence Certificate identifying the affected sections or topics and certifying that the filer reviewed and verified the AI output, including its citations and quotations.

Artificial Intelligence Certificate I certify that I have used artificial intelligence (“AI”) to generate content or conduct research as follows [identify sections or topics] and that prior to filing this document, I have reviewed and verified the accuracy of the artificial intelligence, and the Court may consider and rely upon that content generated by artificial intelligence when ruling. I have confirmed as genuine all citations and quotations from AI outputs.

Applies to

Notice of hearing

A Notice of Hearing must list the relevant motions and docket lines and must be e-filed and served immediately after hearing time is reserved.

The Notice of Hearing should list all motion(s) and the docket line of the motion, e-filed and served immediately after reserving hearing time.

Applies to

Proposed order

Each proposed order must include a cover letter that either certifies agreement by all parties or identifies any party disagreement.

All proposed orders must be accompanied by a cover letter either (1) certifying that all parties agree to the order or (2) containing a statement identifying any disagreement of the parties as to the proposed order.

Applies to

Proposed order

Every consent proposed order must include either “Consent” or “Agreed” in its caption.

All consent Orders shall include the word “Consent” or “Agreed” in the caption of the proposed Order.

Applies to

Emergency motion

A detailed motion requesting an emergency hearing must state the issues, reasons for emergency relief, and time needed for each party’s presentation.

If a party believes there is a factual basis for setting an emergency hearing, a detailed motion setting forth the following must be filed: (1) the issues to be resolved, (2) reasons why an emergency hearing is necessary, and (3) the amount of time needed for each party’s presentation.

Applies to

Suggestion of bankruptcy

If any party files for federal bankruptcy protection, a Suggestion of Bankruptcy must be filed in the court file.

Should any party file for federal bankruptcy protection, a Suggestion of Bankruptcy MUST be filed in the Court file.

Applies to

Proposed mediation order

Moving counsel must lead the mediation coordination and submit a proposed mediation order.

Counsel for the moving party shall take the lead in coordinating the mediation and submit a proposed mediation order.

Applies to

Expert affidavit

Each party must disclose its experts’ opinions in affidavit form 15 days before mediation.

Each party shall disclose their experts’ opinions in affidavit form fifteen (15) days prior to the mediation.

Applies to

Joint pre hearing stipulation

After mediation, counsel must provide and file a joint pre-hearing stipulation identifying disputed items and positions, witnesses and experts, the form of expert testimony, and the discovery and hearing-readiness schedule.

Upon completion of the mediation requirement set forth above, counsel shall provide to the Court, and file with the Clerk, in writing, a joint pre-hearing stipulation containing the following: (a) A list of the line items of costs or attorney’s fees2 that remain in dispute within the claim. (b) Identify by line item the legal and factual basis for each objection and dispute by the non-movant and the specific response of the movant(s) to each objection, together with legal authorities in support of each party’s position. (c) A list of all non-expert witnesses that will testify and the subject matter about which they will testify to at the hearing. (d) A list of each expert who will testify at the hearing and the specific opinions he/she will render if not already contained within the affidavit previously filed.3 (e) Whether experts will testify by affidavit or live. (f) The timeframe within which discovery on this matter will be completed and when each side will be ready for hearing on the issue of fees and costs.

Applies to

Expert affidavit

Experts may present at the hearing only opinions included in their affidavits or a supplemental submittal.

Opinions not expressed within the affidavits, or by a supplemental submittal, will not be permitted at the hearing.

Applies to

Proposed order

Must include

proposed order

When the Court holds costs or attorney’s fees matters under advisement, counsel must comply with the Division CV-E procedures for submitting proposed orders.

In the event the Court takes any costs and attorney’s fees matters under advisement, counsel for the movant(s) and non-movant(s) opposing any part of the claim shall comply with Division CV-E Policies and Procedures for submitting proposed orders to the Court set forth in Section XXIV published on the Court’s website.

Applies to

Pretrial stipulation

Must include

exhibit list

Counsel must prepare and file a Pretrial Stipulation at the Pretrial Conference.

Counsel shall prepare a Pretrial Stipulation3 which shall be filed with the Court at the Pretrial Conference

Applies to

Pretrial conference checklist

Must include

caption

The Division CV-E Pretrial Conference Checklist and a proposed Pretrial Conference Order must be submitted to the court.

complete the Division CV-E “Pretrial Conference Checklist”1 to be submitted to the Court at the Pretrial Conference; draft a proposed “Pretrial Conference Order”1 to be submitted to the Court at the Pretrial Conference or immediately thereafter

Applies to

Pretrial stipulation

Must include

exhibit list

The Pretrial Stipulation must list all potential trial exhibits and state any objections to opposing-party exhibits.

The Pretrial Stipulation shall contain a list of all exhibits that may be offered in evidence at trial, together with a statement of objections, if any, to exhibits offered by the opposing party.

Applies to

Exhibit list

Must include

exhibit list

Before opening statements, counsel must give the Trial Clerk an itemized list of all exhibits intended for introduction.

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.

Applies to

Expert witness notice

An expert witness omitted from the required notice may not testify without a court order.

Any expert witness not included on the Notice as provided herein will not be allowed to testify without an order of the Court.

Applies to

Fact witness list

A fact witness omitted from the required preliminary disclosure may not testify at trial without a court order.

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

Applies to

Proposed order

When JAC has no objection to the underlying motion, counsel must attach JAC’s response to the proposed order as Exhibit A.

When counsel is submitting a proposed order related to a motion to which JAC has no objection, counsel shall attach JAC’s response to their proposed order, labeled as “Exhibit A”.

Applies to

Emergency hearing motion

A motion requesting an emergency hearing must be detailed and state the issues, reasons emergency relief is necessary, and time needed for each party’s presentation.

If a party believes there is a factual basis for setting an emergency hearing, a detailed motion setting forth the following must be filed: (1) the issues to be resolved, (2) the reasons why an emergency hearing is necessary, and (3) the amount of time needed for each party’s presentation.

Applies to

Trial set memorandum

The trial set memorandum must be completed before it is presented to the court.

TRIAL SET MEMORANDUM CV-H (PLEASE COMPLETE BEFORE PRESENTING TO COURT)

Applies to

Notice of hearing

Every notice of hearing must clearly state whether the hearing is in person or via ZOOM.

Notices of hearing must clearly state whether the hearing will occur in person or via ZOOM.

Applies to

Motion for leave

Hearings lasting 30 minutes or more and hearings at any critical stage must be in person; a party seeking remote attendance must file a motion for leave stating the grounds for remote attendance.

All hearings of 30 minutes or more, or for any critical stage of the case, are to occur in-person. Any party seeking to leave to attend such hearings via ZOOM or other remote means must file a motion for leave to attend remotely stating the grounds justifying remote attendance.

Applies to

Proposed order

Every proposed order submitted after a hearing must include a cover letter identifying the proceeding and confirming that the same materials were provided to opposing counsel and unrepresented parties, including their position on the order.

All proposed Orders presented following a hearing MUST INCLUDE A COVER LETTER CLEARLY STATING: 1. What the proposed order is for (including the case number, the motion heard, the date and time, the title of the order, etc.); and 2. That all opposing counsel/unrepresented parties have been provided with the same materials being provided to the Court, and whether the parties agree with the language of the proposed order and whether any party indicated they would submit a competing order.

Applies to

Proposed order

If an unrepresented party does not use e-Portal, the proposed order must be submitted in writing with enough copies for the court and each non-e-Portal party.

If there is an unrepresented party involved in the case not using e-Portal, the proposed Order must be submitted to the Court in writing, with sufficient copies for an original to be entered by the Court and a copy for each party not using e-Portal.

Applies to

Withdrawal order

If a withdrawal motion is granted, the withdrawing attorney must prepare a written order containing the client's last known address, telephone number, and email address.

If the motion is granted, the attorney moving to withdraw shall prepare a written order setting forth the client’s last known address, telephone number, and email address.

Applies to

Motion or formal pleading

Requests for relief by pro se parties must be submitted as a motion or formal pleading and filed with the Clerk of the Court.

Requests for relief must be in the form of a motion or formal pleading and filed with the Clerk of the Court.

Applies to

Motion

Must include

proposed order

A written motion seeking leave to appear remotely and a proposed consent order are required for a non-evidentiary hearing longer than 30 minutes.

counsel must seek leave of Court by filing a written Motion and providing a courtesy copy of the Motion setting forth good cause to grant the Motion pursuant to Rule 2.530, Fla. R Gen. Prac. &. Jud. Admin. and proposed consent Order to the Court via electronic mail.

Applies to

Motion

Must include

proposed order

A written good-cause motion and proposed consent order are required to participate in an evidentiary hearing through Zoom or other communication technology.

counsel must seek leave of Court by filing a written motion setting forth good cause to grant the motion pursuant to Rule 2.530(b)(2), Fla. R Gen. Prac. & Jud. Admin. and providing a courtesy copy of the Motion and a proposed Consent Order to the Court via electronic mail.

Applies to

Notice of hearing

Must include

certificate of conference

A Notice of Hearing must include a certificate of conferral stating whether the conference occurred, documenting any good-faith attempts if it did not, and identifying the conference date, participating attorneys, and results.

Counsel must file with the Notice of Hearing a “Certificate of Conferral Prior to Scheduling the Motion for Hearing” certifying that the meet and confer occurred (or did not occur and setting out the good faith attempts to schedule the conference) and identifying the date of the conference, the names of the participating attorneys, and the specific results obtained.

Applies to

Cover letter

Every proposed order presented after a hearing must include a cover letter identifying the order and confirming that the same materials were provided to opposing counsel or unrepresented parties and stating whether they agree with the proposed order.

ALL PROPOSED ORDERS PRESENTED FOLLOWING HEARING, whether submitted to the Court in writing or via email as contemplated supra, MUST INCLUDE A COVER LETTER INDICATING: 1. What the Order is for (i.e. the case, the motion heard, including date and time, the title of the Order, etc.); and 2. That all opposing counsel/unrepresented parties have been provided with the same materials being provided to the Court, and whether the parties agree with the language of the proposed Order.

Applies to

Cover letter

The cover letter must state that opposing counsel or the unrepresented party received the same materials as the court and whether that party agrees with the proposed order's language.

The letter must state that opposing counsel/unrepresented party has been provided with the same materials being provided to the Court and whether opposing counsel/unrepresented party agrees with the language of the proposed Order.

Applies to

Motion to withdraw

Every motion to withdraw must state the reasons for withdrawal and be set for hearing with proper notice to the client, all parties, and all attorneys.

All Motions to Withdraw must set forth reasons for withdrawal and be set for hearing, with proper notice to the client, in accordance with Fla. R. Gen. Prac. & Jud. Admin. 2.505(f)(l), and all parties/attorneys.

Applies to

Substitution of counsel

Every substitution of counsel, including one within the same firm, must include the client's written signature showing knowledge and consent.

All Substitutions of Counsel, even if they are within the same firm, must include the client’s written signature indicating knowledge and consent.

Applies to

Motion

Must include

certificate of conference

The certifying lawyer must state that an authorized firm lawyer had a substantive, good-faith discussion with opposing counsel before the motion was noticed for hearing, but no agreement was reached.

I HEREBY CERTIFY that a lawyer in my firm with full authority to resolve this matter had a substantive conversation in person, by telephone, or by communication technology with opposing counsel on [enter date] in a good faith effort to resolve this motion before the motion was noticed for hearing but the parties were unable to reach an agreement.

Applies to

Motion

Must include

certificate of conference

As an alternative, counsel may certify three good-faith attempts to contact opposing counsel about resolving the motion without a hearing, together with the date and time of each attempt.

I HEREBY CERTIFY that a lawyer in my firm with full authority to resolve this matter attempted in good faith to contact opposing counsel in person, by telephone, or by communication technology on: 1. ___ (Date)_____________ at ____(Time)________; 2. ___ (Date)_____________ at ____(Time)________; 3. ___ (Date)_____________ at ____(Time)________; to discuss resolution of this motion without a hearing and the lawyer in my firm was unable to speak with opposing counsel.

Applies to

Trial evidence

Trial evidence must include a completed Exhibit List form.

All evidence must be brought in hard copy on the day of trial and must include a completed Exhibit List form.

Applies to

Agreed consent or stipulated order

Agreed, consent, or stipulated orders must state on their face that all interested parties consent or do not object and include the parties' signatures.

Agreed/Consent/Stipulated Orders must show on its face that all interested Parties consent or do not object and will contain signatures of the Parties.

Applies to

Parenting plan

A Parenting Plan in a case involving shared parental responsibility must include language compliant with Florida Statute § 61.13(2)(b)3.a.

In cases where the parties will be exercising shared parental responsibility, the Parenting Plan must include language in compliance with Fla. Stat. 61.13(2)(b)3.a.

Applies to

Notice of hearing

A notice of hearing for a remote appearance must list the judicial Zoom credentials, and every notice of hearing must contain the required ADA notification.

A notice of hearing involving any remote appearance must list the judicial Zoom credentials. All notices of hearing must contain the ADA notification required by Florida Rule of General Practice and Judicial Administration 2.540.

Applies to

Remote appearance request motion

A party seeking a remote appearance must submit a proper motion and obtain Court authorization.

In all cases requesting remote appearances, the party must submit a proper motion and gain authorization from the Court.

Applies to

Proposed order

Every proposed order must include a cover letter certifying unanimous agreement or identifying the parties' disagreement.

All proposed orders must be accompanied by a cover letter either (1) certifying that all parties agree to the order or (2) containing a statement identifying any disagreement of the parties as to the proposed order.

Applies to

Emergency hearing motion

An emergency-hearing motion must state the issues, explain the need for emergency relief, and specify each party's presentation time.

If a party believes there is a factual basis for setting an emergency hearing, a detailed motion setting forth the following must be filed: (1) the issues to be resolved, (2) reasons why an emergency hearing is necessary, and (3) the amount of time needed for each party’s presentation.

Applies to

Emergency hearing motion

An emergency-hearing request must state how much time the hearing will require.

When requesting an emergency hearing, the parties shall inform the Court on how long the hearing shall take to ensure proper time is allotted.

Applies to

Notice for trial or motion to set case for trial

A notice for trial or a Motion to Set the case for trial must be filed to request a trial date.

• Procedure: File a notice for trial to set or Motion to Set the case for trial.

Applies to

Motion

Must include

proposed order

The motion seeking leave to present remote testimony at an evidentiary hearing must include a proposed consent order emailed to the Court.

Should counsel desire to participate in an evidentiary hearing and present testimony through Zoom or other communication technology, regardless of the duration of the hearing, counsel must seek leave of Court by filing a written motion setting forth good cause to grant the motion pursuant to Rule 2.530(b)(2), Fla. R Gen. Prac. & Jud. Admin. and providing a courtesy copy of the Motion and a proposed Consent Order to the Court via electronic mail.

Applies to

Hearing package

Hearing notebooks, legal memorandums or briefs, and hard copies of significant cited authorities must be provided to the Court at least three business days before the hearing, or immediately when the hearing is scheduled within that period.

Any hearing notebooks, legal memorandums or briefs, along with hard copies of the significant cited authorities, must be provided to the Court at least three (3) business days before the hearing, or immediately if the hearing is scheduled within that time period.

Applies to

Notice of motion

Must include

certificate of conference

A notice of hearing on a motion to compel must include a statement certifying compliance with Rule 1.380(a)(2) and acknowledging that the noticed hearing requires the judge's consent to cancel.

The moving party’s notice of hearing on a motion to compel shall include the following statement: Undersigned counsel certifies that he or she: (1) has complied with Fla. R. Civ. P. 1.380(a)(2) by conferring, or attempting to confer, in good faith with the opposing party in an effort to resolve the discovery dispute without court action; and (2) is aware of the provisions in First Amended Administrative Order No. 88-2 that the hearing noticed hereby may not be cancelled by the agreement of the parties or counsel, but only by first obtaining the judge’s consent.

Applies to

Motion

Must include

proposed order

The motion seeking leave to use telephone or Zoom at a non-evidentiary hearing over 30 minutes must include a proposed consent order emailed to the Court.

Should counsel desire to attend a non-evidentiary hearing scheduled for more than thirty (30) minutes via telephone or Zoom, counsel must seek leave of Court by filing a written Motion and providing a courtesy copy of the Motion setting forth good cause to grant the Motion pursuant to Rule 2.530, Fla. R Gen. Prac. &. Jud. Admin. and proposed consent Order to the Court via electronic mail.

Applies to

Discovery motion

Must include

certificate of conference

At the time the motion is filed, the moving party must file a statement certifying the good-faith conference and that counsel could not resolve the dispute.

and shall file with the court at the time of filing of the motion a statement certifying that he or she has so conferred with opposing counsel and that counsel have been unable to resolve the dispute.

Applies to

Notice of hearing

Must include

certificate of conference

Counsel must file a certificate of conferral with the notice of hearing that states whether conferral occurred, documents good-faith attempts if it did not, and identifies the conference date, participating attorneys, and specific results.

Counsel must file with the Notice of Hearing a “Certificate of Conferral Prior to Scheduling the Motion for Hearing” certifying that the meet and confer occurred (or did not occur and setting out the good faith attempts to schedule the conference) and identifying the date of the conference, the names of the participating attorneys, and the specific results obtained.

Applies to

Notice of substitution of counsel

Every substitution of counsel, including a same-firm substitution, must include the client’s written signature acknowledging knowledge and consent.

All Substitutions of Counsel, even if they are within the same firm, must include the client’s written signature indicating knowledge and consent.

Applies to

Proposed order

The filing must include both a PDF cover letter and a proposed order in Word format.

Filer must submit both a cover letter in PDF format and a proposed order in Word format.

Applies to

Conformed order

The order certificate must state “Counsel to mail copies to:” and counsel must mail the conformed order to the parties.

The order’s certificate should reflect “Counsel to mail copies to:” and counsel shall mail copies of the conformed order to the parties.

Applies to

Motion or pleading

Requests for relief must be submitted as a motion or pleading filed with the clerk.

Requests for relief must be in the form of a motion or pleading and filed with the Clerk.

Applies to

Motion

A matter for the court’s attention must be raised by filing the proper motion and copying all parties or counsel.

If you have a matter to bring to the Court’s attention, please file the proper motion with the Clerk of Court and copy all parties and/or counsel in the case with said motion.

Applies to

Pretrial stipulation

The Joint Pre-Trial Stipulation must concisely identify facts remaining to be litigated.

a concise statement of those facts which remain to be litigated;

Applies to

Pretrial stipulation

The Joint Pre-Trial Stipulation must provide a complete witness list, including anticipated impeachment witnesses and each witness’s name and address.

a complete list of witnesses, including anticipated impeachment witnesses, specifying the name and address of each;

Applies to

Pretrial stipulation

The parties must prepare and sign the Joint Pre-Trial Stipulation, file it at the Pre-Trial Conference, and include all eight categories of specified trial-preparation information.

The parties shall cooperate in preparation of the Joint Pre-Trial Stipulation which shall be signed by both signed by the parties or their counsel and filed with the Court at the Pre-Trial Conference. The suggested format for the Joint Pre-Trial Stipulation can be found at the Court’s webpage and shall contain at least the following:

Applies to

Pretrial stipulation

The Joint Pre-Trial Stipulation must concisely state the nature of the action and all claims to be tried for the Court to read to the jury.

a concise factual statement of the nature of the action which shall be read to the jury by the Court to apprise the jury of the nature of the case, all claims of any party to be tried;

Applies to

Pretrial stipulation

The Joint Pre-Trial Stipulation must concisely identify admitted facts that will not require proof at trial.

a concise statement of those facts which are admitted and will not require proof at trial;

Applies to

Pretrial stipulation

The Joint Pre-Trial Stipulation must include an exhibit list with specific objections, following the suggested Trial Exhibit table.

exhibit list including the specific objections to any exhibit. The suggested Trial Exhibit table can be found at the Court’s webpage;

Applies to

Pretrial stipulation

The Joint Pre-Trial Stipulation must state objections to specific portions of video depositions, testimony, or video exhibits that may be offered at trial.

a statement reflecting objections to specific portions of video deposition, testimony, or video exhibits which may be offered at trial; and

Applies to

Trial exhibits

All trial exhibits must be shown to opposing counsel at the Attorney Conference.

All exhibits intended to be offered at trial shall be exhibited to all opposing counsel at the Attorney Conference.

Applies to

Plaintiff retained expert notice

Plaintiff's retained-expert notice must state each expert's identity and address, expertise, expected testimony, facts and opinions, and the grounds supporting each opinion.

No later than [120 DAYS] prior to the Pre-Trial Conference, Plaintiff shall serve on all opposing counsel and file with the Court a Notice containing the following information regarding each retained expert witness who will testify at trial on behalf of Plaintiff: a) the name and address of the expert witness; b) the area(s) of expertise of the witness: c) the subject matter of the expected testimony or the witness; d) the substance of the facts and opinions about which the witness is expected to testify; and e) a summary of the grounds on which each of the opinions of the witness will be based.

Applies to

Defendant expert notice

Each defendant's expert-witness notice must contain the same information required for Plaintiff's retained-expert notice.

No later than [90DAYS] prior to the Pre-Trial Conference, each Defendant shall serve on all other counsel and file with the Court a Notice containing the same information regarding each expert witness who will testify at trial on behalf of that Defendant.

Applies to

Expert disclosure

Treating physicians and non-retained experts who will testify must be included in the disclosure and described with the same information required for retained experts.

The parties shall include each treating physician and non-retained expert witness who will testify at trial as an expert witness in their disclosure and disclose the same information as retained experts.

Applies to

Expert related motion or objection

Expert-related motions and objections must specifically state their grounds and substantial legal arguments and identify the supporting evidence or material relied upon.

Any expert related motions or objections shall state with particularity the grounds upon which they are based and the substantial matters of law to be argued, and shall identify any evidence or supporting material upon which the movant relies.

Applies to

Motion in limine

Every motion in limine must be case specific.

Motions in Limine must be case specific.

Applies to

Motion in limine

A motion in limine must specifically state its grounds and substantial legal arguments and identify the evidence or supporting material relied upon.

The Motion in Limine shall state with particularity the grounds upon which it is based and the substantial matters of law to be argued and shall identify any evidence or supporting material on which the movant relies.

Applies to

Jury instructions

Plaintiff must provide a complete set of proposed jury instructions.

Plaintiff shall provide a complete set of proposed jury instructions.

Applies to

Jury instructions

Defendant must provide only special jury instructions not included in Plaintiff’s submission.

Defendant shall provide only special instructions not included in Plaintiff’s submission.

Applies to

Verdict form

The parties must attempt to agree on and submit one verdict form; if agreement is impossible, each party must submit its own proposed form.

The parties shall seek to agree on a verdict form and submit one agreed form. If the parties cannot agree, each party shall submit its own proposed form.

Applies to

Jury instructions

Proposed instructions and the verdict form must be submitted at the Pretrial Conference in jury-ready form with a face sheet identifying the proposing party and a numbered instruction list; citations may be attached separately but cannot appear on the jury-submitted instructions.

The proposed instructions and verdict form will be submitted to the Court at the Pre-Trial Conference. All instructions will be in a form suitable for submission to the jury with a face sheet which identifies the proposing party and a numbered list of the proposed instructions. A party may attach citations of authority for individual instructions, but such citations shall not be contained on the instructions to be submitted to the jury.

Applies to

Certificate

When an attorney signs Certification B, the attorney’s signature and date are required.

Attorney’s signature:______________________________ Signed on_________________________, 20____

Applies to

Cme request

A request for a compulsory medical examination must specify the examination's time, place, manner, conditions, scope, examiner, and examiner qualifications with some specificity.

Requests for an examination must set forth the time, place, manner, conditions, and scope of the examination as well as the name of, and the qualifications of, the person conducting the examination with some specificity.

Applies to

Cme objection

Objections to a compulsory medical examination must state the specific reasons for the objections.

The objections must state the specific reasons for the objections.

Applies to

Checklist

Must include

local rule certificate

The applicable certification clause must be reviewed and signed before submitting the checklist with the petition.

Please review and sign the applicable certification clause at the end of the checklist prior to submitting it with your Petition.

Applies to

Petition

The petition must be verified and signed by the petitioner.

The Petition is verified and signed by the Petitioner.

Applies to

Petition

The petition must include the decedent's date of death and a legal description of the property, not merely a street address.

The Petition includes decedent’s date of death. The Petition contains a legal description of the property (a street address is insufficient).

Applies to

Proof of notice to AHCA

When notice to creditors is required, the publication period must have expired and proof of notice to AHCA must be filed.

The publication period for the notice to creditors has expired and proof of notice to AHCA has been filed

Applies to

Proposed order

Must include

proposed order

The proposed order must identify the beneficiaries, describe the real property, determine protected homestead status, and direct surrender of the homestead property.

The proposed order reflects title passing to the correct beneficiaries. The proposed order describes the real property and determines whether any of the real property constitutes the protected homestead of the decedent and directs the personal representative/debtors of the decedent to surrender the homestead property.

Applies to

Certification

Must include

local rule certificate

For a represented petitioner, only counsel completes the applicable certification clause; for a pro se petitioner, the petitioner completes it.

If the Petitioner is represented by counsel, only counsel must complete the applicable Certification Clause. If the Petitioners is pro se then the applicable Certification must be completed by the Petitioner.

Applies to

Certification

Must include

local rule certificate

The applicable certification must state that the signer reviewed the required information and that all required information was filed previously or concurrently with the petition.

The undersigned Petitioner☐ (print name)__________________________/Attorney ☐ (print name)_____________________________certifies that he/she has reviewed the information necessary to support the Petition to Determine Homestead. The Petitioner ☐/Attorney ☐ further certifies that all the required information was previously filed or filed concurrently with the Petition.

Applies to

Certificate

Must include

local rule certificate

Certification B must include the petitioner or attorney’s printed name and certification that the information necessary to support the Petition to Determine Homestead has been reviewed.

The undersigned Petitioner☐ (print name)__________________________/Attorney ☐ (print name)_____________________________certifies that he/she has reviewed the information necessary to support the Petition to Determine Homestead.

Applies to

Certificate

If information cannot be submitted, the petitioner or attorney must certify that a diligent search and reasonable effort were made and state the reasons the information could not be submitted.

The Petitioner ☐/Attorney ☐ certifies that, after a diligent search and reasonable effort, the Petitioner ☐/Attorney ☐ was unable to submit the following information for the following reasons:

Applies to

Certificate

The petitioner must sign and date the document.

Petitioner’s signature:______________________________ Signed on_________________________, 20____

Applies to

Cme examination authorization

An examination sought under Rule 1.360(a)(1)(B) must be authorized by a court order or by a written agreement of all parties.

Examinations sought under Fla. R. Civ. P. 1.360(a)(1)(B) must be obtained with an order from this Court, or with a written agreement of all parties.

Applies to

Out of county cme request

An out-of-county examination requires Court approval after an evidentiary hearing and a proper record.

Out of county examinations must be approved by the Court but only after an evidentiary hearing and the proper record having been made.

Applies to

Notice of hearing

Every Notice of Hearing must contain the ADA notification required by Florida Rule of General Practice and Judicial Administration 2.540.

All notices of hearing must contain the ADA notification required by Florida Rule of General Practice and Judicial Administration 2.540.

Applies to

Emergency hearing motion

A motion requesting an emergency hearing must state the issues, reasons emergency relief is necessary, and presentation time needed by each party.

If a party believes there is a factual basis for setting an emergency hearing, a detailed motion setting forth the following must be filed: (1) the issues to be resolved, (2) reasons why an emergency hearing is necessary, and (3) the amount of time needed for each party’s presentation.

Applies to

Stipulation for order of dismissal

Counsel must submit a stipulation for an order of dismissal when notifying the court of a settlement or 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.

Applies to

Cover letter

Each proposed order must have a cover letter certifying unanimous agreement or identifying the parties’ disagreement.

All proposed orders must be accompanied by a cover letter either (1) certifying that all parties agree to the order or (2) containing a statement identifying any disagreement of the parties as to the proposed order.

Applies to

Consent order

A consent order’s caption must include the word “Consent” or “Agreed.”

All consent Orders shall include the word “Consent” or “Agreed” in the caption of the proposed Order.

Applies to

Proposed order cover letter

Each proposed order must have a cover letter that certifies unanimous agreement or identifies the parties' disagreement.

All proposed orders must be accompanied by a cover letter either (1) certifying that all parties agree to the order or (2) containing a statement identifying any disagreement of the parties as to the proposed order.

Applies to

Proposed order

A proposed order entered by consent must include “Consent” or “Agreed” in its caption.

All consent Orders shall include the word “Consent” or “Agreed” in the caption of the proposed Order.

Applies to

Notice of hearing

A notice of hearing must identify all motions and their docket lines, be e-filed and served immediately after hearing time is reserved, include the judge’s Zoom credentials for remote appearances, and contain the required ADA notification.

The Notice of Hearing should list all motion(s) and the docket line of the motion, e-filed and served immediately after reserving hearing time. A notice of hearing involving any remote appearance will list the Judge’s Zoom credentials. All notices of hearing must contain the ADA notification required by Florida Rule of General Practice and Judicial Administration 2.540.

Applies to

Notice of service

A Notice of Service must be filed when the submitting attorney mails proposed orders to unrepresented parties.

The attorney submitting the order is responsible for ensuring copies of the order(s) are mailed to any unrepresented party or parties and a Notice of Service is filed on the case.

Applies to

Emergency motion

A detailed motion for an emergency hearing must identify the issues, explain the need for emergency relief, and state each party’s required presentation time.

If a party believes there is a factual basis for setting an emergency hearing, a detailed motion setting forth the following must be filed: (1) the issues to be resolved, (2) reasons why an emergency hearing is necessary, and (3) the amount of time needed for each party’s presentation.

Applies to

Stipulation for order of dismissal

Upon settlement or dismissal, counsel must immediately notify the Court and submit a stipulation for an order of dismissal; a mediation report alone will not remove the case from the docket.

• Settlement: All counsel shall immediately notify the 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. A copy of the mediation report is not sufficient to remove the case from the docket.

Applies to

Suggestion of bankruptcy

If any party files for federal bankruptcy protection, a Suggestion of Bankruptcy must be filed in the court file.

• Bankruptcy: Should any party file for federal bankruptcy protection, a Suggestion of Bankruptcy MUST be filed in the Court file.

Applies to

Proposed order

Must include

proposed order

A proposed order may not be submitted without a pending request or stipulation for relief, and an agreed order must identify who agreed and include evidence or a detailed explanation of the agreement.

Proposed orders should never be submitted without some request or stipulation for relief being on the docket. Agreed orders should say in them who specifically has agreed to the requested relief. Evidence of the agreement should be submitted with the motion or other request for relief or the motion should detail the specific circumstances of the agreement.

Applies to

Pretrial detention motion

A motion to impose pretrial detention by revoking bail must include evidentiary support, such as a sworn arrest and booking report or a timely request for judicial notice.

Motions to impose pretrial detention by revoking bail must have some evidentiary support, such as attaching a sworn arrest and booking report or filing a timely request for judicial notice.

Applies to

Motion

A motion or other pleading must state its grounds, which will usually include the relief sought, undisputed and disputed pertinent facts, and the constitutional provisions, statutes, rules, or case law authorizing or prohibiting the relief.

Florida Rule of Criminal Procedure 3.190 requires “Each motion or other pleading [to] state the ground or grounds on which it is based.” Stating the “grounds” for a motion will usually entail at least the following: i. What is the relief sought? ii. What are the undisputed facts, or facts that must be taken as true, that are pertinent to granting or denying the relief sought? iii. What are the disputed facts, if any, pertinent to granting or denying the relief sought that must be resolved before the court rules? iv. What constitutional provisions, statutes, rules, or case law authorize or prohibit the relief sought?

Applies to

Plea form

A separate plea form should be completed for each case, and multiple cases should not be consolidated onto one form.

A separate plea form should be filled out for each case a defendant is resolving. Multiple cases should not be consolidated onto one plea form.

Applies to

Plea form

Plea forms are court filings that must be signed by counsel and should receive careful attention to detail.

The plea forms are court filings signed by counsel and should be given the care and attention to detail that all court filings should receive.

Applies to

Plea form

The current felony plea forms available at the stated court website should be used.

Use the current versions of the plea forms found here: https://www.jud4.org/court-administration/felony-plea-forms.

Applies to

Plea form

The plea form’s count and charge box should list only the crimes to which the defendant is pleading guilty.

The count, charge, etc. box should contain only the crimes that the defendant is pleading guilty to.

Applies to

Plea form

The plea form’s fine box should contain only fines currently being assessed.

The fine box should only contain fines that are being assessed.

Applies to

Plea form

Special probation conditions belong in the Probation Conditions section, while the Negotiated Sentence section should contain only the probationary term’s length.

Special conditions of probation should be listed in the Probation Conditions section, not the Negotiated Sentence section. That section should just list the length of the probationary term.

Applies to

Plea form

A sentence involving withholding adjudication of guilt must identify jail time as a special condition of probation.

For sentences involving a withhold of adjudication of guilt, jail time must be a special condition of probation.

Applies to

Plea form

The plea form’s sections concerning costs, restitution, and Marsy’s Law compliance should be completed.

Fill out the parts pertaining to costs, restitution, and Marsy’s Law compliance.

Applies to

Sentencing scoresheet

A scoresheet must be provided to the Court before sentence is imposed, ideally at the beginning of the sentencing hearing.

The Court must be provided with a scoresheet prior to imposition of sentence, Navarro v. State, 416 So. 3d, 1217, 1222-23 (Fla. 5th DCA 2025) (sentencing without a scoresheet for the judge to consider is fundamental error), ideally at the beginning of the sentencing hearing.

Applies to

Notice of hearing

A notice of hearing involving a remote appearance must list the Judge’s Zoom Meeting ID.

A notice of hearing involving any remote appearance will list the Judge’s Zoom Meeting ID.

Applies to

Notice of hearing

Every notice of hearing must contain the ADA notification required by Florida Rule of General Practice and Judicial Administration 2.540.

All notices of hearing should contain the ADA notification required by Florida Rule of General Practice and Judicial Administration 2.540.

Applies to

Motion

Hearings will be set only for motions filed with the Clerk.

Hearings will only be set on motions filed with the Clerk.

Applies to

Motion

A request to appear remotely using communication technology must be made by motion.

Requests to use communication technology for an appearance must be made by motion.

Applies to

Motion

A party seeking an emergency hearing must file a detailed motion stating the issues, reasons for emergency relief, and the time needed for each party’s presentation.

• Requirements: If a party believes there is a factual basis for setting an emergency hearing, a detailed motion setting forth the following must be filed: (1) the issues to be resolved, (2) reasons why an emergency hearing is necessary, and (3) the amount of time needed for each party’s presentation.

Applies to

Pretrial stipulation

If personalty remains unresolved before the final hearing, each party must submit and attach to the pretrial stipulation a list of assets sought, including each asset’s description, ownership interest, encumbrances, and fair market value or present balance.

NOTE: If the issue of personalty is not settled prior to final hearing, each party shall submit to the Court a list of assets sought by each party, stating the specific description of such asset, the nature of the party’s interest, the amount of debt encumbering any asset (i.e., lien balance), and the fair market value or present balance of such asset. ATTACH LIST TO PRE-TRIAL STIPULATION.

Applies to

Financial affidavits

Each party must provide a mandatory, up-to-date financial affidavit as an exhibit.

A. Mandatory UP-TO-DATE Financial Affidavits of each of the parties.

Applies to

Attorney fee statement

A party seeking attorney’s fees at or after final hearing must file a verified statement explaining how time was spent and providing a detailed cost list.

All parties seeking attorney’s fees at the time of final hearing or subsequent thereto must file a verified statement as to the manner of time spent, along with a detailed list of costs.

Applies to

Trial set memorandum

The trial set memorandum must be completed before it is presented to the court.

TRIAL SET MEMORANDUM IN DIVISION FM-G (PLEASE COMPLETE BEFORE PRESENTING TO COURT)

Applies to

Uncontested final hearing requirements

Before an uncontested final hearing, one party must provide a completed Consent Final Judgment checklist, proper proof of Florida residency, and a signed Consent Final Judgment copy.

Prior to an uncontested final hearing, one party must provide the following: (1) a completed checklist for entry of the Consent Final Judgment, (2) proper proof of Florida residency, and (3) a copy of the signed Consent Final Judgment.

Applies to

Pre trial stipulation

If personalty remains unsettled before the final hearing, each party must attach to the pretrial stipulation a list of assets sought, including each asset’s description, the party’s interest, any encumbering debt, and its fair market value or present balance.

If the issue of personalty is not settled prior to final hearing, each party shall submit to the Court a list of assets sought by each party, stating the specific description of such asset, the nature of the party’s interest, the amount of debt encumbering any asset (i.e., lien balance), and the fair market value or present balance of such asset. ATTACH LIST TO PRE-TRIAL STIPULATION.

Applies to

Attorney fees statement

Parties seeking attorney’s fees at or after the final hearing must file a verified statement describing the time spent and a detailed list of costs.

NOTE: All parties seeking attorney’s fees at the time of final hearing or subsequent thereto must file a verified statement as to the manner of time spent, along with a detailed list of costs.

Applies to

Uncontested dissolution checklist

The checklist must be completed before presentation to and the hearing before the Court.

This form must be completed BEFORE presentation to and hearing by the Court.

Applies to

Financial affidavit

Each party must provide a current, up-to-date financial affidavit as a mandatory exhibit.

A. Mandatory UP-TO-DATE Financial Affidavits of each of the parties.

Applies to

Attorney fee statement

A party seeking attorney’s fees at or after the final hearing must file a verified statement describing time spent and a detailed list of costs.

NOTE: All parties seeking attorney’s fees at the time of final hearing or subsequent thereto must file a verified statement as to the manner of time spent, along with a detailed list of costs.

Applies to

Uncontested dissolution checklist

The uncontested dissolution checklist must be completed before the matter is presented to the Court for hearing.

This form must be completed BEFORE presentation to and hearing by the Court.

Applies to

Answer and waiver

An Answer and Waiver must be filed with the Clerk of Court.

Answer and Waiver

Applies to

Financial affidavit

A Financial Affidavit must be filed with the Clerk of Court.

Financial Affidavit

Applies to

Uccjea affidavit

A UCCJEA Affidavit must be filed with the Clerk of Court.

UCCJEA Affidavit

Applies to

Children first in divorce course completion certificate

A course completion certificate for Children First in Divorce must be filed with the Clerk of Court.

Course completion certificate for Children First in Divorce

Applies to

Child support guideline worksheet

A Child Support Guideline Worksheet must be filed with the Clerk of Court.

Child Support Guideline Worksheet

Applies to

Certificate of counsel

The attorney must provide a Certificate of Counsel certifying review of the court file and information and confirming that the required pleadings have been filed with the Clerk of Court.

Certificate of Counsel I, the undersigned attorney, do hereby certify that I have reviewed the above court file and the above information and the required pleadings are filed with the Clerk of Court.

Applies to

Hearing notice

After a hearing time is set, no party may add or notice additional matters for that time without the express consent of all parties.

Once a hearing time is set, no party may add or notice additional matters for that time without the express consent of all parties.

Applies to

Emergency motion

A motion requesting an emergency hearing must state the issues, reasons an emergency hearing is necessary, and the time needed for each party’s presentation.

If a party believes there is a factual basis for setting an emergency hearing, a detailed motion setting forth the following must be filed: (1) the issues to be resolved, (2) reasons why an emergency hearing is necessary, and (3) the amount of time needed for each party’s presentation.

Applies to

Emergency motion

Emergency motions must be verified or sworn by the movant and signed by counsel when applicable.

All such motions must be verified/sworn by the movant & signed by counsel, if applicable.

Applies to

Putting children first completion

Completion of Putting Children First is required in dissolution and paternity actions.

Completion of the Putting Children First is required for Dissolution and Paternity actions.

Applies to

Trial set memoranda

Before the Case Management Conference, each party must email a completed Trial Set Memoranda identifying the desired mediator and trial date.

The parties shall submit a completed Trial Set Memoranda, including the desired mediator and trial date as an e-mail attachment to jennw@coj.net prior to the Case Management Conference.

Applies to

Ex parthe checklist

A fully completed checklist is required before presenting an uncontested dissolution for an ex parte hearing.

All uncontested dissolutions are heard at ex parte and MUST have a checklist fully completed before presenting your case to the Judge.

Applies to

Trial set memorandum

The trial set memorandum must be completed before it is presented to the court.

(Please complete before presenting to court)

Applies to

Motion

Must include

certificate of conference

A Certificate of Conferral complying with Florida Rule of Civil Procedure 1.202 is required for a motion hearing to be set.

To that end, the Court will not set a hearing on motions which do not include the Certificate of Conferral required by Florida Rule of Civil Procedure 1.202.

Applies to

Proposed order

Must include

proposed order

When an unrerepresented party is not using the e-Portal, the proposed order must be submitted in writing with enough copies for the court and each non-e-Portal party.

If there is an unrepresented party involved in the case not using the e-Portal, the proposed Order must be submitted to the Court in writing, with sufficient copies for an original to be entered by the Court and a copy for each party not using e-Portal.

Applies to

Proposed order

Must include

proposed order

The party submitting the proposed order must provide addressed, stamped envelopes for parties not using the e-Portal.

Further, the party presenting the proposed Order, shall be responsible for providing addressed, stamped envelopes for parties not using the e-Portal.

Applies to

Proposed order

Must include

proposed order

The proposed-order service list must include the addresses of every unrepresented party and every party not using the e-Portal.

The proposed Order service list must contain addresses for any unrepresented party or party not using the e-Portal.

Applies to

Proposed order

Must include

proposed order

Every post-hearing proposed order must include a cover letter identifying what the order addresses, confirming that opposing counsel and unrepresented parties received the same materials, and stating whether they agree with the proposed language.

All proposed Orders presented following a hearing MUST INCLUDE A COVER LETTER INDICATING: 1. What the Order is for (i.e., the case, the motion heard, including date and time, the title of the Order, etc.); and 2. That all opposing counsel/unrepresented parties have been provided with the same materials being provided to the Court, and whether the parties agree with the language of the proposed Order.

Applies to

Proposed order

A proposed order submitted through the Florida Courts e-Portal must include a cover letter and a courtesy copy of the related motion, stipulation, or other materials, which must be sent to all opposing counsel or unrepresented parties.

Proposed Orders without a hearing may be submitted to the Court via the Florida Courts e-Portal with a cover letter and courtesy copy of the motion, joint stipulation, etc. related to the proposed Order, which must be copied to all opposing counsel/unrepresented parties.

Applies to

Letter

The cover letter must state that opposing counsel or an unrepresented party received the same materials as the Court, whether the party consents to the requested relief, and if so, whether it agrees with the proposed order language.

The cover letter must state (i) that opposing counsel/unrepresented party has been provided with the same materials being provided to the Court, (ii) whether opposing counsel/unrepresented party consents to the relief requested in the motion and proposed order and, if so, (iii) whether opposing counsel/unrepresented party agrees with the language of the proposed order.

Applies to

Proposed order

Every proposed consent order must include either “Consent” or “Agreed” in its caption.

All consent Orders shall include the word “Consent” or “Agreed” in the caption of the proposed Order.

Applies to

Notice of hearing

The moving party must file the notice of hearing.

4. The moving party is responsible for filing and serving the notice of hearing.

Applies to

Notice of hearing

The notice of hearing submitted to the Court must include the appropriate pleadings and be marked “Uniform Motion Calendar.”

9. At least three business days before the hearing a copy of the notice of hearing, with the appropriate pleading(s) attached, shall be forwarded to the Court, marked "Uniform Motion Calendar.”

Applies to

Notice of hearing

The notice of hearing must certify that counsel attempted to resolve the motion's subject before seeking judicial intervention.

11. Counsel must certify in the notice of hearing and the motion to be heard that counsel has attempted to resolve the subject of the motion prior to seeking judicial intervention.

Applies to

Motion

Must include

certificate of conference

The motion must include a conference certification stating that a conference occurred and whether all or part of the motion is resolved; no hearing will be set without it.

The moving party shall file with the motion a statement certifying that the moving counsel has conferred with opposing counsel or the unrepresented party and stating whether counsel or the unrepresented party agrees on the resolution of all or part of the motion. No hearing will be set on a motion which lacks this statement.

Applies to

Motion

Must include

caption

A motion whose relief is wholly or partly unopposed must identify that status in its caption using an equivalent succinct indication.

If the interested parties agree to all or part of the relief sought in any motion, the caption of the motion shall include the word “unopposed,” “agreed,” or “stipulated” or otherwise succinctly inform the reader that, as to all or part of the requested relief, no opposition exists.

Applies to

Proposed order

A proposed order submitted after a hearing must include a cover letter identifying the order and confirming that opposing counsel or unrepresented parties received the same materials and stating whether they agree with its language.

All proposed Orders presented following a hearing MUST INCLUDE A COVER LETTER INDICATING: 1. What the Order is for (i.e., the case, the motion heard, including date and time, the title of the Order, etc.); and 2. That all opposing counsel/unrepresented parties have been provided with the same materials being provided to the Court, and whether the parties agree with the language of the proposed Order.

Applies to

Proposed order

A no-hearing proposed-order cover letter must confirm that opposing parties received the same materials, state whether they consent to the requested relief, and, if so, whether they agree with the proposed order's language.

The cover letter must state (i) that opposing counsel/unrepresented party has been provided with the same materials being provided to the Court, (ii) whether opposing counsel/unrepresented party consents to the relief requested in the motion and proposed order and, if so, (iii) whether opposing counsel/unrepresented party agrees with the language of the proposed order.

Applies to

Proposed order

The caption of every consent proposed order must include the word “Consent” or “Agreed.”

All consent Orders shall include the word “Consent” or “Agreed” in the caption of the proposed Order.

Applies to

Urgent order email

An urgent-order email must use an “URGENT” subject line containing the case number, case name, and reason for the email.

The email must include the following information: Subject line: URGENT: Case number, case name, and reason for the email (e. g., PENDING SALE; EMERGENCY TEMPORARY GUARDIAN, etc.)

Applies to

Order of referral

An Order of Referral to the General Magistrate must be filed in all guardian advocate and guardianship cases before a hearing will be set.

The Order of Referral to the General Magistrate will be filed for all guardian advocate and guardianship cases. A hearing will not be set until the referral has been filed.

Applies to

Affidavit of heirs

Every probate case must include an affidavit of heirs.

All probate cases must file an affidavit of heirs.

Applies to

Notice of hearing

Attorneys must prepare and file the Notice of Hearing.

Attorneys must prepare and file the Notice of Hearing.

Applies to

Checklist

The checklist requires the attorney’s signature and date.

ATTORNEY’S SIGNATURE DATE

Applies to

Emergency motion

A motion seeking an ex parte hearing without notice must state an adequate reason for withholding notice from the other party.

If seeking an ex parte hearing without notice to the other party, your motion must state an adequate reason why the other party should not be given notice.

Applies to

Emergency verified motion

Emergency verified motions for child pick-up orders must be verified or sworn by the moving party.

Pursuant to Florida Supreme Court Approved Family Law Form 12.941(d), all Emergency Verified Motions for Child Pick-Up Orders must be verified/sworn by the movant.

Applies to

Residency evidence

The checklist requires residency evidence and a copy to be attached.

RESIDENCY EVIDENCE (Check and attach a copy):

Applies to

Guideline child support worksheet

The filer must indicate whether a guideline child support worksheet was filed and, if yes, whether it is attached.

GUIDELINE CHILD SUPPORT WORKSHEET FILED: Yes No N/A; If Yes, attached: Yes No

Applies to

Central governmental depository information form

The checklist requires the Central Governmental Depository Information Form to be completed and filed when applicable.

CENTRAL GOVERNMENTAL DEPOSITORY INFORMATION FORM: Completed and Filed Yes No N/A

Applies to

Financial affidavits

The checklist requires financial affidavits to be filed for the applicable parties.

FINANCIAL AFFIDAVITS FILED: Husband Wife Father Mother N/A

Applies to

Marital settlement agreement

The checklist requires confirmation whether a marital settlement agreement signed by both parties has been filed.

MARITAL SETTLEMENT AGREEMENT SIGNED BY BOTH PARTIES: ______ Yes ______ No N/A

Applies to

Consent final judgment or consent order

The checklist requires confirmation whether a consent final judgment or other consent order signed by both parties has been filed.

CONSENT FINAL JUDGMENT OR OTHER CONSENT ORDER SIGNED BY BOTH PARTIES: Yes No

Applies to

Checklist

The checklist requires the attorney to certify personal review of the court file and that the relevant pleadings and documents are in the file or will be presented with the form.

I, the undersigned attorney, do hereby certify that I have personally reviewed the above court file and that the above relevant pleadings and documents are contained in the court file or will be presented to the Court with this form.

Applies to

Notice of hearing

A notice of hearing involving a remote appearance must include the judge's Zoom credentials.

A notice of hearing involving any remote appearance will list the Judge’s Zoom credentials.

Applies to

Notice of hearing

Every notice of hearing must contain the ADA notification required by Florida Rule of General Practice and Judicial Administration 2.540.

All notices of hearing will contain the ADA notification required by Florida Rule of General Practice and Judicial Administration 2.540.

Applies to

Certificate

When the parties have minor children, both parents must complete an authorized parenting course and file the certificate.

If there are minor children of the parties, both parents must have completed an authorized parenting course and filed the certificate, pursuant to Fla. Stat. §61.21.

Applies to

Parenting plan

A Parenting Plan involving shared parental responsibility must include language complying with Florida Statute 61.13(2)(b)3.a.

In cases where the parties will be exercising shared parental responsibility, the Parenting Plan must include language in compliance with Fla. Stat. 61.13(2)(b)3.a.

Applies to

Remote appearance request

A request to appear remotely using communication technology must be made by motion.

Requests to use communication technology for an appearance must be made by motion.

Applies to

Proposed order

Every proposed order must have a cover letter certifying agreement or identifying the parties' disagreement.

All proposed orders must be accompanied by a cover letter either (1) certifying that all parties agree to the order or (2) containing a statement identifying any disagreement of the parties as to the proposed order.

Applies to

Consent order

The caption of a consent order must include the word “Consent” or “Agreed.”

All consent Orders shall include the word “Consent” or “Agreed” in the caption of the proposed Order

Applies to

Consent order

When applicable, a consent order must contain the parties' signatures.

and, where applicable, contain the signatures of the parties.

Applies to

Proposed order

A proposed order must not be sent until the related motion appears on the docket.

Do not send a Proposed Order until the Motion appears on the docket.

Applies to

Proposed order

A proposed order must identify the title of the particular motion heard.

Always designate the title of the particular motion heard, such as “Order Denying Wife’s Motion to Dismiss,” Etc.

Applies to

Emergency motion

An emergency-hearing motion must state the issues, reasons for emergency relief, time needed for each party's presentation, and supporting law.

If a party believes there is a factual basis for setting an emergency hearing, a detailed motion setting forth the following must be filed on the docket: (1) the issues to be resolved; (2) reasons why an emergency hearing is necessary; (3) the amount of time needed for each party’s presentation; and (4) the law upon which the motion is grounded.

Applies to

Exhibits

A completed Exhibit List form must accompany the exhibits.

A completed Exhibit List form must accompany your exhibits.

Applies to

Hearing request

A short-hearing request must identify opposing counsel, provide the case style and number, include a courtesy copy of the filed motion and docket reference, and state the hearing duration.

The hearing request must include: (1) Opposing counsel on the email chain; (2) The Clay County case style and case number; (3) A courtesy copy of the motion and reference to the docket number. (The Motion must be filed prior to requesting a hearing.) (4) The length of time needed.

Applies to

Certificate of completion

Parties must file the course Certificate of Completion before entry of final judgment; failure to complete the course may delay that judgment.

The parties are required to file the Certificate of Completion in the Court file before the entry of a Final Judgment. Failure to complete the course may result in a delay in entry of the final judgment.

Applies to

Motion

Must include

certificate of conference

A motion to compel or protective-order motion must be accompanied by a statement certifying the good-faith conference and the inability to resolve the dispute without court action.

shall file with the Court at the time of filing the motion, a statement certifying that the movant, in good faith, has conferred with the opposing person or party, and that they have been unable to resolve the dispute without court action.

Applies to

Trial set memo

When setting a case for trial, the parties must complete and submit a Trial Set Memo containing docket numbers to the judicial assistant.

The parties are to complete and submit a Trial Set Memo to the Judicial Assistant, complete with docket numbers, when setting trial.

Applies to

Relevant filings

Division forms must be used for all relevant filings.

• Usage: Division forms must be used for all relevant filings.

Applies to

Pretrial stipulation

If personalty remains unresolved before the final hearing, each party must submit and attach to the pretrial stipulation a list of assets sought, including each asset’s description, the party’s interest, any encumbering debt, and the asset’s fair market value or present balance.

NOTE: If the issue of personalty is not settled prior to final hearing, each party shall submit to the Court a list of assets sought by each party, stating the specific description of such asset, the nature of the party’s interest, the amount of debt encumbering any asset (i.e., lien balance), and the fair market value or present balance of such asset. ATTACH LIST TO PRE- TRIAL STIPULATION.

Applies to

Attorney fee statement

Parties seeking attorney’s fees at or after the final hearing must file a verified statement describing how their time was spent.

NOTE: All parties seeking attorney’s fees at the time of final hearing or subsequent thereto must file a verified statement as to the manner of time spent, along with a detailed list of costs.

Applies to

Exhibit list

The parties' up-to-date financial affidavits are mandatory exhibits.

A. Mandatory UP-TO-DATE Financial Affidavits of each of the parties.

Applies to

Attorney fees statement

A party seeking attorney’s fees at or after the final hearing must file a verified statement describing the manner of time spent and a detailed list of costs.

All parties seeking attorney’s fees at the time of final hearing or subsequent thereto must file a verified statement as to the manner of time spent, along with a detailed list of costs.

Applies to

Motion

A motion requesting an emergency hearing must be detailed and state the issues, reasons emergency relief is necessary, and time needed for each party’s presentation.

• Requirements: If a party believes there is a factual basis for setting an emergency hearing, a detailed motion setting forth the following must be filed: (1) the issues to be resolved, (2) the reasons why an emergency hearing is necessary, and (3) the amount of time needed for each party’s presentation.

Applies to

Proposed order

When submitting a proposed order for a motion to which JAC has no objection, counsel must attach JAC’s response as Exhibit A.

• JAC Proposed Orders: When counsel is submitting a proposed order related to a motion to which JAC has no objection, counsel shall attach JAC’s response to their proposed order, labeled as “Exhibit A”.

Applies to

Completed checklist

Must include

local rule certificate

The attorney must certify personal review of the court file and that the relevant pleadings and documents are in the file or will be presented with the form.

I, the undersigned attorney, do hereby certify that I have personally reviewed the above court file and that the above relevant pleadings and documents are contained in the court file or will be presented to the Court with this form.

Applies to

Trial set memorandum

For a Motion to Set hearing, both counsel and parties must complete the Trial Set Memorandum and email it to the Judicial Assistant at least one business day before the hearing date.

Prior to the hearing for a Motion to Set, a Trial Set Memorandum should be completed by both counsel/parties then emailed to the JA at least one (1) business day before the scheduled date.

Applies to

Financial affidavit

Financial affidavits on form 12.902(b) or 12.902(c) must be filed under Florida Family Law Rule 12.285.

Financial Affidavits, Florida Family Law Rules of Procedure form 12.902(b) or (c), shall be filed in accordance with Florida Family Law Rule of Procedure 12.285.

Applies to

Proposed parenting plan

Each party in a time-sharing case must file and email a proposed parenting plan at least three business days before the hearing.

If this is a case involving time sharing, each party shall file a proposed parenting plan and email a copy in Word format to astrickland@coj.net at least three (3) business days in advance of the hearing. The proposed parenting plan should also be included as an exhibit.

Applies to

Email address designation

Every unrepresented party must designate an email address with the clerk and register for portal email service if not already registered.

All unrepresented parties shall file a designation of email address with the Clerk of Court and register for email service with the Florida Court’s E-filing Portal at www.myflcourtacess.com forthwith, if they have not already done so.

Applies to

Notice of in person appearance

Parties seeking an in-person appearance must notify the clerk at least three business days before the hearing.

However, Zoom will be the default for scheduled hearings, unless the parties file notice with the Clerk of Court that at least one (1) party intends to appear in person at least three (3) business days before the hearing.

Applies to

Consent final judgment hearing submission

Before the final hearing in an uncontested dissolution case, one party must provide a completed Consent Final Judgment checklist, proof of Florida residency, and a signed Consent Final Judgment.

Prior to a final hearing in an uncontested dissolution of marriage case, one party must provide the following: (1) a completed checklist for entry of the Consent Final Judgment, (2) proper proof of Florida residency, and (3) a copy of the signed Consent Final Judgment.

Applies to

Asset list

If personal-property issues remain unresolved before the final hearing, each party must submit an asset list describing each asset, the party's interest, any lien balance, and the asset's fair market value or present balance.

If the issue of personal property is not settled prior to final hearing, each party shall submit to the Court a list of assets sought by each party stating the specific description of such asset, the nature of the party’s ===== PAGE 4 ===== interest, the amount of the debt encumbering any asset (i.e., lien balance), and the fair market value or present balance of such asset.

Applies to

Financial affidavit

Each party must provide a financial affidavit as a mandatory exhibit.

17. Exhibits: A. Mandatory financial affidavits of each of the parties.

Applies to

Attorney fee statement

Parties seeking attorney’s fees at or after the final hearing must file verified statements describing the time spent and a detailed list of costs.

NOTE: All parties seeking attorney’s fees at the time of the final hearing or subsequent thereto must file verified statements as to the manner and time spent, along with a detailed list of costs.

Applies to

Attorney fees statement

Parties seeking attorney’s fees at or after the final hearing must file a verified statement describing the manner of time spent and a detailed list of costs.

NOTE: All parties seeking attorney’s fees at the time of final hearing or subsequent thereto must file a verified statement as to the manner of time spent, along with a detailed list of costs.

Applies to

Default judgment hearing submission

Before a default final hearing, the party seeking default judgment must have filed either proof of service or an affidavit of diligent search.

The party seeking the default judgment must have filed proof of service or an affidavit of diligent search prior to the hearing.

Applies to

Publication

A publication in a dissolution or paternity case must include the prescribed affidavit of diligent search and proof of searches.

publication must include an affidavit of diligent search, pursuant to Family Law Form 12.913(b) (for dissolution cases) or 12.913(c) (for paternity cases) with proof of searches.

Applies to

Notice of contempt motion

Notice for a motion seeking to hold an opposing party in contempt must contain the quoted bodily-attachment warning.

Pursuant to Rule 12.615(b), the notice must contain the following language: “FAILURE TO APPEAR AT THE HEARING MAY RESULT IN THE COURT ISSUING A WRIT OF BODILY ATTACHMENT FOR YOUR ARREST. IF YOU ARE ARRESTED, YOU MAY BE HELD IN JAIL UP TO 48 HOURS BEFORE A HEARING IS HELD.”

Applies to

Notice of hearing

Every notice of hearing must contain the ADA notification required by Florida Rule of General Practice and Judicial Administration 2.540.

All notices of hearing will contain the ADA notification required by Florida Rule of General Practice and Judicial Administration 2.540.

Applies to

Trial set memorandum

The parties must email the completed Trial Set Memorandum to the Judicial Assistant as an attachment at least 24 hours before the ex parte hearing.

The parties shall complete the form, and submit it as an e-mail attachment to the Judicial Assistant at least 24 hours prior to the ex-parte hearing.

Applies to

Proposed order

A proposed order must include a cover letter that either certifies unanimous agreement or identifies any disagreement.

All proposed Orders must be accompanied by a cover letter either (1) certifying that all parties agree to the order or (2) containing a statement identifying any disagreement of the parties as to the proposed Order.

Applies to

Proposed order

A consent order must include “Consent” or “Agreed” in its caption.

All consent Orders shall include the word “Consent” or “Agreed” in the caption of the proposed Order.

Applies to

Relevant filings

Division forms are mandatory for all relevant filings.

• Usage: Division forms must be used for all relevant filings.

Applies to

Emergency motion

A motion requesting an emergency hearing must state the issues, reasons emergency relief is necessary, and time needed for each party’s presentation.

If a party believes there is a factual basis for setting an emergency hearing, a detailed motion setting forth the following must be filed: (1) the issues to be resolved, (2) reasons why an emergency hearing is necessary, and (3) the amount of time needed for each party’s presentation.

Applies to

Emergency motion

A request for an ex parte hearing without notice must state an adequate reason for withholding notice from the other party.

If seeking an ex parte hearing without notice of hearing, you must state an adequate reason why the other party should not be given notice.

Applies to

Emergency hearing motion

A request for an emergency hearing must be made by a detailed motion stating the issues, the reasons emergency relief is necessary, and the time needed for each party's presentation.

If a party believes there is a factual basis for setting an emergency hearing, a detailed motion setting forth the following must be filed: (1) the issues to be resolved, (2) reasons why an emergency hearing is necessary, and (3) the amount of time needed for each party’s presentation.

Applies to

Emergency hearing motion

An emergency motion must be verified or sworn by the moving party and signed by counsel when the party is represented.

All such motions must be verified/sworn by the movant & signed by counsel, if applicable.

Applies to

Relevant filings

The division's forms are mandatory for every filing to which they apply.

Division forms must be used for all relevant filings.

Applies to

Certificate of counsel

An attorney must provide a Certificate of Counsel certifying review of the court file and information and confirming that the required pleadings are filed with the Clerk of Court.

Certificate of Counsel I, the undersigned attorney, do hereby certify that I have reviewed the above court file and the above information and the required pleadings are filed with the Clerk of Court.

Applies to

Pretrial stipulation

The pretrial stipulation must include a guideline worksheet for child support.

12. Child Support (Attach guideline worksheet):

Applies to

Pretrial stipulation

When the time-sharing structure is in controversy, a proposed parenting plan must be attached to the pretrial stipulation.

Indicate requested structure by each party, if in controversy (attach proposed parenting plan):

Applies to

Pretrial stipulation

If personalty remains unresolved before the final hearing, each party must submit and attach a list of contested assets containing the specified asset descriptions, ownership interests, encumbrances, and values or balances.

NOTE: If the issue of personalty is not settled prior to final hearing, each party shall submit to the Court a list of assets sought by each party, stating the specific description of such asset, the nature of the party’s interest, the amount of debt encumbering any asset (i.e., lien balance), and the fair market value or present balance of such asset. ATTACH LIST TO PRE-TRIAL STIPULATION.

Applies to

Financial affidavit

The pretrial stipulation must include an up-to-date financial affidavit from each party.

20. Exhibits: A. Mandatory UP-TO-DATE Financial Affidavits of each of the parties.

Applies to

Attorney fees statement

A party seeking attorney’s fees at or after the final hearing must file a verified statement describing time spent and a detailed list of costs.

NOTE: All parties seeking attorney’s fees at the time of final hearing or subsequent thereto must file a verified statement as to the manner of time spent, along with a detailed list of costs.

Applies to

Pretrial stipulation

If personal-property issues remain unresolved before the final hearing, each party must submit and attach to the pretrial stipulation a list describing each disputed asset, the party's interest, any lien balance, and the asset's fair market value or present balance.

NOTE: If the issue of personalty is not settled prior to final hearing, each party shall submit to the Court a list of assets sought by each party, stating the specific description of such asset, the nature of the party’s interest, the amount of debt encumbering any asset (i.e., lien balance), and the fair market value or present balance of such asset. ATTACH LIST TO PRE-TRIAL STIPULATION.

Applies to

Uncontested dissolution checklist

The uncontested dissolution of marriage checklist must be completed before presentation to and the hearing by the Court.

This form must be completed BEFORE presentation to and hearing by the Court.

Applies to

Uncontested dissolution filing

The listed pleadings and supporting documents must be filed with the Clerk of Court for an uncontested dissolution of marriage.

Have the following documents been filed with the Clerk of Court? Husband Wife N/A No Children Answer and Waiver Financial Affidavit UCCJEA Affidavit Course completion certificate for Children First in Divorce Child Support Guideline Worksheet

Applies to

Certificate of counsel

An attorney must provide a Certificate of Counsel certifying review of the court file and information and confirming that the required pleadings are filed with the Clerk of Court.

Certificate of Counsel I, the undersigned attorney, do hereby certify that I have reviewed the above court file and the above information and the required pleadings are filed with the Clerk of Court.

Applies to

Sentencing requirement waiver form

The defendant must authorize the attorney to admit violations of probation or community control.

I, ______________________________ have authorized my attorney to admit that I have violated the following conditions of Probation/Community Control:

Applies to

Sentencing requirement waiver form

The form must identify the violated condition and state whether it is general or special.

Directions: Specifically List the Condition and Specify whether the Condition is a General or Special Condition.

Applies to

Sentencing requirement waiver form

The defendant must initial an acknowledgment authorizing the attorney to admit the allegations.

The Defendant Initials acknowledge that the attorney is authorized to admit the allegations.

Applies to

Sentencing requirement waiver form

The defendant must initial an acknowledgment that the attorney discussed and investigated the violation allegations and answered the defendant's questions.

The Defendant’s initials acknowledge that the attorney has discussed the violation allegation(s), investigated the allegations to the Defendant’s satisfaction, and answered all questions.

Applies to

Sentencing requirement waiver form

The defendant must initial an acknowledgment that section 948.08 was reviewed with counsel and was read to or by the defendant before authorization.

Before I authorized my attorney to admit that I violated Probation/Community Control, I reviewed section 948.08, Florida Statutes, with my attorney. My attorney has read the statute to me, or I have read it. _______________ (Defendant’s Initials)

Applies to

Sentencing requirement waiver form

The form must identify a listed crime or acknowledge a previous conviction for a qualifying offense.

I understand that the following crime is listed in the statute or I acknowledge that I have a previous conviction for a qualifying offense.

Applies to

Sentencing requirement waiver form

The defendant must initial an acknowledgment of the right to have the State prove eligibility and the court's duty to determine whether the defendant poses a danger to the community.

I understand that I am entitled to have the State prove my eligibility and the Court must make a determination if I pose a danger to the community or not. ______________ (Defendant’s Initials)

Applies to

Sentencing requirement waiver form

The defendant must acknowledge that the admission permits the court to impose the statutory sentence without further evidence or findings.

Based on my admission, the Court can impose the sentence pursuant to the Florida Statute as outlined in my plea agreement without any further evidence or Court findings.

Applies to

Sentencing requirement waiver form

The defendant must acknowledge having sufficient time to review the form and asking counsel all necessary questions before making the legal decision.

I have had sufficient time to all matters in this form with my attorney and I have asked my attorney all the questions necessary to make this legal decision.

Applies to

Sentencing requirement waiver form

The court must find that the defendant was informed, knowingly and voluntarily waived his rights, and freely and voluntarily made the waiver before accepting it.

The Court finds that the Defendant has been fully informed of the waiver and its sentencing consequences. The Court also finds that the Defendant has voluntarily and knowingly waived his rights with a clear understanding of the legal implications. The Court accepts the waiver as being freely and voluntarily made by the Defendant.

Applies to

Correspondence

Correspondence requesting an emergency calendar change must clearly identify itself as an “Emergency Request.”

If the request is an Emergency Request, a correspondence with Ms. Wilk SHALL clearly state that it is an “Emergency Request.”

Applies to

Plea form

All sex case pleas must be in writing, and the appropriate plea forms must be completed for court review.

All sex case pleas must be in writing and the appropriate plea forms must be completed for the Court to review.

Applies to

Firearm enhancement factual finding waiver form

The firearm-enhancement waiver form must list only crimes qualifying under section 775.087, Florida Statutes.

Directions: List only the crimes that qualify under section 775.087, Florida Statutes.

Applies to

Firearm enhancement factual finding waiver form

The defendant must provide initials acknowledging the attorney's discussion of the factual-finding requirements and applicable law.

The Defendant’s initials acknowledge that the attorney has discussed the requirements of the factual findings and the law .

Applies to

Email communication

An email subject line must state the case number, case name, and relevant matter.

The subject line must contain the case number, case name, and relevant matter (e.g., 2025 CA 001234 – ABC v. 123 - 2-Hour Hearing Requested.).

Applies to

Notice of hearing

A Notice of Hearing must identify each motion and its docket line and must be e-filed and served immediately after hearing time is reserved.

The Notice of Hearing should list all motion(s) and the docket line of the motion, e-filed and served immediately after reserving hearing time.

Applies to

Motion to set case for trial

A Motion to Set Case for Trial and a completed Trial Set Memorandum are required to set a case for trial.

(1) File a Motion to Set Case for Trial (whether jury or non-jury) when case is at issue. (2) Complete a Trial Set Memorandum.

Applies to

Proposed order

Every proposed order submitted after a hearing must include a cover letter.

ALL PROPOSED ORDERS PRESENTED FOLLOWING HEARING, whether submitted to the Court in writing or via email as contemplated supra, MUST INCLUDE A COVER LETTER INDICATING:

Applies to

Proposed order

A proposed order submitted without a hearing must include a cover letter copied to all opposing counsel and unrepresented parties.

Proposed Orders without a hearing may be submitted to the Court with a cover letter, which must be copied to all opposing counsel/unrepresented parties.

Applies to

Proposed order

Every consent proposed order must include the word “Consent” or “Agreed” in its caption.

All consent Orders shall include the word “Consent” or “Agreed” in the caption of the proposed Order.

Applies to

Notice of hearing

A Notice of Hearing involving a remote appearance must list the judge’s Zoom credentials.

A notice of hearing involving any remote appearance will list the Judge’s Zoom credentials.

Applies to

Notice of hearing

Every Notice of Hearing must include the ADA notification required by Florida Rule of General Practice and Judicial Administration 2.540.

All notices of hearing must contain the ADA notification required by Florida Rule of General Practice and Judicial Administration 2.540.

Applies to

Proposed order

Every proposed order must include a cover letter that either certifies unanimous agreement or identifies the parties’ disagreements concerning the order.

All proposed orders must be accompanied by a cover letter either (1) certifying that all parties agree to the order or (2) containing a statement identifying any disagreement of the parties as to the proposed order.

Applies to

Consent order

A proposed consent order must include either “Consent” or “Agreed” in its caption.

All consent Orders shall include the word “Consent” or “Agreed” in the caption of the proposed Order.