Court Rules

Eleventh Judicial Circuit of Florida, Miami-Dade County Document Filing Requirements

912 rules from official source documents

Rules 451 to 500, page 10 of 19

Required elements, certificates, and structural requirements for court documents.

CRITICAL

Applies to
Motion to disqualify

Motions to disqualify must follow the procedures in the Administrative Memorandum on Motions to Disqualify.

Motions to Disqualify must follow the procedures laid out in the Administrative Memorandum on Motions to Disqualify.

Judge Michaelle Gonzalez-Paulson

CRITICAL

Applies to
Emergency motion

Emergency motions must include a statement that opposing counsel was notified in an attempt to resolve the matter amicably.

Emergency Motions must be uploaded via CourtMAP once filed and MUST contain a statement indicating that opposing counsel has been notified in an attempt to resolve the matter in an amicable manner.

Judge Michaelle Gonzalez-Paulson

CRITICAL

Applies to
Proposed order

Proposed order titles must include the full name of the motion, and agreed orders must use the Agreed Order option in CourtMAP.

The Title of the Proposed Order should include the full name of the Motion at issue. If the order is an Agreed Order, please utilize the "Agreed Order" option when submitting via courtMAP.

Judge Michaelle Gonzalez-Paulson

CRITICAL

Applies to
Proposed order

Orders must be complete with no blanks; incomplete orders will be rejected and must be resubmitted.

Orders must contain all information required (i.e., no blanks shall be left). Incomplete orders will be rejected, and you will be asked to resubmit the proposed order with the complete information.

Judge Michaelle Gonzalez-Paulson

CRITICAL

Applies to
Proposed order

Proposed orders that do not comply with Administrative Order 22-02 will be rejected.

PLEASE NOTE: AS OF NOVEMBER 15, 2022, ANY PROPOSED ORDER THAT DOES NOT COMPLY WITH THE REQUIREMENTS OF ADMINISTRATIVE ORDER 22-02 WILL BE REJECTED

Judge Michaelle Gonzalez-Paulson

CRITICAL

Applies to
Ex parte motion to compel

Ex-parte motions to compel must comply with AO 06-09 (7-day wait) and state the date discovery was served and the date the motion was filed.

Ex-parte motions to compel (including both discovery and attorney fee order compliance) MUST COMPLY WITH Administrative Order 06-09, including the requirement of waiting 7 days, and MUST reflect the date discovery was served (date or docket #), and when the motion to compel was filed (date or docket #).

Judge Michaelle Gonzalez-Paulson

CRITICAL

Applies to
Order of good cause

Do not submit orders of good cause; the court generates them after reviewing the docket and a timely affidavit.

DO NOT SUBMIT ORDERS OF GOOD CAUSE, THE COURT WILL GENERATE THEM UPON REVIEW OF THE DOCKET AND AN AFFIDAVIT OF GOOD CAUSE TIMELY FILED.

Judge Michaelle Gonzalez-Paulson

CRITICAL

Applies to
Proposed order
Must include
case number

All proposed orders submitted by counsel must include the docket index number (or e-filing number and date filed) and the full name of the motion.

PLEASE NOTE: Administrative Order 22-02 (linked on this page) requires ALL proposed orders submitted by counsel include the following: Docket Index Number: _______________________ Or E-filing Number _______________ Date Filed: ______________________ Full Name of Motion: ___________________________________________

Judge Michaelle Gonzalez-Paulson

CRITICAL

Applies to
Proposed order

Underlying documents must be attached as Supporting Documents with proposed orders or the order may be rejected.

Please submit the relevant underlying document(s) as "Supporting Documents" with the Proposed Order (for example, settlement agreement, stipulation for substitution of counsel, etc.). Because of docketing delays, failure to do so may result in your proposed order being rejected and you will be asked to resubmit the the relevant documents attached.

Judge Michaelle Gonzalez-Paulson

CRITICAL

Applies to
Proposed order

Proposed orders must be complete with no blanks; incomplete orders will be rejected.

Orders must contain all information required (i.e., no blanks shall be left). Incomplete orders will be rejected and you will be asked to resubmit the proposed order with the complete information.

Judge Michaelle Gonzalez-Paulson

CRITICAL

Applies to
Notice of hearing

Parties must prepare and file their own Notice of Hearing with Zoom instructions or courtroom address.

Once approved, you will receive a Notice of Hearing directly from the Court. If you did not receive the Notice of Hearing, please communicate with the Clerk of Court's office and confirm you are on the service list. You still need to prepare your own NOH with proper Zoom instructions OR proper address and courtroom and file it with the Clerk. If your notice is rejected, an explanation will be given in the Comment section.

Judge Michaelle Gonzalez-Paulson

CRITICAL

Applies to
Agreed amended case management order

Agreed amended CMOs must use the required form order and space amended deadlines like the original CMO.

Agreed Amended Case Management Order MUST use the form order linked below. Any other format will be rejected. Additionally, the amended deadlines must be spaced out just as the original CMO's deadlines (e.g., hearings on MSJs must be heard at least 30 days prior to the trial readiness date).

Judge Michaelle Gonzalez-Paulson

CRITICAL

Applies to
Notice of hearing

The setting party is responsible for filing the Notice of Hearing on the docket and should include the Court's universal Zoom link; the Court will not issue a Notice for Motion Calendars and no Zoom link will be sent out.

The setting party is responsible for filing the Notice of Hearing on the docket and should include the Court's universal Zoom link; the Court will not issue a Notice for Motion Calendars and no Zoom link will be sent out.

Judge Michaelle Gonzalez-Paulson

CRITICAL

Applies to
Emergency motion

Emergency motions must certify that the matter is a true emergency that cannot wait for the motion calendar.

1. Your motion must contain a certification that the matter is a true Emergency and cannot wait to be heard during a motion calendar.

Judge Michaelle Gonzalez-Paulson

CRITICAL

Applies to
Motion for extension of time

Motions for extension of time must state the timeframe of the extension requested.

Motions for Extensions of Time must include a timeframe for the requested extension.

Judge Michaelle Gonzalez-Paulson

CRITICALCivil cases

Applies to
Request for electronic appearance

Requests for electronic appearance must be made in writing via a filed motion or email in urgent circumstances and must include all attorneys of record.

A request in writing, made by a duly filed motion or, in urgent circumstances, by email to the Court, will be the only request that this Court may consider and/or grant. All attorneys of record on the case must be included and/or copied on a request for an electronic appearance by a party, witness or attorney.

Judge Michelle Alvarez Barakat

CRITICALCivil cases

Applies to
Request for electronic appearance

Oral (ora tenus) requests for electronic appearances are not considered.

No ora tenus requests for an electronic appearance will be considered.

Judge Michelle Alvarez Barakat

CRITICALCivil cases

Applies to
Request for electronic appearance

Requests must state grounds for the electronic appearance but exclude medical/personal details, providing only the general reason why in-person appearance is difficult or burdensome.

The Court requires that the grounds for the electronic appearance be provided. However, any medical condition, diagnosis or other personal type of information shall not be included. Instead, only the general concern or reason why and in-person appearance is difficult or burdensome shall be set forth in written request.

Judge Michelle Alvarez Barakat

CRITICALCivil cases

Applies to
Motion for clarification

Parties seeking clarification, modification, exception, or waiver must file, serve, and notice a motion for clarification for a timely hearing.

Should any party need clarification, or a modification, exception, and/or waiver of the obligations below, a motion for clarification must be filed, served, and noticed for a timely hearing.

Judge Michelle Alvarez Barakat

CRITICALCriminal cases

Applies to
Waiver of credit for time served

When a defendant waives any amount of credit for time served, defense counsel must complete a waiver form (available from the Clerk) and obtain the defendant's signature.

If the defendant is waiving any amount of credit for time served, Defense Counsel must fill out a waiver form (available from the Clerk) and have the defendant sign it.

Judge Michelle Delancy

CRITICALCriminal cases

Applies to
Jac motion to declare defendant indigent for costs
Must include
proposed order

JAC indigency motions must be submitted to chambers with supporting documentation, JAC's response, and a proposed order; the Court may rule without a hearing unless JAC requests one or the judge has concerns.

JAC MOTIONS: Submit the Motion to have Defendant Declared Indigent for Costs along with supporting documentation, JAC's response, and a proposed order, to Chambers. If JAC does not request a hearing, the Court may enter the proposed order without a hearing after reviewing the documents. If JAC requests a hearing, or if Judge Delancy has concerns after reviewing the Motion and supporting documentation, the judicial assistant will set the Motion on calendar for hearing.

Judge Michelle Delancy

CRITICAL

Applies to
Virtual appearance

Anyone appearing virtually before Judge Urbistondo must comply with the Standing Order on Virtual Court Appearances.

ANY INDIVIDUAL APPEARING VIRTUALLY FOR COURT BEFORE JUDGE URBISTONDO, WHETHER A PARTY, INCLUDING PRO SE, OR SELF-REPRESENTED, ATTORNEY, WITNESS, OR FRIEND/FAMILY MEMBER OF A DEFENDANT, MEDIA PERSONNEL OR OBSERVER, MUST COMPLY WITH THE RULES OUTLINED IN "Judge URBISTONDO'S STANDING ORDER ON VIRTUAL COURT APPEARANCES" IN THE DOCUMENTS SECTION OF THIS PAGE.

Judge Michelle Urbistondo

CRITICALCivil cases

Applies to
Agreed order

The court will not accept agreed orders that continue cases or change trial deadlines.

THE COURT DOES NOT ACCEPT AGREED ORDERS CONTINUING CASES, OR CHANGING TRIAL DEADLINES.

Judge Michelle Urbistondo

CRITICALCivil cases

Applies to
Notice of hearing

A notice of hearing must include the division Zoom meeting ID.

The notice of hearing must include the division zoom meeting ID.

Judge Michelle Urbistondo

CRITICALCivil cases

Applies to
Agreed order

An agreed order must include the opposing party’s written stipulation as a supporting document or it will be rejected.

Agreed Orders shall include as a supporting document the stipulation of the opposing party in writing or the Order will be rejected.

Judge Michelle Urbistondo

CRITICALCivil cases

Applies to
Motion calendar request

The notice of hearing and motion must be filed with the Clerk to add a matter to the Motion Calendar.

In order for your matter to be added to the Judge's Motion Calendar, the notice of hearing and motions(s) MUST be filed with the Clerk.

Judge Michelle Urbistondo

CRITICALCivil cases

Applies to
Notice of hearing

File all motions with the Clerk before setting a hearing date and file an additional Notice of Hearing that includes Zoom instructions.

All Motions must be filed with the Clerks' office prior to setting a hearing date and you are required to do an additional Notice of Hearing INLCUDING THE ZOOM INSTRUCTIONS.

Judge Michelle Urbistondo

CRITICALCivil cases

Applies to
Special set hearing request

Special sets may not exceed one hour, and doubling time slots is prohibited.

Judge Urbistondo does NOT allow more than 1 hour for special sets and doubling time slots is prohibited.

Judge Michelle Urbistondo

CRITICAL

Applies to
Notice of trial

Trial notices must contain all attorneys' names, phone numbers, and email addresses.

Notice must contain all Attorneys names, phone numbers and e-mail addresses.

Judge Miesha Darrough

CRITICAL

Applies to
Notice of trial

Trial notices must identify which party each attorney represents and how many hours/days are needed for trial.

The Notice must also identify who each Attorney represents, Plaintiff(s) or Defendant(s) and how many hours/days are needed.

Judge Miesha Darrough

CRITICAL

Applies to
Courtmap account

Accurate email addresses and phone numbers must be provided so parties receive documents and case updates.

Accurate email addresses and phone numbers must be provided to ensure receipt of documents and case updates

Judge Miesha Darrough

CRITICAL

Applies to
Special set request

Special set requests must include the date the motion was filed or the docket index number, or the request may be rejected.

Special Set dates are available on courtMAP. When requesting a Special Set, include the date the motion was filed or the docket index number, or the request may be rejected.

Judge Miesha Darrough

CRITICAL

Applies to
Cover letter

The cover letter accompanying an order must state the date and time of the hearing, the judge's ruling, the title of the motion heard, and whether the parties agree on the proposed order.

Your cover letter must include the date and time when your hearing took place, the judge's ruling on that date, the title of the motion heard, and if the parties agree on the proposed order.

Judge Migna Sanchez-Llorens

CRITICAL

Applies to
Notice of readiness

A copy of the filed notice of readiness must be submitted under supporting documents for the matter to be set for trial.

Submit a copy of the filed notice of readiness (under supporting documents) in order for the matter to be set for trial.

Judge Migna Sanchez-Llorens

CRITICAL

Applies to
Exhibit list

Each side must submit an exhibit list identifying each exhibit number/letter with a brief description, together with all exhibits submitted separately.

2. Submit to the e-Portal, in the manner detailed below, an Exhibit List, containing the exhibit number/letter, with the corresponding brief description of the exhibit, and all exhibits separately.

Judge Migna Sanchez-Llorens

CRITICAL

Applies to
Special set request form

Special set hearing requests require a completely filled out Special Sets Request Form and a copy of the motion to be heard.

Special set hearing requests require a completely filled out Special Sets Request Form and a copy of the motion to be heard.

Judge Migna Sanchez-Llorens

CRITICAL

Applies to
Unified scheduling order

Counsel must file a unified scheduling order in all cases using the court's template.

COUNSEL SHALL FILE A UNIFIED SCHEDULING ORDER ON ALL CASES (REFER TO TEMPLATE LOCATED UNDER THE "PROPOSED ORDERS" IN THIS WEBSITE.

Judge Migna Sanchez-Llorens

CRITICAL

Applies to
Scheduling order

When submitting the scheduling order in CourtMAP, parties must select 'Generic Order' and use 'Order on Case Management Plan' as the order title in the title box.

When submitting the Scheduling Order, select "Generic Order" in CourtMAP and type "Order on Case Management Plan" under "Document" and use "Order on Case Management Plan" as the title of the order in the title box.

Judge Migna Sanchez-Llorens

CRITICAL

Applies to
Proposed order

Each order must be titled in CourtMAP's designated title block, not in the body of the order, and CourtMAP will not accept submissions without the title block completed.

Each order must be titled in the block in CourtMAP marked "Generic Order-You must rename the Order Title," NOT in the body of the order. CourtMAP will not let you submit your order without filling out the title block.

Judge Migna Sanchez-Llorens

CRITICAL

Applies to
Cover letter
Must include
case number

The cover letter accompanying original notes and mortgages must include the case number, case style, and division number.

The original notes and mortgages must be received by chambers at least three (3) days prior to your scheduled hearing with a cover letter that includes: (1) the case number, (2) case style, and (3) division number.

Judge Migna Sanchez-Llorens

CRITICAL

Applies to
Notice of unavailability

If counsel or a client will be unavailable before calendar call due to medical reasons or pre-paid vacations, a notice of unavailability must be filed on the docket.

PRIOR TO CALENDAR CALL: If counsel or client ONLY are unavailable due to medical reasons or pre-paid vacations you SHALL file a notice of unavailability to the docket.

Judge Migna Sanchez-Llorens

CRITICAL

Applies to
Proposed order

All proposed orders must be accompanied by a cover letter with letterhead correspondence stating whether the motion was granted, or the proposed order will be rejected.

ALL PROPOSED ORDERS MUST BE ACCOMPANIED BY A COVER LETTER. ALL UPLOADED ORDER MUST HAVE LETTERHEAD CORRESPONDENCE AS TO WHETHER THE MOTION WAS GRANTED, OTHERWISE THE PROPOSED ORDER WILL BE REJECTED.

Judge Migna Sanchez-Llorens

CRITICAL

Applies to
Proposed order

All order submissions must attach a cover letter, the relevant motion(s), all supporting documents such as case law or memoranda, and the response(s) to the motion(s).

The following must be attached to all orders: (1) a cover letter, * (2) the relevant motion(s), (3) all supporting documents such as relevant case law or memorandum, and (4) the response(s) to the motion(s).

Judge Migna Sanchez-Llorens

CRITICAL

Applies to
Motion for default
Must include
certificate of service

Motions for default must be submitted as proposed orders with proof of service, affidavit of diligent search, proof of publication (where applicable), and non-military affidavits, all of which must be filed.

Motions for Default must be submitted as a proposed order, per the above procedures, with the following: (1) proof of service, (2) affidavit of diligent search, (3) proof of publication (where service is by publication), (4) and non-military affidavit(s) (all of which must be filed).

Judge Migna Sanchez-Llorens

CRITICAL

Applies to
Jury trial readiness certification
Must include
proposed order

Before scheduling a calendar call date in a jury trial, a completed Jury Trial Readiness Certification must be uploaded to CourtMAP as a proposed order with the jury instructions attached.

JURY TRIALS: BEFORE SCHEDULING A CALENDAR CALL DATE, a Jury Trial Readiness Certification (located under "Hearing Documents") must be completed and uploaded to CourtMAP as a "Proposed Order" with Jury Instructions as a supporting document at least one (1) week prior to the Calendar Call hearing date. The Court will not sign off on the Jury Trial Certificate of Readiness without the supporting documents attached, which includes the Jury Instructions.

Judge Migna Sanchez-Llorens

CRITICAL

Applies to
Jac indigency motion
Must include
proposed order

JAC indigency motions must be submitted to Chambers with supporting documentation, JAC's response, and a proposed order; the Court may enter the order without a hearing unless JAC requests one or the Judge has questions, in which case the JA will set it for hearing.

JAC MOTIONS: Submit the Motion to have the Defendant Declared Indigent for Costs along with supporting documentation, JAC's response, and a proposed order, to Chambers. If JAC does not request a hearing, the Court may enter the proposed order without a hearing after reviewing the documents. If JAC requests a hearing, or if Judge de la O has questions after reviewing the Motion and supporting documentation, the judicial assistant will set the Motion on calendar for hearing.

Judge Miguel M de la O

CRITICAL

Applies to
Credit for time served waiver form

Defense counsel must complete and have the defendant sign a credit-for-time-served waiver form (available from the Clerk) whenever any amount of credit for time served is waived.

If the defendant is waiving any amount of credit for time served, Defense Counsel must fill out a waiver form (available from the Clerk) and have the defendant sign it.

Judge Miguel M de la O

CRITICAL

Applies to
Notice of hearing

The notice of hearing must state the motion’s filing date and the name of the person with whom the hearing was coordinated.

THE FOLLOWING INFORMATION MUST BE INCLUDED IN YOUR NOTICE OF HEARING OR YOUR MATTER WILL NOT BE HEARD: 1) Date the Motion was filed. 2) Name of the Person the hearing was coordinated with*     (COORDINATION IS MANDATORY)

Judge Milena Abreu

CRITICAL

Applies to
Notice of hearing

The notice of hearing must state the motion’s filing date, the person with whom the hearing was coordinated, and the discovery motion and relief sought.

THE FOLLOWING INFORMATION MUST BE INCLUDED IN YOUR NOTICE OF HEARING OR YOUR MATTER WILL NOT BE HEARD: 1) Date the Motion was filed; 2) Name of the Person the hearing was coordinated with*     (COORDINATION IS MANDATORY) 3) The name of the Discovery Motion and what is sought

Judge Milena Abreu

CRITICAL

Applies to
Notice of hearing

The party setting the hearing must place the Zoom link on the notice of hearing after the motion title.

Party setting hearing must include Zoom link on Notice of Hearing after title of Motion.

Judge Milena Abreu