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

CRITICALCivil cases

Applies to

Exhibit

Each exhibit must be marked for identification on the bottom of its first page (e.g., "Petitioner's 1" or "Respondent's A") and must match the markings on the Proposed Exhibit List.

Each Exhibit shall be marked for identification on the bottom of the first page of the document "Petitioner's 1, 2, 3, etc." or "Respondent's A, B, C, etc." Each marked Exhibit must correspond with the identification markings on the Proposed Exhibit List.

CRITICALCivil cases

Applies to

Proposed exhibit list

The Proposed Exhibit List must describe each exhibit, mark each as "Petitioner's 1, 2, 3, etc." or "Respondent's A, B, C, etc.", and indicate whether the parties agree the document may be admitted.

The Proposed Exhibit List must contain a description of each of the exhibits a party wishes to use at an evidentiary hearing. Each exhibit listed on the Proposed Exhibit List must be marked for identification on the Proposed Exhibit List as "Petitioner's 1, 2, 3, etc." or "Respondent's A, B, C, etc.". Parties or their counsel must indicate on the Proposed Exhibit List whether the parties agree the document may be admitted into evidence.

CRITICALCivil cases

Applies to

Notice of hearing

Must include

case number

Notice of hearing must include the docket entry number in the title next to each motion and in the CourtMAP subject area.

PLEASE INCLUDE THE DOCKET ENTRY NUMBER IN THE TITLE NEXT TO EACH MOTION ON YOUR NOTICE OF HEARING. And also in the subject area when setting in courtmap.

CRITICALCivil cases

Applies to

Notice of hearing

Must include

case number

Notices of hearing must state the docket numbers of the motion and all related memoranda and are insufficient without a docket entry number.

NOTICE OF HEARINGS: Parties are to state the docket number of the motion and all memoranda related to the issue filed by either side on their Notice of Hearing. Notices of hearing are not deemed sufficient unless a docket entry number is listed.

CRITICALCivil cases

Applies to

Motion

Must include

proposed order

All motions must be accompanied by a proposed order.

Attorneys and parties shall submit all motions with a proposed order through courtMap..

CRITICALCivil cases

Applies to

Notice of hearing

Notices of hearing must include the docket entry number in the title next to each motion, and in the subject area when setting in CourtMAP.

PLEASE INCLUDE THE DOCKET ENTRY NUMBER IN THE TITLE NEXT TO EACH MOTION ON YOUR NOTICE OF HEARING. And also in the subject area when setting in courtmap.

CRITICALCivil cases

Applies to

Emergency motion

Must include

proposed order

Emergency motions must be filed with a proposed order in CourtMAP under the EMERGENCY SUBMISSION category.

-If you have an Emergency Motion please file the Motion with a Proposed Order in CourtMAP under the EMERGENCY SUBMISSION.

CRITICALCivil cases

Applies to

Business records certification

A party relying on certified business records must bring the original certification to trial.

If a party is relying on business records through certification then the original certification must be brought to the trial.

CRITICAL

Applies to

Exhibits

All exhibits must be pre-marked and initialed and provided to the clerk on the first day of trial or evidentiary hearing, using numerical markings for plaintiff's exhibits and alphabetical markings for defendant's exhibits, and no exhibit (except impeachment exhibits) may be offered unless pre-marked.

All exhibits are to be pre-marked and initialed and provided to clerk on the first day of trial or evidentiary hearing. Plaintiff's exhibits are marked, if stipulated or agreed, into evidence with a numerical marking, i.e., 1, 2, 3. Plaintiff's exhibits, if not yet deemed admitted, are marked for identification as 1a. 1b, 1c, for identification. Defendant shall likewise mark agreed exhibits alphabetically, i.e., a, b, c, and mark for identification as, i.e., a1, a2, a3. Exhibits shall be one-sided. No document or exhibit, except impeachment exhibits, may be offered into evidence unless it has been pre-marked.

CRITICAL

Applies to

Notice of hearing

Notices of hearing and the CourtMap setting subject area must include the Docket Entry number (D.E. #), or the court will cancel the hearing.

Parties shall include the Docket Entry number (“D.E. #”) on all Notices of Hearing, the Subject area for the CourtMap setting, and in Proposed Orders submitted to CourtMap. If the docket entry numbers are omitted from notices of hearing and the subject area for the CourtMap setting, the court will cancel your hearing.

CRITICAL

Applies to

Proposed order

Proposed orders submitted to CourtMap must include the Docket Entry number (D.E. #), or the court will reject the orders.

If the docket entry numbers are omitted from the proposed orders, the court will reject your orders.

CRITICAL

Applies to

Emergency motion

Must include

proposed order

An emergency motion must be filed with a proposed order.

If you have an Emergency Motion please file the Motion with a Proposed Order in CourtMAP under the EMERGENCY SUBMISSION.

CRITICAL

Applies to

Joint case management report

Initial case management hearings require client attendance and submission of a joint case management report.

Initial Case Management hearings, set pursuant to Rule 1.201(b), are governed by a detailed court order setting the hearing, require client attendance, and submission of a joint case management report.

CRITICAL

Applies to

Emergency motion

Emergency motions must be uploaded via CourtMAP and include a certification explaining why the matter is a true emergency, cannot wait for a regular motion calendar, and detailing the emergency.

Emergency Motions must be uploaded via CourtMAP and MUST contain a Certification that the matter is a true Emergency, and cannot wait to be heard during a regular motion calendar.  The certification/motion must include the details of the Emergency.

CRITICAL

Applies to

Emergency motion

An emergency motion must state that opposing counsel was notified and that a good-faith attempt to resolve the matter amicably was made.

The Emergency Motion MUST contain a statement indicating that opposing counsel has been notified, and an attempt to resolve the matter amicably has been made in good faith.

CRITICAL

Applies to

Notice of cancellation

Cancellation requests must be made through CourtMAP, and an approved cancellation notice must state a valid reason.

Must be requested through CourtMap. If approved, the Notice of Cancellation must state a valid reason.

CRITICAL

Applies to

Notice for trial

A copy of a filed notice for trial must be provided to the judicial assistant or bailiff.

If parties file Notice for Trial – a copy must be provided to the JA or the Bailiff.

CRITICAL

Applies to

Notice of hearing

When scheduling a hearing, the setting party must provide the opposing party a Zoom-instruction notice and file it with the Clerk.

The setting party must provide Notice of Hearing with instructions on how to appear using Zoom to the opposing party when scheduling a hearing and must file the notice with the Clerk.

CRITICAL

Applies to

Motion calendar submission

To add a matter to the judge's motion calendar, the notice of hearing and motion must be filed with the Clerk.

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.

CRITICAL

Applies to

Notice of hearing

The moving party must state on the notice of hearing that it was physically mailed and allow appropriate delivery time.

The moving party SHALL indicate on the Notice of Hearing that the Notice was physically mailed to the party, with an appropriate time for delivery.

CRITICALCivil cases

Applies to

Continuance motion

Must include

proposed order

If a defendant has not been served before a pre-trial conference, the plaintiff's attorney must be present and/or file a continuance motion with a proposed order in courtMAP.

For Pre-trial Conferences, if there is NON-SERVICE on a case, Plaintiff Attorney MUST BE present and/or file for continuance along with a Proposed order in CourtMaps.

CRITICALCivil cases

Applies to

Witness list

At least 10 days before trial, a written witness list (excluding impeachment witnesses) with names, addresses, and the general nature of each witness's testimony must be furnished to opposing counsel and a copy filed in the case.

The names and addresses of all witnesses except those used for impeachment, shall be furnished to opposing counsel in writing together with a statement of the general nature of the testimony of each witness, and a copy thereof in this cause.

CRITICALCivil cases

Applies to

Ex parte motion

Must include

certificate of conference

Ex-parte motions must include the Rule 1.380(a)(2) certification of conferral, with specific language that counsel conferred with opposing counsel, or the court will reject the ex-parte order.

Any and all EX-PARTE Orders MUST INCLUDE THE Certification in previous filed MOTION as Required by Rule 1.380(a) (2) of attempt to Confer on discovery. Specific language that you conferred with opposing counsel needs to be in the EX-PARTE Motion otherwise the Court will REJECT the EX-PARTE Order.

CRITICALCivil cases

Applies to

Motion for zoom appearance

Must include

proposed order

Special set hearings are in person unless a party requests Zoom access in advance by filing a motion with a proposed/agreed order.

Special Set hearings will be conducted in person unless a party request Zoom access in advance by filing a Motion and submitting a Proposed/Agreed Order.

CRITICALCivil cases

Applies to

Stipulation for settlement

Must include

proposed order

Counsel must notify the court immediately upon settlement and submit a Stipulation for Settlement and Order of Dismissal.

Counsel shall notify the Court immediately in the event of settlement and submit a Stipulation for Settlement and Order of Dismissal.

CRITICALCivil cases

Applies to

Motion for zoom appearance

Must include

proposed order

To request a special set hearing via Zoom, file a motion with a correlating proposed order on courtMAP and, if approved, amend the notice of hearing with the Zoom details.

To request a Special Set hearing via Zoom: - File a motion and submit a proposed order that correlates to the motion on Court Map. If approved, amend the notice of hearing with the Zoom details.

CRITICALCivil cases

Applies to

Ex parte motion to compel

Ex-parte motions to compel must reflect compliance with Eleventh Circuit Administrative Order No. 06-09 or they will be summarily denied.

Ex-Parte Motions to Compel: Before filing an Ex-Parte Motion to Compel, please ensure you have complied with the Eleventh Circuit Court Administrative Order No. 06-09. Motions that do not reflect compliance with the Administrative Order will be summarily denied.

CRITICALCivil cases

Applies to

Notice of settlement

A Notice of Settlement must be filed with the Clerk's Office when a case is resolved through settlement.

Settlements: If your case is resolved through settlement, a Notice of Settlement must be filed with the Clerk's Office.

CRITICAL

Applies to

Notice of hearing

Notices of unilaterally set hearings must state that the movant set the matter unilaterally after good faith efforts to reach the opposing party failed.

After receiving a date and time for a unilaterally set hearing, the notice must include the language that undersigned set this matter unilaterally after good faith efforts to reach the opposing party were unsuccessful.

CRITICAL

Applies to

Order on stipulation for substitution of counsel

Orders on stipulations for substitution of counsel must include the client's written consent and the new attorney's name and bar number in the body of the order.

If you are submitting an order on a Stipulation for Substitution of Counsel, you must submit the written consent of the client. Additionally, the name and bar number of the "new" attorney must be included within the body of the proposed order.

CRITICAL

Applies to

Proposed order after hearing

Proposed orders submitted after a hearing must be accompanied by a cover letter with the hearing details and the Court's oral ruling.

If you are submitting a proposed order after a hearing, you must submit a cover letter that includes the hearing details and the Court's oral ruling.

CRITICAL

Applies to

Proposed order

Supporting documents such as motions, affidavits, and cover letters must always accompany proposed orders submitted via CourtMAP.

Supporting documents (i.e: motions, affidavits, cover letters, etc.) must always be submitted in support of your proposed order.

CRITICAL

Applies to

Any court filing (pleading, motion, memorandum, response, proposed order, or other court record)

Must include

ai disclosure

Any attorney or self-represented litigant who uses generative AI in preparing a court filing must disclose that use on the face of the filing.

Any attorney or self-represented litigant who uses any generative artificial intelligence tool in the preparation of a pleading, motion, memorandum, response, proposed order, or other court record, must disclose such use on the face of the filing.

CRITICAL

Applies to

Final order of dismissal and final judgment

A final disposition form must accompany all Final Orders to Dismiss and Final Judgments.

Final disposition forms must be submitted with all Final Orders to Dismiss and Final Judgments.

CRITICAL

Applies to

Order of dismissal

Orders of dismissal must specify whether dismissal applies to an individual defendant or all defendants, or the court may dismiss the entire case.

When submitting an Order of Dismissal, specify whether the Dismissal applies to an individual Defendant or all Defendants. Failure to do so may cause the Court to enter an Order Dismissing the entire case.

CRITICAL

Applies to

Ex parte motion to compel

Must include

certificate of conference

Ex-parte motions to compel must contain the good faith effort certification required by Rule 1.380(a)(2).

Ex-Parte Motions to Compel: must contain certification of "good faith effort" required by Rule 1.380(a)(2).

CRITICAL

Applies to

Emergency motion

Emergency motions must contain a certification 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.

CRITICAL

Applies to

Motion

All arguments and supporting documents must be included in the filed motion rather than held for presentation at hearing.

PLEASE SUBMIT ALL ARGUMENTS AND SUPPORTING DOCUMENTS IN THE FILED MOTION

CRITICAL

Applies to

Notice of readiness

A copy of the filed notice of readiness must be submitted under supporting documents when selecting a calendar call/trial date.

A copy of the filed notice of readiness must be submitted (under supporting documents).

CRITICAL

Applies to

Emergency motion

Emergency motions must contain 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.

CRITICAL

Applies to

Court filing prepared with generative ai

Must include

ai disclosure

Filings prepared with generative AI must include a specified certification, placed at the conclusion of the filing or immediately above the signature block.

The filing shall include a statement substantially in the following form: "Generative artificial intelligence was used in the preparation of this filing. The undersigned certifies that all factual assertions, legal authority, and citations have been independently reviewed and verified for accuracy and accepts full responsibility for the contents of this filing." This certification may be included at the conclusion of the filing or immediately above the signature block.

CRITICALCivil cases

Applies to

Certification of trial readiness

At the conclusion of the pre-trial conference, the parties and the court must certify eight trial-readiness elements, including completed discovery and motions, finalized jury instructions, exchanged exhibits and witness lists, and an estimated trial length.

At the conclusion of the pre-trial conference, the parties and the court must certify the following: a. The case is at issue. b. All discovery is completed. c. All dispositive motions have been filed, heard, and ruled upon. d. All pre-trial motions have been filed, heard, and ruled upon. e. Jury instructions have been filed, argued, and the form and content of jury instructions are finalized (to the extent possible) by the court. f. Exhibits have been exchanged, pre-marked, and stipulated where appropriate. g. Witness lists have been exchanged, and all witnesses are available and secured for trial. THE TRIAL PERIOD SHALL BE EITHER 1 or 2 weeks, AS DETERMINED BY THE TRIAL JUDGE. CERTIFICATION OF READINESS REQUIRES THE PARTIES, ATTORNEYS, AND WITNESSES TO BE AVAILABLE FOR THE ENTIRE TRIAL PERIOD. h. An estimated length of trial from commencement through charging the jury, stated as a number of hours.

CRITICALCivil cases

Applies to

Certification of trial readiness

The Certification of Trial Readiness must be signed by all parties and the presiding Judge.

Upon completion of (4) above, the attached Certification of Trial Readiness shall be signed by all parties and the presiding Judge.

CRITICAL

Applies to

Cover letter

Every proposed order cover letter must state whether the matter was heard, the hearing date, the motion's title, that the proposed order was sent to the opposing party, and whether the opposing party agrees.

The cover letter must address the following: 1. Whether the matter has been heard 2. Date of the hearing (if previously heard) 3. Title of the motion 4. The proposed order has been sent to the opposing party 5. Whether opposing party agrees with the proposed order

CRITICAL

Applies to

Proposed order

Proposed orders submitted without a cover letter showing they were sent to the opposing party are treated as ex parte communications and will not be read by the judge.

ALL PROPOSED ORDERS SENT WITHOUT A COVER LETTER INDICATING THAT IT HAS BEEN SENT TO THE OPPOSING PARTY ARE CONSIDERED EXPARTE COMMUNICATIONS AND WILL NOT BE READ BY THE JUDGE.

CRITICAL

Applies to

Petition

Must include

proposed order

Filings of petitions with proposed orders in courtMAP must include the established checklist certification forms, and failure to include them results in summary rejection.

As of September 1, 2020, filings of petitions with proposed orders in courtMAP must include established checklist certification forms as supporting documents with your submissions. Failure to include the checklist certification form will result in summary rejection of your submission.

CRITICAL

Applies to

Motion for clarification rehearing reconsideration

Must include

proposed order

Motions for clarification, rehearing, or reconsideration must be submitted as a proposed order with supporting documents, including a cover letter, via CourtMAP.

Motions for Clarification, Rehearing, Reconsideration: Submit a "Proposed Order" with supporting documents (including a cover letter) via CourtMAP. Court will review and advise if a response is needed and/or if a hearing should be set.

CRITICAL

Applies to

Motion to withdraw as counsel

Motions to withdraw as counsel must use the court's form order found on the division website under 'Documents.'

On Motions to Withdraw as Counsel, you must use our form order found on our website below under "Documents."

CRITICAL

Applies to

Proposed order

Proposed orders for matters already heard by the Court must include 'Post Hearing' in the title and the hearing date in the first sentence of the body.

If the matter has been heard by the Court, include the words "Post Hearing" in the title of your proposed order and include the hearing date in the first sentence of the body of the order.

CRITICAL

Applies to

Emergency petition motion

Emergency petitions/motions must contain a certification that the matter is a true emergency and a statement that opposing counsel has been notified in an attempt to resolve the matter amicably.

Your Petition/Motion must contain the following: - a certification that the matter is a true emergency and cannot wait to be heard during a special set hearing. - a statement indicating that opposing counsel has been notified in an attempt to resolve the matter in an amicable manner.