Eleventh Judicial Circuit of Florida, Miami-Dade County Pre-Motion Conference Requirements

CRITICALCriminal cases

Parties must make a good faith effort to coordinate a hearing date with opposing counsel before requesting a non-evidentiary hearing.

The requesting party must make a good faith effort to coordinate a hearing date with the opposing party, prior to requesting the hearing.

CRITICALCriminal cases

Parties must make a good faith effort to coordinate a hearing date with opposing counsel before requesting an evidentiary hearing (motions requiring more than 5 minutes or any evidence).

To request a hearing on a motion that will require more than 5 minutes or which will require the court to consider any form of evidence, including sworn testimony, the requesting party must make a good faith effort to coordinate a hearing date with the opposing party, prior to requesting the hearing.

CRITICAL

The Court will not rule on a downward departure motion unless a plea has been entered or a guilty verdict rendered.

The Court will not rule on a downward departure motion unless a plea has been entered or a guilty verdict rendered.

CRITICAL

Seven categories of motions (court default, reschedule foreclosure sales, extension of time for service, continue/strike trial dates, compel mediation, cancel sale, writ of possession) must always be set for hearing, even if agreed to.

THE FOLLOWING MOTIONS MUST ALWAYS BE SET FOR HEARING: MOTIONS FOR COURT DEFAULT MOTIONS TO RESCHEDULE FORECLOSURE SALES MOTIONS FOR EXTENSION OF TIME TO EFFECTUATE SERVICE OF PROCESS MOTIONS TO CONTINUE TRIAL OR STRIKE TRIAL DATES, EVEN IF AGREED TO MOTIONS TO COMPEL MEDIATION MOTIONS TO CANCEL SALE (EVEN IF AGREED TO) MOTIONS TO ISSUE WRIT OF POSSESSION

CRITICAL

To schedule a special set hearing, the moving party must coordinate with opposing counsel based on courtMAP availability and submit the filed motion and request form; a notice of hearing should not be filed by either side.

*The moving party MUST coordinate the date/time with opposing counsel based on the Court's availability, which is found on courtMap. Once the date has been agreed to, the moving party shall submit a copy of the filed motion and the Court's request form under the supporting documents option on courtMAP when selecting the proposed hearing date for the Court's approval. A notice of hearing should NOT be filed or submitted by either side.

CRITICAL

Special set hearings must be coordinated with opposing counsel in CourtMAP and approved by Chambers, with virtual sets on Zoom, on-camera appearance for testimony, and no doubling up of time slots.

*Special Set hearings must be coordinated with the opposing counsel in CourtMAP. Once approved by Chambers, you will receive a notice of hearing, which is sent to those parties on the service list. All virtual special sets will be conducted via Zoom. The Zoom meeting ID is 954 243 9000. If language interpretation is needed, please contact Chambers so a special Zoom ID can be created. If necessary, the call-in number is 786-635-1003. For any hearing where testimony is given, parties must appear on camera.

CRITICAL

Movants must confer (or attempt to confer) with opposing counsel on scheduling and may set the matter unilaterally if opposing counsel fails to respond within 10 days.

Unilateral Scheduling: Counsel for the movant shall confer or make reasonable effort to confer with opposing counsel regarding scheduling availability. Opposing counsel shall cooperate and act reasonably and in good faith to provide dates of availability. If opposing counsel fails to respond to a scheduling request within 10 days, counsel for the movant may set the matter unilaterally.

CRITICAL

Attorneys and self-represented litigants must make every good-faith effort to confer with the person or party who has not met discovery obligations before seeking court action; violations may result in sanctions.

Attorneys (and pro se litigants) must make every good faith attempt to confer with the person or party failing to meet discovery obligations to secure the information or material without court action. Sanctions may be imposed on those found in violation of this procedure.

CRITICAL

An order to withdraw requires a motion-calendar hearing unless the client provides written consent.

Orders to Withdraw require a hearing on the motion calendar unless written consent from the client is provided.

CRITICAL

The moving party must attempt to coordinate a motion-calendar hearing with opposing counsel, may set it unilaterally after a good-faith effort if cooperation is unavailable, and should expect the motion may be heard 11 days after filing.

1. Coordination Required: The moving party must attempt to coordinate the hearing date with opposing counsel. If cooperation is not obtained despite a good faith effort, the hearing may be set unilaterally. The Court expects that any motion may be heard eleven days after its filing.

CRITICAL

A motion to withdraw must be scheduled on the motion calendar unless the client gives written consent.

Motions to Withdraw Must be scheduled on the motion calendar unless written consent from the client is obtained.

CRITICAL

A case will not be set for trial until the parties have attended mediation.

A case will not be set for trial if the parties have not attended mediation.

CRITICAL

An Attorneys Fee Preliminary Order must be completed before any attorney's fee hearing matter may be set.

A preliminary order must be completed prior to setting any matter related to an Attorney's Fee hearing.

CRITICAL

The court will not notice hearings; the moving party must confer with the opposing party and notice the hearing under the Rules of Judicial Administration.

Please note, the court will not notice hearings, the moving party must confer with the opposing party and notice the hearing in accordance with the Rules of Judicial Administration.

CRITICAL

The court does not notice hearings; the moving party must confer with the opposing party and notice the hearing under the Rules of Judicial Administration.

Please note, the court will not notice hearings, the moving party must confer with the opposing party and notice the hearing in accordance with the Rules of Judicial Administration.

CRITICAL

Any motion requiring more than five minutes must be specially set for hearing instead of being heard on the Five-Minute Motion Calendar.

PLEASE NOTE: Any motion requiring more than five (5) minutes must be specially set for hearing.

CRITICAL

All cases must attend mediation before trial; contact the JA for a referral, and only after the Mediator's report is filed may a Notice for Trial be filed via the e-portal or clerk.

ALL CASES MUST ATTEND MEDIATION PRIOR TO TRIAL. -Please contact the JA for a referral to Mediation. -Once the Mediator's report has been filed, file a Notice for Trial via the e-portal or with the clerk's office.

CRITICAL

Parties must coordinate with the opposing party on a hearing date before setting the motion on the courtMAP Motion Calendar with the motion and responses (e-file stamped) attached.

On COURTMAP, coordinate with opposing party and select the date to have the motion heard. Once a date is agreed upon you may set the hearing using in the Motion Calendar slot. As supporting documents, attach the motion and any responses with an e-file stamp.

CRITICAL

All cases must attend mediation before filing a Notice of Readiness for Trial.

All cases must attend mediation prior to filing a Notice of Readiness for Trial.

CRITICAL

A Case Management Conference is required before trial can be set on all notices of trial.

All notices of Trial will need a Case Management Conference before trial can be set.

CRITICALCriminal cases

Before seeking an Arthur Hearing, defense counsel must first speak with the assigned ASA, and only if no agreement is reached may counsel email the JA to place the case on calendar for a bond status hearing.

Defense Counsel must first speak with assigned ASA to verify that the State will not agree to any pretrial release conditions. If the parties cannot reach agreement, Defense Counsel may email the JA to request that the case be placed on calendar for status regarding bond.

CRITICAL

Motions to dismiss and motions or objections concerning discovery disputes must be specially set and may not be placed on the Motion Calendar.

IMPORTANT NOTICE: Motions to Dismiss AND motions and/or objections relating to discovery disputes shall not be placed on the Motion Calendar as said motions shall be specially set for hearing.

CRITICAL

Defense Counsel should first present the documentary proof to the State and inquire whether the State will stipulate the defendant has satisfied the Nebbia requirements. If there is no stipulation, submit the documents to chambers and the judicial assistant will call the attorney's office with the date for the Nebbia hearing.

Defense Counsel should first present the documentary proof to the State and inquire whether the State will stipulate the defendant has satisfied the Nebbia requirements. If there is no stipulation, submit the documents to chambers and the judicial assistant will call the attorney's office with the date for the Nebbia hearing.

CRITICALCivil cases

Before setting a foreclosure motion on the calendar, parties must meet and confer by phone, in person, or Zoom; email does not satisfy the requirement.

Parties are required to MEET AND CONFER prior to setting motions on calendar. (The parties are required to speak over the phone, in-person or via zoom. Emails do NOT satisfy this requirement.)

CRITICALCriminal cases

Motions for Arthur Hearings must first be set on the calendar for scheduling purposes only, after which the Court will give counsel a future hearing date.

Motions for Arthur Hearings must first be set on calendar for scheduling purposes only. The Court will provide counsels with a future date for the Hearing.

CRITICAL

All cases must attend mediation before filing a Notice of Readiness for Trial.

All cases must attend mediation prior to filing a Notice of Readiness for Trial.

CRITICAL

Attorneys and pro se litigants must meet no less than 20 days before trial to discuss settlement and all aspects of the trial.

PARTY MEETING: No less than twenty (20) days prior to the trial, the attorneys/pro se litigants shall meet and communicate concerning settlement and all aspects of the trial.

CRITICALCivil cases

Motions for rehearing/reconsideration must be set on the special set calendar for at least 30 minutes.

Motions for Rehearing/Reconsideration MUST be set on the special set calendar for no less than 30 minutes.

CRITICALCivil cases

Motions for summary judgment must be set for no less than 30 minutes starting January 1, 2026.

BEGINING JANUARY 1ST, 2026 ALL MOTIONS FOR SUMMARY JUDGMENT ARE NO LESS THAN 30 MINUTES.

CRITICALCivil cases

The five-minute motion calendar excludes motions to dismiss, quash service, fee hearings, summary judgment, protective order, rent determination, evidentiary hearings, motions in limine, sanctions, and any motion over five minutes.

The Court will not hear Motions to Dismiss, Motions to Quash Service, Fee Hearings, Motions for Summary Judgment, Motion for Protective Order, Motion to Determine Rent, Evidentiary Hearings, Motions in Limine, Motions for Sanctions, or Any Motions That will take more than five (5) minutes.

CRITICAL

Before setting a motion hearing, parties must make good faith efforts to resolve issues, coordinate date and time, and confirm the hearing requires no more than five minutes.

The parties must use good faith efforts to resolve the issues set forth in the motion prior to the setting of a motion, coordinate the date and time of the hearing; and confirm that the hearing shall require no more than five minutes.

CRITICAL

Before seeking an Arthur hearing, defense counsel must first speak with the assigned ASA to verify the State will not agree to any pretrial release conditions.

Defense counsel must first speak with the assigned ASA to verify that the State will not agree to any pretrial release conditions.

CRITICALCivil cases

Unilateral setting of hearings is prohibited unless Court approval is first obtained.

Unilateral setting of hearings is not permitted. If you are seeking a unilateral hearing, Court approval is required.

CRITICALCivil cases

Motions to Transfer must be heard by the Administrative Judge rather than the assigned Division Judge.

Motions to Transfer must be heard by the Administrative Judge, not by the assigned Division Judge.

CRITICALCivil cases

Motions for contempt/enforcement may not be set on the 5-Minute Motion Calendar and must be specially set with the Judicial Assistant.

DO NOT SET MOTIONS FOR CONTEMPT/ENFORCEMENT ON THE 5-MINUTE MOTION CALENDAR. ALL MOTIONS FOR CONTEMPT/ENFORCEMENT SHALL BE SPECIAL SET WITH THE JUDICIAL ASSISTANT.

CRITICALCivil cases

Movants must meet and confer with opposing counsel before scheduling and noticing any hearing, and unilateral hearing settings are prohibited unless the Court approves.

Important: Any movant scheduling and noticing a hearing (Motion Calendar and Special Set) before this Court must meet and confer with opposing counsel in order to attempt to resolve any and all issues possible. Unilateral setting of hearings is not permitted. If you are seeking a unilateral hearing, Court approval is required.

CRITICAL

Landlord-tenant motions, defendants' claims of exemption, reconsideration, re-hearing, attorney's fees, entitlement, tax costs, summary judgment (except credit card/collection cases), 57.105, emergency motions, and case management or status conferences may not be scheduled for or heard on the Motion Calendar.

The following motions are NOT ALLOWED to be heard on Motion Calendar: NO LANDLORD & TENANT MOTIONS, (INCLUDING EMERGENCY MOTIONS TO STAY WRIT), Defendants' Claim of Exemption, Motions for Reconsideration, Motions for Re-Hearing, Motions to Compel Hearing Dates (when attorneys' offices cannot coordinate), Motions for Attorney's Fees, Motions for Entitlement, Motions to Tax Costs, Motions for Summary Judgment, Motions for Final Summary Judgment (EXCEPT CREDIT CARD/COLLECTION CASES), Motions for 57.105, Emergency Motions, Case Management Conferences, Status Conference. Please DO NOT schedule these motions on Motion Calendar as they WILL NOT be heard and will be taken off the Motion Calendar.

CRITICAL

A law firm may set no more than two motions per day per office, even across separate files, and add-on hearings are not permitted.

No Law Firm (including all attorneys affiliated with the firm) may set more than two (2) motions per day per office, even if the motions involve separate files. NO "ADD-ONs" will be permitted.

CRITICAL

A case with pending motions for summary judgment will not be placed on calendar call until all such motions have been heard, and no summary judgment motions may be heard during the trial period.

IF THERE ARE ANY MOTIONS FOR SUMMARY JUDGMENT PENDING, THEN YOUR CASE WILL NOT BE PLACED ON CALENDAR CALL UNTIL ALL MOTIONS FOR SUMMARY JUDGMENT HAVE BEEN HEARD. NO MOTIONS FOR SUMMARY JUDGMENT SHOULD BE HEARD DURING THE TRIAL PERIOD.

CRITICAL

All hearings must be coordinated with opposing counsel, and the Judge will not hear any hearings that were set unilaterally.

All hearings MUST be coordinated with opposing counsel. The Judge WILL NOT hear any hearings set unilaterally.

CRITICALCivil cases

A pre-trial conference must be held no later than 15 days before trial, at which all motions are heard and ruled upon and draft jury instructions and witness and exhibit lists are completed.

No later than 15 days prior to the trial date, a pre-trial conference must be held. At this conference, all motions shall be heard and ruled upon, draft jury instructions must be completed, and witness and exhibit lists must be completed.

CRITICAL

The moving party must confer with the opposing party and notice the hearing in accordance with the Rules of Judicial Administration.

Please note, the moving party must confer with the opposing party and notice the hearing in accordance with the Rules of Judicial Administration.

CRITICAL

All cases must attend mediation before trial.

ALL CASES MUST ATTEND MEDIATION PRIOR TO TRIAL.

CRITICAL

Summary judgment motions may not be set on 10-minute special set slots; parties must email and call chambers, and the JA will set a Zoom case management conference where the judge assigns the MSJ hearing date.

Please email and call chambers with your request; MSJs are not to be set on 10min Special Set slots. The JA will set you on a Zoom Case Management Conference where the Judge will provide a future date and time for the MSJ to be heard.

CRITICAL

Hearings requiring 30 minutes must be set on the 5-minute motion calendar with the motion type indicated, after which the judge will provide a date and time in open court.

Judge Woodward’s Procedure: If you require 30 minutes for a hearing, you must set the matter on the 5-minute motion calendar and indicate the type of motion requesting 30 minutes. The judge will provide the attorneys with a date and time in open court.

CRITICAL

All parties to any motion in this division must comply with the division's conferral requirements.

All parties to a motion must meet the conferral requirements of this division.

CRITICAL

The meet and confer obligation must be an actual effort between attorneys personally, not between staff members.

“Meet and Confer” under this rule requires an actual effort between attorneys, not staff.

CRITICAL

Daubert and summary judgment motions must be scheduled and heard before calendar call and the first day of the trial period, or they will be struck.

Daubert and Motions for Summary Judgment: Must be scheduled for hearing before the time of the calendar call and the hearing must occur prior to the first day of the trial period. Failure to timely schedule these motions shall result in the striking of the motions.

CRITICAL

All parties must meet and confer before filing any motion to narrow issues, determine hearing time if requested, and address related issues such as completing discovery.

This Court requires that all parties meet and confer prior to filing any motion, to determine if issues can be narrowed, the appropriate amount of time required for hearing, if hearing is requested, and any other issues, such as the completion of related discovery.

CRITICAL

A filed motion will not be considered unless it is set for hearing, and the Court may strike motions that are not timely set.

Filing a motion is insufficient for consideration by the Court – the party must set the motion for hearing to bring the filing to the Court's attention. The Court may strike sua sponte motions filed but not timely set.