Judge Tanya Davis Wilson
Individual Rules, Standing Orders & Policies
- Rules last changed:
Limits & Logistics
Courtesy Copies
Courtesy copies
- Email • After Hearing
Cover Letter, Motion, Supporting Memorandum, Case Law
- Email • At Least Five Business Days Before Hearing
Hearing Materials
- At Least Five Business Days Before Hearing
Joint Pretrial Statement
- 3 Business Days Before Pretrial Conference
Adjournments
- A continuance request must be made immediately when the trial date is not workable, be written and signed by the requesting attorney and parties, state opposing counsel's position and prior continuance history, identify when the parties would be ready for trial, and comply with Florida rules 1.460 and 2.545(e).
- A stipulated motion to continue does not extend the trial until the Court reviews it and enters an order, and attorneys must continue complying with the trial order until then.
- The parties may not extend the pretrial-order deadlines by joint stipulation.
- +1 more
Request must include
Communication
Chambers
Phone
Chambers
Phone
Duty Judge
Phone
Court-wideClerk
Phone
Court-wideClerk
Clerk
Document Format Requirements18 rules
Proposed jury instructions and verdict forms must be submitted in hard copy and electronically in Word.
Proposed jury instructions and verdict forms must be submitted both in hard copy and electronically in Word
If remote appearances are permitted, documents intended for admission into evidence must be Bates stamped and hard copies must be provided to the court at least five business days before the hearing.
In the event remote appearances are permitted, all documents intended to be admitted into evidence shall be Bates stamped and hard copies provided to the Court at least 5 business days prior to the hearing.
Exhibits exchanged for an evidentiary hearing or non-jury trial must be Bates-stamped.
No later than 5 business days before the hearing, counsel and/or pro se parties shall exchange any and all exhibits, which must be Bates-stamped.
A trial brief filed with the court must be submitted in hard copy to the judge's chambers no later than three working days before trial begins.
If a trial brief is to be filed with the Court it must be submitted to the Judge’s Chambers in hard copy no later than three (3) working days before the trial is to commence.
Paper
A Notice for Trial filed with the clerk must include enough stamped, addressed envelopes for counsel and unrepresented parties who do not participate in e-filing.
Notices for Trial pursuant to Fla.R.Civ.P 1.440 and filed with the Clerk shall include a sufficient number of stamped addressed envelopes for all counsel and unrepresented parties who do not participate in e-filing.
The copy sent to the court must be provided in hard copy and by email in Word format.
A copy of the single set of jointly‐proposed jury instructions and verdict form shall be forwarded to the court (i) in hard copy AND (ii) via email to the Judicial Assistant at 34orange@ninthcircuit.org in WORD FORMAT no later than seven (7) days before trial period is to commence.
A signed paper copy of the Joint Pretrial Statement must be delivered to chambers at least three business days before the Pretrial Conference.
Joint Pretrial Statement: Signed by attorneys/pro se parties and filed and a hard copy delivered to chambers no later than 3 business days prior to Pretrial Conference. (§7b)
Paper
The single set of jointly proposed jury instructions or verdict forms must be provided to the court in Word format seven days before trial begins.
A copy of the single set of jointly‐proposed Jury Instructions/Verdict Form (in Word format) must be provided to the Court seven (7) days before trial period is to commence.
DOCX
Two hard copies of each deposition intended for use in court must be brought to court.
Copies: Bring two (2) hard copies of any deposition to be used to court.
When all parties participate in e-filing and courtesy materials are sent after the hearing, the proposed order must be provided in Word format.
If all parties participate in e-filing, courtesy copies along with the proposed order in Word may be provided by email to 34orange@ninthcircuit.org, after the hearing takes place.
DOCX
Electronically submitted courtesy copies must be indexed, with each index entry hyperlinked to the indexed document, exhibit, or case.
For electronically provided copies, counsel must index the materials and ensure the index contains a hyperlink to the Document/exhibit/case indexed.
Courtesy copies sent to the court must be bookmarked PDFs or hard copies.
Be sent in bookmarked pdf or hard copies.
Case authorities included in courtesy copies should be highlighted.
Cases should be highlighted.
A proposed agreed order sent to chambers must be prepared in Word format.
Proposed agreed orders should be: emailed to 34orange@ninthcircuit.org in Word along with an e-filed cover letter indicating whether: o Opposing counsel agrees to the content and form of the order.
DOCX
Hard copies of the case law cited in a trial brief should be submitted with the pertinent sections appropriately highlighted.
Please submit hard copies of case law cited in the trial brief with appropriate highlighting of the pertinent sections.
Paper
Orders must use plain white 8½-by-11-inch paper, double spacing, and the applicable formatting requirements, and the judge may require electronic Word submission by email.
All orders must be formatted for 8 1/2 X 11 plain white paper, double spaced, and comply with the formatting requirements of Rule 2.520, Fla. R. Jud. Admin. The Judge may require orders to be provided electronically in Word by email.
The e-filed cover letter must bear the filing stamp across its top.
The cover letter must have the filing stamp across the top
When all parties receive service through the statewide ePortal, the proposed order in Word format rather than PDF, together with the e-filed cover letter, may be emailed to 34orange@ninthcircuit.org.
the proposed Order(s) in Word format, (not PDF), along with a copy of the e-filed cover letter, may be emailed to 34orange@ninthcircuit.org.
DOCX
Document Filing Requirements76 rules
Proposed jury instructions and verdict forms must be submitted in both hard copy and electronically in Word to the Judicial Assistant no later than three days before the start of the trial period.
17. JURY INSTRUCTIONS / VERDICT FORMS: Proposed jury instructions and verdict forms must be submitted both in hard copy and electronically in Word to the Judicial Assistant at 34orange@ninthcircuit.org no later than three (3) days before the start of the trial period.
Document Type
Jury Instructions And Verdict Forms
After conferring, filing counsel must prepare and file a written stipulation confirming agreed motions in limine and the agreement concerning each.
Subsequent to the meeting(s) counsel filing the Motion in Limine must prepare and file a stipulation confirming in writing the agreed upon Motions in Limine and the agreements as to each.
Document Type
Stipulation
The memorandum must identify each unresolved motion item and present arguments and case law supporting the disputed motions.
a. Identifying each item in the Motion(s) in Limine that has not been agreed to by opposing counsel at the meet and confer; and b. Setting forth any arguments and case law in support of the disputed Motion(s) in Limine.
Document Type
Memorandum Of Law
After the meet-and-confer requirement is satisfied, filing counsel must submit a written memorandum of law with supporting case law.
After the meet and confer requirement has been satisfied, counsel filing the Motion(s) in Limine shall submit to the Court a written memorandum of law, with supporting case law:
Document Type
Memorandum Of Law
The Court will not consider additional case law omitted from the original memoranda or responses unless the case law issued after those submissions.
No additional case law will be considered that has not been set forth in the previously submitted memorandums or responses unless that case law was issued subsequent to the submittal of the memorandums or responses.
Document Type
Memorandum Of Law
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 Motion in Limine will prepare the proposed order on any contested hearing reflecting the Court’s rulings.
Document Type
Proposed Order
When a hearing is directed, the moving party must send notice of hearing and identify in the notice the disputed matters submitted for resolution.
The moving party must send out the notice of hearing and specifically set forth in the “Notice” the ===== PAGE 2 ===== specific matters that remain in dispute and that will be submitted to the Court for resolution.
Document Type
Notice Of Hearing
The Notice of Hearing filed with the Court must include a Certificate of Compliance.
include a Certificate of Compliance in the Notice of Hearing filed with the Court.
Document Type
Notice Of Hearing
For contested hearings, every motion must be docketed with the clerk before a hearing is requested.
For CONTESTED HEARINGS, all motions must be DOCKETED with the Clerk PRIOR to requesting a hearing.
Document Type
Motion
Bench trials and evidentiary hearings are in person unless the parties obtain a court order permitting remote appearances.
All bench trials and evidentiary hearings shall take place in person, unless the parties move for and obtain a court order permitting remote appearances.
Document Type
Hearing Notice
An in-person hearing notice must include the Orange County Courthouse address and hearing room number.
Notices of in-person hearings must include the address of the Orange County Courthouse, as well as the hearing room number.
Document Type
Notice Of Hearing
Every notice of hearing must state the parties’ appearance format and the filing date of the motion or motions.
Every notice of hearing must state how the parties will appear at the hearing and must include the date the motion(s) was filed.
Document Type
Notice Of Hearing
A hearing request concerning a motion to dismiss or motion to strike must identify the date the case management order was filed and the case-management-order deadline for those motions.
For motions to dismiss/strike please include the below information in your request: DATE CASE MANAGEMENT ORDER WAS FILED: CASE MANAGEMENT ORDER DEADLINE FOR MOTIONS TO DISMISS/STRIKE (e.g. 45 or 60 days):
Document Type
Hearing Request
An emailed hearing request must include the case number, parties and counsel, requested hearing information, motion filing information, certificate-of-conference status, meet-and-confer date, pretrial date, and appearance format.
The emailed hearing request to the JA must include all of the following: CASE NO.: PLAINTIFF NAME & COUNSEL: DEFENDANT NAME & COUNSEL: HEARING DATE & TIME REQUESTED: LENGTH OF HEARING: TITLE OF MOTION & DATE FILED: DOES THE MOTION INCLUDE THE CERTIFICATE OF CONFERRAL? Please see Fla.R.Civ.Pro. 1.202 if you have questions about this requirement. DATE OF MEET & CONFER: PRETRIAL DATE: VIRTUAL OR IN PERSON
Document Type
Hearing Request
When written client consent is attached to a motion to withdraw as counsel, the submission to chambers must include the motion, an e-filed cover letter, and a proposed order containing a certificate of service.
If you have written client consent (attached to the motion) you may submit a copy of the motion along with an efiled cover letter and a proposed order to chambers. A certificate of service must be included in the proposed order.
Document Type
Motion To Withdraw
An emergency-hearing motion must explain in its body both the circumstances establishing the emergency and the substance of the motion.
The body of the motion must contain a detailed explanation of the circumstances constituting the emergency as well as the substance of the motion.
Document Type
Emergency Motion
Before an emergency hearing is set, email the motion to the court with a cover letter and a proposed order.
The Motion must be e-mailed to the Court with a cover letter, and a proposed order before a hearing will be set.
Document Type
Emergency Motion
The proposed order's body must include the client's name, address, telephone number, and email address.
The body of the proposed order and certificate of service must include the name, address, telephone number and e-mail address of the client to whom the pleadings will be sent.
Document Type
Proposed Order
The caption of every proposed order must describe the order's subject and the court's ruling.
All Orders must describe, in the caption, the subject and ruling of the court, i.e. “Order Granting Plaintiff’s Motion for Partial Summary Judgment on Liability.”
Document Type
Proposed Order
Every proposed order must include a full Certificate of Service; the abbreviation “CC” is insufficient.
A Certificate of Service must be included in the proposed order. CC is not sufficient.
Document Type
Proposed Order
The submitting party must state that opposing counsel reviewed and approved the order’s form when submitting it to the Court for review.
Must indicate that opposing counsel has reviewed and approved the form of the order when submitting to the Court for review.
Document Type
Cover Letter
Proposed orders must contain the prescribed Certificate of Service language identifying the Florida Courts E-Filing Portal and electronic service.
Please utilize the following language in proposed orders: CERTIFICATE OF SERVICE I HEREBY CERTIFY that the foregoing was filed with the Clerk of the Court on the date set forth in the electronic signature below by using the Florida Courts E-Filing Portal System. Accordingly, a copy of the foregoing is being served on this day to all attorney(s)/interested parties identified on the ePortal Electronic Service List, via transmission of Notices of Electronic Filing generated by the ePortal System.
Document Type
Proposed Order
A motion in limine is decided on written submissions rather than a hearing and must be emailed to chambers with a cover letter, supporting and opposition memoranda, and a proposed order.
Motions in Limine are not set for hearing. Please follow our procedures on Motions in Limine in the link below. The judge requires written submissions. A cover letter, the Motion in limine, the Memorandum of Law in favor, the Memorandum of Law in opposition and a proposed order. This should provided in one email to 34orange@ninthcircuit.org
Document Type
Motion In Limine
A motion to compel seeking attorney’s fees must include, at filing, a statement certifying the good-faith conferral or attempted conferral and inability to resolve the dispute.
If you are seeking attorney’s fees, you must, before filing a Motion to Compel pursuant to Fla. R. Civ. P 1.380, confer with counsel for the opposing party in a good-faith effort to resolve by agreement the issues raised, and shall file with the court at the time of filing of the motion, a statement certifying that counsel has conferred or attempted to confer with opposing counsel and that counsel have been unable to resolve the dispute.
Document Type
Motion To Compel
Discovery motions, motions to compel, and protective-order motions must be filed and set for hearing and must include certification of a good-faith attempt to resolve the dispute.
The mere filing of a Discovery Motion, Motion to Compel or Motion for Protective Order is insufficient. A Motion must be filed and set for hearing to bring the matter to the Court’s attention. Motions to compel, as well as all discovery motions must comply with the Florida Rules of Civil Procedure including, but not limited to, a certification of a good faith attempt to resolve that matter without court action.
Document Type
Discovery Motion
Parties must email Chambers a completed pre-trial checklist and pre-trial statement by 10:00 A.M. on the day before the pre-trial conference.
Parties shall email to Chambers by 10:00 A.M. the day before the Pre-Trial Conference a completed Pre-Trial Check List and Pre-Trial Statement.
Document Type
Pretrial Checklist And Pretrial Statement
Closing the case requires a dismissal or judgment covering all defendants and claims; a notice of settlement alone is insufficient.
A Notice of Settlement is not sufficient to close the case. A dismissal or judgment as to all defendants/claims is required.
Document Type
Dismissal Or Judgment As To All Defendants Claims
A final report from each primary treating physician is required and should address the need for future care and, if possible, approximate costs.
A final report from each primary treating physician with an indication of the need for, or the lack of need for, future care and, if possible the approximate costs.
Document Type
Final Medical Report
Copies of initial medical records are required, including the history and physical and, if hospitalization occurred, admission, discharge, and summary resume records.
Copies of the initial medical records including the history and physical showing the presenting condition, if hospitalized the admission and discharge and summary resume will be necessary.
Document Type
Initial Medical Records
When the injury or treatment results in scarring or disfigurement, photographs of the child after the incident and of the present condition are required.
If the injury or treatment involves resulting scarring or disfigurement, photographs of the child after the incident and photographs of the present condition will be required.
Document Type
Photographs
If an annuity will be purchased, the Court requires a copy of specified information about its cost, value, payment schedule, company, owner, relationships, and rating.
If an annuity is to be purchased, the Court will need a copy of the information setting forth the cost, present value, payment schedule, the name of the company that will be used, the name of the owner of the annuity and its relationship to those companies being released, as well the rating of the company.
Document Type
Annuity Information
A copy of the release and relevant settlement agreements, together with counsel-review assurances and written confirmation of the parties' intended limited release, must be provided.
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.
Document Type
Release And Settlement Agreement
Counsel with settlement authority must confer before scheduling the motion hearing and include a Certificate of Compliance in the Notice of Hearing; counsel scheduling the hearing must arrange the conference.
Counsel with full authority to resolve the matter shall Page 3 of 7 ===== PAGE 4 ===== confer before scheduling the hearing on the motion to attempt to resolve or otherwise narrow the issues raised in the motion, and include a Certificate of Compliance (attached hereto as "Exhibit A") that the conference has occurred in the Notice of Hearing filed with the court. It shall be the responsibility of counsel who schedules the hearing to arrange the conference.
Document Type
Notice Of Hearing
The Notice of Hearing must include a Certificate of Compliance stating whether the meet-and-confer occurred, documenting any good-faith attempts, and identifying the conference date, participating attorneys, and specific results.
Counsel shall include in the Notice of Hearing the Certificate of Compliance 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 ofthe conference, the names of the participating attomeys, and the specific results obtained.
Document Type
Notice Of Hearing
A lawyer in the certifying firm with authority to resolve the matter must certify a good-faith attempt to contact opposing counsel in person, by telephone, or by video conference.
I HEREBY CERTIFY that a lawver in my firm with full authority to resolve this matter attempted in good faith to contact opposing counsel in person, by telephone or by video conference on:
Document Type
Motion
The certifying party states that an authorized firm lawyer had a substantive, good-faith discussion with opposing counsel before noticing the motion for hearing, but no agreement was reached.
I HEREBY CERTIFY that a lawver in my firm with full authority to resolve this matter had a substantive conversation in person, by telephone or by video conference with opposing counsel 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.
Document Type
Motion
Every order withdrawing counsel of record must include the client’s service address, email address, and telephone number.
Every Order of Withdrawal as counsel of record must contain an address and an e- mail address for service of papers upon the client and a telephone number for the client. Fla. R. Jud. Admin. 2.505 (f) (1)
Document Type
Order Of Withdrawal
Every motion must identify the particular rule, statute, and/or leading case on which it is based.
Every motion shall cite the particular rule or statute and/or leading case upon which the motion is based.
Document Type
Motion
A motion to dismiss must state its grounds and substantial legal matters specifically and with particularity; the Court may request a written response and then decide the matter in chambers without a hearing.
Fla.R.Civ.P. 1.140(b) relating to motions to dismiss requires that the “grounds . . . and the substantial matters of law to be argued shall be stated specifically and with particularity.” The Court may elect to request a written response from opposing counsel and then consider the matter in Chambers without a hearing.
Document Type
Motion To Dismiss
Each hearing notice must identify the specific motions and hearing method, provide remote-appearance information when applicable, and may not call up all pending motions; unnoticed or insufficiently noticed motions will not be heard.
Every notice must specify the motions to be heard. A notice calling up “all pending motions” is insufficient. Every notice must also specify the manner (e.g. telephone, video, in person) in which the motions are to be heard and provide appropriate information for remote appearances, if applicable. Motions not noticed, or insufficiently noticed, will not be heard.
Document Type
Notice Of Hearing
Every notice of hearing must state that the parties met in person and conferred on the issue presented to the Court.
All notices of hearing must reflect that the parties met, in person, and conferred on the subject being brought before the Court for resolution.
Document Type
Notice Of Hearing
Every motion for summary judgment must include a concise, non-argumentative statement of all uncontested material facts and a brief statement of the legal propositions relied upon.
To comply with this rule, every such motion must contain (a) a concise, non-argumentative statement of all uncontested material facts and (b) a brief statement of the legal proposition(s) relied upon.
Document Type
Motion For Summary Judgment
The Notice for Trial must state whether the case will be tried by jury or non-jury and estimate the total trial duration in days or hours.
The notice must indicate whether the case is to be tried by jury or non-jury and estimate the total number of days or hours needed for the trial.
Document Type
Notice Of Trial
If a removed case is finally disposed of in federal court, removal counsel must file the federal final order or judgment and Final Disposition Form 1.998 with the state court clerk, which will then close the case.
If, however, the case is finally disposed of in Federal Court, including all pendent claims, counsel who sought the removal will file with the Clerk of this Court a copy of the Final Order or judgment of the Federal District Court together with Final Disposition Form 1.998 and the clerk will close the case.
Document Type
Federal Case Closure Filing
After final judgment, dismissal, or voluntary dismissal, prevailing counsel or settlement-paper counsel must promptly file Final Disposition Form 1.998 with the Clerk, and the form may accompany the proposed final order or judgment.
When a case had been finally disposed of by Final Judgment, Final Order of Dismissal or Notice of Voluntary Dismissal, counsel for prevailing party or counsel preparing settlement papers must promptly file with the Clerk Final Disposition Form 1.998 (found in the forms appended to the Florida Rules of Civil Procedure). The form may accompany the proposed Final Order or Final Judgment and the Judge will send it to the Clerk for filing along with the signed Final Order or Final Judgment.
Document Type
Final Disposition Form
The Joint Pretrial Statement must identify disputed testimony by page and line and include each party’s argument and supporting authority.
The parties shall include in the Joint Pretrial Statement a page‐and‐line description of any testimony that remains in dispute after an active and substantial effort at resolution, together with argument and authority for each party’s position.
Document Type
Joint Pretrial Statement
Counsel must file jointly proposed jury instructions and one jointly proposed jury verdict form with the clerk no later than 10 days before trial begins.
Not later than ten (10) days before the trial period is to commence, counsel shall file with the clerk a set of jointly‐proposed jury instructions, together with a single jointly‐ proposed jury verdict form.
Document Type
Jointly Proposed Jury Instructions
Each proposed order must be accompanied by an attorney e-filed cover letter bearing the filing stamp across the top and indicating opposing counsel's approval of the order's form; the cover letter, but not the proposed order, must be e-filed with the Clerk.
All proposed orders must be accompanied by an e-filed cover letter (the cover letter must have the filing stamp across the top) and must indicate that opposing counsel has reviewed and approved the form of the order when submitting to the Court for review. The cover letter (but not the proposed order) must be e-filed by the attorney with the Clerk.
Document Type
Cover Letter
Proposed orders must include the prescribed certificate of service language describing e-filing through the Florida Courts E-Filing Portal and electronic service on persons on the ePortal Electronic Service List.
Please utilize the following language in proposed orders: CERTIFICATE OF SERVICE I HEREBY CERTIFY that the foregoing was filed with the Clerk of the Court on the date set forth in the electronic signature below by using the Florida Courts E-Filing Portal System. Accordingly, a copy of the foregoing is being served on this day to all attorney(s)/interested parties identified on the ePortal Electronic Service List, via transmission of Notices of Electronic Filing generated by the ePortal System.
Document Type
Proposed Order
Exhibits must be exchanged, their pages numbered and initialed, and objections noted.
3. EXHIBITS: Must be Exchanged / Pages must be numbered and initialed / Objections must be noted /
Document Type
Exhibits
All exhibits must be tagged and marked before the first day of trial, with tags available from the Trial Clerk.
Must be Tagged* (*All exhibits must be marked before the first day of trial. Tags are available from the Trial Clerk.
Document Type
Exhibits
A completed pretrial checklist must be brought to the pretrial conference and not filed.
Bring (do not file) completed checklist to Pre-Trial Conference
Document Type
Pretrial Checklist
Filing & Service rules
Electronic Filing Rules
The attorney must e-file the cover letter, but not the proposed order, with the Clerk.
The cover letter (but not the proposed order) must be e-filed by the attorney with the Clerk.
Page 8 | ORDERS AND RULINGS — Submitting Orders to Chambers
The Administrative Judge must sign and electronically file an order of disqualification with copies to affected judges, counsel of record, and unrepresented parties.
Orders of disqualification shall be immediately forwarded to the Administrative Judge for reassignment. The Administrative Judge will sign and e-file the order with copies to the affected Judges, counsel of record and unrepresented parties.
Page 3 | SECTION 4. ASSIGNMENT, REASSIGNMENT AND TRANSFER OF CASES.
All filings in the Civil Division must be made electronically under the cited Florida Supreme Court electronic-access standards.
All filings in Civil Division are to be done electronically in accordance with Florida Supreme Court Standards for Electronic Access to the Courts - Version 18.0 - Updated August 2017, (as noted in AOSC09-30).
Page 4 | SECTION 5. COURT FILES AND RECORDS.
The hearing notice must be electronically filed at least five working days before the hearing.
Notice must be e-filed no less than five (5) working days before the hearing.
Page 6 | SECTION 10. HEARINGS. (A) Regularly Scheduled Hearings. (2)
Each proposed order must be accompanied by an e-filed, filing-stamped cover letter stating that opposing counsel approved the order or will submit a competing order.
All proposed orders must be accompanied by an e-filed cover letter (the cover letter must have the filing stamp across the top) and must indicate that opposing counsel has reviewed and approved the form of the order or that opposing counsel will be submitting a competing order. Rule 2.525, Fla R. Jud. Admin.
Page 9 | SECTION 12. ORDERS AND JUDGMENTS. (B) Requirements for Orders. (1)
Orders must be electronically filed through the statewide ePortal, and when any party is served by U.S. Mail, chambers must receive paper copies and stamped addressed envelopes for each party not receiving electronic service.
Orders will be electronically filed through the statewide ePortal. If any party receives service by U.S. Mail, rather than through the ePortal, sufficient paper copies of the order and stamped, addressed envelopes must be provided to chambers for each party not receiving electronic service. Rule 2.525, Fla. R. Jud. Admin.
Page 9 | SECTION 12. ORDERS AND JUDGMENTS. (B) Requirements for Orders. (10)
The attorney must e-file the cover letter, and not the proposed order, with the Clerk.
The cover letter (but not the proposed order) must be e-filed by the attorney with the Clerk.
Page 1 | All Submitted Orders
Filing Timing and Cure Windows
Motions in limine must be heard before trial week.
HEARD BEFORE trial week.
Page 2 | Motions in Limine
Motions in limine must be filed before pretrial.
8. MOTIONS IN LIMINE: Must be filed before Pre-trial
Page 2 | Motions in Limine
All motions in limine must be filed by the deadline in the OCMC and/or Uniform Order unless the Court grants an extension.
Any and all Motions in Limine from any party must be filed no later than the timeframe set forth in the OCMC and/or UNIFORM ORDER unless extended by this Court.
Page 1 | Standing Procedures for Motions in Limine
Opposing counsel has five business days to file an optional written response.
Opposing counsel will have five (5) business days to file a written response if they wish.
Page 1 | Standing Procedures for Motions in Limine
When a hearing is canceled less than four hours beforehand and the judge’s notification cannot be confirmed, counsel must appear or send someone to inform the judge.
If the hearing is cancelled less than 4 hours beforehand, and counsel cancelling the hearing has not been able to confirm the Judge has been informed, counsel shall appear or have someone appear on counsel’s behalf to so inform the Judge.
Page 6 | Miscellaneous Issues re: Hearings
When counsel is asked to prepare an order, it must be drafted and circulated within three working days.
Drafted and circulated within three (3) working days
Page 7 | ORDERS AND RULINGS — Proposed Orders
A proposed order must be submitted to the court within seven days after the hearing, with a copy provided to opposing counsel.
Submitted to the Court within seven (7) days of the hearing, with a copy to opposing counsel.
Page 7 | ORDERS AND RULINGS — Proposed Orders
A certificate of service must be filed no later than three days after the order's date when parties are served outside the Florida Courts eFiling Portal.
If there are parties not receiving service through the Florida Courts efiling Portal, counsel will serve a copy of the Order via U.S. Mail to the non-efiling parties and file a certificate of service in the Court file no later than three days from the date of this order.
Page 8 | ORDERS AND RULINGS — Submitting Orders to Chambers — Certificate of Service
The exhibit-production steps must occur after the good-faith telephone conference and no later than five business days before the hearing.
After the substantive, good faith telephone conference and no later than 5 business days before the hearing, the parties must:
Page 10 | PREPARING EVIDENCE FOR THE VIDEOCONFERENCE
The offering party must file deposition designations, and responsive cross-designations must be filed within five business days afterward.
Designations of the offering party must be filed, and responsive cross-designations filed within five (5) business days thereafter
Page 5 | Use of Depositions
Joint jury instructions and verdict forms must be prepared and submitted to the court at least five business days before trial begins.
Joint jury instructions and verdict forms are to be prepared and submitted to the Court at least 5 business days prior to the beginning of the trial period.
Page 6 | Jury Instructions and Verdict Forms
The agreed jury instructions must be delivered to the court in hard copy and by email at least five business days before trial begins.
The agreed set of jury instructions must be provided to the Court by hard copy as well as via e-mail no less than 5 business days prior to the beginning of the trial.
Page 6 | Jury Instructions and Verdict Forms
Trial briefs are mandatory and must be submitted three business days before trial.
Trial Briefs (mandatory): 3 business days prior to Trial. (§10)(e.g. by Wednesday for the trial period commencing the following Monday) A hard copy must be delivered to chambers 3 business days prior to Trial.
Page 3 | SUMMARY OF NON‐JURY DEADLINES
The signed Joint Pretrial Statement must be filed, with a hard copy delivered to chambers, no later than three business days before the Pretrial Conference.
Joint Pretrial Statement: Signed by attorneys/pro se parties and filed and a hard copy delivered to chambers no later than 3 business days prior to Pretrial Conference. (§6b)
Page 3 | SUMMARY OF NON‐JURY DEADLINES
The transfer filing fee must be delivered within 30 days after entry of the order transferring the case.
When an order has been entered transferring a case from an Orange or Osceola Circuit Court to another Circuit Court on grounds of improper venue or forum non conveniens, the party designated in the order to pay the transfer costs within thirty (30) days of the date of the order, shall deliver to the Clerk the filing fee for the other Court to accompany the file upon its transfer.
Page 4 | SECTION 4. ASSIGNMENT, REASSIGNMENT AND TRANSFER OF CASES.
The hearing notice must be filed no less than five working days before the hearing.
Notice must be e-filed no less than five (5) working days before the hearing.
Page 6 | SECTION 10. HEARINGS. (A) Regularly Scheduled Hearings. (2)
If counsel or pro se parties fail or refuse to cooperate in scheduling depositions, the party or attorney trying to schedule must file a Motion to Set Deposition and give at least five (5) days’ notice of an ex parte or short matters hearing.
If counsel, or pro se Parties, fail or refuse to cooperate in scheduling depositions, the party or attorney attempting to schedule the deposition shall file a Motion to Set Deposition and notice such motion for an ex parte or short matters hearing with at least five (5) days’ notice.
Page 11 | SECTION 14. DEPOSITION GUIDELINES
For a discovery-dispute hearing, the movant must provide the specified case and discovery materials to the court at least five days before the hearing.
Movants shall provide the Court with copies of the correct complaint/petition, answer(s) if served, and overdue requests for discovery and any applicable response at least five (5) days prior to the hearing.
Page 11 | SECTION 13. DISCOVERY
Deposition designations must be made at the attorneys’ or parties’ meeting, and cross-designations must be made within three days afterward.
At the meeting of the attorneys/pro se parties, deposition designations shall be made. Cross designations shall be made within three (3) days after the meeting.
Page 1 | Additional Pretrial Guidelines for Division 34 — Deposition Designations
Defendants must disclose intended expert witnesses no later than 60 days before the pretrial conference and provide three days when retained experts will be ready for deposition.
By Defendant(s): Not later than 60 days before the date of the pretrial conference, Defendant(s) shall disclose all expert witnesses (including treating physicians) that in good faith Defendant(s) actually intend to call at trial. Disclosure includes providing three (3) days when the retained experts will be ready, with opinion, for deposition.
Page 1 | Additional Pretrial Guidelines for Division 34 — Expert Witness Disclosure
Motions in limine must be scheduled and heard no later than one week before the trial period begins.
Motions in Limine must be scheduled and heard no later than one week prior to the beginning of the trial period.
Page 1 | Additional Pretrial Guidelines for Division 34 — Scheduling of Motions in Limine
Motions to exclude expert witnesses must be heard at least 30 days before the pretrial conference unless good cause supports later scheduling.
Motions to exclude expert witnesses must be heard at least thirty (30) days prior to pre‐trial conference unless good cause is shown for scheduling the matter later.
Page 1 | Additional Pretrial Guidelines for Division 34 — Frye/Daubert Hearings
Plaintiffs must disclose intended expert witnesses no later than 90 days before the pretrial conference and provide three days when retained experts will be ready for deposition.
By Plaintiff(s): Not later than 90 days before the date of the pretrial conference, Plaintiff(s) shall disclose all expert witnesses (including treating physicians) that in good faith Plaintiff(s) actually intend to call at trial. Disclosure includes providing three (3) days when the retained experts will be ready, with opinion, for deposition.
Page 1 | Additional Pretrial Guidelines for Division 34 — Expert Witness Disclosure
A copy of the jointly proposed jury instructions and verdict form must be sent to the court both in hard copy and by email in Word format no later than seven days before trial begins.
A copy of the single set of jointly‐proposed jury instructions and verdict form shall be forwarded to the court (i) in hard copy AND (ii) via email to the Judicial Assistant at 34orange@ninthcircuit.org in WORD FORMAT no later than seven (7) days before trial period is to commence.
Page 2 | Additional Pretrial Guidelines for Division 34 — Jury Instructions
Counsel must not send a proposed order to the Court until opposing counsel has approved its form, because the Court does not hold orders awaiting approval or objection.
The Court does not hold orders waiting for approval or objection. Please do not send proposed Orders to the Court until you have approval as to the form by opposing counsel.
Page 1 | Other useful information
All exhibits must be marked before the first day of trial.
(*All exhibits must be marked before the first day of trial.
Page 1 | Exhibits
A party offering deposition testimony must provide written page-and-line designations within four days after pretrial.
By the party offering the testimony: 4 days after pretrial.
Page 2 | Depositions, Interrogatories & Request and Responses to Admissions
Cross-designations responding to deposition designations must be made within eight days after pretrial.
Cross Designations in response to the designations: 8 days after pretrial.
Page 2 | Depositions, Interrogatories & Request and Responses to Admissions
Objections to deposition portions must be called up, set for hearing, and ruled upon no later than ten days after pretrial.
Objections: Objections to portions of depositions must be called up, set for hearing, and ruled upon no later ten (10) days after the pretrial.
Page 2 | Depositions, Interrogatories & Request and Responses to Admissions
If no written objection is filed within five days of e-filing the motion and affidavit, the movant must promptly present a proposed order to the presiding judge during an ex parte proceeding or by mail.
If no written objection is filed by an opposing party within five (5) days of e-filing the motion and affidavit, the movant must then promptly present a proposed order to the presiding Judge either during ex parte or by mail.
Page 6 | SECTION 8. INDIGENT PARTIES
The court will not hear motions in limine during the trial period unless the movant shows good cause.
No Motions in Limine will be heard during the trial period absent a showing of good cause.
Page 1 | Additional Pretrial Guidelines for Division 34 — Scheduling of Motions in Limine
Submitted orders are processed when the judge has time; if the judge or judicial assistant is unavailable, processing may be delayed, and orders received while the judge is away are processed upon the judge's return in the order received.
Orders are processed as the Judge has time out of Court. If the Judge is out of the office, the Order(s) will be processed upon return in the order they were received. Additionally, there may be a delay if the JA is out of the office.
Page 1 | Processing of submitted orders
Service and Proof of Service Rules
If not all parties use e-filing, counsel must serve the order on non-efiling parties by U.S. Mail and file a certificate of service no later than three days after the order's date.
If all parties are not on e-filing, counsel will serve a copy of the Order via U.S. Mail to the non-efiling parties and file a certificate of service in the court file no later than three days from the date of the order.
Page 4 | PROCEDURES FOR REMOTE APPEARANCE — Courtesy Copies
Opposing counsel must be copied on every email sent to the court.
Opposing counsel must be copied on any email to the Court.
Page 6 | Miscellaneous Issues re: Hearings
Counsel must serve the proposed order by U.S. mail on parties not receiving service through the Florida Courts eFiling Portal.
If there are parties not receiving service through the Florida Courts efiling Portal, counsel will serve a copy of the Order via U.S. Mail to the non-efiling parties and file a certificate of service in the Court file no later than three days from the date of this order.
Page 8 | ORDERS AND RULINGS — Submitting Orders to Chambers — Certificate of Service
The proposed order must be served that day on all attorneys and interested parties on the ePortal electronic service list through Notices of Electronic Filing.
Accordingly, a copy of the foregoing is being served on this day to all attorney(s)/interested parties identified on the ePortal Electronic Service List, via transmission of Notices of Electronic Filing generated by the ePortal System.
Page 8 | ORDERS AND RULINGS — Submitting Orders to Chambers — Certificate of Service
Each witness must receive copies of all pre-marked Bates-stamped exhibits before the hearing.
The witness must be provided copies of all pre-marked, Bates- stamped exhibits prior to the hearing.
Page 10 | PREPARING WITNESSES FOR THE VIDEOCONFERENCE
Counsel and pro se parties must exchange all Bates-stamped exhibits no later than five business days before the evidentiary hearing or non-jury trial.
No later than 5 business days before the hearing, counsel and/or pro se parties shall exchange any and all exhibits, which must be Bates-stamped.
Page 10 | PREPARING EVIDENCE FOR THE VIDEOCONFERENCE
Evidentiary objections must be filed with the clerk, and objections not noted are waived.
The objections shall be filed with the Clerk and any objections not noted are waived.
Page 10 | PREPARING EVIDENCE FOR THE VIDEOCONFERENCE
No later than five business days before the hearing, the parties must provide exhibits to the other party and witnesses and mail two hard-copy sets of the exhibits and filed objections to the court, one for the judge and one for the clerk.
provide a set of the exhibits to the other party and the witness(es), and mail 2 hard copies of the exhibits and the filed objections (one for the Judge and one for the Clerk) to the Court for use at the hearing.
Page 10 | PREPARING EVIDENCE FOR THE VIDEOCONFERENCE
Disqualification orders must be promptly sent to the Administrative Judge for reassignment, who will sign and electronically file them and provide copies to affected judges, counsel of record, and unrepresented parties.
Orders of disqualification shall be immediately forwarded to the Administrative Judge for reassignment. The Administrative Judge will sign and e-file the order with copies to the affected Judges, counsel of record and unrepresented parties.
Page 3 | SECTION 4. ASSIGNMENT, REASSIGNMENT AND TRANSFER OF CASES.
A copy of the proposed order must be served electronically on all attorneys and interested parties identified on the ePortal Electronic Service List by transmission of Notices of Electronic Filing.
Accordingly, a copy of the foregoing is being served on this day to all attorney(s)/interested parties identified on the ePortal Electronic Service List, via transmission of Notices of Electronic Filing generated by the ePortal System.
Page 1 | Certificate of Service
If any party does not receive service through the Florida Courts e-filing Portal, counsel must serve the order by U.S. Mail and file a certificate of service in the Court file no later than three days after the order's date.
If there are parties not receiving service through the Florida Courts efiling Portal, counsel will serve a copy of the Order via U.S. Mail to the non-efiling parties and file a certificate of service in the Court file no later than three days from the date of this order.
Page 1 | Certificate of Service
When any party receives service by U.S. Mail, counsel must serve the order by U.S. Mail to non-efiling parties and file a certificate of service no later than three days from the order's date.
if any party receives service by U.S. Mail, counsel will serve a copy of the Order via U.S. Mail to the non-efiling parties and file a certificate of service in the Court file no later than three days from the date of the order.
Page 1 | Proposed Orders where some parties receive service by U.S. Mail
Changed expert opinions or conclusions based on new information must be disclosed immediately, accompanied by a revised or supplemental report and dates for updated depositions.
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.
Page 5 | Opinions Not Contained in Written Reports
The examining physician or healthcare provider must provide all counsel a detailed written report no later than 14 business 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 14 business days after the day of the examination.
Page 5 | Written Reports
When a proposed deposition date falls within 14 days after the examination, the written report must reach deposition counsel at least five days before deposition.
Should any of the dates be within 14 days of the examination the above referred to report shall be provided to deposing counsel no later than 5 days before the deposition date.
Page 5 | Written Reports
When scheduling the examination, the requesting party must provide opposing counsel with at least three dates for the examiner's oral deposition.
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.
Page 5 | Written Reports
The attorney noticing a hearing must provide all parties, including pro se litigants, at least five days' notice.
The attorney noticing the hearing must provide at least 5-days’ notice Notice of of the hearing to all parties, including pro se litigants.
Page 3 | PROCEDURES FOR REMOTE APPEARANCE — Notice of Hearing
Mailed uncontested or agreed matters should include extra copies and addressed, stamped envelopes, with a copy enclosed for any unrepresented litigant who has not opted into electronic service.
Uncontested or agreed matters that are mailed should include extra copies and addressed and stamped envelopes with a copy to any unrepresented litigant who has not opted-in to e-service.
Page 7 | (B) Ex Parte Matters
Counsel submitting proposed orders or judgments must provide sufficient copies and stamped, self-addressed envelopes to parties not participating in electronic filing.
When submitting proposed orders or judgments, counsel shall also include sufficient copies and self-addressed, stamped, envelopes for all parties who do not participate in electronic filing.
Page 9 | SECTION 12. ORDERS AND JUDGMENTS. (A) Who Is To Prepare.
When service is by U.S. Mail, chambers must receive sufficient paper copies of the order and stamped addressed envelopes for each party not receiving electronic service.
If any party receives service by U.S. Mail, rather than through the ePortal, sufficient paper copies of the order and stamped, addressed envelopes must be provided to chambers for each party not receiving electronic service. Rule 2.525, Fla. R. Jud. Admin.
Page 9 | SECTION 12. ORDERS AND JUDGMENTS. (B) Requirements for Orders. (10)
Counsel must provide addressed, stamped envelopes to the Judicial Assistant for service of default judgments.
Counsel must provide addressed and stamped envelopes to the Judicial Assistant for service of default judgments.
Page 9 | SECTION 12. ORDERS AND JUDGMENTS. (C) Requirements for Judgments. (4)
Filing Fees and Waivers
The party designated in a venue- or forum-non-conveniens-transfer order must deliver the other court’s filing fee to the Clerk within 30 days after the order so the fee accompanies the transferred file.
When an order has been entered transferring a case from an Orange or Osceola Circuit Court to another Circuit Court on grounds of improper venue or forum non conveniens, the party designated in the order to pay the transfer costs within thirty (30) days of the date of the order, shall deliver to the Clerk the filing fee for the other Court to accompany the file upon its transfer.
Page 4 | SECTION 4. ASSIGNMENT, REASSIGNMENT AND TRANSFER OF CASES.
A party seeking waiver of Clerk’s fees and costs for the specified appeals must electronically file a motion with an affidavit of insolvency.
A party claiming indigency who desires to have Clerk’s fees and costs waived in connection with an appeal from County Court to the Civil Division of this Court or from the Civil Division of this Court to an appellate court must e-file a motion accompanied by an affidavit of insolvency.
Page 6 | SECTION 8. INDIGENT PARTIES
When County Court has subject-matter jurisdiction, the assigned judge must order transfer and specify the party responsible for any necessary filing fees; the Clerk assigns the case after receiving the case and fee.
When this Court finds the County Court has subject matter jurisdiction, the assigned Judge shall enter an order transferring the case and specifying which party shall pay any necessary filing fees. When the case and filing fee has been received, the Clerk shall assign the case to a Judge as if it was a newly filed case.
Page 4 | SECTION 4. ASSIGNMENT, REASSIGNMENT AND TRANSFER OF CASES.
A party seeking waiver of certain Clerk’s and Sheriff’s fees and costs must file the Clerk-provided affidavit of insolvency.
A party claiming indigency and seeking to have certain Clerk’s and Sheriff’s fees and costs waived must complete and file an affidavit of insolvency provided by the Clerk.
Page 5 | SECTION 8. INDIGENT PARTIES
For a represented party, the attorney may submit the written certificate required by Florida Statute 57.018(1) for waiver of fees and costs.
If a party is represented, the attorney may submit a written certificate as required by Florida Statute 57.018 (1).
Page 5 | SECTION 8. INDIGENT PARTIES
Courtesy Copy Requirements
Trial briefs are not required for jury trials, but for non-jury trials hard copies must reach chambers and an electronic Word copy must be emailed or provided on a flash drive at least three business days before trial.
10. TRIAL BRIEFS: If jury trial, not required. If non-jury trial, hard copies must be delivered to Judge’s Chambers as well as a copy emailed in Word to Chambers, or in the alternative, provided on a flash drive at least three (3) business days before trial.
Page 2 | Trial Briefs
For ex parte and short matters, courtesy copies of the notice of hearing and motion must be emailed to the judicial assistant at least three business days before the hearing after checking the AI calendar; late copies may result in cancellation of the hearing.
A courtesy copy of the notice of hearing and motion must be provided to the Court at least 3 business days before the hearing. Please check AI Courtesy calendar before emailing the JA to make sure the date is not full. Copies Any copies delivered after this deadline may not be reviewed and may cause the hearing to be canceled. Courtesy copies must be provided for ex parte and short matters.
Page 3 | PROCEDURES FOR REMOTE APPEARANCE — Courtesy Copies
The cover letter, motions, supporting memoranda, and/or case law to be heard must reach chambers by email and hard copy at least five (5) business days before the hearing.
Cover letter, Motion(s), supporting memoranda and/or case law to be heard must be received, by email AND hard copy to chambers at least five (5) business days prior to the hearing to ensure an opportunity for the Court to review.
Page 7 | COURTESY COPIES REQUIRED
Failure to provide both email and hard-copy courtesy copies to chambers at least five business days before the hearing may result in cancellation of the hearing.
Failure to provide courtesy copies by email AND hard copy to chambers at least five (5) business days prior to the hearing may result in the hearing being cancelled.
Page 7 | COURTESY COPIES REQUIRED
A copy of a motion for rehearing, reconsideration, or new trial must be sent directly to chambers when the motion is filed.
Upon filing said Motion, you must send a copy directly to chambers for review as the Clerk does not provide them to the Court.
Page 9 | MOTIONS FOR REHEARING, RECONSIDERATION OR NEW TRIAL
Counsel must provide courtesy copies of materials relied on at a scheduled hearing to the court and opposing counsel at least five court days before the hearing.
Counsel is required to provide the court (and opposing counsel) \ /ith courtesy copies of any memoranda, case law or any other materials on which counsel may rely at a scheduled hearing at least five (5) court days before the scheduled hearing.
Page 4 | 7. Courtesy copies
One hard copy of the Joint Pretrial Statement must be delivered to chambers no later than three business days before the Pretrial Conference.
Joint Pretrial Statement: Signed by attorneys/pro se parties and filed and a hard copy delivered to chambers no later than 3 business days prior to Pretrial Conference. (§6b)
Page 3 | SUMMARY OF NON‐JURY DEADLINES
One hard copy of the trial brief must be delivered to chambers three business days before trial.
A hard copy must be delivered to chambers 3 business days prior to Trial.
Page 3 | SUMMARY OF NON‐JURY DEADLINES
A motion for rehearing, reconsideration, or new trial must be accompanied by a simultaneous chambers copy sent directly to the Judge with a cover letter requesting a hearing if desired.
Counsel filing such a motions shall simultaneously provide a chambers copy directly to the Judge with a cover letter requesting a hearing, if one is desired.
Page 7 | (F) Hearings on Motions for Rehearing, Reconsideration or New Trial
If counsel files a legal memorandum in support of or opposition to a motion, counsel must provide the Judge with chambers copies of the memorandum and its cited legal authorities.
If filed, counsel must furnish the Judge with chambers copies of the memorandum and copies of any legal authorities cited therein.
Page 8 | SECTION 11. MOTION PRACTICE GENERALLY. (B) Chambers Copies of Memorandums
Chambers copies and authority lists must be accompanied by a cover letter identifying the case style and number and hearing date and time, affirmatively showing service on opposing counsel, and delivered to the Judge at least five business days before the hearing.
Chambers copies and authority lists must be under cover letter referencing the case style and number and stating the date and time of the hearing, show affirmatively that a copy has been sent to opposing counsel and shall be delivered to the Judge at least five (5) business days before the hearing.
Page 8 | SECTION 11. MOTION PRACTICE GENERALLY. (B) Chambers Copies of Memorandums
Opposing counsel must receive the same hearing information provided to the court.
Copy opposing counsel with the same information provided to the Court.
Page 7 | COURTESY COPIES REQUIRED
When all parties participate in e-filing, courtesy copies and the proposed order may be emailed after the hearing.
If all parties participate in e-filing, courtesy copies along with the proposed order in Word may be provided by email to 34orange@ninthcircuit.org, after the hearing takes place.
Page 4 | PROCEDURES FOR REMOTE APPEARANCE — Courtesy Copies
A copy of the Notice for Trial should be sent directly to the judge’s chambers.
A copy of the Notice for Trial should be sent directly to the Judge’s Chambers.
Page 12 | SECTION 16. SETTING CASES FOR TRIAL
Sealing & Redaction Procedures
The closing statement must not be filed publicly with the court; it must be submitted directly under seal or brought to the hearing if one is held.
The closing statement should NOT befiled with the Court and should be submitted to the Court directly under seal or be brought to the hearing if one is held.
Page 2 | Closing Statement
Filing Bundling Requirements
Orders and judgments may not be submitted to the judge for safekeeping while awaiting an objection.
Orders and judgments may not be submitted to the Judge to hold waiting for an objection.
Page 10 | SECTION 12. ORDERS AND JUDGMENTS. (D) How Presented. (2)
Pre-Motion Conference Requirements
Before a motion in limine is set for hearing, counsel—not support or paralegal personnel—must confer by telephone, in person, or both on every requested motion.
Before setting the Motions in Limine for hearing before the Court, counsel, not support nor paralegal personnel, must meet either by telephone and/or in person and confer on each and every requested Motion in Limine.
Page 1 | Standing Procedures for Motions in Limine
A motion in limine is abandoned if it is untimely or, when unresolved, was not discussed at the meet-and-confer and set for hearing.
Any Motions in Limine not timely filed and/or not discussed at the meet and confer and (if unresolved) not set for hearing will be considered abandoned.
Page 2 | Standing Procedures for Motions in Limine
Counsel with settlement authority must confer before scheduling a motion hearing to resolve or narrow the motion’s issues and must include a Certificate of Compliance in the Notice of Hearing.
Counsel with full authority to resolve the matter shall confer before scheduling the hearing on the motion to attempt to resolve or otherwise narrow the issues raised in the motion, and include a Certificate of Compliance in the Notice of Hearing filed with the Court.
Page 2 | HOW TO SCHEDULE A HEARING
Before filing a motion to compel for attorney’s fees, counsel must confer in good faith with opposing counsel and file a certification of the conferral or attempted conferral and the unresolved dispute.
If you are seeking attorney’s fees, you must, before filing a Motion to Compel pursuant to Fla. R. Civ. P 1.380, confer with counsel for the opposing party in a good-faith effort to resolve by agreement the issues raised, and shall file with the court at the time of filing of the motion, a statement certifying that counsel has conferred or attempted to confer with opposing counsel and that counsel have been unable to resolve the dispute.
Page 9 | ATTORNEY’S FEES IN DISCOVERY DISPUTES
A mandatory meet-and-confer process applies to all motions set for hearing in the circuit civil division, except motions for injunctive relief without notice, judgment on the pleadings, summary judgment, or maintenance of a class action.
A mandatory meet and confer process is hereby established, as set forth below, for all motions to be setfor hearing in the circuit civil division and to occur before scheduling the hearing except for the following motions: injunctive relief without notice; judgment on the pleadings; summary judgment; or to permit maintenance of a class action.
Page 3 | 6. Mandatory meet and confer process
A qualifying conference requires a substantive, good-faith conversation in person, by telephone, or by video conference; merely attempting to confer or exchanging ultimatums by fax, email, or letter does not satisfy the requirement.
The term "confer" requires a substantive conversation in person or by telephone or video conference in a good faith effort to resolve the motion without the need to schedule a hearing, and does not envision an exchange of ultimatums by far, e-mail or letter. Counsel who merely attempt to confer have not conferred for purposes of this Order.
Page 4 | 6. Mandatory meet and confer process
After reviewing the memoranda and any responses, the Court will either rule without a hearing or direct that a hearing be set.
The Court will review the memorandums and responses thereto, if any, and either; a. Rule on the specifically disputed Motion(s) in Limine without a hearing; or b. Direct that a hearing be set on the disputed Motion in Limine.
Page 1 | Standing Procedures for Motions in Limine
Adjournment & Extension Requirements
A continuance request must be made immediately when the trial date is not workable, be written and signed by the requesting attorney and parties, state opposing counsel's position and prior continuance history, identify when the parties would be ready for trial, and comply with Florida rules 1.460 and 2.545(e).
Motions to Continue: If counsel believes the trial date is not workable, an immediate request for continuance should be made. All Motions to Continue must: (1) be in writing; (2) be signed by the attorney and the parties requesting same; (3) identify the position of opposing counsel on the motion; (4) indicate any other continuances that have been sought and/or granted or denied; (5) set forth when the parties will be ready for trial, if granted; and, (6) comply with Fla. R. Civ. P. 1.460 and Fla. R. Jud. Admin 2.545(e).
Page 2 | PRIOR TO PRE-TRIAL
A stipulated motion to continue does not extend the trial until the Court reviews it and enters an order, and attorneys must continue complying with the trial order until then.
Stipulated Motions to Continue will not result in the trial being continued unless and until the Court reviews the motion and enters an order on same. The Court may require a hearing on the Motion or conduct a Case Management Conference. The attorneys must comply with the requirements in the trial order until the Court grants a continuance of trial.
Page 2 | PRIOR TO PRE-TRIAL
Any extension of a procedural deadline must be obtained before the deadline expires, either by stipulation or, if that is unavailable, by motion and order.
Time limits specified in the rules and applicable orders and division procedures must be observed. If additional time is needed, an extension must be obtained before the time limit expires by stipulation or, failing that, by motion and order.
Page 11 | SECTION 13. DISCOVERY
The parties may not extend the pretrial-order deadlines by joint stipulation.
Joint stipulations to extend times set forth therein are not permitted.
Page 2 | PRIOR TO PRE-TRIAL
Chambers Communication Rules
Communications with the judicial office must comply with Canon 3, and all parties must be copied on emails unless an ex parte communication is authorized by law.
All communications with the judicial office must comply with Canon 3 of the Code of Judicial Conduct, which prohibits a judge from initiating, permitting, or considering ex parte communications and from considering other communications outside the presence of the parties concerning a pending or impending proceeding, unless authorized by law. All parties must be copied on any e-mail directed to the judicial office, unless an ex parte communication is authorized by law.
Page 1 | COMMUNICATIONS WITH THE JUDICIAL OFFICE
All communications to the judicial office must be sent by email to the Division 34 address, and the subject line must include the case number, case name, and relevant matter.
Method of Communication: ALL communications to the judicial office MUST be submitted by e-mail to 34orange@ninthcircuit.org. Division 34 emails sent to the Judicial Assistant’s personal email will go unanswered and will be deleted. The subject line must contain the case number, case name, and relevant matter (e.g., 2024 DR 001234 SC – Doe v. Doe - 2-Hour Hearing Requested.)
Page 1 | COMMUNICATIONS WITH THE JUDICIAL OFFICE
Ex parte and short-matter hearings must be coordinated with opposing counsel, then the Notice of Hearing must be emailed to the Judicial Assistant and confirmation received that the case was added to the list.
These hearings are not scheduled with the Judicial Assistant, but must be coordinated with opposing counsel on a date that Judge Wilson is available. You must email the JA at 34orange@ninthcircuit.org the NOH to be added and receive confirmation that your case has been added to the list.
Page 2 | HOW TO SCHEDULE A HEARING
Email Judge Wilson’s Judicial Assistant at 34orange@ninthcircuit.org and copy opposing counsel or pro se litigants when requesting that a hearing be added to the docket.
5. Reach out to Judge Wilson’s Judicial Assistant via email at 34orange@ninthcircuit.org and copy opposing counsel/pro se litigants for the hearing to be added to the docket.
Page 5 | COMMUNICATIONS WITH THE JUDICIAL OFFICE
A proposed agreed order must be emailed to the court in Word format with an electronically filed cover letter.
Proposed agreed orders should be: emailed to 34orange@ninthcircuit.org in Word along with an e-filed cover letter indicating whether: o Opposing counsel agrees to the content and form of the order.
Page 8 | ORDERS AND RULINGS — Submitting Orders to Chambers
Any settlement or resolution of a matter or parties on the trial docket must be reported immediately by email to the court at 34orange@ninthcircuit.org.
The Court must be notified immediately at 34orange@ninthcircuit.org of any settlement or resolution of any matter or of any parties to any matter, on the trial docket.
Page 3 | SETTLEMENT OR RESOLUTION
All motions not heard on the Uniform Motion Calendar must be specially scheduled through the Judge’s Judicial Assistant for a definite date and time.
All other motions must be specially set through the Judge’s Judicial Assistant at a date and time certain.
Page 7 | (D) Other Motion Hearings
A request for more than one hour of hearing time requires the Judge’s permission, obtained through the Judicial Assistant or by counsel’s personal ex parte appearance.
Requests for hearing time in excess of one (1) hour require permission of the Judge, obtained through request directed to the Judicial Assistant or by personal appearance of counsel at ex parte.
Page 7 | (D) Other Motion Hearings
When a previously set hearing becomes unnecessary, the attorney must immediately notify the Judge’s Judicial Assistant and all other counsel.
If a hearing becomes unnecessary after it has been set, the Judge’s Judicial Assistant and all other counsel must be notified immediately.
Page 8 | SECTION 11. MOTION PRACTICE GENERALLY. (E) Canceling Hearings.
An opposing or other motion may not be cross-noticed unless opposing counsel agrees and the Judicial Assistant grants permission.
Opposing or other motions may not be cross-noticed without agreement with opposing counsel and permission from the Judicial Assistant.
Page 8 | SECTION 11. MOTION PRACTICE GENERALLY. (D) Notices of Hearing. (2)
Counsel must immediately notify the judge’s judicial assistant by telephone of the settlement of any case scheduled for trial.
Counsel will immediately notify the Judge’s Judicial Assistant by telephone and email of the settlement of any case scheduled for trial.
Page 12 | SECTION 17. SETTLEMENTS
The court will not consider unsolicited communications from non-parties, and parties may contact the judicial office only as permitted by the court’s practices and procedures.
Unsolicited communications from non- parties will not be considered by the court. Parties may only contact the judicial office in accordance with these practices and procedures.
Page 1 | COMMUNICATIONS WITH THE JUDICIAL OFFICE
Attorneys and self-represented litigants must provide an email address for electronic delivery of signed orders unless excused.
All attorneys and self-represented litigants must provide an e-mail address to receive signed orders electronically, unless excused. Fla. R. Gen. Prac. & Jud. Admin. 2.516.
Page 1 | COMMUNICATIONS WITH THE JUDICIAL OFFICE
Attorneys and self-represented litigants must use Form 2.603 to update their contact information whenever the email account registered for electronic service changes.
It is the responsibility of attorneys and self-represented litigants to update their contact information using Form 2.603 any time there is a change in the e- mail account registered for electronic service.
Page 1 | COMMUNICATIONS WITH THE JUDICIAL OFFICE
A requested hearing time is not confirmed until the Judicial Assistant replies.
Your hearing time is not confirmed until you receive a reply from the Judicial Assistant.
Page 5 | HOW TO SCHEDULE A HEARING
This should be provided in one email to 34orange@ninthcircuit.org.
This should provided in one email to 34orange@ninthcircuit.org
Page 9 | MOTIONS IN LIMINE
A party must provide a requested follow-up or confirmation email to the judicial assistant.
If the judicial assistant requests a follow-up or confirmation e-mail correspondence, the party shall comply.
Page 5 | Sections 7–10: Courtesy copies, scheduling, communications, and technology
All non-scheduling communications with a judicial assistant must be by telephone or email, depending on the judicial assistant's preference.
All communications from a party, other than those relating solely to scheduling hearing time, with ajudicial assistant for any given matter before the court shall be by telephone or by e-mail correspondence, depending on the judicial assistant's preference.
Page 5 | Sections 7–10: Courtesy copies, scheduling, communications, and technology
True emergency matters arising on weekends, holidays, or after business hours should be referred to the Duty Judge at 407/836-3980.
True emergency matters arising on weekends, holidays or after business hours should be referred to the Duty Judge. The Duty Judge may be contacted through the Orange County Sheriff’s Communications Section at 407/836-3980.
Page 3 | SECTION 3. ADMINISTRATIVE JUDGE; ALTERNATE JUDGES; DUTY JUDGE.
When multiple attorneys or unrepresented parties will appear by telephone, one participant—typically the moving party—should arrange a conference call connecting everyone.
If two or more attorneys or unrepresented parties are to appear by telephone, one of them (typically the moving party) should arrange to connect the other parties/attorneys on a conference call.
Page 7 | (E) Remote Appearances
An order may not be emailed to the Judge or Judicial Assistant unless either directs that the order be sent by email.
No order may be emailed to the Judge or Judicial Assistant unless directed by the Judge or Judicial Assistant.
Page 7 | (B) Ex Parte Matters
Counsel must contact the Judge’s office to confirm whether Short Matters will be heard by the selected division on the chosen date and to verify the hearing location.
Contact the Judge’s office to ascertain whether Short Matters will be heard by a specific division on the date selected, and to confirm the location (hearing room or courtroom) at which the hearings will occur.
Page 7 | (C) Uniform Motion Calendar (“Short Matters”)
Deposition disputes may be addressed by contacting the judge’s judicial assistant, who may arrange a conference call with the judge.
Disputes arising in depositions may be resolved by contacting the Judge’s Judicial Assistant who will then arrange, if possible, for a conference call with the Judge.
Page 11 | SECTION 14. DEPOSITION GUIDELINES
Counsel may contact the Court by email at 34orange@ninthcircuit.org for matters concerning hearing procedures that are not addressed in the document.
INFORMATION NOT COVERED: If any matters concerning the conduct of the hearing procedures of the division are not covered herein, counsel is free to contact the Court by email at 34orange@ninthcircuit.org.
Page 11 | INFORMATION NOT COVERED
The Judicial Assistant may be contacted by phone or email to advise counsel about future trial dockets upon inquiry, although the requested docket is not guaranteed.
Judicial Assistant: Tammy Edwards Phone: (407) 836-0568 Email: 34orange@ninthcircuit.org Address: 425 N. Orange Avenue, Orlando, Florida 32801 Chambers: 1735 Hearing Room: 17B, Courtroom 18-B HOW TO SET A CASE FOR TRIAL The Judicial Assistant can advise counsel, upon inquiry, as to future trial dockets but there is no guarantee whether your case will be able to be set on the docket requested.
Page 1 | HOW TO SET A CASE FOR TRIAL
Hearing time must be confirmed with the judicial assistant by telephone or email, according to the judicial assistant's preference.
The party shall then either call or send an e-mail correspondence, depending on the judicial assistant's preference, to the judicial assistant to confirm the hearing time.
Page 5 | Sections 7–10: Courtesy copies, scheduling, communications, and technology
Counsel and unrepresented parties may arrange a remote appearance at any hearing through the Judicial Assistant.
Counsel or unrepresented parties may arrange, through the Judicial Assistant, to appear remotely at any hearing.
Page 7 | (E) Remote Appearances
To determine whether an order has been signed, counsel should first check the e-service email, then the Clerk's system, and only afterward contact the Judicial Assistant.
If you want to know if a specific Order has been signed by the Judge, you should first check your e-service email as the Order may have been e-served. If not received by email, then check the Clerk’s system to see if it has been docketed before contacting the Judicial Assistant
Page 1 | Processing of submitted orders