Court Rules

Court-wide rules

Applies court-wide

These 197 rules apply across Twentieth Judicial Circuit of Florida, Charlotte, Collier, Glades, Hendry and Lee Counties. Where this judge's own standing orders above address the same topic, the judge's requirement controls.

Filing Requirements

All 49
  • Applies to
    Case management plan

    A court-ordered case management plan must specify the projected trial date, state that its deadlines will be strictly enforced, and state that the presiding judge will order a final trial period no later than 45 days before the projected trial period.

  • Applies to
    Case management order

    The case management order must include the listed case-management deadlines, including service, discovery, motions, witness and exhibit disclosures, alternative dispute resolution, and the projected trial period.

  • Applies to
    Trial period reset order

    If the court-ordered trial period does not reach trial, the court must enter an order setting a new trial period as soon as practicable based on the case’s needs and court resources.

Service

All 42

  • Plaintiffs must serve their actions promptly, and service issues must be addressed promptly and diligently.

  • Applies to
    Court ordered case management plan

    If service has not been effected by the date of the court-ordered case management plan, the plaintiff must serve each defendant a copy of the plan with the summons and complaint.

  • Deadline
    180 calendar days
    Applies to
    Summons and complaint

    A defendant may not be served under an extension more than 180 days after filing.

Filing Timing

All 40

  • Expert-witness disclosure is due 160 days before trial.

  • The plaintiff must make the initial discovery disclosure within 60 days after service of the complaint or joinder.

  • Each defendant must make the initial discovery disclosure within 60 days after service.

Formatting

All 23

  • Composite exhibits must be satisfactorily marked and securely bound before presentation to the court.

  • Oversized exhibits may be used, but if practicable they must be reduced to 8½-by-11 inches, with the reduced copy retained by the clerk in the court file.

  • Format
    DOCX

    At docket sounding, counsel or parties must submit both a Microsoft Word electronic version and a printed copy of the jury instructions and verdict form.

More categories

View all Twentieth Judicial Circuit of Florida, Charlotte, Collier, Glades, Hendry and Lee Counties rules
About Judge Kyle Cohen

Judge Kyle S. Cohen was appointed as a Circuit Court Judge to the 20th Judicial Circuit on May 28, 2020. Judge Cohen began his service on July 9, 2020 and is currently assigned to Unified Family Court in Collier County. Prior to taking the bench, Judge Cohen served as an Assistant United States Attorney in the civil division for the Middle District of Florida in the Fort Myers Office. As the sole civil division AUSA in the Fort Myers United States Attorney's Office, Judge Cohen was responsible for all aspects of any defensive and affirmative federal civil litigation affecting the interests of the United States within a six-county radius. On the defensive side, Judge Cohen handled many different types of federal civil litigation such as Federal Tort Claims Act (“FTCA”) cases, medical malpractice, employment discrimination, and bankruptcy. Judge Cohen's affirmative work primarily consisted of fraud investigations and claims brought pursuant to the Federal False Claims Act (“FCA”). As a result of these investigations, Judge Cohen amassed over $384 million in FCA recoveries. Prior to joining the United States Attorney's Office, Judge Cohen was an associate at Howrey in Washington D.C. where he was a member of the Global Litigation, Commercial Trial, and Insurance Recovery practice groups. He attended law school at Georgetown University law Center and is a proud graduate of the University of Florida for undergrad.

Mailing address: Lee County Justice Center 1700 Monroe Street Fort Myers, FL 33901 Judicial assistant: Cheyanne Phone: (239) 533-8244 Email: CPhillips@ca.cjis20.org

Common questions about Judge Kyle Cohen's rules

What formatting rules apply to filings before Judge Kyle Cohen?

Judge Kyle Cohen's formatting rule includes file format paper, binding tabbed 3-ring, and include an exhibit list index. For a Zoom evidentiary hearing, counsel must submit a hard copy of the evidence to the judge at least 48 hours before the hearing in a tabbed binder with an Exhibit List Index.

View ruleSource: page 3, section Evidentiary Hearings set via Zoom

What must be included with notice of hearing filings before Judge Kyle Cohen?

The rule identifies required filing content or certificates. A Notice of Hearing for a Zoom hearing must state that the hearing is via Zoom and include Judge Cohen’s Zoom Meeting ID.

View ruleSource: page 1, section HEARINGS

What must be included with discovery motion filings before Judge Kyle Cohen?

The rule identifies required filing content or certificates. Discovery motions scheduled for a hearing of 15 minutes or longer before Magistrate Bernardo must contain a Certificate of Good Faith.

View ruleSource: page 2, section Motion to be heard by Magistrate Bernardo

How may parties contact Judge Kyle Cohen's chambers?

The rule addresses email communications with Judge Kyle Cohen's chambers. The rule lists email cphillips@ca.cjis20.org. Hearings requiring at least one hour must be scheduled directly with the Judicial Assistant by email at cphillips@ca.cjis20.org.

View ruleSource: page 2, section Extended Hearings

How do I request an adjournment or extension before Judge Kyle Cohen?

Advance notice is not fully stated in the structured details. The request must include reason for request. A hearing longer than 60 minutes cannot be cancelled by the parties without a stipulation signed by both parties and filed with the clerk; a copy of the filed stipulation must then be emailed to the judicial assistant.

View ruleSource: page 4, section Cancellations

Is electronic filing required before Judge Kyle Cohen?

Yes. Electronic filing is required for the covered filings. A proposed order must be submitted through the court’s e-filing portal after the underlying motion appears on the Clerk’s docket.

View ruleSource: page 3, section Proposed Orders

When is a filing treated as filed before Judge Kyle Cohen?

The rule addresses filing timing, filing status, or cure windows. A hard copy of the evidence must be submitted to the judge at least 48 hours before a Zoom evidentiary hearing.

View ruleSource: page 3, section Evidentiary Hearings set via Zoom

What rule applies to service for order of referral before Judge Kyle Cohen?

The rule addresses service method, recipient, or timing requirements. Details: method: service by email. An Order of Referral must be prepared, and mag-bernardohearings@ca.cjis20.org must be added to the Electronic Service List.

View ruleSource: page 2, section Motion to be heard by Magistrate Bernardo
Complete rules summary for Judge Kyle Cohen

Judge Cohen’s Judicial Assistant may be contacted by phone at (239) 533-8244 or by email at cphillips@ca.cjis20.org, with email preferred.

A Notice of Hearing for a Zoom hearing must state that the hearing is via Zoom and include Judge Cohen’s Zoom Meeting ID.

Every Notice of Hearing must include the JACS confirmation number.

Every Notice of Hearing must state the JACS confirmation number, motion title, filing date, hearing date and time, courtroom, and requested hearing duration.

A user unable to log in to JACS must email the JACS administrator with the user’s bar number.

Scheduling problems with JACS should be reported to the JACS administrator by email.

An Order of Referral must be prepared, and mag-bernardohearings@ca.cjis20.org must be added to the Electronic Service List.

Discovery motions scheduled for a hearing of 15 minutes or longer before Magistrate Bernardo must contain a Certificate of Good Faith.

Hearings requiring at least one hour must be scheduled directly with the Judicial Assistant by email at cphillips@ca.cjis20.org.

An extended-hearing scheduling email must identify the pleading, its filing date, and the amount of hearing time requested.

A proposed order must be submitted through the court’s e-filing portal after the underlying motion appears on the Clerk’s docket.

All orders must use Times New Roman font at 12-point size.

The proposed order’s document title must begin with the case number, and emergency or time-sensitive orders must include “Emergency or Urgent” before the case number using the specified format.

The drafting attorney must submit the proposed order in Word format with a cover letter stating that there are no objections.

The drafting attorney must provide proposed orders to opposing counsel with a reasonable time for approval or comment before submitting them to the court, and opposing counsel must promptly communicate objections.

If counsel objects to an order or judgment, counsel must redline it and submit it to the judge with a cover letter identifying the drafter and source of the redlines; competing orders must not be submitted unless the court directs.

For a Zoom evidentiary hearing, counsel must submit a hard copy of the evidence to the judge at least 48 hours before the hearing in a tabbed binder with an Exhibit List Index.

A hard copy of the evidence must be submitted to the judge at least 48 hours before a Zoom evidentiary hearing.

Anticipated case law for an in-person evidentiary hearing must be emailed to the judicial assistant at least 48 hours before the hearing.

The Agreed Case Management Plan must be submitted to the Civil Department in Word format.

The agreed pretrial conference order must be submitted through the court portal.

The pretrial order must use the updated or revised form available on the court website or it will be rejected.

A cancelled hearing requires filing a Notice of Cancellation with the clerk and emailing a copy to the judicial assistant no later than 4:00 p.m. on the business day before the hearing.

A cancellation notice received after 4:00 p.m. generally requires the parties to appear at the scheduled hearing unless the judicial assistant advises otherwise.

A hearing longer than 60 minutes cannot be cancelled by the parties without a stipulation signed by both parties and filed with the clerk; a copy of the filed stipulation must then be emailed to the judicial assistant.

A stipulation to continue trial does not automatically continue the trial; it must be set for a hearing before docket sounding and should state the reasons for the request.

Parties must continue preparing for trial as scheduled unless the court enters an order granting a continuance.

An opposed motion to continue must include the moving party’s written consent and be coordinated for hearings through JACS.

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