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 Michael T. McHugh

Judge Michael McHugh was appointed to the 20th Judicial Circuit Bench by Governor Jeb Bush. He has served in the Juvenile, Felony, Family, and Civil Divisions. He has served as Administrative Judge of the Family and Civil Divisions. As Administrative Judge of the Civil Division, Judge McHugh put together a workgroup that included members of the bar, judges, and other stakeholders to implement “Differentiated Civil Case Management.” Before Chief Justice Canady implemented case management statewide pursuant to an Administrative Order during the COVID pandemic, only the 20th Judicial Circuit had circuit-wide case management for more than a decade. Judge McHugh was elected as Chief Judge in 2015, he was the youngest judge ever elected Chief Judge in the Twentieth Judicial Circuit, and the only person to ever serve four terms in this position. He is currently serving as the Circuit Civil Administrative Judge. Judge McHugh received his undergraduate degree from the Fisher School of Accounting at the University of Florida. He also received his law degree from the Levin School of Law at the University of Florida. After graduating Law School, he served as a prosecutor for the Twentieth Judicial Circuit where he tried various cases including murder prosecutions. After leaving the State Attorney’s Office he began working for Allstate Insurance Company. He litigated all levels of cases and tried over 50 civil jury trials to verdict. When he was appointed to the bench he was managing attorney of the Tampa and Fort Myers offices. Judge McHugh has served on many statewide committees. He was appointed to the “Workgroup on the Continuity of Operations and Proceeding During and After COVID-19” and served as the chair of the civil sub group. He was also a member of the “Workgroup on Improved Resolution of Civil Cases.”, and chaired the Judicial Management Council “Workgroup on Trial Court Technology.” Currently he is chairing the Judicial Management Council’s “Workgroup on Uncontested Probate Proceedings.” He also is a current member of the Trial Court Budget Committee and the “Supreme Court’s Local Rules Workgroup.” Judge McHugh is married and has three children. His oldest son, Gareth, is a practicing attorney at Sullivan and Cromwell in New York. His second son, Dylan, graduated from the University of Florida and is attending Law School. His daughter, Elizabeth, is attending the University of Florida.

Mailing address: Lee County Justice Center 1700 Monroe Street Fort Myers, FL 33901 Judicial assistant: Kathy Phone: (239) 533-2775 Fax: (239) 485-2587

Common questions about Judge Michael T. McHugh's rules

Are courtesy copies required for Judge Michael T. McHugh?

Judge McHugh does not require courtesy copies of pleadings.

View ruleSource: page 4, section E. Courtesy Copies of Case law and Other Documents

What formatting rules apply to filings before Judge Michael T. McHugh?

Judge Michael T. McHugh's formatting rule includes submit in word format, use no special characters, use no special spacing, and ensure the order can be edited if necessary. All proposed orders must use word format and contain no special characters or spacing so they remain editable if necessary.

View ruleSource: page 4, section D. Submission of Orders and Judgments

What must be included with joint stipulation for remote appearance filings before Judge Michael T. McHugh?

The rule identifies required filing content or certificates. A remote appearance requires a joint stipulation signed by both parties and agreement by both parties to appear remotely.

View ruleSource: page 1, section Judge McHugh Procedures

What must be included with remote appearance scheduling request filings before Judge Michael T. McHugh?

The rule identifies required filing content or certificates. A CourtScribes remote-appearance request must include the attorney-specified party, contact, court, appearance, case, proceeding, and representation information that follows.

View ruleSource: page 1, section COURTSCRIBES REMOTE APPEARANCE FOR ATTORNEYS: Instructions for the Attorneys

How may parties contact Judge Michael T. McHugh's chambers?

Every hearing must be scheduled with the Judicial Assistant before any remote appearance is arranged.

View ruleSource: page 1, section Judge McHugh Procedures

How do I request an adjournment or extension before Judge Michael T. McHugh?

Advance notice is not fully stated in the structured details. Continuances are disfavored and require a showing of good cause; absent good cause, the continuance motion must be signed by the requesting party.

View ruleSource: page 2, section B. Scheduling Procedures

Is electronic filing required before Judge Michael T. McHugh?

Yes. Electronic filing is required for the covered filings. The completed Order of Referral to the Magistrate must be uploaded to the E-portal.

View ruleSource: page 3, section B. Scheduling Procedures

When is a filing treated as filed before Judge Michael T. McHugh?

The rule addresses filing timing, filing status, or cure windows. The joint remote-appearance stipulation must be filed no later than five days before the hearing.

View ruleSource: page 1, section Judge McHugh Procedures
Complete rules summary for Judge Michael T. McHugh

Every hearing must be scheduled with the Judicial Assistant before any remote appearance is arranged.

A remote appearance requires a joint stipulation signed by both parties and agreement by both parties to appear remotely.

Parties should not submit an order requesting a remote appearance because a filed stipulation is the only requirement.

The joint remote-appearance stipulation must be filed no later than five days before the hearing.

The remote-appearance rules apply to every hearing before Judge McHugh, including pre-trial conferences and docket-sounding hearings.

Attorneys may arrange a remote appearance on 48 hours' advance notice using one of the listed scheduling methods.

Attorneys may schedule a CourtScribes remote appearance by email to scheduling@courtscribes.com.

Attorneys may schedule a CourtScribes remote appearance by calling 833-274-2237.

A CourtScribes remote-appearance request must include the attorney-specified party, contact, court, appearance, case, proceeding, and representation information that follows.

If you do not receive confirmation within 2 hours of placing your order and making payment, call (833) SCRIBES (727-4237) for assistance.

If you do not receive confirmation within 2 hours of placing your order and making payment, call (833) SCRIBES (727-4237) for assistance.

Unless Judge McHugh specifically instructs otherwise, communicate with the judicial office by phone to the Judicial Assistant rather than by email.

All parties must be copied on communications directed to the judicial office unless an ex parte communication is authorized by law.

Check the Clerk’s docket for a proposed order’s status and allow sufficient time before contacting the judicial office about that status.

After selecting and coordinating a hearing date, speak directly with the judicial assistant to schedule the hearing; leaving only a message will not schedule it.

File a Notice of Hearing with the Clerk and serve it on all parties immediately after reserving hearing time, and include the required ADA notification.

Continuances are disfavored and require a showing of good cause; absent good cause, the continuance motion must be signed by the requesting party.

A proposed or agreed order may be submitted for judicial review after compliance with the instructions and continuance rule, but an agreed order requires consent from every party.

Discovery motions lasting at least 15 minutes should be scheduled before the magistrate, with a completed Order of Referral uploaded to the E-portal and the Magistrate’s Assistant contacted to arrange the hearing.

The completed Order of Referral to the Magistrate must be uploaded to the E-portal.

The Magistrate’s Assistant must be contacted at KWagner@ca.cjis20.org to schedule the magistrate hearing.

A remote appearance requires a joint stipulation signed by both parties and their agreement to appear remotely, and no proposed order granting remote appearance should be submitted.

The joint stipulation for a remote appearance must be filed no later than five days before the scheduled hearing.

The remote-appearance rules apply to all hearings scheduled before Judge McHugh, including pretrial conferences and docket-sounding hearings.

Parties may schedule a remote appearance by email to CourtScribes with at least 48 hours’ advance notice.

A remote-appearance scheduling request must identify the appearing party, contact information, court location, department, appearance date and time, case name and number, nature of the proceeding, and represented party.

All proposed orders must use word format and contain no special characters or spacing so they remain editable if necessary.

All orders must be submitted through the E-Filing Portal at the stated website.

Judge McHugh does not require courtesy copies of pleadings.

Documents submitted to the judge before a hearing may be e-filed with the clerk or mailed to the judge’s office.

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