Sanctions motions must be separate, state justifying rule/statute, and specify remedy.

Discovery objections must state if responsive materials are being withheld.

Sanctions imposed if party objects then claims no responsive documents exist.

Burden objections must state no search was conducted and explain why search would be unduly burdensome.

Boilerplate and general objections are prohibited and will be struck.

Boilerplate objections of 'vague, overly broad, or unduly burdensome' will be stricken.

Must seek clarification from opposing counsel before objecting on vagueness grounds.

If no clarification received, unilaterally define vague terms and respond accordingly.

Objections must specify whether overbroad means irrelevant or disproportionate.

Must confer in good faith to narrow scope before asserting objections for irrelevant, disproportionate, or burdensome requests.

Must respond to undisputed portions of discovery requests despite objections.

Generalized privilege objections must specify privilege type, communication details, and include privilege log or be deemed waived.

Non-privileged materials must be produced promptly even while preparing privilege log.

Counsel must attempt to resolve discovery disputes through direct communication before seeking court intervention.

Discovery motions cannot be filed until after attempting to resolve disputes through direct communication.

Discovery hearing requests must be sent via email to reinhart@flsd.uscourts.gov with specific subject line.

Discovery hearing request email must include two available afternoons within 7 business days and estimated hearing time.

Discovery hearing request email must be copied to all counsel and certify that opposing counsel's availability has been confirmed.

Joint discovery memorandum (max 5 pages) required 48 hours before hearing.

Junior lawyers (5 or fewer years) may have multiple attorneys argue.