Courtesy copies are required for notice of hearings. Details: 1 copy, delivery upon filing, by email. Source materials must be provided via hand-delivery or email to CM/ECF mailbox on hearing date.
The rule does not state that a pre-motion letter is required, but it sets the applicable pre-motion procedure. Parties must have actual conversation (in person or phone) before filing discovery hearing notice.
Judge Darrin P. Gayles' formatting rule includes palatino linotype font, 12 point type, double spacing, margins top 1 inches, bottom 1 inches, left 1.25 inches, right 1.25 inches, file format docx, justified, case style must mirror the case style used in this order, and page numbers beginning on the second page. Proposed orders must be in Word format, 12-pt Palatino Linotype, double-spaced, justified, with page numbers starting on page 2.
The rule requires notice of electronic filing. File Notice of Hearing and serve opposing counsel via ECF on same day Chambers confirms discovery calendar placement.
The rule identifies required filing content or certificates. Notice of authorities may list authorities with one-sentence summaries, no arguments.
Parties may contact Judge Darrin P. Gayles' chambers by letter ecf only as allowed by the rule. Letters requesting relief are prohibited unless invited or directed by the judge.
Bundling is encouraged for covered papers before Judge Darrin P. Gayles. Motions and memoranda are rarely needed.
Parties must have actual conversation (in person or phone) before filing discovery hearing notice.
Email/telefax demands for same-day response are not good faith confer efforts.
Court may impose sanctions for improper discovery, bad faith withholding, or failure to confer in good faith.
Discovery motions (compel, protective order, sanctions) require Court authorization.
Unauthorized discovery motions and memoranda will be stricken.
Discovery hearings scheduled every Friday afternoon.
Contact Chambers at (305) 523-5720 to schedule discovery hearing.
Must disclose if attorneys are local (Miami-Dade, Broward, Palm Beach) or not local when scheduling discovery hearing.
No hybrid hearings - all counsel must participate via same method (Zoom or in-person).
Chambers provides available dates for parties to confer and confirm availability.
File Notice of Hearing and serve opposing counsel via ECF on same day Chambers confirms discovery calendar placement.
Each side limited to 30 minutes for discovery hearings.
Hearing notice must include certificate of good faith per Local Rule 7.1(a)(3).
Source materials must be provided via hand-delivery or email to CM/ECF mailbox on hearing date.
Source materials must be actual discovery documents, not memoranda or letters.
Notices and source materials cannot be used to submit memoranda or arguments.
Non-routine disputes may include one-paragraph explanation in hearing notice.
Notice of authorities may list authorities with one-sentence summaries, no arguments.
Motion for leave to file discovery motion/memoranda may be filed for complex disputes.
Motions and memoranda are rarely needed.
Parties must engage in reasonable compromise; sanctions may be imposed for bad faith.
Letters requesting relief are prohibited unless invited or directed by the judge.
Local Rule 7.1 requires certificate of conferral for motions, with sanctions for non-compliance.
Proposed orders must be in Word format, 12-pt Palatino Linotype, double-spaced, justified, with page numbers starting on page 2.
Pro se litigants must file documents in person or by U.S. mail with no exceptions.
Pro se litigants must file consent form to receive electronic notices; paper copies will then cease.
Pro se litigants must maintain current email address with the Court after filing consent.
Pro se litigants prohibited from emailing Chambers for relief or filing copies.
Pro se litigants may call Chambers to schedule discovery hearings.
All other relief requests must follow stated procedures and Local Rules.