Judge Eduardo I. Sanchez
Individual Rules, Standing Orders & Policies
Limits & Logistics
Document Limits
Communication
Chambers
Page & Word Limits3 rules
The opposing party must file a response to the motion, no longer than five (5) pages, within five (5) business days of service of the discovery motion.
Opposition
5 pages
Applies to: Attorney
All discovery motions shall be no longer than five (5) pages.
Discovery Motion
5 pages
Applies to: Attorney
No reply shall be permitted.
Reply
Document Filing Requirements2 rules
The movant shall include in the motion a certificate of good faith that complies with Local Rule 7.1(a)(3). See S.D. Fla. L.R. 7.1(a)(3).
DocumentDiscovery Motion
Boilerplate or general objections are prohibited.
The parties shall not make nonspecific, boilerplate objections. See, e.g., S.D. Fla. L.R. 26.1(e)(2)(A) (“Where an objection is made to any interrogatory or subpart thereof or to any production request under Federal Rule of Civil Procedure
DocumentDiscovery Objection
Filing & Service rules
Pre-Motion Conference Requirements
Parties must have good faith in-person, phone, or video conference before filing discovery motions.
If a discovery dispute arises, the parties must actually speak to one another, either in person, via telephone, or via Zoom (or equivalent conferencing/communication platform) to resolve their discovery disputes before seeking court intervention. E-mail correspondence alone does not constitute a sufficient conferral.
Civil cases
Page 1 | I. PROCEDURES FOR DISCOVERY DISPUTES
Chambers Communication Rules
Chambers communications about discovery must be by email with all counsel copied; no arguments allowed.
All such communications with chambers regarding discovery matters must be by email, and all counsel of record must be copied on the email. No argument or background about the dispute is permitted by email.
Civil cases
Page 3 | I. PROCEDURES FOR DISCOVERY DISPUTS