Judge Lauren Fleischer Louis's rules set a pre-motion procedure for discovery. Parties must confer in good faith to resolve discovery disputes before bringing the dispute before the Court.
Judge Lauren Fleischer Louis' rule states these limits: 10 pages; 10 pages; 5 pages. Discovery motions and response briefs limited to 10 pages; reply briefs limited to 5 pages.
Judge Lauren Fleischer Louis' formatting rule includes file format docx. Proposed protective orders for joint motions must be in Word (DOCX) format.
The rule identifies required filing content or certificates. Parties are prohibited from making non-specific, boilerplate objections to discovery requests; grounds must be stated with specificity.
The rule requires certificate of conference. Discovery motions must include a certificate of conference attesting to good faith conferral with live conversation, dates of conferral, and means of communication.
Parties may contact Judge Lauren Fleischer Louis' chambers by email only as allowed by the rule. The rule lists email louis@flsd.uscourts.gov. Parties filing a joint motion for protective order must promptly send the proposed order to louis@flsd.uscourts.gov via email.
No. The rule prohibits holding covered papers for bundling. Source Materials for Informal Discovery Hearings must be filed as separate documents.
Yes. Electronic filing is required for the covered filings. Movants with CM/ECF credentials must file Notice of Hearing and calendar Discovery Hearing via CM/ECF system.
The rule addresses filing timing, filing status, or cure windows. All discovery including dispute resolution must be completed before the discovery cut-off date; no court intervention is available after the cut-off date even if parties agree to additional discovery.
The rule addresses service method, recipient, or timing requirements. Details: method: service by email, recipient: all parties. Request email for Informal Discovery Hearing must copy all parties.
Participation in the Informal Discovery Hearing procedure is optional.
Proposed protective orders for joint motions must be in Word (DOCX) format.
Parties filing a joint motion for protective order must promptly send the proposed order to louis@flsd.uscourts.gov via email.
The Court will omit any provision in a protective order that allows bypassing Local Rule 5.4’s sealing requirements.
Parties are prohibited from making non-specific, boilerplate objections to discovery requests; grounds must be stated with specificity.
Objections to discovery requests for vagueness/overbreadth/burden must explain specific ways; irrelevance/disproportionality objections must explain why; vagueness objections require prior clarification attempt.
Non-specific, boilerplate objections to discovery requests are disregarded by the Court as meaningless.
Objections based on “not reasonably calculated to lead to admissible evidence” are outdated and invalid; discovery scope is relevance and proportionality, not admissibility.
Discovery motions and response briefs limited to 10 pages; reply briefs limited to 5 pages.
Discovery motions must include a certificate of conference attesting to good faith conferral with live conversation, dates of conferral, and means of communication.
Parties must confer in good faith to resolve discovery disputes before bringing the dispute before the Court.
Sanctions motions must be filed in writing and cannot be resolved via Informal Discovery Hearing.
All discovery including dispute resolution must be completed before the discovery cut-off date; no court intervention is available after the cut-off date even if parties agree to additional discovery.
Discovery disputes must be raised in a timely manner per Local Rule 26.1(g)(2), which the Court strictly enforces.
Failure to confer in good faith is an independent basis to deny discovery motion relief; opposing party's failure to confer is considered for fee awards if motion is granted.
Any party may file a written discovery motion without leave of Magistrate Judge Louis; motions are considered in ordinary course unless expedited consideration is warranted.
Informal Discovery Hearing procedures do not apply to written discovery motions.
Parties may not send materials to chambers via email for hearings on written discovery motions.
Parties must confer and identify at least two available hearing dates within 14 days to use Informal Discovery Hearing procedure.
Pre-motion email requesting Informal Discovery Hearing must include required content and certification of good faith conference.
Request for Informal Discovery Hearing must be sent via email to louis@flsd.uscourts.gov.
Request email for Informal Discovery Hearing must copy all parties.
Notice of Hearing must be filed within 24 hours of Court confirmation (or 2 business days if no CM/ECF credentials) and calendared in CM/ECF.
Source Materials for Informal Discovery Hearings must be filed as separate documents.
Movants with CM/ECF credentials must file Notice of Hearing and calendar Discovery Hearing via CM/ECF system.
Notice of Hearing must detail each discovery dispute with 2-3 sentences per dispute, no argument.
Each party must email relevant materials and proposed order to chambers by 12:00 PM two business days before Informal Discovery Hearing.
Proposed order required to be sent with pre-hearing email for Informal Discovery Hearing.
Only relevant materials may be sent to chambers; send only Answers if they include original requests.
Rule 37(a) motions to compel discovery may be resolved via Informal Discovery Hearing.