Judge Patrick M. Hunt

Each party is limited to filing one Daubert motion. If all evidentiary issues cannot be addressed in a 20-page memorandum, leave to exceed the page limit will be granted upon a showing of good cause. The parties are reminded that Daubert motions must contain the Local Rule 7.1(a)(3) certification.

Each party is limited to filing one motion in limine. If all evidentiary issues cannot be addressed in a 20-page memorandum, leave to exceed the page limit will be granted upon a showing of good cause. The parties are reminded that motions in limine must contain the Local Rule 7.1(a)(3) certification.

Any party intending to use deposition testimony as substantive evidence must designate by line and page reference those portions in writing. The designations must be served on opposing counsel and filed with the Court fourteen days before the deadline to file the joint pretrial stipulation. The adverse party must serve and file any days to serve and file objections to the cross-designations.

All trial exhibits must be pre-marked. Plaintiffs’ exhibits must be marked numerically with the letter “P” as a prefix. Defendants’ exhibits must be marked alphabetically with the letter “D” as a prefix. A list setting out all exhibits must be submitted at the beginning of trial. This list must indicate the pre-marked identification label (e.g., P-1 or D-1) and must also include a brief description of the exhibit.

If this case will proceed by jury trial, the parties shall submit their proposed jury instructions and verdict form jointly, although they need not agree on each proposed instruction. Where the parties do not agree on a proposed instruction, that instruction shall be set forth in bold type. Instructions proposed only by Plaintiff shall be underlined. Instructions proposed only by Defendant shall be italicized. Every instruction must be supported by citation to authority. The parties shall use as a guide the Eleventh Circuit Pattern Jury Instruction for Civil Cases, including the directions to counsel contained therein. Proposed jury instructions and verdict form, in typed form, including substantive charges and defenses, shall be submitted to this Court in Microsoft Word format via e-mail to: hunt@flsd.uscourts.gov. Instructions for filing proposed documents may be viewed at: http://www.flsd.uscourts.gov.

All objections to discovery requests must be specific. The parties shall not make generalized, vague, or boilerplate objections. Nonspecific objections do not comply with the Federal Rules of Civil Procedure or the Local Rules and will not be sustained by this Court. See Fed. R. Civ. P. 33(b)(4) (“The grounds for objecting to an interrogatory must be stated with specificity.”); Fed. R. Civ. P. 34(b)(2)(B) (“For each item or category, the response must either state that inspection and related activities will be permitted as requested or state an objection to the request, including the reasons.” (emphasis added)); S.D. Fla. L.R. 26.1(g)

an objection that a discovery request is irrelevant and/or not reasonably calculated to lead to admissible evidence must include a specific explanation describing why the request lacks relevance and/or why the information sought is not reasonably calculated to lead to admissible evidence.

The movant shall include in the motion a certificate of good faith that complies with S.D. Fla. L.R. 7.1(a)(3) and that specifically indicates the efforts that were made to resolve the dispute prior to filing the motion.