Judge Robin L. Rosenberg's rules set a pre-motion procedure for deposition designation notebooks. Objections require full, reasonable conferral between parties before being raised.
Judge Robin L. Rosenberg's formatting rule includes times new roman font, 14 point type. Agreed jury instructions must use Times New Roman 14 point typeface.
The rule requires caption, judge name, and case number. Discovery begins immediately; Initial Disclosures due February 18, 2020
The rule requires names and addresses and expert reports or summaries. Primary expert witness disclosure and deposition deadline.
Parties may contact Judge Robin L. Rosenberg's chambers by email only as allowed by the rule. Calendar Call and Status Conference scheduled; non-evidentiary hearings via Zoom
Judge Robin L. Rosenberg's rules specify what an adjournment or extension request must include. The request must include agreement of all parties, joint notice, and new deadlines. Extending discovery deadline waives Rule 56(d) arguments about inability to move for summary judgment.
Yes. Judge Robin L. Rosenberg's rules include a junior lawyer participation incentive. Court welcomes less-experienced counsel to argue motions at hearings.
Trial set for February 1, 2021 at 9:00 a.m. in West Palm Beach
Calendar Call and Status Conference scheduled; non-evidentiary hearings via Zoom
Pro hac vice, substitution of counsel, and discovery motions referred to Magistrate Judge
Magistrate Judge has authority to permit amendments; pending motions become moot
Discovery begins immediately; Initial Disclosures due February 18, 2020
Primary expert witness disclosure and deposition deadline.
Rebuttal expert witness disclosure and deposition deadline.
Expert witness rules do not apply to treating physicians and health providers.
Expert discovery must be completed by November 16, 2020.
All pretrial motions (summary judgment, Daubert, motions in limine) must be filed by December 1, 2020.
Mediation must be completed by January 1, 2021.
Pretrial stipulation, deposition designations, and Rule 26(a)(3) witness/exhibit lists due January 4, 2021.
Counter-designations and objections to deposition designations due January 8, 2021; late designations inadmissible without exigent circumstances.
Objections to counter-designations and responses to objections to designations due January 14, 2021.
Responses to objections to counter-designations due January 17, 2021.
Jury instructions or proposed findings, joint statement, joint trial plan, exhibit/witness lists, and notice of intent to seek adjudication due January 25, 2021.
Notice of remaining issues and joint deposition designation notebook due January 27, 2021.
Pretrial deadlines before dispositive motions can be modified by joint notice without court order.
Court will not modify other deadlines if parties modify deadlines by agreement.
Extending discovery deadline waives Rule 56(d) arguments about inability to move for summary judgment.
Motion required for modifications when parties cannot agree or for dispositive motion deadlines.
Joint notice procedure cannot be used to extend deadlines to answer pleadings or respond to motions.
Failure to follow procedures may result in denial of motion without prejudice.
Parties must submit joint jury instructions and verdict form in Word format to specified email.
Jury instructions must cite Eleventh Circuit pattern instructions or supporting case law.
Joint jury instructions must include preliminary and final instructions; voir dire and verdict forms also required.
Agreed jury instructions must use Times New Roman 14 point typeface.
Objected instructions must be italicized (plaintiff) or bold-faced (defendant).
Each jury instruction must be on a separate page with citations to authority (except pattern instructions).
Parties must use Eleventh Circuit pattern jury instructions as a guide.