Southern District of Florida Local Rules and Judge Filing Requirements

Proposed orders are required for all motions.

Boilerplate objections to discovery requests are prohibited; objections must state specific grounds.

Court may impose sanctions for improper discovery, bad faith withholding, or failure to confer in good faith.

Motions in limine limited to one per party; require Local Rule 7.1(a)(3) certification.

Trial set for February 1, 2021 at 9:00 a.m. in West Palm Beach

Substantive matters must be submitted as motions on the docket, not by phone or email.

Contact Chambers at (305) 523-5720 to schedule discovery hearing.

Calendar Call and Status Conference scheduled; non-evidentiary hearings via Zoom

All discovery matters referred to Magistrate Judge; parties may consent to trial by Magistrate Judge with specified deadline.

Contact chambers by noon Friday to schedule discovery calendar; 30 minutes per side allowed.

Parties must have actual conversation (in person or phone) before filing discovery hearing notice.

Court will sua sponte review motions and determine which require hearings.

Discovery disputes must be resolved through conference before filing motions; sanctions may be imposed for bad faith.

Parties must meet and confer within 21 days of defendant's response.

Parties must confer in person or by phone before filing discovery motion.

Proposed orders must be in Word format, 12-pt Palatino Linotype, double-spaced, justified, with page numbers starting on page 2.

All pleadings must be double-spaced, 12-point font, 1-inch margins, single-sided, and paginated.

Agreed jury instructions must use Times New Roman 14 point typeface.

Trial scheduled to commence during two-week period beginning 120 days after dispositive motions deadline.

Trial exhibits must be pre-marked with P/D prefixes and listed with descriptions by calendar call.

Each side limited to 30 minutes for discovery hearings.

Discovery motions and responses limited to 10 pages; replies limited to 5 pages.

Daubert motions limited to 20 pages; one per party; require Local Rule 7.1(a)(3) certification.

Each party limited to one motion in limine with max 3 requests, including Daubert challenges.

Discovery motions and sanctions motions limited to 5 pages.

Motions for extensions of time will rarely be granted.

Responses and replies to discovery motions due within 7 days.

Pretrial deadlines before dispositive motions can be modified by joint notice without court order.

Motions to join parties and amend complaint must be filed within 60 days of joint scheduling report.

Discovery disputes must be raised within 28 days (with 7-day extension) and completed before discovery cutoff.

Plaintiff must file Motion for Entry of Clerk’s Default within 7 days of defendant's answer deadline if no response is filed, with failure resulting in potential dismissal without prejudice.

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.

Moving parties must request discovery dispute hearing relief within 15 days of the grounds for relief arising.

Responses to discovery motions must be filed within 5 business days of service of the discovery motion.

Parties have 28 days (plus 7-day extension per Local Rule 26.1(g)(2)(C)) to make good-faith resolution efforts for discovery disputes; unapproved extensions are invalid.

Court welcomes less-experienced counsel to argue motions at hearings.

Junior lawyers (5 or fewer years) may have multiple attorneys argue.

Parties must notify court if lawyer with 5 or fewer years experience will argue.

Junior lawyers (5 years or less experience) may have multiple attorneys argue if notified in advance.

Junior attorneys (5 years or less) may have multiple attorneys argue.

Plaintiff must serve motion on defendant/counsel, include service details in Certificate of Service, and not rely solely on CM/ECF for service.

Request email for Informal Discovery Hearing must copy all parties.

Moving parties must email relevant hearing materials to chambers at least 3 days before the hearing.

Objections to the scope of a deposition notice must be timely served, not filed, in advance of the deposition.

Stay relief orders involving property in pending Florida state court actions must serve the applicable state court clerk as an interested party.

Proposed orders must be emailed to chambers in Word format.

Movants with CM/ECF credentials must file Notice of Hearing and calendar Discovery Hearing via CM/ECF system.

Default judgments must be uploaded to the CM/ECF electronic filing system after entry of the order granting the motion.

Motions and memoranda are rarely needed.

Substantive discovery motions filed on docket will be stricken; use discovery calendar instead.

Settlement negotiations before conference are not required but encouraged.

Written discovery motions between parties are prohibited unless specifically authorized by court order.

Source Materials for Informal Discovery Hearings must be filed as separate documents.

Source materials must be provided via hand-delivery or email to CM/ECF mailbox on hearing date.

All papers and exhibits must comply with the federal judiciary privacy policy per Local Rule 5005-1(A)(2).