Southern District of Florida Local Rules and Judge Filing Requirements

Trial exhibits must be pre-marked with P or D prefixes and listed at trial start.

Written judge authorization required for specific electronic device access.

Motion must include certificate of good faith conference per Local Rule 7.1(a)(3).

The Court will omit any provision in a protective order that allows bypassing Local Rule 5.4’s sealing requirements.

Discovery motions must include a certificate of good faith complying with Local Rule 7.1(a)(3).

Settlement must be reported promptly by phone or email.

Chambers communications about discovery must be by email with all counsel copied; no arguments allowed.

Parties filing a joint motion for protective order must promptly send the proposed order to louis@flsd.uscourts.gov via email.

The Court will not accept telephone requests for immediate rulings on deposition conduct or objections during ongoing depositions.

Contact Chambers at (954) 769-5460 to schedule discovery hearings.

Parties must have good faith in-person, phone, or video conference before filing discovery motions.

Participation in the Informal Discovery Hearing procedure is optional.

Parties must confer in person, by phone, or via Zoom to resolve discovery disputes before filing a discovery motion; email alone is insufficient.

Counsel must confer in good faith before seeking court intervention for discovery disputes.

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

Discovery motions limited to 5 pages.

Each party limited to one Daubert motion with 20-page limit, certification required.

Discovery motions and response briefs limited to 10 pages; reply briefs limited to 5 pages.

Discovery motions and responses are limited to 5 pages; replies are prohibited (0 pages).

Discovery motions limited to 3 pages.

Electronic devices are prohibited in federal courthouses except for specified categories.

Proposed protective orders for joint motions must be in Word (DOCX) format.

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

Electronic devices are prohibited in federal courthouses except for specified categories.

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

Parties may agree to extensions of interim discovery deadlines without court approval if they do not impact the discovery cutoff or scheduling order deadlines.

Discovery disputes must be brought to court within 28 days of when grounds for relief occur.

Motion must be filed within 30 days; response within 5 business days; reply within 3 business days.

Responses and replies to discovery motions due within 7 days.

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

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.

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

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

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.

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.

The Court strongly encourages attorneys with five or fewer years of experience to participate in all court proceedings, including discovery hearings.

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

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

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

Settlement negotiations before conference are not required but encouraged.

Motions and memoranda are rarely needed.

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

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.

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

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

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

Proposed orders must be emailed to chambers in Word format.

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

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