The rule does not state that a pre-motion letter is required, but it sets the applicable pre-motion procedure. Parties must confer in person, by phone, or via Zoom to resolve discovery disputes before filing a discovery motion; email alone is insufficient.
Judge Ryon M. McCabe's rule states these limits: 5 pages; 5 pages. Discovery motions and responses are limited to 5 pages; replies are prohibited (0 pages).
The rule requires local rule certificate and certificate of conference. Discovery motions must include a certificate of good faith complying with Local Rule 7.1(a)(3).
The rule identifies required filing content or certificates. Privilege objections must identify the specific privilege nature, communication details, and sender/receiver relationships per Local Rule 26.1(e)(2)(B).
Parties may contact Judge Ryon M. McCabe's chambers by phone only as allowed by the rule. The Court will not accept telephone requests for immediate rulings on deposition conduct or objections during ongoing depositions.
Judge Ryon M. McCabe's rules specify what an adjournment or extension request must include. Parties may agree to extensions of interim discovery deadlines without court approval if they do not impact the discovery cutoff or scheduling order deadlines.
The rule addresses filing timing, filing status, or cure windows. Responses to discovery motions must be filed within 5 business days of service of the discovery motion.
Yes. Judge Ryon M. McCabe's rules include a junior lawyer participation incentive. The Court strongly encourages attorneys with five or fewer years of experience to participate in all court proceedings, including discovery hearings.
Discovery motions must include a certificate of good faith complying with Local Rule 7.1(a)(3).
Parties must confer in person, by phone, or via Zoom to resolve discovery disputes before filing a discovery motion; email alone is insufficient.
Discovery motions and responses are limited to 5 pages; replies are prohibited (0 pages).
Discovery motions must include as exhibits all relevant materials (e.g., discovery demands, responses) described per CM/ECF Rule 3L(2).
Discovery motions must cite the best supporting legal authority.
Responses to discovery motions must be filed within 5 business days of service of the discovery motion.
Parties may agree to extensions of interim discovery deadlines without court approval if they do not impact the discovery cutoff or scheduling order deadlines.
The Court will not accept telephone requests for immediate rulings on deposition conduct or objections during ongoing depositions.
Counsel must contact chambers via email (McCabe@flsd.us.courts.gov) to cancel or modify discovery hearing schedules if disputes are resolved.
The Court strongly encourages attorneys with five or fewer years of experience to participate in all court proceedings, including discovery hearings.
Privilege objections must identify the specific privilege nature, communication details, and sender/receiver relationships per Local Rule 26.1(e)(2)(B).
General privilege objections lacking a proper privilege log may be deemed waived.