Judge Yeney Hernandez's rules set a pre-motion procedure for discovery. Parties must confer in good faith (in person, video, or phone, not just email) before seeking court intervention for discovery disputes.
Judge Yeney Hernandez's rule states these limits: 5 pages. Notice of Hearing is limited to 5 pages per side.
The rule identifies required filing content or certificates. No additional materials after Notice of Hearing is filed; amendments require emailing Chambers for leave.
The rule requires certificate of conference. Counsel must include a certificate of good faith meet and confer efforts complying with Local Rule 7.1(a)(3) when seeking court intervention for discovery disputes.
Parties may contact Judge Yeney Hernandez's chambers by email only as allowed by the rule. The rule lists email Chambers_Hernandez@flsd.uscourts.gov. Moving parties must email chambers within Local Rule 26.1(g)(2) timeframe to schedule discovery hearings, with specific subject line, date, and content requirements.
The rule addresses filing timing, filing status, or cure windows. 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 rule addresses service method, recipient, or timing requirements. Objections to the scope of a deposition notice must be timely served, not filed, in advance of the deposition.
No additional materials after Notice of Hearing is filed; amendments require emailing Chambers for leave.
Parties must confer in good faith (in person, video, or phone, not just email) before seeking court intervention for discovery disputes.
Counsel must include a certificate of good faith meet and confer efforts complying with Local Rule 7.1(a)(3) when seeking court intervention for discovery disputes.
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.
Discovery dispute resolution must be completed before the discovery cutoff date; no court intervention or remedies are available after the cutoff.
Discovery motions under Rule 37 are prohibited without court leave; exceptions for stay discovery or extension of time to respond to discovery motions, which go to District Judge.
Moving parties must email chambers within Local Rule 26.1(g)(2) timeframe to schedule discovery hearings, with specific subject line, date, and content requirements.
Moving party must state requested additional time in email to Chambers for discovery hearing.
Notice of Hearing is limited to 5 pages per side.
Notice of Hearing must be filed within one business day of Court confirming hearing date and time.
Notice of Hearing must not include any legal argument, only frame issues and explain dispute.
Notice of Hearing must include Exhibits A (proposed order), B (source materials), C (citations list and copies of authorities).
Exhibit C (citations list) must not contain legal argument; highlighting and parentheticals allowed.
Notice of Hearing must include a certificate of conferral complying with Local Rule 7.1(a)(3).
Email communications are not evidence of conferral; counsel communications not evidence, but may be addressed orally at hearing.
Parties must email Chambers if all or some discovery disputes are resolved; file Notice of Cancellation if all resolved.
For agreed orders, do not file motion; email Chambers proposed order in Word format with agreement statement.
Objections to Court-entered orders differing from proposed order must use discovery hearing procedures, no motion required.
Court will not enter stipulated orders extending discovery response deadlines or unlitigated discovery agreement orders.
Objections to the scope of a deposition notice must be timely served, not filed, in advance of the deposition.