Judge Fernando L. Aenlle-Rocha

Parties must file a Joint Status Report within 7 days after the settlement conference.

Otherwise, the parties must file, within seven (7) days after the settlement conference, a Joint Status Report regarding the outcome of settlement negotiations, the likelihood of possible further negotiations, and any assistance the court may

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Page 6 | D

Parties must file a Notice of Settlement within 7 days after the case settles.

If the case settles, the parties shall file a Notice of Settlement within seven (7) days after the case is settled.

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Page 6 | D

Proposed FPTCO must be filed at least 14 days before the Final Pretrial Conference.

The parties must file a proposed Final Pretrial Conference Order ("Proposed FPTCO") at least fourteen (14) days before the FPTC.

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Page 7 | Final Pretrial Conference/Proposed Final Pretrial Conference Order

Oppositions to motions in limine must be filed at least 14 days before FPTC.

At least fourteen (14) days before the FPTC: Oppositions to Motions in Limine

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Page 8 | Schedule for Filing Pretrial Documents for Jury and Bench Trials

Motions in limine, memoranda of contentions, witness lists, joint exhibit list, joint status report, proposed findings (bench trial), and declarations (bench trial) must be filed at least 28 days before FPTC.

At least twenty-eight (28) days before the FPTC: Motions in Limine, Memoranda of Contentions of Fact and Law, Witness Lists, Joint Exhibit List, Joint Status Report Regarding Settlement, Proposed Findings of Fact and Conclusions of Law (bench trial only), Declarations containing Direct Testimony (bench trial only).

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Page 8 | Schedule for Filing Pretrial Documents for Jury and Bench Trials

Oppositions to motions in limine must be filed at least 14 days before the FPTC.

Oppositions must be filed at least fourteen (14) days before the FPTC.

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Page 9 | TRIAL REQUIREMENTS

Motions in limine must be filed at least 28 days before the FPTC.

All motions in limine must be filed at least twenty-eight (28) days before the FPTC.

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Page 9 | TRIAL REQUIREMENTS

Amended Joint Exhibit List must be filed by noon on the Friday before trial and emailed to chambers in Word format.

Any Amended Joint Exhibit List must be filed by 12:00 p.m. (noon) on the Friday before trial and emailed to FLA_Chambers@cacd.uscourts.gov in Microsoft Word format.

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Page 10 | TRIAL REQUIREMENTS

Witness lists must be filed 28 days before FPTC, follow LR 16-5 format, include specific content, and use the judge's template.

Witness lists must be filed twenty-eight (28) days before the FPTC. They must be in the format specified in Local Rule 16-5, and must include for each witness (i) a brief description of the testimony, (ii) the reasons the testimony is unique and not redundant, and (iii) a time estimate in hours for direct and cross-examination. The parties should use the template posted to Judge Aenlle-Rocha’s webpage.

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Page 10 | TRIAL REQUIREMENTS

Joint Exhibit List must be filed 28 days before FPTC, follow LR 16-6 format, include objections column, and use the judge's template.

The Joint Exhibit List must be filed twenty-eight (28) days before the FPTC. It must be in the format specified in Local Rule 16-6 and shall include an additional column stating any objections to authenticity and/or admissibility and the reasons for the objections. The parties should use the template posted to Judge Aenlle-Rocha’s webpage.

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Page 10 | TRIAL REQUIREMENTS

Joint agreed jury instructions must be filed no later than 14 days before the FPTC.

Joint agreed upon proposed jury instructions must be filed no later than fourteen (14) days prior to the FPTC.

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Page 10 | TRIAL REQUIREMENTS

Amended witness lists must be filed by noon on the Friday before trial and emailed to chambers in Word format.

Any Amended Witness List must be filed by 12:00 p.m. (noon) on the Friday before trial and emailed to FLA_Chambers@cacd.uscourts.gov in Microsoft Word format.

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Page 10 | TRIAL REQUIREMENTS

Parties must file joint agreed and disputed jury instructions 14 days before the final pretrial conference.

Fourteen (14) days before FPTC: The parties shall file their (1) Joint Agreed Upon Proposed Jury Instructions and their (2) Disputed Jury Instructions.

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Page 11 | Jury Instructions

Parties must file a proposed joint general verdict form 14 days before the final pretrial conference.

The parties shall make every effort to agree on a general verdict form before submitting proposals to the court, and shall file a proposed joint general verdict form fourteen (14) days before the FPTC.

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Page 12 | Joint Verdict Forms

Joint Statement of the Case must be filed 14 days before the Final Pretrial Conference.

The parties must file a Joint Statement of the Case fourteen (14) days before the FPTC for the court to read to the prospective jurors before commencement of voir dire.

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Page 13 | 6. Joint Statement of the Case (Jury Trial Only)

Proposed Findings of Fact and Conclusions of Law must be filed 28 days before FPTC in Local Rule 52-3 format.

For any trial requiring findings of fact and conclusions of law, each party shall file and serve on the opposing party, no later than twenty-eight (28) days before the FPTC, its Proposed Findings of Fact and Conclusions of Law in the format specified in Local Rule 52-3.

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Page 14 | 8. Proposed Findings of Fact and Conclusions of Law (Bench Trial Only)

Declarations of direct testimony must be filed 28 days before FPTC when ordered by the court.

When ordered by the court in a particular case, each party shall, at least twenty-eight (28) days before the FPTC, file declarations containing the direct testimony of each witness whom that party intends to call at trial.

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Page 14 | 9. Declarations of Direct Testimony (Bench Trial Only)

Evidentiary objections to declarations must be filed 14 days before FPTC.

If such declarations are filed, each party shall file any evidentiary objections to the declarations submitted by any other party at least fourteen (14) days before the FPTC.

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Page 14 | 9. Declarations of Direct Testimony (Bench Trial Only)

Reply in support of Rule 56 motion is due 1 week after the opposition is filed.

Reply due 1 week after Opposition is filed

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Page 2 | SCHEDULE OF PRETRIAL DATES

Opposition to Rule 56 motion is due 2 weeks after the motion is filed.

Opposition due 2 weeks after Motion is filed

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Page 2 | SCHEDULE OF PRETRIAL DATES

All motions must be scheduled for hearing on or before the applicable deadline.

All motions must be noticed to be heard on or before their respective deadlines.

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Page 2 | SCHEDULE OF PRETRIAL DATES

Rule 56 motion must be filed at least 5 weeks before the hearing date.

Rule 56 Motion due at least 5 weeks before hearing

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Page 2 | SCHEDULE OF PRETRIAL DATES

Proposed FPTCO must be filed at least 14 days before the Final Pretrial Conference.

The parties must file a proposed Final Pretrial Conference Order ("Proposed FPTCO") at least fourteen (14) days before the FPTC.

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Page 7 | E. Final Pretrial Conference/Proposed Final Pretrial Conference Order

Proposed Findings of Fact and Conclusions of Law and Declarations containing Direct Testimony (bench trial only) must be filed at least 28 days before the FPTC.

Proposed Findings of Fact and Conclusions of Law (bench trial only) ... Declarations containing Direct Testimony (bench trial only)

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Page 8 | A. Schedule for Filing Pretrial Documents for Jury and Bench Trials

Jury trial documents (jury instructions, verdict forms, statement of case, voir dire) must be filed at least 14 days before the FPTC.

Joint Agreed Upon Proposed Jury Instructions (jury trial only) ... Disputed Proposed Jury Instructions (jury trial only) ... Joint Proposed Verdict Forms (jury trial only) ... Joint Proposed Statement of the Case (jury trial only) ... Proposed Voir Dire Questions, if any (jury trial only)

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Page 8 | A. Schedule for Filing Pretrial Documents for Jury and Bench Trials

Motions in Limine, Memoranda of Contentions of Fact and Law, Witness Lists, Joint Exhibit List, and Joint Status Report Regarding Settlement must be filed at least 28 days before the FPTC.

At least twenty-eight (28) days before the FPTC: Motions in Limine, Memoranda of Contentions of Fact and Law, Witness Lists, Joint Exhibit List, Joint Status Report Regarding Settlement

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Page 8 | A. Schedule for Filing Pretrial Documents for Jury and Bench Trials

Oppositions to Motions in Limine must be filed at least 14 days before the FPTC.

At least fourteen (14) days before the FPTC: Oppositions to Motions in Limine

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Page 8 | A. Schedule for Filing Pretrial Documents for Jury and Bench Trials

Motions in limine must be filed at least 28 days before the FPTC.

All motions in limine must be filed at least twenty-eight (28) days before the FPTC.

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Page 9 | 1. Motions in Limine

No replies are permitted for motions in limine.

There shall be no replies.

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Page 9 | 1. Motions in Limine

Oppositions to motions in limine must be filed at least 14 days before the FPTC.

Oppositions must be filed at least fourteen (14) days before the FPTC.

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Page 9 | 1. Motions in Limine

Joint Exhibit List must be filed 28 days before the FPTC.

The Joint Exhibit List must be filed twenty-eight (28) days before the FPTC.

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Page 10 | 3. Joint Exhibit List

Amended Joint Exhibit Lists must be filed by noon on the Friday before trial and emailed to chambers in Word format.

Any Amended Joint Exhibit List must be filed by 12:00 p.m. (noon) on the Friday before trial and emailed to FLA_Chambers@cacd.uscourts.gov in Microsoft Word format.

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Page 10 | 3. Joint Exhibit List

Witness lists must be filed 28 days before the FPTC.

Witness lists must be filed twenty-eight (28) days before the FPTC.

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Page 10 | 2. Witness Lists

Amended Witness Lists must be filed by noon on the Friday before trial and emailed to chambers in Word format.

Any Amended Witness List must be filed by 12:00 p.m. (noon) on the Friday before trial and emailed to FLA_Chambers@cacd.uscourts.gov in Microsoft Word format.

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Page 10 | 2. Witness Lists

Joint agreed upon proposed jury instructions must be filed no later than 14 days before the FPTC.

Joint agreed upon proposed jury instructions must be filed no later than fourteen (14) days prior to the FPTC.

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Page 10 | 4. Jury Instructions (Jury Trial Only)

Parties must file joint agreed and disputed jury instructions 14 days before the Final Pretrial Conference.

Fourteen (14) days before FPTC: The parties shall file their (1) Joint Agreed Upon Proposed Jury Instructions and their (2) Disputed Jury Instructions.

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Page 11 | Jury Instructions

Parties must file a joint general verdict form 14 days before FPTC, or file competing verdict forms with redline and basis if no agreement.

The parties shall make every effort to agree on a general verdict form before submitting proposals to the court, and shall file a proposed joint general verdict form fourteen (14) days before the FPTC. If the parties are unable to agree on a verdict form, the parties shall file one document titled 'Competing Verdict Forms' which shall include: (i) the parties' respective proposed verdict form; (ii) a 'redline' of any disputed language; and (iii) the factual or legal basis for each party's respective position.

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Page 12 | Joint Verdict Forms (Jury Trial Only)

Proposed Findings of Fact and Conclusions of Law must be filed no later than 28 days before the FPTC.

For any trial requiring findings of fact and conclusions of law, each party shall file and serve on the opposing party, no later than twenty-eight (28) days before the FPTC, its Proposed Findings of Fact and Conclusions of Law in the format specified in Local Rule 52-3.

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Page 13 | 8. Proposed Findings of Fact and Conclusions of Law (Bench Trial Only)

Parties must exchange proposed jury instructions 35 days before the final pretrial conference.

Thirty-five (35) days before the FPTC: The parties shall exchange proposed general and special jury instructions.

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Page 11 | Jury Instructions

Parties must exchange objections to jury instructions 28 days before the final pretrial conference.

Twenty-eight (28) days before the FPTC: The parties shall exchange any objections to the instructions.

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Page 11 | Jury Instructions

Proposed Findings of Fact and Conclusions of Law must be served on the opposing party.

each party shall file and serve on the opposing party, no later than twenty-eight (28) days before the FPTC, its Proposed Findings of Fact and Conclusions of Law

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Page 13 | 8. Proposed Findings of Fact and Conclusions of Law (Bench Trial Only)

Proofs of service must be filed within 3 days after service of summons and complaint.

If Plaintiff has not already served the operative complaint on all Defendants, Plaintiff shall do so promptly and shall file proofs of service of the summons and complaint within three (3) days thereafter.

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Page 2 | I. Introduction

Counsel must provide a copy of this Order to newly appearing parties and known but unappeared parties.

Plaintiff’s counsel or, if Plaintiff is appearing pro se, Defendant’s counsel, shall provide this Order to any parties who first appear after the date of this Order and to parties who are known to exist but have not yet entered appearances.

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Page 7 | IV. Notice to be Provided by Counsel

Counsel must deliver copies of this Order and the Scheduling and Trial Order to their clients.

Counsel are ordered to deliver to their clients a copy of this Order and the court’s forthcoming Scheduling and Trial Order, which will contain the pretrial and trial schedule for this action.

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Page 7 | V. Disclosures to Clients

Tables must be attached, electronically filed, and emailed as editable Excel files.

All tables shall be attached to the motion and electronically filed. The courtesy copy of the table shall be emailed to the court’s chambers email address at fla_chambers@cacd.uscourts.gov as a Microsoft Excel file with all restrictions removed so the spreadsheet can be edited.

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Chambers courtesy copies are required.

B. Chambers Courtesy Copies ........................................................................ 14

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Chambers courtesy copies are required for certain filings

B. Chambers Courtesy Copies

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Page 2 | II. GENERAL REQUIREMENTS

Chambers courtesy copies are required.

Chambers Courtesy Copies ........................................................................ 14

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Page 2 | V. ADDITIONAL REQUIREMENTS

Conformed copies of moving papers and responses must be delivered to Magistrate Judge's Courtroom Deputy Clerk at time of filing.

Counsel shall deliver a conformed copy of the moving papers and responses to the Magistrate Judge's Courtroom Deputy Clerk at the time of filing.

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Attorney fee table courtesy copies must be emailed to chambers as editable Excel files.

The courtesy copy of the table shall be emailed to the court's chambers email address at fla_chambers@cacd.uscourts.gov as a Microsoft Excel file with all restrictions removed so the spreadsheet can be edited.

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Parties must email courtesy copies of specified trial documents to chambers in Word format on the day they are due.

The parties shall email copies of: (1) the Witness Lists, (2) the Joint Exhibit List, (3) the Joint Proposed FPTCO, (4) the Joint Agreed Upon Proposed Jury Instructions, (5) the Disputed Proposed Jury Instructions, (6) Joint Proposed Verdict Forms, and (7) Proposed Voir Dire Questions, including any amended documents, in Microsoft Word format to chambers the day they are due at: FLA_Chambers@cacd.uscourts.gov.

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Page 9 | TRIAL REQUIREMENTS

Amended witness lists must be emailed to chambers in Word format.

Any Amended Witness List must be filed by 12:00 p.m. (noon) on the Friday before trial and emailed to FLA_Chambers@cacd.uscourts.gov in Microsoft Word format.

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Page 10 | TRIAL REQUIREMENTS

Amended Joint Exhibit List must be emailed to chambers in Word format.

Any Amended Joint Exhibit List must be filed by 12:00 p.m. (noon) on the Friday before trial and emailed to FLA_Chambers@cacd.uscourts.gov in Microsoft Word format.

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Page 10 | TRIAL REQUIREMENTS

Parties must deliver two courtesy copies of trial exhibits to the Courtroom Deputy Clerk on first day of trial.

The parties must present the following materials to the Courtroom Deputy Clerk on the first day of trial: 1. The three sets of binders described above, with one (1) original set of trial exhibits for the jury, and two (2) copies of trial exhibits for the court.

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Page 16 | C. Materials to Present on First Day of Trial

Chambers copies should not be submitted unless specifically requested.

The processing of unnecessary chambers copies wastes resources and burdens the court. Chambers copies should not be submitted unless requested. This order, however, is not intended to affect the parties’ ability to file and lodge documents and materials that are exempt from electronic filing under Local Rule 5-4.2.

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Chambers copies should not be submitted unless specifically requested.

The processing of unnecessary chambers copies wastes resources and burdens the court. Chambers copies should not be submitted unless requested. This order, however, is not intended to affect the parties’ ability to file and lodge documents and materials that are exempt from electronic filing under Local Rule 5-4.2.

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Page 14 | V. Additional Requirements

Chambers courtesy copies are discouraged unless specifically requested.

Chambers copies should not be submitted unless requested.

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Procedure exists for filings under seal.

D. Filings Under Seal ...................................................................................... 15

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Sealed documents with confidential titles require two cover sheets with generic title.

Parties should pay close attention to the title in the caption of every document submitted to the court for filing under seal. The title of the document will become part of the public docket text when it is entered on the docket, even though the document itself will be sealed. If the title of the document contains confidential information that should not be reflected on the public docket, parties must submit the document with two cover sheets. The first cover sheet must contain a generic title (e.g.: “SEALED APPLICATION”; “SEALED MOTION”; “SEALED PROPOSED

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Sentencing documents may be filed under seal only when strictly necessary, with redacted version justifying deletions.

The court does not permit sentencing documents to be filed under seal except as strictly necessary and justified. When necessary, a sentencing document may be filed under seal along with a redacted version that deletes the confidential information and that justifies each deletion (e.g., "medical information").

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Sealed documents must be identified by first-listed defendant and case number only.

The outer envelope containing any document filed under seal or in camera should identify the case title by the first-listed defendant and case number only, and should state that the document is being filed under seal or in camera.

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Applications to file under seal must comply with Local Rule 79-5 and 79-5.2.2.

Local Rule 79-5 governs applications to file documents under seal. Local Rule 79-5.2.2 explains how to apply to file under seal and how to proceed if leave is granted. Parties must comply with all provisions of Local Rule 79-5.

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Page 15 | D. Filings Under Seal

Parties must file both a complete sealed version and a redacted public version of documents.

The parties should file a complete version of the documents under seal and a redacted version for public viewing, omitting only the portions that the court has authorized to be filed under seal.

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Page 15 | D. Filings Under Seal

Each document sought to be sealed requires individual justification showing good cause or compelling reasons.

For each document or other type of information a party seeks to file under seal, the party must identify and discuss the factual and/or legal justification that establishes "good cause" or "compelling reasons" for the information to be protected.

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Page 15 | D. Filings Under Seal

Parties must meet and confer before filing an application to seal.

An application to seal also must meet and confer before filing an application to seal.

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Page 16 | D. Filings Under Seal

Each item must be individually justified for sealing; blanket claims will be denied.

Sealing must be justified for each individual item: blanket claims of confidentiality will result in the application to seal being denied. Counsel is strongly encouraged to consider carefully whether sealing or redaction is absolutely required for a given piece of evidence or argument. An application to seal that

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Local Rule 79-5 governs applications to file documents under seal.

Local Rule 79-5 governs applications to file documents under seal. Local Rule 79-5.2.2 explains how to apply to file under seal and how to proceed if leave is granted. Parties must comply with all provisions of Local Rule 79-5.

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File complete sealed version and redacted public version when possible.

Documents that are not confidential or privileged in their entirety should not be filed under seal if the confidential portions can be redacted and filed separately with a reasonable amount of effort. The parties should file a complete version of the documents under seal and a redacted version for public viewing, omitting only the portions that the court has authorized to be filed under seal.

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Protective orders for discovery must be submitted to Magistrate Judge; cannot authorize sealing for dispositive motions or trial without court order.

Proposed protective orders pertaining to discovery must be submitted to the assigned Magistrate Judge. Protective orders must not purport to allow any matters to be filed under seal in connection with dispositive motions (including a class certification motion) or trial without a court order. The existence of a protective order alone does not authorize the filing of pleadings or other documents under seal in whole or in part.

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Blanket confidentiality claims are prohibited; each item must be individually justified.

Sealing must be justified for each individual item: blanket claims of confidentiality will result in the application to seal being denied.

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Page 15 | D. Filings Under Seal

Sealed filings are permitted.

Filings Under Seal ...................................................................................... 15

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Page 2 | V. ADDITIONAL REQUIREMENTS

Cross-motions on same issues prohibited; parties must meet and confer to determine single moving party.

the court will not entertain cross-motions that seek to adjudicate the same legal issues. If parties wish to cross-move for summary judgment, their counsel shall meet and confer to determine which party will move and which will oppose the one motion for summary judgment.

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Multiple summary judgment motions or exceeding page/word limits requires leave of court with good cause showing.

evade the word or page limitations for briefs by filing multiple motions. If a party believes good cause exists for more than one summary judgment motion or to increase word or page limits, the party shall seek leave by noticed motion setting forth a detailed showing of good cause. Failure to do so will result in the striking of the motion(s).

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Cross-motions on same issues prohibited; parties must meet and confer to determine single moving party.

the court will not entertain cross-motions that seek to adjudicate the same legal issues. If parties wish to cross-move for summary judgment, their counsel shall meet and confer to determine which party will move and which will oppose the one motion for summary judgment.

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Page 9 | Page 9

Post-trial briefs are prohibited unless the court specifically authorizes additional briefing.

The court will not accept post-trial briefs unless it finds that circumstances warrant additional briefing and such briefing is specifically authorized.

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Page 18 | D. Closing Arguments and Post-Trial Briefs (Bench Trial)

TRO applications will not be ruled on for at least 24 hours after service unless notice is excused.

The court will not rule on any Application for a TRO for at least twenty-four (24) hours after the party subject to the requested order has been served, unless notice is excused as per Fed. R. Civ. P. 65(b), or the interests of justice so require.

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Opposition to ex parte applications must be filed within 24 hours of service.

Following service of the ex parte application by electronic, facsimile, or personal service, the moving party shall notify the opposing party that any opposition must be filed no later than twenty-four (24) hours following service.

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Good faith conference required before motions to dismiss/strike under Local Rule 7-3.

Many motions to dismiss or strike can be avoided if the parties confer in good faith as required by Local Rule 7-3, especially for perceived defects in a complaint, answer, or counterclaim that can be corrected by amendment.

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All parties must participate in settlement conference or ADR.

As stated in Local Rule 16-15, the parties in every action must participate in a Settlement Conference or Alternative Dispute Resolution (“ADR”) procedure.

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Pre-filing meet and confer requirement exists for motions.

B. Pre-Filing Requirement to Meet and Confer ........................................................... 6

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Scheduling conference will be set per FRCP 16 and 26; strict compliance required.

Pursuant to Fed. R. Civ. P. 16(b), the court will issue an order setting a scheduling conference as required by Fed. R. Civ. P. 26 and the Local Rules of this court. Strict compliance with Fed. R. Civ. P. 16 and 26 is required.

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Pre-filing conference required to discuss motion substance and potential resolution.

Counsel must comply with Local Rule 7-3, which requires counsel to engage in a pre-filing conference “to discuss thoroughly … the substance of the contemplated motion and any potential resolution.” Counsel shall discuss the issues to a sufficient degree that if a motion is still necessary, the briefing may be directed to those substantive issues requiring resolution by the court.

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Page 6 | III. MOTIONS – GENERAL REQUIREMENTS

Rule 56 motions require 35-day filing deadline, 21-day opposition deadline, and 14-day reply deadline.

The hearing on any such motion shall be set for a date in advance of the Final Pretrial Conference. This court requires an extended briefing schedule for motions under Rule 56, as follows: • Any Rule 56 Motion must be filed at least thirty-five (35) days before the noticed hearing date. • Any Opposition must be filed at least twenty-one (21) days before the noticed hearing date (fourteen (14) days after the Motion is filed). • Any Reply must be filed at least fourteen (14) days before the noticed hearing date (seven (7) days after the opposition is filed).

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Page 9 | Page 9

Rule 56 motions require extended briefing schedule: motion 35 days before hearing, opposition 21 days before (14 days after motion), reply 14 days before (7 days after opposition).

Any Rule 56 Motion must be filed at least thirty-five (35) days before the noticed hearing date. Any Opposition must be filed at least twenty-one (21) days before the noticed hearing date (fourteen (14) days after the Motion is filed). Any Reply must be filed at least fourteen (14) days before the noticed hearing date (seven (7) days after the opposition is filed).

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Page 9 | IV. SPECIFIC MOTION REQUIREMENTS

Opposition to TRO applications must be filed within 24 hours of service.

Applications for a Temporary Restraining Order ("TRO") are governed by Local Rule 7-19, which applies to ex parte applications. Thus, oppositions to an Application for a TRO must be filed within twenty-four (24) hours following service of the Application.

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Page 17 | G. Injunctions and Restraining Orders

Court will not rule on TRO applications for at least 24 hours after service unless notice is excused.

The court will not rule on any Application for a TRO for at least twenty-four (24) hours after the party subject to the requested order has been served, unless notice is excused as per Fed. R. Civ. P. 65(b), or the interests of justice so require.

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Page 17 | G. Injunctions and Restraining Orders

Opposition to ex parte applications must be filed within 24 hours of service.

Following service of the ex parte application by electronic, facsimile, or personal service, the moving party shall notify the opposing party that any opposition must be filed no later than twenty-four (24) hours following service.

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Page 17 | G. Injunctions and Restraining Orders

Settlement conference or ADR required in every case.

As stated in Local Rule 16-15, the parties in every action must participate in a Settlement Conference or Alternative Dispute Resolution ("ADR") procedure.

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Page 18 | K. Settlement Conference / Alternative Dispute Resolution ("ADR")

Court will issue scheduling conference order; strict compliance with FRCP 16 and 26 required.

Pursuant to Fed. R. Civ. P. 16(b), the court will issue an order setting a scheduling conference as required by Fed. R. Civ. P. 26 and the Local Rules of this court. Strict compliance with Fed. R. Civ. P. 16 and 26 is required.

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Page 18 | J. Order Setting Scheduling Conference

Pre-filing conference required before any motion; Notice of Motion must include compliance statement; court may strike motion if parties fail to meet and confer in good faith.

Counsel must comply with Local Rule 7-3, which requires counsel to engage in a pre-filing conference "to discuss thoroughly … the substance of the contemplated motion and any potential resolution." Counsel shall discuss the issues to a sufficient degree that if a motion is still necessary, the briefing may be directed to those substantive issues requiring resolution by the court. Counsel shall resolve minor procedural or other non-substantive matters during the conference. The pro se status of one or more parties does not negate this requirement. The Notice of Motion must include a statement of compliance with Local Rule 7-3. The court may strike or deny a motion if counsel fail to meet and confer in good faith.

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Parties must meet and confer before filing motions or requests for relief, except for exempt categories.

The parties are required under Local Rule 7-3 to meet and confer to attempt to resolve disputes before filing a motion. In addition, this court requires the parties to meet and confer regarding any other request for relief except those identified as exempt in Local Rules 7-3 and 16-12.

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Discovery motions handled by assigned Magistrate Judge; must be filed early enough to obtain responses before discovery cut-off.

Discovery motions are handled by the Magistrate Judge assigned to the case. Any motion challenging the adequacy of discovery responses must be filed, served, and calendared sufficiently in advance of the discovery cut-off date to permit the responses to be obtained before that date if the motion is granted.

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For Rule 56 motions, the motion must be filed at least 5 weeks before the hearing, opposition is due 2 weeks after the motion is filed, and reply is due 1 week after the opposition is filed.

 Rule 56 Motion due at least 5 weeks before hearing  Opposition due 2 weeks after Motion is filed  Reply due 1 week after Opposition is filed

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Page 4 | SCHEDULE OF PRETRIAL AND TRIAL DATES

Parties must meet and confer before filing any motion, except as exempted by Local Rules 7-3 and 16-12.

The parties are required under Local Rule 7-3 to meet and confer to attempt to resolve disputes before filing a motion. In addition, this court requires the parties to meet and confer regarding any other request for relief except those identified as exempt in Local Rules 7-3 and 16-12.

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Page 6 | C

Parties must meet and confer before filing a motion in limine.

Before filing a motion in limine, the parties must meet and confer to determine whether the opposing party intends to introduce the disputed evidence and attempt to reach an agreement that would obviate the need for the motion.

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Page 9 | TRIAL REQUIREMENTS

Parties must meet and confer before filing any motion, as required by Local Rule 7-3.

The parties are required under Local Rule 7-3 to meet and confer to attempt to resolve disputes before filing a motion.

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Page 2 | SCHEDULE OF PRETRIAL DATES

For Rule 56 motions, motion due 5 weeks before hearing, opposition due 2 weeks after motion, reply due 1 week after opposition.

Rule 56 Motion due at least 5 weeks before hearing. Opposition due 2 weeks after Motion is filed. Reply due 1 week after Opposition is filed.

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Page 4 | SCHEDULE OF PRETRIAL AND TRIAL DATES

Parties must meet and confer before filing any motion, except as exempted by Local Rules 7-3 and 16-12.

The parties are required under Local Rule 7-3 to meet and confer to attempt to resolve disputes before filing a motion. In addition, this court requires the parties to meet and confer regarding any other request for relief except those identified as exempt in Local Rules 7-3 and 16-12.

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Page 6 | C. Law and Motion and Local Rule 7-3

Rule 56 summary judgment motions must be filed at least 5 weeks before the hearing; opposition due 2 weeks after motion; reply due 1 week after opposition.

Rule 56 Motion due at least 5 weeks before hearing Opposition due 2 weeks after Motion is filed Reply due 1 week after Opposition is filed

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Page 11 | Last Date to Hear Motions

For Rule 56 motions, the motion must be filed at least 5 weeks before the hearing, opposition due 2 weeks after motion, reply due 1 week after opposition.

Rule 56 Motion due at least 5 weeks before hearing; Opposition due 2 weeks after Motion is filed; Reply due 1 week after Opposition is filed

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Page 3 | SCHEDULE OF PRETRIAL AND TRIAL DATES

Parties must meet and confer before filing any motion or request for relief, except as exempted by Local Rules 7-3 and 16-12.

The parties are required under Local Rule 7-3 to meet and confer to attempt to resolve disputes before filing a motion. In addition, this court requires the parties to meet and confer regarding any other request for relief except those identified as exempt in Local Rules 7-3 and 16-12.

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Page 5 | C. Law and Motion and Local Rule 7-3

Parties must participate in a settlement conference or ADR; no trial without personal appearance of all parties and corporate principals.

Pursuant to Local Rule 16-15, the parties must participate in a Settlement Conference or Alternative Dispute Resolution (“ADR”) procedure. The Scheduling Order indicates the procedure the parties shall use. If the parties prefer an ADR procedure other than the one ordered by the court, they shall file a Stipulation and Proposed Order. The parties’ request may not necessarily be granted. No case will proceed to trial unless all parties, including the principals of all corporate parties, have appeared personally at a settlement conference.

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Page 5 | D. Settlement Conference/Alternative Dispute Resolution Procedures

Parties must discuss planned motion to compel with opposing party at least 6 weeks before discovery cut-off.

a planned motion to compel must ordinarily be discussed with the opposing party at least six (6) weeks before the cut-off.

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Page 5 | B.1

For a motion to compel, parties must meet and confer at least six weeks before the discovery cut-off.

Given the requirements to meet and confer and to give notice, a planned motion to compel must ordinarily be discussed with the opposing party at least six (6) weeks before the cut-off.

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Page 5 | B. Discovery Cut-Off and Discovery Disputes

Parties must meet and confer before filing a motion in limine.

Before filing a motion in limine, the parties must meet and confer to determine whether the opposing party intends to introduce the disputed evidence and attempt to reach an agreement that would obviate the need for the motion.

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Page 9 | 1. Motions in Limine

Continuance requests must be filed at least 5 business days before deadline; expired deadlines show lack of due diligence.

Counsel shall avoid submitting requests for continuance or extension of time less than five (5) business days prior to the expiration of the scheduled date. A request to continue or extend dates or deadlines that have already expired constitutes a presumptive lack of due diligence.

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Continuance rules exist.

H. Continuances............................................................................................... 17

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Continuance requests must include a proposed order emailed to chambers on filing day.

Counsel requesting a continuance or extension of time must file electronically a request or, if the parties are in agreement, a stipulation which extension of time. A proposed order in Word format must be emailed directly to the court’s chambers email address at fla_chambers@cacd.uscourts.gov on the day the document is e-filed. The proposed order must include the entire relief the parties seek.

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Opposition to ex parte applications must be filed within 24 hours of service.

Following service of the ex parte application by electronic, facsimile, or personal service, the moving party shall notify the opposing party that any opposition must be filed no later than twenty-four (24) hours following service.

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Page 8 | C. Ex Parte Applications

Counsel must notify chambers via email at least 3 business days before a scheduled appearance if there's a calendar conflict with a more senior judge, and must propose a new date by stipulation.

If any counsel discovers a calendar conflict with a scheduled appearance in a court of a more senior district judge, counsel must inform opposing counsel and the Courtroom Deputy Clerk via chambers email address at twyla_freeman@cacd.uscourts.gov as soon as possible and not later than three (3) business days before the scheduled appearance. Counsel should attempt to agree on a new date to accommodate the calendar conflict. Counsel must propose a new date by Stipulation and [Proposed] Order.

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Page 4 | D. Calendar Conflicts

Continuance/extension requests require good cause, proposed order in Word format emailed to chambers, and should be filed at least 5 business days before deadline; expired deadlines are presumptively lacking due diligence.

Counsel requesting a continuance or extension of time must file electronically a request or, if the parties are in agreement, a stipulation which sets forth the factual basis for the request for an extension of time. A proposed order in Word format must be emailed directly to the court's chambers email address at fla_chambers@cacd.uscourts.gov on the day the document is e-filed. The proposed order must include the entire relief the parties seek. Failure to comply with the Local Rules and this Order will result in rejection of the request without further notice to the parties. Requests extending scheduling dates do not become effective unless and until this court so orders. Counsel shall avoid submitting requests for continuance or extension of time less than five (5) business days prior to the expiration of the scheduled date. A request to continue or extend dates or deadlines that have already expired constitutes a presumptive lack of due diligence.

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Page 17 | H. Continuances

Continuance or extension requests must be filed electronically.

Counsel requesting a continuance or extension of time must file electronically a request or, if the parties are in agreement, a stipulation which

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Page 18 | H. Continuances

Motion to compel must be discussed with opposing party at least 6 weeks before discovery cut-off.

Given the requirements to meet and confer and to give notice, a planned motion to compel must ordinarily be discussed with the opposing party at least six (6) weeks before the cut-off.

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Continuance requests must be by motion/stipulation/application with detailed declaration including prior request history.

Requests for continuances of pretrial and trial dates must be by motion, stipulation, or application, and be accompanied by a detailed declaration setting forth the reasons for the requested relief. The declaration should include whether any previous requests for continuances have been made and whether these requests were granted or denied by the court. Stipulations extending dates set by the court are not effective unless approved by the court.

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Continuance requests require detailed factual showing of good cause and due diligence, with specific description of efforts since complaint filing.

supported by a detailed factual showing of good cause and due diligence demonstrating the necessity for the continuance and a description of the parties' efforts, dating back to the filing of the complaint, of the steps they have taken to advance the litigation. This detailed showing must demonstrate that the work still to be performed reasonably could not have been accomplished within the applicable deadlines. General statements are insufficient to establish good cause. Without such compelling factual support and showing of due diligence, requests to continue dates set by the court may be denied.

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Continuance requests must be by motion or stipulation, include a detailed declaration with reasons and history of prior requests, and show good cause and due diligence; stipulations require court approval.

Requests for continuances of pretrial and trial dates must be by motion, stipulation, or application, and be accompanied by a detailed declaration setting forth the reasons for the requested relief. The declaration should include whether any previous requests for continuances have been made and whether these requests were granted or denied by the court. Stipulations extending dates set by the court are not effective unless approved by the court. ... a request or stipulation to continue a trial or pretrial date must be supported by a detailed factual showing of good cause and due diligence demonstrating the necessity for the continuance and a description of the parties’ efforts, dating back to the filing of the complaint, of the steps they have taken to advance the litigation. This detailed showing must demonstrate that the work still to be performed reasonably could not have been accomplished within the applicable deadlines. General statements are insufficient to establish good cause. Without such compelling factual support and showing of due diligence, requests to continue dates set by the court may be denied.

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Page 21 | K

Continuance requests must be by motion/stipulation/application with a detailed declaration showing good cause and due diligence, including previous requests and efforts dating back to complaint filing.

Requests for continuances of pretrial and trial dates must be by motion, stipulation, or application, and be accompanied by a detailed declaration setting forth the reasons for the requested relief. The declaration should include whether any previous requests for continuances have been made and whether these requests were granted or denied by the court. Stipulations extending dates set by the court are not effective unless approved by the court. ... Therefore, a request or stipulation to continue a trial or pretrial date must be supported by a detailed factual showing of good cause and due diligence demonstrating the necessity for the continuance and a description of the parties’ efforts, dating back to the filing of the complaint, of the steps they have taken to advance the litigation. This detailed showing must demonstrate that the work still to be performed reasonably could not have been accomplished within the applicable deadlines. General statements are insufficient to establish good cause.

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Page 21 | K. Continuances of Pretrial and Trial Dates

Continuance requests must be by motion/stipulation/application with a detailed declaration showing good cause, due diligence, prior requests, and efforts since complaint filing; stipulations require court approval.

Requests for continuances of the trial date must be by motion, stipulation, or application, and be accompanied by a detailed declaration setting forth the reasons for the requested relief. The declaration should include whether any previous requests for continuances have been made and whether these requests were granted or denied by the court. Stipulations extending dates set by the court are not effective unless approved by the court. The court has a strong interest in keeping scheduled dates certain, and changes in dates are disfavored. Trial dates set by the court will not readily be changed. Therefore, a request or stipulation to continue a trial date must be supported by a detailed factual showing of good cause and due diligence demonstrating the necessity for the continuance and a description of the parties’ efforts, dating back to the filing of the complaint, of the steps they have taken to advance the litigation. This detailed showing must demonstrate that the work still to be performed reasonably could not have been accomplished within the applicable deadlines. General statements are insufficient to establish good cause. Without such compelling factual support and showing of due diligence, requests to continue dates set by the court may be denied.

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Page 6 | F. Continuances of Trial Date

Requests to extend already-expired deadlines show presumptive lack of due diligence.

A request to continue or extend dates or deadlines that have already expired constitutes a presumptive lack of due diligence.

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Page 18 | H. Continuances

Continuance requests should not be submitted within 5 business days of the deadline.

Counsel shall avoid submitting requests for continuance or extension of time less than five (5) business days prior to the expiration of the scheduled date.

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Page 18 | H. Continuances

Court strongly disfavors changes to scheduled dates and will not readily change trial dates.

The court has a strong interest in keeping scheduled dates certain, and changes in dates are disfavored. Trial dates set by the court will not readily be changed.

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Continuance of the Scheduling Conference requires good cause.

A request to continue the Scheduling Conference will be granted only for good cause.

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Page 6 | III. Scheduling Conference

Motions heard Fridays at 1:30 PM; no pre-clearance needed except for summary judgment, TRO, or preliminary injunctions.

The court hears motions in civil actions on Fridays, beginning at 1:30 p.m. It is not necessary to clear a hearing date with the Courtroom Deputy Clerk before filing a motion, except for motions for summary judgment, temporary restraining orders, or preliminary injunctions.

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Page 5 | III. MOTIONS – GENERAL REQUIREMENTS

In-person attendance required for hearings and trials; telephone/video only for status conferences with undue hardship showing.

The court requires in-person attendance for all hearings and trials, unless otherwise instructed by the court. The court may permit appearances by telephone or video conference for status conferences upon a showing that a personal appearance will cause undue hardship.

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Page 16 | E. Appearance at Hearings

Remote appearance requests must be emailed to Courtroom Deputy Clerk with opposing counsel copied at least 3 court days in advance with undue hardship statement.

If you wish to appear by telephone or video conference, you must: 1. email the Courtroom Deputy Clerk and copy opposing counsel at least three (3) court days in advance of the scheduled appearance and provide a detailed statement of undue hardship;

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Page 16 | E. Appearance at Hearings

Counsel may not contact judge or chambers staff directly; contact Courtroom Deputy Clerk via email or phone only for appropriate matters, not for status inquiries.

Counsel must not attempt to contact the court or chambers staff by email, telephone, or ex parte means. For appropriate matters only, counsel may contact the Courtroom Deputy Clerk via chambers email address at twyla_freeman@cacd.uscourts.gov, or by telephone at (213) 894-5686. Counsel must not contact the Courtroom Deputy Clerk regarding the status of any matter before the court. Counsel must include on all papers his or her email address, telephone number, and facsimile number to facilitate communication with the Courtroom Deputy Clerk.

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Page 18 | I. Communications with Chambers

Phone contact with Courtroom Deputy Clerk permitted for appropriate matters only; status inquiries prohibited.

Counsel must not attempt to contact the court or chambers staff by email, telephone, or ex parte means. For appropriate matters only, counsel may contact the Courtroom Deputy Clerk via chambers email address at twyla_freeman@cacd.uscourts.gov, or by telephone at (213) 894-5686. Counsel must not contact the Courtroom Deputy Clerk regarding the status of any matter before the court.

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Page 18 | I. Communications with Chambers

In-person attendance required for all hearings/trials; remote appearances for status conferences only with 3-day advance notice and undue hardship showing.

The court requires in-person attendance for all hearings and trials, unless otherwise instructed by the court. The court may permit appearances by telephone or video conference for status conferences upon a showing that a personal appearance will cause undue hardship. If you wish to appear by telephone or video conference, you must: 1. email the Courtroom Deputy Clerk and copy opposing counsel at least three (3) court days in advance of the scheduled appearance and provide a detailed statement of undue hardship; 2. use a landline to call into the bridge line provided by the Courtroom Deputy Clerk or use a hardline internet connection to connect to the Zoom link for the court; and 3. be available and ready to call in for at least fifteen (15) minutes before the time of the scheduled hearing.

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Parties must notify court in advance of difficult legal issues and immediately notify Clerk of unexpected issues to minimize jury waiting time.

If any party anticipates that a difficult question of law or evidence will necessitate legal argument requiring research or briefing, that party must give the court advance notice. The parties must notify the Courtroom Deputy Clerk immediately of any unexpected legal issue that could not have been foreseen and addressed in advance. To the extent such issue needs to be addressed outside the jury's presence, the relevant party must inform the Courtroom Deputy Clerk before jurors are excused for the day to minimize the time jurors are kept waiting. The court expects all parties to work diligently to minimize delays and avoid keeping jurors waiting.

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Proposed FPTCO must be emailed to chambers in Microsoft Word format.

The parties shall email the Proposed FPTCO in Microsoft Word format to chambers at FLA_Chambers@cacd.uscourts.gov.

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Page 8 | E. Final Pretrial Conference/Proposed Final Pretrial Conference Order

Parties must email copies of specified trial documents in Word format to chambers on the due date.

The parties shall email copies of: (1) the Witness Lists, (2) the Joint Exhibit List, (3) the Joint Proposed FPTCO, (4) the Joint Agreed Upon Proposed Jury Instructions, (5) the Disputed Proposed Jury Instructions, (6) Joint Proposed Verdict Forms, and (7) Proposed Voir Dire Questions, including any amended documents, in Microsoft Word format to chambers the day they are due at: FLA_Chambers@cacd.uscourts.gov.

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Page 9 | Trial Requirements

Amended Witness Lists must be emailed to chambers in Word format.

Any Amended Witness List must be filed by 12:00 p.m. (noon) on the Friday before trial and emailed to FLA_Chambers@cacd.uscourts.gov in Microsoft Word format.

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Page 10 | 2. Witness Lists

Amended Joint Exhibit Lists must be emailed to chambers in Word format.

Any Amended Joint Exhibit List must be filed by 12:00 p.m. (noon) on the Friday before trial and emailed to FLA_Chambers@cacd.uscourts.gov in Microsoft Word format.

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Page 10 | 3. Joint Exhibit List

Contact chambers only for appropriate matters; do not inquire about case status.

Counsel must not attempt to contact the court or chambers staff by email, telephone, or ex parte means. For appropriate matters only, counsel may contact the Courtroom Deputy Clerk via chambers email address at twyla_freeman@cacd.uscourts.gov, or by telephone at (213) 894-5686. Counsel must not contact the Courtroom Deputy Clerk regarding the status of any matter before the court.

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Calendar conflicts with senior judges must be reported to chambers email within 3 business days; propose new date by stipulation and order.

If any counsel discovers a calendar conflict with a scheduled appearance in a court of a more senior district judge, counsel must inform opposing counsel and the Courtroom Deputy Clerk via chambers email address at twyla_freeman@cacd.uscourts.gov as soon as possible and not later than three (3) business days before the scheduled appearance. Counsel should attempt to agree on a new date to accommodate the calendar conflict. Counsel must propose a new date by Stipulation and [Proposed] Order.

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Page 4 | D. Calendar Conflicts

Do not contact chambers about case status.

Counsel must not contact the Courtroom Deputy Clerk regarding the status of any matter before the court.

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Page 18 | I. Communications with Chambers

Contact chambers only via specified email or phone for appropriate matters.

Counsel must not attempt to contact the court or chambers staff by email, telephone, or ex parte means. For appropriate matters only, counsel may contact the Courtroom Deputy Clerk via chambers email address at twyla_freeman@cacd.uscourts.gov, or by telephone at (213) 894-5686.

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Page 18 | I. Communications with Chambers

Ex parte applications considered on papers only; hearing only if court deems necessary; for extraordinary relief only.

The court considers ex parte applications on the papers and does not usually set these matters for hearing. The parties will be notified if the court deems a hearing necessary. Ex parte applications are solely for extraordinary relief and should be used with discretion. Sanctions may be imposed for misuse of ex parte applications.

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Parties must give advance notice of difficult legal issues and immediately notify the Courtroom Deputy Clerk of unexpected issues to minimize jury delays.

If any party anticipates that a difficult question of law or evidence will necessitate legal argument requiring research or briefing, that party must give the court advance notice. The parties must notify the Courtroom Deputy Clerk immediately of any unexpected legal issue that could not have been foreseen and addressed in advance. To the extent such issue needs to be addressed outside the jury’s presence, the relevant party must inform the Courtroom Deputy Clerk before jurors are excused for the day to minimize the time jurors are kept waiting.

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Page 21 | J

Parties must give advance notice to the court of anticipated difficult legal issues and immediately notify the Courtroom Deputy Clerk of unexpected issues.

If any party anticipates that a difficult question of law or evidence will necessitate legal argument requiring research or briefing, that party must give the court advance notice. The parties must notify the Courtroom Deputy Clerk immediately of any unexpected legal issue that could not have been foreseen and addressed in advance. To the extent such issue needs to be addressed outside the jury’s presence, the relevant party must inform the Courtroom Deputy Clerk before jurors are excused for the day to minimize the time jurors are kept waiting.

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Page 21 | J. Advance Notice of Unusual or Difficult Issues

Communications with chambers are governed by specific rules.

I. Communications with Chambers ............................................................... 18

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Communications with chambers are permitted.

Communications with Chambers ............................................................... 18

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Page 2 | V. ADDITIONAL REQUIREMENTS

Chambers email (twyla_freeman@cacd.uscourts.gov) must be used to notify of calendar conflicts at least 3 business days in advance.

If any counsel discovers a calendar conflict with a scheduled appearance in a court of a more senior district judge, counsel must inform opposing counsel and the Courtroom Deputy Clerk via chambers email address at twyla_freeman@cacd.uscourts.gov as soon as possible and not later than three (3) business days before the scheduled appearance.

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Page 4 | D. Calendar Conflicts

Counsel must inform Courtroom Deputy Clerk of exhibit agreements and exhibits admitted without motion.

Counsel must inform the Courtroom Deputy Clerk of any agreements reached regarding any proposed exhibits, as well as those exhibits that may be received into evidence without a motion to admit.

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Proposed FPTCO must be emailed to chambers at FLA_Chambers@cacd.uscourts.gov.

The parties shall email the Proposed FPTCO in Microsoft Word format to chambers at FLA_Chambers@cacd.uscourts.gov.

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Page 8 | Final Pretrial Conference/Proposed Final Pretrial Conference Order

Chambers email address for sending courtesy copies and amended documents.

FLA_Chambers@cacd.uscourts.gov

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Page 9 | TRIAL REQUIREMENTS

Parties must give advance notice of anticipated difficult legal issues and immediately notify the Courtroom Deputy Clerk of unexpected issues.

If any party anticipates that a difficult question of law or evidence will necessitate legal argument requiring research or briefing, that party must give the court advance notice. The parties must notify the Courtroom Deputy Clerk immediately of any unexpected legal issue that could not have been foreseen and addressed in advance.

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Page 6 | E. Advance Notice of Unusual or Difficult Issues

Junior lawyers (under 5 years) may increase likelihood of oral argument if noted in bold/underline.

The parties’ lead counsel are encouraged to permit junior or less experienced litigators to participate in court proceedings, including to argue motions and to examine witnesses at trial. The court is more likely to hear oral argument if a party notes in its moving or opposing papers, in bold and underlined font, that a litigator who graduated from law school within the last five (5) years, or otherwise has had minimal oral advocacy experience, will conduct the argument.

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Junior lawyers (graduated within 5 years or with minimal oral advocacy experience) increase likelihood of oral argument if noted in bold and underlined font.

The parties' lead counsel are encouraged to permit junior or less experienced litigators to participate in court proceedings, including to argue motions and to examine witnesses at trial. The court is more likely to hear oral argument if a party notes in its moving or opposing papers, in bold and underlined font, that a litigator who graduated from law school within the last five (5) years, or otherwise has had minimal oral advocacy experience, will conduct the argument.

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Page 7 | F. Oral Argument

Junior lawyers (under 5 years experience) may increase likelihood of oral argument if noted in bold/underline.

The parties’ lead counsel are encouraged to permit junior or less experienced litigators to participate in court proceedings, including to argue motions and to examine witnesses at trial. The court is more likely to hear oral argument if a party notes in its moving or opposing papers, in bold and underlined font, that a litigator who graduated from law school within the last five (5) years, or otherwise has had minimal oral advocacy experience, will conduct the argument.

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