Judge Caryn Siperstein
Individual Rules, Standing Orders & Policies
- Rules last changed:
Limits & Logistics
Document Limits
Courtesy Copies
Courtesy copies
- Before Hearing
- Upon Filing
Trial Brief
- Chambers Drop Off • At Least 5 Business Days Before Trial
E Filed Document
Court-wideJoint Pretrial Statement
Court-wide
Adjournments
- In an emergency requiring rescheduling of the compulsory medical examination, the physician or plaintiff must immediately notify their respective legal representative and provide the reason.
- Counsel should grant reasonable scheduling, rescheduling, cancellation, extension, and postponement requests when doing so would not prejudice the client's opportunity for full, fair, and prompt adjudication.
- Reasonable extensions of litigation deadlines should ordinarily be granted as a courtesy unless time is of the essence or a motion and order are required.
- +18 more
Request must include
Communication
Chambers
Phone
Chambers
Clerk
Phone
Court-wideClerk
Phone
Court-wideDuty Judge
Page & Word Limits1 rule
Not confirmed. Read the court's wording below.Note?
The parties should make best efforts to restrict Motions and Responses to no more than 5 pages for UMC and 10 pages for special set and ensure a proposed order is provided as indicated herein.
Summary: The standing order recommends limiting motions and responses to five pages on the Uniform Motion Calendar and ten pages for a special set, with a proposed order provided.
Motion
5 pages
Response
10 pages
Document Format Requirements17 rules
Checked against the court's document on Oct 1, 2026Mandatory
A complete set of proposed jury instructions and verdict forms must be filed with the clerk and submitted to the court in hard copy at the pretrial conference.
A complete set of proposed jury instructions and verdict forms were filed with the Clerk and submitted to the Court in hard copy form at the Pretrial Conference.
Paper
Checked against the court's document on Oct 1, 2026Mandatory
Every proposed order must be printed on 8.5-by-11-inch paper and provided to opposing counsel and any self-represented litigant.
All proposed orders must be printed on 8.5 x 11-inch paper and provided to opposing counsel and any self-represented litigant.
Checked against the court's document on Oct 1, 2026Mandatory
Every proposed order must be submitted in Word format and provided to opposing counsel and any self-represented litigant.
All proposed orders must be submitted in Word format and provided to opposing counsel and any self-represented litigant.
DOCX
Checked against the court's document on Oct 1, 2026Mandatory
If the fee-and-cost motion remains unresolved, the parties must jointly file a submission at Calendar Call and provide hardcopy billing spreadsheets for each attorney and a separate hardcopy costs spreadsheet.
If the parties cannot resolve the motion, then at Calendar Call, the parties shall jointly file a submission to the Court and provide a hardcopy of a spreadsheet for each attorney's billing and for one for the costs.
Checked against the court's document on Oct 1, 2026Important
Requested structured database data must be extracted with appropriate queries and returned in a verifiably responsive, readable format using specified criteria and fields.
Where structured data (e.g., data from a database) is requested, appropriate queries will be used to extract relevant data from any such database, which data shall match specified criteria, and returning specified fields, in a form and format that is verifiably responsive and readable by the use of commonly available tools.
Checked against the court's document on Oct 1, 2026Important
When native production is impossible or inadvisable, each file page must be converted into a single-page TIFF image reflecting its printed appearance.
In such cases where production in native format is not possible or advisable (e.g., redacted documents), native format files shall be converted to static images and each page thereof saved electronically as a single-page "TIFF" image that reflects how the source document would have appeared if printed out to a printer attached to a computer viewing the file.
Checked against the court's document on Oct 1, 2026Important
A TIFF production must include a multipage TXT file containing searchable text and the applicable metadata.
Accompanying this TIFF shall be a multipage text (.TXT) file containing searchable text from the native file, and the metadata as discussed later in this document.
Checked against the court's document on Oct 1, 2026Important
Documents not produced in native format must have each page saved electronically as an image file.
For file or records not produced in their native format, each page of a document shall be electronically saved as an image file.
Checked against the court's document on Oct 1, 2026Important
Documents or records available only or originally in hard-copy form must be converted to single-page TIFF files and produced under the same protocols or as otherwise agreed by the parties.
Documents or records which either were originally generated or instantiated as ESI but now only exist in physical hard-copy format, or documents or records that were originally generated in hard-copy format shall be converted to a single page .TIFF file and produced following the same protocols set forth herein or otherwise agreed to by the parties.
Checked against the court's document on Oct 1, 2026Important
Absent a requesting party's written agreement otherwise, ESI must be produced in native data format with all associated metadata.
Unless otherwise agreed to in writing by a requesting party, ESI shall be produced in native data format, together with all associated metadata.
Checked against the court's document on Oct 1, 2026Important
Electronic documents provided to the court should use the filing name “#___ Ex. [brief description of document].”
Documents that are uploaded or provided to the court in an electronic format should be named as follows: #___ Ex. [brief description of document]. For example, #1 Ex. contract between John Smith and Susan Jones 09.12.73.
Checked against the court's document on Oct 1, 2026Note
Static-image load files should accompany their associated images to facilitate use in document-management or litigation-support systems.
Load files of the static images should be created and produced together with their associated static images to facilitate the use of the produced images by a document management or litigation support database system.
We could not find this wording in the court's document. Open the source before relying on it.Mandatory?
All documents shall be pre-marked for identification, and shall be Bates stamped for ease of identification during remote testimony.
Machine summary and details
Summary: Documents used in the evidentiary hearing must be pre-marked for identification and Bates stamped.
Not confirmed. Read the court's wording below.Important?
There must be columns numbered in chronological order for each entry to address:
Summary: The fee-and-cost spreadsheets must contain chronologically numbered columns addressing the specified billing and cost information for each entry.
Not confirmed. Read the court's wording below.Important?
The parties agree that production will be made in native format, as the ESI exists on the producing party's computer system.
Summary: Producing parties must produce ESI in its native computer format.
Not confirmed. Read the court's wording below.Important?
No paper copies are needed. The Notice of Hearing should be attached for ease with the correct hearing date. This applies to each and every hearing, including UMC and Special Sets. . If the Court does not receive your proposed order with attachment on time, your hearing may be canceled.
Summary: No paper courtesy copies are needed, the notice of hearing should be attached to the proposed order for every UMC and special-set hearing, and a late submission may result in cancellation.
Paper
Not confirmed. Read the court's wording below.Important?
Courtesy copies must be submitted in Word format New Times Roman 12.
Summary: Courtesy copies must be submitted in Word format using Times New Roman 12-point font.
DOCX
Document Filing Requirements85 rules
Checked against the court's document on Oct 1, 2026Mandatory
A proposed form of order must be uploaded to OLS five days before any hearing, with the motion and response attached as an exhibit and, for motions to dismiss, the operative complaint.
A proposed form of order must be uploaded prior to any hearing by OLS five (5) days in advance with the Motion and Response attached as an Exhibit as well as the Operative complaint for Motions to Dismiss.
Document Type
Proposed Order
Checked against the court's document on Oct 1, 2026Mandatory
Parties seeking a Special Set hearing must upload a proposed agreed status order with the request.
To obtain a Special Set hearing the parties must upload a proposed agreed status order with request to special set.
Document Type
Status Order
Checked and corrected to match the court's document on Oct 1, 2026Mandatory
The signer of a filing must represent that the legal authorities identified in the filing exist and are accurately cited.
The amendments expand the ===== PAGE 2 ===== existing representation under rule 2.515(d)(2) “to require the signer of a filing to represent that the legal authorities identified in that filing ‘exist and are accurately cited.’
Document Type
Filing
Checked and corrected to match the court's document on Oct 1, 2026Mandatory
A party must produce all documents to which it has no objection and match any objection to the specific request or portion challenged.
Objections to portions of a document request do not excuse the responding party from producing those documents to which there is no objection. 175 Specific objections should be matched to specific requests.
Document Type
Document Request Response
Checked against the court's document on Oct 1, 2026Mandatory
A party withholding discoverable information on privilege or protection grounds must expressly assert the claim and describe the withheld materials sufficiently for evaluation without revealing protected information.
A party who responds to or objects to discovery requests and who withholds information otherwise discoverable by asserting that the information is privileged or subject to other protection from discovery must assert a claim expressly and must describe the nature of the documents, communications, or things not produced or disclosed, such that, without revealing the privileged or protected information itself, the description will enable other parties to assess the applicability of the privilege or protection.
Document Type
Privilege Claim
Checked against the court's document on Oct 1, 2026Mandatory
An objection to only part of a discovery request must identify the objectionable part and permit inspection of the remaining materials.
An objection to part of a request must specify the part and permit inspection of the rest.
Document Type
Discovery Response
Checked against the court's document on Oct 1, 2026Mandatory
The parties must jointly prepare and file a short Notice of Compliance confirming compliance with paragraphs 1 and 2.
Counsel for the Parties shall jointly prepare and file a short Notice of Compliance confirming they have met the requirements of Para. 1 and 2 of this Order.
Document Type
Notice Of Compliance
Checked against the court's document on Oct 1, 2026Mandatory
For a neuropsychological examination, the examiner must provide all raw examination data to Plaintiff’s treating or retained psychologist or neuropsychologist, who must return it to the defense examiner when the case concludes.
8a. If the examination involves neuropsychological testing: In addition to the report, the examiner shall provide all raw data, including copies of all notes, tests, test results, scoring and test protocols, to Plaintiff’s treating or retained psychologist or neuropsychologist, who must return them to the defense examiner at the conclusion of this case.
Document Type
Neuropsychological Examination Raw Data
Checked against the court's document on Oct 1, 2026Mandatory
The examining physician must prepare a detailed written report containing all findings, tests, diagnoses, and conclusions.
The examining physician shall prepare a detailed written reporting setting forth all of the examining physician’s findings, including all tests made, diagnoses and conclusions.
Document Type
Medical Examination Report
Checked against the court's document on Oct 1, 2026Mandatory
A proposed order must include a conferral statement, factual and legal support for the requested relief, and the motion or response attached as an exhibit.
The proposed order must include a statement of conferral, factual and legal basis in support of the relief requested as well as the motion/response attached as an exhibit.
Document Type
Proposed Order
Checked against the court's document on Oct 1, 2026Mandatory
Five days before the calendar call, the parties must e-file and upload by OLS specified pretrial materials, attaching them as exhibits to the pretrial order.
The parties will ensure that they have e-filed and 5 days prior to the Calendar call uploaded by OLS a pretrial stipulation, a pretrial checklist, exhibit list, witness list, agreed jury instructions, verdict form and proposed final judgement attached as exhibits to the pretrial order.
Document Type
Pretrial Order
Checked against the court's document on Oct 1, 2026Mandatory
Each party must upload a proposed order by OLS for every hearing linked to an event date.
All parties must upload a proposed order by OLS for all hearings linked to an event date.
Document Type
Hearing
Checked against the court's document on Oct 1, 2026Mandatory
Counsel must prepare, sign, and file a written Pretrial Stipulation.
Pursuant to Rule 1.200(a)(11), Fl. R. Civ. Pr., counsel for the parties have prepared, signed and filed a written Pretrial Stipulation, the contents of which are incorporated herein by reference.
Document Type
Pretrial Stipulation
Checked against the court's document on Oct 1, 2026Mandatory
Counsel must prepare, sign, and submit a written Pretrial Conference Checklist for filing with the clerk, attached to the order as Exhibit A.
Pursuant to this Court’s procedures and the Order Setting Case for Trial, counsel for the parties have prepared, signed and submitted to the Court for filing with the Clerk, a written Pretrial Conference Checklist that will be attached to this Pretrial Conference Order as Exhibit A.
Document Type
Pretrial Conference Checklist
Checked against the court's document on Oct 1, 2026Mandatory
All trial exhibits, including rebuttal exhibits, must be exhibited to opposing counsel at least 30 days before the Pretrial Conference.
All exhibits intended to be offered at trial, including rebuttal, shall be exhibited to all opposing counsel THIRTY (30) DAYS prior to the Pretrial Conference.
Document Type
Exhibits
Checked against the court's document on Oct 1, 2026Mandatory
At least 180 days before the Pretrial Conference, every party must serve and file a notice identifying treating physicians and non-retained experts who may testify.
No later than ONE HUNDRED EIGHTY (180) DAYS prior to the Pretrial Conference, all parties shall serve on all opposing counsel and file with the Court a notice containing the following information regarding each treating physician and non-retained expert witness who will testify at trial as an expert witness on behalf of a party
Document Type
Treating Physician And Non Retained Expert Notice
Checked against the court's document on Oct 1, 2026Mandatory
Before opening statements, each party must give the Trial Clerk an itemized Exhibit List of all trial exhibits.
Prior to Opening Statements, counsel for each party shall deliver to the Trial Clerk an Exhibit List that contains an itemized list of all exhibits to be introduced during trial.
Document Type
Exhibit List
Checked against the court's document on Oct 1, 2026Mandatory
Plaintiffs must disclose all trial witnesses, including rebuttal witnesses, at least 75 days before the Pretrial Conference, and defendants must do so at least 60 days before it.
Plaintiff(s) shall disclose to Defendant(s) a final written list or notice of all witnesses expected to testify at trial, including any rebuttal witnesses, no later than SEVENTY-FIVE (75) DAYS prior to the Pretrial Conference. Defendant(s) shall disclose to Plaintiff(s) a final written list or notice of all witnesses expected to testify at trial, including any rebuttal witnesses, no later than SIXTY (60) DAYS prior to the Pretrial Conference.
Document Type
Final Witness List
Checked against the court's document on Oct 1, 2026Mandatory
Proposed typed jury instructions and verdict forms must be filed at the Pretrial Conference and may be supplemented before the jury-instruction conference.
Typed proposed jury instructions and verdict forms shall be filed with the Court at the Pretrial Conference and may be supplemented prior to the jury instruction conference at trial.
Document Type
Jury Instructions And Verdict Forms
Checked against the court's document on Oct 1, 2026Mandatory
At least 30 days before the Pretrial Conference, each party must exchange and file written deposition designations for witnesses expected to testify by transcript or video.
No later than THIRTY (30) DAYS prior to the Pretrial Conference, all parties shall exchange and file written notice(s) of deposition designations of witnesses whose testimony the party expects to be presented by deposition, whether by transcript or video.
Document Type
Deposition Designations
Checked against the court's document on Oct 1, 2026Mandatory
Every proposed order must include a cover letter certifying unanimous agreement or identifying the parties' disagreement.
All proposed orders must be accompanied by a cover letter either (1) certifying that all parties agree to the order or (2) containing a statement identifying any disagreement of the parties as to the proposed order.
Document Type
Proposed Order
Checked against the court's document on Oct 1, 2026Mandatory
Every proposed order must state the case status, calendar call date, timely filing and setting, preconference by telephone and email, factual basis, cited legal authority, and the parties' desired outcome.
All proposed orders must state (i) the status of the case (ii) calendar call date (iii) the motion was timely filed and set, (iv) conferral of the parties prior to filing the motion by telephone and email. (v) factual basis (vi) legal authority with citations (vii) the parties desired outcome,
Document Type
Proposed Order
Checked against the court's document on Oct 1, 2026Mandatory
In non-jury trials, competing proposed final judgments must be provided five days before calendar call.
Non-jury trials require competing proposed final judgments provided 5 days prior to calendar call.
Document Type
Proposed Final Judgment
Checked against the court's document on Oct 1, 2026Mandatory
Proposed orders for hearings must include specified supporting documents as attached exhibits.
For all hearings, exhibits must be attached to the proposed order including but not limited to the Notice of Hearing, Motion and Response, operative complaint for Motions to Dismiss, the Note/Mortgage for Foreclosures, contracts, agreements and bills.
Document Type
Proposed Order
Checked against the court's document on Oct 1, 2026Mandatory
A true emergency is limited to matters of life and death or irreparable harm, and a motion may not be titled emergency unless it cannot be handled through the ordinary process without irreparable harm.
The term "emergency" encompasses matters of life and death, or instances of irreparable harm, which does not include urgent matters. Please do not entitle your motion "Emergency" unless it cannot be handled in the ordinary course without irreparable harm.
Document Type
Emergency Motion
Checked against the court's document on Oct 1, 2026Mandatory
Every order or final judgment must be uploaded with a cover letter confirming review and agreement, or identifying and redlining the specific disagreement.
All Orders/Final Judgments MUST be uploaded with cover letter and/ or supporting attachments. A cover letter is required (as a supporting document) stating that all parties have reviewed the Order and are in agreement with the form of the Order. If parties are not in agreement with the form of the Order, the SPECIFICS of the disagreement must be noted in the cover letter to the Judge and redlined.
Document Type
Order
Checked against the court's document on Oct 1, 2026Mandatory
A request for an emergency hearing must be made by a detailed motion stating the issues, reasons emergency treatment is necessary, and time needed for each party.
If a party believes there is a factual basis for setting an emergency hearing, a detailed motion setting forth the following must be filed: (1) the issues to be resolved, (2) reasons why an emergency hearing is necessary, and (3) the amount of time needed for each party's presentation.
Document Type
Emergency Motion
Checked and corrected to match the court's document on Oct 1, 2026Mandatory
Each party must upload a proposed form of order through OLS before every hearing and no sooner than five days before the hearing.
A proposed form of order must be uploaded by each party prior to any and all hearings by OLS, no sooner than five (5) days in advance.
Document Type
Proposed Order
Checked against the court's document on Oct 1, 2026Mandatory
Every proposed order must include a statement of good-faith compliance with Local Rule 4, and a notice of hearing lacking that language will have its hearing canceled.
All proposed orders must include a statement of Good Faith compliance with Local Rule 4 (PDF). In addition, any Notice of Hearing that does not include this language will result in the cancellation of the hearing.
Document Type
Proposed Order
Checked against the court's document on Oct 1, 2026Mandatory
For a bench trial, five days before calendar call the parties must upload by OLS competing proposed final judgments with factual and legal authority and the listed pretrial materials as exhibits.
However, if this matter is a bench trial, the parties will upload by OLS five days before calendar call competing proposed final judgements with factual basis and legal authority with the pretrial stipulation, pretrial checklist, order of proof, exhibit list, and witness list as exhibits.
Document Type
Pretrial Order
Checked against the court's document on Oct 1, 2026Mandatory
Five days before calendar call, the parties must upload by OLS the pretrial stipulation, checklist, exhibit list, witness list, order of proof, agreed jury instructions, verdict form, and proposed final judgment as exhibits to the pretrial order.
Five (5) days prior to the Calendar call, the Parties must upload by OLS a pretrial stipulation, pretrial checklist, exhibit list, witness list, order of proof, agreed jury instructions, verdict form and proposed final judgment attached as exhibits to the pretrial order.
Document Type
Pretrial Order
Checked against the court's document on Oct 1, 2026Mandatory
Five days before the hearing, the parties must submit one combined omnibus order by OLS specifying each party's position.
The parties are directed to submit one combined omnibus order with specificity indicating each party's position five days prior to the hearing by OLS.
Document Type
Proposed Order
Checked against the court's document on Oct 1, 2026Mandatory
The rebuttal-expert disclosure must state the expert's name, address, and telephone number.
The nonmoving party shall file a disclosure submitting the name, address, and telephone number of any expert it intends to use as rebuttal to the attorneys' fees and costs claimed by the moving party, no later than fifteen (15) days prior to Calendar Call.
Document Type
Rebuttal Expert Disclosure
Checked against the court's document on Oct 1, 2026Mandatory
The nonmoving party's disclosure must identify every disputed fee and cost line item and state the specific basis for the objection.
The nonmoving party shall file a disclosure submitting to the moving party no later than thirty (30) days prior to Calendar Call of its specific objections to all fees and costs, by identifying each line item and the specific basis for the opposing party's objections,
Document Type
Nonmoving Party Objections
Checked against the court's document on Oct 1, 2026Mandatory
The joint spreadsheet must present chronologically numbered entries containing the labor date, attorney-labor description, hourly fee, billed time, proposed reduction, objections or agreements, and total fee sought or reduction.
There must be columns numbered in chronological order for each entry to address: The date of the labor, A description of attorney labor Hourly dollar fee charged by the attorney for the specific labor The moving party's time billed and the non-moving party's proposed reduction Specific objections or agreements for each line item A tabulation of the total fees sought or proposed reductions for each line item
Document Type
Fee And Cost Spreadsheet
Checked against the court's document on Oct 1, 2026Mandatory
The moving party's disclosure must identify the attorneys' fee expert's name, address, and telephone number and include copies of billing timesheets, cost invoices, and other relevant evidence.
The moving party shall file a disclosure submitting to the nonmoving party the name, address, and telephone number of the attorneys' fee expert and the moving party shall also submit copies of all billing timesheets, invoices for costs, and any other documentary evidence relating to the motion for attorneys' fees and costs, no later than forty-five (45) days prior to Calendar Call.
Document Type
Moving Party Fee Disclosure
Checked against the court's document on Oct 1, 2026Mandatory
Expert disclosures must include the information required by Florida Rule of Civil Procedure 1.280(c)(5) and the order’s expert-disclosure requirements.
All expert disclosures shall contain all information required by Fla. R. Civ. P. 1.280(c)(5), and paragraphs 12-15 below.
Document Type
Expert Disclosure
Checked against the court's document on Oct 1, 2026Mandatory
Each party must file and submit an original and copy of proposed jury instructions and the verdict form at least 10 days before the Jury Instruction Charge Conference.
At least ten (10) days prior to this conference with the Court each party shall file and submit to the Court an original and copy of that party's Proposed Jury Instructions and Verdict Form.
Document Type
Jury Instructions
Checked against the court's document on Oct 1, 2026Mandatory
A motion seeking track re-designation must include an uploaded proposed order regarding the re-designation.
The party seeking re-designation shall file a motion with the Court and upload a proposed order regarding the re-designation.
Document Type
Motion
Checked against the court's document on Oct 1, 2026Mandatory
An agreed request to shorten deadlines, including the trial-ready date, must be submitted as a stipulated Amended DCMO through OLS together with a motion explaining the reasons.
Requests to shorten deadlines, including the trial ready date, if agreed, are to be made by submission of a stipulated Amended DCMO through Online Scheduling (OLS) with a copy of the motion explaining the reasons for amendment.
Document Type
Stipulated Amended Dcmo
Checked against the court's document on Oct 1, 2026Mandatory
A motion to modify a non-trial DCMO deadline must comply strictly with Rule 1.200(e).
Motions to modify a DCMO deadline that do not affect the Calendar Call date or trial period must strictly follow Rule 1.200(e).
Document Type
Dcmo Deadline Modification Motion
Checked against the court's document on Oct 1, 2026Mandatory
A certificate confirming postal and email service of the order must be filed for the court.
Movant shall serve a copy of this order to CLIENT by United States Postal Service and email, and file a certificate of service confirming the same for the Court.
Document Type
Order
Checked against the court's document on Oct 1, 2026Mandatory
A notice of a remote proceeding must include available video-conferencing details, including links and login information.
(ii) include, if available, the video conferencing details, including links and login information;
Document Type
Notice Of Remote Proceeding
Checked against the court's document on Oct 1, 2026Mandatory
Every notice of a remote proceeding must state that the proceeding will occur by video conferencing.
All notices of remote proceedings must (i) indicate that the proceeding will occur by video conferencing;
Document Type
Notice Of Remote Proceeding
Checked against the court's document on Oct 1, 2026Mandatory
A notice of a remote proceeding must provide telephone-participation instructions when a self-represented party lacks access to the video-conferencing platform.
(v) provide instructions for participation by telephone if a self-represented party does not have access to the video conferencing platform that is being used.
Document Type
Notice Of Remote Proceeding
Checked against the court's document on Oct 1, 2026Mandatory
The parties must jointly prepare a final exhibit index that identifies every hearing exhibit and any objections and objecting party, with the movant primarily responsible for providing it to the court and clerk.
During the meet and confer after the exchange of exhibit lists, the parties shall prepare jointly an index of all exhibits that will be used at the hearing. The movant shall be primarily responsible for preparing this index and for providing the final copy of the index to the court and clerk’s office. This index shall also specifically identify what objections exist, if any, to each exhibit and which party is making the objection.
Document Type
Exhibit Index
Checked against the court's document on Oct 1, 2026Mandatory
Witness lists exchanged at least ten business days before the hearing must identify each witness, known contact information, interpreter or ADA-accommodation needs, and interpreter names.
At least 10 business days in advance of an evidentiary hearing, the parties shall exchange wit- ness lists that include the witnesses’ names and, if known, email addresses and telephone num- bers. The parties shall also identify any witness for whom an interpreter or an accommodation under the Americans with Disabilities Act will be required, and include the names of all interpret- ers on the witness list.
Document Type
Witness List
Checked against the court's document on Oct 1, 2026Important
An agreed proposed order must be uploaded for Status and Case Management Conferences.
Please upload an agreed proposed order on Status and Case Management Conferences (see forms).
Document Type
Proposed Order
Checked against the court's document on Oct 1, 2026Important
The proposed order must state whether the motion is timely under the DCMO Order and use docket entry numbers, not filing numbers, when referencing filed documents.
All parties must include in their proposed order if the motion is timely pursuant to the DCMO Order and provide Docket Entry numbers (DE#__) not filing numbers when referencing another filed document.
Document Type
Proposed Order
Checked against the court's document on Oct 1, 2026Important
The proposed order must state the parties' desired outcome, provide factual and legal bases, and confirm good-faith efforts to resolve the issues by telephone and email.
The proposed order must include language as to the parties desired outcome that provides factual basis, legal authority and confirms that the parties conferred in a good faith effort to resolve the issues raised by telephone and email.
Document Type
Proposed Order
Checked and corrected to match the court's document on Oct 1, 2026Important
Objections to document requests must be specific and include a full, case-specific explanation rather than boilerplate objections.
Objections made to document requests should be specific, not generalized, 172 and should be in compliance with the provisions of Rules 1.350(b) and 1.410(c), Florida Rules of Civil Procedure. Boilerplate objections such as “the request is overly broad, unduly burdensome, and outside the scope of permissible discovery” are insufficient without a full, fair explanation particular to the facts of the case.
Document Type
Document Request Objection
Checked against the court's document on Oct 1, 2026Important
A party limiting production based on an objection must clearly describe the limitation in its response.
When production is limited by a party’s objection, the producing party should clearly describe the limitation in its response.
Document Type
Document Request Response
Filing & Service rules
Electronic Filing Rules
An attorney in good standing with The Florida Bar must electronically file the comment through the Florida Courts E-Filing Portal.
If filed by an attorney in good standing with The Florida Bar, the comment must be electronically filed via the Florida Courts E-Filing Portal (Portal).
Checked against the court's document on Oct 1, 2026
Page 6 | IN RE: AMENDMENTS TO FLORIDA RULE OF GENERAL PRACTICE AND JUDICIAL ADMINISTRATION 2.515.
Final judgments must be submitted through Online Services in Word format with a service list but without a date or signature line because the Court will electronically sign, date, file, and serve them.
Final Judgments: Orders should be submitted through Online Services, in Word format, with a service list but without a date and signature line, as the orders will be signed and dated electronically and will be e-filed and e-served. This is a directive of the Supreme Court AOSC19-74.
Checked against the court's document on Oct 1, 2026
Page 1 | Submission of Orders and Judgments
Anyone unable to submit a comment electronically must mail or hand-deliver the originally signed comment to the Office of the Clerk, and no additional copies are accepted.
Any person unable to submit a comment electronically must mail or hand-deliver the originally signed comment to the Florida Supreme Court, Office of the Clerk, 500 South Duval Street, Tallahassee, Florida 32399; no additional copies are required or will be accepted.
Checked and corrected to match the court's document on Oct 1, 2026
Page 6 | IN RE: AMENDMENTS TO FLORIDA RULE OF GENERAL PRACTICE AND JUDICIAL ADMINISTRATION 2.515.
A nonlawyer or a lawyer not licensed to practice in Florida may file the comment through the Portal but is not required to do so.
If filed by a nonlawyer or a lawyer not licensed to practice in Florida, the comment may be, but is not required to be, filed via the Portal.
Checked against the court's document on Oct 1, 2026
Page 6 | IN RE: AMENDMENTS TO FLORIDA RULE OF GENERAL PRACTICE AND JUDICIAL ADMINISTRATION 2.515.
Florida court recordkeeping and filing are conducted electronically.
Court recordkeeping and filing is now done in electronic format in Florida courts.
Checked against the court's document on Oct 1, 2026 · Civil cases
Page 29 | PROTECTING CLIENT CONFIDENCES AND DATA
For a new civil case subject to Differentiated Case Management, the Court automatically generates, files, and serves the DCMO through the e-portal upon the initiating party.
Immediately upon the filing of a new civil case that is subject to Differentiated Case Management, a Uniform Differentiated Case Management Order and Order Setting Trial (“DCMO”) as described in Part 2(b) shall be automatically generated by the Court, filed, and served through the e-portal upon the party initiating the action.
Checked against the court's document on Oct 1, 2026 · Civil cases
Page 2 | 2. Assigning Tracks, Pre-Trial Schedules and Calendar Call Through Automated Differentiated Case Management Orders (DCMO)
An order must not be uploaded more than once, and an erroneous upload must be reported to the judicial assistant rather than replaced by a duplicate while awaiting a signed copy.
DO NOT SUBMIT/UPLOAD MORE THAN ONCE. If an order was uploaded with an error, please contact the J.A. to notify of the erroneous uploaded order. The J.A. will be able to locate the order to delete and allow the parties to upload the correct order to avoid duplicate filings and/or filings of erroneous orders. Please do not upload a duplicate order for lack of receiving a signed copy of a previously uploaded order.
Not confirmed. Read the court's wording below.
Page 1 | Submission of Orders and Judgments
Proposed notices of hearing may not be emailed or uploaded for the Judge's signature and must instead be filed in the case file.
Please do not email or upload proposed notices of hearings to be signed by the Judge as you are required to file the same in the case file.
Not confirmed. Read the court's wording below.
Page 1 | AG Divisional Instructions
Post-hearing submissions are prohibited unless the Court requests them.
No post-hearing submittals will be accepted unless requested by the Court.
Not confirmed. Read the court's wording below.
Page 1 | Scheduling Procedures
To be excused from calendar call, the parties must confer, file the document in the docket, and email it to cad-divisionAG@pbcgov.org five days before calendar call.
The parties will be excused from calendar call if the same is filed in the docket and emailed to cad-divisionAG@pbcgov.org, 5 days prior to calendar call, after the parties have conferred.
Not confirmed. Read the court's wording below. · Civil cases
Page 1 | PRETRIAL CONFERENCE CHECKLIST/E-CALENDAR
Filing Timing and Cure Windows
Comments must be filed by August 11, 2026, and a person wishing to participate in oral argument must also file a separate request by that date.
All comments must be filed with the Court on or before August 11, 2026, as well as a separate request for oral argument if the person filing the comment wishes to participate in oral argument, which may be scheduled in this case.
Checked against the court's document on Oct 1, 2026
Page 6 | IN RE: AMENDMENTS TO FLORIDA RULE OF GENERAL PRACTICE AND JUDICIAL ADMINISTRATION 2.515.
Interested persons must file comments with the Court within 75 days of the opinion's date.
Because the amendments were not published for comment previously, interested persons shall have 75 days from the date of this opinion in which to file comments with the Court. 2
Checked against the court's document on Oct 1, 2026
Page 6 | IN RE: AMENDMENTS TO FLORIDA RULE OF GENERAL PRACTICE AND JUDICIAL ADMINISTRATION 2.515.
The moving party must provide the fee expert’s contact information and supporting billing records to the nonmoving party at least 45 days before Calendar Call.
The moving party shall file a disclosure submitting to the nonmoving party the name, address, and telephone number of the attorneys’ fee expert and the moving party shall also submit copies of all billing timesheets, invoices for costs, and any other documentary evidence relating to the motion for attorneys’ fees and costs, no later than forty-five (45) days prior to Calendar Call.
Checked against the court's document on Oct 1, 2026 · Civil cases
Page 1 | IN RE: STANDING ORDER ON MOTIONS FOR ATTORNEYS’ FEES AND COSTS
The nonmoving party must disclose the contact information of any rebuttal expert no later than 15 days before Calendar Call.
The nonmoving party shall file a disclosure submitting the name, address, and telephone number of any expert it intends to use as rebuttal to the attorneys’ fees and costs claimed by the moving party, no later than fifteen (15) days prior to Calendar Call.
Checked against the court's document on Oct 1, 2026 · Civil cases
Page 1 | IN RE: STANDING ORDER ON MOTIONS FOR ATTORNEYS’ FEES AND COSTS
A motion seeking costs, attorneys’ fees, or both must be served no later than 30 days after the judgment, judgment of dismissal, or notice of voluntary dismissal that concludes the action as to that party.
Rule 1.525, Florida Rules of Civil Procedure, governs Motions for Costs and Attorney’s Fees, and provides that any party seeking a judgment taxing costs, attorneys’ fees, or both shall serve a motion no later than 30 days after filing of the judgment, including a judgment of dismissal, or the service of a notice of voluntary dismissal, which judgment or notice concludes the action as to that party,
Checked and corrected to match the court's document on Oct 1, 2026 · Civil cases
Page 1 | IN RE: STANDING ORDER ON MOTIONS FOR ATTORNEYS’ FEES AND COSTS
The nonmoving party must identify its objections to each fee and cost line item and state the specific basis for each objection no later than 30 days before Calendar Call.
The nonmoving party shall file a disclosure submitting to the moving party no later than thirty (30) days prior to Calendar Call of its specific objections to all fees and costs, by identifying each line item and the specific basis for the opposing party’s objections,
Checked against the court's document on Oct 1, 2026 · Civil cases
Page 1 | IN RE: STANDING ORDER ON MOTIONS FOR ATTORNEYS’ FEES AND COSTS
If the fee-and-cost motion remains unresolved, the parties must jointly file a submission and provide hardcopy billing and cost spreadsheets at Calendar Call.
If the parties cannot resolve the motion, then at Calendar Call, the parties shall jointly file a submission to the Court and provide a hardcopy of a spreadsheet for each attorney’s billing and for one for the costs.
Checked against the court's document on Oct 1, 2026 · Civil cases
Page 1 | IN RE: STANDING ORDER ON MOTIONS FOR ATTORNEYS’ FEES AND COSTS
Objections to an examination request under Florida Rule of Civil Procedure 1.360(a)(1)(A) must be filed within 30 days of the written request, assuming service of process occurred at least 15 days before the request was served.
Objections to “Examination of Persons” under Fla. R. Civ. P. 1.360(a)(1)(A) must be filed no later than 30 days from the written request assuming service of process has occurred at least 15 days prior to the request being served.
Checked and corrected to match the court's document on Oct 1, 2026 · Civil cases
Page 226 | APPENDIX 7-1 — Guidelines Regarding Compulsory Medical Examinations
All hearing materials must be received no sooner than five business days before the hearing.
The Court must receive all materials for the hearing no sooner than five (5) business days before the hearing.
Checked and corrected to match the court's document on Oct 1, 2026
Page 1 | Scheduling Procedures - Submission Deadlines
All motions must be set within five days of filing, heard within 60 days as permitted by law, and set and heard at least 30 days before calendar call or they may be deemed abandoned.
The parties must move to set all motions within 5 days of filing and timely heard within 60 days as permitted by law, but no later than 30 days prior to calendar call, or the same may be deemed abandoned.
Checked against the court's document on Oct 1, 2026
Page 1 | AG Divisional Instructions
A status report must be filed every 90 days, and noncompliance may result in dismissal without prejudice.
All parties must ensure that a status report is filed in the case file every 90 days. Failure to comply with this division instruction may result in the matter being dismissed without prejudice.
Checked and corrected to match the court's document on Oct 1, 2026
Page 1 | Motions to Stay or Bankruptcy Stays
A response to every motion must be filed within five days unless the Florida Rules provide otherwise, failing which the motion may be deemed unopposed.
All motions require a filed Response within 5 days of the motion being filed unless otherwise indicated in the FL.R.C.P. or the motion may be deemed unopposed.
Checked against the court's document on Oct 1, 2026
Page 1 | AG Divisional Instructions
All motions must be set and heard no later than 30 days before calendar call.
All motions must be set and heard 30 days before calendar call at the latest.
Checked against the court's document on Oct 1, 2026 · Civil cases
Page 1 | AGREED STATUS ORDER AND SPECIAL SETTING MOTION
Responses to motions not governed by a different Civil Rules of Procedure requirement must be filed within five days of the order.
Responses to all motions other than required by the Civil Rules of Procedure are ordered within 5 days of this order.
Checked against the court's document on Oct 1, 2026 · Civil cases
Page 1 | AGREED STATUS ORDER AND SPECIAL SETTING MOTION
A mediation report must be filed within 48 hours of mediation.
A notice of mediation was filed on ____, mediation is scheduled for _______ and a mediation report will be filed with 48 hours of the same.
Checked against the court's document on Oct 1, 2026 · Civil cases
Page 1 | AGREED STATUS ORDER AND SPECIAL SETTING MOTION
At least 45 days before Calendar Call, the moving party must disclose its attorneys' fee expert's contact information and submit billing timesheets, cost invoices, and other supporting evidence.
The moving party shall file a disclosure submitting to the nonmoving party the name, address, and telephone number of the attorneys' fee expert and the moving party shall also submit copies of all billing timesheets, invoices for costs, and any other documentary evidence relating to the motion for attorneys' fees and costs, no later than forty-five (45) days prior to Calendar Call.
Checked against the court's document on Oct 1, 2026 · Civil cases
Page 1 | IN RE: STANDING ORDER ON MOTIONS FOR ATTORNEYS' FEES AND COSTS
At least 15 days before Calendar Call, the nonmoving party must disclose the contact information of any rebuttal expert it intends to use.
The nonmoving party shall file a disclosure submitting the name, address, and telephone number of any expert it intends to use as rebuttal to the attorneys' fees and costs claimed by the moving party, no later than fifteen (15) days prior to Calendar Call.
Checked against the court's document on Oct 1, 2026 · Civil cases
Page 1 | IN RE: STANDING ORDER ON MOTIONS FOR ATTORNEYS' FEES AND COSTS
A party seeking costs, attorneys' fees, or both must serve the motion within 30 days after the judgment is filed or, for voluntary dismissal, after service of the notice of dismissal.
WHEREAS, Rule 1.525, Florida Rules of Civil Procedure, governs Motions for Costs and Attorney's Fees, and provides that any party seeking a judgment taxing costs, attorneys' fees, or both shall serve a motion no later than 30 days after filing of the judgment, including a judgment of dismissal, or the service of a notice of voluntary dismissal, which judgment or notice concludes the action as to that party,
Checked against the court's document on Oct 1, 2026 · Civil cases
Page 1 | IN RE: STANDING ORDER ON MOTIONS FOR ATTORNEYS' FEES AND COSTS
At least 30 days before Calendar Call, the nonmoving party must file specific objections identifying each disputed line item and the basis for each objection.
The nonmoving party shall file a disclosure submitting to the moving party no later than thirty (30) days prior to Calendar Call of its specific objections to all fees and costs, by identifying each line item and the specific basis for the opposing party's objections,
Checked against the court's document on Oct 1, 2026 · Civil cases
Page 1 | IN RE: STANDING ORDER ON MOTIONS FOR ATTORNEYS' FEES AND COSTS
Each party must electronically produce all intended trial exhibits to the other parties at least 30 days before the Pretrial Conference.
No later than thirty (30) days prior to the Pretrial Conference (“Conference”), each party shall produce to all other parties all trial exhibits in electronic format it intends to introduce at trial.
Checked against the court's document on Oct 1, 2026 · Civil cases
Page 1 | Pre-Trial Conference
Each party’s counsel must deliver an itemized exhibit list to the trial clerk at least five days before trial.
No later than FIVE (5) DAYS prior to the Trial, counsel for each party shall deliver to the Trial Clerk an Exhibit List that contains an itemized list of all exhibits to be introduced during trial.
Checked against the court's document on Oct 1, 2026 · Civil cases
Page 1 | Trial Exhibits
Plaintiff's counsel, or the unrepresented plaintiff, must schedule mediation and file a notice of mediation within 48 hours after the order.
Plaintiff's counsel or Plaintiff, if unrepresented, shall be responsible for scheduling mediation and filing a notice of mediation in 48 hours of this order.
Checked against the court's document on Oct 1, 2026 · Civil cases
Page 1 | Failure to Attend Mediation
Within 48 hours after the mediation conference, the plaintiff must file a mediation report and email the division to report whether the case settled.
After the mediation has taken place, the Plaintiff shall, within 48 hours of the mediation conference, inform the Court in writing as to whether or not the case has been settled by filing the mediation report and emailing the division.
Checked against the court's document on Oct 1, 2026 · Civil cases
Page 1 | Failure to Attend Mediation
Mediation reports must be filed within 48 hours after mediation, and the parties must set a status conference on UMC within five days after mediation.
All mediation reports must be filed within 48 hours of mediation and the parties have set the case for a Status Conference on UMC within 5 days of the same.
Checked against the court's document on Oct 1, 2026 · Civil cases
Page 1 | X. Mediation
Within the order's unspecified number of days, the client must either have new counsel file a written appearance or personally file a written notice of self-representation, unless the client is a representative entity that must retain counsel.
Within ____ days from the date of this Order, CLIENT shall either: Retain new counsel and have that counsel file a written appearance with the Clerk of the Court; OR File a written notice with the Clerk of the Court advising that CLIENT will represent himself/herself. [If CLIENT is a corporation, trustee or a trust, personal representative of an estate, or otherwise named in a representative capacity, CLIENT must retain counsel.]
Checked against the court's document on Oct 1, 2026
Page 1 | Order Granting Motion to Withdraw, Status of Case and Directions to the Clerk to Update the Case File
Witness lists must be filed with the court at least ten business days before the evidentiary hearing and must omit witnesses’ email addresses and telephone numbers.
Witness lists shall also be filed with the Court without the witnesses’ email addresses or phone numbers at least 10 business days in advance of an evidentiary hearing.
Checked against the court's document on Oct 1, 2026
Page 8 | 3.3.1 Witness lists
A written response to a Daubert motion should be filed ten days after the motion is filed.
Written Responses to any Daubert Motions should be filed ten (10) days after the Motion is filed.
Checked against the court's document on Oct 1, 2026
Page 1 | Daubert Motions
An extension motion or Amended DCMO must be submitted promptly after the circumstances prompting the amendment become known.
Motions to extend a deadline or for an Amended DCMO must be resolved early in the case and must be submitted as soon as circumstances giving rise to the amendment become known.
Checked and corrected to match the court's document on Oct 1, 2026 · Civil cases
Page 5 | b. Modification of Pretrial Deadlines Other Than Calendar Call/Trial
The parties and their experts must meet remotely to discuss fee and cost objections no later than 5 days before Calendar Call.
Both parties and their respective experts shall meet, via remote conference, to discuss the specific objections to the fees and costs being claimed no later than five (5) days prior to Calendar Call.
Not confirmed. Read the court's wording below. · Civil cases
Page 1 | IN RE: STANDING ORDER ON MOTIONS FOR ATTORNEYS’ FEES AND COSTS
If the proposed jury instructions and verdict forms were not submitted at the pretrial conference, the plaintiffs must file them with the clerk and submit hard copies to the court by 9:00 a.m. on the stated date.
The Plaintiff(s) shall file with the Clerk and submit to the Court in hard copy form a complete set of proposed jury instructions and verdict forms by no later than 9:00 a.m. on ___________________________, 20_____.
Not confirmed. Read the court's wording below. · Civil cases
Page 1 | PRETRIAL CONFERENCE ORDER
When directed by the Court after a hearing, the movant must confer with opposing counsel and submit the proposed order electronically within 48 hours after the ruling.
If the Court directs after the hearing: the Moving party shall, confer with opposing counsel and submit proposed orders electronically within 48 hrs. after the Court's ruling on the matter.
Not confirmed. Read the court's wording below.
Page 1 | Submission of Orders and Judgments
A response to a motion for rehearing, reconsideration, or clarification must be filed within five days and attached to the respondent's competing order.
A Response shall be filed within 5 days and provided as an exhibit to the Respondent's competing order.
Not confirmed. Read the court's wording below.
Page 1 | Motion for Rehearing/Reconsideration/Clarification
The parties must attend mediation 30 days before calendar call.
The parties must attend mediation 30 days prior to calendar call.
Not confirmed. Read the court's wording below. · Civil cases
Page 1 | AGREED STATUS ORDER AND SPECIAL SETTING MOTION
A response to the Summary Judgment Motion is due on the stated date, and the motion cannot be heard earlier than 50 days after filing.
The Summary Judgment Motion was filed on __.(date). A timely response is due on____ and the earliest time the SJM can be heard is ____pursuant to the FL.R.C.P. (50 days from filing).
Not confirmed. Read the court's wording below. · Civil cases
Page 1 | AGREED STATUS ORDER AND SPECIAL SETTING MOTION
The parties must be trial ready at calendar call.
The parties must be trial ready at calendar call.
Not confirmed. Read the court's wording below. · Civil cases
Page 1 | AGREED STATUS ORDER AND SPECIAL SETTING MOTION
The document must be filed in the docket and emailed to the designated address at least five days before calendar call.
The parties will be excused from calendar call if the same is filed in the docket and emailed to cad-divisionAG@pbcgov.org, 5 days prior to calendar call, after the parties have conferred.
Not confirmed. Read the court's wording below. · Civil cases
Page 1 | PRETRIAL CONFERENCE CHECKLIST/E-CALENDAR
Plaintiff must provide the final trial witness list, including rebuttal witnesses, at least 75 days before the Pretrial Conference.
Plaintiff(s) shall furnish Defendant(s) a final list of all witnesses expected to testify at trial, including any rebuttal witnesses, no later than SEVENTY-FIVE (75) DAYS prior to the Pretrial Conference.
Not confirmed. Read the court's wording below. · Civil cases
Page 1 | Trial Witnesses
The original Joint Pretrial Stipulation must be filed with the clerk and one copy mailed or delivered to the court at least 15 days before the Pretrial Conference.
The original shall be filed with the Clerk and one copy shall be mailed or delivered to the Court no later than fifteen (15) days prior to the pretrial conference.
Not confirmed. Read the court's wording below. · Civil cases
Page 1 | Joint Pretrial Stipulation
Parties have ten days after receiving counter-designations to exchange and file objections to counter-designations and counter-counter-designations.
No later than TEN (10) DAYS after receiving counter-designations, all parties shall exchange and file objections to counter-designations and counter-counter-designations, if necessary.
Not confirmed. Read the court's wording below. · Civil cases
Page 1 | Deposition Designations
Parties have ten days after receiving deposition designations to exchange and file objections and counter-designations.
No later than TEN (10) DAYS after receiving such designations, all parties shall exchange and file objections and counter-designations to the same.
Not confirmed. Read the court's wording below. · Civil cases
Page 1 | Deposition Designations
All parties must exchange and file deposition designations at least 90 days before the Final Case Management Conference.
No later than NINETY (90) DAYS prior to the Final Case Management Conference, all parties shall exchange and file deposition designations of witnesses whose testimony the party expects to be presented by deposition, whether by transcript or video.
Not confirmed. Read the court's wording below. · Civil cases
Page 1 | Deposition Designations
Defendants must provide the final trial witness list, including rebuttal witnesses, at least 60 days before the Pretrial Conference.
Defendant(s) shall furnish Plaintiff(s) a final list of all witnesses expected to testify at trial, including any rebuttal witnesses, no later than SIXTY (60) DAYS prior to the Pretrial Conference.
Not confirmed. Read the court's wording below. · Civil cases
Page 1 | Trial Witnesses
All evidence intended for introduction must be filed at least two calendar days before the evidentiary hearing, following the court’s instructions.
At least 2 calendar days before an evidentiary hearing, the parties shall file all evidence sought to be introduced pursuant to instructions provided by the court.
Not confirmed. Read the court's wording below.
Page 7 | 3.2 DOCUMENT PROCEDURES
A written request for a compulsory examination should be made no later than 70 days before the pretrial date.
If examinations under these rules are requested such written request should be made no later than 70 days before the pretrial date to allow time for objections, hearings on same and an opportunity to reset the examination.
Not confirmed. Read the court's wording below. · Civil cases
Page 226 | APPENDIX 7-1 — Guidelines Regarding Compulsory Medical Examinations
The proposed order must be uploaded no sooner than five days before the hearing.
Please upload the same no sooner than 5 days prior to hearing.
Not confirmed. Read the court's wording below.
Page 1 | AGREED STATUS ORDER
Service and Proof of Service Rules
A party asserting privilege over inadvertently disclosed materials must serve written notice on the recipient within ten days of actually discovering the disclosure.
the party must serve written notice of the assertion of privilege on the party to whom the materials were disclosed, within ten days of actually discovering the 475 inadvertent disclosure.
Checked and corrected to match the court's document on Oct 1, 2026 · Civil cases
Page 151 | Preservation and Spoliation of Evidence
Objections to interrogatories must be served within 30 days after service of the interrogatories to be preserved.
objections to interrogatories served under Rule 1.340 are preserved by serving any objections to the interrogatories within 30 days after service of the interrogatories.
Checked against the court's document on Oct 1, 2026 · Civil cases
Page 156 | OTHER FORMS OF DISCOVERY
Plaintiff must serve the standing order on defendant's counsel within 20 days of counsel's first appearance and schedule a meet and confer within 60 days after service.
Plaintiff shall serve this Order upon counsel for Defendant within 20 days of the first appearance of counsel for Defendant, and shall schedule a meet and confer with counsel for Defendant within 60 days of such service.
Checked against the court's document on Oct 1, 2026 · Civil cases
Page 205 | Standing Order on Electronically Stored Information Discovery
The designated email address may be used for service of all documents required to be served in the proceeding.
Pursuant to Fla. R. Gen. Prac. and Jud. Admin. 2.516, the following e-mail address is designated for the ___________, ____________________, for the purpose of service of all documents required to be served in this proceeding: Primary E‐Mail Address: ______________________________
Checked and corrected to match the court's document on Oct 1, 2026
Page 1 | ORDER TO DESIGNATE EMAIL ADDRESS FOR SERVICE OF PROCESS
Attorneys and self-represented litigants generally must make and receive service by email through the Florida Courts E-Filing Portal unless excused.
All attorneys and self-represented litigants must make and receive service by e-mail, which is generally through the Florida Courts E-Filing Portal, unless excused. Florida Rules of General Practice and Judicial Administration. 2.516.
Checked and corrected to match the court's document on Oct 1, 2026
Page 1 | Communications with the Judicial Office
Further papers and pleadings may be served on the client by mail or email, with service complete upon the corresponding transmission.
All further papers and pleadings shall be served by mail to CLIENT’S last known mailing address or by email to CLIENT’S designated email address(es). Service shall be complete upon mailing or emailing.
Checked against the court's document on Oct 1, 2026
Page 1 | Order Granting Motion to Withdraw, Status of Case and Directions to the Clerk to Update the Case File
Movant must serve the order on the client by both United States Postal Service and email and file a certificate confirming that service.
Movant shall serve a copy of this order to CLIENT by United States Postal Service and email, and file a certificate of service confirming the same for the Court.
Checked against the court's document on Oct 1, 2026
Page 1 | Order Granting Motion to Withdraw, Status of Case and Directions to the Clerk to Update the Case File
A lawyer must notify opposing counsel of substantive communications with the court or another tribunal, but scheduling and clerical communications are excepted.
3.5 A lawyer must avoid substantive ex parte communications in a pending case with a presiding judge. The lawyer must notify opposing counsel of all communications with the court or other tribunal, except those involving only scheduling or clerical matters. (See R. Regulating Fla. Bar 4-3.5).
Checked against the court's document on Oct 1, 2026
Page 7 | 3. Honest and Effective Communication
Participants should check court procedures and local orders and, unless they provide otherwise, email the court and opposing parties copies of materials they intend to present at the hearing no later than 48 hours beforehand.
Participants should always check the court’s procedures and any local orders, but in the absence of anything to the contrary, participants should email copies of any materials the participant in- tends to present to the court during the hearing to the court and opposing parties no later than 48 hours in advance of the hearing.
Checked and corrected to match the court's document on Oct 1, 2026
Page 6 | Remote Procedures Applicable to All Non-Evidentiary Hearings
A copy of every proposed order must be emailed to the opposing party for objection.
A copy of all proposed orders must be emailed to the opposing party for objection.
Checked against the court's document on Oct 1, 2026 · Civil cases
Page 1 | AG Divisional News
The parties must serve subpoenas for third-party documents or depositions by the date stated in the report.
The parties shall serve subpoenas seeking third party documents and/or depositions by [DATE].
Checked and corrected to match the court's document on Oct 1, 2026 · Civil cases
Page 1 | V. Discovery Schedule
The parties must serve deposition notices on other parties by the date stated in the report.
The parties shall serve their notices of deposition on any other party by [DATE].
Checked and corrected to match the court's document on Oct 1, 2026 · Civil cases
Page 1 | V. Discovery Schedule
The parties must serve interrogatories by the date stated in the report.
The parties shall serve Interrogatories by [DATE].
Checked and corrected to match the court's document on Oct 1, 2026 · Civil cases
Page 1 | V. Discovery Schedule
A copy of a written court or tribunal communication should be provided to opposing counsel contemporaneously or sufficiently before the related hearing.
3.6 When submitting a written communication to a court or other tribunal, a lawyer should provide opposing counsel with a copy of the document contemporaneously or sufficiently in advance of any related hearing.
Checked against the court's document on Oct 1, 2026
Page 7 | 3. Honest and Effective Communication
A lawyer should notify opposing parties and subpoenaed witnesses when a hearing, deposition, or trial is cancelled or rescheduled.
3.14 A lawyer should notify opposing parties and subpoenaed witnesses of a cancelled or rescheduled hearing, deposition, or trial.
Checked and corrected to match the court's document on Oct 1, 2026
Page 8 | 3. Honest and Effective Communication
A notice of hearing must be filed and served immediately after hearing time is reserved.
A notice of hearing must be filed and served immediately after reserving hearing time.
Not confirmed. Read the court's wording below.
Page 1 | Scheduling Procedures
A copy of every proposed order must be emailed to the opposing party for objection.
A copy of all proposed orders must be emailed to the opposing party for objection.
Not confirmed. Read the court's wording below.
Page 1 | AG Divisional Instructions
Courtesy copies intended for the court’s consideration at a hearing must be served on all parties at least five business days before the hearing.
All courtesy copies of documents or supplements that a Party desires the Court to consider at a hearing shall be served upon all Parties at least five (5) business days prior to the applicable hearing.
Not confirmed. Read the court's wording below. · Civil cases
Page 1 | CASE MANAGEMENT CONFERENCES
Unless the case is exempt from DCM or the Court orders otherwise, the initiating party must serve the DCMO on each defendant or respondent in the same manner and at the same time as the summons and complaint or petition.
Unless exempted from DCM in Part 1, or by order of the Court, the DCMO shall be served by the party initiating the action upon each defendant/respondent in the same manner and at the same time as the summons and complaint/petition.
Not confirmed. Read the court's wording below. · Civil cases
Page 2 | 2. Assigning Tracks, Pre-Trial Schedules and Calendar Call Through Automated Differentiated Case Management Orders (DCMO)
This form is used to obtain constructive service on the defendant.
NOTE: This fonn is used to obtain constructive service on the defendant.
Not confirmed. Read the court's wording below. · Civil cases
Page 4 | Attempts to Serve Process and Results
The parties must serve document-production demands by the date stated in the report.
Demands for production of documents by [DATE].
Not confirmed. Read the court's wording below. · Civil cases
Page 1 | V. Discovery Schedule
The parties must serve requests for admission by the date stated in the report.
Admission by [DATE].
Not confirmed. Read the court's wording below. · Civil cases
Page 1 | V. Discovery Schedule
A participant sharing previously undisclosed authority or evidence must contemporaneously provide a copy to all participants by email or another electronic means.
In addition, any participant sharing previously undisclosed authority or evidence should also contemporaneously provide a copy to all participants by email or other electronic means.
We could not find this wording in the court's document. Open the source before relying on it.
Page 6 | Remote Procedures Applicable to All Non-Evidentiary Hearings
A lawyer should immediately notify all opposing parties of the scheduling of a hearing, deposition, or trial.
3.13 A lawyer should immediately provide a scheduling notice for a hearing, deposition, or trial to all opposing parties.
Not confirmed. Read the court's wording below.
Page 8 | 3. Honest and Effective Communication
Courtesy Copy Requirements
Trial briefs are optional, but any submitted trial briefs require courtesy hard copies for chambers at least five business days before trial.
Trial Briefs are not required, however, do the parties understand that if you choose to submit them, courtesy hard copies must be delivered to chambers at least five (5) business days before trial to allow adequate time for review?
Checked against the court's document on Oct 1, 2026 · Civil cases
Page 1 | PRETRIAL CONFERENCE CHECKLIST/E-CALENDAR
For all hearings, the parties must provide courtesy hard copies of the hearing materials to the court in advance of the hearing in addition to the electronic submission.
For all hearings the parties will provide courtesy hard copies of materials to the Court in advance of the hearing in addition to the electronic submission.
Checked and corrected to match the court's document on Oct 1, 2026 · Civil cases
Page 1 | IX. Pre-Trial Motions.
The court does not require courtesy copies.
The court does not require the submission of courtesy copies.
Checked and corrected to match the court's document on Oct 1, 2026
Page 1 | Courtesy Copies of Case Law and Other Documents
The parties must confer at least ten days before the Final Case Management Conference and file a case status report with the court, with a courtesy copy provided to the court by the conference.
At least ten (10) days prior to the Final Case Management Conference, the parties shall confer to prepare a case status report, which shall be filed with the Clerk of the Court and a courtesy copy of the same provided to the Court either prior to or at the time of the Final Case Management Conference.
Not confirmed. Read the court's wording below. · Civil cases
Page 1 | CASE MANAGEMENT CONFERENCES
Division AG does not use electronic courtesy copies.
Division AG does not utilize e-courtesy.
Not confirmed. Read the court's wording below.
Page 1 | Courtesy Copies of Case Law and Other Documents
Sealing & Redaction Procedures
Counsel should invoke the sealing process for private or sensitive information before it becomes publicly available in the court record.
If necessary, counsel should invoke the process of sealing private or sensitive information before the record becomes available as a public record.
Checked and corrected to match the court's document on Oct 1, 2026 · Civil cases
Page 29 | PROTECTING CLIENT CONFIDENCES AND DATA
The parties were directed to file all written responses to each other’s discovery requests under seal by the following day.
Consequently, I directed the parties to file, under seal, all their written responses to each other’s discovery requests by the following day.
We could not find this wording in the court's document. Open the source before relying on it. · Civil cases
Page 178 | 2. Potentially obstructionist discovery responses
Filing Bundling Requirements
When the parties do not file exhibits jointly, they must file them unilaterally at least two calendar days before the evidentiary hearing.
In the absence of a joint filing, must file uni- laterally at least 2 calendar days in advance.
Not confirmed. Read the court's wording below.
Page 7 | 3.2 DOCUMENT PROCEDURES
Parties may schedule only one motion hearing at a time and may schedule another only after the Court rules on the last motion heard.
The parties may set only one hearing at a time and may set an additional hearing after the Court rules on the last motion heard.
Not confirmed. Read the court's wording below.
Page 1 | Scheduling Procedures
Multiple hearings may not be scheduled simultaneously without Court approval, and another motion may be scheduled only after the Court rules on the preceding motion.
Please do not set multiple hearings at one time without Court approval and the parties may only set other motions after the Court rules on the last motion heard.
Not confirmed. Read the court's wording below.
Page 1 | AG Divisional Instructions
Parties should jointly file all exhibits, but if they do not, each must file its exhibits unilaterally at least two calendar days before the hearing.
The parties should seek to file all exhibits jointly, but in the absence of a joint filing, must file uni- laterally at least 2 calendar days in advance.
Not confirmed. Read the court's wording below.
Page 7 | 3.2 DOCUMENT PROCEDURES
Pre-Motion Conference Requirements
The parties and their experts must hold a remote conference to discuss the specific fee and cost objections no later than five days before Calendar Call.
Both parties and their respective experts shall meet, via remote conference, to discuss the specific objections to the fees and costs being claimed no later than five (5) days prior to Calendar Call.
Checked against the court's document on Oct 1, 2026 · Civil cases
Page 1 | IN RE: STANDING ORDER ON MOTIONS FOR ATTORNEYS' FEES AND COSTS
If the scheduling order so directs, the movant must request a conference with the court before filing a motion for an order relating to discovery.
(v) direct that before moving for an order relating to discovery, the movant must request a conference with the court;
We could not find this wording in the court's document. Open the source before relying on it. · Civil cases
Page 192 | APPENDIX 3-2 — COMPARISON OF FLORIDA AND FEDERAL RULES OF E-DISCOVERY
After conferring, the movant must schedule a hearing for every contested nondispositive motion within five days of filing or the motion may be deemed abandoned without further notice or hearing.
As required under the DCMO's, after the parties have met and conferred, the movant must schedule for hearing all contested, non-dispositive motions within five (5) days of filing. Failure to schedule a hearing within five (5) days may result in the Court deeming the motion(s) abandoned without further notice or hearing.
Not confirmed. Read the court's wording below.
Page 1 | Motions
Before filing, the movant must confer by telephone with opposing parties, including self-represented parties, in good faith and identify that conferral in the proposed order.
Before filing, movants must confer by telephone with opposing parties including self represented parties in a good faith effort to resolve the issues raised in the motion and indicate the same in the proposed order.
Not confirmed. Read the court's wording below.
Page 1 | Motions
Adjournment & Extension Requirements
Counsel must not seek extensions or continuances, or refuse to grant them, to harass an opponent or prolong litigation.
11. A lawyer should not seek extensions or continuances or refuse to grant them for the purpose of harassment or prolonging litigation.
Checked against the court's document on Oct 1, 2026
Page 4 | B. SCHEDULING, CONTINUANCES, AND EXTENSIONS OF TIME
The Court must approve any such motions, stipulations, or agreements at a hearing by the Pretrial Conference; noncompliant motions will be heard only upon good cause shown.
Any such motion(s), stipulation(s), or agreement(s) must be approved upon hearing by the Court no later than the Pretrial Conference. No such motion will be heard that is not in compliance with this Order except upon good cause shown.
Checked and corrected to match the court's document on Oct 1, 2026
Page 1 | CONTINUANCES
A trial may not be continued by agreed order, and any proposed continuance order must state good cause with specific factual and legal support.
Trials cannot be continued by an Agreed Order. The proposed order must state with specificity good cause with factual and legal basis.
Checked against the court's document on Oct 1, 2026
Page 1 | Scheduling Procedures - Continuance Procedure
A continuance motion must specifically state the need and when discovered, opposition, readiness actions and dates, the proposed ready date, and whether all parties agree to that date.
Motions for continuance must state with specificity: (1) the basis of the need for the continuance, including when the basis became known to the movant; (2) whether the motion is opposed; (3) the action and specific dates for the action that will enable the movant to be ready, including, but not limited to, confirming the specific date any required participants are available; and (4) the proposed date by which the case will be ready to proceed and whether that date is agreed by all parties.
Checked against the court's document on Oct 1, 2026
Page 1 | Scheduling Procedures - Continuance Procedure
The parties may extend most order deadlines by agreement without court approval, but not the listed deadlines and not when the extension would continue trial or prevent pretrial mediation.
The parties are permitted to grant extensions to the deadlines set forth in this Order, without Court approval, except for Paragraphs 11, and 27-33 below, provided that any such deadline extension agreement does not cause a continuance of the trial or would prevent the completion of mediation prior to trial.
Checked against the court's document on Oct 1, 2026 · Civil cases
Page 1 | COMPLEX CASE MANAGEMENT DATES AND DEADLINES
When parties cannot agree to extend DCMO deadlines, the requesting party must move to amend the DCMO and set the motion for a DCM conference under Part 6.
If the parties cannot mutually agree upon an extension of DCMO deadlines, the party seeking an extension shall move to amend the DCMO and set the motion for a DCM conference in accordance with Part 6.
Checked against the court's document on Oct 1, 2026 · Civil cases
Page 5 | b. Modification of Pretrial Deadlines Other Than Calendar Call/Trial
A motion to continue trial or the Calendar Call must be governed strictly by Rule 1.460.
The DCMO shall set an actual trial period. Accordingly, motions to continue trial (including Calendar Call) shall strictly follow and be governed by Rule 1.460.
Checked against the court's document on Oct 1, 2026 · Civil cases
Page 6 | 5. Continuances of Trial
Counsel must not impose unfair or extraneous conditions when granting extensions.
12. A lawyer should not attach to extensions unfair and extraneous conditions.
Checked against the court's document on Oct 1, 2026
Page 4 | B. SCHEDULING, CONTINUANCES, AND EXTENSIONS OF TIME
Counsel must have reasonably legitimate reasons for requesting scheduling changes, extensions, or postponements and must not request them solely for delay or unfair advantage.
13. A lawyer should not request rescheduling, cancellations, extensions, or postponements without reasonably legitimate reasons and never solely for the purpose of delay or obtaining unfair advantage.
Checked against the court's document on Oct 1, 2026
Page 4 | B. SCHEDULING, CONTINUANCES, AND EXTENSIONS OF TIME
Reasonable extensions of litigation deadlines should ordinarily be granted as a courtesy unless time is of the essence or a motion and order are required.
9. Requests for reasonable extensions of time to respond to litigation deadlines, whether relating to pleadings, discovery, or motions, ordinarily should be granted between counsel as a matter of courtesy unless time is of the essence, and unless the Court or rules of procedure require a motion and order as to the requested extension, counsel should agree to extensions of time via email or other correspondence to create efficient and cost effective litigation, and to avoid unnecessary motion practice.
Checked against the court's document on Oct 1, 2026
Page 4 | B. SCHEDULING, CONTINUANCES, AND EXTENSIONS OF TIME
Agreed extensions of Summary Judgment, Daubert, or discovery deadlines must be set for hearing, and the parties must be prepared to explain why the extension will not affect the Calendar Call date.
Agreements to extend the dates for the filing of Summary Judgment and Daubert motions, and for the completion of discovery, must be set for hearing, and the parties must be prepared to address how the proposed extension will not affect the Calendar Call date.
Checked against the court's document on Oct 1, 2026 · Civil cases
Page 5 | b. Modification of Pretrial Deadlines Other Than Calendar Call/Trial
A continuance sought solely to wait for an in-person court event is disfavored, will be considered only in extraordinary circumstances, and should be requested as early as practicable.
Requests for continuances based solely on a participant’s preference to wait until the court event can be conducted in person are disfavored, and will be considered only under extraordinary cir- cumstances. Parties and counsel should make any such requests as early as practicable.
Checked and corrected to match the court's document on Oct 1, 2026
Page 4 | 1. Remote Procedures Applicable to All Proceedings
Counsel should grant reasonable scheduling, rescheduling, cancellation, extension, and postponement requests when doing so would not prejudice the client's opportunity for full, fair, and prompt adjudication.
8. A lawyer should accede to all reasonable requests for scheduling, rescheduling, cancellations, extensions, and postponements that do not prejudice the client's opportunity for full, fair, and prompt consideration and adjudication of the client's claim or defense.
Checked against the court's document on Oct 1, 2026
Page 4 | B. SCHEDULING, CONTINUANCES, AND EXTENSIONS OF TIME
A continuance or trial-period extension request must be written, specifically state the required grounds and dates, and include signatures and a conferral certificate or an explanation of conferral efforts.
motions for continuance or stipulations/agreements and motions to amend or extend deadlines set forth in this order that change the trial period, even if agreed, must be in writing and state with specificity the following: the signature of the named party and the attorney representing the party requesting the continuance except for good cause shown; a concise statement of the facts and reasons that form the basis of the need for the continuance, including when the basis became known to the movant; whether the motion is opposed; the action and specific dates for the action that will enable the movant to be ready for trial by the proposed date ... the proposed date by which the case will be ready for trial and whether that date is agreed to by all parties; and either a certificate of conferral substantially in the form provided in rule 1.202(b), Fla. R. Civ. P., or if the conference required in rule 1.460(d), Fla. R. Civ. P. did not occur, an explanation of the dates and methods of the efforts to confer
We could not find this wording in the court's document. Open the source before relying on it.
Page 1 | CONTINUANCES
A specially set hearing cannot be canceled or continued by agreed order or by a notice of cancellation.
Specially set hearings cannot be cancelled or continued by Agreed Order or Notice of Cancellation.
Not confirmed. Read the court's wording below.
Page 1 | Scheduling Procedures
Continuances are disfavored and require good cause, lack of due diligence is not a sufficient basis, and absent good cause the requesting party must sign; the motion is due at least 30 days before the relevant calendar call unless exigent circumstances apply.
Motions for continuance are disfavored and will be granted only upon good cause shown. Successive continuances are highly disfavored. Lack of due diligence is not grounds for granting a continuance. Except for good cause shown, the motion must be signed by the party requesting the continuance, as required by Florida Rule of General Practice and Judicial Administration 2.545(e). Motions for continuance must be submitted at least thirty (30) days prior to calendar call for which the continuance is sought, barring exigent circumstances.
Not confirmed. Read the court's wording below.
Page 1 | Scheduling Procedures - Continuance Procedure
A continuance request that changes the trial period must be written and specify the requesting parties, reasons, opposition, trial-readiness actions and dates, proposed ready date, and conferral certificate or explanation.
motions for continuance or stipulations/agreements and motions to amend or extend deadlines set forth in this order that change the trial period, even if agreed, must be in writing and state with specificity the following: the signature of the named party and the attorney representing the party requesting the continuance except for good cause shown; a concise statement of the facts and reasons that form the basis of the need for the continuance, including when the basis became known to the movant; whether the motion is opposed; the action and specific dates for the action that will enable the movant to be ready for trial by the proposed date, including, but not limited to, confirming the specific date any required participant such as third-party witnesses or experts are available; the proposed date by which the case will be ready for trial and whether that date is agreed to by all parties; and either a certificate of conferral substantially in the form provided in rule 1.202(b), Fla. R. Civ. P., or if the conference required in rule 1.460(d), Fla. R. Civ. P. did not occur, an explanation of the dates and methods of the efforts to confer substantially in the alternative form provided in rule 1.202(b), Fla. R. Civ. P.
Not confirmed. Read the court's wording below. · Civil cases
Page 1 | Continuances
Any continuance motion, stipulation, or agreement affecting the trial period must be approved by the court no later than the Pretrial Conference.
Any such motion(s), stipulation(s), or agreement(s) must be approved upon hearing by the Court no later than the Pretrial Conference.
Not confirmed. Read the court's wording below. · Civil cases
Page 1 | Continuances
A trial-continuance motion must be immediately set for a DCM conference under Part 6 and filed promptly once good cause appears.
Such motions shall immediately be set for a DCM Conference in accordance with Part 6, and shall be filed promptly after the appearance of good cause to support such motion.
Not confirmed. Read the court's wording below. · Civil cases
Page 6 | 5. Continuances of Trial
In an emergency requiring rescheduling of the compulsory medical examination, the physician or plaintiff must immediately notify their respective legal representative and provide the reason.
If there is an emergency by either the physician or the Plaintiff, each person shall immediately notify their respective legal representative with the reason for the need to reschedule.
Not confirmed. Read the court's wording below. · Civil cases
A lawyer may request rescheduling, cancellation, extension, or postponement only for legitimate reasons and not for delay or unfair advantage.
4.19 A lawyer must not request rescheduling, cancellations, extensions, and postponements without legitimate reasons or solely for the purpose of delay or obtaining unfair advantage. (See R. Regulating Fla. Bar 4-4.4).
Not confirmed. Read the court's wording below.
Page 10 | Expectations
Chambers Communication Rules
Scheduling emails to chambers must copy all parties, and draft orders or documents may not be emailed unless the Court approves them.
For scheduling, please copy all parties. Please do not send draft orders or documents to this email unless approved by the Court.
Checked against the court's document on Oct 1, 2026
Page 1 | Contact Information
When contacting the judicial assistant, email CAD-DivisionAG@pbcgov.org and copy all parties.
Please email CAD-DivisionAG@pbcgov.org when contacting the JA and copy all parties.
Checked against the court's document on Oct 1, 2026 · Civil cases
Page 1 | AG Divisional News
The judicial assistant aims to respond substantively to inquiries within one business day or acknowledge receipt with a response estimate and alternate immediate contact.
The judicial assistant strives to substantively respond to all inquiries within one business day. If the judicial assistant is unable to substantively respond within one business day, your message will be acknowledged as received with an indication of when to expect a substantive response and alternate contact for immediate assistance.
Checked and corrected to match the court's document on Oct 1, 2026
Page 1 | Communications with the Judicial Office
Self-represented litigants and attorneys excused from email service may call the judicial office at 561-355-3845, but text messages are not accepted.
Self-represented litigants and attorneys excused from e-mail service may communicate with the judicial office by telephone call to 561-355-3845. The judicial office does not accept text messages.
Checked against the court's document on Oct 1, 2026
Page 1 | Communications with the Judicial Office
The Sheriff must promptly notify the judge’s office by telephone at (561) 355-3845 during office hours after executing the writ.
Upon execution of this Writ, the Sheriff shall promptly notify by telephone AND DURING OFFICE HOURS the office of the undersigned Judge at (561) 355-3845.
Checked against the court's document on Oct 1, 2026 · Civil cases
Page 1 | ORDER OF CONTEMPT AND WRIT OF BODILY ATTACHMENT
Email communications with the judicial office are limited to scheduling, must identify the case and matter in the subject line, must copy all parties, and may not transmit ex parte communications, proposed orders, exhibits, or filings.
Email communications with the Judicial office are limited to scheduling matters. The subject line of any e-mail to the judicial office must contain the case number, case name, and relevant matter (e.g., 2026 CA 001234 – Doe v. Doe –Hearing Requested Cancelled). You must copy all parties on communications with the Court; no ex-parte communications will be considered. Please do not provide proposed orders, exhibits, or filings to the Court by email.
Not confirmed. Read the court's wording below.
Page 1 | Communications with the Judicial Office
Counsel may call chambers during a deposition to request a brief hearing when an irreconcilable dispute must be resolved.
Counsel may want to take a break during the deposition and call chambers, requesting a brief hearing to resolve the matter.
Not confirmed. Read the court's wording below. · Civil cases
Page 90 | The Proper Response to Improper Conduct