Eleventh Judicial Circuit of Florida, Miami-Dade County Filing Rules

The cover letter accompanying a proposed order must state that all opposing counsel/unrepresented parties received the same materials provided to the Court and whether the parties agree with the language of the proposed Order.

A written motion seeking a confidentiality determination must be captioned "Motion to Determine Confidentiality of Court Records."

Motions for rehearing, reconsideration, new trial, and other post-trial motions on entitlement to fees and costs are not heard on Motion Calendar and must be submitted with a proposed order through Proposed Orders in courtMAP.

Only one expert per specialty per side is permitted unless otherwise ordered.

Parties must appear at FWOP hearings regardless of filings unless the case is fully resolved or a Court Order excuses appearance.

If hearings cannot be coordinated through courtMAP, the moving party must contact the Judicial Assistant to have the hearing scheduled.

Chambers is located at the Lawson E. Thomas Courthouse, 175 N.W. 1st Avenue, 2920, Miami, FL 33128, and can be reached by telephone at (305) 349-5674.

A copy of any cross-notice of a hearing already set or approved by the Judge must be sent to the judicial assistant or the matter may not be heard.

If parties cannot agree on a hearing date, both must email the Judicial Assistant; if they agree, only one party needs to schedule the hearing.

Parties must contact chambers and follow up on all emails sent to chambers.

For in-person trials, parties must not file any exhibits.

When requesting Zoom conversion of a hearing, the moving party must upload the Order onto courtMAP.

File the motion and hearing request with the clerk through the E-Filing Portal and add the specified address to the courtesy-copy email list.

For insurance cases, do not submit motions or proposed orders on pretrial conference waivers; they will be rejected.

Notices of Cancellation must be filed through e-filing and courtMAP.

The motion attached to a proposed order must be filed with the Clerk before uploading or the order will be rejected.

The posted sealing order must remain posted for no less than 30 days.

All special set hearing documentation must be uploaded and e-filed at least 7 days before the hearing, in addition to the courtMAP upload.

Do not request or schedule a hearing for a motion that has not been filed.

Parties must comply with the Evidence Submission Procedure no less than 5 days before an evidentiary hearing or trial; this deadline supersedes shorter deadlines.

Do not issue hearing notice before confirmation; if the opposing party is not registered with CourtMAP, generate a notice with a certificate of service and mail it to that party.

The moving party on the foreclosure motion calendar must give five business days' notice.

Opposing counsel and unrepresented parties must be copied on the courtesy-copy cover letter and enclosures unless the enclosures were already provided via the e-portal/service of process, and the letter must specify this.

All matters to be heard by the court must be filed with the Clerk of Court and a copy must be submitted to the other side or their attorney.

Original loan documents must be delivered to the Clerk's office before the hearing and must never be sent to chambers.

Filing a Motion for Protective Order without attempting to set it for immediate hearing does not protect a party from the discovery requested.

The five-minute motion calendar is limited to non-evidentiary matters.

The parties must meet and confer as required by the rules of civil procedure before a motion is set.

Parties must meet and confer on the language of a proposed order before submitting it.

Parties must meet and confer before filing motions, and the filing party must state that no resolution was reached or that the other party could not be contacted despite due diligence.

Before scheduling a motion, counsel must email the courtesy copy of the motion to the Judicial Assistant and cover opposing counsel on the same email.

Seal/expunge petitions must be filed with the Clerk's office with a copy sent to chambers.

Motions in limine must be filed with the Clerk's office and a copy sent to chambers by facsimile or e-mail.

Counsel must add the division email F006@jud11.flcourts.org to their service list so Chambers receives email copies of e-filed motions, since the Clerk's Office does not provide them.

A copy of each motion must be sent to chambers by email, fax, or hand delivery (the clerk does not forward e-filed motions to the judge), and the original motion must be filed with the clerk's office.

Special set hearings cannot be cancelled by only filing a Notice of Cancellation (except on settlement, agreed order, or withdrawal); rescheduling requires a Motion to Continue.

Parties must contact chambers and provide a reason when canceling any scheduled hearing.

Continuance motions may be made ore tenus at Sounding or calendared before Sounding; those filed after Sounding are addressed the day of trial, except for special set trials where the Court will set the motion between Sounding and trial.

Hearing cancellations must be received by email at least 24 hours before the hearing.

Parties may submit agreed orders extending discovery deadlines.

Motions and memoranda for specially set hearings must contain 1 inch margins.

Insert a page before each exhibit showing its number or letter in large, bold, centered type, using the largest size that fits on one page.

Motions and memoranda submitted for specially set hearings must include page numbers.

The proposed order submitted with a hearing request must be in Microsoft Word format.

The accompanying motion and supporting documents must be uploaded under the Supporting Documents tab in PDF format.

The court prefers supporting documentation to be submitted in the same document as the motion for efficiency.

All proposed orders must be submitted through CourtMap together with the respective motion and cover letter.

No more than two motions may be set for one special set hearing without prior Court approval.

Every proposed order must be accompanied by the motion, supporting documents, stipulation, and a letter of explanation.

Each supporting document for a special set hearing must be submitted separately and properly titled.

A motion to seal may be granted only where confidentiality is required to protect an enumerated interest, such as preventing a serious and imminent threat to the administration of justice, a trade secret, a compelling government interest, obtaining evidence, avoiding substantial injury to innocent third parties or a party, or complying with established public policy.

The closing statement must not be filed with the Court; it must be submitted directly under seal or brought to the hearing if one is held.

Motions to seal/expunge must be filed with the Clerk with all supporting documentation and a copy provided to chambers.

Special set motions are limited to 25 pages and must be double-spaced with one-inch margins and 12-point font.

Reply briefs shall not exceed 10 pages.

A case may have no more than 15 minutes and three motions total on the five-minute motion calendar.

A Motion or Response longer than 20 pages requires a hard copy at least seven calendar days before the hearing.

Motions and memoranda are limited to 20 pages, excluding exhibits, and leave of court must be obtained before submitting any that exceed the limit.

Transcripts of General Magistrate hearings must be arranged directly with the vendor Absolute Digital Inc. at the requesting party's expense.

A final invoice for the audio recording must be paid before the recording will be released.

A final invoice for the audio recording (per Rule 2.420 review) must be paid before the recording is released.

The required forms packet is available from the Clerk's Office at a cost not to exceed $35.00, subject to good-cause waiver of the procedures by the Administrative or Associate Administrative Judge.

A final invoice for the audio recording must be paid before the recording will be released.