Southern District of Florida Local Rules and Judge Filing Requirements

USB flash drive with digital exhibits required at trial.

Objections based on irrelevance or not reasonably calculated to lead to admissible evidence are outdated.

Discovery responses must include clear statement that all responsive documents have been produced.

If motion is granted, court must award reasonable expenses including attorney’s fees under FRCP 37(a)(5).

Lead counsel must submit the completed Order Scheduling Mediation form to the Court.

Jurors and witnesses with subpoenas may bring phones and e-readers.

Contact Chambers at (305) 523-5720 to schedule discovery hearing.

Parties may not send materials to chambers via email for hearings on written discovery motions.

Moving party must state requested additional time in email to Chambers for discovery hearing.

Calls to Chambers require prior party consultation, opposing counsel on line, and specific information provided.

Objections to Rule 30(b)(6) topics must be resolved through conference or hearing before deposition.

Rule 37(a) motions to compel discovery may be resolved via Informal Discovery Hearing.

Joint motions exempt from pre-filing procedures.

Parties may still request oral argument even if Court sets hearings sua sponte.

Personal conferral (in person/phone) required unless opposing party refuses after reasonable time; moving party must advise court of refusal.

The Probation Office must disclose the Final PSR and Addendum no later than 7 days prior to the sentencing hearing.

If the case settles in whole or in part, counsel must file a notice of settlement signed by counsel of record within 14 days after the mediation conference.

Plaintiff must file either Motion for Default Final Judgment or Motion to Determine Joint and Several Liability on Default within 7 days of Clerk's entry of default.

Discovery disputes must be raised in a timely manner per Local Rule 26.1(g)(2), which the Court strictly enforces.

Mediation must be completed within 20 days after the defendant’s response to the statement of claim is due.

Replies to discovery motion responses limited to 5 pages.

Opposition to discovery motion limited to 5 pages, due within 5 business days.

Discovery motions limited to 3 pages.

Response to discovery motion limited to 5 pages, due within 5 business days.

Each side limited to 30 minutes for discovery hearings.

Law enforcement officers with valid ID and official business exempt.

Exhibits must use numerical labels only with case number, exhibit number, and offering party.

Proposed jury instructions must also be emailed to the Court at scola@flsd.uscourts.gov in Word format (.doc).

Proposed orders must be in Word format, 12-pt Palatino Linotype, double-spaced, justified, with page numbers starting on page 2.

Calendar call scheduled for Tuesday prior to trial commencement at 8:30 a.m.

Extending discovery deadline waives Rule 56(d) arguments about inability to move for summary judgment.

All discovery must be completed 135 days after joint scheduling report filing in expedited track.

Motions for extensions of time will rarely be granted.

Discovery disputes must be brought to court within 28 days of when grounds for relief occur.

Motion must be filed within 30 days; response within 5 business days; reply within 3 business days.

If stay relief involves property subject to a Florida state court action, serve the clerk of that state court as an interested party with the order and include the state court case number below the clerk's name on the certificate of service.

The adverse party must serve and file objections and cross-designations within seven days.

Notice of objection to a deposition notice must be served (not filed) on the opposing party within five days of receipt, and failure to timely preserve may result in waiver.

Plaintiff must serve motion on defendant/counsel, include service details in Certificate of Service, and not rely solely on CM/ECF for service.

Plaintiffs must send a copy of the motion to defendants’ counsel or directly to pro se defendants.

Parties must notify court if lawyer with 5 or fewer years experience will argue.

Experienced counsel may supplement/amend junior counsel's argument with additional time.

Junior lawyers (5 or fewer years) may have multiple attorneys argue.

Junior lawyers (5 years or less experience) may argue with multiple attorneys if notified in advance.

Junior lawyers (5 years or less) may argue with multiple attorneys if notified in advance.

Motions and memoranda are rarely needed.

Substantive discovery motions filed on docket will be stricken; use discovery calendar instead.

Written discovery motions between parties are prohibited unless specifically authorized by court order.

Source Materials for Informal Discovery Hearings must be filed as separate documents.

Settlement negotiations before conference are not required but encouraged.

Proposed voir dire questions must be filed with the joint pretrial stipulation and emailed to the Court in Word format (.doc).

Proposed orders must be emailed to chambers in Word format.

Movants with CM/ECF credentials must file Notice of Hearing and calendar Discovery Hearing via CM/ECF system.

Source materials must be provided via hand-delivery or email to CM/ECF mailbox on hearing date.

All papers and exhibits must comply with the federal judiciary privacy policy per Local Rule 5005-1(A)(2).