Seventeenth Judicial Circuit of Florida, Broward County Pre-Motion Conference Requirements

CRITICALCriminal cases

For special set hearings (15 minutes or longer), the motion must first be filed with the Clerk of Court, and chambers does not accept ex parte communication.

You MUST first file your motion with the Clerk of Court. This office does not accept ex-parte communication.

CRITICAL

Calendar Call is limited to trial readiness and negotiated pleas; no other substantive motions or requests will be heard at Calendar Call without specific permission from the Court.

The only matters that will be addressed at the calendar call is trial readiness. Negotiated pleas will also be taken at Calendar Call. No other substantive motions or requests will be heard on Calendar Call without specific permission from the Court.

CRITICAL

Parties must attend mediation before setting any temporary relief matter for an evidentiary hearing.

The parties must attend mediation before setting any temporary relief matter for an evidentiary hearing.

CRITICAL

Before setting a matter on the UMC, the movant must attempt to resolve the matter by direct communication with all parties and certify the good-faith attempt.

Per Local Rule 10A prior to setting any matter on uniform motion calendar, the party or parties noticing the motion shall attempt to resolve the matter by direct communication with all parties, and shall also certify a good faith attempt to resolve or narrow the issues contained in the motion. Direct communication means by oral or written communication, including by telephone, in person, email, or text messaging.

CRITICAL

All parties must confer and attempt in good faith to resolve the issues before scheduling a special set hearing.

All parties must confer prior to scheduling the hearing and in good faith attempt to reach a resolution of the issues.

CRITICAL

All parties must confer and attempt in good faith to resolve the issues before scheduling any hearing.

All parties must confer prior to scheduling the hearing and in good faith attempt to reach a resolution of the issues.

CRITICAL

Before setting a motion to compel discovery for hearing, both parties must make a bona fide, item-by-item effort to resolve each contested matter.

Prior to setting Motions to Compel on the docket, Judge Barner requires both parties to make a bona fide effort to resolve each contested matter, on an item by item basis, prior to the matter being set for hearing.

CRITICAL

Parties must confer in good faith before scheduling a special set hearing, and no law firm may notice more than two total cases per day without leave of court.

All parties must confer prior to scheduling the hearing and in good faith attempt to reach a resolution of the issues. No more than two (2) total cases may be noticed by any law firm, including all attorneys affiliated with the firm, on any given day except by leave of the Court.

CRITICAL

Parties must make a bona fide, item-by-item effort to resolve contested discovery before setting a motion to compel for hearing.

Prior to setting Motions to Compel on the docket, Judge Powell requires both parties to make a bona fide effort to resolve each contested matter, on an item by item basis, prior to the matter being set for hearing.

CRITICAL

Court-set pretrial conferences must be attended by the parties or counsel; failure to attend results in sanctions.

Any pretrial conference set by the Court must be attended by the parties or legal counsel. Failure to attend will result in sanctions.

CRITICAL

A law firm, including all affiliated attorneys, may not set more than two motions on a single day unless the motions involve separate cases.

NO LAW FIRM (INCLUDING ALL ATTORNEYS AFFILIATED WITH THE FIRM) may set more than two (2) motions on any single day, unless the Motions involve separate cases.

CRITICAL

Double-booking or back-to-back hearings are prohibited at any time, and sanctions may be imposed for non-compliance.

NO DOUBLE BOOKING or “BACK TO BACK” of any hearing is permitted at any time. Sanctions may be imposed for non-compliance.

CRITICAL

Any motion set without following the hearing procedures will be cancelled and sanctions may be imposed.

ANY MOTION SET WITHOUT FOLLOWING THESE PROCEDURES WILL BE CANCELLED AND SANCTIONS MAY BE IMPOSED.

CRITICAL

All parties must consult regarding each attorney's availability before scheduling a hearing.

STEP 2: CONSULT WITH OPPOSING COUNSEL. IT IS MANDATORY that all parties consult regarding availability of each attorney.

CRITICAL

Case management conferences are mandatory appearances with no motions heard, and cancellations are permitted only if the case has settled or been dismissed.

Are mandatory appearances. No motions will be heard at that time. Cancellations of case management hearings - if the case has settled or has been dismissed.

CRITICAL

Parties must meet and confer five days before any status hearing and ten days before any trial.

The parties shall meet and confer five (5) days before any status hearing and ten (10) days before any trial.

CRITICAL

Parties must communicate (confer) with opposing counsel before requesting a hearing time.

Prior to requesting a Hearing, parties are required to communicate with opposing counsel.

CRITICALCivil cases

Parties must hold a mandatory conference before proceeding, as required by Local Rule 10a.

A mandatory conference between parties is mandated pursuant to Local Rule 10a.

CRITICALCivil cases

Matters a party wishes to heard, whose contested status is unknown, or that the court instructs to set for hearing must be scheduled as special set hearings under Section III.

(b) If the moving party wishes to set a matter for hearing, is unaware whether a matter is contested or is otherwise instructed by the court to set the matter for hearing, a hearing shall be scheduled as a "special set hearing in accordance with Section III."

CRITICALCivil cases

All parties must comply with Local Rule 10A before any hearing, or the case may be reset.

All parties prior to any hearing shall be required to comply with Local Rule 10A, failure to comply may result in your case being reset.

CRITICAL

All UMC hearings must be coordinated with the opposing counsel/party before the hearing is set.

All UMC hearings must be coordinated with the opposing counsel/party before setting the hearing.

CRITICAL

No case may be set for trial until a mediation impasse report is filed with the Clerk's Office.

No case shall be set for trial unless and until a mediation impasse report is filed with the Clerk's Office.

CRITICAL

Discovery motions may no longer be heard on UMC; they must be specially set, heard in-person with all parties attending, and limited to 5-minute increments.

As of October 31, 2025, discovery motions will no longer be heard on UMC and must be specially set pursuant to Division Procedures. Going forward, all discovery hearings shall be held IN-PERSON and all parties shall be in attendance. Motions shall be limited to 5-minute increments.

CRITICAL

No temporary relief hearing may be set unless the parties have first attended mediation and an impasse has been reported; failure to attend or provide notice of impasse results in cancellation.

"No temporary relief hearing shall be set unless the parties have first submitted to mediation and an impasse has been reported." Admin. Order No. 2026-06-UFC.

CRITICAL

A mandatory in-person Pre-Trial Conference is held on UMC approximately two weeks before trial, with attendance required for all parties and counsel.

Pre-Trial Conference: The Court will schedule a Pre-Trial Conference approximately two weeks prior to the trial date on the Court's Uniform Motion Calendar (UMC). Please see the Uniform Trial Order for the notice of hearing. The Pre-Trial Conference will be held in-person and attendance is mandatory for all parties and counsel.

CRITICAL

A law firm and its affiliated attorneys may not set more than three motions on a single day without advance court approval.

NO LAW FIRM (INCLUDING ALL ATTORNEYS AFFILIATED WITH THE FIRM) may set more than three (3) motions on any single day, even if the Motions involve separate files, unless approved in advance by the Court.

CRITICAL

Double booking hearings is prohibited and sanctions may be imposed; add-ons require court approval.

NO DOUBLE BOOKING of any hearing is permitted at any time. Sanctions may be imposed for non-compliance. No “ADD-ONs” will be permitted without approval of the Court.

CRITICAL

A fee hearing cannot be set until the Court determines entitlement and the parties comply with the preliminary order.

NOTE: Before a Fee Hearing may be set, the Court must determine Entitlement first. The parties must comply with the court's preliminary order.

CRITICAL

All parties must consult regarding attorney availability before scheduling a hearing.

It is MANDATORY that all parties consult regarding availability of each attorney. Users may log on at the same time to see the Court's schedule of available times when selecting the date and time for a hearing.

CRITICAL

For all other Motions to Compel, parties must make a bona fide item-by-item effort to resolve each matter first.

For all other Motions to Compel, the Court requires all parties to make a bona fide effort to resolve each matter being compelled on an item by item basis.

CRITICAL

The Order Preliminary on a fees motion will not be entered until a final judgment or stipulation disposing of the underlying case is entered.

However, the Court will not enter its Order Preliminary unless there is a Final Judgment, Stipulation for Dismissal, etc., entered disposing of the underlying case.

CRITICAL

No reply or further memorandum may be filed on a motion or response unless the Court grants leave.

No party shall file any reply or further memorandum directed to the motion or response allowed in (a) and (b) unless the Court grants leave.

CRITICAL

Hearings over 15 minutes require Court review before dates are provided: email the motion with attachments and case law (copying all parties) with a cover letter stating requested time for both sides, then contact Ms. Stitt by email for potential dates, and notice the hearing only after Ms. Stitt authorizes it by email.

Any hearings over 15 minutes must be reviewed by the Court before any dates are provided. Please provide via email, remember to copy all parties to the email (please do not mail in hard copies) a copy of the motion (with all attachments) and any case law to the Court and indicate on a cover letter how much time is requested for both sides. Also, please include correct email addresses for all parties. You should contact Ms. Stitt via email (copy all parties) within a few days after receipt of the documents, for potential hearing dates. Once a date has been agreed to by all parties, please advise Ms. Stitt by email. Ms. Stitt will then authorize you, by email, to serve and file a notice of hearing for the appropriate date. Failure to strictly comply with this procedure may result in the inability to schedule future special set hearings.

CRITICAL

Before setting a matter on UMC, the noticing party must attempt to resolve or narrow the issues by direct communication with all parties and certify the good-faith attempt.

Prior to setting any matter on uniform motion calendar, the party or parties noticing the motion shall attempt to resolve the matter by direct communication with all parties, and shall also certify a good faith attempt to resolve or narrow the issues contained in the motion. Direct communication means by oral or written communication, including by telephone, in person, email, or text messaging.

CRITICAL

The fee/cost amount hearing may not occur until all counsel file a certification that all fee/cost discovery is complete.

The hearing to determine the amount of fees/costs to award shall not take place until all counsel file a certification with the Court that all discovery in connection with all fee/cost issues, has been completed.

CRITICAL

A reply statement of (material) facts is not permitted in summary judgment practice.

A reply statement of facts is not permitted.

CRITICAL

Motions for summary judgment must be scheduled for hearing and heard prior to Calendar Call.

MOTIONS FOR SUMMARY JUDGMENT MUST be scheduled for hearing and heard prior to CALENDAR CALL, VII (d) (1).

CRITICAL

Unless a new lawyer is substituting, a motion to withdraw must be set for a UMC hearing with notice to all parties.

Unless a New Lawyer is substituting as attorney, a Motion to Withdraw must be set for a hearing on UMC, with notice to all parties.

CRITICAL

All hearings are in-person; remote appearance requests must be made by written motion filed with the Clerk, not by calling or emailing the Judicial Assistant.

All division 59 hearings are in-person. All requests for appearance by Zoom or by phone must be made by written motion filed with the Clerk of Court then following the procedures to obtain a hearing. Please do not call and/or send emails asking to appear remotely or for a continuance. The Judicial Assistant does not have the authority to permit anyone to appear remotely or continue any hearings for any reasons.

CRITICAL

Motions subject to legal sufficiency review (e.g., suppress, dismiss, post-conviction) must be provided to the Court before a hearing is set, and the Court may rule on sufficiency before setting any hearing.

Any motion which is not subject to on-line scheduling, or which is subject to an evaluation of legal sufficiency, including but not limited to, Motions to Suppress, Motions to Dismiss, Post-Conviction motions, etc… must be provided to the Court prior to the setting of a hearing. The Court may rule on the sufficiency of the motion prior to setting any hearing.

CRITICAL

Evidentiary motions and motions requiring factual determinations cannot be heard on the day of trial and must be heard before announcing ready for trial or during the week between calendar call and the first day of the trial period.

No evidentiary motions will be heard on the day of trial. While the Court will hear legal motions, such as motions in limine, any motion that requires a factual determination (including any discovery issues) must be set and heard either prior to announcing ready for trial or during the week between calendar call and the first day of the trial period.

CRITICAL

Before setting a matter on UMC, the noticing party must attempt to resolve it by direct communication with all parties and certify the good-faith attempt.

Prior to setting any matter on uniform motion calendar, the party or parties noticing the motion shall attempt to resolve the matter by direct communication with all parties, and shall also certify a good faith attempt to resolve or narrow the issues contained in the motion.

CRITICAL

When no default has been entered and both sides are represented, parties must consult on availability, and a moving party may unilaterally set a hearing only after two documented coordination attempts spaced at least 24 hours apart with at least 24 hours response time for the second attempt.

If a default has not been entered and both sides are represented by counsel, it is mandatory that all parties consult regarding the availability of the opposing side. A moving party may unilaterally set a hearing if the non-moving party fails to respond and/or participate in coordination after two (2) documented attempts, with at least 24 hours between each attempt, and a response time of at least 24 hours for the second attempt.

CRITICAL

All matters must be mediated before final hearing, with exceptions for contempt/enforcement, discovery issues, pleadings motions, uncontested matters, and court-ordered hardship/emergency exceptions.

All matters must be mediated prior to final hearing in an effort to resolve the disputed issues without court intervention. All post-judgment matters and temporary support and/or timesharing matters are automatically referred to mediation prior to a hearing. The following hearings may be scheduled without prior mediation: civil contempt or enforcement of support; discovery issues (motions to compel, objections to discovery, etc.); motions directed to the pleadings (seeking to amend, strike, dismiss, set aside, or for default, etc.); uncontested matters (name change, dissolution, etc.); and where the Court has entered an order allowing an exception based upon a hardship, emergency or other exigent circumstances pursuant to a written motion filed with the Court.

CRITICAL

Mediation is required before all Temporary Relief hearings, and no hearing dates will be given until mediation is completed.

Mediation is required for all Temporary Relief hearings, No hearing dates will be given until the parties go to Mediation.

CRITICAL

CMCs, contempt motions, motions to dismiss, and all discovery matters may not be heard on UMC and must be specially set.

CASE MANAGEMENT CONFERENCES, MOTIONS FOR CONTEMPT AND MOTIONS TO DISMISS AND ALL DISCOVERY MATTERS SHALL NOT BE HEARD ON UMC AND MUST BE SPECIALLY SET.

CRITICAL

Before setting any hearing on CMS or requesting a special set hearing, the setting party must meet and confer with the opposing party per Local Rule 10A.

Prior to setting a hearing on CMS, and prior to requesting a special set hearing, counsel (or the self-represented party) for the setting or requesting party must meet and confer with the opposing party regarding the matter to be set and the hearing date. The meet and conferral must be in accordance with Local Rule 10A.

CRITICAL

The moving party must coordinate with opposing counsel or the opposing side before setting a Motion Calendar hearing.

The Moving party must coordinate with the opposing counsel/side prior to setting the hearing.

CRITICAL

After filing a summary judgment/disposition motion, the movant must schedule a 'Motion to set Summary Judgment/Summary Disposition hearing' on the motion calendar only, where the judge will confer with both parties and set the matter and its duration.

After the respective motion is filed with the Clerk of the Court and the moving party is READY to proceed on the said matter, the moving party shall then schedule a “Motion to set Summary Judgment/Summary Disposition hearing” on the MOTION CALENDAR ONLY. The Judge will confer with both parties at the hearing and determine when the said matter will be scheduled and for what duration.

CRITICAL

Special set hearings are set by the Court only after a motion calendar hearing has been held.

ONLINE SPECIAL SET HEARINGS WILL BE SET BY THE COURT AFTER A MOTION CALENDAR HEARING IS HELD

CRITICAL

The moving party must meet and confer with opposing counsel or the opposing side before setting a hearing.

The Moving party must coordinate with the opposing counsel/side before setting the hearing.

CRITICAL

Substantive motions and requests will not be heard at Calendar Call without specific permission from the Court.

No other substantive motions or requests will be heard on Calendar Call without specific permission from the Court.

WARNING

If opposing counsel does not respond within two full days of good-faith contact, the hearing may be set unilaterally.

If you tried in good faith to coordinate a hearing, and have not received a response from opposing counsel within two full days of your contact, you may set the hearing unilaterally.

WARNING

If the opposing party fails to provide reasonable deposition dates within two business days, the requesting party may unilaterally set the deposition.

If the opposing party does not provide reasonable dates within two business days of the request, you may unilaterally set the deposition. The burden will then be on the opposing party to move for protective order and explain why no reasonable dates were provided.

WARNING

Any party may request a pretrial conference at any time, and at-issue cases not set for trial must either agree on a trial setting or seek a pretrial conference.

Any party may request a pretrial conference at any time by making a request to the Court. The Court may also set a pretrial conference at any time. If your case is not set for trial and is “at issue”, the parties must either 1) agree on a trial setting; or 2) seek a pretrial conference.

WARNING

Only one special-set time slot per case per day may be booked; on the 5-minute Motion Calendar one slot covers two motions per case per day and they must be set simultaneously.

Special Sets - You can only book one (1) time slot per case per day = Motion Calendar (5 minute hearings) - 1 slot, 2 motions per case, per day - must be set simultaneously.

WARNINGCivil cases

At the Pretrial Conference or Calendar Call the parties should be prepared to address the length of time the final hearing requires, the number of witnesses to be called, the outstanding discovery, and any pending Motions. The parties should have conferred prior to the Pretrial Conference or Calendar Call to ensure efficiency.

At the Pretrial Conference or Calendar Call the parties should be prepared to address the length of time the final hearing requires, the number of witnesses to be called, the outstanding discovery, and any pending Motions. The parties should have conferred prior to the Pretrial Conference or Calendar Call to ensure efficiency.

WARNING

Hearings over five minutes or requiring evidence must be Special Set; motions to vacate GM/HO R&R are limited to 30 minutes, temporary relief to 1 hour, and temporary relocation to 3 hours.

Any hearing requiring more than five (5) minutes or requiring evidence must be Special Set by the Court. Hearings on motions filed to vacate the GM/HO's Report and Recommendation are limited to THIRTY (30) minutes. Hearings on temporary relief are limited to ONE (1) hour pursuant to Administrative Order No. 2026-06-UFC. Hearings on temporary relocation are limited to THREE (3) hours.

WARNING

UMC is limited to five-minute, non-testimony matters such as uncontested finals, defaults, adoption, name-change, and non-evidentiary matters; rehearing, motions to vacate R&R, and expedited-hearing requests are not appropriate for UMC.

UMC hearings are limited to matters which can be heard in five (5) minutes and do not require any testimony. UMC is appropriate for uncontested final hearings, default final hearings, adoption hearings and final hearings, name-change hearings, and non-evidentiary matters. UMC is not appropriate for motions for rehearing/clarification/reconsideration, motions to vacate reports and recommendations, or motions to set expedited hearings.

WARNING

Hearings on motions for rehearing/reconsideration/clarification, if any, are limited to thirty minutes.

Hearings, if any, are limited to THIRTY (30) minutes.

WARNING

Temporary relocation hearings are limited to one hour and final relocation hearings to a one-day trial.

Hearings on Petitions for TEMPORARY Relocation are limited to one (1) hour. Final Hearings on Petitions for Relocation are limited to a one (1) day trial.

WARNING

Motions for rehearing/reconsideration/clarification may not be set for hearing unless explicitly authorized by the Court.

Except where explicitly authorized by the Court, no motions for rehearing or reconsideration or clarification shall be set for hearing.

WARNING

Invocation of the rules is discretionary and rarely granted, and filing the motion does not excuse appearance at the pretrial conference unless an order is entered.

Please remember that the invocation of rules is discretionary with the Court and is rarely granted. Do not assume that the Rules have been invoked unless you receive a signed order from Judge Peffer. Also, please note that submission of a motion to invoke the rules does NOT excuse appearance at the Pretrial Conference unless the Court has actually entered the order.

WARNING

Attorney fee hearings will not be scheduled until the attorney fee scheduling order is complied with; a copy of the fee motion must be provided to Ms. Stitt so the Court can issue a scheduling order.

An attorney fee hearing will not be scheduled until there has been compliance with the attorney fee scheduling order. (see last page of procedures). Please provide Ms. Stitt with a copy of your attorney fee motion so that a scheduling order may be issued by the Court.

WARNING

Cases are placed on the trial docket via a Status Conference on the Motion Calendar, or the parties may email div24@17th.flcourts.org to request a particular trial period.

TRIAL ORDERS: The parties are to schedule a Status Conference on Motion Calendar for the Court to place a case on a Trial Docket. Alternatively, the parties can agree to be placed on a trial period by emailing the court requesting a particular trial period. The email should be sent to div24@17th.flcourts.org.

WARNING

Motions to Mitigate or Reduce Sentence should not be scheduled without Court approval and are generally ruled on in chambers based on the papers.

Motions to Mitigate or Reduce Sentence should not be scheduled without Court approval. The Court will generally rule on the merits of the motion based on the information provided, in chambers.

WARNING

Agreed motions should not be scheduled for hearing unless the Court determines a hearing is necessary.

Agreed motions should not be scheduled for hearing unless the Court determines it necessary.

WARNING

Downward departure hearings may only be set once all parties are fully ready, bifurcation is allowed only in emergencies, and the Defendant bears the burden of presenting a treatment plan.

Hearings on downward departure motions shall only be set once all parties are fully ready to be heard. Bifurcated hearings will only be done on an emergency basis. If Defendant seeks a program, it is Defendant’s burden to present a treatment plan to the Court.

WARNING

Before scheduling a special set hearing, all parties must confer in a good faith attempt to resolve the issues.

All parties must confer prior to scheduling the hearing and in a good faith attempt to reach a resolution of the issues.

WARNING

For all other Motions to Compel, represented parties must make a bona fide effort to resolve each matter being compelled on an item-by-item basis.

For all other Motions to Compel, Judge Di Pietro requires all parties represented by counsel to make a bona fide effort to resolve each matter being compelled, on an item by item basis.

WARNING

Before submitting a motion to return property, contact the Law Enforcement Agency and State Attorney's Office; provide an agreed order if agreed, or set a hearing and notify both if contested; firearms require a hearing and an FDLE check.

When submitting a motion to return property, please do the following: 1. Contact the Law Enforcement Agency and the State Attorney's Office. 2. If agreed, please provide my office with an agreed order. 3. If contested, set for a hearing and notify the Law Enforcement Agency and the State Attorney's Office. *Firearms must be set for a hearing, and the person getting the property must have a FDLE check run.

INFO

Appellate matters have no hearings unless ordered by the Court, and all motions are decided on the papers.

There are no hearings for appellate matters unless ordered by the Court. All motions are decided on the papers.

INFO

Downward departure motions requiring evidentiary support should be set for hearing only once all parties are ready to be heard.

Any Downward Departure motion that requires the presentation of evidence to support the basis for departure should be set once all parties are ready to be heard.