Judge Michaelle Gonzalez-Paulson
Individual Rules, Standing Orders & Policies
Limits & Logistics
Courtesy Copies
Courtesy copies
- Not Required
Filings > 40 pages
Motion for Attorneys Fees
- 1 copy • Email
Response, Pleading
- 1 copy • Email • If Filed Less Than 48 Hours Before Hearing
Communication
Chambers
Phone
Chambers
Document Format Requirements3 rules
Proposed orders should be in Times New Roman type, with a minimum of 12-point font.
- Font
- Times New Roman
- Font size
- At least 12 points
- Proposed order
Formatting
- •Minimum 12-point font
Proposed orders should be in Times New Roman type, with a minimum of 12 point font.
- Font
- Times New Roman
- Font size
- At least 12 points
- Proposed order
Formatting
- •Minimum 12-point font
Please be mindful that, because of docketing delays, filings do not always appear on the docket immediately. Case law or statutes provided in the materials should highlight the relevant portions.
Document Filing Requirements18 rules
Motions for Substitution of Counsel must comply with the requirements of Fla. R. Jud. Admin. 2.505 and certify that the incoming counsel has conferred with current counsel, reviewed the case docket, and is aware of all upcoming depositions, hearings, and other deadlines in the case.
Motions to Disqualify must follow the procedures laid out in the Administrative Memorandum on Motions to Disqualify.
Emergency Motions must be uploaded via CourtMAP once filed and MUST contain a statement indicating that opposing counsel has been notified in an attempt to resolve the matter in an amicable manner.
The Title of the Proposed Order should include the full name of the Motion at issue. If the order is an Agreed Order, please utilize the "Agreed Order" option when submitting via courtMAP.
Orders must contain all information required (i.e., no blanks shall be left). Incomplete orders will be rejected, and you will be asked to resubmit the proposed order with the complete information.
PLEASE NOTE: AS OF NOVEMBER 15, 2022, ANY PROPOSED ORDER THAT DOES NOT COMPLY WITH THE REQUIREMENTS OF ADMINISTRATIVE ORDER 22-02 WILL BE REJECTED
Ex-parte motions to compel must comply with AO 06-09 (7-day wait) and state the date discovery was served and the date the motion was filed.
Court's wording
Ex-parte motions to compel (including both discovery and attorney fee order compliance) MUST COMPLY WITH Administrative Order 06-09, including the requirement of waiting 7 days, and MUST reflect the date discovery was served (date or docket #), and when the motion to compel was filed (date or docket #).
DO NOT SUBMIT ORDERS OF GOOD CAUSE, THE COURT WILL GENERATE THEM UPON REVIEW OF THE DOCKET AND AN AFFIDAVIT OF GOOD CAUSE TIMELY FILED.
All proposed orders submitted by counsel must include the docket index number (or e-filing number and date filed) and the full name of the motion.
- Document
- Proposed order
Must include
- •Case number
Court's wording
PLEASE NOTE: Administrative Order 22-02 (linked on this page) requires ALL proposed orders submitted by counsel include the following: Docket Index Number: _______________________ Or E-filing Number _______________ Date Filed: ______________________ Full Name of Motion: ___________________________________________
Underlying documents must be attached as Supporting Documents with proposed orders or the order may be rejected.
Court's wording
Please submit the relevant underlying document(s) as "Supporting Documents" with the Proposed Order (for example, settlement agreement, stipulation for substitution of counsel, etc.). Because of docketing delays, failure to do so may result in your proposed order being rejected and you will be asked to resubmit the the relevant documents attached.
Orders must contain all information required (i.e., no blanks shall be left). Incomplete orders will be rejected and you will be asked to resubmit the proposed order with the complete information.
Parties must prepare and file their own Notice of Hearing with Zoom instructions or courtroom address.
Court's wording
Once approved, you will receive a Notice of Hearing directly from the Court. If you did not receive the Notice of Hearing, please communicate with the Clerk of Court's office and confirm you are on the service list. You still need to prepare your own NOH with proper Zoom instructions OR proper address and courtroom and file it with the Clerk. If your notice is rejected, an explanation will be given in the Comment section.
Agreed amended CMOs must use the required form order and space amended deadlines like the original CMO.
Court's wording
Agreed Amended Case Management Order MUST use the form order linked below. Any other format will be rejected. Additionally, the amended deadlines must be spaced out just as the original CMO's deadlines (e.g., hearings on MSJs must be heard at least 30 days prior to the trial readiness date).
The setting party is responsible for filing the Notice of Hearing on the docket and should include the Court's universal Zoom link; the Court will not issue a Notice for Motion Calendars and no Zoom link will be sent out.
1. Your motion must contain a certification that the matter is a true Emergency and cannot wait to be heard during a motion calendar.
Motions for Extensions of Time must include a timeframe for the requested extension.
Please submit the relevant underlying document(s) as "Supporting Documents" with the Agreed Order (for example, settlement agreement, stipulation for substitution of counsel, etc.).
The Court will not include sanctions on ex-parte motions to compel (expenses, attorney's fees, or waiver of non-privilege objections) - those require a hearing.
Filing & Service rules
Electronic Filing Rules
For insurance cases, do not submit motions or proposed orders on pretrial conference waivers; they will be rejected.
For Insurance Cases ONLY: Administrative Order 21-10 invoked the Florida Rules of Civil Procedure and waived pretrial conferences for ALL insurance cases. DO NOT submit motions/proposed orders on these issues; they will be rejected.
Page 1 | Division Procedures
Documents accompanying proposed orders must be e-filed through the Florida Courts E-Filing Portal, not by the Clerk.
PLEASE NOTE: When sending documents with proposed orders DO NOT get e-filed by the Clerk. You must use the Florida Courts E-Filing Portal.
Page 1 | Additional Instructions (Agreed Orders via CourtMAP)
Small claims pre-trial conference waivers must be submitted as Agreed Orders through CourtMAP.
Small Claims Pre-Trial Conference Waivers are to be submitted as Agreed Orders via CourtMAP.
Page 1 | Division Procedures
Do not submit proposed orders to chambers by mail or email unless the Court instructs otherwise.
Unless instructed by the Court to do so, please do not submit proposed orders via mail or e-mail to Chambers.
Page 1 | Additional Instructions (Agreed Orders via CourtMAP)
Proposed orders must be submitted through CourtMAP.
Proposed Orders are to be submitted through CourtMAP.
Page 1 | Proposed Orders (A.O. 22-02)
Special set cancellations must be made on CourtMAP with a filed Notice of Cancellation, with a courtesy call to the JA especially within 24 hours.
CANCELATIONS: The setting party must cancel the hearing on CourtMAP and Notices of Cancellation must be filed, even if you have filed a proposed order that includes the cancelation of the hearing. Chambers do not need a courtesy copy of the NOC, but a courtesy call to the Judicial Assistant will be appreciated, particularly if the Special Set hearing is being canceled less than 24 hours before the hearing date.
Page 1 | Special Set Hearings
Special set dates must be selected through CourtMAP with the motion attached; doubling time slots is not allowed.
Select your date through CourtMAP (review each date separately until you find the amount of time you wish to set for. Doubling on time slots is not allowed. Your date selection on CourtMAP will generate a Special Set Request email to Chambers. Chambers will review your submission and approve or reject. Attach the motion to be considered for the Special Set Hearing as a supporting document when selecting the hearing date. Your Special Set Hearing request may be rejected if the motion is not attached.
Page 1 | Special Set Hearings
Documents accompanying proposed orders must be e-filed via the Florida Courts E-Filing Portal, not by the Clerk.
PLEASE NOTE: sending documents with proposed orders DO NOT get efiled by the Clerk. You must use the Florida Courts E-Filing Portal.
Page 1 | Proposed Orders (A.O. 22-02)
Agreed orders must be submitted through CourtMAP.
Please submit Agreed Orders through CourtMAP.
Page 1 | Additional Instructions (Agreed Orders via CourtMAP)
Cancellations must be requested through CourtMAP with supporting documents and a valid reason; approval is not guaranteed.
CANCELLATIONS: Must be requested through CourtMap. Please attach any closing documents or Notice of Settlement. If attaching a Notice of Cancellation, you must state a valid reason. This does not guarantee approval of cancellation by the Judge.
Page 1 | Emergency Motion Procedures
Emergency motions must be uploaded via CourtMAP after filing and must state that opposing counsel was notified.
Emergency Motions must be uploaded via CourtMAP once filed and MUST contain a statement indicating that opposing counsel has been notified in an attempt to resolve the matter in an amicable manner.
Page 1 | Emergency Motion Procedures
Parties must submit all materials via CourtMAP so that the Court may review the materials beforehand.
Parties must submit all materials via CourtMAP so that the Court may review the materials beforehand.
Page 1 | Motion Calendar Information
Do not email or fax any documents to chambers.
Please do NOT email or fax any documents to chambers.
Page 1 | Emergency Motion Procedures
Hearings must be scheduled through CourtMAP with the motion attached as a supporting document.
Schedule your hearing through CourtMAP and attach a copy of the Motion as a supporting document.
Page 1 | Motion Calendar Information
The setting party must cancel hearings on CourtMAP and file a Notice of Cancellation.
CANCELATIONS: Setting party must cancel the hearing on courtMAP and Notices of Cancellation must be filed, even if you have filed a proposed order canceling the hearing.
Page 1 | Motion Calendar Information
Self-represented litigants should register at the Florida Courts eFiling Portal, CourtMAP, MyFloridaCourtAccess, and Florida Bar consumer links.
Self-represented Litigants should register at the following links: https://www.jud11.flcourts.org/Florida-Courts-eFiling-Portal https://cmap.jud11.flcourts.org/ https://www.myflcourtaccess.com/ https://www.floridabar.org/public/consumer/
Page 1 | Pro-se/Self-Represented Litigants
Filing Timing and Cure Windows
The motion attached to a proposed order must be filed with the Clerk before uploading or the order will be rejected.
The Motion attached to the Proposed Order must be filed with Clerk prior to uploading any proposed orders. Failure to do so will result in the proposed order being rejected and require you to resubmit the proposed order.
Page 1 | Proposed Orders (A.O. 22-02)
Parties must be prepared to appear within one hour of submitting an emergency motion.
2. You must be prepared to appear before the Court within one (1) hour of submission of the Emergency Motion to the Court.
Page 1 | Emergency Motion Procedures
In FWOP cases, the Affidavit of Good Cause must be filed 5 days before the hearing or the case will be dismissed.
If your case is set for FWOP you need to file your Affidavit of Good Cause 5 DAYS PRIOR TO THE HEARING. If you fail to file the Affidavit, an Order will be entered Dismissing the Case.
Page 1 | FWOP
All motions in limine must be heard before trial begins, generally on the Thursday and Friday prior to trial.
ALL Motions in Limine MUST be heard prior to the Commencement of the trial on your case. Please note, that the Judge generally reserves the Thursday and Friday prior to trial for these motions.
Page 1 | Jury Trial Procedures
All motions must be filed with the Clerk's office before setting a hearing date.
All Motions must be filed with the Clerks' office prior to setting a hearing date.
Page 1 | Special Set Hearings
Motion calendar hearings require notice 5 calendar days before the hearing.
Notice Before Hearing: 5 Calendar Days
Page 1 | Motion Calendar Information
The motion attached to an agreed order must be filed with the Clerk before the proposed order is uploaded or the order will be rejected.
The Motion attached to the Agreed Order must be filed with the Clerk prior to uploading any proposed orders. Failure to do so will result in the proposed order being rejected and require you to resubmit the proposed order.
Page 1 | Additional Instructions (Agreed Orders via CourtMAP)
Hard-copy materials must be mailed to the South Dade Justice Center at least 5 business days before the hearing or they may be stricken.
Please send the materials via USPS, FEDEX, or UPS to the South Dade Justice Center, 10710 S.W. 211 ST, Miami, FL 33189, Attention: Judge Gonzalez-Paulson. Any materials filed or otherwise submitted to the Court less than 5 business days prior to the hearing may be considered untimely and stricken. YOUR HEARING MAY BE CANCELED AND RESET BY THE JUDGE IF YOU DO NOT COMPLY WITH THESE PROCEDURES.
Page 1 | Special Set Hearings
Motion for Default or Default Final Judgments shall be filed 2 days prior to the hearing and Proposed Orders Need to be Submitted. Failure to timely file will result in the Dismissal of the case for Lack of Prosecution.
Motion for Default or Default Final Judgments shall be filed 2 days prior to the hearing and Proposed Orders Need to be Submitted. Failure to timely file will result in the Dismissal of the case for Lack of Prosecution.
Page 1 | FWOP
All motions must be filed with the Clerk before a hearing is set.
All Motions MUST be filed with the Clerk prior to setting a hearing.
Page 1 | Motion Calendar Information
Responsive pleadings must be filed at least 5 business days before the hearing.
ANY RESPONSIVE PLEADING MUST BE FILED AT LEAST 5 BUSINESS DAYS PRIOR TO THE HEARING.
Page 1 | Special Set Hearings
Special set hearings must be scheduled at least 7 days in advance unless prior approval is received.
Special Sets must be set at least seven (7) days prior to the requested hearing date unless you have received prior approval.
Page 1 | Special Set Hearings
Summary judgment motions must be heard no later than 30 days from the trial date.
Motions in Summary Judgment need to be heard no later than 30 days from trial date.
Page 1 | Division Procedures
Summary judgment motions must be filed and heard by CMO/Trial Order deadlines, before calendar call, and never during the trial period.
Motions for Summary Judgment MUST be filed and heard by the dates established in the Case Management Order of your case, or, if your case does not have a Case Management Order, the timeframe established in the Trial Order. In all cases, Motions for Summary Judgment MUST be set for hearing prior to Calendar Call. NO MOTIONS FOR SUMMARY JUDGMENT WILL BE HEARD DURING THE TRIAL PERIOD.
Page 1 | Jury Trial Procedures
After 3 documented attempts over at least 72 hours, the moving party may unilaterally set the hearing 14 to 45 days after the third attempt.
IMPORTANT: In the event parties are unable to coordinate any non-dispositive and non-evidentiary hearing, deposition, or motion within a reasonable period of time (not less than 72 hours) and after 3 documented attempts, the moving party shall unilaterally set the issue for hearing pursuant to divisional instructions to occur no less than 14 days and no more than 45 days after the third attempt.
Page 1 | Motion Calendar Information
Service and Proof of Service Rules
All parties must be included on the service list for proposed orders.
Please ensure that ALL parties have been included on the service list.
Page 1 | Proposed Orders (A.O. 22-02)
Written notice of the hearing and a copy of the motion must be provided to opposing counsel/parties immediately after the hearing is set.
Written Notice to opposing counsel/parties shall be provided immediately after a hearing is set by a party, along with a copy of the motion.
Page 1 | Motion Calendar Information
Landlord/tenant proposed orders must include all parties on the service list.
For any Landlord/Tenant Proposed Orders, please ensure that ALL parties are included in the service list.
Page 1 | Pro-se/Self-Represented Litigants
Courtesy Copy Requirements
A courtesy copy of any response or other relevant pleading filed less than 48 hours before the hearing should be emailed to the Court's JA. Include the case number and hearing date/time in the subject of the email.
A courtesy copy of any response or other relevant pleading filed less than 48 hours before the hearing should be emailed to the Court's JA. Include the case number and hearing date/time in the subject of the email.
Page 1 | Motion Calendar Information
Once you e-file your Motion for Attorney's Fees, a courtesy copy shall be submitted to the Judicial Assistant via email at jsolorzanoruiz@jud11.flcourts.org, and upon receipt of the motion, the Court will issue a Preliminary Order on Motion to Tax Costs and Award Attorney's Fees.
Once you e-file your Motion for Attorney's Fees, a courtesy copy shall be submitted to the Judicial Assistant via email at jsolorzanoruiz@jud11.flcourts.org, and upon receipt of the motion, the Court will issue a Preliminary Order on Motion to Tax Costs and Award Attorney's Fees.
Page 1 | Fee Hearings
Party submissions over 40 combined pages must be submitted in hard copy to chambers at least 5 business days before the hearing.
Party submissions that total more than 40 pages combined (this includes the Motion to be heard, legal memoranda, key legal authorities (no more than five cases), discovery, or other materials in support of or in opposition to the Motion) MUST be submitted in hard copy to Judge Gonzalez-Paulson's Chambers at least 5 business days (excluding holidays and weekends) before the scheduled hearing.
Page 1 | Fee Hearings
No courtesy copy of the Notice of Cancellation is needed; a courtesy call to the JA is appreciated.
Chambers does not need a courtesy copy of the NOC, but a courtesy call to the Judicial Assistant will be appreciated.
Page 1 | Motion Calendar Information
Filing Bundling Requirements
No more than 2 motions should be set for one Special Set hearing unless you have received prior approval from the Court by coordinating with her JA.
No more than 2 motions should be set for one Special Set hearing unless you have received prior approval from the Court by coordinating with her JA.
Page 1 | Special Set Hearings
Do not book two 30-minute slots for the same case or the CourtMAP request will be rejected.
Please DO NOT use two (2) 30-minute slots for the same case, otherwise your hearing request on CourtMAP will be rejected.
Page 1 | Special Set Hearings
Only one motion may be scheduled per motion calendar slot or the hearing may be canceled.
Only schedule ONE MOTION per Motion Calendar slot. The Court may cancel your hearing otherwise.
Page 1 | Motion Calendar Information
Do not book two 15-minute slots for one 30-minute hearing or the request will be rejected.
Please DO NOT use two (2) 15-minute slots for the same case if you need 30 minutes, otherwise, your hearing request will be rejected.
Page 1 | Special Set Hearings
Pre-Motion Conference Requirements
Landlord/tenant, attorney's fees, sanctions, claim of exemptions, motions to dismiss, judgment on the pleadings, and most summary judgment motions cannot be set on the motion calendar.
The following motions are NOT for Motion Calendar: Landlord/Tenant matters, Attorneys' Fees matters, Sanctions Motions, Claim of Exemptions hearings, Motions to Dismiss, Motions for Judgment on the Pleadings, and Motions for Summary Judgement (with the exception of SP Contract and Indebtedness) . *Please do not set these on the Motion Calendar; they will be canceled and you will be asked to reset.
Page 1 | Motion Calendar Information
Adjournment & Extension Requirements
Motions to continue trial or hearings must be set on calendar, and party continuance agreements require Judge approval.
All Motions to Continue Trial, Strike Trial dates, or Continue a Hearing set by the Judge must be set on Calendar. Any agreement between the parties for a continuance must be approved by the Judge.
Page 1 | Special Set Hearings
Motions for Continuance of a trial should also be filed and heard before the Calendar Call, and should be set on the Judge's Motion Calendar. No agreed order to continue a trial will be accepted unless the parties have had a hearing before the Judge and the Judge has approved the continuance.
Motions for Continuance of a trial should also be filed and heard before the Calendar Call, and should be set on the Judge's Motion Calendar. No agreed order to continue a trial will be accepted unless the parties have had a hearing before the Judge and the Judge has approved the continuance.
Page 1 | Jury Trial Procedures
Chambers Communication Rules
Landlord/tenant hearing requests must be emailed to the Judicial Assistant.
For these Landlord/Tenant matters, please email the Judicial Assistant with your request for a hearing.
Page 1 | Motion Calendar Information
Cross-notices of hearings already set must be sent to the Judicial Assistant so the calendar is updated, or the matter may not be heard.
If you seek to cross-notice a hearing already set and/or approved by the Judge, send a copy of the cross-notice to the Court's Judicial Assistant to ensure the calendar is properly updated. Otherwise, the matter may not be heard.
Page 1 | Division Procedures
To set a jury trial, file a timely Notice for Trial and email a copy to the JA/Bailiff; do not send hard copies.
1) File a Notice for Trial that is timely and is in accordance with the applicable statutes/rules of procedure; and 2) E-mail a copy of the filed Notice for Trial to the Court's Judicial Assistant and/or Bailiff. PLEASE DO NOT SEND HARD COPIES TO THE COURT.
Page 1 | Jury Trial Procedures
Emails to the judicial assistant must copy all parties, and the Judge must never be emailed directly about a case.
If you need to email the Judge's judicial assistant (e.g., to request or cancel a hearing, confirm the filing of a motion, etc.), you must copy all parties in the case. Otherwise, these may be considered impermissible ex-parte communications, which will not be read and will be deleted. DO NOT email Judge Gonzalez-Paulson directly about your case; the email will be deleted without reading it.
Page 1 | Division Procedures
All in-person special set hearings must be scheduled with the Judicial Assistant.
ALL IN PERSON SPECIAL SETS NEED TO BE SCHEDULED WITH THE JA.
Page 1 | Pro-se/Self-Represented Litigants
Landlord/tenant hearings must be coordinated with the Judicial Assistant.
Landlord/Tenant hearings must be coordinated with the Court's judicial assistant.
Page 1 | Special Set Hearings
Fee hearings may only be scheduled through the Judicial Assistant via email.
Once the parties have complied with said Order, they must contact the Judicial Assistant via e-mail to schedule a Fee Hearing. IMPORTANT: ONLY THE JA CAN SCHEDULE A HEARING ON ATTORNEY'S FEES.
Page 1 | Fee Hearings
Special sets longer than 30 minutes must be scheduled by email to the judicial assistant or bailiff.
Special Sets longer than 30 minutes, such as Attorney's Fees Hearings, Non-Jury Trials, Summary Judgment motions, and Evidentiary Hearings (including Claim of Exemption hearings) need to be set with the judicial assistant or bailiff. Please send an email with your hearing request to jsolorzanoruiz@jud11.flcourts.org.
Page 1 | Special Set Hearings
Contact chambers after dropping off hard-copy materials to confirm receipt.
Please make sure you contact the Judge's Chambers when your materials have been dropped off to confirm that they were received by the Judge.
Page 1 | Special Set Hearings
Cross-noticed motion calendar hearings require a copy of the cross notice to the JA or a separate slot at the same time.
If you wish to cross-notice a motion calendar hearing, send a copy of the cross notice to the Judge's judicial assistant to ensure that the courtMAP calendar is properly updated or set the notice for the same time in a separate motion calendar slot.
Page 1 | Motion Calendar Information
Parties needing an interpreter must call chambers as soon as possible before the hearing.
If you need an interpreter, you must call the Judge's chambers as soon as possible in advance of the hearing.
Page 1 | Division Procedures
Non-jury trials are set by scheduling with the Judicial Assistant.
Note: Non-jury trials may be set by scheduling them with the JA.
Page 1 | Jury Trial Procedures
For summary judgment and motions to dismiss, contact the JA to obtain a hearing date when time is of the essence.
For Motions in Summary Judgment and Motions to Dismiss, contact the JA where time is of the essence to attain a date.
Page 1 | Division Procedures
The Parties shall coordinate the date and time of the hearings to ensure that all sides are available on the selected date. Should you need additional dates and times, please contact the Judge's Judicial Assistant.
The Parties shall coordinate the date and time of the hearings to ensure that all sides are available on the selected date. Should you need additional dates and times, please contact the Judge's Judicial Assistant.
Page 1 | Special Set Hearings
Email the JA to obtain a summary judgment special set date before calendar call.
If you are in need of a MSJ special set date prior to calendar call, email Jasmine, the J.A. to obtain dates at jsolorzanoruiz@jud11.flcourts.org
Page 1 | Special Set Hearings