Twentieth Judicial Circuit of Florida, Charlotte, Collier, Glades, Hendry and Lee Counties Pre-Motion Conference Requirements

CRITICALCivil cases

The discovery conference must be a substantive in-person or telephone conversation conducted in good faith to resolve the dispute without court action; merely attempting to confer or exchanging self-serving emails or faxes is insufficient.

The conference by and between counsel shall be conducted in person or by telephone. Counsel that merely "attempt" to confer have not "conferred." The word "confer" requires a substantive conversation in person or by telephone in a good faith effort to resolve the matter without court action and does not envision an exchange of self-serving letters or ultimatums submitted via e-mail or facsimile.

CRITICAL

All motions must comply with Florida Rule of Civil Procedure 1.202’s conferral requirement before filing.

PLEASE MAKE SURE ALL MOTIONS FILED COMPLY WITH FLORIDA RULE OF CIVIL PROCEDURE 1.202 – “CONFERRAL PRIOR TO FILING MOTIONS”.

CRITICAL

A civil motion to compel may be submitted without a hearing only if the moving party follows the procedures stated in the order.

A Motion to Compel discovery in a civil action may be submitted to the Court without a hearing if the moving party has complied with the following procedures:

CRITICALCivil cases

The moving party must confer in good faith with the opposing party to try to resolve the motion's issues, in person, by phone, or by video conference.

The moving party must confer with the opposing party in a good faith effort to resolve the issues raised in the motion. Such conferral must be between the attorneys in-person, by phone or by video-conference.

CRITICAL

Motions to withdraw in civil cases must be scheduled before Judge Brodie in a five-minute JACS calendar slot.

All Motions to Withdraw in Civil cases must be set before Judge Brodie in a 5 minute time slot on her JACS calendar.

CRITICAL

Before filing a nondispositive motion or a motion listed under Rule 1.202(c), the movant must confer in good faith with opposing counsel, but the requirement does not apply to litigants without lawyers.

Before filing a non-dispositive motion or a motion listed under Rule 1.202(c), the moving party must confer with opposing counsel in a good-faith effort to resolve issues to be raised in the motion. Rule 1.202 does not apply to litigants without lawyers.