AG Divisional Instructions

Judicial Practices and Procedures

Last updated 5/28/2026

Contact Information

Caryn Siperstein, Judge
Violet Woxberg, Judicial Assistant

Zoom Information

The Court uses Zoom remote platform for remote appearances. See Remote Appearance subsection for details.

Meeting Link: Join Zoom Meeting
Meeting ID: 85056337361
Passcode: No passcode required.

Dial by your location:
US Toll-free 877-853-5257 or 888-475-4499

*Parties must comply with important division instructions as non-compliance may result in resetting your hearing.

• A proposed form of order must be uploaded by each party prior to any and all hearings by OLS, no sooner than five (5) days in advance. For all hearings, exhibits must be attached to the proposed order including but not limited to the Notice of Hearing, Motion and Response, operative complaint for Motions to Dismiss, the Note/Mortgage for Foreclosures, contracts, agreements and bills. A copy of all proposed orders must be emailed to the opposing party for objection. Please upload an agreed proposed order on Status and Case Management Conferences (see forms). All proposed orders must state (i) the status of the case (ii) calendar call date (iii) the motion was timely filed and set, (iv) conferral of the parties prior to filing the motion by telephone and email. (v) factual basis (vi) legal authority with citations (vii) the parties desired outcome,  
• Please provide when uploading orders on OLS a properly titled order, mark Y if the order is agreed and N if it is opposed with an event date, provide Docket Entry numbers (DE#__), not filing numbers, when referencing another filed case document and indicate any related cases.
• To special set hearings the parties must upload an Agreed Status Order with Request to Special Set indicating the DCMO DE# and date filed, calendar call date, the Division instruction deadline to file, set and hear all motions is 30 days prior to calendar call (see Division Documents for sample) and availability for the next 60 days on Mondays. The parties cannot special set the same on OLS. Please be cognizant of the Summary Judgment time to hear is 50 days from the date of filing.
• The parties must move to set all motions within 5 days of filing and timely heard within 60 days, but no later than 30 days prior to calendar call, or the same may be deemed abandoned. Parties may set only one hearing at a time and may set an additional hearing after the Court rules on the last motion heard. All hearings will include a Case Management Conference and the Court may hear any outstanding motions at a Case Management Conference.
• Mediation must be set and completed no later than 30 days prior to calendar call.
• All motions require a filed Response within 5 days of the motion being filed unless otherwise indicated in the FL.R.C.P. or the motion may be deemed unopposed.
• The following motions will be heard on the papers unless hearing time is requested by the Court: Motions to Dismiss Without Prejudice, Motions for Extension of Time to Respond to Discovery, Motions Extending DCMO Deadlines/Continuances, and Discovery Motions. All parties must confer by telephone & email and indicate the same in the proposed competing orders, which will be uploaded with the motion and written response.
• The Court may also enter orders Sua Sponte on review of a case file.
• All dispositive motions must be set for hearing unless agreed to by the parties. If the same is by default, notice must be sent by Certified Mail Return Request Receipt. Summary Judgment motions set must confirm all discovery required for the same is completed.
• Please do not email or upload case law or proposed notices of hearings to be signed by the Judge as you are required to file the same in the case file.
• Division AG does not utilize e-courtesy.
• Trials cannot be continued by an Agreed Order. The proposed order must state with specificity good cause with factual and legal basis.

• Compliance with Local Rule 4 is mandatory and this Court requires conferral with self-represented parties.

  Foreclosure Summary Judgments and Final Judgments are to be set with the Senior Judge.

Table of Contents

A. Communications with the Judicial Office

1. Method of Communication:

• Motions:
  If you are making a request to the Court, you must file a motion, which shall be provided to all parties and upload the same as an exhibit with a proposed form order by OLS to the division queue. Trainings on the Court's online system can be found on the CourtHelp4U YouTube channel. The direct link on how to schedule and how to upload orders is Online Scheduling Home Page (youtube.com).
• Division or Judicial E-mails:
  Email communications with the Judicial office are limited to scheduling matters. The subject line of any e-mail to the judicial office must contain the case number, case name, and relevant matter (e.g., 2026 CA 001234 – Doe v. Doe –Hearing Requested Cancelled). You must copy all parties on communications with the Court; no ex-parte communications will be considered. Please do not provide proposed orders, exhibits, or filings to the Court by email.
• Telephone:
  Self-represented litigants and attorneys excused from e-mail service may communicate with the judicial office by telephone call to 561-355-3845. The judicial office does not accept text messages.

2. Ex parte Communications:

All communications with the judicial office must comply with Canon 3 of the Code of Judicial Conduct, which prohibits a judge from initiating, permitting, or considering ex parte communications and from considering other communications outside the presence of the parties concerning a pending or impending proceeding, unless authorized by law. All parties must be copied on any e-mail directed to the judicial office, unless an ex parte communication is authorized by law. Parties may only contact the judicial office in accordance with these practices and procedures.

3. Unsolicited Communications:

Parties may only contact the judicial office in accordance with these practices and procedures. Unsolicited communications from non-parties will not be considered by the court.

4. E-Filing Portal Contact Information:

• All attorneys and self-represented litigants must make and receive service by e-mail, which is generally through the Florida Courts E-Filing Portal, unless excused. Florida Rules of General Practice and Judicial Administration. 2.516.
• All attorneys and self-represented litigants must provide an e-mail address to receive signed orders electronically, unless excused. Fla. R. Gen. Prac. & Jud. Admin. 2.516. It is the responsibility of attorneys and self-represented litigants to update their contact information using Form 2.603, email designation form, any time there is a change in the e-mail account registered for electronic service.

5. Response to Inquiries:

• The judicial assistant strives to substantively respond to all inquiries within one business day. If the judicial assistant is unable to substantively respond within one business day, your message will be acknowledged as received with an indication of when to expect a substantive response and alternate contact for immediate assistance.
• When the judicial assistant is out of the office, your message will be acknowledged as received with an indication of when to expect a substantive response and an alternate contact for immediate assistance.
• Neither the Judge nor the Judicial Assistant can give legal advice regarding how to proceed with the case. For assistance, you can contact the Self-Help Center at 561-355-6781 located on the first floor of the Main West Palm Beach Courthouse or visit the self-service center in the Clerk's Office in the Satellite Courthouses. You may also go to MyPalmBeachClerk.com to seek information. Additionally, the Palm Beach County Bar Association has a lawyer referral and information service at 561-687-3266 and you can visit www.palmbeachbar.org. If you are unrepresented for financial reasons, you may contact the Legal Aid Society of Palm Beach County (561) 655-8944, toll-free: (800) 403-9353 or legalaidpbc.org.

6. Other Communication Procedures:

Compliance with Local Rule 4 is mandatory and this Court requires conferral with self-represented parties.

Any e-mail sent to or from the judicial office may be a public record subject to disclosure.

7. Self-represented Litigants:

Please file an email designation. It is important for litigants not represented by counsel to fill out and file with the Clerk an email designation form (PDF). This will allow the Court to submit orders to the parties via email instead of sending by the U.S. Postal Service, which will greatly reduce the time for communication from the Court. Clerk Self Service visit: self-service center of the Clerk online.

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B. Scheduling Procedures- must be in compliance with the DCMO and division instructions

The parties must move to set all motions within 5 days of filing and timely heard within 60 days or the same may be deemed abandoned. All motions require a filed Response within 5 days of the motion being filed unless otherwise indicated in the FL.R.C.P. or the motion may be deemed unopposed. All motions must be set and heard no later than 30 days prior to calendar call. The parties may set only one hearing at a time and may set an additional hearing after the Court rules on the last motion heard.

In first party property damage cases the following protocol is expected. PLAINTIFF's DEPOSITION shall be taken within 45 days after Defendant's answer has been filed. Defendant's FIELD ADJUSTER DEPOSITION shall be taken within 45 days after Plaintiff's deposition. Defendant's CORPORATE REPRESENTATIVE DEPOSITION shall be taken within 30 days after the Field Adjuster's deposition.

1. Court Schedule:

1. Trials

   Tuesday through Friday unless the matter is scheduled with senior judge, which begin on a Monday or special set. Mediation must be set and completed no later than 30 days prior to calendar call. For Trials, the parties must utilize a stenographers for purposes of transcribing/transcription.

2. Uniform Motion Calendar

   Motion calendar hearings are held Via "Zoom" Monday through Thursday at 8:45 and are set through the online schedule system. Please do not contact the JA as scheduling is between the parties. All UMC hearings are limited to 10 minutes (5 mins. per side). Only one motion/hearing per case may be scheduled per hearing day. The parties may set one motion until the Court rules on the same. Parties may not substitute another motion in place of one previously noticed. Every hearing is a Case Management Conference and the Court may hear any outstanding motions at that time. Parties must upload five days prior to all hearings competing proposed orders with factual basis, legal authority, date of calendar call, date of conferral by telephone and outstanding discovery. The Court may rule on the papers on any non-dispositive motion. Uncontested Summary Judgment hearings may be scheduled on the Court's UMC docket, but foreclosure SJMs are to be set before the Senior Judge if uncontested or involving a self-represented parties (all original documents must be filed). The Court will not entertain boilerplate (non-case specific) Motions in Liminie. All parties at any hearing must be prepared to address case management issues, argue all non-evidentiary motions if time permits, and have authority to make binding representations on motions, issues and scheduling. To set go to:

   Online Services

3. Special Set

   All special set hearings for 15-30 minutes are set on Mondays by agreed proposed Status Order with request to Special Set providing the parties availabilities on Mondays for the next 60 days. The proposed status order must include the status of the case, including discovery, mediation, compliance with the DCMO and division instructions, and all outstanding motions. If the request is for a Summary Judgment Motion, the parties must state when the SJM was filed, time to answer and the earliest time the SJM can be heard pursuant to the FL.R.C.P. The parties must attach as an exhibit the motions to be set with the proposed order. Please do not call or email the JA as to the same. (See division forms). The parties cannot set the same unilaterally or online. Once the parties receive a Court order setting, the parties must upload five days prior to all hearings competing proposed orders with factual basis, legal authority, date of calendar call, date of conferral by telephone and outstanding discovery. The Court may rule on the papers on any non-dispositive motion.

4. On the Papers

   The following motions will be heard on the papers unless hearing time is requested by the Court: Motions to Dismiss Without Prejudice, Motions for Extension of Time to Respond to Discovery, Motions Extending DCMO Deadlines/Continuances, and Discovery Motions. All parties must confer by telephone & email and indicate the same in the proposed competing orders, which will be uploaded with the motion and written response. The Court may also enter orders Sua Sponte on review of a case file. All dispositive motions must be set for hearing unless agreed to by the parties including default final Judgements. 

2. Scheduling Hearings:

• Please do not request hearing time from the JA as all available hearing times are posted on the Online Services for UMC and Special sets require a proposed order as indicated herein. To request a special set time the parties must upload a proposed Agreed Status Order with request to special set with the DCMO attached (see sample under division documents). New hearing time for the next unposted month will be opened at the end of each month for UMC only. Please ensure the motion is filed with the Clerk of Court before a hearing is scheduled and the parties conferred. All notice of hearings must clearly state the title of Motion being heard by the Court, must be served on all parties and filed in the case docket; the Court does not sign the same. Parties may not change their hearings to another matter to be heard. All hearings require the parties to provide competing orders with factual basis and legal authority uploaded by OLS, no sooner than 5 days before the hearing and attach the motion/response.
• Parties may schedule a Differentiated Case Management Conference (DCMC) pursuant to AO 3.110 (PDF), which must be set through OLS on the: 1) Differentiated Case Management Conference docket; or 2) Uniform Motion Calendar.
• All hearings expected to exceed 15 minutes must be requested by motion to be special set
• The first question the Court will ask of the parties before commencing the hearing will be about compliance with the DCMO and division instructions Failure to comply may result in the cancellation of the hearing.
• Please do not set any motions on UMC after the calendar call date.
• Specially set hearings cannot be cancelled or continued by Agreed Order or Notice of Cancellation. The only ways for a Special Set hearing to be cancelled are: 1) Case has settled; or the motion is now moot or withdrawn with a proposed order indicating the same uploaded by OLS or 2) After hearing and granted by the Court to the cancellation of a Special Set hearing. Once a hearing is scheduled on-line, the JA cannot cancel it, move it, add to it. If any changes need to be made to a scheduled hearing, a MOTION MUST BE FILED with a proposed order uploaded by OLS after conferral by all parties.
• No post-hearing submittals will be accepted unless requested by the Court.
• For evidentiary hearings, parties must coordinate the pre-hearing exchange of witness lists, exhibit lists, evidence and, if necessary, the taking of depositions. If you wish to call witnesses to testify at a hearing, you must file a witness list containing the name and address of every witness. If you intend to call expert witnesses, you must include the name of the expert witness, the address of the expert witness and nature of the expert testimony. Absent agreement of the parties or good cause, the parties shall exchange witness and expert witness lists at least ten (10) days prior to the hearing. If you wish to introduce evidence at a hearing, absent agreement of the parties or good cause, the exhibit list and all exhibits must be exchanged with opposing counsel at least five (5) days prior to the hearing. Confidential information (such as Bank Account Numbers, Social Security Numbers, Health Information, etc.) must be removed from documents provided to the Court as required by Fla. R. Jud. Admin., Rule 2.420(d). Counsel must provide to the Clerk of Court a set of all exhibits, in hard copy, pre-marked in accordance with the instructions of the Clerk and Comptroller (mypalmbeachclerk.com) and uploaded to the E-Evidence portal. All demonstrative aids, including PowerPoint presentations and blow-up charts, must be disclosed to all opposing counsel and self-represented parties prior to a hearing. In fairness to all parties and to prevent Due Process concerns, absent agreement of the parties or good cause, any evidentiary materials not provided to all other parties and the Court in accordance with these instructions will not be considered by the Court. Of course, all parties shall make best efforts to provide evidentiary materials well in advance of these deadlines. The Court may consider adjourning the hearing and/or sanctioning any parties who do not give adequate prior notice to opposing parties and the Court.

3. Notice of Hearing:

• A notice of hearing must be filed and served immediately after reserving hearing time.
• A notice of hearing involving any remote appearance must list the Division Zoom link.
• All notices of hearing must contain the Americans with Disabilities Act (ADA) notification required by Florida Rule of General Practice and Judicial Administration 2.540 and the language that counsel has complied with Local Rule 4.
• Please do not email or upload proposed notices of hearings to be signed by the Judge as you are required to file the same in the case file.

• A copy of the Notice of Hearing, along with a courtesy copy of the Motion being scheduled (and, if a Motion to Dismiss, a copy of the operative Complaint) shall be uploaded by OLS as attachments to a proposed order five days prior to the hearing date. A notice must state as follows:

  The parties conferred prior to setting the hearing.

  The JA cannot cancel this hearing unless compliance with one of the outlined exceptions;

  No add-ons or substitutions are permitted;

  Any Memorandums submitted are limited to 10 double-spaced pages;

  Any materials submitted are due at least 5 days prior to the hearing attached to a proposed order by OLS;

  All parties must provide a proposed form of order, no sooner than 5 days before the hearing by OLS with exhibits as attachments and provide a copy to their adversary in compliance with the Division Instructions, which all parties have reviewed.

4. Submission Deadlines:

• The Court must receive all materials for the hearing no sooner than five (5) business days before the hearing.

5. Order of Proceedings:

• The following motions will be heard on the papers unless hearing time is requested by the Court: Motions to Dismiss Without Prejudice, Motions for Extension of Time to Respond to Discovery, Motions Extending DCMO Deadlines, and Discovery Motions. All parties must confer by telephone & email and indicate the same in the proposed competing orders, which will be uploaded with the motion and written response.
• The Court may also enter orders Sua Sponte on review of a case file.
• All dispositive motions must be set for hearing unless agreed to by the parties. If the same is by default, notice must be sent by Certified Mail Return Request Receipt. Summary Judgment motions set must confirm all discovery required for the same is completed.
• All parties at any hearing must be prepared to address case management issues, argue all non-evidentiary motions if time permits, and have authority to make binding representations on motions, issues and scheduling.
• Failure to appear at any scheduled hearing will result in the imposition of sanctions without further notice of the Court, including imposition of attorney fees, striking of discovery, striking of pleadings, dismissal of action, or any other action deemed appropriate by the Court.

6. Continuance Procedure:

• Motions for continuance are disfavored and will be granted only upon good cause shown. Successive continuances are highly disfavored. Lack of due diligence is not grounds for granting a continuance. Except for good cause shown, the motion must be signed by the party requesting the continuance, as required by Florida Rule of General Practice and Judicial Administration 2.545(e). Motions for continuance must be submitted at least thirty (30) days prior to calendar call for which the continuance is sought, barring exigent circumstances. Except for good cause shown, the motion must be signed by the party requesting the continuance, as required by Florida Rule of General Practice and Judicial Administration 2.545(e).
• Motions for continuance must state with specificity: (1) the basis of the need for the continuance, including when the basis became known to the movant; (2) whether the motion is opposed; (3) the action and specific dates for the action that will enable the movant to be ready, including, but not limited to, confirming the specific date any required participants are available; and (4) the proposed date by which the case will be ready to proceed and whether that date is agreed by all parties.
• Trials cannot be continued by an Agreed Order. The proposed order must state with specificity good cause with factual and legal basis. Please do not provide a chart amending the DCMO. See below Motions.

7. Cancelling Hearings:

1. Cancellation of UMC Hearings
   You must cancel hearings by notifying the judicial assistant immediately. You must also immediately file and serve a notice of cancellation on opposing counsel and any self-represented litigant. To cancel a hearing scheduled for UMC, the scheduling attorney's office must file a Notice of Cancellation and submit a copy to the Court via CAD-DivisionAG@pbcgov.org. In addition, that attorney's office must log in to the 15th Judicial Circuit's Online Scheduling System, select "Uniform Motion Calendar 'UMC' Scheduling;" select "Cancel Hearings" and follow the directions on the screen.
2. Cancellation of Special Set Hearings Parties must provide an agreed order for the Court's review and attach the Motion as an exhibit or a proposed order that the motion is withdrawn or settled.

8. Other Scheduling Procedures:

• The Court will not entertain boilerplate (non-case specific) Motions in Limine. The Court will not hear the same without the parties timely filing/setting pursuant to the DCMO.
• Please set summary judgement/final judgement motions on Foreclosure cases with the Senior Judge as indicated below.

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C. Remote Appearance

1. Remote Appearance Procedure:

• The court maintains a hybrid virtual courtroom, allowing parties to appear either in person or remotely, as provided by Florida Rule of General Practice and Judicial Administration 2.530. Requests to use communication technology for an appearance must be made by motion.
• Any objection to the use of communication technology must be filed immediately.
• All hearings 60 minutes or less will be conducted by Zoom (unless otherwise directed by the Court) and the Zoom information should be included on the Notice of Hearing. Most hearings over 60 minutes, evidentiary hearings, non-jury trials, and jury trials will be held in person in Courtroom 10D.
• Please include the Zoom information in place of Courtroom 10D on your Notices of Hearing for Uniform Motion Calendar hearings and all matters that zoom will be utilized.

2. Platform Used:

ALL REMOTE HEARINGS IN DIVISION AG WILL BE HELD VIA ZOOM AND NOTICED USING THE COURT'S ZOOM INSTRUCTIONS.

3. Platform Meeting ID#:

Meeting Link: Join Zoom Meeting
Meeting ID: 85056337361
Passcode: No passcode required.

Dial by your location:
US Toll-free 877-853-5257
US Toll-free 888-475-4499

4. Requirements:

• Any person appearing remotely must dress and behave professionally in the same manner as if physically present in the courtroom.
• Any person appearing remotely must enable the person's camera when joining the proceeding and keep the camera turned on until instructed otherwise by the court.
• Any person appearing remotely must mute the person's microphone when joining the proceeding and keep the microphone turned off until instructed otherwise by the court.
• If a witness appears remotely, the party calling the witness must ensure the witness has a functioning camera and microphone and has tested the internet connection before the hearing. The oath will be administered in accordance with Florida Rule of General Practice and Judicial Administration 2.530.
• Any person appearing remotely must be in a private location that is quiet and free from distractions. Under no circumstances will a participant be permitted to appear remotely from a moving vehicle.
• A proposed order must be provided no sooner than 5 days prior to all hearings.

5. Technology Needs:

All participants in a remote hearing must have a camera, microphone, and speaker to allow them to be seen and heard during a video conference. A smart phone or laptop usually is manufactured with all three installed. A PC with an external camera and headset will also work. If using a smart phone or tablet, you must download the Zoom app.

6. Other Remote Appearance Procedures

The Judicial Assistant does not handle requests regarding Audio Visual equipment and other courtroom accommodations. These matters are handled by the Court Technology in coordination with the Court Room Deputy. You are free to use outside vendors. Court Administration has some equipment available as well. Any requests for media equipment from the Court, please complete the Courtroom Media Request form and submit it to Court Technology at least 5 days prior to trial.

The courtroom is a medium sized courtroom with an eight (8) seat jury box. There is a large monitor for Zoom appearances and electronic exhibits can be displayed on the large television screen in the courtroom. Electronic evidence is best displayed using the share screen function of Zoom. Alternatively, it may be displayed utilizing a dongle connecting a laptop to the courtroom system. If you are utilizing Zoom in person in the Courtroom please be sure to press the "Join without audio" option. If you do, you will be connected to the courtroom's audio and video system. If you join with audio, even if are muted, there will be an echo and you will not be connected to the courtroom's system.

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D. Submission of Orders and Judgments

1. Format:

• All proposed orders must be submitted in Word format and provided to opposing counsel and any self-represented litigant.
• All proposed orders must be printed on 8.5 x 11-inch paper and provided to opposing counsel and any self-represented litigant.
• All proposed orders must be accompanied by a cover letter either (1) certifying that all parties agree to the order or (2) containing a statement identifying any disagreement of the parties as to the proposed order.
• All proposed orders must include a statement of Good Faith compliance with Local Rule 4 (PDF). In addition, any Notice of Hearing that does not include this language will result in the cancellation of the hearing. Please read the division forms regarding the specificity of date conferred or three dates attempting conferral by telephone call by counsel. Conferral with self represented parties is required.
• If a case is set for trial or calendar call any motion and order to withdraw as counsel must reference the trial period, calendar call date and other outstanding DCMO deadlines in the proposed form of order. See Division Forms.

2. Submission Method:

• All proposed orders must be submitted to the court by the proposed order portion of the Florida Courts E-Filing Portal (OLS).
• A proposed form of order must be uploaded by each party prior to any and all hearings by OLS no sooner than five (5) days in advance, which includes Case Management Conferences. For all hearings, the Motion and Response must be attached as Exhibits as well as the Operative complaint for Motions to Dismiss and the Note/Mortgage for Foreclosures. A copy of all proposed orders must be emailed to the opposing party for objection. Please upload an agreed proposed order on Status and Case Management Conferences (see forms). All proposed orders must include the status of the case indicating the motion was timely filed and set, the parties desired outcome, factual basis, legal authority, calendar call date, confirmation of conferral in a good faith effort to resolve the issues raised by telephone and email. Please also include the notice of hearing with the date of the hearing and service of all parties.
• Please provide in all proposed orders: 1) compliance with Local Rule 4 is mandatory and this Court requires conferral by telephone with self-represented litigants for all motions 2) legal citations referenced in the proposed order 3) on OLS all parties must include a properly titled orders, mark Y if the order is agreed and N if opposed and the event dated 4) provide Docket Entry numbers (DE#__), not filing numbers, when referencing another filed case document and 5) status of the case including the calendar call date. and related cases.
• To special set hearings the parties must upload an Agreed Status Order with Request to Special Set indicating the DCMO DE# and date filed, calendar call date, the deadline to file the motion and to set the same (see Division Documents for sample).
• Summary Judgment Hearings: Parties must upload a proposed order prior to hearing as indicated above with an undisputed statement of facts with citations. Contested Summary Judgment hearings are to be Special Set and must be timely in accordance with the DCMO. The Court will not hear motions untimely filed and/or set. Fla.R.Civ.P. 1.510 requires the Parties to cite specifically to the record. The rule further states the Court need not consider materials not cited, and the rule requires the non-moving party must respond in writing. All Motions for Summary Judgment should clearly state and separately reference each undisputed material fact to be relied upon, and the legal basis for summary judgment based upon those undisputed facts. All Responses to Motions for Summary Judgment should clearly state and separately reference any facts that are disputed, as well as the legal basis for denying relief based upon the facts alleged to be undisputed by the opposing party. The Court is familiar with the current general legal standard for a Motion for Summary Judgment; Motions and Responses should focus on the specific issues involved in the case at bar. The Court will review all the provided materials and prepared to conduct the required hearing. The parties will be given 5 minutes per side, afterwards the Court will ask pertinent questions. All summary judgment hearings require a Court Order to cancel the hearing. YOU CAN NO LONGER CANCEL A SUMMARY JUDGMENT HEARING ONLINE (whether or not a Notice of Hearing has been issued). To request a continuance or cancellation of a Summary Judgment hearing, you must confer and upload an agreed order for the Court to consider 5 days prior to the hearing.
• Uncontested Summary Judgment hearings may be scheduled on the Court's UMC docket, but foreclosure SJs are to be set before the Senior Judge if uncontested or involving a self-represented parties (all original documents must be filed). The following documents are required at an Uncontested Summary Judgment hearings. Summary Judgment Foreclosure Checklist with adding machine tape attached (set all with Senior Judge).
  • Notice of Hearing
  • Motion for Summary Judgment
  • Payment History
  • Affidavit of Indebtedness (including a loan payment history)
  • Affidavit of Attorney's Fees
  • Affidavit of Costs
  • Opposing affidavits (if any – see FRCP 1.510)
  • Original Note and Mortgage (or copies if already filed with the Clerk's office)
  • Final Judgment and Copies (tab the original for Judge's signature)
  • Final Disposition Form
• If the Final Judgment is entered, the Clerk's office will need the Certificate of Title.
• Sale dates are available on the Clerk's website. Plaintiff or Plaintiff's attorney must prepare a Notice of Sale and send a copy to all parties on the case. This step is not required to be conducted in the courtroom. Notices of Sale may be emailed to the designated newspaper for publication. The original must be filed with the Clerk of Court. Notices should include sale date, billing information, signature of Plaintiff or Plaintiff's attorney, sale location (Palm Beach Clerk Auctions), time of sale (10:00 AM) and all other information as required by F.S. Section 45.031(2).
• Final Judgments: Orders should be submitted through Online Services, in Word format, with a service list but without a date and signature line, as the orders will be signed and dated electronically and will be e-filed and e-served. This is a directive of the Supreme Court AOSC19-74. All Orders/Final Judgments must be uploaded with cover letter and/ or supporting attachments. A cover letter is required (as a supporting document) stating that all parties have reviewed the Order and are in agreement with the form of the Order. If parties are not in agreement with the form of the Order, the SPECIFICS of the disagreement must be noted in the cover letter to the Judge and redlined. Parties may submit competing Orders and cover letters and the Judge will sign the Order which reflects the Court's ruling.
• DO NOT SUBMIT/UPLOAD MORE THAN ONCE. If an order was uploaded with an error, please contact the J.A. to notify of the erroneous uploaded order. The J.A. will be able to locate the order to delete and allow the parties to upload the correct order to avoid duplicate filings and/or filings of erroneous orders. Please do not upload a duplicate order for lack of receiving a signed copy of a previously uploaded order. Deleting an order in OLS DOES NOT remove the order from the Court's queue.
• When uploading multiple orders, please upload each order individually. Orders uploaded as an attachment cannot be signed and processed. The parties should consider an Omnibus Order.
• If the order being submitted is regarding a hearing held in open court, the date of that hearing must be included in the first sentence of the order. If an Order is uploaded without a note or cover letter, the Court will reject the Order.
• After a hearing, unless otherwise directed at the hearing and the Order must state the date the hearing was held. All parties must have reviewed the Order before it is submitted to the Court Online Services.
• Additionally, when submitting an Order in the OLS portal, please fill in all fields, especially the date of the hearing and a complete title of the order instead of just "Order or "Final Judgment". If the field is left blank, it will be auto-filled with " Proposed Order" which makes it more difficult for the Court to differentiate between multiple orders.
• If the Court directs after the hearing: the Moving party shall, confer with opposing counsel and submit proposed orders electronically within 48 hrs. after the Court's ruling on the matter. The names and addresses of all persons receiving copies must appear in the Order or Final Judgment, pursuant to Administrative Order 2.306.
• Please note: Do not mail duplicate Orders that have also been uploaded to the Online Scheduling System.
• For "Order on Motion to Vacate the Final Judgment of Mortgage Foreclosure, Cancel Foreclosure Sale, Dismiss Action without Prejudice, Dissolve the Lis Pendens, and Release Original Documents" please upload the Order to the portal. If the sale date is within 2 weeks, please email the J.A. to alert as to the time sensitive pending order.

3. Deadline for Submissions:

No sooner than five (5) days prior to the hearing.

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E. Courtesy Copies of Case Law and Other Documents

1. When Required:

The court does not require the submission of courtesy copies.

Division AG does not utilize e-courtesy.

All documents must be provided by the E-evidence portal for evidentiary hearings.

All case law must be cited in the Motion, Response. Reply and Proposed Order. Please do not attach cases.

2. Format:

Courtesy copies must be submitted in Word format New Times Roman 12.

All parties must upload by OLS their proposed order with all copies attached as exhibits. No paper copies are needed. The Notice of Hearing should be attached for ease with the correct hearing date. This applies to each and every hearing, including UMC and Special Sets. . If the Court does not receive your proposed order with attachment on time, your hearing may be canceled.

3. Submission Method:

Courtesy copies must be submitted to the court by OLS.

4. Deadline for Submissions:

No sooner than five (5) days prior to the hearing attached to proposed order as exhibit.

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F. Emergency and Other Urgent Matters

If a party believes there is a factual basis for setting an emergency hearing, a detailed motion setting forth the following must be filed: (1) the issues to be resolved, (2) reasons why an emergency hearing is necessary, and (3) the amount of time needed for each party's presentation.

1. Requirements: Emergency Motions/Request for Emergency Hearings

The term "emergency" encompasses matters of life and death, or instances of irreparable harm, which does not include urgent matters. Please do not entitle your motion "Emergency" unless it cannot be handled in the ordinary course without irreparable harm. File your original Emergency Motion with the Clerk of Court, Civil Division and upload a proposed form of order with the Motion as an attachment providing a copy to all parties. The Clerk's Office will forward to the Judge, or an alternate, for review and directive to determine whether an emergency hearing should be scheduled. Please do not set an Emergency Motion for hearing unless directed to do so by the Court's Judicial Assistant. It is not appropriate to file an emergency for failure to comply with a DCMO deadline. All motions must indicate conferral or specific attempts to confer.

2. Scheduling:

If the court determines that an emergency exists, a hearing will be scheduled unilaterally by the court. All parties shall make themselves available for the emergency hearing, barring exigent circumstances.

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G. Exhibits for Evidentiary Proceedings

1. Submission Method:

• Submit all exhibits electronically by E-Evidence portal.
• Pre-mark all exhibits in accordance with the instructions of the Clerk and Comptroller. See Civil Evidence Guidelines.

2. Format:

• Exhibits must be labeled in the following format: Insert label preference (e.g., "Petitioner/Plaintiff 1" or "Respondent/Defendant A").
• All attorneys and self-represented litigants must bring sufficient copies of each exhibit for the clerk, the court, and each party to review during the hearing or trial.

3. Deadline for Submissions:

Electronic exhibits must be submitted five (5) days before the evidentiary proceeding.

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H. Pretrial Procedures and Conferences

1. Case Management Conference (CMC):

All hearings will include a Case Management Conference and the Court may hear any outstanding motions at a Case Management Conference.

• Any party may request a CMC when a case requires.
• The court strongly encourages the early use of CMCs in more complex cases, multiple-party litigation, or any case that might benefit from court intervention.
• Unless excused by the court in advance, all CMCs are mandatory for attorneys and self-represented litigants. Parties represented by counsel are not required to appear at a CMC.

2. Status Conference:

Any party may request a status conference when a case requires.

3. Requirements:

Any request for a CMC or status conference must articulate the reasons for the necessity of the conference.

4. Calendar Call

Please file a pretrial checklist which can be found under division forms 5 days prior to the same and ensure the agreed jury instructions and verdict form are e-filed and uploaded as a word document as a proposed order on OLS.

5. Scheduling:

Division AG Calendar Call will be held in person or on Court order via Zoom on the above posted link on the listed date at 9:00 a.m. Attendance at Calendar Call is required. No motions of any kind will be heard at the time of Calendar Call or thereafter. The Trial Docket week assignments will be posted by end of day the Wednesday following Calendar Call, unless Monday or Tuesday is a holiday.

Please review the posted trial dockets on the Trial Docket page for the specific trial docket periods. Division AG has 10 week trial dockets.

As required in the DCMO's, at the calendar call, parties are expected to be ready for trial in compliance with all provisions of the case management order; have completed mediation; timely filed a joint pretrial stipulation with all exhibit and witness lists attached; and all motions have been heard or are set for hearing 30 days before calendar call. Counsel must also be prepared to confirm whether the case is jury or non-jury, to advise the Court of the number of days anticipated for trial and the number of potential jurors requested for the venire. Unless an enlarged panel has previously been authorized and ordered by the Court after the motion and hearing, with the approval of the Chief Judge, the maximum number of jurors is 31 by A.O. Conflicts recognized by the Court are limited to specially set trials and pre-paid vacations, life events, or medical issues. An appearing attorney must be prepared to advise the Court of all attorneys' availability for trial and future hearings as necessary, or those conflicts will not be recognized by the Court. Any other lawyer conflicts, as well as witness and litigant conflicts, will be considered as preferences. Counsel shall be prepared to advise the Court of efforts made to preserve testimony, arrange for remote appearance, video deposition or otherwise resolve any witness or litigant appearance conflicts.

6. Other Procedures Relating to Pretrial Procedures and Conferences

Non-jury trials require competing proposed final judgments provided 5 days prior to calendar call.

Jury trials require agreed jury instructions and verdict form as well as a form final judgment.

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I. Setting Case for Trial

1. Procedure:

For Trials, the parties must utilize a stenographer for purposes of transcribing/transcription.

2. Notices of Trial/ DCMO

1. Notice of Trial
   File the original Notice with the Clerk and only send a copy to the Judicial Assistant indicating that you are not on a trial track by DCMO. If you are not on a trial track please set UMC or upload an agreed order to set the same. If the parties have a Calendar call date and seek to expedite trial, please upload by OLS an agreed order on the same. Please file the appropriate motion pursuant to Rule 1.440(b).

2. Uniform Differentiated Case Management Order and Order Setting Trial (DCMO)
   Pursuant to the 15th Judicial Circuit's Administrative Order 3.110 (as amended 12/24), at the time of filing cases that are not exempt under the administrative order will be automatically designated to one of three tracks—the General Track, the Streamlined Track or the Expedited Track—and will receive one of the three orders below:

   1. Uniform Differentiated Case Management Order and Order Setting Trial (DCMGJT). The General Track is for JURY TRIALS, and time to disposition is within 18 months after service on the last defendant or 120 days after commencement of the action.
   2. Uniform Differentiated Case Management Order and Order Setting Trial (DCMSNT). The Streamlined Track is for NON-JURY TRIALS, and time to disposition is within 12 months after service on the last defendant or 120 days after commencement of the action.
   3. Uniform Differentiated Case Management Order and Order Setting Trial (DCMENT). The Expedited Track is for FORECLOSURE TRIALS, and time to disposition is within 12 months after service on the last defendant or 120 days after commencement of the action.
   4. A fourth track, the Complex Track, contemplates disposition within 30 months after service on the last defendant or 120 days after commencement of the action. Cases will not be automatically designated as complex; a motion must be filed and a hearing set.

   This is your trial order. Each of the DCMOs listed above contains a schedule with a calendar call date and pretrial deadlines. These are firm deadlines. The ways to modify these deadlines if necessary is addressed in section III. Cases must be ready for trial by the date of calendar call. IMPORTANT NOTE: Cases will be reassigned tracks only under very limited circumstances. Re-designation is not for merely modifying deadlines or obtaining continuances. See Part 4 of Administrative Order 3.110.

   As required in the DCMO, parties are expected to be ready for trial at the time of calendar call and in compliance with all provisions of the case management order; completed mediation; timely filed a joint pretrial stipulation with all exhibit and witness lists attached; and all motions have been heard or are set for hearing. Counsel must also be prepared to confirm whether the trial is jury or non-jury, and to advise the Court of the number of days anticipated for trial and the number of potential jurors requested for the venire. Unless an enlarged panel has previously been ordered by the Court after motion and a hearing timely filed and set, the A.O. provides for 31 and the Court may grant a maximum of 40.

   If your case is not reached on the scheduled docket, the case will be reset as soon as practicable or the Court will set a CMC to discuss rescheduling as soon as practicable. Unless the Court enters an order or the parties agree in writing otherwise, no additional discovery, witnesses or exhibits are allowed. The parties are required to be trial ready at the first docket.

3. Foreclosure Cases

See Foreclosure

Summary Judgement motions and Default Final Judgements with self represented defendants are to be set before the Senior Judge. In addition, uncontested or slightly contested (2 hours or less) residential foreclosure cases are heard by a Senior Judge, please email CAD-SRJDTrials@pbcgov.org.

Notices of Foreclosure Trials must be filed with the Clerk's office and then emailed to the Senior Judge. The Notice shall include:

1. the specific matters to be tried and an estimate of time needed for the trial. See Rule 1.440(b), Fla.R.Civ.Pro.
2. The number of witnesses for each side should be included in the notice. See Rule 1.440(b), Fla.R.Civ.Pro.

If there is an opposing counsel, counsels must confer as to the amount of time needed for trial. The agreement or lack of agreement as to the length of time shall be reflected on the Notice for Trial.

The parties must send a copy to the Judicial Assistant pursuant to the divisional instructions. The Judicial Assistant will forward all notices of trial requesting ninety (90) minutes or less to a case manager to issue a trial order for a docket to be heard by Senior Judges.

Any requests for two hours or more shall be set for calendar call and heard by the Judge presiding in that division. Please review each trial order carefully. All motions for continuances of the trial shall be filed and noticed pursuant to the instructions on the Order Setting Trial prior to the trial date. Motions for Continuance will be heard in the division in which they are assigned. Senior Judges will not entertain motions for continuances on the day of trial.

All evidence for trial should be pre-marked and Date Stamped.

4. Notice Period:

• The court does not set date-certain trials. After calendar call/pre-trial conference, the court will assign cases to specific days during the trial period and may assign back-up cases. Attorneys, self-represented litigants, parties, and witnesses are expected to be available during the entire trial period.

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J. Forms

Division forms are available for download.

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K. Other Division Procedures

1. ADA Accommodations:

• If you need an ADA accommodation, please call 561‐355‐4380. If you are hearing or voice impaired, call 1‐800‐955‐8771. You can also fax 561‐656‐7662, or e‐mail ADA@pbcgov.org.
• Information on ADA accommodations can be found on the Circuit ADA web page.

2. Interpreter Requests:

Please bring your own translator. The Court does not provide the same.

3. Audio Visual Equipment Requests

The Judicial Assistant does not handle requests regarding Audio Visual equipment and other courtroom accommodations. These matters are handled by the Court Technology in coordination with the Court Room Deputy. You are free to use outside vendors. Court Administration has some equipment available as well. Any requests for media equipment from the Court, please complete the Courtroom Media Request form and submit it to Court Technology at least 5 days prior to trial. The courtroom is a medium sized courtroom with an eight (8) seat jury box. There is a large monitor for Zoom appearances and electronic exhibits can be displayed on the large television screen in the courtroom. Electronic evidence is best displayed using the share screen function of Zoom. Alternatively, it may be displayed utilizing a dongle connecting a laptop to the courtroom system. If you are utilizing Zoom in person in the Courtroom please be sure to press the "Join without audio" option. If you do, you will be connected to the courtroom's audio and video system. If you join with audio, even if are muted, there will be an echo and you will not be connected to the courtroom's system.

4. Settlements, Dismissal of Cases and Final Judgement

If a case settles or is voluntarily dismissed and there are future hearings or a trial scheduled on the Court's docket, EMAIL the Judicial Assistant immediately at CAD-DivisionAG@pbcgov.org to inform her of same, to allow the Court to free up hearing/trial time for other cases. Please be courteous to the other cases in the division and note any upcoming hearings that should be canceled to allow the hearing time to be freed for other cases to schedule. If the case is on a trial docket, the case will not be removed from the trial docket until the JA receives a copy of the filed Notice of Settlement or Voluntary Dismissal. The notification to the Court must be followed up by necessary and appropriate formal paperwork. Submit Orders of Dismissal of Cases on the Online Scheduling System. Cases will not be removed from the Trial Docket until a filed copy of the closing document (Notice of Settlement; Voluntary Dismissal; etc.) is received by the Judicial Assistant. Pursuant to Local Rule 3, a proposed Final Judgement will be provided to the Court timely after the final hearing/jury verdict.

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L. Motions

As required under the DCMO's, after the parties have met and conferred, the movant must schedule for hearing all contested, non-dispositive motions within five (5) days of filing. Failure to schedule a hearing within five (5) days may result in the Court deeming the motion(s) abandoned without further notice or hearing. Parties may not set for hearing a motion that does not comply with the DCMO deadlines. The parties should make best efforts to restrict Motions and Responses to no more than 5 pages for UMC and 10 pages for special set and ensure a proposed order is provided as indicated herein. Failure of counsel and self-represented parties to appear at any scheduled hearing will result in the imposition of sanctions including imposition of attorney fees, striking of discovery, striking of pleadings, dismissal of action, entry of a default judgment or any other action deemed appropriate by the Court. In an effort to eliminate unnecessary hearings, mandatory compliance with Rule 1.202 and Local Rule No. 4 is strictly enforced. Before filing, movants must confer by telephone with opposing parties including self represented parties in a good faith effort to resolve the issues raised in the motion and indicate the same in the proposed order.

1. Motions to Amend

   All motions to amend pleadings must comply with the Rules and attached proposed amended pleading as Exhibit A. The proposed order must indicate that the amended pleading will be filed within 5 days of the filed order and the opposing party has twenty (20) days to respond to the same once it is filed. Please indicate if it is unopposed, but do not include language that it is "deemed" filed if granted. Please attach the motion and proposed amended pleading as an exhibit to the proposed form of order by OLS. The same must indicate that it is timely filed and/or set in compliance with the DCMO, basis for the amendment and the difference from the last filed pleading.

2. Motions to Compel

   Please segregate each interrogatory and production request with each response/objection immediately thereafter. The Court requires that all parties make a good faith effort to confer prior to filing motions, which applies to all counsel and self-represented litigants. See Administrative Order NO. 3.202. All discovery motions and proposed orders must indicate the specific effort made to avoid Court intervention including telephone calls and emails. Please indicate if a privileged log was provided in the proposed form of order.

3. Motions for Disbursement of Surplus Funds

   The party that filed the motion must set motions for Surplus Funds for hearing with notice to all parties. Sixty days from the issuance of the Certificate of Disbursement must elapse prior to any hearing being set. Any contested evidentiary hearings taking more than 10 minutes (five (5) minutes each side) should be set for a special set hearing, otherwise most Motions for Surplus can be scheduled for Uniform Motion Calendar pursuant to the divisional instructions.

4. Motion for Rehearing/Reconsideration/Clarification

   Please provide a proposed form of order with attached Motion and provide a copy to the opposing party upon filing of the motion. The motion must include confirmation of conferral by the parties. Motions for Rehearing / Reconsideration/ Clarification are not scheduled by the parties/attorneys and the Court will determine the same. See Local Rule 6 (PDF). Local Rule #6 mandates the following: With the exception of motions for new trial or rehearing pursuant to Rule 1.530, Fla.R.Civ.P., or similar procedural rule, no petition for rehearing, motion for reconsideration, or like pleading shall be set for oral argument except upon court order. The petition or motion shall be filed with clerk and a copy shall be furnished to the assigned judge along with a copy of the original order. by OLS. A Response shall be filed within 5 days and provided as an exhibit to the Respondent's competing order. Upon consideration of the matter, the judge shall either deny the petition or motion or shall set it for oral argument.

5. Motions to Withdraw

   All orders must be provided prior to the hearing and include the new contact information including a physical address, telephone number and Email Address Designation for Process of Service (Word), in compliance with Fla. R. Gen. Prac. & Jud. Admin. 2.516, as well as the current status of the case indicating hearing/ trial dates pending and the last time the parties attended mediation. See division documents for a sample form.

   If there is an affidavit of client consent and certification that there is no opposition by the opposing party, an Agreed Proposed form of Order can be uploaded by OLS.

   If there is no client consent and/or there is opposition by the other party, the motion should be set for a UMC hearing to allow argument.

   Note the motion must be more than bare assertion as to irreconcilable differences, which will enable this Court to determine if a requisite ground is present as enumerated in the Rules Regulating the Florida Bar 4-1.16(b). Schultz v. State, 289 So. 3d 921, 924 (Fla. 4th DCA 2020). The withdrawing attorney must set a case management conference scheduled for after the Motion to Withdraw, which requires all parties to appear. The "Order Setting Case Management Conference" shall indicate that all parties and clients must attend the hearing. The order shall also include the following language:

   Failure for all parties and clients to attend will result in sanctions which may include the striking of pleadings or the case being dismissed, without prejudice, and closed without further notice from this Court for failure to comply with this order.

   The "Order Setting Case Management Conference" shall indicate that the hearing will be held remotely with the information provided in the "Remote Appearance" section above.

   Corporations and trusts are required to hire new counsel prior to the case management conference.

6. Motions for Writ of Possession

   All motions for Writ of Possession (to vacate premises) must be set at Uniform Motion Calendar with proof of proper and timely notice to all parties, including unknown tenants. Notices will be sent by Certified Mail Return Request Receipt withe the green card filed with the Clerk. Tenants who receive a Notice of Hearing for a Writ of Possession have the right to be present at the hearing and must attend if they are seeking an extension.

7. Motions in Limine

   All Motions in Limine shall be set on UMC consistent with the DCMO deadlines as indicated prior to calendar call. The Court will not entertain boilerplate, non case-specific Motions, which require the opposing counsel to follow the law, or seek an order prohibiting counsel from violating the rules of evidence, making "Golden Rule" arguments during closing argument, or expressing personal beliefs. If these issues arise during trial, they may be raised contemporaneously via objection. All case-specific Motions in Limine as well as Objections to Deposition Designations shall be filed and scheduled timely.

8. Motions to Extend Time to Serve

   All ex parte Motions to extend time to serve process should be filed prior to the deadline for service and show the following for good cause: legitimate efforts have been made to serve defendants, circumstances preventing timely service; indicate how the problem can be rectified, and the length of extension reasonably necessary. Motions seeking relief nunc pro tunc, after expiration of the deadline for service, must be set for hearing and state the DCMO deadline. Please attach an Affidavit of Diligent Search that includes efforts taken including a skip trace, search of Sunbiz, search home address of registered agent, United States Post Office inquiry through the Freedom of Information Act, regulatory agencies, DMV, Armed Forces of the U.S., Tax Assessor, Tax Collector, Internet databank locator service, Dept. of Corrections, Law Enforcement, telephone and address listings, ect. Parties may submit proposed Orders on their Motion and the Court will either enter the Order or direct the party to set the matter for hearing.

9. Discovery Motions

   Discovery relates to pending claims and defenses, not for potential claims. Proportionality applies to all discovery. Proportionality begins with relevance to pending claims and may no longer include everything that is relevant if not proportionate to needs of the case. Discovery rulings are always without prejudice unless otherwise stated. Documents not subject to objection must be produced, even if objections made to others. Discovery rulings are always without prejudice unless otherwise stated. Please cite to the specific Rule in the proposed order. Rules 1.280 General Provisions Regarding Discovery and Rule 1.380 Failure to Make Discovery; Sanctions. If the parties are in agreement on a discovery deadline extension or other modification that does not affect other deadlines or impact the date for completion of all discovery, an agreed order may be uploaded for Court review without a hearing. Objections to discovery must be stated with specificity, and include reasons. Boilerplate objections are not sufficient. Any ground not stated in a timely objection will be considered waived, absent good cause. See Rule 1.340, Rule 1.350. Discovery Motions seeking to extend deadlines or modify discovery obligations must be filed prior to the expiration of the deadline. The mere filing of a Motion does not extend any deadline or modify any discovery obligation. Any disputed discovery motions must clearly identify:

   1. The specific disputed request, response, objection or relevant excerpt from deposition testimony.
   2. The relief requested.
   3. Specific reasons supporting the relief requested.
   4. The legal and factual basis for compelling, overruling or sustaining any objection.
   5. If sanctions are requested, the legal and factual basis for sanctions.
   6. The parties conferred by telephone or in person.

10. Motions for Judicial Default

    Motions for Judicial Default must be set for hearing with all defaulted parties noticed. To ensure Due Process, the Court will inquire about efforts made to notice the defaulted parties both of the Motion and of the hearing. Please include in your proposed order the date of Clerk's default or efforts to obtain a Clerk's default, conferral with all defaulted parties by telephone providing the telephone number called and email address used including for self represented default parties and filing the green card certified mail return request receipt in the case file for the notice of final hearing. Please also attach the complaint as an exhibit.

11. Motions to Dismiss

    Please note the court-ordered deadlines in the DCMO's for filing and resolving amendments and motions directed to the pleadings. As required under Rule 1.200(e)(1), deadlines in the DCMO's are strictly enforced unless modified by the Court. Counsel will confer to determine an agreed order is appropriate to allow Leave to Amend rather than a hearing on a Motion to Dismiss.

12. Motions to Continue Trial

    A motion to continue trial must be in writing unless made at trial and, except for good cause shown, must be signed by the named party (not counsel) requesting the continuance. Rule 1.460(d). The parties must advise the Court with specificity of all discovery and other matters that are preventing the case from trial readiness, when the same can be achieved and upload a proposed order prior with factual and legal basis. Motions to Extend Time should be filed as soon as circumstances giving rise to the need for and for good cause stating the current DCMO deadlines with Docket Entry, confirmation of the current calendar call and trial dates and those requested.  Florida Rules of Civil Procedure (floridabar.org) Rule 1.460 and Florida Rules of General Practice and Judicial Administration (floridabar.org) Rule 2.545(e). All motions and proposed orders for continuance, even if agreed, must state with specificity: (1) the basis of the need for the continuance, including when the basis became known to the movant; (2) whether the motion is opposed; and (3) the specific date and the action needed that will enable the movant to be trial ready. For example: "The deposition of John Smith is set for 4/9/26 as he was in the hospital and the discovery deadline is extended for this matter only. There is no prejudice, all other DMCO deadlines remain, the parties will be trial ready for the ten week trial period with a calendar call date of 4/24/26". Please do not provide a chart amending all deadlines. As noted in Rule 1.200(f), notices of unavailability have no effect on the deadlines set by the case management order. If a continuance is granted based on the dilatory conduct of an attorney or named party, the Court may impose sanctions on the attorney, the party, or both. The matter may be ruled on the papers or set for hearing on a UMC or DCMC docket. Consistent with the DCMO's, absent unforeseeable, exigent circumstances, the failure to complete discovery is not grounds for a continuance. Motions to Continue Trial are disfavored and will rarely be granted and then only upon good cause shown. Successive continuances are highly disfavored. Lack of due diligence in preparing for trial is not grounds to continue the case. Rule 1.460(a) Failure to timely complete discovery and/or file a motion for summary judgment shall not be grounds to continue a trial.

13. Motions to Extend Differentiated Case Management (DCMO) Deadline

    See Rule 1.200 and Section O above. Please state with specificity the matters to be completed within the new deadline date sought to be amended, the time needed to complete, and the effect on other DCMO deadlines.

14. Daubert Motions

    Any party seeking to exclude expert testimony under Daubert shall file a Motion with the Court specifically identifying the basis for the challenge. Written Responses to any Daubert Motions should be filed ten (10) days after the Motion is filed. Please be mindful of the court-ordered deadlines in the DCMO's for disclosing experts and expert opinions, and for filing Daubert Motions. The same must be filed timely under Rule 1.200(e)(1) in accordance with deadlines in the DCMO.

15. Motions on Attorney Fees

    Motions to determine entitlement to attorney's fees and costs may be set for hearing on the Court's UMC docket. The parties must meet and confer, prior to setting the matter for hearing. Once entitlement is determined, the parties are to comply the division standing order on attorney's fees and costs. The parties must attend mediation prior to setting the hearing to determine the amount.

16. Motions to Consolidate

    Please review A.O. 2.302. See related orders.

17. Motions for a Directed Verdict

    The Court requests a proposed order with legal authority cited 24 hours prior to the hearing on the same if possible.

18. Motion for Enlarged Jury Panel

    Local rules and A.O. No. 2.402-12.21 require advance approval of the Chief Judge and Jury Office for jury panels exceeding 40 jurors. To ensure enough jurors are available, requests for enlarged jury panels must be resolved at least six (6) months before calendar call. The requests must be made via motion and scheduled for hearing on the Court's UMC docket or as part of a case management conference. If the Court has not issued an order granting a motion for enlarged panel, the Court will not be able to accommodate a venire of more than 40 potential jurors. Per the DCMO, failure to timely request an enlarged panel may result in Court-ordered sanctions, including a limitation on peremptory challenges.

19. Motion for Approval of Settlement

    Please set for hearing and upload a proposed order with the motion, guardian ad litem report, the retainer agreement and settlement statement.

20. Writ of Garnishment

    The movant must indicate the date, DE, the amount of the final judgement and the outstanding amount of the final judgement as well as the date of the expiration of the judgement. See Chapter 77 of the Florida Statutes. F.R.C.P. 1.202C(11).

21. Motions on Foreclosure Matters

    Summary Judgement and Final Judgment should be set with senior judge. All proposed orders must include the Mortgage and Note as exhibits. All pleadings must be closed.  Plaintiff is required to schedule their uncontested motion for summary judgment through OLS on the Senior Judge docket.

22. Motion on Default Final Judgment and Default Summary Judgment

    This motion must be set for hearing on UMC. To ensure Due Process, the Court will inquire about efforts made to notice the defaulted parties both of the Motion and of the hearing. Please include in your proposed order the date of default, conferral with all defaulted parties by telephone providing the telephone number called and email address used including for self-represented parties and filing the green card certified mail return request receipt in the case file for the notice of final hearing. Please also attach the complaint, contract, bill or the like as an exhibit to the proposed order, which must include the above details with the factual basis and legal authority for final judgment. If you are seeking attorney fees, please provide legal basis and provide bills for review.

23. Motions for Summary Judgment

    Parties must upload a proposed order prior to hearing as indicated above with an undisputed statement of facts with citations. The parties must be cognizant the all SJM cannot be set until 50 days after filing in compliance with the Fla.R.Civ.P. The same must be set and heard 30 days before calendar call and timely filed under the DCMO. The Court will not hear motions untimely filed, set and heard.

    1. Contested Summary Judgment
       Fla.R.Civ.P. 1.510 requires the Parties to cite specifically to the record. All Motions for Summary Judgment should clearly state and separately reference each undisputed material fact to be relied upon, and the legal basis for summary judgment based upon those undisputed facts. All Responses to Motions for Summary Judgment should clearly state and separately reference any facts that are disputed, as well as the legal basis for denying relief based upon the facts alleged to be undisputed by the opposing party. The Court is familiar with the current general legal standard for a Motion for Summary Judgment; Motions and Responses should focus on the specific issues involved in the case at bar The Court will review all the provided materials and prepared to conduct the required hearing. The parties will be given 5 minutes per side, afterwards the Court will state on the record the reasons for granting or denying the motion.

       All summary judgment hearings require a Court Order to cancel the hearing. YOU CAN NO LONGER CANCEL A SUMMARY JUDGMENT HEARING ONLINE (whether or not a Notice of Hearing has been issued). To request a continuance or cancellation of a Summary Judgment hearing, you must confer and upload an agreed order for the Court to consider 5 days prior to the hearing.

    2. Uncontested Summary Judgment hearings may be scheduled on the Court's UMC docket, but foreclosure SJs are to be set before the Senior Judge if uncontested or involving a self-represented parties (all original documents must be filed).

       The following documents are required at an Uncontested Summary Judgment hearing:

       1. Summary Judgment Foreclosure Checklist with adding machine tape attached (set all with Senior Judge)
       2. Notice of Hearing
       3. Motion for Summary Judgment
       4. Payment History
       5. Affidavit of Indebtedness (including a loan payment history)
       6. Affidavit of Attorney's Fees
       7. Affidavit of Costs
       8. Opposing affidavits (if any – see FRCP 1.510)
       9. Original Note and Mortgage (or copies if already filed with the Clerk's office)
       10. Final Judgment and Copies (tab the original for Judge's signature)
       11. Final Disposition Form
       12. If the Final Judgment is entered, the Clerk's office will need the Certificate of Title.

       Sale dates are available on the Clerk's website. Plaintiff or Plaintiff's attorney must prepare a Notice of Sale and send a copy to all parties on the case. This step is not required to be conducted in the courtroom. Notices of Sale may be emailed to the designated newspaper for publication. The original must be filed with the Clerk of Court. Notices should include sale date, billing information, signature of Plaintiff or Plaintiff's attorney, sale location (Palm Beach Clerk Auctions), time of sale (10:00 AM) and all other information as required by F.S. Section 45.031(2).

       For "Order on Motion to Vacate the Final Judgment of Mortgage Foreclosure, Cancel Foreclosure Sale, Dismiss Action without Prejudice, Dissolve the Lis Pendens, and Release Original Documents" please upload the Order to the portal. If the sale date is within 2 weeks, please email the J.A. to alert as to the time sensitive pending order.

24. Final Judgments Orders should be submitted through Online Services, in Word format, with a service list but without a date and signature line, as the orders will be signed and dated electronically and will be e-filed and e-served. This is a directive of the Supreme Court AOSC19-74 (Paper Orders are no longer accepted for signature by the Court). All Orders/Final Judgments MUST be uploaded with cover letter and/ or supporting attachments. A cover letter is required (as a supporting document) stating that all parties have reviewed the Order and are in agreement with the form of the Order. If parties are not in agreement with the form of the Order, the SPECIFICS of the disagreement must be noted in the cover letter to the Judge and redlined. Parties may submit competing Orders and cover letters and the Judge will sign the Order which reflects the Court's ruling.

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