FL-MD — Watchpoints

Six compliance traps for practitioners new to M.D. Fla.:

• No reply without leave — almost ever. The no-reply default (L.R. 3.01(e)) catches practitioners accustomed to districts where replies are routine. Only MSJ replies and social security brief replies are permitted as of right. Every other reply requires a motion for leave, capped at 3 pages, with no proposed reply attached. Miss this and you may not reply at all.
• The 3.01(g) Certificate must be in the motion, not a cover letter. The certificate goes at the end of the motion under the heading "Local Rule 3.01(g) Certificate." A separate email or letter documenting conferral is not sufficient. Omission risks denial without prejudice.
• Motion and memo must be one document. L.R. 3.01(b) does not permit a motion followed by a separate memorandum of law. Everything must fit in a single document of 25 pages or fewer. Filing a separate brief after the motion is a local rule violation.
• No incorporation by reference. L.R. 3.01(h) is absolute. A motion cannot incorporate arguments from another brief or pleading. Each document must be self-contained. This applies to responses and replies as well.
• No letters or emails to request or oppose relief. L.R. 3.01(l): "A party must not use a letter, email, or the like to request relief or to respond to a request for relief." Judges in this district do not accept correspondence in lieu of motions.
• Typeface and spacing requirements are mandatory. L.R. 1.08 specifies exactly five approved typefaces (at 13-point) plus Times New Roman (at 14-point). Arial, Calibri, and other common fonts are not on the approved list. Character spacing must be 100% scale, Normal spacing, Normal position. Compressed character spacing to expand page count is not permitted.