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M.D. Fla. · Judge Berger · Practice Guide

Hon. Wendy Berger

All local rules for M.D. Fla., integrated with this judge's published requirements.

Drafting the Motion
Length limits — motion, opposition, reply
🏛 M.D. Fla. local rule
Motion

(b) LENGTH AND CONTENT OF A MOTION, A BRIEF, OR AN OBJECTION. A motion must include — in a single document no longer than twenty-five pages — a concise statement of the precise relief requested, a statement of the basis for the request, and a legal memorandum supporting the request. M.D. Fla. Local Rule 3.01(b) ↗

Opposition

(c) LENGTH AND CONTENT OF A RESPONSE. A party responding to a motion or brief may file a legal memorandum no longer than twenty pages. M.D. Fla. Local Rule 3.01(c) ↗

Reply

(e) NO REPLY AS A MATTER OF RIGHT. Except for a reply to a motion for summary judgment or a reply brief in a social security action, no party may reply without leave. A motion for leave to reply must not exceed three pages; must specify the need for, and the length of, the proposed reply; and must not include the proposed reply. No response to a motion for leave to reply is permitted. A party may reply to a response to a motion for summary judgment within fourteen days after service of the response. A reply must not exceed seven pages. M.D. Fla. Local Rule 3.01(e) ↗

AI use & disclosure requirements
👤 Judge Berger — standing order

Due to the increasing use of generative artificial intelligence ("AI") in the researching and drafting of legal documents, including pleadings, motions, briefs, and other filings, the undersigned requires all parties appearing before her, through counsel or pro se, to certify at the end of any filing: (1) That no generative AI was used in the drafting and preparation of the filing; or (2) To the extent that generative AI was used in any drafting of the filing, that any language drafted by AI-even if later edited by a human-was personally reviewed by the filer or another human for accuracy and that all legal citations reference actual, non-fictitious cases or cited authority and accurately reflect the contents of such authority. The AI Certification does not count against any page limitations. Filings that do not comply with this Order may be stricken without substantive consideration and without leave to amend. Numerous failures to comply with the certification requirement set forth in this Order or to otherwise properly review and ensure the accuracy of AI generated content will result in sanctions up to and including dismissal of claims with prejudice, default, and referral to the proper licensing authority. All filings remain subject to Federal Rule of Civil Procedure 11, 28 U.S.C. Section 1927, and applicable ethical rules. DONE AND ORDERED in Jacksonville, Florida on April 2, 2026. Source ↗

Filing & Scheduling
Briefing schedule & hearing date
🏛 M.D. Fla. local rule
Notice period

(d) TIME TO RESPOND. A party may respond to a motion within fourteen days after service of the motion. However, a party may respond within twenty-one days after service to a motion to dismiss, for judgment on the pleadings, for summary judgment, to exclude or limit expert testimony, to certify a class, for a new trial, or to alter or amend the judgment. If a party fails to timely respond, the motion is subject to treatment as unopposed. M.D. Fla. Local Rule 3.01(d) ↗

Hearing days

Silent on motion hearing days. M.D. Fla. Local Rule 3.01 (silent) ↗

Proposed orders
🏛 M.D. Fla. local rule

(k) NO PROPOSED ORDER. Unless otherwise permitted by these rules, no party in a civil action may submit a proposed judgment or other order without leave. M.D. Fla. Local Rule 3.01(k) ↗

The Hearing
Oral argument
🏛 M.D. Fla. local rule

(i) ORAL ARGUMENT OR EVIDENTIARY HEARING. A party must request oral argument or an evidentiary hearing in a separate document accompanying the party’s motion or response and stating the time necessary. M.D. Fla. Local Rule 3.01(i) ↗

More from Judge Berger’s procedures
👤 Judge Berger — standing order
AI certification

Due to the increasing use of generative artificial intelligence ("AI") in the researching and drafting of legal documents, including pleadings, motions, briefs, and other filings, the undersigned requires all parties appearing before her, through counsel or pro se, to certify at the end of any filing: (1) That no generative AI was used in the drafting and preparation of the filing; or (2) To the extent that generative AI was used in any drafting of the filing, that any language drafted by AI--even if later edited by a human--was personally reviewed by the filer or another human for accuracy and that all legal citations reference actual, non-fictitious cases or cited authority and accurately reflect the contents of such authority. The AI Certification does not count against any page limitations. Filings that do not comply with this Order may be stricken without substantive consideration and without leave to amend. Numerous failures to comply with the certification requirement set forth in this Order or to otherwise properly review and ensure the accuracy of AI generated content will result in sanctions up to and including dismissal of claims with prejudice, default, and referral to the proper licensing authority. All filings remain subject to Federal Rule of Civil Procedure 11, 28 U.S.C. section 1927, and applicable ethical rules. Source ↗

Font typeface

Revised Local Rule 1.08(a), (b) is amended as follows: each pleading, motion, or other paper, excluding an exhibit, an attachment, a transcript, an image, or other addendum, shall be in at least 12-point Arial typeface, including all indented quotations, footnotes, and endnotes. In all other respects, the Rule shall be applied as written. Source ↗

MSJ response deadline

Revised Local Rule 3.01(c) is amended as follows: a party may respond to a motion for summary judgment within thirty days after service of the motion. In all other respects, the Rule shall be applied as written. Source ↗

content assembled from published local rules & standing orders · click any section in the rail for the full treatment
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