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

Hon. William Jung

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

Before You File
Contacting chambers
👤 Judge Jung — standing order

Contacting Chambers Counsel may call chambers with procedural questions and for other assistance. However, the law clerks will not give legal advice, interpret the rules, provide time estimates for the court's written rulings, or discuss the merits of a case.

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) ↗

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) ↗

👤 Judge Jung — standing order

Does the court accept proposed orders? No, unless requested by the court. In the limited cases in which the court requests a proposed order, it should be emailed to the chambers inbox in Microsoft Word (.doc or .docx) format.

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) ↗

Discovery
Discovery referral procedure
👤 Judge Jung — standing order

Does the court refer discovery matters to the assigned magistrate judge? Yes.

More from Judge Jung’s procedures
👤 Judge Jung — standing order
Conferral requirement

Local Rule 3.01(g) Certification Local Rule 3.01(g) requires a moving party to confer with opposing counsel in a good-faith effort to resolve the issue to be raised in a motion before filing a motion in a civil case. Source ↗

Courtesy copies

Should courtesy copies of pleadings and motions be forwarded to chambers? No, unless a pleading or motion exceeds 100 pages, including exhibits and attachments. A courtesy copy should be mailed or delivered to chambers as soon as practicable after filing. Source ↗

Extension of time requirements

Requests for Extensions of Time Because the Middle District of Florida is one of the busiest trial courts in the country, extensions of court-imposed dates and deadlines will be granted only for compelling reasons. The court's permission is required to extend court-imposed dates and deadlines. The court encourages the parties to work together in a collegial manner with respect to all pending matters; however, it is solely the court's province to grant an extension of time. Notably, after a defendant has been served, if that defendant needs additional time to respond to the complaint, that defendant should file a motion requesting an extension of time, rather than informally seeking an extension of time from plaintiff's counsel. An informal agreement without the benefit of a court order is insufficient. Counsel should consult the Local Rules about admission to practice before the court. If defense counsel does not meet the requirements for being admitted to practice in this court, defense counsel should retain local counsel and seek admission on a pro hac vice basis. Source ↗

Mediation requirements

What is the court's policy on alternative dispute resolution such as court-annexed, nonbinding arbitration and mediation? Mediation is required in almost all civil cases. Source ↗

Oral argument procedure

Does the court set aside time in a given week or month to hear oral arguments on pending motions? The court will schedule oral arguments on selected pending motions as its trial calendar permits. Source ↗

Summary judgment requirements

Does the court require a statement of material facts in support of a motion for summary judgment? Yes. (See the Motions for Summary Judgment section under the Civil Motions section of the Preferences tab.) Source ↗

Know Before You Go
👤 Judge Jung — deviations that burn people
  • - No proposed orders unless specifically requested or authorized.
  • - Courtesy copies required when filing exceeds 100 pages.
  • - LR 3.01(g) conferral required before filing any civil motion; failure to comply results in denial or striking of the motion.
  • - Mediation required in most/all civil cases.
  • - MSJ must include numbered Statement of Material Facts with pinpoint record citations; opposing party must mirror in numbered paragraphs.
  • - Notice of Unavailability has no force or effect; must file motion for extension.
content assembled from published local rules & standing orders · click any section in the rail for the full treatment
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