Southern District of Florida
Local rules, motion practice, and judge procedures for S.D. Fla. practitioners.
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Hard 28-day window for discovery motions. From the triggering event — response received, deposition completed, production made — you have 28 days to file. Miss the window and the motion is untimely. FL-SD is the only court in our 10-court sample with this rule.
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Emergency ≠ time-sensitive. Filing under the Emergency procedure without imminent irreparable harm can get you sanctioned. Use "Expedited" for urgent matters that don't meet the emergency threshold.
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Motions go stale at 90 days. A motion pending more than 90 days must be re-noticed or the court may rule without further briefing.
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Proposed orders go to chambers twice. File to CM/ECF and email to the judge's chambers. One without the other is non-compliance.
Quick Reference
Quick-reference summary of the most frequently needed rules for the Southern District of Florida.
| Topic | Rule | Key Detail |
|---|---|---|
| Font | L.R. 5.1(a)(4) | 12-point minimum, including footnotes and quotations. |
| Margins | L.R. 5.1(a)(4) | 1 inch on all sides. |
| Spacing | L.R. 5.1(a)(4) | 1.5 spacing minimum; single spacing for block quotes (50+ words) and footnotes. |
| Page limit — motions | L.R. 7.1(c)(2) | 20 pages (motion + memo combined). |
| Page limit — opposition | L.R. 7.1(c)(2) | 20 pages. |
| Page limit — reply | L.R. 7.1(c)(2) | 10 pages. |
| Hearings | L.R. 7.1(b) | No hearing unless set by the Court; must request in 'Request for Hearing' section. |
| 90-day stale motion rule | L.R. 7.1(b)(4) | If fully briefed 90 days with no hearing/ruling, file 'Notice of Ninety Days Expiring' within 14 days. |
| Opposition due | L.R. 7.1(c)(1) | 14 days after service of motion. |
| Reply due | L.R. 7.1(c)(1) | 7 days after service of opposition. |
| Conferral required | L.R. 7.1(a)(3) | Yes — orally or in writing, before filing most motions; certification required. |
| Discovery filing rule | L.R. 26.1(b)-(c) | NOT filed until used in proceeding. |
| Privilege log deadline | L.R. 26.1(e)(2)(D) | Within 14 days of production/response. |
| Bates stamping | L.R. 26.1(e)(6) | Required — each page individually numbered. |
| Discovery motion deadline | L.R. 26.1(g)(2) | Within 28 days of triggering event. |
| SMF required (SJ)? | L.R. 56.1(a)-(b) | Yes — separate document, 10 pages. |
| Opponent's SMF (SJ) | L.R. 56.1(b)(2) | 10 pages response + 5 pages additional facts; first word must be 'disputed' or 'undisputed'. |
| Mediation | L.R. 16.2(d)(1) | Mandatory in most civil cases. |
| Courtesy copies | L.R. 5.1(c) | Not permitted unless requested by the judge's office. |
| Proposed orders | L.R. 7.1(a)(2) | Required — attach as exhibit via CM/ECF + email Word version to judge. |
| Pro hac vice fee | Court Fee Schedule | $250 per attorney, per case. |
| Local counsel required (PHV) | Attorney Admission Rule 4(b) | Yes — SDFL bar member who is an authorized CM/ECF filer. |
| PHV limit | Attorney Admission Rule 4(b) | More than 3 PHV motions in 365 days = presumed general practice. |
Orientation
At a Glance
Quick-reference summary of the most frequently needed rules for the Southern District of Florida. | Topic | Rule | Key...
Watchpoints
## Watchpoints — Southern District of Florida FL-SD has several distinctive aspects of its motion practice — the 28-day...
Pro Hac Vice
SDFL pro hac vice: $250 per attorney per case. Local counsel (SDFL bar member, authorized CM/ECF filer) required. PHV...
Formatting
Filing & Administration
Filing & Service (CM/ECF)
All SDFL bar members must file electronically via CM/ECF. No fax filing. Registration requires mandatory online training...
Proposed Orders
SDFL requires proposed orders with specific motions (habeas, default, pro hac vice, stipulation approval, emergency/ex...
Discovery
Discovery
SDFL discovery governed by two documents: Local Rules (binding) and Discovery Practices Handbook (guidance only, Admin...
Judge-Specific Procedures
SDFL judges maintain individual standing orders that supplement and sometimes modify local rules. If judge's discovery...
Motion Practice
Conferral / Meet and Confer
Before filing any motion in a civil case, counsel must confer (orally or in writing) with all affected parties in good...
Briefing Schedule & Deadlines
Opposition due 14 days after service. Reply due 7 days after service of opposition. Failure to file may be deemed cause...
Motion Practice & Hearings
SDFL uses a no-hearing-unless-set-by-the-Court model (L.R. 7.1(b)(1)). To request oral argument, include a separate...
Dispositive Motions
Summary Judgment
SDFL requires a separate Statement of Material Facts (SMF) — 10 pages movant, 10 pages opponent response + 5 pages...
Court-Annexed Mediation
Mediation is mandatory in virtually every SDFL civil case. Parties select mediator within 14 days of referral order; if...