Procedures verified June 25, 2026
Magistrate Judge Ellen Frances D'Angelo -- United States District Court, Southern District of Florida
Wilkie D. Ferguson, Jr. United States Courthouse, 400 North Miami Avenue, Miami, FL 33128
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Key Traps — Where Counsel Gets Caught
- 1. Four mandatory exhibits required with every discovery motion — Exhibit A: proposed order in Word (email to DAngelo@flsd.uscourts.gov; each party submits its own separately); Exhibit B: all source materials (interrogatories, answers, etc.); Exhibit C: all documents either party intends to rely on at hearing; Exhibit D: list of legal citations + copies of authorities (may highlight passages and add parentheticals — no argument permitted). Motion filed without certificate of good faith will be stricken.
Quick Reference
| Topic | Rule |
|---|---|
| Chambers Copies | Conditional |
Procedural Briefing by Motion Type
S.D. Fla. · Standing Orders
Procedural Requirements
Key Traps
Compare to Other S.D. Fla. Judges
Procedural facts only. Judges shown to illustrate variance in this district.
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Before You File
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At Filing
Chambers Copies
Conditional
Proposed orders: email Word version to DAngelo@flsd.uscourts.gov (submitted as Exhibit A with each discovery motion; each party submits its own proposed order separately). [D'Angelo -- courtesy_copies_details]
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Before the Hearing
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Background Rules
Chambers Contact
All email communications to chambers must copy all counsel of record, except for confidential settlement statements. Proposed orders: email Word version to DAngelo@flsd.uscourts.gov. Electronic equipment in courtroom: file motion at least 72 hours in advance; may schedule equipment test 24 hours before hearing. [D'Angelo -- chambers_contact_restrictions]
Discovery Dispute Procedure District-default
Standing Discovery Order (8 pages): [Model C] Confer first (in-person, phone, or videoconference; email alone insufficient), then file motion within the 28-day window per L.R. 26.1(g)(2). Motion ≤5 pages + certificate of good faith (non-compliance = stricken); response ≤5 pages within 3 business days; no reply without court order. Four mandatory exhibits required with every motion (see key_traps record). Court issues standing discovery order upon case referral. If district judge's discovery order conflicts, district judge's order prevails. [D'Angelo -- discovery_dispute_procedure]
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AI & Style Preferences
Additional Notes
Sources: Judge D'Angelo's chambers page (6 tabs including Employment) and Civil Standing Discovery Order PDF (8 pages). Miami division. Model C with 4-exhibit structure -- most structured discovery briefing in the district. Response within 3 business days. Chambers email: DAngelo@flsd.uscourts.gov. All non-confidential emails copy all counsel.
Sources & Currency
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Procedures verified June 25, 2026.
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