Procedures verified June 25, 2026
Magistrate Judge Lauren F. Louis -- United States District Court, Southern District of Florida
Wilkie D. Ferguson, Jr. United States Courthouse, 400 North Miami Avenue, Miami, FL 33128
warning
Key Traps — Where Counsel Gets Caught
- 1. - Sanctions motions (including motions to exclude undisclosed material) CANNOT use Pathway 2 informal hearing -- written motion only under Pathway 1.
- 2. - Providing discovery 'subject to and without waiving' an objection is improper: if you produce the material, the objection is waived.
- 3. - 'Not reasonably calculated to lead to admissible evidence' is an outdated and disregarded objection under current rules.
- 4. - Rule 30(b)(6) scope objections: serve in advance of deposition (do not file); adjudicated after the deposition.
- 5. - 28-day window strictly enforced; all disputes must be FULLY COMPLETED before discovery cutoff.
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
Pre-Motion Conference
Two pathways available (unique in FL-SD). Pathway 1: any party may file a written discovery motion without seeking leave. Pathway 2 (informal): parties confer, identify 2+ jointly agreed dates within next 14 days, movant emails louis@flsd.uscourts.gov with specified subject and contents. CRITICAL: Motions for sanctions (including exclusion of undisclosed material) CANNOT use Pathway 2 -- written motion only. [fl-sd-mj-louis — pre_motion_procedure]
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At Filing
Chambers Copies
Conditional
For Pathway 2 informal hearings: parties send materials to chambers via email within 24 hours of hearing confirmation. [fl-sd-mj-louis — courtesy_copies_details]
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Before the Hearing
Oral Argument
Within 24 hours of the Court confirming the Informal Discovery Hearing, the Movant shall file a Notice of Informal Discovery Hearing in CM/ECF. By no later than 12:00 P.M. two business days before the Informal Discovery Hearing, each party shall send an email to louis@flsd.uscourts.gov, attaching copies of all materials relevant to the discovery dispute(s) to be heard at the hearing. [fl-sd-mj-louis — oral_argument_procedure]
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Background Rules
Chambers Contact
For Pathway 2 (informal hearing): movant sends ONE email to louis@flsd.uscourts.gov with all parties copied; subject line 'Request for Discovery Hearing'; include case number, caption, jointly proposed dates, anticipated duration, and certificate of conferral. Do not send multiple emails or call chambers for scheduling under this pathway. [fl-sd-mj-louis — chambers_contact_restrictions]
Discovery Dispute Procedure District-default
Within 24 hours of the Court confirming the Informal Discovery Hearing, the Movant shall file a Notice of Informal Discovery Hearing in CM/ECF. By no later than 12:00 P.M. two business days before the Informal Discovery Hearing, each party shall send an email to louis@flsd.uscourts.gov, attaching copies of all materials relevant to the discovery dispute(s) to be heard at the hearing. [fl-sd-mj-louis — discovery_dispute_procedure]
Under Seal Filings
Proposed protective orders must be emailed to louis@flsd.uscourts.gov in Word format. Court will omit any provision that would allow parties to bypass L.R. 5.4 sealing requirements. [fl-sd-mj-louis — under_seal_requirements]
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AI & Style Preferences
Additional Notes
Sources: Judge Louis's Discovery Practices and Procedures PDF (9 pages, 3 parts). Miami division. The two-pathway system is unique in the district. Pathway 2 (informal) is faster but unavailable for sanctions motions. Chambers email for all matters: louis@flsd.uscourts.gov.
Sources & Currency
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Procedures verified June 25, 2026.
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