Procedures verified June 25, 2026

Magistrate Judge Jared M. Strauss -- United States District Court, Southern District of Florida

Broward County Courthouse, 299 E. Broward Blvd, Fort Lauderdale, FL 33301

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Key Traps — Where Counsel Gets Caught

  1. 1. Boilerplate objections (vague, overbroad, or unduly burdensome) will be stricken. If a request is vague/overbroad/unduly burdensome, must confer with opposing counsel to narrow scope before asserting objections -- and must still respond as to matters where scope or burden is not contested. Prior conferral to narrow objections does NOT restart the conferral clock: must confer again separately before requesting a discovery hearing.

Quick Reference

Topic Rule
Chambers Copies Conditional

Procedural Briefing by Motion Type

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Before You File

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At Filing

Chambers Copies
Conditional
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Before the Hearing

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Background Rules

Discovery Dispute Procedure District-default
No written discovery motions concerning discovery disputes between parties shall be filed unless specifically authorized by Order. The moving party may request a discovery hearing -- only after adequate good faith conferral regarding each and every issue -- by filing a 'Notice of Discovery Dispute' (not a motion). The notice shall briefly describe (in one or two sentences) the nature of the discovery dispute, shall state the case's discovery deadline, shall briefly describe the efforts made to confer, shall provide the Court with at least three alternative dates within the ensuing two weeks that both counsel are available for a hearing (noting availability on each date as morning, afternoon, or all day), and shall state the amount of time that the parties anticipate needing for the hearing. The notice shall not include argument for the moving party's position. Conferral before asserting objections does not obviate the need to confer again before requesting a hearing (fn.1). Joint Discovery Status Report (chart, 1 page per request/issue) filed 48 hrs before hearing; email Word copy to strauss@flsd.uscourts.gov. Arguments at hearing treated as ore tenus motions; Rule 37(a)(5) fee-shifting applies. [Strauss -- discovery_dispute_procedure]
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AI & Style Preferences

Additional Notes
Sources: Judge Strauss's Discovery Procedures PDF (7 pages). Fort Lauderdale division. Model B: contact chambers first, file motion same day hearing confirmed. Motion limited to 3 pages. First hearing via Zoom.

Sources & Currency

verified Procedures verified June 25, 2026. Verify now →

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