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Broward County's Local Rules of Court
17th Judicial Circuit (Division 13)
Florida

LOCAL RULE 00 | BASIC INFO

Michael A. Robinson
Circuit Court Judge
Seventeenth Judicial Circuit in and for Broward County, Florida
SealFlorida Broward County Courthouse
201 S.E. 6th Street
Room 14-150
Courtroom 14-131
Fort Lauderdale, FL 33301
(954) 831-6362
Div12@17th.FLCourts.org
Mairale Dyson

Judicial Assistant, Mairale Dyson
(mdyson@17th.FLCourts.org)

IMPORTANT NOTE:

when emailing the Judicial Assistant please do the following:

1. On the subject line of the email type the Case Style and the Case Number;

2. In the body of the email confirm that all parties to the case (Plaintiff or Plaintiff’s Attorney(s) and Defendant or Defendant’s Attorney(s) are listed and copied to the email. Do not write anything else other than “see attached”.

3. Confirm that whatever attachments, that may be added to the email, have been properly filed with the Clerk of the Court and served upon all parties to the case; and,

4. Please do not write comments in the body of the email as this type of communication is not shared with the Court.

5. If a cover letter accompanies the filed motion, please keep it simple.

ALL JURY TRIALS ARE HELD IN COURTROOM WW#14150
PARTIES ARE REQUIRED TO UTILIZE THE ONLINE ELECTRONIC SCHEDULING SYSTEM FOR THE 17TH JUDICIAL CIRCUIT “CASE MANAGEMENT SYSTEM” TO SCHEDULE MOTION CALENDAR, SPECIAL SET HEARINGS, SCHEDULING CASES FOR TRIAL (CALENDAR CALL) AND UPLOADING E-ORDERS

No person can enter the courthouse without face covering.
Until further notice, ALL hearings will be held Via Division 13 ZOOM Video Conferencing

Please Note: DO NOT Send hard copies of pleadings, motions or supporting materials for any hearing. Parties shall upload all materials to be considered by the Court at least 4 days before the scheduled hearing. The Court does not have immediate access to Fedex, UPS and/or US Postal Service mail. Additionally, your Notice of Hearing must include the ZOOM link. Please do not notice any hearings in the courthouse.

UPLOADING DOCUMENTS FOR HEARINGS.

You may mail, fedex or email any documents for the hearing. Preferably they can be uploaded and they should also be filed with the Clerk of the Court.

Please use the below link to upload supporting documents to all hearings.
http://www.17th.FLCourts.org/attach-documents-2/
Note: When looking for your case do not use the date of the case to look it up, use at least 30 days prior to the hearing.

If you have further questions on this or any other CMS issue please contact our IT department: calendar@17th.FLCourts.org

LOCAL RULE 01 | HEARINGS

All hearings, including, motion calendar, special set hearings, LOPs, CMC and most Non-jury trials will proceed as scheduled and counsel, parties and court reporters shall appear by ZOOM. All jury trials will be in person in the courtroom (WW#14150).

General Rules for all hearings:

1) All persons present for a hearing will clearly and slowly announce their appearance: attorneys, court reporters, witnesses, notaries, interpreters etc.

2) The attorney who desires testimony must make arrangements to have the interpreter, court reporter and witness appear via Zoom and must ensure a person authorized to administer oaths is present.

3) Prior to the hearing, the attorney who desires evidence must upload proposed exhibits as “Supporting Documents” for the hearing/motion through the CMS portal and if opposed, be prepared to lay a predicate for their admission in evidence. Use Bates numbers on all proposed exhibits so they can be identified for the court record.

4) Remote hearings require an utmost respect, courtesy, patience and professionalism. Be considerate of all parties and witnesses, wait for others to finish speaking and don’t interrupt. Be patient. There are multiple hearings on the docket and in the waiting room. Please avoid background noise and be aware that if your video camera is on, then everyone involved can see you! Be mindful and considerate of the Court Reporter.

Alternatives are Available:

If the parties file a written stipulation and notify the Court, they can waive argument and have the Court decide the issues on written motion and memoranda.

Do not ask for relief by contacting via email or telephonically the Judge or Judicial Assistant. File the appropriate Motion.

BELOW IS JUDGE MICHAEL A. ROBINSON’S
INVITATION AND INSTRUCTION TO JOIN HIS HEARINGS DOCKET VIA ZOOM CONFERENCE

VIA DIVISION 13 ZOOM (ONLY)

Topic: Judge Robinson Docket

Join Zoom Meeting

https://17thFLCourts.zoom.us/j/571442299

Meeting ID: 571 442 299

Toll Free Number(s)
(888) 475-4499
(833) 548-0276
(833) 548-0282
(877) 853-5257

then
Meeting ID: 571 442 299

LOCAL RULE 02 | ONLINE SCHEDULING

LOCAL RULE 03 | UNILATERALLY ONLINE HEARINGS

LOCAL RULE 04 | LIMITS ON THE NUMBER OF CASES

Judges have limits on the number of cases that can be scheduled using the Online Scheduling System. If you are unable to schedule your matter on a specific date, it is likely because the docket is full and there are no additional time slots available. Please schedule on an alternate date.

LOCAL RULE 05 | UNIFORM MOTION CALENDAR

(Monday – Friday @ 8:30 A.M.)

To comply with the Local Rule 10(A), every party setting a motion for hearing shall execute the following certification:
I hereby certify that,

1. I have made a good faith attempt to resolve this matter prior to my noticing this motion for hearing, and

2. The issues before the Court may be heard and resolved by the court within five (5) minutes.
Parties cannot add-on to an existing UMC hearing unless AGREED to by all parties. Add-ons will only be heard within the allotted time, both sides get equal time. No more than two motions may be noticed for a case on UMC.

Any person scheduling a motion calendar shall set the same a minimum of five (5) days in advance of the hearing. Self-Represented parties may obtain permission to utilize the Online Scheduling System. Prior to setting any matter on uniform motion calendar, the party or parties noticing the motion shall attempt to resolve the matter by direct communication with all parties, and shall also certify a good faith attempt to resolve or narrow the issues contained in the motion. Direct communication means by oral or written communication, including by telephone, in person, email, or text messaging.

All time requirements regarding the scheduling of hearings shall be governed by the Florida Rules of Civil Procedure, Florida Family Law Rules of Procedure, or Florida Rules of Judicial Administration, as applicable.

LOCAL RULE 06 | SUPPORTING DOCUMENTS

LOCAL RULE 07 | SELF-REPRESENTED (“PRO SE”) PARTIES

If you represent yourself, any requests you are making of the Judge needs to be in EMAIL. The Judicial Assistant is not a lawyer and handles scheduling only, therefore, do not call and ask for advice on what to file or how to prepare anything. On some matters, you may be able to go to the Clerk of Court’s office on the fourth floor and they can help you with their forms.

LOCAL RULE 08 | PRO SE REGISTRATION FORM

If you represent yourself you can register for CMS by going to: www.17th.FLCourts.org.
1. Self Help
2. Court Management System Help
3. CMS Manuals
4. New User
5. Pro se Registration Form
Fill out the request form and, when accepted, you can view and schedule hearings.

For Hearings Requiring Court Reporters and Interpreters:

Parties who desire a Court Reporter will make the necessary arrangements with the Court Reporter to appear by ZOOM at all hearings.
• The Court Reporter will announce his or her presence.

• Any witness(es) or interpreters will announce their presence, the attorneys must ensure a person authorized to give oaths is present.

LOCAL RULE 10 | MOTIONS – PAGE AND OTHER LIMITATIONS

(a) In a motion or petition for an order, the movant shall include a concise statement of the relief requested, a statement of the basis for the request and citation to legal authority, statutory and case law, in support of the motion. Motions set on motion calendar shall not exceed four (4) pages and motions scheduled for special set hearing shall not exceed ten (10) pages. Font size shall not be less than 12 points.

(b) Each party opposing a motion or petition may file a response that includes citation to legal authority, statutory and case law in opposition to the request. A response to a motion calendar matter shall not exceed three (3) pages and a response to a special set matter shall not exceed seven (7) pages.

(c) No party shall file any reply or further memorandum directed to the motion or response allowed in (a) and (b) unless the Court grants leave.

(d) A motion requesting relief from the page limitation shall not exceed two (2) pages, specify what efforts have been made to comply with the page limitation, specify the length of the proposed filing and do not include any attachments.

LOCAL RULE 11 | MOTIONS

(a) Motions for Rehearing/Reconsideration.

The moving party must comply with Adm. Order No. 2017-33-GEN. “Administrative Order Regarding Motion for Rehearing.” DO NOT set a hearing regarding the motion. The filed motion along with a proposed order MUST BE submitted electronically for the Court’s consideration. YOU MUST include all parties in your email to the Court.

(b) Motions to Continue Trial.

In accordance with the Uniform Pretrial Order, continuances will only be considered for good cause on written motion prior to calendar call. Also, please comply with Fla. R. Civ. P. 1.460 and 2.545(e) regarding party consent. If the case is continued the parties must reset it for trial using the Online Scheduling System. If a case is settled prior to the trial date, the scheduling party MUST immediately provide email notification to Ms. Mairale Dyson.

(c) Motions to Withdraw.

If you do not have client written consent in accordance with Fla. R. Jud. Adm. 2.505, please notice the client with both the motion and the notice of hearing. In the body of the proposed order granting withdrawal please include the client’s address, email address and phone number. If the client is an individual please include the following language in the Order:
Within 20 days client shall either retain new counsel who must file a Written Notice of Appearance with the Clerk of Court; or

the client must file a written notice with the Clerk of Court advising that he or she will be representing himself or herself (pro se).
If the client is a business entity please include the following language in the Order:
(Name of Client) shall be represented by counsel who shall file a Written Notice of Appearance within 20 days of the date of the order.
Failure to follow this Order will create a presumption that client no longer wishes to participate in this litigation and the Court may sua sponte, or upon motion by opposing counsel, impose sanctions against client. Those sanctions may include striking pleadings, granting attorney’s fees and costs, the entry of default, dismissal of the lawsuit with prejudice and/or any sanctions deemed appropriate and just by the Court.

(d) Motions for Summary Judgment – Generally.

A motion for Summary Judgment is designed to relieve the Court of the expense of a trial when a party is unable to support by competent evidence any material issue of fact. The movant for summary judgment has the initial burden of demonstrating the nonexistence of any genuine issue of material fact. But once he tenders competent evidence to support his motion, the opposing party must come forward with counterevidence sufficient to reveal a genuine issue. It is not enough for the opposing party merely to assert that any issue does exist. Rather it is incumbent upon the opposing party to come forward with competent evidence revealing a genuine issue of fact.

Pursuant to the Florida Supreme Court’s amendment to Florida Rule of Civil Procedure 1.510 effective May 1, 2021, parties moving for summary judgment must support or oppose the motion with a statement of material facts. In the interest of judicial economy, in the interest of proper and careful consideration of each party’s statement of material facts, and in the interest of determining matters on summary judgment on the merits, the Court orders the parties to file any statements of material facts as follows:
1. The moving party shall file a statement of material facts as a separate filing from a motion for summary judgment.

2. The statement shall not exceed ten (10) pages.

3. Each material fact in the statement that requires evidentiary support shall be set forth in an individually numbered paragraph and supported by a specific citation. This specific citation shall reference pages (and paragraph or line numbers, if applicable) of the cited exhibit(s). When a material fact requires evidentiary support, a general citation to an exhibit, without a page number or pincite, is not permitted.

4. Each exhibit referenced in the motion for summary judgment and/or in the statement of material facts must be filed on the docket. Exhibits which have already been filed on the docket need not be refiled. If a deposition transcript is referenced, a complete copy must be filed which includes all exhibits. Within twenty-four (24) hours of filing a motion for summary judgment, the movant shall separately file an index of the cited exhibits which names each exhibit and references the docket entry at which that exhibit may be found.

5. The responding party may file an opposing statement of material facts which responds to the moving party’s statement of material facts.

6. The opposing statement of material facts shall not exceed ten (10) pages.

7. A responding party’s opposing statement of material facts must specifically respond to each statement in the movant’s statement by setting forth each of the individually numbered paragraphs contained in the movant’s statement and after each paragraph, detail respondent’s response or opposition.

By way of example:
Movant’s Statement of Material Facts
1. Blackacre is a vacant property located at 123 Main Street. Exhibit A ¶ 1.

2. Bobby Jackson Doe owns Blackacre. Exhibit B ¶ 12.
Respondent’s Opposing Statement of Material Facts
1. Blackacre is a vacant property located at 123 Main Street. Exhibit A ¶ 1.
Admitted that Blackacre is located at 123 Main Street. Exhibit A ¶ 1. Denied that the property is vacant. Exhibit C at 5.
2. Bobby Jackson Doe owns Blackacre. Exhibit B ¶ 12.
Denied as phrased. Admitted that the last recorded deed to Blackacre names Bobby Jackson Doe. Exhibit B ¶ 12.
8. Each exhibit referenced in the response to the motion for summary judgment and/or in the opposing statement of material facts must be filed on the docket. Exhibits which have already been filed on the docket need not be refiled. If a deposition transcript is relied upon, a complete copy must be filed which includes all exhibits. Within twenty-four (24) hours of filing a response to the motion for summary judgment, the responding party shall separately file an index of the cited exhibits which names each exhibit and references the docket entry at which that exhibit may be found.

9. In the event that cross motions for summary judgment are filed, the Court may order the parties to submit a consolidated statement of material facts and responses as appropriate. If cross motions are anticipated, the parties may jointly move for an order to file consolidated statements prior to filing the motions for summary judgment.

10. A reply statement of facts is not permitted.

11. Remember Rule 1.510 requires that the motion be served at least 40 days before the time set for the hearing and requires the non movant to serve a response at least 20 days before the time set for the hearing.
Please DO NOT CALL the Judicial Assistant to confirm these procedures, hearings, to see if your documents have been received or signed by the Judge and/or for technical support using the Court Management System (CMS).

You can confirm your hearing by calling the scheduling party. When a hearing is set or cancelled, the Court Management System (CMS) will notify all parties registered with the E-Portal via email. Please notify the Court reporter of any cancellations.

(e) Motions for Summary Judgment – Foreclosure cases.

(1) How were the parties served?

(2) If there was a substitution of plaintiff, is a supplemental or amended pleading required for transactions post complaint (Rule 1.190(d))?

(3) Have all of the parties answered or been defaulted?

(4) If there are Affirmative Defenses, are they addressed by the Affidavit of Indebtedness (“AOI”)?

(5) Does the AOI comply with 90.803(6) and Yisrael v. State, 993 So.2d 952, 956-958 (Fla. 2008)? Are the business records attached?

(6) If there was a change in servicers is there an Affidavit or Declaration for the business records of each servicer?

(7) If the complaint pleads that there is an “owner” other than plaintiff, is there some proof regarding the authorization of the plaintiff to act on behalf of the “owner”?

(8) If the complaint pleads a “lost note” count and the note is no longer “lost” was the complaint amended? Feltus v. U.S. Bank, 80 So.3d 375 (Fla. 2d DCA 2012).

(9) Is the original note, with all allonges, present so it can be cancelled? Does it run to the plaintiff or is it endorsed in blank? Does it match the copy attached to the complaint?

(f) Motions for Default Final Judgment.

A hearing may not be required if the Plaintiff has pleaded a specific dollar amount in the complaint. Please include a copy of that portion of the complaint that states the specific dollar amount with your AOI. If the Plaintiff is seeking any relief beyond well-pleaded liquidated damages, a hearing is required, Minkoff v. Caterpillar Financial Services Corp., 103 So.3d 1049 (Fla. 4th DCA 2013). Attorney fees and other unliquidated damages will require either an evidentiary or a summary judgment hearing. Quiet Title and Partition actions require an affidavit or certified copy of the deed upon which you rely.

LOCAL RULE 12 | HEARINGS

(a) Generally.

All hearings must be coordinated with opposing counsel. A courtesy copy of the motion and all related papers must be uploaded onto the CMS system “supporting documents” at least four (4) business days prior to the hearing and should include the below:

Please Note: DO NOT Mail, Fed Ex or UPS hard copies of pleadings, motions or supporting materials for any hearing. All motions and related papers must be uploaded as Supporting Documents and must be uploaded in time for the Court’s review before the hearing.

(1) The online scheduling receipt;

(2) The notice of hearing; (Note: the Notice of Hearing must include information on ZOOM. Please do not notice any physical hearings in the courthouse at this time.)

(3) The motion together with all items to which the motion is directed. For motions to dismiss, include the complaint. For discovery motions, include the subject discovery.

(4) Orders after any hearing should be uploaded to the CMS system for review/approval of the Court BUT should not be uploaded until after all parties review and approve of the language on the order.

(b) Uniform Motion Calendar (UMC).

Please see Local Rule 10A with regard to UMC limitations and good faith certifications. Judge Robinson will commence docket at 8:30 a.m. (MONDAY through FRIDAY)
(1) Judge Robinson attempts to review each matter prior to the hearing. If your matter is resolved, please timely cancel you hearing online in the same manner in which it was set. Where possible, please cancel by 3:00 p.m. on the business day prior to the hearing. If you have any difficulty with Online Scheduling please email calendar@17th.FLCourts.org.

(2) Matters will be heard on a “first come, first served” basis. If opposing counsel is not present, please call them and if acceptable to do so text said counsel.

(c) Special Set Hearings – 15 and 30 minutes.

Special Set Hearings for up to 30 minutes may be set online. Please do not contact Ms. Dyson to set a hearing requiring 30 minutes or less or to confirm the hearing after it has been scheduled.

(d) Special Set Hearings – Over 30 minutes.

Any hearings over 30 minutes must be reviewed by the Court before any dates are provided. Please provide via email, remember to copy all parties to the email (please do not mail in hard copies) a copy of the motion (with all attachments) and any case law to the Court and indicate on a cover letter how much time is requested for both sides. Also, please include correct email addresses for all parties. You should contact Ms. Dyson via email (copy all parties) within a few days after receipt of the documents, for potential hearing dates. Once a date has been agreed to by all parties, please advise Ms. Dyson by email. Ms. Dyson will then authorize you, by email, to serve and file a notice of hearing for the appropriate date. Failure to strictly comply with this procedure may result in the inability to schedule future special set hearings.

(e) Cancellation of a Special Set Hearing.

In accordance with Local Rule 10A special set hearings may not be cancelled absent an agreement on the merits or court approval. If your matter is resolved, please cancel your hearing online in the same manner in which it was set. Please cancel as soon as possible so that someone else may use the time slot. Otherwise, please cancel by 3:00 p.m. on the business day prior to the hearing. Notify the court reporting service.

(f) Telephonic Appearances at Hearings.

Requests for phone hearings and/or appearances by phone will be addressed in accordance with Fla. R. Jud. Adm. 2.530. Please include with your motion an order indicating the name of the attorney who will be appearing via telephone for the hearing. The Court will initiate the call. The Court utilizes the use of Court Call.

(g) Attorney Fee Hearings.

An attorney fee hearing will not be scheduled until there has been compliance with the attorney fee scheduling order. (see last page of procedures). Please provide Ms. Dyson with a copy of your attorney fee motion so that a scheduling order may be issued by the Court.

(h) Emergency Hearings.

Please see Administrative Order # 2021-50-CIV

(i) Case Management Hearings.

The Court welcomes case management hearings and encourages the use of agreed Case Management Orders.

LOCAL RULE 13 | SPECIAL SET HEARING DOCKETS 2021

Dates and time slots for morning special sets 15 - 30 minutes are available/appear online, please discuss and agree with opposing party(s) before scheduling.

Please Note: DO NOT Mail, Fed Ex or UPS hard copies of pleadings, motions or supporting materials for any hearing. All motions and related papers must be uploaded as Supporting Documents and must be uploaded in time for the Court’s review before the hearing.

LOCAL RULE 14 | TRIAL DOCKETS 2022/2023

2023
Calendar Call Dates
Trial Week PeriodCalendar Call Start Time in 2023
ATTENTION
(Parties can longer schedule their own calendar calls. Please schedule a UMC hearing for this issue)
January 3, 2023January 9 - January 2710:30
February 6, 2023February 13 - March 310:30
March 6, 2023March 13 - March 3110:30
April 3, 2023April 10 - April 2810:30
May 1, 2023May 8 - May 2610:30
June 5June 12 - June 3010:30
July 6July 20 - July 2810:30
August 7August 14 - September 110:30
August 28September 11 - September 2910:30
October 2October 9 - October 2710:30

LOCAL RULE 15 | TRIAL EVIDENCE

All trial evidence should be pre-marked (alphabetically) and agreed to prior to the day of trial. All exhibits stipulated to by the parties shall be numbered. You will be provided with exhibit stickers along with instructions on how the exhibits should be labeled. All exhibits are to be provided to our in-court clerk by 9:30 a.m. the day of the trial. To the extent possible, evidentiary disputes must be addressed prior to trial. Any video which will not be played in its entirety must be edited prior to trial.

For Information on Evidence Presentation System in courtrooms please review this video:
https://youtube/V8aqOA0fZ5g

LOCAL RULE 16 | COURT HOLIDAYS AND SUSPENSION DATES 2022/2023

December 26, 2022Christmas Day (Observed)
January 2, 2023New Year’s Day (Observed)
January 16, 2023Martin Luther King Day
April 7, 2023Good Friday
May 29, 2023Memorial Day
June 19, 2023Juneteenth
July 4, 2023Independence Day
September 4, 2023Labor Day
September 25, 2023Yom Kippur
November 10, 2023Veterans’ Day
November 23, 2023Thanksgiving Day
November 24, 2023Friday after Thanksgiving
December 25, 2023Christmas Day

LOCAL RULE 17 | ELECTRONIC ORDERS AND JUDGMENTS

NOTE: THIS DIVISION ACCEPTS ALL ORDERS VIA ELECTRONIC SUBMISSION

(a) Generally.

(1) Orders and Judgments may be uploaded. Do not include correspondence, motions or stipulations. Motions and stipulations must appear on the docket prior to uploading.

(2) The signature line must be on the last page of the submission. However, the signature line must not be on a page alone.

(3) Please verify that all email addresses are accurate.

(4) If an order has been uploaded, please do not email or mail it (do not duplicate your efforts).

(b) Orders After Hearing.

The order reflects the court's ruling at a previous hearing and the language is agreed to by all parties. The order must contain the date of hearing and type of motion.

(c) Local Rule 10A Discovery Orders.

See Local Rule 10A. If there has been a request for an extension of time an ex parte motion may not be utilized.
The Online Electronic Scheduling System for the 17th Judicial Circuit will send the approved electronic order to those registered with the state E-portal. Electronic orders will not be mailed.

If you have additional questions please see http://www.17th.FLCourts.org/eordersFAQ

If you have technical questions or need assistance with the Online Scheduling System or with the submission of e-orders, please e-mail the JIS Department at: calendar@17th.FLCourts.org

Additional Assistance can be found at:
http://www.17th.FLCourts.org/images/stories/17th_pdf_files/AttorneyCMSManual.pdf
Please let us know if you have any suggestions.

(revised March 2023)

LOCAL RULE 18 | SCHEDULING ORDER ATTORNEY FEES & COSTS NO ENTITLEMENT

IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT
IN AND FOR BROWARD COUNTY, FLORIDA

Plaintiff(s)



vs.




Defendant(s)
)
)
)
)
)
)
)

CASE NO: ________________

JUDGE MICHAEL A. ROBINSON

Scheduling Order Attorney Fees & Costs No Entitlement

Plaintiff’s Motion for Attorney Fees is pending before this Court. Counsel for the parties are hereby ordered to comply as follows:
1. The parties, through counsel, shall initially either agree, or resolve to disagree, on any and all entitlement issues arising out of the pending Motion for an Award of Attorneys Fees/Costs. The Court will hear argument and decide the movant’s entitlement to fees before scheduling a hearing to resolve any disputes as to the proper amount of any fees or costs.

2. Within fifteen (15) days of issuing the Order of Entitlement to Attorney Fees, the moving party shall provide opposing counsel with a copy of all invoices, time records, cancelled checks, records evidencing services rendered, the name, address and C.V. of their expert witness, and any other supporting documentation (which may be the entire file other than the records kept in the Court file and any transcripts) for the fees and costs requested.

3. Within fifteen (15) days of receiving movant’s disclosures, the non-moving party shall respond in writing to each line item of cost and fees. The Response shall agree to each item in whole or in part, or state the legal and factual basis for any objection of the whole or part in question, provide the name, address and C.V. of their expert, and cite any supporting legal authority. If there is an agreement as to the entitlement in part to a particular fee/cost item, but disagreement with the total amount requested, the non-moving party shall state the amount believed to be reasonable.

4. Within fifteen (15) days of receipt of the agreements, objections and disclosures, the moving party shall reply in writing to each objection, either agreeing with the objection, or if not, citing any contrary legal authority.

5. The attorneys for all interested parties shall meet and review the disputed items, reduce any stipulations to writing, and provide the Court with an Agreed Order. Thereafter, the experts may be deposed.

6. The parties and counsel are directed to exercise good faith in complying with the terms of this Order. The Court will first consider Motions to Compel Compliance with this Order, and if necessary may then consider Motions for Sanctions with regard to unreasonable delays, requests for fees and/or costs, any untenable objections thereto, or any other failure to follow any Order Compelling Compliance.

7. Upon request by either party or the Court, this matter may be referred to mediation.

8. The hearing to determine the amount of fees/costs to award shall not take place until all counsel file a certification with the Court that all discovery in connection with all fee/cost issues, has been completed. Any lack of cooperation regarding certification or discovery shall be brought to the Courts attention as soon as possible by way of Motions to Compel Compliance with this Order.
Done and ordered in Broward County, Florida on this _______ day of ________________, 20_____.
MICHAEL A. ROBINSON
CIRCUIT COURT JUDGE
Copies furnished:
All Parties of Record
Congratulations! You're now booked up on Broward County's Local Rules of Court (Division 13)!

You might need to reference them during your pursuit of justice.

For instance, you might need to understand certain local rules to recover from the damages that lawbreaking judges/lawyers have inflicted upon you (see this example of a Florida judge who outright committed perjury).

As always, please get the justice you deserve.

Sincerely,



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