(a) Motions for Rehearing.
(b) Motions to Continue Trial.
(c) Motions to Withdraw.
When an Order is granted on a Motion to Withdraw Attorney of Record, it is the attorney’s responsibility to log on to the State Portal and remove his name permanently from the service list https://myflcourtaccess.com/.
(d) Motions for Summary Judgment – Generally.
(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
2. Sarah Jones owns Blackacre. Exhibit B 12.
Respondent’s Opposing Statement of Material Facts
Admitted that Blackacre is located at 123 Main Street. Exhibit A 1. Denied that the property is vacant. Exhibit C at 5.2. Sarah Jones owns Blackacre. Exhibit B 12.
Denied as phrased. Admitted that the last recorded deed to Blackacre names Sarah Jones. Exhibit B 12.
(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.
(e) Motions for Default Final Judgment.
Last Revised ©
Seventeenth Judicial Circuit of Florida // Fabienne E. Fahnestock, Circuit Court Judge
Fort Lauderdale, FL 33301 // (954) 831-7336
Fort Lauderdale, FL 33301 // (954) 831-7336


