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2 verbatim requirements published by Palm Beach Division E on discovery disputes.
Palm Beach County, Fifteenth Judicial Circuit — Division E only. Divisional instructions change without notice; the division page is the controlling text. Procedural information only; not legal advice.
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Unlock free →Motions to Compel Discovery shall be in writing and shall certify that counsel has attempted in good faith to resolve the issues with opposing counsel but has been unable to do so. Said motion shall also describe what independent efforts counsel has made to obtain the discovery sought.
Reviewer note: Complete-coverage record. Page sha256: df2fd27d420a071fc2ea119921daaa65534ea0c76391c35de1f4ead5fcb2f9c3. Clauses under 60 characters (navigation labels and section headings) were excluded; 628 such fragments were dropped circuit-wide. A separate curated highlight rule may cover one of these clauses with a sharper title — de-duplication is an open curation task, not a data gap.
Every party setting a hearing in Division AO must first confer in a good-faith effort to resolve the matter, and every hearing notice must include a certificate of that conferral. The division instructions state that conferral requires counsel to actually talk.
Under the 2025 case-management amendments, a movant must confer with the opposing party in a good-faith effort to resolve a nondispositive motion before filing it, and must include a certificate of conferral.
CV-E layers a second conferral on top of Rule 1.202: certify conferral before filing the motion (Exhibit A) and again before scheduling it for hearing (Exhibit B).