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1 verbatim requirement on discovery disputes applying circuit-wide.
Sixteenth Judicial Circuit (Monroe County — the Florida Keys). Divisional practices change without notice; the judge's own published page controls. Procedural information only; not legal advice.
Verbatim requirement published by the Sixteenth Circuit for all divisions on discovery disputes, captured 2026-07-24. Reproduced exactly as published; whitespace normalised only. • No ex parte Motion to Compel Discovery shall be entertained unless the motion bears a certificate of moving counsel to the effect that he/she has contacted opposing counsel and attempted to resolve the discovery dispute without a hearing, but that the matter could not be resolved.
No ex parte Motion to Compel Discovery shall be entertained unless the motion bears a certificate of moving counsel to the effect that he/she has contacted opposing counsel and attempted to resolve the discovery dispute without a hearing, but that the matter could not be resolved.
Reviewer note: Source sha256: 6d6afaa765c11161855ed33e01832e5256b8d311c08b53d0100844a83afcf7af. Corpus categories folded into this record: discovery dispute. Published during the completeness pass — the 2026-07-24 arbitration verified 67 verbatim requirements across this bench but published only 6 rules.
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).