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26 verbatim requirements from document (unlisted) [unlisted] 53cp4.
20th Judicial Circuit. Procedural information only; not legal advice.
Verbatim from https://www.ca.cjis20.org/pdf/judge/53cp4.pdf, harvested 2026-07-25; whitespace normalised only. • Any party wishing to have motions heard at the pretrial conference, in addition to complying with the applicable rules, must notify the judge's judicial assistant of the motion sought to be heard and the approximate amount of time required to dispose of same. • All parties, or if represented, their respective counsel are required to attend the pretrial conference unless an agreed pretrial order has been submitted to the court and an order approving the agreed pretrial order has been entered by the Court. • The attorney who expects to conduct the actual trial of the cause is required to attend the conference. • Any joint motion for continuance must be signed by all parties and their respective counsel, and must include detailed reasons for the request. • All discovery, including all depositions, whether for discovery, trial or otherwise, shall be completed no later than thirty (30) days prior to trial . • Disclosure of exhibits and witnesses (lay and expert) shall be no later than forty five (45) days prior to trial. • All dispositive motions addressed to the pleadings, and for summary judgment, shall be filed and scheduled for hearing prior to Pretrial Conference . • No further motions or amendments shall be entertained after said deadline, except upon proof of lack of knowledge by the movant of basis for the motion, good faith by the movant, prejudice to the moving party and lack of prejudice to non-moving parties. 5 Mediation. • The plaintiff, within twenty (20) days hereof, shall submit an agreed mediation order • The mediation conference shall take place no later than twenty (20) days prior to trial. • Any motion to exclude the cause, or any party thereto from mediation must be filed within thirty (30) days from the date hereof and set for hearing as soon as practicable. • Plaintiff shall, at least ten (10) days prior to pretrial conference OR thirty (30) days prior to trial if no pretrial conference ordered, file with the Clerk of the Circuit Court and serve a copy on opposing counsel: i. a short statement of the facts on which plaintiff bases his cause of action; ii. an itemized statement of the special damages that plaintiff expects to prove; iii. if defendant has filed a counterclaim; plaintiff will comply with Defendant iv. a schedule of all exhibits and documentary evidence that plaintiff expects to offer during trial. • Said list shall also include a short concise statement of the testimony anticipated of each witness, as well as the anticipated opinions of each expert witness. • If a mediator cannot be agreed upon, then the mediation order shall be submitted to the court for the appointment of a mediator. -- 3 of 5 -- • Defendant shall at least ten (10) days prior to pretrial conference OR thirty (30) days prior to trial if no pretrial conference ordered, file with the Clerk of the Circuit Court and serve a copy on opposing counsel: i. the facts constituting plaintiff's cause of action that defendant will admit; ii. if defendant has filed affirmative defenses, a statement of the facts on which defendant bases such a defense; iii. if defendant has filed a counterclaim or cross-claim, defendant will comply with Plaintiff Instructions 6(A)(i) and 6(A)(ii); iv. a schedule of all exhibits and documentary evidence that defendant expects to offer during trial. • All parties required to file a pretrial compliance herein shall serve a copy upon the undersigned by hand or mail at her office at least three (3) days before the pretrial conference. • Counsel for all parties shall be prepared to state or discuss at pretrial conference: i. the number of peremptory challenges requested; ii. any matters to be judicially notice; iii. which exhibits expected to be offered by opponent can be admitted without an authenticity predicate or any predicate at all; iv. the length of trial; v. any unique questions of law or unique elements of damages; vi. the best settlement offer authorized by client; vii. the need for a case management conference before the trial. • The court may not be in a position to allow a witness to testify "out of order" or adjust its schedule for the convenience of a witness, especially if such will inconvenience the jury, or the opposing party. • All motions in limine shall be in writing, filed and served prior to Docket Sounding. • Counsel filing said motions in limine shall schedule the motions in limine to be heard before trial, but they may be heard immediately before trial if prior hearing time is unavailable. • All parties are required to file jury instructions, standards and specials, and verdict forms tailored to the case no later than the day of docket sounding. • Counsel shall make another good faith effort in the days before the trial to stipulate into evidence as many exhibits as possible to avoid wasting time at trial laying foundations. • All stipulated exhibits shall be pre- marked by the Clerk before the trial begins. • Should the case settle prior to the day of trial, counsel for the plaintiff or defendant shall notify the court in writing. • Counsel desiring the services of a court reporter at trial must make advance arrangements with the reporter. • Please contact the Operations Division Manager, whose office is located at Lee County Justice Center, 1700 Monroe Street, Fort Myers, Florida 33901, and whose telephone number is (239) 533-1700, within 2 working days of receipt of this notice; if you are hearing or voice impaired, call 1-800-955-8771. -- 5 of 5 --
Any party wishing to have motions heard at the pretrial conference, in addition to complying with the applicable rules, must notify the judge's judicial assistant of the motion sought to be heard and the approximate amount of time required to dispose of same.
Reviewer note: Order PDF sha256: ee2ddd6846b140dfdc0b29097cfc26e314e0e70c7a0bb9171b9ac077a26cd8af. Extracted from the order's own text layer.
Judge Bell caps motions and responses at 5 pages for UMC hearings and 12 pages for special-set hearings.
Judge Alijewicz requires every motion for attorney's fees and/or costs to attach a document detailing time records — no records, no fee award.
Judge Corlew bars informal contact: every communication with the Court must be in writing, filed with the Clerk, with copies furnished to all parties — and no calls to the JA to schedule or cancel UMC.