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22 verbatim requirements from document (unlisted) [unlisted] AnnoyingThingsLawyersDo.
20th Judicial Circuit. Procedural information only; not legal advice.
Verbatim from https://www.ca.cjis20.org/pdf/judge/AnnoyingThingsLawyersDo.pdf, harvested 2026-07-25; whitespace normalised only. • Then the other party must either respond with further testimony or they will leave that suggestion of untruthfulness or contradiction in the evidence before the finder of fact. • Many petitioner’s lawyers seeking alimony call the respondent opposed to alimony as the petitioner’s first witness in order to prove he has the ability to pay, which overlooks she must first prove financial need before the decision moves to a determination of his ability to pay. • Do not let him try to prove it during the petitioner’s case in chief by nonresponsive answers, which will be the inevitable result of calling him as an adverse party witness and asking him to do more than just identify financial documents that the petitioner needs to have admitted to prove an ability to pay. • I sustain objections to over broad requests to produce, although a surprising number of lawyers fail to object to over broad requests within 30 days of service. • These paragraphs do not ask for any “designated documents,” which is what the rule requires. • In a family case, a request is also duplicative and redundant to the extent that it asks for documents that are required to be disclosed under Rule 12.285, and so it is improper because it asks for the same document twice. • The relevance and materiality for the production of further specific, designated documents under Rule 1.350 is not presumed and must be demonstrated. • Rules 1.350, Rule 1.351, and Rule 1.410 do not grant a party the right to a search warrant for everything a party or witness may have just to see what might be there. • Such a request is not “discovery” of the opponent’s relevant documents; rather, such a request is a “fishing expedition.” The discovery rules do not permit “fishing expeditions.” All of the requested documents are not related to a pending claim or issue or likely to lead to admissible evidence at trial, which is the proper scope of discovery. • Requests under all of these rules must seek a document designated with sufficient particularity to suggest that it exists. • Discovery requests must (1) be “related to any pending claim or defense”, Walter v. • Page, 638 So.2d 1030, 1031 (Fla. 2d DCA 1994), and (2) must be “reasonably calculated to lead to the discovery of admissible evidence.” American Honda Motor Company, Inc., v. • Further, requests for documents or papers must be directed at specific documents that are likely to be in the possession of the other party. • These rules do not grant a party a search warrant for everything a party or witness may have. • If objection is made, the party serving the subpoena shall not be entitled to inspect and copy the materials except pursuant to an order of the court...” So, inspection and copying by the requester is what these rules allow. • Lawyers may not argue “I think” or “I believe.” Their personal beliefs about a witness or the evidence are irrelevant. • The older lawyers also taught me that I must never directly accuse a witness or a party of “lying” while I was questioning them. • For this reason, defendant's motion for a new trial must be granted.’ • Instead, they claim that reversal is required because defense counsel did not object during the trial. • Wallshein, 671 So.2d 872 (Fla. 3d DCA 1996), but even in Forman the appellate court cites and quotes treatises on trial practice that condemn such behavior, saying it is “improper and unethical,” and the court held in a footnote: “In so ruling we do not mean to preclude a trial court from taking a stricter view, sustaining the objection, and directing counsel to rephrase the argument.” • In passing, I must note that the treatises such as those cited in Forman should be read and reread by lawyers who enter into trial practice. • For reasons I will never understand, lawyers in family cases and civil bench trials seem to think -- 9 of 10 -- 10 that these authorities do not apply to bench trials or that such improper and unethical behavior is acceptable in a bench trial.
Then the other party must either respond with further testimony or they will leave that suggestion of untruthfulness or contradiction in the evidence before the finder of fact.
Reviewer note: Order PDF sha256: ae3012f7b4dba21c30fdc2c7497a722d2d67ab9b31a895d4336146ec3362f10a. 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.