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40 verbatim requirements from Guidelines Regarding Privilege Logs and Procedures for In-Camera Review.
Fourth Judicial Circuit (Duval, Clay, Nassau). Procedural information only; not legal advice.
Verbatim from https://www.jud4.org/getContentAsset/b0dfa94a-4846-4631-9212-3e87c2f6eb86/135b97c9-84fa-4e82-b956-0fbccec4aa1f/CV-E-Guidelines-Regarding-Privilege-Logs-and-Procedures-for-In-Camera-Review.pdf?language=en, harvested 2026-07-25; whitespace normalised only. • A party withholding information otherwise discoverable by claiming it is privileged shall make the claim expressly by preparing and filing an adequate privilege log compliant with Rule • Practice to “include at a minimum (for documents), sender, recipients, title or type, date and subject matter”1 and the pages of each document listed on the amended privilege log shall be bates numbered. • These categories, especially this last category, must be sufficiently detailed to allow the court to determine whether the discovery opponent has discharged its burden of establishing the requirements expounded upon in the foregoing discussion. • The party requesting the in camera review of documents asserted to be privileged must file a Notice of Request for In Camera Review. • The notice shall identify the documents requested for review by excerpting the complete information provided in the objecting party’s privilege log for each document. • A courtesy copy of the Notice of Request for In Camera Review shall be provided to the Court’s Judicial Assistant by email. • If any of the parties determine that an evidentiary record must be developed for the Court to consider during its in camera review, then the parties must meet and confer to prepare an appropriate Order scheduling the evidentiary hearing to develop a relevant evidentiary record for consideration during the in camera review and establishing appropriate deadlines for matters to be disclosed, discovered, and completed prior to the hearing. • To facilitate this meet and confer process the parties must comply with Division CV-E Procedures for Scheduling and Hearing • The documents appearing in the request for in camera review shall be provided to the Court within 7 business days of receipt of a Notice of Request for In Camera Review if review of 25 documents or less is requested, and within 10 days if review of more than 25 documents is requested. • For all documents submitted for in camera review pursuant to this Order, counsel for the party asserting the privileges raised shall send a cover letter to the Court’s chambers, enclosing documents for in camera inspection in a sealed envelope marked FOR IN CAMERA • The documents shall be produced with bates stamps in the order set forth in the Notice of Request for In Camera Review. • No argument or other information shall be included in the cover letter. • January 2025 (without the enclosed records) shall be provided contemporaneously to all parties’ counsel. • Within 10 days of the party seeking discovery serving a “Notice of Request for In Camera • Request for In Camera Review and memorandum addressing the documents to be reviewed shall be provided to the Court’s Judicial Assistant by email. • Any amendments to the privileges previously asserted shall also be filed and submitted within this initial 10-day submission period. • A courtesy copy of any amendments to the privileges shall be provided to the Court’s Judicial • No further amendments to the privileges asserted as to the documents at issue in the Notice of Request for In Camera Inspection shall be made absent the filing of a Motion to • Within 10 days of any submission by the party asserting the privileges raised, the party seeking discovery may make a submission to the Court also in the form of a memorandum directed to the applicability of the privileges asserted. • A courtesy copy of the memorandum shall be provided to the Court’s Judicial • The party asserting the privileges raised may then file a reply or rebuttal submission to the submission within 5 days of service of the discovery seeking party’s submission. • A courtesy copy of the reply or rebuttal submission shall be provided to the Court’s Judicial • This shall be the extent of any submissions made on these Notices of Request for In Camera inspection by any of the parties. • The parties shall meet and confer to coordinate revisions to the non-party subpoenas that are not subject to objections based on Florida’s • During the same meet and confer the parties must coordinate revisions to the non-party subpoenas that are subject to objections based on Florida’s Constitutional right to privacy or other privilege, confidentiality, or trade secret to accurately reflect the Court’s rulings on any non-privilege objections to permit the party opposing such discovery to issue such subpoenas and serve the subpoenas on the non-parties at the sole expense of the party opposing such discovery. • During the same meet and confer, as it concerns non-party subpoenas that are subject to objections based on Florida’s Constitutional right to privacy or other privilege, confidentiality or trade secret, the parties shall further revise the subject subpoenas duces tecum to request from each of the subpoenaed non-parties that all documents responsive to the subpoenas are bates numbered by each subpoenaed non-party prior to production using a unique prefix (which instruction must be provided within the subject non-party subpoenas to be issued by the party opposing such discovery). • The party opposing such discovery shall bear the cost of bates numbering the copies of the documents responsive to the subpoenas that delivered to the party opposing such discovery and to the Court. • Counsel for all parties shall be copied or otherwise included on any communications with the subpoenaed non-parties or with any other third parties utilized to effectuate service of the subpoenas, and copies of any subpoena served shall be provided to counsel for all parties. • There shall be no communications by the parties or their counsel with the subpoenaed non-parties, directly or indirectly, that interferes with, or attempts to avoid or limit the production if, the documents required to be produced pursuant to the subpoenas as served. -- 4 of 6 -- 5 • The parties shall have a continuing obligation to meet and confer over coordination of service and compliance with the subpoenas with respect to any matter not addressed by these procedures, and the partes are entitled to reserve their rights to request relief from the Court in the event of any matter not resolved in the meet and confer process or any party’s failure to comply with these procedures. • All documents produced in response to the subpoenas by the subpoenaed non-parties shall be made returnable in exact duplicate both to the party opposing such discovery and to the Court, Division CV-E (c/o Hon. • The Party opposing such discovery shall bear the cost of obtaining the copies of the documents responsive to the subpoenas that are delivered to the party’s counsel opposing such discovery, and the party seeking discovery shall bear the cost of obtaining the copies and delivering copies of the documents responsive to the subpoenas that are delivered to the Court. • The party opposing discovery shall promptly, but no later than within five (5) business days, notify Defendant of the receipt and date thereof of any documents from a subpoenaed non-party. • Within thirty (30) days of the objecting party’s receipt of documents produced by any subpoenaed non-party, the objecting party shall produce to the party seeking discovery all documents and related correspondence from the subpoenaed non-parties that are not subject to any objection by the party opposing discovery based on Florida’s Constitutional right to privacy or other privilege, if any, confidentiality, or trade secret. • If necessary, within thirty (30) days of the objecting party’s receipt of documents produced by any subpoenaed non-party, the party opposing such discovery shall prepare and file and serve on the party seeking discovery an adequate privilege log compliant with the guidelines regarding privilege logs set forth on page 1 supra, which log shall set forth each objection, if any, to production of any document (in full or in part) based on Florida’s • The parties shall comply with the Court’s specific procedures for conducting an in camera review set forth on pages 2 and 3 supra. • Notice of Request for In Camera Review, the parties must comply with the briefing and submissions process and timeline set forth in paragraph 5 on pages 2 and 3 of the In Camera • If the parties agree that the in camera review can be conducted by the court based on the briefing, submissions, and the pleadings alone, without an evidentiary hearing, the parties must prepare and file a stipulation confirming the same and email a courtesy copy of the filed stipulation to the Court’s Judicial Assistant. • If the parties determine that an evidentiary record must be developed for the Court to consider during its in camera review, then the parties must comply with the Procedures for Scheduling and Conducting an Evidentiary Hearing set forth below. -- 5 of 6 -- 6 • Within ten (10) days after the Court issues an order following its in camera review of the Privilege Logged Documents, the party opposing such discovery shall produce to the party seeking discovery all Privilege Logged
A party withholding information otherwise discoverable by claiming it is privileged shall make the claim expressly by preparing and filing an adequate privilege log compliant with Rule
Reviewer note: Document sha256: fddda1ad8596bc09f1112b6db2e47c9c3316001234215d3eff4a0677e8643fa0. Extracted from the document'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.