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19 verbatim requirements from Procedures on Motion to Tax Costs and Award Attorney Fees.
Fourth Judicial Circuit (Duval, Clay, Nassau). Procedural information only; not legal advice.
Verbatim from https://www.jud4.org/getContentAsset/b8690867-32cd-4c4f-a452-4b8230589eb9/135b97c9-84fa-4e82-b956-0fbccec4aa1f/PROCEDURES-ON-MOTION-TO-TAX-COSTS-AND-AWARD-ATTORNEY.pdf?language=en, harvested 2026-07-25; whitespace normalised only. • If the parties are unable to agree on the amount of attorney’s fees and costs to be awarded, the matter shall be set for an evidentiary hearing and counsel, to ensure an orderly and efficient presentation and/or resolution of this issue, shall comply with the following Procedures on Motion to Tax Costs and Award Attorney’s Fees prior to such an evidentiary hearing: • Counsel for the moving party shall take the lead in coordinating the mediation and submit a proposed mediation order. • The costs of the mediation shall be shared equally by the parties involved in the pending motion. • Within thirty (30) days of the Order, the movant(s) shall submit to the parties from whom fees or costs sought, the name and address of the fee/cost expert(s) that will be used in support of the motion, along with copies of all billing records, time sheets, invoices for costs, and any other documentary evidence relating to attorneys’ fees and/or court costs claimed (collectively “the claim”). • Within thirty (30) days of the movant’s itemized claim described in paragraph two (2) above, counsel for any non-moving party opposing any part of the claim shall respond in writing to each item of cost and each fee entry submitted by the movant. • This response shall state whether counsel agrees or objects to said item. • For each objection counsel shall state the basis and cite the supporting legal authority. • They shall also identify the name and address of any expert it intends to use in rebuttal. • Within thirty (30) days of receipt of said objections, the moving party shall respond in writing to each objection, stating whether said party concurs with the objection and, if not, state the basis and cite the contrary legal authority. • In the event there is an agreement to a particular cost item or fee request, but disagreement with the amount, the non-moving party shall state the objection and the amount believed to be reasonable. • The Statewide Uniform Guidelines for Taxation of Costs in Civil Actions1 shall be used in an attempt to resolve disputes over taxation of costs. • Not later than fifteen (15) days immediately preceding the mediation, counsel for the parties shall meet and confer to review the disputed items, reduce any stipulations to a written joint pre-hearing stipulation pursuant to the provisions set forth below. • Each party shall disclose their experts’ opinions in affidavit form fifteen (15) days prior to the mediation. • Upon completion of the mediation requirement set forth above, counsel shall provide to the Court, and file with the Clerk, in writing, a joint pre-hearing stipulation containing the following: • Counsel shall meet and confer to prepare an appropriate proposed Order scheduling the evidentiary hearing on the Motion to Tax Costs and Award Attorney’s Fees. • To facilitate this meet and confer process the parties must comply with Division CV-E Procedures for Scheduling and Hearing Motions Requiring Evidentiary Hearing published on the Court’s website and should utilize the Court’s template for Order Scheduling Motion for Evidentiary Hearing and Pre- • Any memorandums of law must be filed no later than three (3) business days before the date of the hearing and a copy provided directly to the Court. • Any caselaw must be submitted with the memorandum and highlighting is not only permitted but also appreciated by the Court. • In the event the Court takes any costs and attorney’s fees matters under advisement, counsel for the movant(s) and non-movant(s) opposing any part of the claim shall comply with
If the parties are unable to agree on the amount of attorney’s fees and costs to be awarded, the matter shall be set for an evidentiary hearing and counsel, to ensure an orderly and efficient presentation and/or resolution of this issue, shall comply with the following Procedures on Motion to Tax Costs and Award Attorney’s Fees prior to such an evidentiary hearing:
Reviewer note: Document sha256: c780e96faa2e1bdffbdf6c87266fdcd4687c4f53e6e64972026bdbd7a310860f. 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.