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Confer in good faith with opposing counsel about the discovery dispute
Speak by phone or in person where required — several divisions state that conferral means counsel actually talk, not just exchange emails.
Rule: Conferral Required Before Filing Nondispositive Motions — Fla. R. Civ. P. 1.202 →Document the conferral
Record date, time, method, participants, and outcome — you will certify this.
Include a certificate of conferral in the motion
State the specific efforts made to resolve the dispute.
Rule: Conferral Required Before Filing Nondispositive Motions — Fla. R. Civ. P. 1.202 →E-file through the Florida Courts E-Filing Portal
Rule: E-Filing Through the Statewide Portal — Florida Courts E-Filing Portal →Check the division's instructions: motion calendar vs. special set
Discovery motions are often motion-calendar matters, but time limits vary by division.
Coordinate the hearing date with opposing counsel before setting
Some divisions require a certificate of good-faith conferral on every hearing notice.
Rule: Good-Faith Conferral Before Setting Any Hearing — Division AO →Submit hearing materials per the division's instructions
Some judges require materials in advance of the hearing.
Submit the proposed order in the division's required format
Word/DOCX is commonly required; check the division page.
Rule: Proposed Orders: Word Format via Online Services — Division AO →Steps marked “check the division's instructions” vary by judge — that variance is exactly what BenchPath tracks. Search your county and division for the specific requirements before relying on the generic sequence. Not legal advice.