FLORIDA MOTION FILING CHECKLIST
Comprehensive Guide for Circuit and County Court Practitioners
Court: Circuit Court / County Court, [________________________________] Judicial Circuit
County: [________________________________], Florida
Case Number: [________________________________]
Division: [________________________________]
Assigned Judge: [________________________________]
Motion Type: [________________________________]
Filing Attorney: [________________________________]
Florida Bar Number: [________________________________]
Date Prepared: [__/__/____]
PART I: PRE-FILING REQUIREMENTS
A. Conferral Requirement — Fla. R. Civ. P. 1.202 (Effective January 1, 2025)
Mandatory conferral applies to ALL non-dispositive motions unless exempted.
☐ Determine whether the motion is subject to the conferral requirement
☐ Identify applicable exemptions (see list below)
☐ If conferral is required, confer with opposing counsel in good faith before filing
☐ Document the date, method, and substance of the conferral
☐ Prepare the certificate of conferral for inclusion in the motion
Motions EXEMPT from Conferral (Fla. R. Civ. P. 1.202(a)):
☐ Motion for injunctive relief
☐ Motion for judgment on the pleadings
☐ Motion for summary judgment (Fla. R. Civ. P. 1.510)
☐ Motion to dismiss for failure to state a claim (Fla. R. Civ. P. 1.140(b)(6))
☐ Motion to dismiss or to permit maintenance of a class action
☐ Motion to involuntarily dismiss an action
☐ Any motion where the movant or nonmovant is unrepresented by counsel (pro se)
Required Certificate of Conferral Language (Fla. R. Civ. P. 1.202(b)):
The certificate must be placed at the end of the motion, above the signature block, in substantially the following form:
"I certify that prior to filing this motion, I discussed the relief requested in this motion by [method of communication] on [date] with [opposing counsel/party name] and [the opposing party agrees/disagrees on the resolution of all or part of the motion]."
OR, if opposing counsel was non-responsive:
"I certify that prior to filing this motion, I discussed the relief requested in this motion by [method of communication] on [date] with [opposing counsel/party name] and the opposing party did not respond [describing with particularity all of the efforts undertaken to accomplish dialogue with the opposing party prior to filing the motion]."
OR, if the motion is exempt:
"I certify that conferral prior to filing is not required under rule 1.202."
Sanctions for Non-Compliance:
☐ Failure to confer may result in denial of the motion without prejudice
☐ Court may impose appropriate sanctions including fees and costs
☐ The motion may be stricken for failure to include the certificate of conferral
B. Standing and Jurisdiction Check
☐ Confirm the court has subject matter jurisdiction over the dispute
☐ Confirm the court has personal jurisdiction over all parties
☐ Verify venue is proper in this county (Fla. Stat. § 47.011 et seq.)
☐ Confirm the filing party has standing to bring the motion
☐ Check whether any stay or injunction prevents filing
☐ Verify the case has not been dismissed, closed, or transferred
C. Deadline and Timeliness Review
☐ Identify the applicable deadline or time limit for filing the motion
☐ Calculate the deadline using Fla. R. Jud. Admin. 2.514 time computation rules
☐ Account for any extensions previously granted by the court
☐ Confirm the motion is timely under all applicable rules and orders
☐ If a scheduling order exists, verify compliance with its deadlines
PART II: MOTION DOCUMENT REQUIREMENTS
A. Caption and Formatting (Fla. R. Civ. P. 1.100)
☐ Full case caption including:
- Court name (e.g., "IN THE CIRCUIT COURT OF THE [____] JUDICIAL CIRCUIT IN AND FOR [____] COUNTY, FLORIDA")
- Case number
- Division (if applicable)
- Party names and designations (Plaintiff/Defendant)
☐ Title of the motion (e.g., "DEFENDANT'S MOTION TO DISMISS PLAINTIFF'S AMENDED COMPLAINT")
☐ Motion clearly identified by rule number where applicable
☐ Professional formatting: standard margins, readable font (12-point minimum), double-spaced text
☐ Page numbers on all pages
B. Body of the Motion
☐ Introduction/Preliminary Statement: Brief identification of the moving party and relief sought
☐ Statement of Facts: Material factual allegations supporting the motion, with record citations
☐ Legal Authority: Applicable Florida Rules of Civil Procedure, Florida Statutes, and case law
☐ Argument: Application of the law to the facts
☐ Prayer for Relief: Specific, clear statement of the relief requested
☐ Certificate of Conferral: Required for non-dispositive motions (Fla. R. Civ. P. 1.202)
☐ Certificate of Service: Required on all motions (Fla. R. Jud. Admin. 2.516)
C. Supporting Memorandum of Law
☐ Determine whether a memorandum of law is required:
- ☐ Required by local rule: ☐ Yes ☐ No
- ☐ Required by court order: ☐ Yes ☐ No
- ☐ Advisable for complexity of issues: ☐ Yes ☐ No
If a memorandum is submitted:
☐ Statement of the issues presented
☐ Statement of facts with record citations
☐ Legal argument with case law citations (Florida cases preferred; federal authority as persuasive)
☐ Conclusion restating the relief requested
☐ Table of contents (if memorandum exceeds 25 pages)
☐ Table of authorities (if memorandum exceeds 25 pages)
☐ Complies with any local page limits
D. Supporting Affidavits and Evidence
☐ Affidavits attached (if required, e.g., summary judgment, temporary injunction)
☐ Affidavits based on personal knowledge (Fla. R. Civ. P. 1.510(c)(4))
☐ Affidavits set out facts that would be admissible in evidence
☐ Affiant is competent to testify to the matters stated
☐ Exhibits properly identified, tabbed, and referenced in the motion
☐ Deposition excerpts properly cited and attached (if applicable)
☐ Business records accompanied by records custodian affidavit (Fla. Stat. § 90.803(6))
E. Proposed Order
☐ Proposed order prepared (required by many local rules)
☐ Proposed order in editable format (typically Word) — check local requirements
☐ Proposed order includes:
- ☐ Case caption
- ☐ Title: "ORDER GRANTING [PARTY]'S MOTION TO [____]"
- ☐ Substantive ruling language
- ☐ Signature line for judge with "DONE AND ORDERED" block
- ☐ Copies-furnished block listing all counsel/parties
☐ Proposed order does not include attorney signature
☐ Proposed order submitted to judge's judicial assistant via the method required by the assigned division
PART III: COMMON MOTION TYPES AND SPECIFIC REQUIREMENTS
A. Motion for Summary Judgment (Fla. R. Civ. P. 1.510 — Amended Effective 1/1/2025)
Filing the Motion:
☐ Motion states that there is no genuine dispute as to any material fact
☐ Motion states that the movant is entitled to judgment as a matter of law
☐ Motion identifies each claim or defense — or the part of each claim or defense — on which summary judgment is sought
☐ Motion supported by affidavits, depositions, admissions, or other evidence (Fla. R. Civ. P. 1.510(c))
☐ Statement of undisputed material facts included (with citations to record)
☐ Filed and served consistent with any court-ordered deadlines
Response Deadline (NEW — Effective 1/1/2025):
☐ Nonmovant must serve a response no later than 40 days after service of the motion (Fla. R. Civ. P. 1.510(c)(5))
☐ Response must include a concise statement of the material facts in genuine dispute, with specific references to evidence in the record
☐ If additional time needed, file motion for extension under Fla. R. Civ. P. 1.090(b) BEFORE the 40-day deadline expires
Hearing Requirements:
☐ Hearing must be set at least 10 days after the deadline for serving a response (unless parties stipulate or court orders otherwise)
☐ Sufficient notice of hearing provided to all parties
☐ Reply materials (if any) filed and served before the hearing
Key Practice Notes:
☐ Failure to respond within 40 days may result in the court deeming movant's facts undisputed under Rule 1.510(e)
☐ Court may grant summary judgment without a hearing if the record supports it
☐ Florida now follows the federal Celotex/Anderson/Matsushita standard (as adopted in In re Amendments to Fla. R. Civ. P. 1.510, SC2020-1490)
B. Motion to Dismiss (Fla. R. Civ. P. 1.140)
☐ Motion filed within 20 days after service of the complaint (or other applicable time period)
☐ Grounds for dismissal identified under Fla. R. Civ. P. 1.140(b):
- ☐ (1) Lack of jurisdiction over the subject matter
- ☐ (2) Lack of jurisdiction over the person
- ☐ (3) Improper venue
- ☐ (4) Insufficiency of process
- ☐ (5) Insufficiency of service of process
- ☐ (6) Failure to state a cause of action
- ☐ (7) Failure to join an indispensable party
☐ Motion to dismiss for failure to state a claim (1.140(b)(6)): accepted all well-pled factual allegations as true
☐ If raising multiple defenses, all raised in a single motion (waiver rule applies — Fla. R. Civ. P. 1.140(h))
☐ Motion is exempt from Fla. R. Civ. P. 1.202 conferral requirement (for failure to state a claim ground)
☐ Memorandum of law attached (recommended for all dismissal motions)
C. Motion to Compel Discovery (Fla. R. Civ. P. 1.380)
☐ Good-faith conferral with opposing counsel completed and documented (Fla. R. Civ. P. 1.380(a)(2) and 1.202)
☐ Certificate of conferral included in the motion
☐ Motion identifies the specific discovery request(s) at issue
☐ Motion attaches copies of the discovery request(s) and response(s)
☐ Motion articulates why responses are insufficient or objections are improper
☐ Request for expenses/fees if appropriate (Fla. R. Civ. P. 1.380(a)(4))
☐ Proposed order attached
D. Motion for Continuance
☐ Good-faith conferral with opposing counsel (Fla. R. Civ. P. 1.202)
☐ Certificate of conferral included
☐ Motion states whether opposing counsel agrees or objects
☐ Specific grounds for continuance stated (e.g., unavailability, need for additional discovery, settlement negotiations)
☐ Proposed alternative dates included
☐ Filed as far in advance of the hearing/trial as practicable
☐ If filed within days of trial, affidavit of good cause may be required
E. Motion for Temporary Injunction (Fla. R. Civ. P. 1.610)
☐ Verified complaint or supporting affidavit filed
☐ Motion demonstrates:
- ☐ Substantial likelihood of success on the merits
- ☐ Irreparable harm absent injunctive relief
- ☐ Threatened injury outweighs any possible harm to defendant
- ☐ Entry of injunction would not be adverse to the public interest
☐ Bond posted or waiver of bond requested (Fla. R. Civ. P. 1.610(b))
☐ Proposed order of temporary injunction prepared
☐ Notice of hearing to all parties (unless ex parte relief sought with specific justification)
☐ Exempt from Fla. R. Civ. P. 1.202 conferral requirement
F. Motion in Limine (Fla. Stat. § 90.104)
☐ Filed sufficiently in advance of trial (check local rules for deadlines)
☐ Identifies the specific evidence sought to be excluded or admitted
☐ States the evidentiary basis under the Florida Evidence Code (Fla. Stat. ch. 90)
☐ Cites applicable case law
☐ Conferral with opposing counsel completed (subject to Fla. R. Civ. P. 1.202)
☐ Proposed order attached
G. Motion for Default (Fla. R. Civ. P. 1.500)
☐ Defendant failed to file responsive pleading within the time allowed
☐ Clerk's default entered (Fla. R. Civ. P. 1.500(a)) — motion to clerk or court
☐ Affidavit of non-military service filed (Servicemembers Civil Relief Act, 50 U.S.C. § 3931)
☐ If damages are liquidated: motion for default final judgment by clerk
☐ If damages are unliquidated: motion for default final judgment by court with proof of damages
☐ Proposed final judgment attached
PART IV: ELECTRONIC FILING REQUIREMENTS
A. Florida Courts E-Filing Portal (Fla. R. Jud. Admin. 2.525)
☐ Register for an account at https://www.myflcourtaccess.com (if not already registered)
☐ Confirm e-filing is mandatory for this case type and party (attorneys must e-file; pro se parties may be exempt)
☐ Verify the correct county and case type are selected in the portal
☐ Enter the correct case number
B. Document Format Requirements
☐ All documents in PDF format (Word documents will be converted by the portal)
☐ PDF/A format preferred (portal will convert standard PDFs to PDF/A)
☐ Documents are text-searchable (not scanned images, unless original is a scanned document)
☐ File size within portal limits (typically 25 MB per document; check current limits)
☐ Documents properly named for identification (e.g., "Motion_to_Dismiss.pdf")
☐ Sensitive information redacted per Fla. R. Jud. Admin. 2.425:
- ☐ Social Security numbers (last four digits only, or omitted)
- ☐ Bank account numbers (last four digits only)
- ☐ Dates of birth (year only, unless required)
- ☐ Names of minor children (initials only)
- ☐ Victim names in certain proceedings
☐ Confidential filing designation applied if the document contains information that must be filed under seal
C. Filing Fee Payment
☐ Determine the applicable filing fee (if any) for the motion type
☐ Common filing fees (Fla. Stat. § 28.241):
- ☐ Most motions: No separate filing fee (covered by initial filing fee)
- ☐ Motion to reopen case: Varies by county
- ☐ Motion for trial by jury: Demand fee may apply
- ☐ Cross-claim or counterclaim: Filing fee per Fla. Stat. § 28.241
☐ Payment method selected (credit card, e-check, or fee waiver)
☐ If indigent: Application to Proceed Without Prepayment of Costs filed (Fla. Stat. § 57.081)
☐ Fee waiver/indigency affidavit:
- ☐ Signed under oath
- ☐ Demonstrates income at or below 200% of the federal poverty level, or
- ☐ Currently receiving means-tested government assistance (e.g., SNAP, TANF, SSI, Medicaid)
D. Submission and Confirmation
☐ Review all uploaded documents before final submission
☐ Submit the filing through the portal
☐ Receive and save the confirmation email from the portal
☐ Note the filing date and time stamp (filing is effective upon submission, not acceptance)
☐ Monitor the portal for clerk acceptance or rejection within 48 hours
☐ If filing is rejected, correct deficiencies and refile promptly
PART V: SERVICE OF PROCESS
A. Service of the Motion (Fla. R. Jud. Admin. 2.516)
☐ Service required on all parties who have appeared in the action
☐ Primary method of service: e-mail to the designated e-mail address(es) (Fla. R. Jud. Admin. 2.516(b)(1))
☐ Service via the Florida Courts E-Filing Portal constitutes service on all registered e-service recipients
☐ Alternative service methods (only if e-mail service is not feasible):
- ☐ Hand delivery
- ☐ U.S. mail (adds 5 days to response time under Fla. R. Jud. Admin. 2.514(b))
- ☐ Facsimile (if authorized by the court)
☐ Service on pro se parties without e-mail: serve by U.S. mail or hand delivery
☐ Service completed before or simultaneously with filing
B. Certificate of Service (Fla. R. Jud. Admin. 2.516(f))
☐ Certificate of service included as the last page of every filed document
☐ Certificate states the method of service
☐ Certificate lists the name and e-mail address (or physical address) of each person served
☐ Certificate states the date of service
☐ Certificate is signed by the filing attorney
Sample Certificate of Service:
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on [__/__/____], a true and correct copy of the foregoing was served via the Florida Courts E-Filing Portal, which will send a notice of electronic filing to the following:
[Attorney Name], Esq.
[Firm Name]
[E-mail Address]
[Secondary E-mail Address]/s/ [Attorney Name]
[Attorney Name], Esq.
Florida Bar No. [____]
[Firm Name]
[Address]
[Phone]
[E-mail Address]
PART VI: TIME COMPUTATION RULES
A. Computing Time (Fla. R. Jud. Admin. 2.514)
☐ Day of the event excluded: When computing any time period, exclude the day of the event that triggers the period
☐ Count every day: Include intermediate Saturdays, Sundays, and legal holidays
☐ Last day falls on weekend/holiday: If the last day of a period falls on a Saturday, Sunday, or legal holiday, the period extends to the next day that is not a Saturday, Sunday, or legal holiday
☐ "Days" means calendar days unless otherwise specified
☐ Service by mail: Add 5 calendar days after service by mail (Fla. R. Jud. Admin. 2.514(b))
☐ Service by e-mail: No additional days added
B. Common Deadlines Reference
| Motion Type | Filing/Response Deadline | Hearing Notice |
|---|---|---|
| Motion to Dismiss (1.140) | 20 days after service of complaint | Reasonable notice |
| Summary Judgment Response (1.510) | 40 days after service of motion | 10 days after response deadline |
| Motion to Compel (1.380) | No fixed deadline; file after conferral | Reasonable notice |
| Motion for Rehearing (1.530) | 15 days after rendition of order | Per court |
| Motion for New Trial (1.530) | 15 days after return of verdict | Per court |
| Motion for Relief from Judgment (1.540) | Reasonable time; max 1 year for (b)(1)-(3) | Per court |
| Motion to Amend Pleading (1.190) | Leave of court after responsive pleading | Reasonable notice |
C. Requesting Extensions of Time (Fla. R. Civ. P. 1.090(b))
☐ Motion for extension filed BEFORE the original deadline expires (preferred)
☐ State good cause for the extension
☐ If filed after deadline: must demonstrate "excusable neglect" (higher standard)
☐ Propose a specific new deadline
☐ Confer with opposing counsel before filing (Fla. R. Civ. P. 1.202)
☐ Include certificate of conferral and statement of opposing counsel's position
PART VII: HEARING REQUIREMENTS
A. Scheduling the Hearing
☐ Contact the assigned judge's judicial assistant (JA) for available hearing times
☐ Follow the division's specific scheduling procedures (many circuits use online scheduling portals)
☐ Determine the estimated time needed for argument
☐ Coordinate with all parties on available dates before contacting the JA (required in many circuits)
☐ Obtain a confirmed hearing date and time
B. Notice of Hearing
☐ Notice of hearing filed and served after confirming the hearing date
☐ Notice includes:
- ☐ Date, time, and location of hearing (courtroom number, floor)
- ☐ Whether hearing is in person, by phone, or via Zoom/video (many circuits still offer remote options)
- ☐ Title of motion(s) to be heard
- ☐ Estimated duration
☐ Reasonable notice provided (typically 5 days for non-evidentiary hearings)
☐ For summary judgment hearings: at least 10 days after the response deadline (Fla. R. Civ. P. 1.510)
☐ Certificate of service included on the notice of hearing
C. Preparing for the Hearing
☐ Courtesy copies of the motion and all supporting documents delivered to chambers (if required by the division)
☐ Courtesy copy of the proposed order (in editable format) provided to the JA
☐ Opposition papers reviewed
☐ Reply filed and served (if applicable and permitted)
☐ Argument outlined with key cases and statutes ready for citation
☐ If evidentiary hearing: witnesses and exhibits prepared per the Florida Evidence Code (Fla. Stat. ch. 90)
D. Post-Hearing
☐ Order entered by the court (or proposed order submitted as directed)
☐ Ensure the order is served on all parties (court may handle service via the portal)
☐ Calendar any deadlines triggered by the order (e.g., discovery deadline, amended pleading deadline)
☐ If motion denied: evaluate options (motion for rehearing, interlocutory appeal, etc.)
PART VIII: LOCAL RULE REMINDERS BY CIRCUIT
Important: Florida has 20 judicial circuits, each with local administrative orders and division-specific procedures. Always check the local rules for the circuit and division where your case is pending.
☐ 1st Circuit (Escambia, Okaloosa, Santa Rosa, Walton): Check local administrative orders at www.firstcircuit.org
☐ 2nd Circuit (Franklin, Gadsden, Jefferson, Leon, Liberty, Wakulla): Check local rules at www.leoncountyclerk.gov
☐ 3rd Circuit (Columbia, Dixie, Hamilton, Lafayette, Madison, Suwannee, Taylor): Verify local practices
☐ 4th Circuit (Clay, Duval, Nassau): Detailed division procedures at www.jud4.org
☐ 5th Circuit (Citrus, Hernando, Lake, Marion, Sumter): Check www.circuit5.org
☐ 6th Circuit (Pasco, Pinellas): Check www.jud6.org
☐ 7th Circuit (Flagler, Putnam, St. Johns, Volusia): Check www.circuit7.org
☐ 8th Circuit (Alachua, Baker, Bradford, Gilchrist, Levy, Union): Verify local practices
☐ 9th Circuit (Orange, Osceola): Check www.ninthcircuit.org — detailed motion practice procedures
☐ 10th Circuit (Hardee, Highlands, Polk): Check www.jud10.org
☐ 11th Circuit (Miami-Dade): Extensive local rules at www.jud11.flcourts.org
☐ 12th Circuit (DeSoto, Manatee, Sarasota): Check www.jud12.flcourts.org
☐ 13th Circuit (Hillsborough): Check www.fljud13.org
☐ 14th Circuit (Bay, Calhoun, Gulf, Holmes, Jackson, Washington): Verify local practices
☐ 15th Circuit (Palm Beach): Check www.15thcircuit.com — detailed e-filing and motion procedures
☐ 16th Circuit (Monroe): Check www.keyscourts.net
☐ 17th Circuit (Broward): Check www.17thcircuit.com — extensive divisional procedures
☐ 18th Circuit (Brevard, Seminole): Check www.flcourts18.org
☐ 19th Circuit (Indian River, Martin, Okeechobee, St. Lucie): Check www.circuit19.org
☐ 20th Circuit (Charlotte, Collier, Glades, Hendry, Lee): Check www.ca.cjis20.org
PART IX: COMMON MISTAKES TO AVOID
☐ Failing to confer before filing — Under the 2025 amendments, Fla. R. Civ. P. 1.202 violations may result in denial of the motion and sanctions
☐ Omitting the certificate of conferral — Must appear above the signature block on non-dispositive motions
☐ Missing the 40-day summary judgment response deadline — This is now measured from service of the motion, not the hearing date
☐ Filing motions in the wrong division — Verify the assigned judge and division before filing
☐ Improper service — E-service is mandatory for represented parties; verify e-mail addresses are current
☐ Failing to include a certificate of service — Required on every filed document
☐ Submitting non-searchable PDFs — The e-filing portal and many courts require text-searchable documents
☐ Including unredacted sensitive information — Fla. R. Jud. Admin. 2.425 requires redaction of SSNs, bank accounts, DOBs, and minor names
☐ Not checking local rules — Each circuit (and often each division within a circuit) has specific requirements for motions, hearings, courtesy copies, and proposed orders
☐ Filing fee errors — Ensure the correct fee is paid; rejected filings for non-payment waste time and may cause missed deadlines
☐ Waiver of defenses — Under Fla. R. Civ. P. 1.140(h), certain defenses (lack of personal jurisdiction, improper venue, insufficiency of process, insufficiency of service) are waived if not raised in the first responsive pleading or pre-answer motion
☐ Not calendaring deadlines triggered by filing — File the motion, then immediately calendar the response deadline, hearing date, and any other triggered deadlines
☐ Submitting proposed orders in PDF rather than editable format — Many judges require Word (.docx) format for proposed orders
☐ Missing hearing notice requirements — Ensure all parties receive adequate notice; lack of notice is grounds for vacating any resulting order
PART X: EMERGENCY AND EXPEDITED MOTIONS
A. Emergency Motions
☐ Caption must include "EMERGENCY" designation (e.g., "EMERGENCY MOTION FOR...")
☐ Motion must include a statement explaining the nature of the emergency
☐ Describe the irreparable harm that will occur without immediate relief
☐ Explain why regular motion procedures are inadequate
☐ Contact the JA directly to schedule an emergency hearing
☐ Provide as much notice to opposing counsel as circumstances permit
☐ Some circuits require a separate "Certificate of Emergency" or "Declaration of Emergency"
☐ If ex parte relief is sought, explain why notice to the opposing party is impracticable
B. Expedited Motions
☐ Caption should include "EXPEDITED" or "TIME-SENSITIVE" designation
☐ Statement of why expedited consideration is necessary
☐ Proposed expedited briefing schedule
☐ Contact the JA to request an earlier hearing date
PART XI: POST-DISPOSITION MOTIONS
A. Motion for Rehearing (Fla. R. Civ. P. 1.530)
☐ Filed within 15 days after the date of rendition of the order or judgment
☐ Specifies the points of law or fact that the court overlooked or misapprehended
☐ Does not merely reargue previously considered matters
☐ Tolls the time for filing a notice of appeal (Fla. R. App. P. 9.020(h))
B. Motion for Relief from Judgment (Fla. R. Civ. P. 1.540)
☐ Filed within a "reasonable time" and, for grounds (b)(1)-(3), not more than 1 year after the judgment
☐ Grounds identified:
- ☐ (1) Mistake, inadvertence, surprise, or excusable neglect
- ☐ (2) Newly discovered evidence
- ☐ (3) Fraud, misrepresentation, or other misconduct by an adverse party
- ☐ (4) Void judgment
- ☐ (5) Judgment satisfied, released, or discharged
☐ Supported by affidavit or other evidence
FINAL REVIEW CHECKLIST
Before submitting the motion for filing, confirm:
☐ All required sections of the motion are complete
☐ Case caption is accurate (case number, party names, court, division)
☐ Legal citations are accurate and current
☐ Certificate of conferral is included (if required)
☐ Certificate of service is included and accurate
☐ All supporting documents, affidavits, and exhibits are attached
☐ Proposed order prepared and ready for submission to the JA
☐ Document is in proper PDF format and text-searchable
☐ Sensitive information is properly redacted
☐ Filing fee (if any) is prepared for payment
☐ All deadlines have been calendared
☐ A copy of all filed documents has been saved to the case file
Sources and References
- Florida Rules of Civil Procedure: https://www.floridabar.org/rules/
- Florida Rules of Judicial Administration: https://www.floridabar.org/rules/
- Florida Courts E-Filing Portal: https://www.myflcourtaccess.com
- 2025 Civil Procedure Rule Amendments (SC2024-0662): https://supremecourt.flcourts.gov
- Florida Statutes (Title V, Judicial Branch): http://www.leg.state.fl.us/statutes/
- Fla. R. Civ. P. 1.202 Conferral Requirement: https://floridarulesofcivilprocedure.com/rule-1-202-conferral-prior-to-filing-motions/
- Fla. R. Civ. P. 1.510 Summary Judgment Amendments: https://flabizlaw.org/member-articles/an-updated-cheat-sheet-for-practitioners-the-new-new-florida-summary-judgment-rule-10-things-to-know-revised/
- Florida Bar CLE Resources on 2025 Rule Changes: https://www.floridabar.org
Prepared by: [________________________________]
Florida Bar No.: [________________________________]
Firm: [________________________________]
Date Completed: [__/__/____]
This checklist is current as of February 2026. Practitioners should verify all rules, fees, and local procedures before filing. The Florida Rules of Civil Procedure, Florida Rules of Judicial Administration, and local administrative orders are subject to amendment.
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