Is it appropriate to telephone Chambers regarding questions of procedures on pending matters?

Yes, but check my Website first.

Is it appropriate to telephone Chambers regarding the status of pending matters?

Yes.

What can an attorney do to call attention to a pending motion of a particular importance to expedite a ruling?

Send a letter with a copy to opposing counsel or set up a conference call. If both counsel agree, one can make the inquiry.

How far in advance of a hearing should memoranda be forwarded to Chambers?

48 hours.

Should courtesy copies of pleading and motions be forwarded to Chambers and if so, how far in advance?

Only send copies of complicated or seriously contested motions. Copies of routine motions to compel, or to set trial etc. are not needed. 48 hours is sufficient, except for Motions for Summary Judgment, which should be sent 5 days in advance.

Should copies of cases cited in motions and memoranda be forwarded to Chambers?

Only for new or non routine issues. I don't need another copy of Roe v Patients' Compensation Fund, for instance, or any of the cases citing the standards for Summary Judgment.

Do you object to cases printed in Westlaw of CD-Rom format rather than copied from a reporter?

No.

Is it appropriate to cite unpublished opinions in motions or memoranda?

As long as it is cited as such.

If copies of cases are submitted, do you accept copies which have portions highlighted by counsel?

Yes.

Is it appropriate to send notices, motions, supporting memoranda and draft orders via fax?

Only if the matter is an emergency, or otherwise expedited. It should be of a reasonable length.

Do you allow telephonic hearings and if so, what is the maximum length?

Yes; no maximum. Please note that my chambers phone does not have the capacity to talk to more than one party at a time, so any multiple party calls must be conferenced by the party making the call.

Do you have any special procedures for handling emergency motions?

Yes. Fax or hand carry the Motion; I will review it and advise you if it will be entertained on an emergency basis either ex-parte, if appropriate, or when you may have a hearing.

Will you entertain motions in limine prior to trial and, if so, how far in advance should they be filed and set for hearing?

Yes. At reasonable time depending on the circumstances.

In connection with preliminary injunctions, do you limit the hearing to argument of counsel; and if not, what are your procedures for the receipt of evidence during hearing on a preliminary injunction?

No. I will accommodate as much evidence as is reasonable, giving the time allotted. I will also give each side equal time.

What is your policy/practice regarding the use of alternative dispute resolution?

I require mediation in all cases.

Under what, if any, circumstances will you grant trial dates certain?

For old long cases on a two week docket; to accommodate elder or infirm parties in accord with statute and/or rule; and in all non-jury trials.

If the case is not reached during the scheduled trail term, will the trial date be automatically rescheduled on your next trial docket? If no, what is your practice of procedure regarding scheduling trials which were not reached on the trial docket?

No. I have no firm practice. The age of the case together with the age of "competing" cases and the length of the cases and the availability of two week v. one week dockets.

Do you require trial briefs in jury trials?

Not regularly. If a matter is very complicated, novel and/or esoteric, I might, but I will advise the attorneys well in advance.

Do you require trial briefs in bench trials?

Same as above.

What are your requirements for trial briefs?

I don't have any special requirements.

When are trial briefs due?

In accordance with the order requiring the brief.

Do you require prepared findings of fact and conclusions of law to be filed in bench trials? If yes, when do you require the proposed findings of fact and conclusions of law to be filed?

No.

When do you require parties to file proposed jury instructions?

On the first day of the trial.

In multiple party cases, do you grant each party three peremptory challenges?

Usually.

In connection with opening statements, do you have any standard time limits imposed upon counsel? If yes, what are the time limits?

No, but be reasonable.

Can exhibits be used in opening statements?

Yes, absent vigorous objection. Make sure it's something that will be admitted.

Do you allow Plaintiffs to make a rebuttal during opening statements?

No.

Do you conduct evidentiary hearings on experts prior to trial?

If required by Frye or issues touching upon qualifications.

What, if any, procedural requirements do you have relative to the use of videotapes, trial graphics, depositions and demonstrative aids?

None other than those imposed by the Rules of Court Administration.

What, if any, procedures do you have concerning objections at trial?

If it is going to involve any discussion at all, ask to approach. I disapprove of argument or discussion in front of the jury.

Do you permit jurors to ask questions either orally or in writing?

Only if by stipulation, and then in accordance with the procedures outlined in the current jury instruction on the matter.

Do you allow jurors to take notes during trial?

Same as above.

Should jury instructions also be submitted to Chambers on a computer disk?

No.

Should findings of fact and conclusions of law filed in connection with a civil bench trial also be submitted to Chambers on a computer disk?

I don't require findings,etc.

When a dispute arises during a deposition, is it appropriate to call Chambers to seek an immediate ruling?

Yes.

Do you have any special procedures during voir dire?

No.

Do you have any special procedures for back striking?

No.

Do you have any advice for new/inexperienced lawyers?

Read and take seriously "50 Things I Wish I Would Have Learned in Law School" by Gene Summerlin originally published in The Prairie Barrister Vol. 8 No. 2 (2002) see me for a copy or, better yet, join the Professionalism Section of the Florida Bar, and read it in the Winter 2005 issue of "The Professional" a publication of the Center for Professionalism of the Florida Bar.