IN THE CIRCUIT COURT OF THE 11TH JUDICIAL CIRCUIT IN AND FOR
MIAMI-DADE COUNTY, FLORIDA
CIRCUIT CIVIL DIVISION
CASE NO.: CA 15
vs. MOTION FOR CONTINUANCE
RE-SETTING CASE FOR TRIAL
THIS CAUSE came on to be heard before me and having reviewed the court file and
being fully advised in the premises, it is:
ORDERED AND ADJUDGED that the above captioned matter is hereby continued to
the THREE WEEK TRIAL DOCKET BEGINNING MONDAY, JANUARY 1st 2010, AT
UNLESS EXCUSED BY THIS COURT, ALL ATTORNEYS ARE HEREBY ORDERED TO
APPEAR AT CALENDAR CALL, THURSDAY, JANUARY 2010, AT 1:30 P.M. AT
THE DADE COUNTY COURTHOUSE, 73 WEST FLAGLER STREET, COURTROOM 3-2,
MIAMI, FL 33130.
The case was continued/reset because SEE BELOW , . The trial had been set
on this Court’s three-week trial docket beginning Monday, Jan. 1st, 2010, at 9:00 a.m.
IT IS FURTHER ORDERED AND ADJUDGED that:
The pretrial procedures contained in the original trial order shall remain in effect
and any time limits will be adjusted to the new trial date by the attorneys who are also
ordered to adhere to the new dates.
All subpoenas heretofore issued are hereby validated and in full force and effect for the
aforementioned trial period and the witnesses and other parties may be served with a copy of this
Order by mail and will be notified that their previously served subpoenas are valid for the above
[LEAVE BLANK. THIS AREA FOR JUDGE REYES TO INSERT ELECTRONIC
ADDENDUM TO UNIFORM ORDER SETTING CAUSE FOR
JURY TRIAL, PRE-TRIAL CONFERENCE AND PRETRIAL
MOTIONS FOR CONTINUANCE
MOTIONS IN LIMINE
ADDITIONAL PRE-TRIAL INSTRUCTIONS
In addition to the provisions mandated in the Uniform Order Setting Cause for Jury Trial,
Pre-Trial Conference and Pre-Trial Instructions and any Order Granting a Motion for
Continuance, the following shall also be adhered to by the parties and their counsel.
IT IS ORDERED AND ADJUDGED that:
1. All motions for continuance shall be in writing unless made at a trial and, except for
good cause shown, shall be signed by the party requesting the continuance. Fla. R. Jud. Admin.
2. Motions for continuance shall be set for hearing prior to the Calendar Call during this
Court’s Uniform Motion Calendar.
3. Only Emergency Motions for Continuance will be heard at Calendar Call. In addition
to the grounds for the requested continuance, the movant shall also state why the motion was not
set for hearing during this Court’s Uniform Motion Calendar.
4. If the motion for continuance is unopposed or agreed to by all parties, the motion and
proposed Order can be submitted electronically for ruling without a hearing indicating the month
(trial period) the parties wish to have the trial heard. The Court will make every effort to
accommodate the requested trial period. The motion must still comply with Fla. R. Jud.
5. Parties are directed to Judge Reyes’ webpage linked at www.jud11.flcourts.org for the
procedures to be followed in submitting any proposed orders and emergency motions and for
the procedures to be followed in setting any hearings except Motions in Limine which shall be
heard the first day of trial unless a special set hearing is requested (the instructions for Motions
in Limine to be heard on the first day of trial are attached herein). See below.
6. Attorneys must meet with the Clerk in the courtroom one (1) hour before the scheduled
voir dire to pre-mark all exhibits intended to be used. The exhibits which the parties can agree
upon will be marked into evidence. The exhibits that the parties cannot agree upon will be
marked for identification. Thus, it is anticipated that there will never be a circumstance where an
attorney seeks to introduce an item into evidence that has not previously been marked. Therefore,
it should never be a surprise to opposing counsel.
7. If depositions are intended to be used at any point during the trial and if there are any
objections requiring ruling by the Court, prior to voir dire the Court must be given a copy of the
deposition and a cover sheet reflecting the page and line where the objection appears so that the
objections may be ruled upon prior to use during the trial. That way there will be no interruptions
during the trial concerning those objections.
8. Absent Order of Court, no case can go to trial without having previously been mediated.
9. Prior to voir dire the Court must receive all proposed jury charges in two (2) piles of
non duplicated charges: pile one (1) will be all jury charges which the parties have agreed upon
and pile two (2) will consist of those jury charges that the parties are unable to agree upon. The
parties are required to have met with each other, exchanged their proposed jury charges, discussed
the proposed jury charges, and thus produced the two (2) aforesaid piles. Failure to follow this
procedure will result in automatic sanctions being imposed upon the attorneys.
10. All Motions in Limine must be in writing and copies electronically delivered to Judge
Reyes and opposing counsel at least two (2) days prior to trial or they will be deemed waived.
Motions in Limine will be heard the first day of trial unless the movant requests a Special Set
Hearing. See the next page for instructions on how to submit the Motions in Limine to be heard
the day of trial and www.jud11.flcourts.org for instructions on how to set motions on the Uniform
Motion Calendar and how to set Special Set Motions.
11. It shall be within the discretion of the court to waive the requirements set forth herein or
to impose sanctions for failure to comply with such requirements.
HOW TO ELECTRONICALLY SUBMIT MOTIONS IN LIMINE TO BE
HEARD THE FIRST DAY OF TRIAL TO JUDGE REYES
(For setting all other motions go to www.jud11.flcourts.org)
STEP 1: SAVE THE MOTION IN LIMINE, AND MEMORANDUM OF LAW, IN
WORD OR WORDPERFECT FORMAT, NOT PDF OR SCANNED.
STEP 2: SAVE ANY SUBMITTED DOCUMENTS WITH THE CASE NUMBER
(USING THE SAME COURT CASE NUMBER FORMAT LISTED IN
STEP 4) AND THE NAME OF THE DOCUMENT. SOME EXAMPLES:
99-7123 Plaintiff’s Motion in Limine[movant states issue(s)]
09-23 Defendant’s Motion in Limine [movant states issue(s)]
STEP 3: CREATE AN EMAIL TO CA15SpecialSets@jud11.flcourts.org
STEP 4: IN THE SUBJECT LINE OF THE EMAIL, WRITE THE COURT CASE
NUMBER ONLY AND NOTHING ELSE USING THE FOLLOWING
FORMAT (TWO DIGIT YEAR FOLLOWED BY A HYPHEN WITH THE
SEQUENTIAL CASE NUMBER):
DO NOT USE ZEROS AFTER THE HYPHEN TO FILL IN THE
SEQUENTIAL CASE NUMBER.
DO NOT WRITE ANYTHING ON THE SUBJECT LINE OTHER THAN
THE COURT CASE NUMBER USING THE ABOVE FORMAT!
STEP 5: ATTACH TO THE ABOVE EMAIL, A WORD OR WORDPERFECT
VERSION OF THE MOTION IN LIMINE AND MEMORANDUM OF LAW
AND ANY EXHIBITS.1
DO NOT ATTACH & SEND
A SCANNED VERSION OF THE MOTION IN LIMINE AND
MEMORANDUM OF LAW AND ANY EXHIBITS.1
DO NOT ATTACH & SEND
A PDF VERSION OF THE MOTION IN LIMINE AND MEMORANDUM OF
LAW AND ANY EXHIBITS. 1
WE WILL ONLY ACCEPT A WORD OR WORDPERFECT VERSION OF
THE MOTION AND MEMO OF LAW.1
STEP 6: SEND THE EMAIL WITH THE ATTACHED MOTION IN LIMINE AND
MEMORANDUM OF LAW IN WORD OR WORDPERFECT FORMAT
AND ANY EXHIBITS1 TO CA15SpecialSets@jud11.flcourts.org.
Exhibits to the Motion, Memorandum of Law, or any documents supporting the motion
received from opposing counsel can be sent PDF or scanned. If the Movant is setting the
opposing counsel’s Motion or if a party is setting for hearing an opponent’s Objections, those
can be sent PDF or scanned. But, the MOVANT’S MOTION AND MEMORANDUM OF
LAW must be sent in WORD OR WORDPERFECT format.