Judicial Section Details

**NOTE: No in-person appearances will be permitted in Division 31 absent further order.  It is ORDERED that, effective immediately, all proceedings in Division 31 (Judge Sanchez-Llorens) shall be conducted via Zoom.

FORECLOSURE CALENDARS: (see CourtMAP for availability)

- Wednesdays from 9:30 am - 10:30 am

- Wednesdays from 10:30 am - 11:30 am

*Once you enter the zoom hearing rename yourself to include the case number for which you are appearing and your name. You must mute yourself on any Zoom hearings unless you are asked to speak. Video appearance is required for any participant whose testimony or argument is necessary for the hearing.

**NOTE: Foreclosure Calendar is for 5 minutes only. On one calendar event, you may schedule at most two motions. Do not set your case more than once for the same day. A copy of the motion and notice of hearing must be submitted through CourtMAP at least two (2) business days before the hearing date. The e-filed motion and all documents in support must be attached as supporting documents in CourtMAP.

May NOT be set on Foreclosure Calendar:

- Summary Judgments must be set as a special set hearing for at least 30 minutes, unless the motion may be argued by both sides in at most five (5) minutes.

To Cancel Your Motion: Only the moving party may cancel a foreclosure calendar hearing. The moving party must e-file a Notice of Cancellation and cancel the hearing on CourtMAP.

To Cancel/Reschedule Foreclosure Sale: The parties have known the sale date well in advance. If ALL parties agree to cancel/reschedule the sale, upload an agreed order with a cover letter to CourtMAP making sure that all parties have reviewed the order before submittal. Once the agreed order with cover letter has been uploaded, call chambers to alert the Court.

Additional Foreclosure Calendar Details: 
- Once a green "success" message appears, the hearing has made calendar. You must give seven (7) business days notice by filing and serving a Notice of Hearing to all parties.
- Movant must confer with ALL PARTIES to schedule the motion.
- To check to see if your case made the Judicial Calendar please visit the Clerk of Courts website at: https://www2.miami-dadeclerk.com/ocs
- Motions for default must be submitted with the following: (1) proof of service, (2) affidavit of diligent search, (3) proof of publication (where service is by publication), (4) and non-military affidavit(s) (all of which must be filed). Only one motion per defendant.

- DO NOT SUBMIT PROPOSED ORDERS THROUGH COURTMAP PRIOR TO YOUR HEARING.

Submission of Original Notes: All original notes and mortgages must be mailed to 20 NW 1st Avenue, Suite 19.265, Miami, FL 33128 to the JA's attention. The original notes and mortgages must be received by chambers at least three (3) days prior to your scheduled hearing with a cover letter that includes: (1) the case number, (2) case style, and (3) division number.

**NOTE: If the parties reach an agreement prior to the hearing, you may upload an agreed order for the motion on CourtMAP. You must notify chambers through e-mail with all parties copied. Send e-mails to egerard@jud11.flcourts.org  and amjimenez@jud11.flcourts.org. 

Pro Se Litigants are required to file documents through the e-filing portal: https://www.jud11.flcourts.org/Florida-Courts-eFiling-Portal (click the blue button to register)

ATTENTION

MOTION CALENDAR IS CONDUCTED VIA ZOOM VIDEO CONFERENCE UNLESS OTHERWISE INDICATED.
ALL ZOOM HEARING PARTICIPANTS SHALL RENAME THEMSELVES TO INCLUDE FIRST AND LAST NAME AND CASE NUMBER BEFORE JOINING THE MEETING.

ALL MOTIONS SHALL BE ADDED ON THE COURTMAP UNDER VIEW ALONG WITH EXHIBITS, ANY AFFIDAVIT, AND/OR CASE LAW THE PARTIES WANT THE COURT TO CONSIDER.

***Note: Purpose of the Breakout Room during a Video Zoom Conference: Counsel attending a Hearing must Meet and Confer before starting the Hearing while they are placed in the Breakout Room.

Virtual (Zoom) Courtroom.  The Zoom platform is free to you.  The Zoom link for your hearing will be generated and sent by the Court one (1) day prior to hearing.
                      a. Join Zoom via Computer: You do not need to download anything or set up an account in order to participate in a Zoom hearing via computer.  Just click the link sent by the Court to open online, and be sure you have a stable internet connection.
                      b. Join Zoom via Smart Phone: You do not need to set up an account in order to participate in a Zoom hearing via smart phone. However, you will need to download the Zoom application from your phone's application store (the application is free). Once downloaded, open the application, click Join Meeting, and type the Meeting ID provided by the Court. 

Court reporters must email the JA and the bailiff for the Zoom link for their hearing.

 **NOTE: You must mute yourself on any Zoom hearings unless you are asked to speak. Video appearance is required for any participant whose testimony or argument is necessary for the hearing.

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MOTION CALENDARS: (see CourtMAP for availability)
- Tuesdays from 9:45 am - 10:30 am

- Tuesdays from 10:30 am - 11:30 am

- Wednesdays from 9:30 am - 10:30 am

- Wednesdays from 10:30 am - 11:30 am

*Once you enter the zoom hearing rename yourself to include the case number for which you are appearing and your name.

**NOTE: Motion Calendar is for 5 minutes only. On one calendar event, you may schedule at most two motions. Do not set your case more than once for the same day. A copy of the motion and notice of hearing must be submitted through CourtMAP at least two (2) business days before the hearing date. The e-filed motion and all documents in support must be attached as supporting documents in CourtMAP.

MUST be set on Motion Calendar:

- Motion to Withdraw
- Motion for Continuation of Trial

**NOTE: Motions for default must be submitted with the following: (1) proof of service, (2) affidavit of diligent search, (3) proof of publication (where service is by publication), (4) and non-military affidavit(s) (all of which must be filed). Only one motion per defendant.

May NOT be set on Motion Calendar:

- Minor settlement must be set as a special set hearing for a minimum of 15 minutes.
- Summary Judgment must be set as a special set hearing for at least 30 minutes, unless the motion may be argued by both sides in at most five (5) minutes.

To Cancel Your Motion: Only the moving party may cancel a motion calendar hearing. The moving party must e-file a Notice of Cancellation and cancel the hearing on CourtMAP.

Additional Motion Calendar Details: 
- Once a green "success" message appears, the hearing has made calendar. You must give seven (7) business days notice by filing and serving a Notice of Hearing to all parties.
- Movant must confer with ALL PARTIES to schedule the motion.
- To check to see if your case made the Judicial Calendar, please visit the Clerk of Courts website at: https://www2.miami-dadeclerk.com/ocs.
- DO NOT SUBMIT PROPOSED ORDERS THROUGH COURTMAP PRIOR TO YOUR HEARING.

- All motion calendar orders shall be uploaded under "Agreed Orders" with a letter. ALL ORDERS SHALL BE SUBMITTED WITH A COVER LETTER OR THEY WILL BE REJECTED.

**NOTE: If the parties reach an agreement prior to the hearing, you may upload an agreed order for the motion on CourtMAP. You must notify chambers through e-mail with all parties copied. Send e-mails toegerard@jud11.flcourts.org and  amjimenez@jud11.flcourts.org.  

PROCEDURES:

ALL CASES SHALL FILE A SCHEDULING ORDER (see forms/docs). IN THE EVENT OF CONFLICTING DEADLINES, PREVIOUSLY ENTERED CASE MANAGEMENT ORDERS (CMO) OR SCHEDULING ORDERS MUST BE FOLLOWED. THE EARLIEST APPLICABLE DEADLINE WILL BE ENFORCED. THE CMO/SCHEDULING ORDER SUPERSEDES ANY CONFLICTING DEADLINES ESTABLISHED BY THIS TRIAL ORDER. DO NOT RELY ON THIS TRIAL ORDER TO EXTEND ANY PRIOR DEADLINES.

PRIOR TO CALENDAR CALL: If counsel or client ONLY are unavailable due to medical reasons or pre-paid vacations you SHALL file a notice of unavailability to the docket. 

 The parties shall complete the form by conferring and filling in the order with specific dates in the following format: 

[Month/day/year] 

**When submitting the Scheduling Order, select "Generic Order" in CourtMAP and type "Order on Case Management Plan" under "Document" and use "Order on Case Management Plan" as the title of the order in the title box.

UPON THE COURT'S SIGNING OF THE SCHEDULING ORDER, COUNSEL SHALL ADD THE CASE ON THE AGREED UPON CALENDAR CALL DATE ON COURTMAP. *Signing up the case on CourtMAP for the calendar call date in the signed scheduling order will automatically generate a trial order for the Judge's signature.
**NOTE: Paragraph 1 of the Scheduling Order states that the Scheduling Order supersedes all trial orders.

The parties must schedule themselves on an available calendar call/trial periods which are posted on CourtMAP under Trial (this generally occurs on the last Thursday of the month). Once APPROVED by Court, you will receive an Order Setting Matter for Trial and Order of Referral to Mediation. 

NOTE: BEFORE SCHEDULING A CALENDAR CALL DATE, PARTIES SHALL SCHEDULE A CASE MANAGEMENT CONFERENCE ON THE COURT'S MOTION CALENDAR FOR A HEARING AT LEAST TWO (2) WEEKS PRIOR TO THE CALENDAR CALL DATE.  Additionally, Order of Mediation MUST be complied with prior to Calendar Call. 

JURY TRIALS: BEFORE SCHEDULING A CALENDAR CALL DATE, a Jury Trial Readiness Certification (located under "Hearing Documents") must be completed and uploaded to CourtMAP as a "Proposed Order" with Jury Instructions as a supporting document at least one (1) week prior to the Calendar Call hearing date.  The Court will not sign off on the Jury Trial Certificate of Readiness without the supporting documents attached, which includes the Jury Instructions.

Once the above has been complied with, select the calendar call/trial period from the Court's available dates.

*Submit a copy of the filed notice of readiness (under supporting documents) in order for the matter to be set for trial.
* Calendar Call is MANDATORY unless excused by Judge. 

Motions to Continue Trial or any other motions will NOT be heard at calendar call. 

Notices for Non-Jury Trial (ONLY) must be filed with the Clerk of Courts and e-mailed to egerard@jud11.flcourts.org and amjimenez@jud11.flcourts.org    

If your case settles, please email the filed notice of settlement and/or filed voluntary dismissal to: egerard@jud11.flcourts.org and amjimenez@jud11.flcourts.org 

NO TELEPHONIC APPEARANCES ALLOWED AT CALENDAR CALL

ALL PROPOSED ORDERS MUST BE ACCOMPANIED BY A COVER LETTER. ALL UPLOADED ORDER MUST HAVE LETTERHEAD CORRESPONDENCE AS TO WHETHER THE MOTION WAS GRANTED, OTHERWISE THE PROPOSED ORDER WILL BE REJECTED.

ONLY AGREED ORDER SHOULD BE UPLOADED ON THIS PLATFORM.

ORDER SUBMISSION PROCEDURES: 

- All orders must be submitted as a Word document on CourtMAP's pre-generated blank order.

- Each order must be titled in the block in CourtMAP marked "Generic Order-You must rename the Order Title," NOT in the body of the order. CourtMAP will not let you submit your order without filling out the title block.

- The following must be attached to all orders: (1) a cover letter, * (2) the relevant motion(s), (3) all supporting documents such as relevant case law or memorandum, and (4) the response(s) to the motion(s).

* Your cover letter must include the date and time when your hearing took place, the judge's ruling on that date, the title of the motion heard, and if the parties agree on the proposed order.

**NOTE: CourtMAP automatically adds the following language to all submitted order: (1) the case style, (2) order title, (3) judge's signature block, and (4) the done and ordered language. 

SUBMITTING AGREED ORDERS:

Be sure to select the AGREED order option in CourtMAP so your order goes into the correct queue. ONLY AGREED ORDER SHOULD BE UPLOADED ON THIS PLATFORM.

 Additional Details:

- Motions for Default must be submitted as a proposed order, per the above procedures, with the following: (1) proof of service, (2) affidavit of diligent search, (3) proof of publication (where service is by publication), (4) and non-military affidavit(s) (all of which must be filed).

- Motions to Withdraw must be set on the Court's Motion Calendar (See Motion Calendar Tab for more details). If the Court grants your motion, download and submit, per the above procedures, the Court's "Order Granting Motion to Withdraw" template located above on this tab.

- Motions for Substitution of Counsel must be filed with the Clerk of Courts either in person or through the e-portal. Once filed, submit your order as a proposed order in CourtMAP, per the above procedures. After you upload your proposed order, call chambers to alert the Court the order is ready for review.

Procedure upon filing a Motion for Rehearing: When the Response has been filed, then upload competing orders on the rehearing. The Judge will grant the rehearing based on the pleadings filed.

**NOTE:  If a hearing is scheduled, do not submit an order prior to the hearing unless the parties have resolved the motion and are submitting an Agreed Order. 

STANDING ORDER ON AMOUNT OF ATTORNEYS FEES & COSTS:

For hearings on Motion for Attorneys' Fees and Costs, there must be a standing order signed by the Judge (which can be found above under proposed orders) in order for a hearing to be set. 

****Should you need hearing dates or to cancel a hearing, please email and call Chambers at 305-349-7122.

*** SPECIAL SET HEARINGS ARE CONDUCTED VIA ZOOM UNLESS OTHERWISE INDICATED.

****Immediately upon filing a Motion for Summary Judgment and/or Daubert Motion, please contact chambers VIA EMAIL and PHONE to secure a special set hearing date. For all hearings needing an earlier date, the parties shall contact chambers VIA EMAIL and PHONE at 305-349-7122.

To schedule a special set hearing of 60 minutes (1 hour) or less, please refer to the on-line scheduling system (CourtMAP).

Special set hearing requests require a completely filled out Special Sets Request Form and a copy of the motion to be heard. E-File your special set request form and the motion(s) with the clerk's office. All motions MUST be filed with the Clerk prior to scheduling a special set hearing.

The moving party MUST coordinate the date/time with opposing counsel based on the Court's availability (found on CourtMAP) and shall submit a copy of the filed motion along with the Court's Request for Special Set form via CourtMAP when selecting the proposed hearing date for the Court's approval (a notice of hearing SHOULD NOT accompany the submission).When submitting a Special Set request, please state whether the hearing is evidentiary.

Special set hearings are NOT Scheduled until they are approved by the Court. Once the Court has approved the proposed hearing date, the parties will receive an automated email indicating same. The parties will also be served with a notice of hearing which will be automatically e-filed.  *If you do not receive the Notice of Hearing, please communicate with the Clerk of Court’s office and confirm you are on the service list.*

If the proposed special set notice is rejected, the parties will receive a message along with the reason for the rejection/cancellation.

If you are setting an Evidentiary hearing, please follow the Evidentiary Process outlined below and on the main page. Additionally, send chambers an e-mail with all parties copied with the date of the Evidentiary special set hearing specifying that the hearing is an Evidentiary hearing.

Submission of Evidence for Zoom Hearings and Zoom Trials:  At least five business days prior to the hearing or trial, each side must:
1. Mark the first page of each document it intends to introduce into evidence.  (Plaintiff with numbers/Defendant with letters.)
2. Submit to the e-Portal, in the manner detailed below, an Exhibit List, containing the exhibit number/letter, with the corresponding brief description of the exhibit, and all exhibits separately. 
          To Submit:    a.  Go to the eFiling Portal;
                               b.  Click on "File Pleading in Existing Case;"
                               c.  Enter Case Number;
                               d.  Once case populates, go to the documents tab, click "Add;"
                               e.  Once Search Bar appears, type "EVIDENCE" and hit "Enter;"
                               f.   Check Off Evidence Submission, then hit "Browse" which allows you to select the respective document to be uploaded; and
                               g.  Click "Save." 
By submitting the documents as indicated above, these go into a separate Evidence Queue that allows the Clerk to access evidence submitted on a particular case.  EACH EXHIBIT MUST BE SUBMITTED SEPARATELY.  DO NOT COMBINE DOCUMENTS THAT MAY NEED TO BE INTRODUCED SEPARATELY.
3. Upload the Exhibit List and each exhibit separately via courtMap to the hearing/trial event.  The list and each exhibit must be properly named when uploaded for ease of reference.  

**NOTE: For additional details on evidence submission for hearings and trials via zoom, refer to the attached document titled, ADMINISTRATIVE MEMORANDUM ON EVIDENTIARY HEARINGS DURING THE PANDEMIC

MOTION FOR SUMMARY JUDGMENT: Attorney's must set a motion for summary judgment for at least 30 minutes. Failure to adhere to procedural deadlines may subject your party to fees and costs.

ALL MOTIONS SHALL BE ADDED ON THE COURTMAP UNDER VIEW ALONG WITH EXHIBITS, ANY AFFIDAVIT, AND/OR CASE LAW THE PARTIES WANT THE COURT TO CONSIDER. 

If you are attempting to schedule a hearing for more than 60 minutes (1 hour), you must email chambers at egerard@jud11.flcourts.org and amjimenez@jud11.flcourts.org (copying all parties). Include in your e-mail a copy of the filed Special Set Request Form, the motion, and any other relevant materials.

SPECIAL SET CANCELLATIONS:

A special set CANNOT BE CANCELLED OR RESCHEDULED WITHOUT A COURT ORDER CANCELLING/OR RESCHEDULING THE HEARING. Please do not submit a new special set request until the court has approved the current hearing's request for cancellation or rescheduling. To cancel, you may file a motion (ensure that it indicates whether opposing counsel is in agreement) and submit a proposed order with a cover letter.  

*** Parties may deliver to chambers a physical copy/binders of evidence, however, one must also be delivered to opposing counsel at least three (3) days prior to the hearing date.