Law clerks may be contacted regarding procedural questions. Law clerks may not be asked substantive legal questions and they cannot provide advice on how to handle legal questions. When you contact Chambers, please have the case number and presiding Judge available as this will be the first question asked so that we may better assist you. Absent a true emergency, counsel of record shall not contact chambers to ask questions concerning the status of pending matters.

Model B -- Chambers-first, hearing required before motion. Contact chambers (reinhart@flsd.uscourts.gov) with 2 proposed afternoon dates within the next 7 business days. NO motion filed until AFTER hearing; court may authorize a formal motion post-hearing if dispute remains unresolved. Pre-hearing: parties file joint discovery memorandum (5 pages or less) at least 48 hours before the hearing. Non-waiver provision (unique among FL-SD magistrates): responding to a discovery request -- even in whole -- does NOT waive future objections; agreeing to limit a demand does not waive right to seek additional discovery; parties need not serve reservation-of-rights language. If parties cannot agree on deposition scheduling after good-faith conferral, requesting party may unilaterally schedule with required notice; burden shifts to deponent to move for protective order.