In the Circuit Court of the Eleventh Judicial Circuit in and for Miami-Dade County, Florida s1

IN THE CIRCUIT COURT OF THE ELEVENTH JUDICIAL CIRCUIT IN AND FOR MIAMI-DADE COUNTY, FLORIDA

CASE NO.

JUDGE ABBY CYNAMON DIVISION 06 Plaintiff, vs.

Defendant. ______/

ORDER FOLLOWING PRETRIAL CONFERENCE/ CALENDAR CALL

This action is taken by the Court pursuant to Rule 1.200, Fla.R.Civ.P. and the Uniform Order Setting Cause for Jury Trial.

1. Counsel Must Meet. All counsel must meet prior to the Thursday before trial and submit for inspection all exhibits to be introduced at trial. All photographs and written documents must be produced at the meeting. At the meeting, counsel shall accomplish the following tasks:

(a) Mark exhibits for identification, inspect all exhibits and discuss objections to them. Counsel shall make a good faith effort to agree to the authenticity of documents in order to limit the necessity of proof of authenticity at trial.

(b) Counsel shall make a good faith effort to limit the number of photographs and agree upon their admissibility at trial.

(c) Review the witness lists filed by each party and determine which witnesses will actually be called at trial.

(d) Both parties shall agree on a description of the case to be read to the jury prior to Voir Dire (FSJI 201.1).

(e) Discuss jury instructions and prepare a list of all stipulations. The Plaintiff’s counsel shall be responsible for preparing proposed preliminary and final instructions.

(f) Exchange Pretrial motions in Limine. All Pretrial Motions in Limine must be submitted by each Counsel no later than the close of business the Thursday before the Monday trial date, unless ordered to be submitted during the week of calendar call. A cover letter should accompany the motions in Limine listing the motions. Case Law should be attached.

2. Submission of a Pretrial Statement . As a result of the above, Plaintiff’s counsel shall provide the Court by courtesy copy, filed with the Clerk of the Court and served on all other parties, a Pretrial Statement signed by the attorney(s) who will try the case, containing the following:

(a) The date all counsel met to review exhibits to be introduced at trial and witnesses to be called.

(b) The names of each attorney serving as trial counsel.

(c) A description of the case to be read to the jury.

(d) All written stipulations.

(e) A list setting forth the witnesses to be called at trial by both parties following the review referenced in 1(c). This list shall be read to the jury.

(f) A schedule of the exhibits to be offered at trial by the attorneys signing the statement. The Plaintiff’s exhibits shall be numbered consecutively and the Defendant’s exhibits lettered alphabetically.

(g) Any objections to exhibits of opposing counsel together with specific legal authority (statutory and case law). Objections to the authenticity of a document shall specifically state the reason for the belief that the document is not authentic.

(h) Proposed jury instructions and verdict form.

The Pretrial Statement and Pretrail motions in Limine shall be submitted by email in Word format to the judicial assistant ([email protected]) no later than the close of business the Thursday before the Monday trial date. A cover sheet with the caption of the case, case number and title shall accompany the jury instructions.

ORDERED in Miami, Miami-Dade County, Florida, this ___ day of _____, 2018.

______ABBY CYNAMON Circuit Court Judge

CC: All Counsel of record