Initial Pleadings
Service of Process must be made within this amount of time from filing the complaint:
Florida: 120 Days
Federal: 90 Days
A motion to dismiss must be brought within this amount of time:
Federal: 21 days, if denied the answer must be filed in 14 days from denial.
Florida: 20 days, if denied the answer must be filed in 10 days from the denial.
Expert Testimony Disclosures
Florida: NA - Deadlines set by case management orders.
Federal: 90 days before trial, or 30 days after opposing party's disclosure for rebuttal experts.
Motion for Summary Judgment
Florida: Anytime after 20 days from commencement of action, or after service of motion for summary judgment by an adverse party.
Federal: 30 days after the close of discovery
A request for waiver of service of process must be responded to within this amount time:
Florida: 20 days from the request, 60 days if teh defendant is outside the US.
Federal: 30 days from the request, 60 days if the defendant is outside the US.
Motion to Change Venue must be brought within this amount of time:
Florida: 20 days from service of complaint
Federal: 21 days
Depositions - Amount of Depositions, Time for Depositions, and Number of Depositions
Florida: Anytime after service of initial disclosures, and 30 days after plaintiff's service of the summons & complaint.
Federal: After the rule 26(f) conference. No more than 10 depositions per party without leave of court, and depositions can not exceed 7 hours.
Length of Temporary Restraining Order
Florida: Effective until further order of the court
Federal: 14 days unless good cause or consent.
An answer to a complaint must be given within this amount of time:
Federal: 21 days (60 if service is waived)
Impleading a 3rd Party must be done within this time frame:
Florida: 20 days from answer, or leave of court.
Federal: 14 days from answer, or anytime after the complaint is filed with leave of court.
Interrogatories
Florida: 30 interrogatories including sub parts without leave of court, and 30 days to respond. 45 days to respond if served with the summons and complaint.
Federal: 25 interrogatories including sub parts, 30 days to respond.
Judgment As a Matter of Law - When to Bring & Renew
Florida: After the non-moving party has presented evidence, or at the close of evidence. Renew 15 days after return of verdict or discharge of jury.
Federal: Any time before submitting to the jury. Renew 28 days after entry of judgment.
An amended complaint can be filed in this amount of time without leave of court:
Florida: Any time before the answer is filed.
Federal: 21 days
Notice of Removal must be brought within this time frame:
Florida: 30 Days from service on defendant
Federal: 30 Days from service on defendant
Florida & Federal: Absolute bar on removal under diversity jurisdiction 1 year after commencement.
Request for Production
Florida: 30 days from service of request, 45 days if served with summons and complaint.
Federal: 30 days after service of the request
Notice of Appeal
Federal: 30 Days
Responses to amended pleadings must be given in this amount of time:
Federal: 14 Days, or the amount of time left to respond to the original pleadings.
A motion to remand must be brought within this amount of time:
Florida: Anytime for lack of SMJ, or 30 days from notice of removal.
Federal: Anytime for lack of SMJ, or 30 days from notice of removal.
Pre-Trial Conference
Florida: Set by case management order issued 120 days after filing suit.
Federal: 90 das after defendant has been served, or 60 days after any defendant's appearance.
Motion for New Trial
Florida: 15 days from return of judgment/verdict.
Federal: 28 days from entry of judgment
The time frame in which an answer must be filed and any counter claims or cross-claims raised:
Florida: 20 Days
Federal: 21 Days
Florida: 60 days after service of complaint.
Federal: 14 days after the rule 26(f) conference.
Pre-Trial Disclosures & Jury Demand
Federal PreTrial Disclosure: 30 days before trial.
Florida PreTrial Disclosures: Set by case management order.
Florida Jury: 10 days from last pleading directed at issue.
Federal Jury: 14 days from last pleading directed at issue.
Motion to Alter or Amend Judgment
& Motion for Relief from Ament
Motion to Alter or Amend:
Florida: 15 days from entry of judgment
Federal: 28 days from entry of judgment
Motion for Relief from Judgment:
Florida: 15 days from filing of judgment
Federal: 28 days from entry of judgment