The Florida Bar

Judicial Practice Survey

Donald Lynn Graham

District Judge

The following information was provided in response to a survey prepared by the Federal Court Practice Committee of The Florida Bar. This information is not binding on any judge or court official and may not be relied upon for precedential purposes. Further information may be found in the attachments (sample orders, etc.) referenced at the end of this Guide entry or on the court's website noted below.

Judge

Name of Court:

Southern District of Florida

Location of Chambers:

United States District Court Wilkie D. Ferguson Jr. United States Courthouse 400 North Miami Avenue, Chambers 13-4, Miami, FL 33128

Assigned Courtroom:

13-4, 13th Floor

Phone:

(305) 523-5130

Chambers Staff

Judicial Assistant/Secretary:

Gina Wong

Phone:

(305) 523-5130

Courtroom Deputy:

Clara Foster

Phone:

(305) 523-5135

Court Reporter:

Carleen ("Carly") Horenkamp

Phone:

(305) 523-5138

Docket Clerk:

CM/ECF Help Desk

Phone:

(888) 318-2260

Communication with Chambers

Do you permit contact with chambers regarding questions of procedure?

Yes

Do you permit contact with chambers regarding the status of pending matters?

Yes

Pretrial Procedure (Criminal)

Do you conduct preliminary pretrial conferences in criminal cases?

Yes

If YES, what matters do you typically discuss during a preliminary pretrial conference?

Category III, IV, V, or multi-defendant cases.

Do you conduct hearings on pretrial motions to dismiss or to sever?

Yes

What is your policy as to plea agreements that involve sentencing recommendations?

A plea is scheduled at calendar call or in advance if parties agree on a date certain within the trial period. Generally, the Court follows Administrative Order 95-02 regarding sentencings.

Pretrial Procedure (Civil)

Do you conduct preliminary pretrial hearings, e.g., pursuant to Fed.R.Civ.P. 16?

Yes

If YES, what matters do you typically discuss during preliminary pretrial hearings?

Status conferences are scheduled approximately one (1) month after a responsive pleading and/or answer has been filed by the defendant.

Do you have any requirements, beyond those found in the Federal Rules and the Local Rules, as to ex parte temporary restraining orders?

Movants are normally required to serve the opposing party prior to ruling on the request for temporary restraining order. In some instances, matters are referred to the Magistrate Judge.

Do you hear preliminary injunction motions?

Yes

Should copies of published cases cited in motions and memoranda be forwarded to chambers?

No

Do you regularly set aside time during a given week/month for hearings on motions?

No

What is your practice concerning oral arguments on referred dispositive motions?

Oral argument on dispositive motions are rarely presented.

Discovery

Do you routinely refer discovery matters to a Magistrate Judge?

Yes

When a dispute arises during a deposition, is it appropriate to call your chambers (if the case has been referred for discovery) to seek an immediate ruling?

Yes

Trial

Do you grant specially set trial dates (dates certain)?

Yes

If YES, under what circumstances will you grant trial dates certain?

With reference to criminal proceedings, criminal cases under categories III, IV, V, and/or multi-defendant cases may be granted trial dates certain. Civil proceedings are rarely granted trial dates certain.

If NO, what is your policy regarding notice for trial during a trial docket (e.g., will you give at least 48 hours' notice)?

The Court attempts to give at least 24 hours notice, however, counsel should be prepared to be called for trial at any time during the trial period.

Do you conduct Daubert hearings prior to trial?

Yes

Do you require trial briefs in jury trials?

No

Do you require trial briefs in bench trials?

No

Do you permit counsel to perform voir dire?

Yes

If YES, what guidelines or restrictions must counsel follow when conducting voir dire?

Time limitations are imposed.

If YES, when should such questions be submitted?

N/A

What are your peremptory challenge procedures?

Parties alternate exercising preemptory challenges.

In multiple party cases, do you grant each party three peremptory challenges?

No

If NO, do you limit each side (i.e., plaintiff/defense) to a total of three peremptory challenges to be shared?

No.

Do you impose any standard time limits on counsel's opening statements?

Yes

If YES, what are the time limits?

Twenty (20) to thirty (30) minutes, however, the parties may request additional time.

Can exhibits be used in opening statements?

Yes

Do you permit jurors to take notes?

Yes

Do you permit jurors to ask questions?

Yes

What, if any, procedures do you have concerning objections at trial?

Parties are to stand and announce a short legal basis for the objection. Speaking objections are not allowed.

When do you require counsel to file proposed jury instructions?

Twelve days prior to trial period.

Do you require proposed findings of fact and conclusions of law to be filed in bench trials?

Yes

If YES, when do you require the proposed findings of fact and conclusions of law to be filed?

Twelve (12) days prior to trial period.

Attachments

Trial Procedures 2008.pdf

Torres Procedures 2009.pdf

Personal Statement 2010.pdf

Lynch Procedures 2009.pdf

Revised: 06-12-2018