Amanda Arnold Sansone
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.
Name of Court:
Middle District of Florida
Location of Chambers:
10B (but I share a courtroom with Judge Susan Bucklew so my courtroom for hearings sometimes changes based on availability).
Email address (only for proposed orders or jury instructions):
Law Clerk phone number(s), only if you permit law clerk(s) to receive calls:
813-301-5782 (cases with an odd terminal digit), 813-301-5779 (cases with an even terminal digit)
Communication with Chambers
Do you permit contact with chambers regarding questions of procedure?
Do you permit contact with chambers regarding the status of pending matters?
May counsel contact chambers to speak with your law clerk(s) on procedural matters?
May counsel contact chambers to speak with your law clerk(s) on the status of pending matters?
Use of Cell Phones, Laptops, and Other Electronics in Court
Other than procedures adopted by the U.S. Marshal's Service relating to access to a federal courthouse, do you have any additional procedures to be followed for the use of cell phones, laptops, or other electronics?
The parties may file a motion for permission to bring cell phones, laptops, or other electroinics into the courthouse.
Is there a designated court staff person to contact relating to the use of electronic media or other audiovisual needs?
Cathy Morgan, Courtroom Deputy
Always verify with the Clerk of Court or the U.S. Marshal's Service as to any procedures relating to the use of cell phones or other electronic devices at the courthouse.
In addition to Local Rules or CM/ECF procedures applicable in the District:
Do you have a preferred method for counsel to correct an electronically filed document that inadvertently contains personal information (as prohibited by Fed.R.Civ.P. 5.2)?
Do you have a preferred method governing the filing of sealed documents?
The parties must comply with Local Rule 1.09.
Do you prefer that (non-trial) exhibits be filed as separate docket entries (instead of filing them as attachments to the document they support)?
When filing documents with multiple attachments, do you prefer that the document be filed such that it is displayed with bookmarks within the PDF image?
Do you prefer that (non-trial) exhibits and depositions be filed conventionally as well as on CM/ECF?
Do you prefer to have proposed orders (other than those required to be filed in the case) submitted as an attachment to documents filed in CM/ECF, or do you prefer to receive them by email or another method?
The parties only should submit proposed orders upon request.
Should proposed orders be submitted in a format which can be edited, or is a PDF version acceptable?
If a proposed order is requested, then counsel should email chambers the proposed order in word format.
Pretrial Detention/Pretrial Procedure (Criminal)
At bond hearings, do you permit the government to proceed by proffer or do you require a government agent to be present to testify?
If a proffer is permitted, can the defendant’s counsel call the government case agent and cross-examine him/her?
If a proffer is permitted, do you prefer that defense counsel present the family of the defendant as witnesses by proffer instead of calling individual witnesses?
What criteria do you apply in determining whether to impose a financial assessment on a defendant for the services of appointed counsel?
I consider the information contained in the financial affidavit.
Do you conduct preliminary pretrial conferences in criminal cases?
Do you require the defendant to be present at status conferences?
Do you have a regular plea deadline?
If NO, is a plea deadline set at pretrial conferences?
What is your policy concerning nolo contendere or Alford pleas?
Only permitted with the district judge's prior approval.
Do you have any special procedures regarding plea agreements for individuals who are cooperating with the government, e.g., sealed plea agreements, etc.?
Pretrial Procedure (Civil)
Do you issue a standard pretrial order?
Do you conduct preliminary pretrial hearings, e.g., pursuant to Fed.R.Civ.P. 16?
If YES, what matters do you typically discuss during preliminary pretrial hearings?
All matters contained in the parties' joint case management report as well as any other matters the parties bring to my attention.
Do you have any requirements, beyond those found in the Federal Rules of Civil Procedure and the Local Rules, as to motions for extension of time or motions for continuance?
Other than as required by Local Rules, do you prefer that the moving parties submit proposed orders along with non-dispositive motions?
Do you have any requirements, beyond those found in the Federal Rules and the Local Rules, as to ex parte temporary restraining orders?
Do you hear preliminary injunction motions?
If YES, do you permit evidence to be introduced?
Should copies of published cases cited in motions and memoranda be forwarded to chambers?
Should copies of unpublished opinions cited in motions and memoranda be forwarded to chambers?
If copies of cases are submitted, do you accept copies that have portions highlighted by counsel?
Do you regularly set aside time during a given week/month for hearings on motions?
Under what circumstances do you allow telephonic hearings?
Upon consideration of a request by the parties or if I am setting the matter on an emergency basis and counsel would have to arrange significant travel.
What is your practice concerning oral arguments on referred dispositive motions?
I will hear oral argument if any party requests it. Even if the parties do not request oral argument, I may set a hearing.
Will you entertain motions in limine prior to trial?
If YES, how far in advance should they be filed?
Fourteen days with an expedited response date of seven days prior to the start of the trial (always a date certain)
Do you receive referrals on discovery matters from a District Judge?
Other than those discovery schedules contained in Local Rules, do you have special discovery deadlines or procedures for certain types of cases (ERISA, FLSA, etc.)?
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?
If I am available, I will hear the dispute. Otherwise, an appropriate motion must be filed.
What is your preference regarding the use of alternative dispute resolution methods such as arbitration or mediation?
All civil cases are referred to private mediation. I will mediate cases upon referral by a district judge.
Do you require counsel to submit a proposed order referring the case to mediation?
Do you automatically set consent cases for trial or do you wait for counsel to propose a time period in which a case should be scheduled for trial?
I will coordinate trial dates with counsel. The date will either be set during a preliminary pretrial conference or during the final pretrial conference.
Do you grant specially set trial dates (dates certain)?
If YES, under what circumstances will you grant trial dates certain?
What is your practice or procedure regarding rescheduling trials that are not reached on a trial docket, e.g., will the trial date be automatically rescheduled on your next trial docket?
Not applicable as all trials are set for a date certain and I have cleared my calendar accordingly.
Do you conduct pretrial conferences?
Do you conduct Daubert hearings prior to trial?
What, if any, procedural requirements do you have regarding the use of videotapes, trial graphics, depositions, and demonstrations?
I strongly encourage counsel to test the courtroom equipment prior to the trial or hearing.
Do you require trial briefs in jury trials?
Do you require trial briefs in bench trials?
If you require trial briefs, when are they due?
Fourteen days before trial
Do you have any requirements for trial briefs?
Trial brief requirements vary and will be addressed at the final pretrial conference. Trial Briefs must contain citations of authority and legal argument for the disputed issues likely to arise at trial. Not all jury trials require trial briefs.
Do you permit counsel to perform voir dire?
If YES, what guidelines or restrictions must counsel follow when conducting voir dire?
After I finish voir dire, I permit very limited, short voir dire by counsel. Parameters for voir dire will be addressed at the final pretrial conference.
If NO, can counsel submit proposed voir dire questions?
If YES, when should such questions be submitted?
Fourteen days before trial.
What are your peremptory challenge procedures?
Exercise challenges against the number of jurors and alternates needed (for example, a civil jury usually has six jurors plus two alternate jurors). with backstriking allowed before acceptance.
In multiple party cases, do you grant each party three peremptory challenges?
If NO, do you limit each side (i.e., plaintiff/defense) to a total of three peremptory challenges to be shared?
Do you allow back striking during jury selection?
Do you impose any standard time limits on counsel's opening statements?
If YES, what are the time limits?
I will address time limits with counsel at the final pretrial conference. I will also address the extent to which exhibits can be used during opening statements.
Can exhibits be used in opening statements?
Do you allow plaintiffs to make a rebuttal during opening statements?
Do you permit jurors to take notes?
Do you permit jurors to ask questions?
What, if any, procedures do you have concerning objections at trial?
State objections and legal grounds only. Do not argue your objection from counsel table.
When do you require counsel to file proposed jury instructions?
Fourteen days before trial.
Should jury instructions also be submitted to chambers electronically?
When standard jury instructions are available, do you prefer that attorneys submit condensed versions of the standard instructions?
Do you require proposed findings of fact and conclusions of law to be filed in bench trials?
If YES, when do you require the proposed findings of fact and conclusions of law to be filed?
Fourteen days before trial.
Should the proposed findings and conclusions also be submitted to chambers electronically?
The proposed findings and conclusions should be emailed to chambers in word format.
What should lawyers avoid at all costs when appearing before you (other than the obvious: don't be late, do be courteous, etc.), i.e., do you have any "pet peeves"?
Counsel must strictly comply with Local Rule 3.01(g).
Do you have any other practice pointers, advice, observations, or suggestions for members of the Bar appearing before you?
Read the Middle District Discovery Manual.
Links to your court's webpage with information about your practices or other links you recommend for practitioners: