Practice Note, September 2026.  One important procedural difference between the federal courts of New York and Florida lies in their approach to interrogatories. In the Southern District of New York (SDNY), Local Civil Rule 33.3 significantly restricts the use of interrogatories. At the outset of litigation, parties may only serve interrogatories seeking (i) the names of … read more here

Practice Note, January 2026.  Practitioners in the Middle District of Florida confront a procedural landscape unlike that in many other federal courts. Local Rule 3.01(e) provides that, absent leave of court, no party may file a reply directed to a response “except for a reply to a motion for summary judgment or a reply brief in a … read more here

Conferral Obligations in the M.D. and S.D. of Florida Practice Note, October 2025.  A significant procedural distinction exists between the U.S. District Courts for the Southern and Eastern Districts of New York (“SDNY/EDNY”) and the U.S. District Courts for the Middle and Southern Districts of Florida (“M.D./S.D. Florida”) with respect to motion practice. While these courts seek to streamline … read more here