Florida Civil Motion, Summary Judgment, and Deposition Checklist

A motion hearing, a summary-judgment motion or response, and an oral deposition are not interchangeable calendar events. Begin with the exact case, court, division, parties, assigned judge, lawyer-selected task, requested relief or discovery event, current docket, case-management and trial orders, applicable statewide rules, local administrative orders, and current judge procedures. Record the authority version and access date before building the work plan.

The responsible lawyer decides the motion or deposition type, legal basis, claims or defenses, relief, burden, record, witness or entity, scope, objections, privilege, evidence, discovery response, and deadlines. Staff can maintain source registers, exact-set control, filing and service evidence, logistics, status, and escalation without choosing a legal theory or treating a prior case’s procedure as controlling.

For an attorney-selected ordinary motion, create a control record for the requested relief, governing authority, supporting record, conferral decision, filing and service plan, hearing route, notice, court-delivery requirements, proposed order, and post-hearing proof. Rule 1.202 applies a prefiling conferral requirement to non-dispositive motions and lists exemptions, including summary judgment and other specified motions. The lawyer decides whether the motion is non-dispositive, whether an exemption applies, what good-faith conferral requires, and what the certificate must state.

Do not assume that an available hearing slot, a prior motion template, or a scheduler’s confirmation supplies authority to file or hear the motion. Case-management orders, local orders, assigned-judge procedures, emergency or expedited requirements, page or exhibit limits, courtesy-copy or submission rules, and a court’s directions may control or supplement the statewide rules.

The October 1, 2026 version of Rule 1.510 does not use the former statewide formulation that measured the motion and response as 40 and 20 days before the hearing. The current rule states that the movant must file and serve the motion consistent with court-ordered deadlines and serve its supporting factual position with the motion. It states that the nonmovant must serve a response, including the supporting factual position, no later than 40 days after service of the motion. The hearing must be at least 10 days after the response deadline unless the parties stipulate or the court orders otherwise.

Treat those rule statements as authority inputs, not permission for staff to calculate or select a case deadline. The lawyer must reconcile the current rule with the motion service event, case-management or trial order, court-set date, stipulation, judge procedures, extensions, amended filings, discovery posture, and any later rule change. Preserve the written calculation and approving lawyer rather than relying on a generic template date.

Rule 1.510 requires a party asserting that a fact cannot be or is genuinely disputed to cite particular parts of record materials or address the absence of admissible support. Build the lawyer-approved factual-position table proposition by proposition, with the exact source, docket entry, page, paragraph, line, exhibit, quoted text, record status, and any contrary or missing material. Preserve the complete source separately from excerpts and demonstratives.

Staff does not label a proposition material, undisputed, admissible, proven, or sufficient; decide whether a claim or defense or part should be presented; select the burden; resolve objections; or determine relief. Those are lawyer decisions. Staff verifies that the approved proposition says what the cited source says, that the citation opens the correct material, and that every filed or delivered version uses the approved record reference.

A litigation event moves through distinct states. Preserve whether each document was approved, signed, submitted, accepted, docketed, served, delivered to the judge or uploaded through a separate court system, scheduled, noticed, amended, withdrawn, heard, orally ruled on, signed, and entered. One receipt or calendar invitation does not prove the other states.

Before release, verify the exact caption and case, document code and title, signature and verification, attachments and exhibit order, bookmarks or accessibility, confidentiality and redaction, service list and method, hearing details, proposed-order format, and any judge-specific delivery route. After release, compare the docket and service evidence with the approved set and preserve every rejection, correction, resubmission, and changed notice.

For a lawyer-approved deposition, separately verify the deponent and capacity, party or nonparty status, entity designation if any, date and time, physical or remote location, officer and reporter, recording method, notice, subpoena, witness fee, interpreter or accommodation, production request, exhibits, confidentiality controls, technology test, and confirmation. A notice, subpoena, invitation, vendor booking, and witness confirmation are different artifacts.

Rule 1.310(b)(7) permits a deposition by communication technology only when the parties stipulate or the court orders it. The notice must state in its title that the deposition will be taken by communication technology, identify the specific technology, and provide instructions for access. Remote attendance is not the same as audiovisual recording; if the deposition will also be audiovisually recorded, Rule 1.310(b)(4)’s separate notice and recording requirements apply. Audiovisually recorded depositions must also be recorded stenographically, unless all parties agree otherwise, and the recording’s safeguarding and access requirements remain distinct controls.

Apply confidentiality, privacy, sealing, redaction, privilege, work-product, protective-order, trade-secret, health-record, minor, safety, and accommodation holds before filing, service, exhibit exchange, vendor transfer, remote access, recording, or public presentation. Rule 1.020 and the general-practice rules address privacy and court records, but the lawyer decides what may be filed, withheld, redacted, sealed, used, or disclosed in the specific matter.

Preserve source records and approved working copies with stable identifiers. Limit vendor and participant access, use approved channels, verify shared links and permissions, and keep a disclosure record. If privileged or protected material may have been exposed, stop distribution and route notice, clawback, remediation, and court-action decisions to the lawyer.

After a hearing, preserve attendance, exhibits used, court directions, oral ruling notes attributed to their source, requested follow-up, proposed-order process, and the exact signed and entered order. An oral statement, minute entry, unsigned draft, signed order, and docketed or entered order are separate statuses. The lawyer decides the ruling’s meaning, compliance, rehearing, appeal, and downstream legal effect.

After a deposition, reconcile attendance, reporter and recording details, exhibits, objections or unresolved events, transcript order and receipt, errata or review activity, corrections, confidentiality, final certified record, and approved use. The lawyer controls testimony interpretation, designation, impeachment, motion or trial use, and whether another discovery or protective step is required.

Close the workflow only when the docket or transcript record, service and delivery proof, calendar, deadlines, outstanding evidence, next action, responsible owner, and unresolved exceptions agree. Reopen it when the court, witness, reporter, party, source record, order, or rule changes.