As Co-Chair of the DCBA’s Civil Litigation Committee, Mr. Reyes helped organize a well-attended panel discussion on motion-calendar practice entitled, “Motion Calendar Practice: Preferences, Pitfalls, and Professionalism.” Armando Rosquete made the introductory remarks. Three judges from Miami-Dade County’s Eleventh Circuit—Judge Rodolfo Ruiz, Judge Migna Sanchez-Llorens and Judge Jorge E. Cueto—participated and provided those in attendance with their insights on issues such as:
- Motions that should and should not be set on motion calendar.
- The best response(s) when opposing counsel files a motion that is inappropriate for motion calendar and opposes specially setting the motion.
- The preferred course(s) of action if opposing counsel refuses to agree to dates for motion calendar or cancels multiple hearings that have been previously scheduled.
- Recommendations for lawyers who are arguing motions to compel during motion calendar.
- The most common mistakes that lawyers make in motion practice.
The judges called upon the lawyers in attendance to provide clear and concise motions as part of motion-calendar practice. They also emphasized the importance of staying within the five-minute limit both as a matter of “best practices” and professionalism. Each judge expressed their willingness to be flexible and available for special-set hearings if the motion is too substantive for a five-minute argument. The issue of attorneys’ conduct at depositions also came up as a topic of conversation.
Mr. Reyes acknowledges his co-chair who help organize this event, Mssrs. Juan Farach, Esq. and Armando Rosquete for his participation and his introduction of the moderator, the Moderator, Markenzy Lapointe.
