How-To: Write a Motion for Leave to File a Reply
| Background: | Your opponent made an obtuse Response to your Motion |
| Problem: | General motion practice doesn't allow you to respond to a response |
| Solution: | You ask the Court for permission to file a Reply to the Response |
I. Definitions
II. Legal Citations
"(d) A motion requesting leave to file either a motion in excess of twenty-five (25) pages, a response in excess of twenty (20) pages, or a reply or further memorandum shall not exceed three (3) pages, shall specify the length of the proposed filing, and shall not include, as an attachment or otherwise, the proposed motion, response, reply, or other paper."
III. Samples
| # | Comments | ₧ | |
|---|---|---|---|
| 1 |  | TBD case. Pro Se Filing. USFLMD. Defendant responded after failing to object. |  |
| 2 | | Attorney Filing. USNYWD. 2007. Sur-reply. FOIA. FBI. Newly discovered information. | |
| 3 | | Attorney Filing. USNYWD. 2007. de bene esse deposition. Opponent mischaracterized the issues. | |
| 4 | | Attorney Filing. USNYWD. 2007. Letter form. "Usurpation of Judicial Authority". | |
| 5 | | ¿ Unknown Result ? Attorney Filing. DOAH. 2007. Mandamus. Out of office. | |
| 6 | | ✓ Granted! Attorney Filing. DOAH. 2008. Sex Charge vs No Sex Charge. | |
| 7 | | ✓ Granted! Attorney Filing. DOAH. 2010. Proposed Order. Fair Opportunity to Respond. | |
| 8 | | ¿ Unknown Result ? Attorney Filing. DOAH. 2012. Fundamental Disagreement. | |
| 9 | | X Denied. Attorney Filing. DOAH. 2015. Non-Party Subpoenas. +Quash. | |
| 10 | | ✓ Granted! Attorney Filing. DOAH. 2016. Timeliness of EEOC Charge. | |
| 11 | | - Withdrawn. Attorney Filing. DOAH. 2017. Demonstratively Incorrect Opposition. | |
IV. Templates
| # | Link | Comments | ₧ |
|---|---|---|---|
| 1 |  | DOAH Version | Replace all placeholder tags (eg "[plfName]" becomes "John Doe"). |  |
| 2 | | USFLMD Version | Replace all placeholder tags (eg "[plfName]" becomes "John Doe"). | |
V. Application
- Separate Filing: At USFLMD, do not submit your actual Reply within your Motion for Leave!
- see Local Rule 3.01(d) (above; Part I)
- Instead, file your Reply in a different document [than your Motion for Leave]
VI. Quick Commentary
- Important Note: At USFLMD, keep your motion to 3-pages-or-less (see Local Rule 3.01(d))
- Note: As always, confer with the opposing party beforehand.
- see Local Rule 3.01(g)
- see 28-106.204(g) FAC (above; Part I)
- Download as many sample documents as you'd like
- Contact TBD for more free samples
- Feel free to use the templates (see Part III - above) to help draft your 'Motion for Leave to Reply'
- Save the final version as a PDF file.
- File the final version in court
VII. Conclusion
So, make sure to tailor your request to your specific set of circumstances.
With the use of the template (as well as the samples above), you can more easily move the Court for Leave to File a Reply.
...POINTS & THINGS...
Please get the justice you deserve.
Sincerely,
www.TextBookDiscrimination.com
