1. At a 2/10/14 small claims motion hearing the judge made these rulings:

a. Denied: 1 Motion in Limine (MIL), 3 Motions to Take Judicial Notice (MTJD), 5 Motions to Compel (MTC) - Requests for Production (RFP), Requests for Admission (RFA), Answers to Interrogatories, a Motion to Activate Sound System and a Motion to Have Defendant pay costs

b. Denied without prejudice to offer at trial: 4 MILs

c. Took under advisement: a MIL (Causes of Action & Elements) and a Motion to Consolidate.

2. This county has a procedure (which may be standard throughout Florida) concerning pre-trial hearings requiring:

a. Prior to trial: counsel must discuss matters of law or fact about which there is no issue, any matters of law or fact that would simplify the issues or aid in the speedy disposition of the action and possible settlement.

b. At least ten days before trial: counsel must present a memorandum to the judge re general nature of the proceedings, factual contentions of each party, the type relief being sought the type counterclaim if any, the defenses interposed in the complaint, counter claim ..., all facts that either party will admit a schedule of exhibits and documentary evidence which may be used by the party at trial, a witness list, any requests for preliminary rulings on questions of law and supporting citations.

1. Could the pre-trial hearing procedure described above be the reason for the denials without prejudice and those motions taken under advisement?

2. What's the proper way to ask the judge to explain his ruling? While letting the opposing attorney wander from motion to motion, topic to topic he kept us on a short leash and was bothered by our questions.

3. Can objections be made in hearings? We know that Motions to Take Judicial Notice are appropriate.

4. Do the motions cited in paragraph 1 above need
a. be re-filed?
b. simply cited in a memorandum or a Motion for Reconsideration?
c. or something else?

5. Doesn't this pre-trial procedure frustrate & run counter to our efforts to get all the evidence in before trial?

6. Since this would be happening ten days prior to trial, when would there be time to file appeals, re-considerations etc?

7. Doesn't this make trial preparation even more difficult?

8. Any implication of bias against pro se litigants here? Isn’t the system described above in fact rewarding lawyers and denying justice to others?

9. How could Joe Six-pack ever have any expectation of justice -- even in a small claims environment? Those pre-trial requirements are intimidating.

10. How likely is it that we can prevail against this attorney-judge juggernaut?

William, thanks for that info.

Its Hard to follow what you are talking about since we know nothing about what was denied or admitted.

How much $ are stake?