Virginia M. Hernandez Covington graduated cum laude with a Bachelor of Science degree from the University of Tampa in 1976 and in 1977, Judge Covington received the degree of Master of Business Administration, also from the University of Tampa. Judge Covington then attended Georgetown University Law Center, where she received her Juris Doctor degree in 1980.
Judge Covington began her career as a trial attorney for the Federal Trade Commission and thereafter became an Assistant State Attorney for Hillsborough County, Florida. In 1983, Judge Covington joined the United States Attorney’s Office for the Middle District of Florida. On September 25, 2001, Judge Covington was appointed to Florida’s Second District Court of Appeal by Governor Jeb Bush. She served on that court until receiving her commission as a United States District Judge on September 10, 2004.
Do you permit counsel to contact assigned law clerks?
Is it appropriate to telephone Chambers regarding questions of procedure on pending matters?
PRETRIAL PROCEDURE (CIVIL):
Preliminary Pretrial Hearings:
Do you conduct preliminary pretrial hearings?
Do you refer preliminary pretrial hearings to a United States Magistrate Judge?
Should courtesy copies of pleadings and motions be forwarded to Chambers?
Should copies of cases cited in motions and memoranda be forwarded to Chambers?
Is it appropriate to cite unpublished opinions in motions or memoranda?
Do you allow telephonic hearings?
What can an attorney do to call attention to a pending motion of particular importance to expedite ruling?
How far in advance of the trial should motions in limine be filed?
Do you regularly set aside time during a given week/month for hearings on motions?
What are your procedures concerning ex-parte temporary restraining orders?
Do you hear preliminary injunction motions?
If yes, do you limit the hearing to argument of counsel?
If no, does the Court routinely refer preliminary injunctions for report and recommendation by a United States Magistrate Judge?
If no, what are your procedures for the receipt of evidence during a hearing on a preliminary injunction?
What is your practice concerning oral arguments on dispositive motions?
What is your policy/practice regarding the use of alternative dispute resolution devices such as court-annexed, non-binding arbitration and mediation?
Do you personally conduct settlement discussions?
Do you refer discovery matters to a United States Magistrate Judge?
When a dispute arises during a deposition, is it appropriate to call the Magistrate Judge’s Chambers to seek an immediate ruling?
Do you personally conduct pretrial conferences in your cases?
If yes, do you have a standing order regarding pretrial conferences?
PRETRIAL PROCEDURE (CRIMINAL):
Preliminary Pretrial Hearings:
Do you personally conduct preliminary pretrial conferences in criminal cases?
Do you refer preliminary pretrial conferences to United States Magistrate Judges?
What is your policy concerning nolo contendre or Alford pleas?
What is your policy concerning plea arrangements that involve sentencing recommendations?
Do you grant trial dates certain?
If a case is not reached during the scheduled trial term, will the trial date be automatically rescheduled on your next trial docket?
What is your policy regarding notice of being called for trial during a trial docket?
Do you require trial briefs in jury trials?
Do you require trial briefs in bench trials?
What are your requirements for trial briefs?
Do you require proposed findings of fact and conclusions of law to be filed in bench trials?
If yes, when do you require the proposed findings of fact and conclusions of law to be filed?
Should findings of fact and conclusions of law filed in connection with a bench trial also be submitted to chambers on a disk?
When do you require parties to file proposed jury instructions?
Where standard jury instructions are available, do you prefer that attorneys submit condensed versions of the standard instructions?
Should jury instructions also be submitted to Chambers on a computer disk?
Do you permit counsel to perform voir dire?
If yes, what guidelines or restrictions must counsel follow when conducting voir dire?
If the Court conducts voir dire, can parties submit proposed voir dire questions?
If yes, when should such questions be submitted?
What are your preemptory challenge procedures?
In multiple party cases, do you grant each party three preemptory challenges?
If no, do you limit each side [i.e., plaintiff/defense] to a total of three preemptory challenges to be shared?
Do you allow back striking during jury selection?
Do you have any standard time limits imposed upon counsel?
Can exhibits be used in opening statements?
Do you allow plaintiffs to make a rebuttal during opening statements?
Use of Expert:
Do you conduct Daubert hearings prior to trial?
Procedure for Use of Videotapes, Trial Graphics, Depositions, and Demonstrations:
What, if any, procedural requirements to you have relative to the use of videotapes, trial graphics, depositions, and demonstrations?
Procedure for Objections:
What, if any, procedures do you have concerning objections at trial?
Do you permit jurors to take notes?
Do you permit jurors to ask questions either orally or in writing?
Do you allow the submission of sentencing memoranda?
If yes, under what circumstances do you allow such submission?
Do you divulge the probation officer’s sentencing recommendation?
Is there a deadline for filing motions to continue sentencing?