New DCA Ruling: Palm Beach County Clerk’s Office No Longer to Accept Paper Filings from Attorneys

Effective Thursday, September 1, 2016, the Clerk’s office will no longer accept paper filings from attorneys pursuant to United Bank v. Estate of Edward G. Frazee, 4D15-826; 2016 Fla. App. LEXIS 10780 (Fla. 4th DCA 2016).  In this case it was held that “since filing is only accomplished through electronic submission (in the absence of a Rule 2.525 exception), a document is not actually ‘filed’ when improperly submitted to the clerk in paper…” id at 6.

In 2013, E-filing of court documents became mandatory for attorneys. Beginning September 1, the Clerk’s office will reject paper filings unless said meets one of the following criteria:

  • Florida Rules of Judicial Administration 2.525.(d)

(3)   Filing by attorneys excused from email service in accordance with rule 2.516(b)

(4)   Submitting evidentiary exhibits or filing non-documentary material

(5)   Filing involves documents in excess of the appropriate size limitations specified in the Florida Supreme Court Standards for Electronic Access to Court.  For such filings, documents may be transmitted using an electronic storage medium, which may include a CO-ROM, flash drive, or similar storage medium

(6)   Filings made in open court, as permitted by the court

(7)   If paper filing is permitted by any approved statewide or local ECF procedures

(8)   If any court determines that justice so requires.

  • Documents which require the attorney to attach prepaid postage (Notice of Action)
  • Original documents (mortgages, notes, wills and death certificates)
  • Informations and indictments cannot be E-filed

For more information about E-Filing, visit

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