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Under the end of judicial labor definition of finality, the trial court is required to use language in its order that conclusively demonstrates that judicial labor has ended. Difficulties in doing this have been experienced by Florida trial courts mainly where the order was in favor of the defendant.
A motion for reconsideration is a request that a court re-examine its decision on a specific matter. This motion is usually filed if a party thinks there was a legal mistake, if new evidence has come up, or if there has been a change in the law or circumstances.
How much time do I have to file a notice of appeal? Thirty days from the date the order you are appealing is filed in the lower tribunal or court or thirty days from the date an order on a motion tolling the time to appeal is filed. See Florida Rules of Appellate Procedure 9.020(h).
Time for Appealing a Non-Final Order. A party must file a notice of appeal of a non-final order in the lower tribunal clerks office within 30 days of the date that the non-final order is rendered, meaning the date the order is signed and filed with the lower tribunals clerks office.
A defendant who pleads guilty or nolo contendere may expressly reserve the right to appeal a prior dispositive order of the lower tribunal, identifying with particularity the point of law being reserved.
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A judgment which resolves all issues except matters, such as attorneys fees and costs, that are collateral to the merits, is immediately appealable.
How is an appeal started? Most appeals are started by filing a Notice of Appeal with the Clerk of the lower court or administrative agency within the time limits specified by the Florida Rules of Appellate Procedure (usually 30 days).
Civil non-final orders other than those specifically listed in Rule 9.130 are not reviewable unless the order qualifies under the strict standards of the appellate courts discretionary extraordinary writ jurisdiction such as certiorari, mandamus or prohibition, or are appealable orders under Florida Rule of Appellate

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