Court Rules
Judge

Judge Hector Gonzalez

Individual Rules, Standing Orders & Policies

Rules last changed:
Eastern District of New York

Limits & Logistics

Document Limits

Pre Motion Response Letter
3 pgs
Memorandum Of Law
25 pgs
Affidavit
10 pgs
Exhibit
15 pgs
Local Rule 56 1 Statement
25 pgs
Local Rule 56 1 Additional Material Facts Section
10 pgs

Courtesy Copies

Courtesy copies

  • 2 copies

Binding: Tabbed Three Ring

Filings >= 25 pages

  • 1 copy • Chambers Drop Off • Upon Filing

Binding: Spiral

Indictment, Information, Complaint

  • As Soon As Practicable

Information

  • With Plea Agreement

Adjournments

3Business Daysnotice
  • Adjournment or extension requests must be filed at least three business days before the relevant deadline or appearance unless there is an emergency.
  • Adjournment or extension requests must be filed by ECF letter (except pro se) and include specified prior-date, history, consent, schedule, and grounds information.

Request must include

Original DateNumber Of Previous RequestsPrevious Requests Granted Or DeniedAdversary PositionAffects Other DatesProposed New DatesReason For Request
5Business Daysnotice
  • Requests to exceed memorandum page limits must be in writing 5 business days before the due date, except reply-brief requests which require at least 3 business days.
10Business Daysnotice
  • Sentencing adjournment applications must be filed in writing at least 10 business days before sentencing.

Communication

Email

Chambers

gonzalez_chambers@nyed.uscourts.gov
Scheduling
Phone

Intake Unit

(718) 613-2665
Technical Issues
Phone

Chambers

Emergencies
Filters:AllMandatoryImportantFormattingMemorandaLettersSummary JudgmentExhibitsECF Filing56.1 StatementsJury

Page & Word Limits6 rules

Page Limits

Machine summary. Not checked yet.Mandatory?

The response shall not exceed three pages.

Summary: Pre-motion response letters are limited to three pages.

Pre Motion Response Letter

3 pages

Page Limits

Machine summary. Not checked yet.Mandatory?

Unless prior permission has been granted, memoranda of law in support of or in opposition to motions are limited to 25 double-spaced pages and reply memoranda are limited to 10 double-spaced pages.

Summary: Support/opposition memoranda are limited to 25 pages and reply memoranda are limited to 10 pages unless prior permission is granted.

Memorandum Support Or Opposition

25 pages

Reply Memorandum

10 pages

HG-MLR · Oct 2025 · p. 7
|SecB. Motion Papers
Page Limits

Machine summary. Not checked yet.Mandatory?

Each exhibit—other than the complaint—is limited to 15 pages.

Summary: Each exhibit is limited to 15 pages, except the complaint.

Exhibit

15 pages

HG-MLR · Oct 2025 · p. 8
|SecB. Motion Papers 5(a)
Page Limits

Machine summary. Not checked yet.Mandatory?

Affidavits may not exceed 10 double- spaced pages.

Summary: Affidavits in support of or opposition to a motion are limited to 10 double-spaced pages.

Affidavit

10 pages

HG-MLR · Oct 2025 · p. 8
|SecB. Motion Papers 5(a)
Page Limits

Machine summary. Not checked yet.Mandatory?

The moving party’s Local Rule 56.1 statement may not exceed 25 double-spaced pages without prior permission of the Court.

Summary: A moving party’s Local Rule 56.1 statement is capped at 25 double-spaced pages unless the Court grants prior permission.

Local Rule 56 1 Statement

25 pages

Page Limits

Machine summary. Not checked yet.Mandatory?

If the opposing statement includes a separate section of additional material facts, that separate section may not exceed 10 double-spaced pages.

Summary: Any separate additional-material-facts section in the opposing Rule 56.1 statement is limited to 10 double-spaced pages.

Local Rule 56 1 Additional Material Facts Section

10 pages

Document Format Requirements9 rules

Formatting

Machine summary. Not checked yet.Mandatory?

Proposed orders, jury instructions, and other submissions for adoption by the Court shall be filed on ECF and emailed to Chambers in PDF and Microsoft Word format.

Summary: Proposed orders, jury instructions, and similar submissions must be provided in PDF format via ECF and email to Chambers.

Required Format

PDF

HG-MLR · Oct 2025 · p. 4
|SecIII.B. Word Processing Files of Certain Submissions
Formatting

Machine summary. Not checked yet.Mandatory?

Use Times New Roman 12-point font for all text, including footnotes, and one-inch margins on all sides. Do not use excessive block quotations. Condensing or kerning of character spacing is not permitted.

Summary: Memoranda must use Times New Roman 12-point font, one-inch margins, and may not use condensed or kerned character spacing.

Typography
Font FamilyTimes New Roman
Size12 pt
Layout & Binding
Margins
Top:1"
Left:1"
Right:1"
Bottom:1"
HG-MLR · Oct 2025 · p. 7
|SecB. Motion Papers
Formatting

Machine summary. Not checked yet.Mandatory?

Deposition transcripts submitted as exhibits to motions for summary judgment should include only one page of testimony per page of exhibit. Parties may not submit “mini-transcripts” with four pages of testimony condensed onto one page in an effort to circumvent the Court’s page limits.

Summary: Summary judgment deposition exhibits must use one testimony page per exhibit page, and mini-transcripts are prohibited.

HG-MLR · Oct 2025 · p. 8
|SecB. Motion Papers 6(a)
Formatting

Machine summary. Not checked yet.Mandatory?

Use Times New Roman 12-point font for all text and one-inch margins on all sides.

Summary: Affidavits must use Times New Roman 12-point font and one-inch margins.

Typography
Font FamilyTimes New Roman
Size12 pt
Layout & Binding
Margins
Top:1"
Left:1"
Right:1"
Bottom:1"
HG-MLR · Oct 2025 · p. 8
|SecB. Motion Papers 5(a)
Formatting

Machine summary. Not checked yet.Mandatory?

All memoranda regarding motions in limine must be prepared in accordance with the requirements of Section IV.B.2, above, specifying the proper formatting and page limits for memoranda.

Summary: Memoranda on motions in limine must comply with the standing formatting and page-limit requirements in Section IV.B.2.

HG-MLR · Oct 2025 · p. 12
|SecFilings Prior to Trial in Civil and Criminal Cases
Formatting

Machine summary. Not checked yet.Mandatory?

Requests to charge, proposed verdict sheets and proposed voir dire questions shall be filed on ECF and provided to Chambers in PDF and Microsoft Word formats no later than 10 business days before trial, unless otherwise ordered by the Court.

Summary: Requests to charge, proposed verdict sheets, and proposed voir dire questions must be filed on ECF and provided to Chambers in PDF and Word at least 10 business days before trial unless otherwise ordered.

HG-MLR · Oct 2025 · p. 12
|SecFilings Prior to Trial in Civil and Criminal Cases
Formatting

Machine summary. Not checked yet.Important?

All written submissions and supporting materials must be text-searchable, to the extent practicable.

Summary: Written submissions and supporting materials must be text-searchable where practicable.

HG-MLR · Oct 2025 · p. 3
|SecIII.A.1 Mandatory ECF Filing
Formatting

Machine summary. Not checked yet.Important?

All exhibits to affidavits or affirmations must be separately tabbed and indexed, whether on ECF or courtesy copies.

Summary: Exhibits to affidavits or affirmations must be separately tabbed and indexed for both ECF and courtesy copies.

HG-MLR · Oct 2025 · p. 8
|SecB. Motion Papers
Formatting

Machine summary. Not checked yet.Important?

On motions for summary judgment, do not attach complete deposition transcripts as exhibits to affidavits or affirmations. Attach only pages containing relevant testimony to which citation is made in the memoranda or affidavits. However, any excerpted submissions must anticipate and comply with Fed. R. Evid. 106. In other words, include the portion of the excerpt necessary for completeness.

Summary: For summary judgment motions, only relevant deposition excerpts may be attached, and excerpts must include material needed for completeness under Rule 106.

HG-MLR · Oct 2025 · p. 8
|SecB. Motion Papers 6

Document Filing Requirements32 rules

Filing Requirements

Machine summary. Not checked yet.Mandatory?

Any such request shall be designated as a “Motion” on ECF even if made in the form of a letter or a joint stipulation with a proposed order, and the ECF entry line must identify the nature of the request as related to an adjournment or extension.

Summary: Adjournment or extension requests must be docketed as motions and clearly labeled as adjournment/extension requests in the ECF entry.

Document Type

Adjournment Or Extension Request

Specific requirements detailed in rule text.
HG-MLR · Oct 2025 · p. 2
|SecC. Requests for Adjournments or Extensions of Time
Filing Requirements

Machine summary. Not checked yet.Mandatory?

In criminal matters, if a party seeks an exclusion of time under the Speedy Trial Act, 18 U.S.C. § 3161, it must confer with the opposing party and indicate in its letter-motion whether the parties consent. The party seeking exclusion must include in its request for adjournment or extension facts that would permit the Court to make an independent finding whether or not to exclude time in conformance with 18 U.S.C. § 3161, and must also submit to the Court a proposed order excluding time under the Speedy Trial Act.

Summary: Speedy Trial Act exclusion requests in criminal cases must include conferral/consent information, supporting facts, and a proposed exclusion order.

Document Type

Adjournment Or Extension Request

Content & Formatting
Proposed Order
HG-MLR · Oct 2025 · p. 2
|SecC. Requests for Adjournments or Extensions of Time
Filing Requirements

Machine summary. Not checked yet.Mandatory?

All requests for relief from the Court, whether by letter or formal motion papers, shall be designated as a “Motion” on ECF. In addition, the ECF entry line must designate the subject matter of the letter or motion (e.g., “Letter motion requesting extension of time to respond to interrogatories”) not simply “Letter.”

Summary: Any request for relief must be docketed as a Motion, and the ECF entry must state the specific subject matter.

Document Type

Motion

Specific requirements detailed in rule text.
HG-MLR · Oct 2025 · p. 3
|SecIII.A.5 Mandatory ECF Filing
Filing Requirements

Machine summary. Not checked yet.Mandatory?

Any attorney appearing before the Court must enter a notice of appearance on ECF.

Summary: Any attorney who appears must file a notice of appearance on ECF.

Document Type

Notice Of Appearance

Specific requirements detailed in rule text.
HG-MLR · Oct 2025 · p. 3
|SecA. Attendance by Principal Trial Counsel
Filing Requirements

Machine summary. Not checked yet.Mandatory?

If the movant is seeking to file a motion for summary judgment under Rule 56, the non-movant’s response letter must include the non-movant’s Rule 56.1 opposing statement. The non-movant’s Rule 56.1 opposing statement must respond to the moving party’s Rule 56.1 statement line-by-line as required by the Local Rules.

Summary: A Rule 56 pre-motion response letter must include a line-by-line Rule 56.1 opposing statement.

Document Type

Pre Motion Response Letter

Specific requirements detailed in rule text.
Filing Requirements

Machine summary. Not checked yet.Mandatory?

All Rule 56.1 statements and opposing statements filed in connection with a pre-motion letter must reference and attach all relevant exhibits. Citations in a brief or Rule 56.1 statement to an exhibit should reference the exhibit by its exhibit number or letter (i.e. “Exhibit A”) and the page number or Bates number containing the referenced information.

Summary: Rule 56.1 statements in pre-motion practice must attach relevant exhibits and cite them by exhibit identifier and page or Bates number.

Document Type

Rule 56 1 Statement

Content & Formatting
Exhibit List
Filing Requirements

Machine summary. Not checked yet.Mandatory?

Except in pro se cases, the Local Rule 56.1 statement by a party opposing summary judgment shall quote verbatim the moving party’s Local Rule 56.1 statement and shall respond to each allegation in the moving party’s statement immediately beneath each allegation.

Summary: In non-pro se cases, an opposing Rule 56.1 statement must quote each moving-party allegation verbatim and respond directly beneath it.

Document Type

Local Rule 56 1 Opposition Statement

Specific requirements detailed in rule text.
HG-MLR · Oct 2025 · p. 8
|SecB. Motion Papers 7
Filing Requirements

Machine summary. Not checked yet.Mandatory?

Any party appealing a Magistrate Judge’s Order of Release or Order of Detention shall include a copy of the transcript before the Magistrate Judge with their motion.

Summary: A motion appealing a magistrate judge’s release or detention order must include the transcript from the magistrate proceeding.

Document Type

Release Or Detention Order Appeal Motion

Specific requirements detailed in rule text.
HG-MLR · Oct 2025 · p. 9
|SecMOTIONS IN CRIMINAL CASES
Filing Requirements

Machine summary. Not checked yet.Mandatory?

In a multi-defendant case, all filings must designate the defendant or defendants, and only the defendant or defendants, as to whom the filing pertains.

Summary: In multi-defendant criminal cases, each filing must identify exactly which defendant(s) it concerns.

Document Type

Filing

Specific requirements detailed in rule text.
HG-MLR · Oct 2025 · p. 10
|SecPRETRIAL PROCEDURES - Criminal Cases - Filings
Filing Requirements

Machine summary. Not checked yet.Mandatory?

Jurisdiction. A brief statement by the plaintiff explaining the basis of subject matter jurisdiction, and a brief statement by the defendant on the presence or absence of subject matter jurisdiction.

Summary: The joint proposed pretrial order must include plaintiff and defendant statements addressing subject matter jurisdiction.

Document Type

Joint Pretrial Order

Specific requirements detailed in rule text.
HG-MLR · Oct 2025 · p. 10
|SecPRETRIAL PROCEDURES - Civil Cases
Filing Requirements

Machine summary. Not checked yet.Mandatory?

Parties and Counsel. The names, addresses (including firm names), and telephone numbers of trial counsel.

Summary: The joint proposed pretrial order must list trial counsel names, firm/address information, and phone numbers.

Document Type

Joint Pretrial Order

Specific requirements detailed in rule text.
HG-MLR · Oct 2025 · p. 10
|SecPRETRIAL PROCEDURES - Civil Cases
Filing Requirements

Machine summary. Not checked yet.Mandatory?

Unless otherwise ordered by the Court, the parties shall submit to the Court a proposed joint pretrial order either: (a) within 60 days of the completion of fact or expert discovery, whichever occurs later; or (b) if a summary judgment motion has been filed, within 30 days after a decision on such motion.

Summary: Parties must submit a proposed joint pretrial order within 60 days after discovery completion or, if summary judgment was filed, within 30 days after that decision unless the Court orders otherwise.

Document Type

Joint Pretrial Order

Specific requirements detailed in rule text.
HG-MLR · Oct 2025 · p. 10
|SecPRETRIAL PROCEDURES - Civil Cases
Filing Requirements

Machine summary. Not checked yet.Mandatory?

At least two business days prior to any status conference, including the initial conference described above, if a party will seek an exclusion of time under the Speedy Trial Act, 18 U.S.C. § 3161, it must provide the Court a letter setting forth sufficient facts that would permit the Court to make an independent finding whether or not to exclude time in conformance with 18 U.S.C. § 3161.

Summary: A party seeking a Speedy Trial Act exclusion must submit a fact-supported letter at least two business days before the status conference.

Document Type

Speedy Trial Exclusion Letter

Specific requirements detailed in rule text.
HG-MLR · Oct 2025 · p. 10
|SecPRETRIAL PROCEDURES - Criminal Cases - Status Conferences
Filing Requirements

Machine summary. Not checked yet.Mandatory?

Caption. The full caption of the action.

Summary: The joint proposed pretrial order must contain the full case caption.

Document Type

Joint Pretrial Order

Content & Formatting
Caption
HG-MLR · Oct 2025 · p. 10
|SecPRETRIAL PROCEDURES - Civil Cases
Filing Requirements

Machine summary. Not checked yet.Mandatory?

The plaintiff’s exhibits must be identified with numbers using the prefix “PX,” and the defendant’s exhibits must be identified with numbers using the prefix “DX.” Except for good cause shown, only exhibits listed will be received in evidence.

Summary: Plaintiff exhibits must use PX numbering and defendant exhibits must use DX numbering, and only listed exhibits are admissible absent good cause.

Document Type

Exhibits

Specific requirements detailed in rule text.
HG-MLR · Oct 2025 · p. 11
|SecPretrial Order
Filing Requirements

Machine summary. Not checked yet.Mandatory?

Consent to Trial by a Magistrate Judge. A statement as to whether all parties have consented to trial of the case by a magistrate judge. The statement shall not identify which parties have or have not consented.

Summary: The pretrial submission must state whether all parties consent to magistrate trial, without identifying which parties did or did not consent.

Document Type

Pretrial Order

Specific requirements detailed in rule text.
HG-MLR · Oct 2025 · p. 11
|SecPretrial Order
Filing Requirements

Machine summary. Not checked yet.Mandatory?

Deposition Testimony. A designation by each party of deposition testimony to be offered in its case in chief, with any cross-designations and objections by any other party.

Summary: Each party must designate deposition testimony for its case in chief, including cross-designations and objections.

Document Type

Pretrial Order

Specific requirements detailed in rule text.
HG-MLR · Oct 2025 · p. 11
|SecPretrial Order
Filing Requirements

Machine summary. Not checked yet.Mandatory?

Witnesses. A list of fact and expert witnesses whose testimony is to be offered in each party’s case in chief, along with the address of each witness and a brief narrative statement of the expected testimony of each witness. Only listed witnesses will be permitted to testify, except when prompt notice has been given and upon good cause shown.

Summary: Each party must list fact and expert witnesses with addresses and expected testimony, and unlisted witnesses are barred absent prompt notice and good cause.

Document Type

Pretrial Order

Specific requirements detailed in rule text.
HG-MLR · Oct 2025 · p. 11
|SecPretrial Order
Filing Requirements

Machine summary. Not checked yet.Mandatory?

Exhibits. A schedule listing exhibits to be offered in evidence and, if not admitted by stipulation, the party or parties that will be offering them.

Summary: Parties must include an exhibit schedule identifying exhibits and the offering party if not stipulated into evidence.

Document Type

Pretrial Order

Specific requirements detailed in rule text.
HG-MLR · Oct 2025 · p. 11
|SecPretrial Order
Filing Requirements

Machine summary. Not checked yet.Mandatory?

Jury or Bench Trial. A statement by each party as to whether the case is to be tried with or without a jury, and the number of trial days needed.

Summary: Each party must state whether trial is jury or bench and estimate trial length in days.

Document Type

Pretrial Order

Specific requirements detailed in rule text.
HG-MLR · Oct 2025 · p. 11
|SecPretrial Order
Filing Requirements

Machine summary. Not checked yet.Mandatory?

Claims and Defenses. A brief summary by each party of the elements of its remaining asserted claims and defenses. These summaries shall include citations to all statutes relied on but should not recite evidentiary matters.

Summary: Each party must provide a brief summary of remaining claims and defenses with statutory citations, without reciting evidentiary matter.

Document Type

Pretrial Order

Specific requirements detailed in rule text.
HG-MLR · Oct 2025 · p. 11
|SecPretrial Order
Filing Requirements

Machine summary. Not checked yet.Mandatory?

Stipulations. A statement of stipulated facts, if any.

Summary: The pretrial submission must include a statement of stipulated facts if any exist.

Document Type

Pretrial Order

Specific requirements detailed in rule text.
HG-MLR · Oct 2025 · p. 11
|SecPretrial Order
Filing Requirements

Machine summary. Not checked yet.Mandatory?

Requests to file memoranda exceeding the page limits set forth herein must be made in writing three business days prior to the due date.

Summary: Any request to exceed memorandum page limits must be submitted in writing at least three business days before the due date.

Document Type

Request To Exceed Page Limits

Specific requirements detailed in rule text.
HG-MLR · Oct 2025 · p. 12
|SecFilings Prior to Trial in Civil and Criminal Cases
Filing Requirements

Machine summary. Not checked yet.Mandatory?

Motions in Limine. A list of motions in limine each party intends to file (pursuant to the deadline set forth in Section VI.C.1, below), with a brief description of each such motion.

Summary: The pretrial order must include each party’s intended motions in limine with brief descriptions.

Document Type

Pretrial Order

Specific requirements detailed in rule text.
HG-MLR · Oct 2025 · p. 12
|SecPretrial Order
Filing Requirements

Machine summary. Not checked yet.Mandatory?

Sentencing memoranda and any objections to the Presentence Report must be provided to the Probation Department.

Summary: Sentencing memoranda and objections to the Presentence Report must be provided to Probation.

Document Type

Sentencing Memorandum

Specific requirements detailed in rule text.
HG-MLR · Oct 2025 · p. 13
|SecVIII. SENTENCING
Filing Requirements

Machine summary. Not checked yet.Mandatory?

The Court will not accept a guilty plea on a violation of supervised release without 24 hours’ notice of the intent to plead, specifying the violations as to which the defendant intends to plead guilty.

Summary: A guilty plea on a supervised release violation requires at least 24 hours notice specifying the violations.

Document Type

Violation Of Supervised Release Guilty Plea Notice

Specific requirements detailed in rule text.
HG-MLR · Oct 2025 · p. 13
|SecVIII. SENTENCING
Filing Requirements

Machine summary. Not checked yet.Mandatory?

In all non-jury trials, parties must file proposed findings of fact and conclusions of law no later than 10 business days after the conclusion of trial, unless otherwise ordered by the Court. Responses to such submissions are not permitted.

Summary: In non-jury trials, parties must file proposed findings and conclusions within 10 business days after trial, and responses are not allowed.

Document Type

Proposed Findings Conclusions

Specific requirements detailed in rule text.
HG-MLR · Oct 2025 · p. 13
|SecVII. POST-TRIAL PROCEDURES
Filing Requirements

Machine summary. Not checked yet.Important?

Counsel must provide a brief description of the subject matter of the letter in the ECF entry field (e.g., “Joint Letter in connection with Initial Status Conference”) not simply, “Letter.”

Summary: ECF letters must include a brief subject-matter description in the entry field, not a generic label.

Document Type

Ecf Letter

Specific requirements detailed in rule text.
HG-MLR · Oct 2025 · p. 1
|SecI. COMMUNICATIONS WITH CHAMBERS - A. Written Communications with Chambers
Filing Requirements

Machine summary. Not checked yet.Important?

All memoranda 10 pages or longer shall contain a table of contents and table of authorities.

Summary: Memoranda that are 10 pages or longer must include a table of contents and table of authorities.

Document Type

Memorandum Of Law

Content & Formatting
Table Of Authorities
Table Of Contents
HG-MLR · Oct 2025 · p. 7
|SecB. Motion Papers
Filing Requirements

Machine summary. Not checked yet.Important?

Statement of Relief Sought. A detailed statement regarding damages and other relief sought for each claim or counterclaim. In non-jury cases, parties should also provide a statement of the elements of each claim or defense involving such party, together with a summary of the facts relied upon to establish each element.

Summary: Parties must detail damages and other relief for each claim/counterclaim, and in non-jury cases should also provide elements and supporting facts.

Document Type

Pretrial Order

Specific requirements detailed in rule text.
HG-MLR · Oct 2025 · p. 11
|SecPretrial Order
Filing Requirements

Machine summary. Not checked yet.Important?

Requests to charge should be limited to the elements of the claims, the damages sought, and defenses.

Summary: Requests to charge should be limited to claim elements, damages sought, and defenses.

Document Type

Jury Instructions

Specific requirements detailed in rule text.
HG-MLR · Oct 2025 · p. 12
|SecFilings Prior to Trial in Civil and Criminal Cases
Filing Requirements

Machine summary. Not checked yet.Note?

Parties may request oral argument by noting “Oral Argument Requested” in their Notice of Motion or opposing memorandum and, if applicable, shall advise the Court that an attorney who intends to participate in the oral argument meets the criteria described in Section II.B, above.

Summary: A party seeking oral argument should label its filing “Oral Argument Requested” and, when applicable, advise the Court that participating counsel meets Section II.B criteria.

Document Type

Notice Of Motion Or Opposing Memorandum

Specific requirements detailed in rule text.

Filing & Service rules

Courtesy Copy Requirements

Non-pro-se parties must deliver one courtesy copy for ECF filings of 25+ pages, with required labeling, ECF stamp, and tabbed spiral binding.

Except for parties proceeding pro se, parties shall deliver to Chambers a courtesy copy of all written submissions filed on ECF that are 25 pages in length or more, inclusive of any exhibits or attachments. All courtesy copies must be clearly marked “Courtesy Copy,” and any documents that have been filed under seal must also be marked as “SEALED.” All courtesy copies must include the stamp generated when a document is filed via ECF (including the document number as listed on the docket). Courtesy copies should be spiral bound on the left side and use tabs to identify documents and exhibits in the submission.

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Page 4 | III.C. Courtesy Copies

For a change-of-plea hearing, the AUSA must email Chambers courtesy copies of the plea agreement and elements sheet at least three business days in advance.

The AUSA shall provide a courtesy copy of the plea agreement and elements sheet by email to Chambers at least three business days before a change-of-plea hearing.

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Page 10 | PRETRIAL PROCEDURES - Criminal Cases - Guilty Pleas

In criminal cases, the AUSA must send Chambers courtesy copies of the indictment or information and, if applicable, the complaint as soon as practicable.

The Assistant United States Attorney (“AUSA”) shall provide to Chambers, as soon as practicable, a courtesy copy of the indictment or information, and a courtesy copy of the complaint, if one exists.

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Page 10 | PRETRIAL PROCEDURES - Criminal Cases - Initial Matters

Parties must provide two tabbed exhibit binders to the Court on the Friday before trial unless otherwise ordered.

The parties shall provide the Court with two tabbed binders containing copies of all exhibits on the Friday before trial, unless otherwise ordered by the Court.

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Page 12 | Filings Prior to Trial in Civil and Criminal Cases

When a defendant will waive indictment and plead to an information, the information should also be provided with the plea agreement.

If the defendant intends to waive indictment and plead guilty to an information at the change-of-plea hearing, a copy of the information should also be provided to the Court along with the plea agreement.

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Page 10 | PRETRIAL PROCEDURES - Criminal Cases - Guilty Pleas

Sealing & Redaction Procedures

A motion for leave is required to file under seal, and the proposed sealed document must be attached.

Motions for leave to file documents under seal should be filed via ECF in accordance with the EDNY’s instructions for filing sealed documents. The proposed sealed document(s) should be attached to the motion for leave to file under seal.

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Page 4 | III.A.8 Sealing of Submissions

Filing Bundling Requirements

Motion papers must be filed promptly and not held for bundling.

Motion papers shall be filed promptly. Do not hold motion papers until all papers are complete. In other words, the Court does not follow a “bundling rule.”

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Page 7 | B. Motion Papers

Each party must bundle all motions in limine into one submission.

All motions in limine by a party must be filed in a single submission.

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Page 12 | Filings Prior to Trial in Civil and Criminal Cases

Similarly situated parties are encouraged to consolidate pre-motion letters to avoid duplication.

Similarly situated parties (i.e., multiple defendants moving to dismiss on overlapping grounds) should make reasonable efforts to consolidate their pre-motion letters to avoid duplication.

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Page 6 | CIVIL MOTIONS

Similarly situated parties should consolidate overlapping motion submissions to avoid duplication.

Similarly situated parties (i.e., multiple defendants moving to dismiss on overlapping grounds) should make reasonable efforts to consolidate their submissions to avoid duplication.

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Page 7 | B. Motion Papers

Pre-Motion Conference Requirements

Civil discovery disputes require a single jointly composed pre-motion letter capped at five pages, and separate/successive letters are not accepted.

For discovery motions, follow Local Civil Rule 37.3. However, in lieu of separate letters by the parties, counsel must describe their dispute(s) in a single letter, jointly composed. The letter may not exceed five pages. Separate and successive letters will not be reviewed.

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Page 4 | IV.A.1 Pre-Motion Letters

Response letters are due within five business days for non-summary-judgment pre-motion letters.

All parties served with a moving party’s pre-motion letter are required to serve and file a letter response within five business days of service of the moving party’s letter unless the motion is for summary judgment.

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Page 5 | CIVIL MOTIONS

For summary-judgment pre-motion letters, response letters are due within 21 days of service.

All parties served with a pre-motion letter seeking summary judgment are required to serve and file a letter response within 21 days of service of the moving party’s letter.

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Page 5 | CIVIL MOTIONS

A detailed pre-motion letter of up to three pages is required before filing non-discovery motions.

A pre-motion letter is required before a party may file any non-discovery motion, except for motions described in Section IV.A.2.a, below. The moving party shall submit a detailed letter not to exceed three pages in length setting forth the basis for the anticipated motion.

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Page 5 | CIVIL MOTIONS

For Rule 56 motions, the movant must include a Rule 56.1 statement with the pre-motion letter.

If the motion is for summary judgment under Rule 56, the movant’s pre- motion letter must also include a copy of the movant’s Rule 56.1 Statement (see Section IV.B.7, below, regarding requirements for the statement and opposing statement).

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Page 5 | CIVIL MOTIONS

The moving party is not permitted to file a reply letter in the pre-motion letter process.

The moving party may not file a reply letter.

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Page 6 | CIVIL MOTIONS

Cross-motions are prohibited, and motions omitted from timely pre-motion letters will not be considered.

There shall be no cross-motions. Any motions not raised in a pre-motion letter by the relevant deadline will not be considered.

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Page 6 | CIVIL MOTIONS

Pre-motion letters for summary judgment and Daubert-type expert-exclusion motions must be filed within 30 days after fact or expert discovery closes, whichever is later.

Pre-motion letters related to any proposed motions for summary judgment or motions to exclude the testimony of experts pursuant to Rules 702-705 of the Federal Rules of Evidence and the Daubert v. Merrill Dow Pharmaceuticals, Inc., 509 U.S. 579 (1993), line of cases shall be filed 30 days after the completion of fact or expert discovery, whichever occurs later.

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Page 6 | CIVIL MOTIONS

Motions in limine must be filed 30 days before trial, oppositions are due 10 business days after filing, all in limine motions must be consolidated, and replies are barred unless the Court orders otherwise.

Any motions addressing evidentiary or other issues which should be resolved in limine shall be filed 30 days before the commencement of trial, unless otherwise ordered by the Court. Any responses are due 10 business days after the motions are filed. All motions in limine by a party must be filed in a single submission. Replies to motions in limine are not permitted.

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Page 12 | Filings Prior to Trial in Civil and Criminal Cases

Daubert expert-exclusion motions must follow dispositive-motion deadlines and are not treated as motions in limine.

Motions to exclude the testimony of experts pursuant to Rules 702–705 of the Federal Rules of Evidence and the Daubert v. Merrell Dow Pharmaceuticals, Inc., 509 U.S. 579 (1993), line of cases, shall be made by the deadline for dispositive motions and shall not be treated as motions in limine.

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Page 12 | Filings Prior to Trial in Civil and Criminal Cases

Serving a pre-motion letter within Rule 12 or Rule 56 deadlines counts as timely motion service under those rules.

Service of the pre-motion letter within the time requirements of Fed. R. Civ. P. 12 or 56 shall constitute timely service of a motion made pursuant to those provisions.

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Page 5 | CIVIL MOTIONS

A party may bypass the pre-motion letter requirement to avoid loss of rights but must file an explanatory letter with the motion.

A party need not comply with the pre-motion letter requirement where it reasonably believes that delay in filing might result in the loss of a right. In that event, the party should file, along with the motion, a letter explaining why the party believes it might be prejudiced if it complied with the pre-motion letter requirement.

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Page 6 | CIVIL MOTIONS

In appropriate cases, the Court may treat the pre-motion letter as the motion itself.

In appropriate cases, the Court may exercise its discretion to construe the pre-motion letter as the motion itself.

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Page 7 | CIVIL MOTIONS

The pre-motion conference may be the only oral-argument opportunity, and counsel should expect a short post-conference motion filing schedule.

The pre-motion conference is often the only opportunity for oral argument on the motion. Counsel should also anticipate a schedule that will require the filing of their motion within a short time after the conference.

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Page 7 | CIVIL MOTIONS

Adjournment & Extension Requirements

Adjournment or extension requests must be filed at least three business days before the relevant deadline or appearance unless there is an emergency.

Absent an emergency, and unless otherwise provided for by these Individual Practices, all requests for adjournments or extensions of time must be made at least three (3) business days prior to a scheduled deadline or appearance.

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Page 2 | C. Requests for Adjournments or Extensions of Time

Adjournment or extension requests must be filed by ECF letter (except pro se) and include specified prior-date, history, consent, schedule, and grounds information.

All requests for adjournments or extensions of time must be filed by ECF Letter only (except for pro se litigants), and must state: (a) the original date; (b) the number of previous requests for adjournment or extension; (c) whether these previous requests were granted or denied; (d) whether the adversary consents, and, if not, the reasons by the applicant, and by the adversary, for and against the relief requested; (e) all other dates previously scheduled, including dates for conferences with the Court, and a suggested modified schedule, agreed to by all other counsel; and (f) the grounds for the extension or adjournment.

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Page 2 | C. Requests for Adjournments or Extensions of Time

Sentencing adjournment applications must be filed in writing at least 10 business days before sentencing.

Applications regarding sentencing adjournments shall be made in writing at least 10 business days prior to the date of sentencing. The response, if any, shall be made in writing at least six business days before the date of sentencing.

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Page 13 | VIII. SENTENCING

Requests to exceed memorandum page limits must be in writing 5 business days before the due date, except reply-brief requests which require at least 3 business days.

Requests to file memoranda exceeding the page limits set forth herein must be made in writing five business days prior to the due date, except with respect to reply briefs, in which case the written request must be made at least three business days prior to the due date.

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Page 7 | B. Motion Papers

Chambers Communication Rules

Written communications with Chambers must be filed as ECF letters, with simultaneous copy service on pro se litigants.

Except as provided below, communications with Chambers shall be by letter electronically filed with the Court, with copies simultaneously delivered or mailed to any pro se litigant.

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Page 1 | I. COMMUNICATIONS WITH CHAMBERS - A. Written Communications with Chambers

Urgent matters should be raised by phone to Chambers, with an initial email request for contact information.

For situations requiring immediate attention from the Court, counsel should call Chambers directly; in such situations, parties should first email Chambers requesting the Court’s contact information.

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Page 2 | I. COMMUNICATIONS WITH CHAMBERS - B. Telephone Calls and Urgent Communications

If exhibit volume makes binder submission impracticable, parties must email Chambers at least 10 business days before trial for courtesy-copy instructions.

If in the judgment of the parties the volume of exhibits makes this requirement impracticable, please email Chambers at least 10 business days before trial for instructions on how to submit courtesy copies of the exhibits.

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Page 12 | Filings Prior to Trial in Civil and Criminal Cases

Counsel may email Chambers for unresolved rules questions and scheduling/calendar matters.

For questions that cannot be answered by reference to these Rules or the E.D.N.Y. Local Rules, or for scheduling and calendar matters, counsel may email Chambers.

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Page 1 | I. COMMUNICATIONS WITH CHAMBERS - B. Telephone Calls and Urgent Communications

In cases with pro se parties, filing and service questions should be directed by phone to the Pro Se Office.

For questions about filing and serving documents in cases in which one or more parties are proceeding pro se, contact the Pro Se Office at (718) 613-2665.

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Page 3 | III.A.4 Mandatory ECF Filing

For very large courtesy-copy submissions, parties must email Chambers for format instructions, including possible CD submission with separately named PDFs.

If a courtesy copy is voluminous (i.e., more than two 2-inch binders), please email Chambers for instructions on whether to submit the courtesy copy in a digital format via compact disc containing separate and appropriately named PDF files for each item in the submission, including exhibits.

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Page 4 | III.C. Courtesy Copies

About United States District Judge Hector Gonzalez

**District Judge Hector Gonzalez** was appointed to the Eastern District of New York by President Joseph R. Biden in 2022. Born in 1964 in Havana, Cuba, Judge Gonzalez immigrated to the United States in 1969 and was raised in Queens, New York. Before his judicial appointment, he was a partner at Dechert LLP, leading the firm's global litigation group, with his practice emphasizing complex commercial, securities, and white-collar litigation. He is a Fellow of the American College of Trial Lawyers. Earlier in his career he served as an Assistant U.S. Attorney in the Southern District of New York, where he headed the Narcotics Unit, and as an Assistant District Attorney in Manhattan. He served six years on the New York City Civilian Complaint Review Board, including four years as chair, and taught trial advocacy as a Fulbright Scholar at Guatemala's University of San Carlos. **Education** - University of Pennsylvania Law School, J.D., 1988 (Law Review editor) - Manhattan College, B.S., 1985 - City University of New York, M.A., 1995 **Career** - U.S. District Judge, Eastern District of New York, 2022–present - Partner (Global Litigation Group), Dechert LLP - Chair, NYC Civilian Complaint Review Board - Assistant U.S. Attorney (Narcotics Unit Chief), SDNY - Assistant District Attorney, Manhattan

**Courthouse:** 225 Cadman Plaza East, Brooklyn, NY 11201 / 100 Federal Plaza, Central Islip, NY 11722 **Phone:** (see Individual Practices and Rules for contact details) **Chambers Staff** - Contact details available in Judge's Individual Practices and Rules

Common questions about Judge Hector Gonzalez's rules

Are courtesy copies required for Judge Hector Gonzalez?

Courtesy-copy rule applies when a filing is >= 25 pages. Details: 1 copy, delivery upon filing, by chambers drop off. Non-pro-se parties must deliver one courtesy copy for ECF filings of 25+ pages, with required labeling, ECF stamp, and tabbed spiral binding.

View ruleSource: page 4, section III.C. Courtesy Copies

Does Judge Hector Gonzalez require a pre-motion conference or letter before filing a motion?

Yes. A pre-motion letter is required for discovery. Details: 5 pages. Civil discovery disputes require a single jointly composed pre-motion letter capped at five pages, and separate/successive letters are not accepted.

View ruleSource: page 4, section IV.A.1 Pre-Motion Letters

What page or word limits apply to pre motion response letter before Judge Hector Gonzalez?

Judge Hector Gonzalez's rule states these limits: 3 pages. Pre-motion response letters are limited to three pages.

View ruleSource: page 5, section CIVIL MOTIONS

What page or word limits apply to memorandum of law before Judge Hector Gonzalez?

Judge Hector Gonzalez's rule states these limits: 25 pages; 10 pages. Support/opposition memoranda are limited to 25 pages and reply memoranda are limited to 10 pages unless prior permission is granted.

View ruleSource: page 7, section B. Motion Papers

What formatting rules apply to filings before Judge Hector Gonzalez?

Judge Hector Gonzalez's formatting rule includes file format PDF, filed on ecf and emailed to chambers., and applies to other submissions for adoption by the court.. Proposed orders, jury instructions, and similar submissions must be provided in PDF format via ECF and email to Chambers.

View ruleSource: page 4, section III.B. Word Processing Files of Certain Submissions

What must be included with adjournment or extension request filings before Judge Hector Gonzalez?

The rule identifies required filing content or certificates. Adjournment or extension requests must be docketed as motions and clearly labeled as adjournment/extension requests in the ECF entry.

View ruleSource: page 2, section C. Requests for Adjournments or Extensions of Time

What must be included with notice of appearance filings before Judge Hector Gonzalez?

The rule identifies required filing content or certificates. Any attorney who appears must file a notice of appearance on ECF.

View ruleSource: page 3, section A. Attendance by Principal Trial Counsel

How may parties contact Judge Hector Gonzalez's chambers?

The rule addresses letter ecf communications with Judge Hector Gonzalez's chambers. Written communications with Chambers must be filed as ECF letters, with simultaneous copy service on pro se litigants.

View ruleSource: page 1, section I. COMMUNICATIONS WITH CHAMBERS - A. Written Communications with Chambers

How does Judge Hector Gonzalez handle sealed or redacted filings?

A motion to seal is required for covered sealed filings before Judge Hector Gonzalez. A motion for leave is required to file under seal, and the proposed sealed document must be attached.

View ruleSource: page 4, section III.A.8 Sealing of Submissions

How do I request an adjournment or extension before Judge Hector Gonzalez?

Requests should be made at least 3 business days in advance when this rule applies before Judge Hector Gonzalez. Adjournment or extension requests must be filed at least three business days before the relevant deadline or appearance unless there is an emergency.

View ruleSource: page 2, section C. Requests for Adjournments or Extensions of Time

Does Judge Hector Gonzalez require motion papers to be bundled?

No. The rule prohibits holding covered papers for bundling. Motion papers must be filed promptly and not held for bundling.

View ruleSource: page 7, section B. Motion Papers
Complete rules summary for Judge Hector Gonzalez

Written communications with Chambers must be filed as ECF letters, with simultaneous copy service on pro se litigants.

ECF letters must include a brief subject-matter description in the entry field, not a generic label.

Counsel may email Chambers for unresolved rules questions and scheduling/calendar matters.

Urgent matters should be raised by phone to Chambers, with an initial email request for contact information.

Adjournment or extension requests must be filed at least three business days before the relevant deadline or appearance unless there is an emergency.

Adjournment or extension requests must be docketed as motions and clearly labeled as adjournment/extension requests in the ECF entry.

Adjournment or extension requests must be filed by ECF letter (except pro se) and include specified prior-date, history, consent, schedule, and grounds information.

Speedy Trial Act exclusion requests in criminal cases must include conferral/consent information, supporting facts, and a proposed exclusion order.

Any attorney who appears must file a notice of appearance on ECF.

Written submissions and supporting materials must be text-searchable where practicable.

Any request for relief must be docketed as a Motion, and the ECF entry must state the specific subject matter.

A motion for leave is required to file under seal, and the proposed sealed document must be attached.

Proposed orders, jury instructions, and similar submissions must be provided in PDF format via ECF and email to Chambers.

Non-pro-se parties must deliver one courtesy copy for ECF filings of 25+ pages, with required labeling, ECF stamp, and tabbed spiral binding.

For very large courtesy-copy submissions, parties must email Chambers for format instructions, including possible CD submission with separately named PDFs.

Civil discovery disputes require a single jointly composed pre-motion letter capped at five pages, and separate/successive letters are not accepted.

In cases with pro se parties, filing and service questions should be directed by phone to the Pro Se Office.

Serving a pre-motion letter within Rule 12 or Rule 56 deadlines counts as timely motion service under those rules.

For Rule 56 motions, the movant must include a Rule 56.1 statement with the pre-motion letter.

Response letters are due within five business days for non-summary-judgment pre-motion letters.

Pre-motion response letters are limited to three pages.

For summary-judgment pre-motion letters, response letters are due within 21 days of service.

Requests to charge should be limited to claim elements, damages sought, and defenses.

A Rule 56 pre-motion response letter must include a line-by-line Rule 56.1 opposing statement.

Rule 56.1 statements in pre-motion practice must attach relevant exhibits and cite them by exhibit identifier and page or Bates number.

Pre-motion letters for summary judgment and Daubert-type expert-exclusion motions must be filed within 30 days after fact or expert discovery closes, whichever is later.

Similarly situated parties are encouraged to consolidate pre-motion letters to avoid duplication.

The moving party is not permitted to file a reply letter in the pre-motion letter process.

Cross-motions are prohibited, and motions omitted from timely pre-motion letters will not be considered.

A party may bypass the pre-motion letter requirement to avoid loss of rights but must file an explanatory letter with the motion.

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