Judge Lara K. Eshkenazi
Individual Rules, Standing Orders & Policies
Limits & Logistics
Document Limits
Courtesy Copies
All filings
- Upon request
Adjournments
- Adjournment/extension requests must be filed in writing at least two business days in advance and include specified required details, with conference adjournments also requiring at least three alternative dates.
Communication
Chambers
Chambers
Phone
Intake Unit
Phone
Chambers
Page & Word Limits4 rules
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Such letter motions may not exceed five (5) pages in length, exclusive of exhibits. A response not exceeding five (5) pages in length, exclusive of exhibits, must be served and filed within three (3) days of receipt of the letter
Summary: Discovery motion letters and responses are each limited to five pages, excluding exhibits, with responses due within three days of receipt.
Discovery Motion
5 pages
Opposition
5 pages
Machine summary. Not checked yet.Mandatory?
The letter motion must not exceed three (3) pages and must explain the need for the changes, whether all parties consent to the proposed changes, and the bases for any objections to the proposed changes.
Summary: Protective-order change letter motions are capped at three pages.
Letter Motion
3 pages
Machine summary. Not checked yet.Mandatory?
At least five (5) days prior to the settlement conference, the parties must submit ex parte settlement letters, not to exceed five (5) pages single-spaced, to Chambers via email (Eshkenazi Chambers@nyed.uscourts.gov).
Summary: Ex parte settlement letters are due at least five days before the conference and are limited to five single-spaced pages.
Ex Parte Settlement Letter
5 pages
Machine summary. Not checked yet.Mandatory?
The memoranda of law in support of and in opposition to dispositive motions are limited to twenty-five (25) pages, and reply memoranda are limited to ten (10) pages.
Summary: Dispositive-motion support/opposition memoranda are capped at 25 pages and reply memoranda at 10 pages.
Support Or Opposition Dispositive Motion Memorandum
25 pages
Reply Dispositive Motion Memorandum
10 pages
Document Format Requirements2 rules
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All discovery letter motions and responses must use reasonable margins and a 12-point font.
Summary: Discovery letter motions and responses must use reasonable margins and 12-point font.
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All memoranda of law must be double spaced, use reasonable margins, and a 12-point font.
Summary: All memoranda of law must be double-spaced, in 12-point font, with reasonable margins.
Document Filing Requirements14 rules
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Each attorney of record must file a Notice of Appearance and will receive notification of all Court orders electronically.
Summary: Attorneys of record are required to file a Notice of Appearance.
Document Type
Notice Of Appearance
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All attorneys must file a Notice of Appearance prior to appearing in Court.
Summary: Attorneys must file a Notice of Appearance before appearing in court.
Document Type
Notice Of Appearance
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Counsel in cases involving pro se litigants must send copies of documents filed via ECF to the pro se party, and file proof of service via ECF.
Summary: In cases with pro se litigants, counsel must serve ECF-filed documents on the pro se party and file proof of service on ECF.
Document Type
Ecf Filing
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Five (5) business days before the Initial Conference, the parties must jointly file the completed Proposed Discovery Plan/Scheduling Order using the form that can be found here:
Summary: Parties must jointly file the completed Proposed Discovery Plan/Scheduling Order five business days before the Initial Conference.
Document Type
Proposed Discovery Plan Scheduling Order
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Litigants must make discovery motions by letter motion.
Summary: Discovery motions must be filed as letter motions.
Document Type
Discovery Motion
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The letter motion must attach as exhibits a clean copy of the proposed order and a redlined comparison between the proposed order and the Court’s form Protective Order.
Summary: Protective-order change letter motions must attach clean and redlined proposed orders as exhibits.
Document Type
Letter Motion
Machine summary. Not checked yet.Mandatory?
The ex parte settlement letters must include the communicated demand and offer as prescribed in Rule IV.B.1 above, the strengths and weaknesses of their case, and any legal arguments in support of their settlement position with citations to relevant authorities.
Summary: Ex parte settlement letters must include prior demand/offer, case strengths and weaknesses, and supporting legal arguments with citations.
Document Type
Ex Parte Settlement Letter
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If any party concludes in good faith that delaying the filing of a motion, in order to comply with any aspect of these individual practices, will deprive the party of a substantive right, the party may file the motion within the time required by the Federal Rules of Civil and/or Appellate Procedure, together with an explanation of the basis for the conclusion.
Summary: A party may file within federal time limits to avoid loss of substantive rights but must include an explanation of that conclusion.
Document Type
Motion Implicating Fed R App P 4 A 4 A Or Similar Time Limiting Rules
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On the date specified in the scheduling order, the parties must submit a joint pretrial order that includes the following:
Summary: By the scheduling-order date, parties must file a joint pretrial order containing required listed components.
Document Type
Joint Pretrial Order
Machine summary. Not checked yet.Mandatory?
All motions addressing any evidentiary or other issues that should be resolved in limine must be filed at least thirty (30) days prior to the commencement date of trial.
Summary: Motions in limine must be filed at least 30 days before trial starts.
Document Type
Motions In Limine
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All exhibits must be pre-marked for the trial, placed in binders with tabs, and exchanged with the other parties with two courtesy copies sent to Judge Eshkenazi at least ten (10) days before trial.
Summary: Trial exhibits must be pre-marked, tabbed in binders, exchanged with other parties, and accompanied by two courtesy copies to chambers at least 10 days before trial.
Document Type
Trial Exhibits
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verdict sheet must be filed at least fourteen (14) days prior to the start of the trial.
Summary: A verdict sheet must be filed at least 14 days before trial begins.
Document Type
Verdict Sheet
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To request a settlement conference, the parties must file a joint letter motion and include at least three (3) dates on which counsel and parties with full settlement authority are available to attend.
Summary: A settlement-conference request must be a joint letter motion listing at least three available dates with full-authority participants.
Document Type
Joint Letter Motion
Machine summary. Not checked yet.Important?
The email should include a brief description of the dispute and a callback number.
Summary: Deposition-dispute emails to Chambers must include a brief dispute description and callback number.
Document Type
Deposition Dispute Email
Filing & Service rules
Courtesy Copy Requirements
Courtesy copies must not be sent unless Chambers specifically requests them.
No courtesy copies are to be sent to Chambers unless requested.
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Page 2 | I.A.3 Courtesy Copies
Courtesy copies are required only if the Court specifically requests them.
Courtesy copies are not required unless specifically requested by the Court.
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Page 7 | V. MOTIONS
Pre-Motion Conference Requirements
Parties must meet and confer in good faith before filing a discovery motion, and noncompliance can lead to denial.
Before making a discovery motion, parties must meet and confer, and make a good faith effort to resolve any disputes. Failure to comply with this requirement will result in denial of the motion.
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Page 4 | III. DISCOVERY — B. Discovery Disputes and Motions
For dispositive motions, parties must seek a pre-motion conference by letter, with five-page limits for request and response, a seven-day response deadline, and no reply letters without permission.
A letter motion requesting a pre-motion conference is required before any dispositive motion may be filed. The request must be accompanied by a summary of the proposed motion, not to exceed five (5) pages. The opposing party must file a letter response within seven (7) days, not to exceed five (5) pages. Reply letters are prohibited absent permission of the Court.
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Page 6 | V. MOTIONS - A. Dispositive Motions
Adjournment & Extension Requirements
Adjournment/extension requests must be filed in writing at least two business days in advance and include specified required details, with conference adjournments also requiring at least three alternative dates.
All requests for adjournments or extensions of time must be in writing and filed electronically as motions at least two (2) business days prior to the scheduled appearance or deadline. These requests must state the original date of the conference or deadline; the reason the adjournment or extension is needed; whether all parties consent (and reason(s) for withholding consent); and the number of prior adjournments or extensions. Requests for conference adjournments must also list at least three (3) alternative dates when all parties are available. The requesting party should also include a proposed revised schedule, if necessary.
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Page 2 | I.A.2 Requests for Adjournments and Extensions
Any request to revise the schedule requires Court approval.
No revisions to the schedule will be made without the Court’s approval.
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Page 7 | V. MOTIONS
Chambers Communication Rules
Letters and motions must be electronically filed (including letter applications for relief via the Motions event), but pro se litigants are exempt.
All letters and motions submitted to the Court must be electronically filed. If relief is sought from the Court, the application may be in the form of a letter, but must be filed using the “Motions” event. Litigants proceeding pro se are exempt from this requirement.
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Page 2 | I.A. Written Communications
Parties must immediately email Chambers at the listed address when specified triggering events occur.
A party or the parties must immediately notify Chambers via email (Eshkenazi_Chambers@nyed.uscourts.gov) if any of the following events occur:
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Page 2 | I.C. Required Notification to Chambers
Phone calls to Chambers are allowed only for emergencies needing same-day court attention.
Telephone calls to Chambers are permitted only in emergency situations requiring same-day attention by the Court.
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Page 2 | I.B. Telephone Calls
Parties must immediately email Chambers when an on-record deposition dispute cannot be resolved.
When a dispute arises during a deposition that the parties cannot resolve themselves despite their best efforts, the parties must contact the Court immediately by e-mailing Eshkenazi_Chambers@nyed.uscourts.gov.
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Page 5 | III. DISCOVERY - C. Deposition Disputes
Fax communications to Chambers are prohibited.
Faxes to Chambers are not permitted.
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Page 2 | I.B. Telephone Calls
Ex parte settlement letters must be emailed to Chambers at least five days before the settlement conference.
At least five (5) days prior to the settlement conference, the parties must submit ex parte settlement letters, not to exceed five (5) pages single-spaced, to Chambers via email (Eshkenazi Chambers@nyed.uscourts.gov).
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Page 6 | IV. SETTLEMENT - B. Ex Parte Submission
Pro se litigants are directed to contact the Pro Se Office by phone for case-related questions.
Pro se litigants should contact the Pro Se Office for any case-related questions at (718) 613-2664.
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Page 4 | II. PRO SE LITIGANTS — E. Pro Se Office