Judge Nina R. Morrison
Individual Rules, Standing Orders & Policies
- Rules last changed:
Limits & Logistics
Document Limits
Courtesy Copies
All filings
- 1 copy • At Time Of Testimony
Courtesy copies
- Not required
Exhibits
- 1 copy • 10 Days Before Trial
Binding: Tabbed Three Ring
Jury Instructions, Proposed Findings Conclusions
- 1 copy • 14 Days Before Jury Selection
Adjournments
- Written adjournment/extension requests must include reason, original date, previous request history, adversary position, and proposed new dates.
- If adjournment/extension affects other dates, propose revisions after conferring with opposing counsel.
- Briefing schedule modifications require Court approval via ECF extension request under Individual Rule 1.7.
Request must include
- Adjournment/extension requests must be made at least 2 working days before the deadline unless emergency.
- Adjournment requests within 24 hours of appearance require ECF filing and phone call to chambers.
- Sentencing adjournment requests must be in writing, submitted 7 business days in advance, and include the reason and opposing party's consent position.
Communication
Chambers
Chambers
Phone
Chambers
Letter via fax
Chambers
Page & Word Limits3 rules
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In any action in which subject matter jurisdiction is founded on diversity of citizenship pursuant to 28 U.S.C. § 1332, the party asserting the existence of such jurisdiction shall, within fourteen (14) days of the filing of the action or its removal from state court to federal court, file on ECF a letter no longer than two (2) pages explaining the basis for that party's belief that diversity of citizenship exists
Summary: Diversity jurisdiction letters are limited to 2 pages maximum.
Letter
2 pages
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. The opposing statement may not exceed twice the length of the moving party's statement.
Summary: Local Rule 56.1 statements limited to 25 pages for movant; opposition limited to twice movant's length.
Local Rule 56 1 Statement
25 pages
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Unless prior permission has been granted, memoranda of law in support of and in opposition to motions are limited to 30 double-spaced pages, not including tables of contents, tables of authorities, exhibits, appendices, or attachments. Reply memoranda are limited to 15 double-spaced pages, not including tables of contents, tables of authorities, exhibits, appendices, or attachments.
Summary: Motion briefs limited to 30 pages (opening/opposition) and 15 pages (reply), with specified exclusions.
30 pages
Document Format Requirements3 rules
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All memoranda of law shall be produced in 12-point font, with footnotes in 11-point font, and shall have one-inch margins on all sides. All memoranda must be filed in a text-searchable format and must have the date of service printed on the front cover.
Summary: Memoranda must use 12-point font (11-point footnotes), 1-inch margins, text-searchable format, and front cover service date.
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All written submissions and supporting materials, except those filed by pro se litigants, must be text-searchable to the extent practicable.
Summary: All submissions must be text-searchable except pro se filings.
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The plaintiff's exhibits must be pre-marked with numbers. The defendant's exhibits must be pre-marked with letters.
Summary: Plaintiff exhibits must be pre-marked with numbers; defendant exhibits with letters.
Document Filing Requirements27 rules
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Proposed orders, jury instructions, and other writings a party requests that the Court adopt shall be filed on ECF and e-mailed, in PDF and word-processing format, to Morrison Chambers@nyed.uscourts.gov. Parties need not submit word-processing files of stipulations of dismissal, of settlement, or of motions for extensions of time unless requested by the Court.
Summary: Proposed orders and jury instructions must be filed on ECF and emailed in both PDF and word-processing format.
Document Type
Proposed Order
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In any action in which subject matter jurisdiction is founded on diversity of citizenship pursuant to 28 U.S.C. § 1332, the party asserting the existence of such jurisdiction shall, within fourteen (14) days of the filing of the action or its removal from state court to federal court, file on ECF a letter no longer than two (2) pages explaining the basis for that party's belief that diversity of citizenship exists, addressing the citizenship of each party to the litigation. Where any party is a corporation, the letter shall state both the place of incorporation and the principal place of business. In cases where any party is a partnership, limited partnership, limited liability company or
Summary: In diversity jurisdiction cases, a letter (max 2 pages) explaining jurisdictional basis must be filed within 14 days.
Document Type
Letter
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Any attorney appearing before the Court must enter a notice of appearance on ECF.
Summary: Attorneys must file a notice of appearance on ECF.
Document Type
Notice Of Appearance
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Parties shall include a declaration identifying each of the exhibits and the page ranges of the exhibits within the compiled PDF.
Summary: Evidentiary filings must include a declaration identifying each exhibit and page ranges.
Document Type
Exhibits
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Each paragraph in the Local Rule 56.1 statement shall contain an assertion of a material undisputed fact, not a description of evidence.
Summary: Local Rule 56.1 statements must contain assertions of material undisputed facts, not descriptions of evidence.
Document Type
Local Rule 56.1 Statement
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Any evidence to which a motion in limine refers to—whether in a motion to preclude the evidence, a motion to admit the evidence, or as relevant context for a motion to admit or preclude other evidence—must be attached to the motion as a clearly labelled exhibit.
Summary: Evidence referenced in motions in limine must be attached as a clearly labelled exhibit.
Document Type
Motion In Limine
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Except for good cause shown, only exhibits listed will be received into evidence.
Summary: Only exhibits listed in Pretrial Order will be admitted unless good cause shown.
Document Type
Pretrial Order
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If a party seeks to introduce evidence through cross-examination or otherwise under either Federal Rule of Evidence 608(b) or 609, the party must file a motion in limine outlining why its intended exhibit(s) and/or area(s) of cross-examination are admissible under the relevant rule.
Summary: Party seeking to use FRE 608(b) or 609 evidence must file motion in limine explaining admissibility.
Document Type
Motion
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At the initial pretrial conference or otherwise, the Court will set a briefing schedule on any motions addressing evidentiary or other issues that should be resolved in limine. Motions in limine and any responsive briefing are typically due at least 30 days before the commencement of trial.
Summary: Motions in limine and responsive briefing are typically due at least 30 days before trial.
Document Type
Motion
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A list of motions in limine each party intends to file (pursuant to the deadline set forth in Rule 6.2.1 below), with a brief description of each such motion.
Summary: Pretrial Order must include list of intended motions in limine with brief description of each.
Document Type
Pretrial Order
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Each party shall securely upload a PDF file of each exhibit, as separate documents, via a secure link provided by the Court's deputy at least ten (10) days before trial.
Summary: Parties must upload PDF files of each exhibit separately via secure link at least 10 days before trial.
Document Type
Exhibits
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In non-jury trials, each party shall submit a statement of the elements of each claim and defenses involving each claim together with a summary of the facts they anticipate will be relied upon to establish each element. The statement shall be due before trial on a schedule to be set by the Court.
Summary: In non-jury trials, parties must submit statement of claim elements, defenses, and anticipated factual summary before trial.
Document Type
Pretrial Statement
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Requests to charge, proposed verdict sheets, and proposed voir dire questions in jury cases shall be filed on ECF and provided to chambers in PDF and Microsoft Word formats no later than 10 days before jury selection, unless otherwise ordered by the Court.
Summary: Trial preparation documents must be filed on ECF and provided to chambers in both PDF and Word formats at least 10 days before jury selection.
Document Type
Proposed Jury Instructions
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6.1.9. 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: JPTO must include designation of deposition testimony to be offered, with cross-designations and objections.
Document Type
Pretrial Order
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Local Rule 56.1 statements: Motions for summary judgment may be denied if the movant does not file a Local Rule 56.1 statement that conforms with the requirements described in these Individual Practice Rules, in addition to those set forth in Local Rule 56.1. Except in pro se cases, the Local Rule 56.1 counter-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: Summary judgment motions require LR 56.1 statements; counter-statements must quote movant's statement verbatim and respond to each allegation immediately beneath it.
Document Type
Motion
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6.1.11. Exhibits: A schedule listing exhibits to be offered into evidence and, if not admitted by stipulation, the party or parties that will be offering them. 6.1.11.1. Except for evidence that a party seeks to admit or reference in cross-examination pursuant to Federal Rule of Evidence 609, the schedule should not include exhibits that a party intends to use solely for impeachment and/or rebuttal purposes. 6.1.11.2. Copies of statements proposed to be read to the jury as "learned treatises" under Federal Rule of Evidence 803(18) shall be listed as exhibits.
Summary: JPTO must include exhibit schedule listing exhibits and offering party; impeachment/rebuttal exhibits excluded unless FRE 609 applies; learned treatises must be listed.
Document Type
Pretrial Order
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The JPTO shall include the following: 6.1.1. Caption: The full caption of the action. 6.1.2. Parties and Counsel: The names, addresses (including firm names), and telephone numbers of trial counsel. 6.1.3. 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. These statements shall include citations to all (i) statutes and legal doctrines relied on, and (ii) relevant facts concerning citizenship and jurisdictional amount. 6.1.4. 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. 6.1.5. Jury or Bench Trial & Trial Length: 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. 6.1.6. 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: Joint Pretrial Order must include caption, parties/counsel info, jurisdiction statements, claims/defenses summary, jury/bench trial statement, and magistrate judge consent.
Document Type
Pretrial Order
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6.1.8. 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: JPTO must list all fact and expert witnesses with addresses and expected testimony; only listed witnesses may testify.
Document Type
Pretrial Order
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Parties must provide evidentiary citations, including specific transcript pages, in any submission that cites record material.
Summary: Evidentiary citations with specific transcript pages required when citing record material.
Document Type
Motion
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Any filing styled as a "Letter" shall identify in its ECF header (i) the addressee and (ii) the subject matter. E.g.: "Letter to Judge Morrison re: Pre-Motion Conference Request" or "Letter to Magistrate Judge Doe re: Status Conference."
Summary: Letters must identify addressee and subject matter in ECF header.
Document Type
Letter
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All court filings shall indicate the docket number followed by the initials of the District Judge (NRM) and the initials of the assigned Magistrate Judge, i.e., "Smith v. Jones, No. 25-cv-1234 (NRM)(LB)."
Summary: All filings must include docket number followed by District Judge initials (NRM) and Magistrate Judge initials.
Document Type
Motion
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The parties are expected to resolve before trial all issues of authenticity, chain of custody, and related matters. Meritless objections on these grounds may result in sanctions.
Summary: Parties must resolve authenticity and chain of custody issues before trial; meritless objections may be sanctioned.
Document Type
Pretrial Order
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Requests to charge should be limited to the elements of the claims, the damages sought, and defenses. General instructions will be prepared by the Court.
Summary: Requests to charge must be limited to elements of claims, damages sought, and defenses only.
Document Type
Jury Instructions
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Provide pro se litigants with a copy of this Court's individual rules and file a certificate of service as early as practicable in the litigation.
Summary: Counsel must provide pro se litigants with the Court's individual rules and file a certificate of service.
Document Type
Certificate
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Sur-replies require prior authorization by the Court.
Summary: Sur-replies require prior authorization from the Court.
Document Type
Sur Reply
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6.1.10. Stipulations: A statement of stipulated facts, if any.
Summary: JPTO must include any stipulated facts.
Document Type
Pretrial Order
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A party may request oral argument on a motion by writing "Oral Argument Requested" on the first page of its brief.
Summary: Oral argument requests must be indicated by writing "Oral Argument Requested" on the first page of the brief.
Document Type
Brief
Filing & Service rules
Courtesy Copy Requirements
Courtesy copies are prohibited unless specifically directed otherwise; electronic ECF filings suffice.
Please do not submit courtesy copies (hard copies) of filings to the Court unless otherwise directed. Electronic submissions filed on ECF will suffice.
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Page 3 | Electronic submissions
Requests to charge, verdict sheets, and voir dire questions must be filed on ECF and provided to chambers in PDF and Word formats 14 days before jury selection.
Requests to charge, proposed verdict sheets, and proposed voir dire questions in jury cases shall be filed on ECF and provided to chambers in PDF and Microsoft Word formats no later than 14 days before jury selection, unless otherwise ordered by the Court.
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Page 21 | 6.2.2
Parties must provide one tabbed exhibit binder with case caption on spine and front cover at least 10 days before trial.
The parties shall provide the Court with one copy of a tabbed binder containing all exhibits, with the case caption on the spine and front cover of each binder, at least ten (10) days before trial, unless otherwise ordered by the Court.
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Page 21 | 6.2.4
When witness will refer to documents during testimony, counsel must have copies for Court, court reporter, and opposing counsel.
When counsel anticipates that a witness will refer to documentary evidence during the witness's direct testimony, counsel shall have (i) one copy of each document for the Court, and (ii) at least one copy each for the court reporter and counsel for each opposing party who is present.
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Page 22 | 6.2.4.3
Filing Bundling Requirements
Parties are encouraged to refrain from filing motion papers until the motion has been fully briefed by all parties.
As a courtesy to the Court, the Court requests that the parties refrain from filing motion papers until the motion has been fully briefed by all parties.
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Page 11 | 5.2.3
Pre-Motion Conference Requirements
Pre-motion conferences required for Rule 12, Rule 56, venue change, and Rule 15 motions, except in bankruptcy/social security/habeas appeals or pro se cases.
Pre-motion conferences are not required in bankruptcy appeals, social security appeals, habeas cases, or cases in which one or more parties are proceeding pro se. In all other cases, a party must request a pre-motion conference before filing: 5.1.1.1. Any motion pursuant to Federal Rule of Civil Procedure 12 or 56; 5.1.1.2. Any motion for a change of venue; or 5.1.1.3. A motion to amend a pleading pursuant to Federal Rule of Civil Procedure 15 when leave of court is required.
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Page 8 | Pre-motion conferences
Pre-motion conference letters limited to 4 pages (6 pages for Rule 56 motions).
To request a pre-motion conference, the moving party is to file and serve a pre-motion conference letter set-ting out the bases for the anticipated motion. The pre-motion conference letter shall not exceed four pages, except for pre-motion conference letters re-lated to Rule 56 motions for summary judgment, which may not exceed six pages.
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Page 8 | Pre-motion conferences
Non-Rule 56 pre-motion conference letters require a response within 5 business days, limited to 4 pages.
All parties served with the moving party's pre-motion conference letter are required to serve and file a letter response within five (5) business days of service of the moving party's letter, except for motions under Federal Rule of Civil Procedure 56. The response to all pre-motion conference letters other than those filed under Rule 56 shall not exceed four pages.
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Page 9 | 5.1.3
Rule 56 pre-motion conference letters require a response within 14 business days, limited to 6 pages.
Rule 56 motions. All parties served with the moving party's pre-motion conference letter are required to serve and file a letter response within fourteen (14) business days of service of the moving party's letter. Responses to pre-motion conference letters under Rule 56 shall not exceed six pages.
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Page 9 | 5.1.3.1
For motions exempt from bundling and pre-motion conference, moving party must confer and submit proposed briefing schedule before filing.
For motions not subject to the Court's bundling practice (see Individual Rule 5.2.3) or its pre-motion conference requirement (see Individual Rule 5.1.1), the moving party shall confer with the opposing party or parties and submit a proposed briefing schedule for the Court to approve prior to filing the motion.
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Page 10 | 5.2.2
When pre-motion conference is waived, parties must submit joint letter with proposed briefing schedule within 3 days.
If the Court notifies the parties that it has waived the pre-motion conference requirement, the parties shall confer on a proposed briefing schedule and provide it to the Court by joint letter within three days of such notification.
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Page 10 | 5.2.2
Moving party must submit proposed briefing schedule with explanatory letter when parties cannot agree.
If the parties cannot agree on a briefing schedule, then the moving party shall submit a proposed schedule to the Court with an accompanying letter explaining the parties' points of disagreement.
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Page 11 | 5.2.2.2
If parties do not propose a briefing schedule, they must follow Local Civil Rule 6.1(b) timing absent good cause.
If the parties do not propose a briefing schedule, absent a showing of good cause, the parties shall brief the motion under the timetables listed in Local Civil Rule 6.1(b).
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Page 11 | 5.2.2.1
Parties must confer before initial pretrial conference about anticipated motions in limine.
Prior to the initial pretrial conference, the parties are expected to confer with one another about the issues raised in each of the opposing party's anticipated motions in limine to determine if it is necessary to brief any contested motion(s) to the Court.
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Page 20 | 6.1.12
Parties may bypass pre-motion conference if delay would deprive substantive right, by filing within FRCP time with explanation.
If a party wishing to file a motion concludes in good faith that delaying the filing of the motion in order to comply with the pre-motion conference requirements or any other 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 party's conclusion.
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Page 10 | 5.1.5
Requests for adjournments or extensions in arbitration/mediation are referred to Magistrate Judge.
Requests for adjournments or extensions of time in arbitration or mediation proceedings.
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Page 6 | 3.1. Matters referred
Rule 56.1 Statement not required with pre-motion conference letter (effective November 13, 2025).
Effective November 13, 2025, the moving party is not required to file a statement of material facts (Rule 56.1 Statement") at the time it files its pre-motion conference letter.
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Page 8 | Pre-motion conferences
Responding party need not file Rule 56.1 Statement when responding to pre-motion conference request.
Effective November 13, the responding party is not required to file a Rule 56.1 Statement (or Counter-Statement) in response to a request for a pre-motion conference on a Rule 56 motion for summary judgment.
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Page 9 | 5.1.3.1
Emergency exception allows filing without pre-motion compliance if delay would deprive substantive right or cause statutory deadline miss.
If any party concludes in good faith that delaying the filing of a motion to comply with any aspect of these individual practices will deprive the party of a substantive right or cause that party to miss a statutory deadline, 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 of the conclusion.
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Adjournment & Extension Requirements
Written adjournment/extension requests must include reason, original date, previous request history, adversary position, and proposed new dates.
All requests for adjournments or extensions of time relating to matters not referred to a Magistrate Judge (see Rule 3) must be in writing and state: (i) the reason for the request; (ii) the original date; (iii) the number of previous requests for adjournments or extensions; (iv) whether any previous requests were granted or denied; (v) whether the adversary consents, and, if not, the reasons given by the adversary for refusing to consent; and (vi) proposed date(s) for adjournment or extension of time.
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Page 3 | Requests for adjournments or extensions of time
Adjournment requests within 24 hours of appearance require ECF filing and phone call to chambers.
Any party seeking an adjournment of a court appearance within 24 hours of the appearance shall file its adjournment request on ECF and then call chambers to advise the Court of the request.
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Page 4 | Requests for adjournments or extensions of time
Adjournment/extension requests must be made at least 2 working days before the deadline unless emergency.
Absent an emergency, requests for adjournments of court appearances and extensions of filing deadlines shall be made at least two working days prior to the scheduled appearance or filing deadline.
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Page 4 | Requests for adjournments or extensions of time
Briefing schedule modifications require Court approval via ECF extension request under Individual Rule 1.7.
After a briefing schedule has been set, the parties may not modify it without the Court's approval. Any parties seeking to modify a briefing schedule shall file a request for an extension on ECF under the requirements of Individual Rule 1.7.
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Page 11 | 5.2.2.3
Sentencing adjournment requests must be in writing, submitted 7 business days in advance, and include the reason and opposing party's consent position.
Absent exceptional circumstances, applications regarding sentencing adjournments shall be made in writing at least seven business days prior to the date of sentencing and must state the reason for the request and whether the opposing party consents. If the opposing party does not consent, the application for adjournment must provide the reasons given by the opposing party for declining to consent.
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Page 24 | 8.3.3. Sentencing
If adjournment/extension affects other dates, propose revisions after conferring with opposing counsel.
If the requested adjournment or extension affects any other scheduled dates, the party seeking the adjournment should propose revisions of the additional affected dates after conferring with opposing counsel.
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Page 4 | Requests for adjournments or extensions of time
Chambers Communication Rules
All chambers communications must be in writing and filed on ECF.
All communications with chambers shall be in writing and filed on ECF, with copies simultaneously delivered to all parties who do not receive automatic notification through ECF. Copies of correspondence between counsel shall not be sent to the Court.
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Page 5 | 2.1. Written communications
For urgent matters, file on ECF first then contact Courtroom Deputy.
If a submission requires immediate attention, please file on ECF and then call or email Judge Morrison's Courtroom Deputy.
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Page 5 | 2.3. Urgent communications
Ex parte communications about case substance are prohibited.
Ex parte telephone calls or emails to chambers about the substance of cases are not permitted.
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Page 5 | 2.2. Telephone calls
Pro se litigants must communicate with the Court only in writing.
A pro se litigant shall: Only communicate with the Court in writing.
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Parties must e-mail a copy of the Joint Pretrial Order in word processing format to chambers.
The parties shall file the JPTO via CM/ECF and e-mail a copy of the JPTO in a word processing format to Morrison Chambers@nyed.uscourts.gov.
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Fax communication with the Court is prohibited without prior authorization.
Parties may not communicate with the Court via fax without prior authorization.
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Page 5 | 2.1. Written communications
Phone and email contact permitted for docketing, scheduling, or calendar matters.
For docketing, scheduling, or calendar matters, please call Courtroom Deputy Freddie Valderrama at (718) 613-2194 or email Freddie_Valderrama@nyed.uscourts.gov.
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Page 5 | 2.2. Telephone calls
Calls to chambers permitted for questions about these rules.
Calls to chambers with questions about these rules are permitted, but please review this document first.
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Page 5 | 2.2. Telephone calls
Junior Lawyer Participation Incentives
Junior lawyers (6 or fewer years experience) may have multiple attorneys argue and divide argument time.
The Court encourages the participation in court proceedings by less experienced attorneys, particularly where that attorney played a substantial role in drafting the underlying filing or in preparing the relevant witness. 4.2.1. For the purposes of this rule, the Court considers a "less experienced attorney" to be a lawyer with six or less years of experience, exclusive of any time after bar admission that the attorney has been employed as a judicial clerk, has been on family or medical leave, or was otherwise not actively engaged in the practice of law. 4.2.2. To facilitate participation of less experienced attor- neys, the Court may permit multiple attorneys to ar- gue different issues for each party. The Court will also entertain such applications where parties are represented by more than one experienced attorney but seek to divide argument time.
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Page 7 | Participation of lawyers
Junior lawyers gain increased oral argument opportunities and may have multiple attorneys argue.
The Court may be inclined to grant a request for oral argument and/or to permit more than one lawyer representing a party to argue when doing so would afford the opportunity for a less experienced attorney described in Rule 4.2 to gain courtroom experience.
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Page 16 | 5.7