Judge Pamela K. Chen
Individual Rules, Standing Orders & Policies
- Rules last changed:
Limits & Logistics
Document Limits
Courtesy Copies
Filings > 50 pages
- Upon Filing
Filings >= 50 pages
- 1 copy • Chambers Drop Off • Upon Filing
Pro Se filings
- 1 copy • Chambers Drop Off
Adjournments
- Adjournment or enlargement requests must be written and include specified history/consent details, and must include proposed revised dates if other scheduled dates are affected.
Request must include
- Adjournment or extension requests must be made at least two working days in advance, and requests within 24 hours of an appearance require a phone call to chambers.
- Adjournment requests for in-court proceedings must be made at least 2 business days in advance.
Communication
Phone
Chambers
Page & Word Limits2 rules
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Unless prior permission has been granted, memoranda of law in support of and in opposition to motions are limited to 25 pages, not including exhibits, appendices or attachments, and reply memoranda are limited to ten pages, not including exhibits, appendices or attachments.
Summary: Support and opposition memoranda are capped at 25 pages, excluding exhibits, appendices, and attachments.
Memorandum Of Law Support Or Opposition
25 pages
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No document longer than ten pages may be faxed without prior permission.
Summary: Faxed documents are limited to 10 pages unless prior permission is obtained.
Faxed Document
10 pages
Document Format Requirements2 rules
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All written submissions and supporting materials to the Court, to the extent practicable, must be text-searchable.
Summary: Written submissions and supporting materials must be text-searchable to the extent practicable.
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The Pretrial Order will use a uniform font type and size throughout.
Summary: The Pretrial Order must use a uniform font type and size throughout.
Document Filing Requirements11 rules
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Video/audio exhibits that are too large to file on ECF may not be submitted via USB or CD. The filing party should contact chambers and will receive instructions for filing such exhibits. The party must also file a cover letter on ECF describing the video/audio evidence submitted to the Court.
Summary: Oversized video/audio exhibits cannot be submitted by USB/CD and require chambers instructions plus an ECF cover letter describing the evidence.
Document Type
Video Audio Exhibit
Machine summary. Not checked yet.Mandatory?
Documents faxed must be electronically filed.
Summary: Any document sent by fax must also be filed electronically.
Document Type
Faxed Document
Machine summary. Not checked yet.Mandatory?
On the day the motion is fully briefed, each party shall electronically file its own moving papers, except where the non-moving party is pro se, in which case the moving party shall file both parties' papers.
Summary: On full briefing, each party must e-file its own papers, except the moving party must file both sides' papers when the non-moving party is pro se.
Document Type
Motion Papers
Machine summary. Not checked yet.Mandatory?
Unless otherwise ordered by the court, within 60 days from the date for the completion of discovery in a civil case, the parties shall submit to the court a proposed pretrial order, which shall include the following:
Summary: Unless the Court orders otherwise, parties must submit a proposed pretrial order within 60 days after discovery completion, and it must contain specified required contents.
Document Type
Pretrial Order
Machine summary. Not checked yet.Mandatory?
In any case where a summary judgment motion is filed against a pro se litigant, the moving party is directed to comply with the notice required by Local Civil Rule 56.2.
Summary: A moving party filing summary judgment against a pro se litigant must provide the notice required by Local Civil Rule 56.2.
Document Type
Summary Judgment Motion
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Proposed orders, jury instructions, and other such writings a party wishes the Court to adopt should be submitted to chambers in word-processing format as well as filed on ECF in PDF format. However, parties need not submit word-processing files of stipulations of dismissal or settlement unless specifically requested to do so. Microsoft Word is the preferred word-processing format, although Corel WordPerfect format is acceptable.
Summary: Proposed orders, jury instructions, and similar proposed text should be sent in word-processing format and filed on ECF as PDF, with an exception for dismissal/settlement stipulations unless requested.
Document Type
Proposed Order And Jury Instructions
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If the parties follow this practice, the notice of motion (or opposition/reply) and all supporting papers are to be served on the other parties along with a cover letter setting forth whom the filer represents and the papers being served. Only a copy of the cover letter should be filed electronically, as a letter, not as a motion.
Summary: When using the hold-until-fully-briefed practice, papers must be served with a cover letter containing specified information, and only that cover letter is e-filed as a letter event.
Document Type
Cover Letter
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Parties may request oral argument, but must do so by separate letter or motion.
Summary: A request for oral argument must be made by a separate letter or motion.
Document Type
Oral Argument Request
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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: If compliance delay would in good faith risk a substantive right, the party may file within Federal Rules timing but must include an explanation of that conclusion.
Document Type
Motion
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Witnesses: A list of names and addresses by each party as to the fact and expert witnesses whose testimony is to be offered in its case in chief, together with 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 good cause shown.
Summary: The joint pretrial order must list fact and expert witnesses with narrative summaries, and unlisted witnesses may testify only with prompt notice and good cause.
Document Type
Pretrial Order
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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: The joint pretrial order must include an exhibit schedule identifying exhibits and the offering party when not stipulated.
Document Type
Pretrial Order
Filing & Service rules
Courtesy Copy Requirements
For ECF submissions of 50 pages or more including exhibits/attachments, one chambers courtesy hard copy is required, it must match the ECF filing with ECF header numbering, and emailing a PDF does not satisfy the requirement.
Parties shall deliver to chambers one (1) courtesy hard copy of all written submissions filed on ECF that are fifty (50) pages in length or more, including any exhibits or attachments. Parties are encouraged to use double-sided printing for their courtesy copies. The courtesy copy should be a reproduction of the document as filed on ECF, with the ECF numbering appearing at the top of the page. The emailing of such submissions in PDF to chambers or the courtroom deputy, does not satisfy this requirement.
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Page 2 | Courtesy Hard Copies
When a pro se non-moving party’s motion papers exceed 50 pages, the moving party must provide one courtesy paper copy to chambers.
Furthermore, in cases involving a pro se non-moving party, where that party’s motion papers exceed 50 pages, the moving party shall provide chambers with one courtesy paper copy of the pro se non-moving party’s motion papers.
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Page 5 | Filing of Motion Papers
For motion papers of 50 pages or more (including exhibits/attachments), one courtesy hard copy must be delivered to chambers, it must mirror the ECF filing with ECF numbering, and emailing a PDF does not satisfy the requirement.
As set forth in Section 1.D, parties shall deliver to chambers one (1) courtesy hard copy of their motion papers filed on ECF that are fifty (50) pages in length or more, including any exhibits or attachments. Parties are encouraged to use double-sided printing for their courtesy copies. The courtesy copy should be a reproduction of the document as filed on ECF, with the ECF numbering appearing at the top of the page. The emailing of such submissions in PDF to chambers or the courtroom deputy, does not satisfy this requirement.
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Page 5 | Filing of Motion Papers
Sentencing submissions over 50 pages (including attachments or exhibits) require simultaneous hard-copy delivery, and email PDF delivery does not satisfy this requirement.
Any sentencing submission in excess of fifty (50) pages, including attachments or exhibits, in addition to being filed electronically, shall be simultaneously provided to the Court in hard copy. The emailing of sentencing submissions in PDF to chambers or the courtroom deputy, does not satisfy this requirement.
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Page 8 | Criminal Cases — Courtesy Hard Copies
Sealing & Redaction Procedures
Sealing requests require a first-step motion for leave with a cover letter explaining the sealing or redaction basis and the target document.
All requests for filing under seal must be made in two parts: Part 1: The filing party shall first file a motion for leave to file under seal. The motion should include a cover letter explaining the reason(s) for sealing, restricting access to, or filing a redacted version of the document, along with the document that is requested to be sealed/restricted/redacted.
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Page 1 | Filing Under Seal
For redacted filings, the filer must provide both versions together or provide an unredacted version with visible highlighted proposed redactions.
When seeking to file a redacted document, the filing party must submit either: (a) the unredacted and redacted versions of the document together; or (b) the unredacted version with the proposed redactions highlighted such that the text to be redacted is still visible.
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Page 1 | Filing Under Seal
Filing Bundling Requirements
The hold-until-fully-briefed filing practice is inapplicable to reconsideration motions, Social Security and bankruptcy appeals, and preliminary-relief motions.
However, this practice does not apply to motions for reconsideration, Social Security and bankruptcy appeals, or motions for preliminary relief, e.g., motions for preliminary injunctions or temporary restraining orders.
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Page 4 | Filing of Motion Papers
Parties are encouraged to hold motion filings until full briefing, except when delay risks missing a statutory deadline.
As a courtesy to the Court, the parties are encouraged not to file their motion papers until the motion has been fully briefed, unless doing so might cause a party to miss a statutory deadline.
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Page 4 | Filing of Motion Papers
Pre-Motion Conference Requirements
Pre-motion conference requests require a 3-page letter motion stating the anticipated motion basis, and non-pro se recipients must file a 3-page response within 7 days.
To request a pre-motion conference, the moving party shall file and serve a letter motion not to exceed three (3) pages in length setting forth the basis for the anticipated motion. Letter motions should be filed using the motion event via ECF. Except for pro se litigants, all parties so served shall serve and file a letter response, not to exceed three (3) pages within seven (7) days from service of the notification letter. Letter responses should be filed using the letter, and not the motion, event.
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Page 3 | Pre-Motion Conference Requests
Counseled civil parties must request a pre-motion conference before specified Rule 12/56 and similar listed motions, with stated case-type exceptions.
In all cases in which the moving party is represented by counsel (except habeas corpus/prisoner petitions and Social Security and bankruptcy appeals), a pre-motion conference with the court must be requested before making any motion: (i) pursuant to Fed. R. Civ. P. 12 or 56; (ii) for a change of venue; (iii) to compel arbitration; (iv) to remand a removed case to State court; and (v) to challenge expert testimony under Daubert v. Merrell Dow Pharmaceuticals, Inc., 509 U.S. 579 (1993).
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Page 3 | Pre-Motion Conference Requests
Pre-motion conference letter requests are not required for Rule 50, 59, and 60 motions.
For example, letter motions requesting pre-motion conferences are not required for motions pursuant to Fed. R. Civ. P. 50, 59 and 60, and counsel should be aware that the Court of Appeals will not accept an argument that compliance with district court motion rules should excuse noncompliance with Fed. R. App. P. 4.
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Page 4 | Pre-Motion Conference Requests
Parties must submit a briefing schedule for court approval, and any changes require further court approval.
The parties are to set up their own briefing schedule and submit it to the court for approval. If the parties cannot agree on a schedule, the moving party will submit a proposed schedule to the court for approval, indicating the opposing party's non-consent or objection. Approval may be given at the pre-motion conference or by ECF order. No changes to the schedule may be made without court approval.
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Page 4 | Briefing Schedule
Adjournment & Extension Requirements
Adjournment or enlargement requests must be written and include specified history/consent details, and must include proposed revised dates if other scheduled dates are affected.
All requests for adjournments or enlargement of time must be in writing and state: i. The original date; ii. The number of previous requests for adjournment or enlargement; iii. Whether these previous requests were granted or denied; and iv. Whether the adversary consents, and, if not, the reasons given by the adversary for refusing to consent. If the requested adjournment or enlargement of time affects any other scheduled dates, proposed revised dates must be provided.
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Page 2 | Requests for Adjournments or Enlargement of Time
Adjournment or extension requests must be made at least two working days in advance, and requests within 24 hours of an appearance require a phone call to chambers.
at least two working days prior to the scheduled appearance or filing deadline. Any adjournment of a court appearance being requested within 24 hours of the appearance shall be accompanied by a telephone call to chambers advising the Court of the request.
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Page 3 | Requests for Adjournments or Enlargement of Time
Adjournment requests for in-court proceedings must be made at least 2 business days in advance.
Requests to adjourn any in-court proceeding shall be made at least two (2) business days in advance, and in the case of sentencing, at least five (5) business days in advance.
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Page 7 | Criminal Cases — Adjournment Requests
Chambers Communication Rules
Written communications with chambers must be filed on ECF and copied to parties not receiving automatic ECF notice.
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.
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Page 3 | Communications with Chambers
Fax communications to chambers are allowed only if copies are sent or delivered to all counsel at the same time.
Faxes to chambers are permitted only if copies are simultaneously faxed or delivered to all counsel.
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Page 3 | Communications with Chambers
Chambers typically reviews ECF filings the next business day, and urgent submissions should be followed by a telephone notification after filing.
As a general matter, materials filed via ECF are reviewed by chambers the first business day after submission. If your submission requires immediate attention, please notify chambers by telephone after you file via ECF.
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Page 2 | Court’s Review of ECF Submissions
Telephone calls to chambers are allowed, and scheduling-related calls should be directed to the listed chambers contact number.
Telephone calls to chambers are permitted. Please review this document before calling chambers with questions. For docketing, scheduling, or calendar matters, call Fida Abdallah at (718) 613-2515.
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Page 3 | Communications with Chambers
Junior Lawyer Participation Incentives
If a lawyer with five years or less of experience will appear, the Court will schedule a pre-motion conference.
However, if a party advises the Court in its pre-motion argument request that an attorney with five years or less of experience as a licensed attorney will be representing the party at the conference, the Court will schedule a pre-motion conference.
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Page 4 | Pre-Motion Conference Requests
If oral argument will be presented by an attorney with five years or less of licensed experience, the Court will schedule oral argument.
However, if a party advises the Court in its oral argument request that an attorney with five years or less of experience as a licensed attorney will be presenting the party’s argument, the Court will schedule an oral argument.
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Page 5 | Oral Argument on Motions