Eastern District of New York Local Rules and Judge Filing Requirements

The JPTO must state whether the case will be jury or bench and estimate the number of trial days needed.

Parties offering more than 10 exhibits must meet with Case Manager 5 days before trial for electronic presentation setup.

A sealed submission filed without prior approval must include an explanation of why sealing is necessary.

Criminal-case memoranda of law must follow the civil-motion memorandum rules unless the court directs otherwise.

Counsel must provide pro se litigants a copy of the Court’s Individual Practice Rules and promptly file a certificate of service.

All communications with the Court must be via letter filed on ECF unless an exception applies.

If exhibit volume makes the binder requirement impracticable, parties should call chambers at least 10 business days before trial for courtesy-copy instructions.

Fax communications to Chambers require prior authorization.

Ex parte telephone calls about case substance are prohibited.

All chambers communications must be written, filed on ECF, with copies to non-ECF parties; counsel correspondence not sent to Court.

Daubert and Rule 12 pre-motion letters and responses are limited to three pages, responses are due within one week, and Rule 12 responses must address leave to amend.

A party seeking a restraining order must identify a mutually agreeable hearing time with the adversary so the Court can hear from both sides before deciding temporary injunctive relief.

Pre-motion request letters are limited to 3 pages, and response letters are also limited to 3 pages and due within 7 days.

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

Unless modified by the summary-judgment subsection, non-movants must file a pre-motion response letter within five business days, limited to three pages.

Text-searchable submissions are mandatory except for pro se litigants.

Proposed orders, jury instructions, and similar proposed writings should be submitted to chambers in Word format.

Memoranda of law must use 12-point font (10-point footnotes), one-inch margins, be text-searchable, and show the date of service on the front cover.

One week before trial, parties must provide three tabbed binders containing all exhibit copies.

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

Extension requests for objection/response deadlines must be directed to Judge Gujarati.

Adjournment requests must be made 72 hours in advance in writing via letter-motion.

Adjournment and extension requests must be filed at least three business days in advance and through ECF, except pro se litigants.

Extension requests for sentencing-memorandum deadlines must be filed by motion and include specified date, history, reason, proposed date, and consent information.

Adjournment requests require at least 3 business days advance notice.

Courtesy copy binders must have case name, docket number, and contents on covers and spines.

Courtesy-copy submissions of 50+ pages must be in one tabbed three-ring binder, with maximum 2-inch size and labeled cover/spine.

Courtesy copies must be double-sided, match the ECF-filed document, include ECF numbering at the top, and be marked "Courtesy Copy."

After filing, movants must mail one hard copy of motion papers and stipulations of fact to Chambers, marked as Courtesy Copy.

Summary-judgment pre-motion conference requests require courtesy hard copies to chambers, and courtesy copies cannot be sent by email or hard drive.

Cross-motions for summary judgment have specific word limits: plaintiff opening 8,750 words; defendant combined 17,500 words; plaintiff combined 12,250 words; defendant reply 3,500 words.

Non-dispositive motions: 15 pages for briefs, 5 pages for replies.

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

Support and opposition memoranda are limited to 25 pages, excluding appendices and attachments.

Letters to chambers are limited to 3 pages.

The Court requires bundled motion filing (file only when fully briefed) except for FRCP 50/52/59/60 motions, remand motions, and pro se movant motions.

Noncompliance with the Bundling Rule leads to termination of the motion without prejudice.

Parties should file motion papers when fully briefed rather than filing seriatim.

Very large filings must be split into multiple ECF docket entries with Help Desk consultation.

The movant must file all motion papers, statements of contentions, and the administrative record together as a complete set.

Sealing requests are typically denied if they do not propose redactions or specifically explain why redactions are not feasible.

Criminal sealed-filing procedures are provided in the referenced EDNY instruction document.

Confidential information filed with the Court must be filed under seal.

Sealing requests must comply with EDNY Administrative Order No. 2004-05.

Confidential treatment may be applied to proprietary commercial data, sensitive personal data, medical/legal records, and non-public criminal history.

Less experienced attorneys are defined as those with 6 or fewer years of experience, excluding clerkships and leave time.

Inexperienced attorneys are encouraged to participate in all court proceedings.

Junior lawyers (5 years or less experience) may increase likelihood of oral argument.

When a lawyer with six or fewer years of experience argues a motion, the Court may allow more experienced counsel to assist during oral argument.

Multiple attorneys may argue for each party at oral argument.