Court Rules
Magistrate Judge

Judge Barbara Moses

Individual Rules, Standing Orders & Policies

Rules last changed:
Southern District of New York

Limits & Logistics

Document Limits

Letter Motion
2,000 wds
Brief
Local Civ. R. 7.1(c) wds
Document
2,000 wds
Pretrial Memorandum
8,750 wds

Courtesy Copies

Formal Motion

  • Hand Delivery • Promptly After Filing

Letter, Letter Motion

  • 1 copy • Hand Delivery • Promptly
  • Mail • Promptly

Motion, Brief, Opposition, Reply

  • Hand Delivery • Upon Filing

Binding: Three Ring Binder

Adjournments

  • Adjournment/extension requests must be made by letter-motion
  • Extension requests must be made before the deadline; adjournments require 4 days notice with proposed dates.
  • Adjournment requests must be made at least 4 days in advance with two proposed dates.

Request must include

Reason For RequestOriginal DateNumber Of Previous RequestsPrevious Requests Granted Or DeniedAdversary PositionProposed New DatesAffects Other Dates
4Calendar Daysnotice
  • Adjournment requests must be made at least 4 days in advance with 2 proposed dates.
Proposed Rescheduled Date

Communication

Email

Intake Unit

prose@nysd.uscourts.gov
Email

Chambers

moses_nysdchambers@nysd.uscourts.gov
Technical IssuesScheduling
No status inquiries
Phone

Chambers

212-805-0228
SchedulingEmergenciesTechnical Issues
No status inquiries
Letter via ECF

Chambers

Emergencies
No status inquiries
Letter via ECF

Intake Unit

No status inquiries
Filters:AllMandatoryImportantFormattingLettersTRO/InjunctionExhibitsECF Filing56.1 StatementsSummary JudgmentEvidence/Witnesses

Page & Word Limits4 rules

Page LimitsCivil cases

Machine summary. Not checked yet.Mandatory?

Absent advance permission from the Court, letters and letter-motions may not exceed 2000 words (approximately four pages) in length, exclusive of attachments, which should be kept to a minimum.

Summary: Letters and letter-motions limited to 2000 words (4 pages) without advance permission

Letter Motion

2,000 words

Applies to: Attorney

Page LimitsCivil cases

Machine summary. Not checked yet.Mandatory?

Absent advance permission from the Court, letters and letter-motions may not exceed 2000 words (approximately four pages) in length, exclusive of attachments, which should be kept to a minimum.

Summary: Letters and letter-motions limited to 2000 words, excluding attachments.

2,000 words

BCM Moses Individual Practices 4 8 25 Final · Apr 2025 · p. 2
|Sec1. Communications with Chambers - Word Limits; Courtesy Copies; Service
Page LimitsCivil cases

Machine summary. Not checked yet.Mandatory?

Unless advance permission has been granted, briefs in support of and in response to a motion (except for motions for reconsideration) must comply with the word limits prescribed by Local Civ. R. 7.1(c).

Summary: Briefs must comply with word limits unless advance permission granted.

Structured details unavailable. See the source text.

Page LimitsCivil cases

Machine summary. Not checked yet.Mandatory?

If the parties believe it would be useful, they may also file pretrial memoranda, limited to 8,750 words (approximately 25 pages).

Summary: Pretrial memoranda are limited to 8,750 words (approximately 25 pages).

Pretrial Memorandum

8,750 words

Document Format Requirements4 rules

FormattingCivil cases

Machine summary. Not checked yet.Mandatory?

The Court expects parties to adhere strictly to the typeface, margin and spacing requirements of Local Civ. R. 7.1(b).

Summary: Parties must strictly adhere to typeface, margin, and spacing requirements.

Typography
Line SpacingLocal Civ. R. 7.1(B)
Layout & Binding
Margins
Local Civ. R. 7.1(b)" all around
FormattingCivil cases

Machine summary. Not checked yet.Mandatory?

Three court days before the date set for the final pretrial conference, each party must provide each other party, and the Court, with a tabbed binder or binders containing copies of its trial exhibits and deposition designations.

Summary: Trial exhibits must be provided in tabbed binders to all parties and the Court three court days before the final pretrial conference.

Layout & Binding
Binding Style
Tabbed Three Ring
FormattingCivil cases

Machine summary. Not checked yet.Important?

Bulky materials should be neatly bound or placed in 3-ring binders with appropriate dividers.

Summary: Bulky materials in courtesy copies should be bound or in 3-ring binders.

Layout & Binding
Binding Style
Three Ring Binder
FormattingCivil cases

Machine summary. Not checked yet.Important?

Courtesy copies should bear the ECF header generated at the time of electronic filing and include protruding tabs for any exhibits.

Summary: Courtesy copies must include ECF header and protruding tabs for exhibits.

Document Filing Requirements19 rules

Filing RequirementsCivil cases

Machine summary. Not checked yet.Mandatory?

In pro se cases, letters and letter-motions filed via ECF by represented parties must also be served on the pro se parties (unless they have consented to electronic service via ECF). Counsel must indicate the mode of service in the letter to the Court and must also file a proof of service.

Summary: In pro se cases, represented parties must serve pro se parties and file proof of service.

Document Type

Letter

Content & Formatting
Certificate Of Service
BCM Moses Individual Practices 4 8 25 Final · Apr 2025 · p. 2
|Sec1. Communications with Chambers - Word Limits; Courtesy Copies; Service
Filing RequirementsCivil cases

Machine summary. Not checked yet.Mandatory?

In pro se cases, letters and letter-motions filed via ECF by represented parties must also be served on the pro se parties (unless they have consented to electronic service via ECF). Counsel must indicate the mode of service in the letter to the Court and must also file a proof of service.

Summary: Pro se parties must be served on letters/motions from represented parties

Document Type

Letter Motion

Content & Formatting
Certificate Of Service
Filing RequirementsCivil cases

Machine summary. Not checked yet.Mandatory?

If the parties have settled while a motion is pending, or shortly before a scheduled conference or hearing, they must promptly so advise the Court, by letter, in order to avoid unnecessary expenditure of judicial resources.

Summary: Settlement notification must be promptly provided by letter

Document Type

Settlement Notification

Specific requirements detailed in rule text.
Filing RequirementsCivil cases

Machine summary. Not checked yet.Mandatory?

As required by Local Civ. R. 56.1(d), each statement of undisputed material fact and response thereto shall be followed by a citation to the specific evidentiary material that supports the statement or response, e.g., "Bennett Deposition Tr. 3:15-4:20," or "Salim Interrog. Resp. No. 18." General references to a "transcript," "interrogatory responses," or the like are inadequate.

Summary: Summary judgment statements must cite specific evidentiary material, not general references.

Document Type

Summary Judgment Motion

Specific requirements detailed in rule text.
Filing RequirementsCivil cases

Machine summary. Not checked yet.Mandatory?

The opposing party must reproduce each paragraph of the moving party's Statement of Material Facts, with the opposing party's response directly beneath.

Summary: Opposition to summary judgment must reproduce each paragraph with response beneath.

Document Type

Summary Judgment Opposition

Specific requirements detailed in rule text.
Filing RequirementsCivil cases

Machine summary. Not checked yet.Mandatory?

The moving party must provide all other parties with an electronic copy, in Microsoft Word format, of the moving party's Statement of Material Facts pursuant to Local Civ. R. 56.1.

Summary: Summary judgment motions require electronic Word copy of Statement of Material Facts.

Document Type

Summary Judgment Motion

Specific requirements detailed in rule text.
Filing RequirementsCivil cases

Machine summary. Not checked yet.Mandatory?

Motions for reconsideration must comply with the requirements of Local Civ. R. 6.3.

Summary: Motions for reconsideration must comply with Local Civ. R. 6.3.

Document Type

Motion For Reconsideration

Specific requirements detailed in rule text.
Filing RequirementsCivil cases

Machine summary. Not checked yet.Mandatory?

The letter-motion must be filed in public view, must explain the particular reasons for seeking to file that information under seal, and should not include any of the confidential information sought to be filed under seal.

Summary: Letter-motion for sealing must be public, explain reasons, and not include confidential information.

Document Type

Letter Motion

Specific requirements detailed in rule text.
Filing RequirementsCivil cases

Machine summary. Not checked yet.Mandatory?

The parties shall submit to the Court for its approval a proposed Joint Pretrial Order within 30 days after the date for the completion of discovery, or, if a summary judgment motion has been filed, within 30 days after the decision on the motion. The proposed Joint Pretrial Order shall be signed by all parties and include the following: i. The full caption of the action. ii. The names and addresses of trial counsel, together with their office and cellular telephone numbers, fax numbers, and email addresses.

Summary: Joint Pretrial Order due within 30 days after discovery or summary judgment decision, must include caption and counsel contact info.

Document Type

Joint Pretrial Order

Content & Formatting
Caption
Filing RequirementsCivil cases

Machine summary. Not checked yet.Mandatory?

Each exhibit shall be pre-marked (plaintiff to use numbers, defendant to use letters).

Summary: Exhibits must be pre-marked with numbers for plaintiffs and letters for defendants.

Document Type

Exhibit

Specific requirements detailed in rule text.
Filing RequirementsCivil cases

Machine summary. Not checked yet.Mandatory?

A pro se party must provide the Court and opposing parties with his or her address, telephone number, and email address, and must promptly update the Court and opposing parties if that information changes

Summary: Pro se parties must provide and promptly update contact information with the Court.

Document Type

Notice Of Appearance

Content & Formatting
Caption
Filing RequirementsCivil cases

Machine summary. Not checked yet.Mandatory?

As required by Local Civ. R. 56.1(d), each statement of undisputed material fact and response thereto shall be followed by a citation to the specific evidentiary material that supports the statement or response, e.g., "Bennett Deposition Tr. 3:15-4:20," or "Salim Interrog. Resp. No. 18." General references to a "transcript," "interrogatory responses," or the like are inadequate.

Summary: LR 56.1 statements and responses must cite specific evidentiary material; general references are inadequate.

Document Type

Summary Judgment Motion

Content & Formatting
Local Rule Certificate
Filing RequirementsCivil cases

Machine summary. Not checked yet.Mandatory?

The moving party must provide all other parties with an electronic copy, in Microsoft Word format, of the moving party's Statement of Material Facts pursuant to Local Civ. R. 56.1.

Summary: Moving party must provide electronic copy of Statement of Material Facts in Word format for summary judgment motions.

Document Type

Summary Judgment Motion

Content & Formatting
Local Rule Certificate
Filing RequirementsCivil cases

Machine summary. Not checked yet.Mandatory?

Deposition testimony may be designated as "Confidential" either on the record during the deposition or in writing within five (5) business days of receipt of the transcript. If so designated, the final transcript of the designated testimony shall be bound in a separate volume and marked "Confidential Information Governed by Protective Order" by the reporter.

Summary: Confidential deposition transcripts must be bound separately and marked with specific confidentiality language.

Document Type

Deposition Transcript

Specific requirements detailed in rule text.
BM Moses Model Protective Order 09 21 22 · p. 2
|SecDiscovery Materials May Be Designated as Confidential
Filing RequirementsCivil cases

Machine summary. Not checked yet.Mandatory?

If a disclosing person makes a claim of inadvertent disclosure, all receiving persons shall, within five (5) business days, return or destroy all copies of the Inadvertently Disclosed Information, and provide a certification of counsel that all such information has been returned or destroyed.

Summary: Receiving persons must provide certification of counsel confirming return or destruction of inadvertently disclosed privileged materials within 5 business days.

Document Type

Certificate

Specific requirements detailed in rule text.
BM Moses Model Protective Order 09 21 22 · p. 5
|SecInadvertent Disclosure of Privileged Materials
Filing RequirementsCivil cases

Machine summary. Not checked yet.Important?

A pro se party must provide the Court and opposing parties with his or her address, telephone number, and email address, and must promptly update the Court and opposing parties if that information changes, using the Notice of Change of Address form...

Summary: Pro se parties must provide and update contact information using Change of Address form.

Document Type

Notice Of Change Of Address

Specific requirements detailed in rule text.
Filing RequirementsCivil cases

Machine summary. Not checked yet.Note?

Letter-motions, as permitted by Local Civ. R. 7.1(d) and § 13.1 of the SDNY ECF Rules & Instructions, should be filed using the "letter-motion" option, listed under "motion." In particular, parties should file as letter-motions all requests for pre-motion conferences, adjournments, extensions, increased page limits, and any other non-dispositive relief listed in § 13.1 may also be made by letter-motion.

Summary: Letter-motions should be filed using the "letter-motion" option under "motion" for pre-motion conferences, adjournments, extensions, and increased page limits.

Document Type

Letter Motion

Specific requirements detailed in rule text.
BCM Moses Individual Practices 4 8 25 Final · Apr 2025 · p. 1
|Sec1. Communications with Chambers - Letter-Motions
Filing RequirementsCivil cases

Machine summary. Not checked yet.Note?

Letters that are informational in nature and do not request relief (for example, status updates requested by the Court) should be filed using the "letter" option, listed under "other documents."

Summary: Informational letters should be filed using the "letter" option under "other documents."

Document Type

Informational Letter

Specific requirements detailed in rule text.
BCM Moses Individual Practices 4 8 25 Final · Apr 2025 · p. 2
|Sec1. Communications with Chambers - Informational Letters
Filing RequirementsCivil cases

Machine summary. Not checked yet.Note?

Non-incarcerated pro se parties who have an email address and wish to receive, serve, and file case-related documents electronically may request permission to do so by filing a Motion for Permission for Electronic Case Filing

Summary: Pro se parties may request permission for electronic filing via motion.

Document Type

Motion

Content & Formatting
Caption

Filing & Service rules

Electronic Filing Rules

Counsel for each party must complete and sign the form, email it to the Court, and send copies to all other parties at the same time, no later than seven calendar days before the settlement conference.

Counsel of record for each party must complete and sign this form and email it to the Court at Moses_NYSDChambers@nysd.uscourts.gov, with copies sent simultaneously to all other parties, no later than one week (seven calendar days) before the parties’ scheduled settlement conference.

Checked against the court's document on Oct 4, 2026 · Civil cases

Page 1 | ACKNOWLEDGMENT FORM-SETTLEMENT CONFERENCE

Filing Timing and Cure Windows

The completed form must be emailed no later than seven calendar days before the scheduled settlement conference.

Counsel of record for each party must complete and sign this form and email it to the Court at Moses_NYSDChambers@nysd.uscourts.gov, with copies sent simultaneously to all other parties, no later than one week (seven calendar days) before the parties’ scheduled settlement conference.

Checked against the court's document on Oct 4, 2026 · Civil cases

Page 1 | ACKNOWLEDGMENT FORM-SETTLEMENT CONFERENCE

Service and Proof of Service Rules

Copies of the completed form must be sent to all other parties simultaneously with its email to the Court.

Counsel of record for each party must complete and sign this form and email it to the Court at Moses_NYSDChambers@nysd.uscourts.gov, with copies sent simultaneously to all other parties, no later than one week (seven calendar days) before the parties’ scheduled settlement conference.

Checked against the court's document on Oct 4, 2026 · Civil cases

Page 1 | ACKNOWLEDGMENT FORM-SETTLEMENT CONFERENCE

Courtesy Copy Requirements

Courtesy copy required for letters/letter-motions with more than one attachment, delivered to chambers with ECF header and tabs.

If a letter or letter-motion includes more than one attachment or exhibit, a paper courtesy copy of the entire submission, marked as such, must be promptly delivered to chambers by mail, overnight courier, or hand delivery. The courtesy copy should bear the ECF header generated at the time of electronic filing and include tabs for the attachments.

Machine summary. Not checked yet. · Civil cases

Page 2 | 1. Communications with Chambers - Word Limits; Courtesy Copies; Service

Courtesy copies required for letters/motions with multiple attachments

If a letter or letter-motion includes more than one attachment or exhibit, a paper courtesy copy of the entire submission, marked as such, must be promptly delivered to chambers by mail, overnight courier, or hand delivery. The courtesy copy should bear the ECF header generated at the time of electronic filing and include tabs for the attachments.

Machine summary. Not checked yet. · Civil cases

Page 2 | Communications with Chambers

Courtesy copies of formal motions must be delivered promptly after filing.

Paper courtesy copies of all formal motion papers, marked as such, must be delivered by hand, mail, or courier promptly after filing.

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Page 4 | Courtesy Copies

Paper courtesy copies of formal motion papers must be delivered promptly after filing with ECF header and tabs.

g. Courtesy Copies. Paper courtesy copies of all formal motion papers, marked as such, must be delivered by hand, mail, or courier promptly after filing. Courtesy copies should bear the ECF header generated at the time of electronic filing and include protruding tabs for any exhibits. Bulky materials should be neatly bound or placed in 3-ring binders with appropriate dividers.

Machine summary. Not checked yet. · Civil cases

Sealing & Redaction Procedures

Sealing requires court permission sought via letter-motion filed electronically on ECF.

Filing under seal requires permission of the Court, which may be sought via letter-motion. The letter-motion requesting approval of sealed or redacted filings and the document(s) as to which sealing is requested must be filed electronically on ECF in compliance with standing order No. 19-mc-00583 and § 6 of the SDNY ECF Rules & Instructions.

Machine summary. Not checked yet. · Civil cases

Page 5 | Sealing Motions

For redacted documents: file redacted version publicly and unredacted version under seal with highlights.

If the letter-motion seeks approval to redact information from a document that is otherwise to be publicly filed, the filing party shall: (a) publicly file the document in the proposed redacted form, and (b) electronically file under seal a copy of the unredacted document, with the proposed redactions highlighted. Both documents must be electronically filed through the ECF system and related to the motion.

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Page 5 | Sealing Motions

Documents sought to be sealed must be filed contemporaneously under seal on ECF and related to the letter-motion.

The document(s) as to which sealing is requested must be contemporaneously filed under seal on ECF and electronically related to the letter-motion. The summary docket text, but not the sealed document, will be open to public inspection and therefore should not include confidential information sought to be filed under seal.

Machine summary. Not checked yet. · Civil cases

Page 5 | Sealing Motions

Meet and confer required before filing sealed/redacted materials

The party seeking leave to file sealed or redacted materials should meet and confer with any opposing parties (or third parties seeking request. When a party seeks leave to file sealed or redacted materials on the ground that an opposing party or third party has requested it, that party shall notify the opposing party or third party that it must file, within three court days, a letter explaining the need to seal or redact the materials.

Machine summary. Not checked yet. · Civil cases

Redacted documents must be publicly filed with unredacted version under seal

If the letter-motion seeks approval to redact information from a document that is otherwise to be publicly filed, the filing party shall: (a) publicly file the document in the proposed redacted form, and (b) electronically file under seal a copy of the unredacted document, with the proposed redactions highlighted.

Machine summary. Not checked yet. · Civil cases

Sealing/redaction must be narrowly tailored and consistent with public access presumption

To be approved, any sealing or redaction of a court filing must be narrowly tailored to serve the purpose that requires the sealing or redaction and must be otherwise consistent with the presumption in favor of public access to judicial documents described in Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110, 119-20 (2d Cir. 2006).

Machine summary. Not checked yet. · Civil cases

Documents to be sealed must be filed under seal and related to letter-motion

The document(s) as to which sealing is requested must be contemporaneously filed under seal on ECF and electronically related to the letter-motion.

Machine summary. Not checked yet. · Civil cases

Sealed/redacted filings require letter-motion filed electronically on ECF

The letter-motion requesting approval of sealed or redacted filings and the document(s) as to which sealing is requested must be filed electronically on ECF in compliance with standing order No. 19-mc-00583 and § 6 of the SDNY ECF Rules & Instructions.

Machine summary. Not checked yet. · Civil cases

Letter-motion for sealing must be filed publicly with explanation

The letter-motion must be filed in public view, must explain the particular reasons for seeking to file that information under seal, and should not include any of the confidential information sought to be filed under seal.

Machine summary. Not checked yet. · Civil cases

Opposing parties must respond to sealing/redaction requests via ECF

If a sealing or redaction request is based on another party's designation of documents or information as 'confidential,' or if any party opposes the sealing or redaction request, that other party shall respond to the requesting party's letter-motion via ECF on the schedule set forth above in § 2(e).

Machine summary. Not checked yet. · Civil cases

Confidential information should be separated via redaction when possible.

Where the confidential portion is reasonably separable from the non-confidential portion, via redaction or otherwise, only the confidential portion shall be so designated.

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Page 2 | Discovery Materials May Be Designated as Confidential

No presumption that confidential discovery materials will be filed under seal; parties must follow individual judge practices for pretrial sealing requests.

Notwithstanding the designation of material as "Confidential" in discovery, there is no presumption that such Confidential Discovery Material will be filed with the Court under seal. The parties shall follow the individual practices of the Magistrate or District Judge to whom they direct pretrial requests for filing under seal.

Machine summary. Not checked yet. · Civil cases

Page 4 | Filing Confidential Materials in this Action

Motions to compel production of inadvertently disclosed privileged information must be filed under seal.

If a receiving person files a motion to compel production of the Inadvertently Disclosed Information, that motion shall be filed under seal, and shall not assert as a ground for entering such an order the mere fact of the inadvertent production.

Machine summary. Not checked yet. · Civil cases

Page 6 | Inadvertent Disclosure of Privileged Materials

Protective order survives termination; confidential materials must be returned or destroyed within 30 days.

This Protective Order shall survive the termination of the litigation. Within 30 days of the final disposition of this action, all Confidential Discovery Material and all copies thereof, shall be promptly returned to the producing person, or, upon permission of the producing person, destroyed.

Machine summary. Not checked yet. · Civil cases

Disclosing party must produce privilege log within 5 business days of return/destruction.

Within five (5) business days of the notification that such Inadvertently Disclosed Information has been returned or destroyed, the disclosing person shall produce a privilege log with respect to the Inadvertently Disclosed Information.

Machine summary. Not checked yet. · Civil cases

Receiving parties must return/destroy inadvertently disclosed privileged info within 5 business days.

If a disclosing person makes a claim of inadvertent disclosure, all receiving persons shall, within five (5) business days, return or destroy all copies of the Inadvertently Disclosed Information, and provide a certification of counsel that all such information has been returned or destroyed.

Machine summary. Not checked yet. · Civil cases

Discovery confidentiality designation alone does not justify sealing/redaction

The parties are cautioned that the designation of documents as 'confidential' for discovery purposes does not, without more, justify a sealing or redaction order.

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No presumption of sealing for confidential discovery materials; follow individual judge's practices.

Notwithstanding the designation of material as “Confidential” in discovery, there is no presumption that such Confidential Discovery Material will be filed with the Court under seal. The parties shall follow the individual practices of the Magistrate or District Judge to whom they direct pretrial requests for filing under seal.

Machine summary. Not checked yet. · Civil cases

Objections to confidentiality designations require written notice and may lead to joint call with court.

Any person who either objects to any designation of confidentiality, or who, by contrast, requests still further limits on disclosure (such as “attorneys’ eyes only,” reserved for extraordinary circumstances), may at any time prior to the trial of this action serve upon the designating person and all other parties a written notice stating with particularity the grounds of the objection or request. If agreement cannot be reached promptly, counsel for all affected persons shall request a joint telephone call with the Court to obtain a ruling.

Machine summary. Not checked yet. · Civil cases

No court permission needed for Rule 5.2 redactions (SSN, birth dates, minor names, financial accounts).

Notwithstanding the foregoing, no leave is required to redact all but the last four digits of an individual's social-security number or taxpayer-identification number, the day and month of an individual's birth, the name of an individual known to be a minor, or all but the last four digits of a financial-account number, consistent with Fed. R. Civ. P. 5.2.

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Page 6 | Sealing Motions

No leave required for redactions under Fed. R. Civ. P. 5.2

No Leave Required to Comply with Fed. R. Civ. P. 5.2. Notwithstanding the foregoing, no leave is required to redact all but the last four digits of an individual's social-security number or taxpayer-identification number, the day and month of an individual's birth, the name of an individual known to be a minor, or all but the last four digits of a financial-account number, consistent with Fed. R. Civ. P. 5.2.

Machine summary. Not checked yet. · Civil cases

Inadvertent disclosure of privileged materials does not waive privilege.

If, in connection with this litigation, and despite having taken reasonable steps to prevent the disclosure of information that it claims is subject to a claim of attorney- client privilege or attorney work product, a producing person inadvertently discloses information subject to a claim of attorney-client privilege or attorney work product protection (“Inadvertently Disclosed Information”), such disclosure, in itself, shall not constitute or be deemed a waiver or forfeiture of any claim of privilege or work product protection with respect to the Inadvertently Disclosed Information and its subject matter.

Machine summary. Not checked yet. · Civil cases

Pre-Motion Conference Requirements

Letter-motions must be filed using the letter-motion option for specific requests

Letter-motions, as permitted by Local Civ. R. 7.1(d) and § 13.1 of the SDNY ECF Rules & Instructions, should be filed using the "letter-motion" option, listed under "motion." In particular, parties should file as letter-motions all requests for pre-motion conferences, adjournments, extensions, increased page limits, and other relief that may be granted without a hearing.

Machine summary. Not checked yet. · Civil cases

Page 1 | Communications with Chambers

Discovery letter-motions must include verbatim disputed requests and responses.

The letter-motion must set forth verbatim each discovery request and response in contention in accordance with Local Civ. R. 37.1 and 5.1. This requirement may be satisfied by attaching the relevant request(s) and response(s) to the letter-motion.

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Page 3 | Discovery Motions

Discovery motions require good faith meet-and-confer in real time before filing.

No discovery dispute will be heard unless the moving party (including a non-party seeking relief from a subpoena) has first conferred in good faith and in "real time" (e.g., in person or by telephone) with the adverse party or parties, in an attempt to resolve the dispute. An exchange of letters or email alone does not satisfy this requirement.

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Page 3 | Discovery Motions

Discovery letter-motions must certify meet-and-confer and detail conference specifics.

The letter-motion must succinctly set forth the basis of the dispute and the relief sought, certify that the required good faith conference took place, and state: (1) the date, time, and duration of the parties' conference; (2) the names of the counsel who participated; and (3) the position of any relevant adverse party as to each contested issue.

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Page 3 | Discovery Motions

Opposition to letter-motions due within 3 court days; reply within 2 court days.

Unless the Court has ordered otherwise or the parties have agreed to a different briefing schedule, any opposition to a letter-motion shall be filed within three court days of the moving letter, and any reply shall be filed within two court days of the opposition.

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Discovery motions require good faith real-time conference before filing.

No discovery dispute will be heard unless the moving party (including a non-party seeking relief from a subpoena) has first conferred in good faith and in "real time" (e.g., in person or by telephone) with the adverse party or parties, in an attempt to resolve the dispute. An exchange of letters or email alone does not satisfy this requirement.

Machine summary. Not checked yet. · Civil cases

Formal motion briefing schedule follows Local Civ. R. 6.1 unless otherwise ordered.

Unless the Court has ordered otherwise or the parties have agreed to a different briefing schedule, opposition and reply papers with respect to formal motions will be due in accordance with Local Civ. R. 6.1.

Machine summary. Not checked yet. · Civil cases

Pre-motion conferences are optional for non-discovery motions and may be requested by letter-motion.

d. Pre-Motion Conferences. For motions other than discovery motions, pre-motion conferences are not required, but may be requested by letter-motion where counsel believe that an informal conference with the Court may obviate the need for the motion or narrow the issues in dispute.

Machine summary. Not checked yet. · Civil cases

Adjournment & Extension Requirements

Adjournment/extension requests must be made by letter-motion

Requests to adjourn a court conference or other court proceeding or to extend a deadline must be made by

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Page 2 | Motions

Adjournment requests must be made at least 4 days in advance with 2 proposed dates.

Requests for extension of a deadline must be made in advance of the deadline to be extended. Absent unforeseeable emergencies, requests for adjournment of a court conference or other proceeding must be made at least four days in advance of the proceeding to be adjourned, and must include at least two proposed dates, on which all counsel are available, for the adjourned proceeding.

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Page 3 | Adjournment Requirements

Adjournment requests must be made at least 4 days in advance with two proposed dates.

Absent unforeseeable emergencies, requests for adjournment of a court conference or other proceeding must be made at least four days in advance of the proceeding to be adjourned, and must include at least two proposed dates, on which all counsel are available, for the adjourned proceeding.

Machine summary. Not checked yet. · Civil cases

Extension requests must be made before the deadline; adjournments require 4 days notice with proposed dates.

Requests for extension of a deadline must be made in advance of the deadline to be extended. Absent unforeseeable emergencies, requests for adjournment of a court conference or other proceeding must be made at least four days in advance of the proceeding to be adjourned, and must include at least two proposed dates, on which all counsel are available, for the adjourned proceeding.

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Chambers Communication Rules

Communications with chambers must be via ECF motion/letter, not email/fax/phone/hard copy

Except as otherwise provided below, communications with the Court (other than during conferences, hearings, or trials) should be by motion or letter, filed on ECF. Except for confidential settlement letters, discussed in § 1(e) below, or as specifically directed by chambers in advance, the Court will not accept letters or motions from counseled parties by email, fax, telephone, or hard copy mailed or delivered directly to chambers.

Machine summary. Not checked yet. · Civil cases

Page 1 | Communications with Chambers

Communications should be by motion or letter filed on ECF; email, fax, telephone, and hard copy are not accepted.

Except as otherwise provided below, communications with the Court (other than during conferences, hearings, or trials) should be by motion or letter, filed on ECF. Except for confidential settlement letters, discussed in § 1(e) below, or as specifically directed by chambers in advance, the Court will not accept letters or motions from counseled parties by email, fax, telephone, or hard copy mailed or delivered directly to chambers.

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Page 1 | 1. Communications with Chambers - Motions and Letters

Ex parte settlement letters must be emailed to chambers

Ex parte letters required by the Court in advance of a settlement conference should be emailed to the chambers email address, which will be provided in the settlement conference scheduling order.

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Page 2 | Communications with Chambers

Pro se parties must submit non-electronic communications to Pro Se Intake Unit, not chambers.

All letters, motions, and other communications to the Court from pro se parties that are not filed electronically must be submitted to the Pro Se Intake Unit, not directly to chambers.

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Page 9 | Communications with Chambers

Pro se parties must submit communications to the Pro Se Intake Unit, not directly to chambers.

All letters, motions, and other communications to the Court from pro se parties that are not filed electronically must be submitted to the Pro Se Intake Unit, not directly to chambers.

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Page 9 | Communications with Chambers

Joint Pretrial Order must be signed by all parties and include caption and counsel contact info

The proposed Joint Pretrial Order shall be signed by all parties and include the following: i. The full caption of the action. ii. The names and addresses of trial counsel, together with their office and cellular telephone numbers, fax numbers, and email addresses.

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Joint Pretrial Order due 30 days after discovery completion or summary judgment decision

Unless the Court has ordered otherwise, the parties shall submit to the Court for its approval a proposed Joint Pretrial Order within 30 days after the date for the completion of discovery, or, if a summary judgment motion has been filed, within 30 days after the decision on the motion.

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Non-natural parties must send decision-maker with settlement authority

If a party is a corporation, union, government entity, or other non-natural person, it must send a decision-maker with knowledge of the case, responsibility for determining the amount of any ultimate settlement, and authority to enter into such a settlement.

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Parties must attend settlement conferences in person with lead trial attorney

Unless excused in advance, each party must attend the conference in person, accompanied by that party's lead trial attorney.

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Permission form required for computing devices; submit 2 business days in advance if Wi-Fi needed.

To seek permission, you must fill out the "Fillable Form for Electronic Devices General Purpose," available on the Southern District of New York's form database, HERE. The completed form should be emailed to chambers using the address above. If Wi-Fi is requested, please submit the form at least two business days prior to your court date.

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Page 1 | INSTRUCTIONS FOR ATTORNEYS BRINGING ELECTRONIC DEVICES TO COURT

Correspondence between parties should not be copied to chambers or filed on ECF except as exhibits.

Copies of correspondence between the parties or their counsel should not be copied to chambers, or filed on ECF, except as exhibits to otherwise properly-filed documents.

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Page 2 | 1. Communications with Chambers - Letters or Emails between Parties

Non-attorneys cannot bring electronic devices into the courthouse.

The Court is unable to authorize non-attorneys to bring electronic devices into the courthouse.

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Page 1 | INSTRUCTIONS FOR ATTORNEYS BRINGING ELECTRONIC DEVICES TO COURT

Telephone calls to chambers permitted for scheduling and calendar matters.

For scheduling and calendar matters, counsel may call chambers at 212-805-0228.

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Page 2 | 1. Communications with Chambers - Telephone Calls

Chambers phone number provided for scheduling; otherwise only for urgent matters

For scheduling and calendar matters, counsel may call chambers at 212-805-0228. Otherwise, telephone calls are permitted only for urgent matters requiring immediate attention or to obtain permission to submit a document other than via ECF.

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Page 2 | Communications with Chambers

Ex parte settlement letters should be emailed to chambers email address.

Ex parte letters required by the Court in advance of a settlement conference should be emailed to the chambers email address, which will be provided in the settlement conference scheduling order.

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Page 2 | 1. Communications with Chambers - Ex Parte Settlement Letters

Hand deliveries left with Court Security Officer at Worth Street entrance; urgent matters require notification to chambers.

Permitted hand deliveries may be left with a Court Security Officer at the Worth Street entrance of the Daniel Patrick Moynihan Courthouse. If the matter requires the Court's immediate attention, ask the Court Security Officer to notify chambers that an urgent delivery has arrived.

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Page 2 | 1. Communications with Chambers - Hand Delivery

Telephone calls permitted only for urgent matters or permission to submit non-ECF documents.

Otherwise, telephone calls are permitted only for urgent matters requiring immediate attention or to obtain permission to submit a document other than via ECF.

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Page 2 | 1. Communications with Chambers - Telephone Calls

Pro se parties can file documents via drop box, mail, or email to ProSe@nysd.uscourts.gov.

Pro se parties may file pleadings, letters, and other documents with the Court by using any of the following methods: i. Drop off the documents in the drop box located in the lobby of the U.S. Courthouse at 500 Pearl Street, New York, NY, 10007. ii. Mail the documents to the Pro Se Intake Unit at 500 Pearl Street, Room 205, New York, New York, 10007. iii. Email the documents to ProSe@nysd.uscourts.gov.

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Page 9 | Communications with Chambers

Pro se parties may file documents via drop box, mail, or email to ProSe@nysd.uscourts.gov.

Pro se parties may file pleadings, letters, and other documents with the Court by using any of the following methods: (i) Drop off the documents in the drop box located in the lobby of the U.S. Courthouse at 500 Pearl Street, New York, NY, 10007. (ii) Mail the documents to the Pro Se Intake Unit at 500 Pearl Street, Room 205, New York, New York, 10007. (iii) Email the documents to ProSe@nysd.uscourts.gov.

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Page 9 | Communications with Chambers

Settlement conferences held Mon-Thu at 2:15 PM

Settlement conferences are normally held Monday through Thursday, beginning at 2:15 p.m.

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Settlement conferences held in Courtroom 20A

Settlement conferences are normally held in Courtroom 20A.

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Pretrial procedures apply only to cases with consent under 28 U.S.C. § 636(c)

The procedures set out below apply only to cases in which the parties have consented pursuant to 28 U.S.C. § 636(c) to have all proceedings before Judge Moses, including trial.

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Attorneys with Service Pass may bring one personal device; others need permission for computing devices.

If you are an attorney with a valid SDNY Attorney Service Pass, you may bring one Personal Electronic Device (e.g., a cellphone) into the courtroom. If you are an attorney without a Service Pass, or if you have a Service Pass but wish to bring in a General Purpose Computing Device (e.g., a laptop) in order to advance proceedings before the Court, you must obtain permission from Judge Moses to bring the necessary device(s) into the courtroom.

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Page 1 | INSTRUCTIONS FOR ATTORNEYS BRINGING ELECTRONIC DEVICES TO COURT

Chambers email address for submitting electronic device permission forms.

Moses_NYSDChambers@nysd.uscourts.gov

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Page 1 | INSTRUCTIONS FOR ATTORNEYS BRINGING ELECTRONIC DEVICES TO COURT

Junior Lawyer Participation Incentives

Court encourages junior lawyer participation in proceedings, allowing second lawyer to handle portions of proceedings.

Normally, the Court applies the "one lawyer per party" rule for conferences, hearings, and motion arguments. However, the Court is willing to vary that rule in order to create opportunities for less experienced lawyers to argue or otherwise participate in courtroom proceedings as to matters they have helped prepare, and firms are encouraged to provide such opportunities for the junior members of their teams. Lead counsel should advise the Court at the outset of a proceeding of any request to permit a second lawyer to handle a portion of that proceeding.

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Page 8 | Junior Lawyers

About United States Magistrate Judge Barbara Moses

**Magistrate Judge Barbara Moses** was appointed to the Southern District of New York on December 23, 2015. Before joining the bench, Judge Moses was a partner at Morvillo Abramowitz Grand Iason & Anello, which she joined in 2002, representing clients in securities and business litigation. She also served as Director of the Constitutional and Civil Litigation Clinic at Seton Hall University School of Law, taught at New York University School of Law, and was a partner at Orrick, Herrington & Sutcliffe. She served as President of the New York County Lawyers' Association. **Education** - Harvard Law School, J.D., 1982 - Dartmouth College, B.A. in philosophy, 1978 **Career** - U.S. Magistrate Judge, Southern District of New York (2015–present) - Partner, Morvillo Abramowitz Grand Iason & Anello (2002–2015) - Director, Constitutional and Civil Litigation Clinic, Seton Hall University School of Law (through 2015) - Adjunct professor, New York University School of Law - Partner, Orrick, Herrington & Sutcliffe

**Courthouse:** Daniel Patrick Moynihan United States Courthouse, 500 Pearl Street, New York, NY 10007-1312 **Courtroom:** 20A **Deputy Phone:** (212) 805-4880 **Chambers Staff** - Scheduling/Contact: Chambers contact via court website

Common questions about Judge Barbara Moses's rules

Are courtesy copies required for Judge Barbara Moses?

Courtesy-copy rule applies for letters and letter motions. Details: 1 copy, delivery promptly, by hand delivery. Courtesy copies required for letters/motions with multiple attachments

View ruleSource: page 2, section Communications with Chambers

Does Judge Barbara Moses require a pre-motion conference or letter before filing a motion?

Yes. A pre-motion letter is required for covered motions before Judge Barbara Moses. Discovery motions require good faith meet-and-confer in real time before filing.

View ruleSource: page 3, section Discovery Motions

What page or word limits apply to letter motion before Judge Barbara Moses?

Judge Barbara Moses' rule states these limits: attorney: 2000 words. Letters and letter-motions limited to 2000 words (4 pages) without advance permission

View ruleSource: page 2, section Communications with Chambers

What page or word limits apply before Judge Barbara Moses?

Judge Barbara Moses' rule states these limits: 2000 words. Excludes attachments. Letters and letter-motions limited to 2000 words, excluding attachments.

View ruleSource: page 2, section 1. Communications with Chambers - Word Limits; Courtesy Copies; Service

What formatting rules apply to filings before Judge Barbara Moses?

Judge Barbara Moses' formatting rule includes local civ. r. 7.1(b) spacing. Parties must strictly adhere to typeface, margin, and spacing requirements.

View ruleSource: page 4, section Memoranda of Law

What must be included with letter motion filings before Judge Barbara Moses?

The rule requires certificate of service. Pro se parties must be served on letters/motions from represented parties

View ruleSource: page 2, section Communications with Chambers

What must be included with settlement notification filings before Judge Barbara Moses?

The rule requires settlement status. Settlement notification must be promptly provided by letter

View ruleSource: page 2, section Communications with Chambers

How may parties contact Judge Barbara Moses' chambers?

The rule addresses letter ecf communications with Judge Barbara Moses' chambers. Communications with chambers must be via ECF motion/letter, not email/fax/phone/hard copy

View ruleSource: page 1, section Communications with Chambers

How does Judge Barbara Moses handle sealed or redacted filings?

Judge Barbara Moses's rules set procedures for sealed or redacted filings. Process: file redacted on ecf. Sealed/redacted filings require letter-motion filed electronically on ECF

How do I request an adjournment or extension before Judge Barbara Moses?

Advance notice is not fully stated in the structured details. The request must include reason for request, original date, number of previous requests, previous requests granted or denied, adversary position, and proposed new dates. Adjournment/extension requests must be made by letter-motion

View ruleSource: page 2, section Motions

Is electronic filing required before Judge Barbara Moses?

Yes. Electronic filing is required for the covered filings. Counsel for each party must complete and sign the form, email it to the Court, and send copies to all other parties at the same time, no later than seven calendar days before the settlement conference.

View ruleSource: page 1, section ACKNOWLEDGMENT FORM-SETTLEMENT CONFERENCE

What filing deadlines does Judge Barbara Moses set?

The completed form must be emailed no later than seven calendar days before the scheduled settlement conference.

View ruleSource: page 1, section ACKNOWLEDGMENT FORM-SETTLEMENT CONFERENCE

What rule applies to service by email for all parties before Judge Barbara Moses?

The rule addresses service method, recipient, or timing requirements. Details: method: service by email, recipient: all parties. Copies of the completed form must be sent to all other parties simultaneously with its email to the Court.

View ruleSource: page 1, section ACKNOWLEDGMENT FORM-SETTLEMENT CONFERENCE

Does Judge Barbara Moses encourage junior lawyer participation?

Yes. Judge Barbara Moses's rules include a junior lawyer participation incentive. Court encourages junior lawyer participation in proceedings, allowing second lawyer to handle portions of proceedings.

View ruleSource: page 8, section Junior Lawyers
Complete rules summary for Judge Barbara Moses

Communications with chambers must be via ECF motion/letter, not email/fax/phone/hard copy

Letters and letter-motions limited to 2000 words (4 pages) without advance permission

Courtesy copies required for letters/motions with multiple attachments

Pro se parties must be served on letters/motions from represented parties

Ex parte settlement letters must be emailed to chambers

Settlement notification must be promptly provided by letter

Summary judgment motions require electronic Word copy of Statement of Material Facts.

Chambers phone number provided for scheduling; otherwise only for urgent matters

Adjournment/extension requests must be made by letter-motion

Adjournment requests must be made at least 4 days in advance with 2 proposed dates.

Discovery motions require good faith meet-and-confer in real time before filing.

Discovery letter-motions must certify meet-and-confer and detail conference specifics.

Discovery letter-motions must include verbatim disputed requests and responses.

Opposition to summary judgment must reproduce each paragraph with response beneath.

Summary judgment statements must cite specific evidentiary material, not general references.

Courtesy copies of formal motions must be delivered promptly after filing.

Courtesy copies must include ECF header and protruding tabs for exhibits.

Bulky materials in courtesy copies should be bound or in 3-ring binders.

Briefs must comply with word limits unless advance permission granted.

Motions for reconsideration must comply with Local Civ. R. 6.3.

Parties must strictly adhere to typeface, margin, and spacing requirements.

Sealed/redacted filings require letter-motion filed electronically on ECF

Letter-motion for sealing must be filed publicly with explanation

Documents to be sealed must be filed under seal and related to letter-motion

Redacted documents must be publicly filed with unredacted version under seal

Sealing/redaction must be narrowly tailored and consistent with public access presumption

Discovery confidentiality designation alone does not justify sealing/redaction

Opposing parties must respond to sealing/redaction requests via ECF

Meet and confer required before filing sealed/redacted materials

No leave required for redactions under Fed. R. Civ. P. 5.2

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