Judge Gabriel W. Gorenstein
Individual Rules, Standing Orders & Policies
- Rules last changed:
Limits & Logistics
Courtesy Copies
Memorandum Of Law
- 1 copy • Hand Delivery • Upon Filing
- 1 copy • Mail • Upon Filing
Adjournments
- Extension requests must include dates, previous requests, reason, adversary position, and proposed changes to other dates.
- Objections to discovery deadline extensions require compliance with pre-motion conference requirements.
- Objection to discovery deadline extension requires compliance with pre-motion conference requirements.
Request must include
- Adjournment requests must be made 5 business days before appearance (unless emergency), contact Deputy Clerk for dates, check other parties’ availability, file ECF letter with positions.
- Adjournment requests must be made at least 5 business days before appearance unless unforeseen circumstances.
Communication
Phone
Chambers
Letter via ECF
Letter via fax
Chambers
Letter via ECF
Chambers
Letter via fax
Chambers
Page & Word Limits2 rules
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Notwithstanding the provisions of Local Rule 7.1 (c) to the contrary, the Court does not impose page or word count limitations on memoranda of law. Nonetheless, a party should make every effort to eliminate repetitive or unnecessary mater from memoranda so as not to unnecessarily burden the Court. Memoranda of more than 10 pages shall contain a table of contents.
Summary: No page/word limits on memoranda of law, but >10 pages requires table of contents.
Structured details unavailable. See the source text.
Machine summary. Not checked yet.Note?
Notwithstanding the provisions of Local Rule 7.1 (c) to the contrary, the Court does not impose page or word count limitations on memoranda of law. Nonetheless, a party should make every effort to eliminate repetitive or unnecessary mater from memoranda so as not to unnecessarily burden the Court. Memoranda of more than 10 pages shall contain a table of contents.
Summary: No page/word limits on memoranda of law, but those over 10 pages must include a table of contents.
Structured details unavailable. See the source text.
Document Filing Requirements22 rules
Machine summary. Not checked yet.Mandatory?
The memorandum of law must set forth all pertinent facts, which may not be accomplished by incorporating by reference other documents, such as affidavits or statements under Local Civil Rule 56.1. Instead, the memorandum must contain a fact section that sets forth all facts relevant to the motion and, for each factual statement, provides one or more citations (with specific page or paragraph numbers) to
Summary: Memoranda must contain fact sections with citations, not incorporate by reference.
Document Type
Memorandum Of Law
Machine summary. Not checked yet.Mandatory?
A memorandum of law must accompany all motions and oppositions thereto. See Local Civil Rule 7.1.
Summary: Memorandum of law required with all motions and oppositions.
Document Type
Motion
Machine summary. Not checked yet.Mandatory?
As required by Local Civil Rule 7.2, counsel must provide a pro se litigant with printed copies of decisions cited in any submission that are reported exclusively in computerized databases.
Summary: Pro se litigants must receive printed copies of cited decisions.
Document Type
Submission
Machine summary. Not checked yet.Mandatory?
Any motion for summary judgment must comply with Local Civil Rule 56.1, except that a party who is not required to comply with Local Civil Rule 56.1(d) based on the applicability of Fed. R. Civ. P. 56(c)(1)(B) may seek to be relieved of Local Civil Rule 56.1(d)'s requirements by raising the issue in the pre-motion conference request.
Summary: Summary judgment motions must comply with Local Rule 56.1.
Document Type
Summary Judgment Motion
Machine summary. Not checked yet.Mandatory?
Unless otherwise ordered by the Court, within 30 days from the date for the completion of discovery in a civil case, the parties shall submit to the Court for its approval a joint pretrial order
Summary: Joint pretrial order required within 30 days after discovery completion
Document Type
Joint Pretrial Order
Machine summary. Not checked yet.Mandatory?
At or before the time the materials set forth in paragraph 3.C above are filed, the parties shall deliver to the Court in a loose-leaf binder: (1) a copy of each of the party’s pre-marked exhibits, see paragraph 3.B.x above, and (2) a copy of any deposition testimony designated in paragraph 3.B.ix above.
Summary: Loose-leaf binder with exhibits and deposition testimony required before trial
Document Type
Chambers Copy
Machine summary. Not checked yet.Mandatory?
Unless otherwise ordered by the Court, each party shall file – at the same time as the filing of the joint pretrial order – the following:
Summary: Trial memoranda and other filings required with joint pretrial order
Document Type
Trial Memorandum Of Law
Machine summary. Not checked yet.Mandatory?
Any requests to schedule a witness out of order and/or for a particular day must be made by a letter application that states the opposing party’s position and that is sent (1) prior to trial and (2) as soon as counsel is aware of the limited availability of that witness.
Summary: Letter application required for out-of-order witness scheduling
Document Type
Letter Application
Machine summary. Not checked yet.Mandatory?
I certify that the person attending the conference (in person or by telephone) is the person with ultimate responsibility for determining the settlement amount: that is, the person responsible for giving settlement authority, not someone who has received authority from another person.
Summary: Conference attendee must have ultimate settlement authority, not delegated authority.
Document Type
Settlement Conference Acknowledgment
Machine summary. Not checked yet.Mandatory?
I certify that I have read both the Court’s Order scheduling this conference as well as the “Standing Order Applicable to Settlement Conferences Before Judge Gorenstein.”
Summary: Attorney must certify having read both the scheduling order and Judge Gorenstein's standing order for settlement conferences.
Document Type
Settlement Conference Acknowledgment
Machine summary. Not checked yet.Mandatory?
I certify that I will promptly supply a copy of opposing counsel’s settlement letter to all persons attending the conference (by telephone or in person), and I will ensure that each person has read opposing counsel’s letter prior to the conference.
Summary: Attorney must provide opposing counsel's settlement letter to all conference attendees before the conference.
Document Type
Settlement Conference Acknowledgment
Machine summary. Not checked yet.Mandatory?
Unless otherwise ordered by the Court, within 30 days from the date for the completion of discovery in a civil case, the parties shall submit to the Court for its approval a joint pretrial order, which shall include the following:
Summary: Joint pretrial order required within 30 days after discovery completion
Document Type
Joint Pretrial Order
Machine summary. Not checked yet.Mandatory?
Unless otherwise ordered by the Court, each party shall file – at the same time as the filing of the joint pretrial order – the following:
Summary: Trial memoranda and related documents due with joint pretrial order
Document Type
Trial Memorandum Of Law
Machine summary. Not checked yet.Mandatory?
At or before the time the materials set forth in paragraph 3.C above are filed, the parties shall deliver to the Court in a loose-leaf binder: (1) a copy of each of the party’s pre-marked exhibits, see paragraph 3.B.x above, and (2) a copy of any deposition testimony designated in paragraph 3.B.ix above.
Summary: Pre-marked exhibits and deposition testimony must be delivered to Court in loose-leaf binder
Document Type
Exhibits Depositions
Machine summary. Not checked yet.Mandatory?
Any requests to schedule a witness out of order and/or for a particular day must be made by a letter application that states the opposing party’s position and that is sent (1) prior to trial and (2) as soon as counsel is aware of the limited availability of that witness. Untimely applications will be denied.
Summary: Out-of-order witness scheduling requests require letter application with opposing party’s position, must be timely
Document Type
Witness Scheduling Request
Machine summary. Not checked yet.Mandatory?
As required by Local Civil Rule 7.2, counsel must provide a pro se litigant with printed copies of decisions cited in any submission that are reported exclusively in computerized databases.
Summary: Printed copies of computer-database-only decisions must be provided to pro se litigants.
Document Type
Submission
Machine summary. Not checked yet.Mandatory?
The memorandum of law must set forth all pertinent facts, which may not be accomplished by incorporating by reference other documents, such as affidavits or statements under Local Civil Rule 56.1. Instead, the memorandum must contain a fact section that sets forth all facts relevant to the motion and, for each factual statement, provides one or more citations (with specific page or paragraph numbers) to
Summary: Memoranda of law must contain a fact section with all relevant facts and citations to specific pages or paragraphs.
Document Type
Memorandum Of Law
Machine summary. Not checked yet.Mandatory?
A memorandum of law must accompany all motions and oppositions thereto. See Local Civil Rule 7.1.
Summary: All motions and oppositions must include a memorandum of law.
Document Type
Motion
Machine summary. Not checked yet.Important?
Untimely applications will be denied.
Summary: Untimely witness scheduling applications will be denied
Document Type
Trial Schedule
Machine summary. Not checked yet.Important?
When a party’s case commences, that party is expected to have witnesses available to fill the trial day, which runs from 9:00 a.m. to 5:00 p.m. with a one hour lunch break. The parties are warned that if a party does not have a witness available to testify, the Court may deem that party to have rested.
Summary: Parties must have witnesses available for full trial day or risk being deemed to have rested
Document Type
Witness Availability
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Orders permitting an attorney to bring an electronic device to the Courthouse may be requested by filing a letter on ECF (using the “Letter” category) that attaches a completed form. Any such letter shall be filed at least two business days before the proceeding at issue. The form for such orders is located on the forms page of the SDNY website and is entitled “Fillable Form For Electronic Devices General Purpose.” (It can be found by using the “what are you seeking” box on the Forms page and searching for “electronic devices.”) Note that only attorneys are eligible for such an order.
Summary: Electronic device orders require ECF letter with form, filed 2 business days before proceeding; only attorneys eligible.
Document Type
Electronic Device Order
Machine summary. Not checked yet.Note?
When a party’s case commences, that party is expected to have witnesses available to fill the trial day, which runs from 9:00 a.m. to 5:00 p.m. with a one hour lunch break.
Summary: Trial day runs 9:00 AM to 5:00 PM with one hour lunch break
Document Type
Trial Schedule
Filing & Service rules
Courtesy Copy Requirements
One courtesy copy of each memorandum of law must be sent to Chambers by mail at filing.
A party must send to Chambers (by postal mail or other delivery to 40 Foley Square) one courtesy copy of each memorandum of law the party files, marked as such, at the same time as it is filed.
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Page 3 | Courtesy Copies of Motion Papers
One courtesy copy of each memorandum of law must be sent to Chambers at 40 Foley Square at the time of filing.
A party must send to Chambers (by postal mail or other delivery to 40 Foley Square) one courtesy copy of each memorandum of law the party files, marked as such, at the same time as it is filed.
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Sealing & Redaction Procedures
Motion to seal must cite case law and justify sealing within 7 days.
At the time of the filing of the redacted and unredacted versions of the materials, the filing party shall either (1) state that the redactions are a result of a Confidentiality Order designation made by another party and that such other party has an obligation to file a motion to seal within 7 days or (2) file a motion to seal (either as a formal motion or as a letter motion) that justifies the proposed sealing by citing case law and providing any factual explanation required to justify the sealing.
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Page 3 | Requests to File Materials Under Seal
Sealed filings require both sealed and redacted versions; sensitive info must be redacted.
The parties are reminded that the filing of any papers or portions of papers under seal is only permitted pursuant to an order of the Court or these Individual Practices. (This does not apply to the sensitive information described in Fed. R. Civ. P. 5.2 which must be redacted and for which no Court order is required). To the extent papers proposed for filing contain material that one or both sides believe should be filed under seal, the party shall (1) file the materials under seal and (2) publicly file the materials in redacted form (that is, in a form that redacts information that is proposed to be sealed).
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Page 3 | Requests to File Materials Under Seal
Motion to seal must be filed within 7 days, either by the filing party or the designating party.
At the time of the filing of the redacted and unredacted versions of the materials, the filing party shall either (1) state that the redactions are a result of a Confidentiality Order designation made by another party and that such other party has an obligation to file a motion to seal within 7 days or (2) file a motion to seal (either as a formal motion or as a letter motion) that justifies the proposed sealing by citing case law and providing any factual explanation required to justify the sealing. In cases where the request to seal arises because of an opposing party’s designations, the opposing party has the obligation to make the written application to the Court justifying the proposed sealing and shall make the application within 7 days of the filing.
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Sealed filings require both sealed and redacted versions, with redactions clearly indicated.
The parties are reminded that the filing of any papers or portions of papers under seal is only permitted pursuant to an order of the Court or these Individual Practices. (This does not apply to the sensitive information described in Fed. R. Civ. P. 5.2 which must be redacted and for which no Court order is required). To the extent papers proposed for filing contain material that one or both sides believe should be filed under seal, the party shall (1) file the materials under seal and (2) publicly file the materials in redacted form (that is, in a form that redacts information that is proposed to be sealed). The set of papers filed under seal shall highlight any proposed redactions or otherwise clearly indicate where they occur.
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Pre-Motion Conference Requirements
Pre-motion conferences required for motions before Judge Gorenstein except for pro hac vice, reconsideration, certain appeal motions, recusal, and show cause applications.
As described below, pre-motion conferences are required where the proposed motion is returnable before Judge Gorenstein, or where the proposed motion has been referred to Judge Gorenstein, except that no pre-motion conference is required for motions for admission pro hac vice, motions for reconsideration or reargument, motions listed in Fed. R. App. P. 4(a)(4)(A), motions for recusal, and applications made by order to show cause.
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Page 2 | Motions
Discovery motions require good faith conference first; moving party must certify conference details in 5-page letter; opposing party responds promptly.
Discovery Motions. No application relating to discovery (that is, any dispute arising under Rules 26 through 37 or Rule 45 of the Federal Rules of Civil Procedure) shall be heard unless the moving party has first conferred in good faith by telephone or in person with all other relevant parties in an effort to resolve the dispute. A party must respond within one business day to any request from another party to confer unless an emergency prevents such a response. If the conference with the relevant parties has not resolved the dispute, the moving party must confirm this fact with the opposing party and must inform the opposing party during the conference that as a result of the impasse the moving party intends to seek relief from the Court regarding the dispute. The moving party must thereafter promptly request a conference with the Court. See Local Civil Rule 37.2. To request a conference with the Court, the moving party shall submit a letter (normally not more than five pages) setting forth the basis of the dispute and the need for the anticipated motion. (Do not use the “Letter Motion” category on ECF for such a letter; use instead the “Letter” category.) The letter must certify that the required in-person or telephonic conference took place between the relevant parties. The letter must also state (1) the date and time of such conference, (2) the approximate duration of the conference, (3) the names of the attorneys who participated, (4) the adversary’s position as to each issue being raised (as stated by the adversary during the in-person or telephonic conference), and (5) that the moving party informed the adversary during the conference that the moving party believed the parties to be at an impasse and that the moving party would be requesting a conference with the Court. None of these requirements may be satisfied by attaching copies of communications between the parties and it is usually unhelpful to attach such communications. The party opposing the requested relief must submit a letter to the Court in response as soon as practicable and in any event within
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Page 2 | Motions
Pre-motion letter (max 3 pages) required before motions to dismiss.
To arrange a pre-motion conference for non-discovery matters, the moving party shall submit a letter setting forth briefly (normally in not more than three pages) the nature of the anticipated motion. An opposing party shall respond within two business days.
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Page 3 | Pre-Motion Conferences in Civil Cases
Pre-motion conferences required for motions before/referred to Judge Gorenstein, except for specified exceptions.
As described below, pre-motion conferences are required where the proposed motion is returnable before Judge Gorenstein, or where the proposed motion has been referred to Judge Gorenstein, except that no pre-motion conference is required for motions for admission pro hac vice, motions for reconsideration or reargument, motions listed in Fed. R. App. P. 4(a)(4)(A), motions for recusal, and applications made by order to show cause.
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Page 2 | Motions
Conference request letter must certify that required conference took place.
The letter must certify that the required in-person or telephonic conference took place between the relevant parties.
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Page 2 | Motions
Discovery motions require good faith conference with opposing parties before filing.
Discovery Motions. No application relating to discovery (that is, any dispute arising under Rules 26 through 37 or Rule 45 of the Federal Rules of Civil Procedure) shall be heard unless the moving party has first conferred in good faith by telephone or in person with all other relevant parties in an effort to resolve the dispute.
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Page 2 | Motions
Conference request letter must include conference date/time, duration, participants, adversary positions, and impasse notification.
The letter must also state (1) the date and time of such conference, (2) the approximate duration of the conference, (3) the names of the attorneys who participated, (4) the adversary’s position as to each issue being raised (as stated by the adversary during the in-person or telephonic conference), and (5) that the moving party informed the adversary during the conference that the moving party believed the parties to be at an impasse and that the moving party would be requesting a conference with the Court.
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Page 2 | Motions
If conference doesn't resolve dispute, moving party must confirm impasse with opposing party.
If the conference with the relevant parties has not resolved the dispute, the moving party must confirm this fact with the opposing party and must inform the opposing party during the conference that as a result of the impasse the moving party intends to seek relief from the Court regarding the dispute.
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Page 2 | Motions
Requirements cannot be satisfied by attaching party communications.
None of these requirements may be satisfied by attaching copies of communications between the parties and it is usually unhelpful to attach such communications.
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Page 2 | Motions
Opposing party must respond to conference request letter as soon as practicable.
The party opposing the requested relief must submit a letter to the Court in response as soon as practicable and in any event within
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Page 2 | Motions
After impasse, moving party must promptly request conference with court.
The moving party must thereafter promptly request a conference with the Court.
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Page 2 | Motions
Conference request letter limited to 5 pages, setting forth dispute basis and need for motion.
To request a conference with the Court, the moving party shall submit a letter (normally not more than five pages) setting forth the basis of the dispute and the need for the anticipated motion.
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Page 2 | Motions
Must respond to conference requests within one business day unless emergency.
A party must respond within one business day to any request from another party to confer unless an emergency prevents such a response.
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Page 2 | Motions
Adjournment & Extension Requirements
Extension requests must include dates, previous requests, reason, adversary position, and proposed changes to other dates.
Requests for extensions of deadlines must state (1) the date or dates sought to be extended, (2) the number of previous requests for extensions, (3) the reason for the extension, and (4) whether the adversary objects and, if so, the reasons given by the adversary for objecting. To the extent a request to extend a particular date requires a change in other scheduled dates, the request must list the proposed change for all such other dates, giving the new proposed date for each affected deadline. A request may be made either by letter or by a joint stipulation that reflects the required information.
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Page 1 | Communications with Chambers
Adjournment requests must be made 5 business days before appearance (unless emergency), contact Deputy Clerk for dates, check other parties’ availability, file ECF letter with positions.
A request for an adjournment of a court appearance shall be made as soon as a party is aware of the need for the adjournment and, in any event, no later than five business days prior to the scheduled appearance (absent unforeseen circumstances). Prior to making such a request, the party intending to make the request should contact the Deputy Clerk ((212) 805-4260), to determine an alternative date for which the Court is available for a rescheduled court appearance. The requesting party should next contact all other parties to determine their availability for that date. The requesting party must then file a letter to the Court on ECF seeking the adjournment, stating the date and time that is being requested. The letter must include a statement as to the other parties’ positions on the change in date. The appearance is not adjourned unless the parties are thereafter informed by the Court that the written application has been granted.
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Page 2 | Communications with Chambers
Extension requests must include dates, previous requests, reason, adversary position, and proposed changes to other dates.
Requests for extensions of deadlines must state (1) the date or dates sought to be extended, (2) the number of previous requests for extensions, (3) the reason for the extension, and (4) whether the adversary objects and, if so, the reasons given by the adversary for objecting. To the extent a request to extend a particular date requires a change in other scheduled dates, the request must list the proposed change for all such other dates, giving the new proposed date for each affected deadline. A request may be made either by letter or by a joint stipulation that reflects the required information.
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Page 1 | Communications with Chambers
Adjournment requests must be made at least 5 business days before appearance unless unforeseen circumstances.
A request for an adjournment of a court appearance shall be made as soon as a party is aware of the need for the adjournment and, in any event, no later than five business days prior to the scheduled appearance (absent unforeseen circumstances).
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Page 2 | Communications with Chambers
Objections to discovery deadline extensions require compliance with pre-motion conference requirements.
Note: to the extent a party’s adversary objects to a request regarding a discovery deadline, the party must also comply with the conference requirements of paragraph 2.A below.
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Page 1 | Communications with Chambers
Objection to discovery deadline extension requires compliance with pre-motion conference requirements.
Note: to the extent a party’s adversary objects to a request regarding a discovery deadline, the party must also comply with the conference requirements of paragraph 2.A below.
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Page 1 | Communications with Chambers
Chambers Communication Rules
Letters by mail/overnight to 40 Foley Square; hand delivery accepted; no email letters.
Letters sent by mail or overnight delivery should be addressed to Judge Gorenstein at the U.S. Courthouse, 40 Foley Square, New York, NY 10007. If delivered by hand, letters should be brought to 40 Foley Square. The Court does not accept letters by email.
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Page 1 | Communications with Chambers
Telephone calls to chambers only for emergencies; otherwise use letters.
Except as provided in Paragraph 1.D below, telephone calls to Chambers are permitted only in emergency situations. For any other situation, a party may submit a letter to the Court in accordance with paragraphs 1.A and 1.B above.
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Page 1 | Communications with Chambers
Settlement conference acknowledgment form must be emailed 4 business days before conference to all attending attorneys and Judge Gorenstein.
Complete this form (please print or type) or its equivalent, sign it, and email it no later than midnight four business days prior to the conference (1) to all other attorneys who will be attending the conference and (2) to Judge Gorenstein.
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Page 1 | ACKNOWLEDGMENT FORM
Letters must be mailed, overnight delivered, or hand-delivered to 40 Foley Square; email not accepted.
Letters sent by mail or overnight delivery should be addressed to Judge Gorenstein at the U.S. Courthouse, 40 Foley Square, New York, NY 10007. If delivered by hand, letters should be brought to 40 Foley Square. The Court does not accept letters by email.
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Page 1 | Communications with Chambers
File ECF letter requesting adjournment with requested date/time and other parties' positions; appearance not adjourned until court grants.
The requesting party must then file a letter to the Court on ECF seeking the adjournment, stating the date and time that is being requested. The letter must include a statement as to the other parties’ positions on the change in date. The appearance is not adjourned unless the parties are thereafter informed by the Court that the written application has been granted.
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Page 2 | Communications with Chambers
Letters to court permitted but must comply with Individual Practices; no copying court on counsel correspondence.
Letters to the Court are permitted. However, the Court will not consider any letter that fails to comply with any applicable requirement contained in these Individual Practices. Parties shall not copy the Court on correspondence sent between counsel or the parties.
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Page 1 | Communications with Chambers
Telephone calls to chambers only permitted in emergency situations.
Except as provided in Paragraph 1.D below, telephone calls to Chambers are permitted only in emergency situations. For any other situation, a party may submit a letter to the Court in accordance with paragraphs 1.A and 1.B above.
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Page 1 | Communications with Chambers
Letters to court permitted but must comply with requirements; no copying court on counsel correspondence.
Letters to the Court are permitted. However, the Court will not consider any letter that fails to comply with any applicable requirement contained in these Individual Practices. Parties shall not copy the Court on correspondence sent between counsel or the parties.
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Page 1 | Communications with Chambers
Call (212) 805-4260 for adjournment date availability.
For information regarding available dates for adjournments as stated in paragraph 1.F below, call Chambers at (212) 805-4260.
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Page 1 | Communications with Chambers
Extension/adjournment requests use “letter motions” ECF category; other letters use “letter” category; no courtesy copies needed for ECF filings.
For any request for an extension or an adjournment (which must comply with paragraphs 1.E and 1.F below), counsel should select the “letter motions” option on ECF. All other letters should be docketed simply as a “letter.” If a letter is filed on ECF, a courtesy copy should not be sent to Chambers.
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Page 1 | Communications with Chambers
Extension/adjournment requests use 'letter motions' ECF category; other letters use 'letter' category; no courtesy copies needed for ECF filings.
For any request for an extension or an adjournment (which must comply with paragraphs 1.E and 1.F below), counsel should select the “letter motions” option on ECF. All other letters should be docketed simply as a “letter.” If a letter is filed on ECF, a courtesy copy should not be sent to Chambers.
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Page 1 | Communications with Chambers
Call chambers at (212) 805-4260 for adjournment date availability.
For information regarding available dates for adjournments as stated in paragraph 1.F below, call Chambers at (212) 805-4260.
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Page 1 | Communications with Chambers
Only attorneys eligible for electronic device orders.
Note that only attorneys are eligible for such an order.
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Page 2 | Communications with Chambers
Discovery conference request letters must use 'Letter' category, not 'Letter Motion' on ECF.
(Do not use the “Letter Motion” category on ECF for such a letter; use instead the “Letter” category.)
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Page 2 | Motions
Contact Deputy Clerk at (212) 805-4260 for available dates, then check other parties' availability before requesting adjournment.
Prior to making such a request, the party intending to make the request should contact the Deputy Clerk ((212) 805-4260), to determine an alternative date for which the Court is available for a rescheduled court appearance. The requesting party should next contact all other parties to determine their availability for that date.
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Page 2 | Communications with Chambers
Electronic device orders require ECF letter (Letter category) filed at least 2 business days before proceeding.
Orders permitting an attorney to bring an electronic device to the Courthouse may be requested by filing a letter on ECF (using the “Letter” category) that attaches a completed form. Any such letter shall be filed at least two business days before the proceeding at issue.
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Page 2 | Communications with Chambers
Junior Lawyer Participation Incentives
Oral argument rarely granted; more likely if junior lawyer (admitted within 5 years) argues.
Judge Gorenstein normally does not hear oral argument on motions. A party may request oral argument by letter. If the Court determines that argument will be heard, it will so advise the parties. (A request for oral argument is more likely to be granted if a party identifies a lawyer to argue the motion who has been admitted within the previous five years and references this paragraph in the letter request.)
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Page 4 | Oral Argument on Motions
Oral argument rarely granted; more likely if lawyer admitted within 5 years argues.
Judge Gorenstein normally does not hear oral argument on motions. A party may request oral argument by letter. If the Court determines that argument will be heard, it will so advise the parties. (A request for oral argument is more likely to be granted if a party identifies a lawyer to argue the motion who has been admitted within the previous five years and references this paragraph in the letter request.)
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