Judge Jeannette A. Vargas
Individual Rules, Standing Orders & Policies
- Rules last changed:
Limits & Logistics
Document Limits
Courtesy Copies
Courtesy copies
Adjournments
- Written requests to reschedule conferences or extend deadlines must include specific required elements
- The deadlines in paragraphs 5(b)–(h) may be extended by written consent of all parties without court application, provided fact discovery is completed by the date in paragraph 5(a).
- A party seeking a limited extension because of an unforeseen circumstance must file an ECF letter-motion before the deadline and explain why discovery could not be completed despite due diligence.
- +4 more
Request must include
- Non-emergency requests to reschedule or extend must be made at least 48 hours in advance
- Unless there is an emergency, extension and adjournment requests must be made as early as possible and at least 48 hours before the deadline or scheduled appearance.
- Except for the extensions allowed in paragraphs 5(i) and 6(e), dates may be modified or extended only by further court order for good cause; a written application must be made at least two business days before the relevant date expires.
Communication
Chambers
Phone
Chambers
Letter via ECF
Chambers
Clerk
Page & Word Limits8 rules
Checked against the court's document on Oct 4, 2026Mandatory
An opposing party that wishes to respond must file a letter of no more than four pages within two business days, unless the Court orders otherwise; reply letters are prohibited.
If the opposing party wishes to respond, it must do so in a letter not to exceed four pages (single spaced, with standard font and margins, inclusive of the signature block) within two business days, unless otherwise ordered by the Court. Reply letters are not permitted.
Opposition
4 pages
Checked against the court's document on Oct 4, 2026Mandatory
Each pretrial memorandum and response is limited to 25 pages.
The pretrial memorandum and response each shall not exceed 25 pages.
Brief
25 pages
Checked against the court's document on Oct 4, 2026Important
If the Court permits a longer brief and states the limit in pages, each additional page may contain no more than 350 additional words when the brief is filed by an attorney or prepared with a computer.
To the extent the court permits a party to submit briefs longer than these limits, and expresses those limits in pages, each additional page must not contain more than 350 additional words if the brief is filed by an attorney or prepared with a computer.
Brief
350 words
Checked against the court's document on Oct 4, 2026Important
Word limits exclude the caption, index, tables of contents and authorities, signature blocks, and required certificates, but include footnotes and endnotes.
These limits do not include the caption, any index, table of contents, table of authorities, signature blocks, or any required certificates, but do include material contained in footnotes or endnotes.
Not confirmed. Read the court's wording below.Mandatory?
Letters may not exceed four pages in length (single-spaced, with standard font and margins, inclusive of signature blocks, but exclusive of exhibits or attachments) without prior permission from the Court.
Summary: Letters are limited to four single-spaced pages, including signature blocks but excluding exhibits and attachments, absent prior Court permission.
Letter
4 pages
Not confirmed. Read the court's wording below.Mandatory?
Unless prior permission has been granted, memoranda of law in support of and in opposition to motions are limited to 8,750 words, and reply memoranda are limited to 3,500 words.
Summary: Unless the Court grants prior permission, supporting and opposition memoranda are limited to 8,750 words and reply memoranda to 3,500 words.
Brief
8,750 words
Reply
3,500 words
Machine summary. Not checked yet.Mandatory?
Unless prior permission has been granted, memoranda of law in support of and in opposition to motions are limited to 25 pages, and reply memoranda are limited to 10 pages.
Summary: Memoranda of law limited to 25 pages, reply memoranda to 10 pages.
25 pages
Applies to: Attorney
Reply Memorandum
10 pages
Applies to: Attorney
Machine summary. Not checked yet.Mandatory?
Unless otherwise ordered by the Court, a defendant’s sentencing submission shall be served two weeks in advance of the date set for sentencing. The Government’s sentencing submission shall be served one week in advance of the date set for sentencing.
Summary: Defendant's sentencing submission due 2 weeks before sentencing; Government's due 1 week before.
Structured details unavailable. See the source text.
Document Format Requirements15 rules
Checked against the court's document on Oct 4, 2026Mandatory
Attorneys complying with the Standing Order may bring mobile phones into the Courtroom, but must keep them turned off at all times.
Attorneys in compliance with the Standing Order may bring mobile phones into the Courtroom, but the phones MUST be kept turned off at all times.
Checked against the court's document on Oct 4, 2026Mandatory
Calculation files supporting proposed damages must be provided in their original format, such as .xlsx.
D. if the proposed damages are supported by calculations, native versions of the files with calculations (i.e., versions of the files in their original format, such as in “.xlsx”), which shall be emailed to Chambers at VargasNYSDChambers@nysd.uscourts.gov;
Checked and corrected to match the court's document on Oct 4, 2026Important
If feasible, submissions should be electronically converted to text-searchable PDF rather than scanned from print.
If feasible, every submission should be in text-searchable format created by converting the document electronically to PDF by computer (that is, not by scanning a printed document).
Checked and corrected to match the court's document on Oct 4, 2026Important
For scanned PDFs, parties should use software to make the document text searchable whenever possible.
If a PDF is created by scanning a printed document (for instance, in the case of a pre-existing documentary exhibit), the party should use software to make the document text searchable whenever possible.
Checked and corrected to match the court's document on Oct 4, 2026Important
Deposition transcripts submitted with a summary judgment motion should be text-searchable and include an index when available.
Deposition transcripts that are supplied in connection with a summary judgment motion, whether in whole or in part, should be text-searchable and include an index where available.
Machine summary. Not checked yet.Mandatory?
At the time of filing, a represented party should e-mail these documents to the Court, in Microsoft Word format.
Summary: Represented parties must email proposed voir dire, jury charge, and verdict form in Word format with Pretrial Statement.
DOCX
We could not find this wording in the court's document. Open the source before relying on it.Mandatory?
The format of all memoranda of law shall comply with Local Rule 7.1, except that all font, including any footnotes, must be in 12-point font or larger.
Machine summary and details
Summary: Memoranda must comply with Local Rule 7.1, and all text, including footnotes, must use at least 12-point font.
Machine summary. Not checked yet.Mandatory?
All memoranda of law shall be in twelve-point font or larger, double spaced, and text-searchable.
Summary: Memoranda of law must be 12-point font or larger, double spaced, and text-searchable.
Machine summary. Not checked yet.Mandatory?
Where submitted in hard copy, exhibits and Section 3500 material should be pre-marked and assembled sequentially in a loose-leaf binder or binders (not to exceed 2 1/2 inches in thickness), or in separate manila folders labeled with the exhibit numbers and placed in redweld folders labeled with the case name and docket number.
Summary: Hard copy exhibits must be pre-marked, sequentially assembled in binders (max 2.5 inches) or manila folders in redweld folders.
Machine summary. Not checked yet.Mandatory?
Attorneys in compliance with the Standing Order may bring mobile phones into the Courtroom, but the phones MUST be kept turned off at all times. Non-compliance with this rule will result in forfeiture of the device for the remainder of the proceedings.
Summary: Mobile phones must be turned off in courtroom; non-compliance results in device forfeiture.
Machine summary. Not checked yet.Mandatory?
The list shall contain six columns labeled as follows: (1) "Exhibit Number"; (2) "Description" (of the exhibit); (3) "Authenticity Objection"; (4) "Admissibility Objection"; (5) "Date Identified"; and (6) "Date Admitted."
Summary: Exhibit list must have 6 specific columns with defined labels.
Machine summary. Not checked yet.Mandatory?
The parties shall complete the first four columns, but leave the fifth and sixth columns blank, to be filled in by the Court during trial.
Summary: First 4 columns of exhibit list must be completed by parties; last 2 left blank for Court.
Machine summary. Not checked yet.Mandatory?
Exhibits must be pre-marked (that is, with exhibit stickers or the like) and should generally be labeled by party and exhibit number (e.g., "GX-1," "PX-1," "DX-1," etc.) rather than letter (e.g., "DX-AA").
Summary: Exhibits must be pre-marked with stickers and labeled by party and number, not letters.
Machine summary. Not checked yet.Note?
At the time of filing, a represented party should e-mail this document to the Court in Microsoft Word format.
Summary: Represented parties should email proposed findings in Microsoft Word format.
DOCX
Machine summary. Not checked yet.Note?
If feasible, every submission should be in text-searchable format created by converting the document electronically to PDF by computer (that is, not by scanning a printed document). If a PDF is created by scanning a printed document (for instance, in the case of a pre-existing documentary exhibit), the party should use software to make the document text searchable whenever possible.
Summary: Submissions should be text-searchable PDFs created electronically, not by scanning
Document Filing Requirements132 rules
Checked against the court's document on Oct 4, 2026Mandatory
Amended or corrected filings must include a redline showing all differences from the original.
Any amended or corrected filing shall be filed with a redline showing all differences between the original and revised filing.
Document Type
Amended Or Corrected Filing
Checked against the court's document on Oct 4, 2026Mandatory
After a case is accepted as related, future papers and correspondence must identify both docket numbers.
After an action has been accepted as related to a prior filing, all future court papers and correspondence must contain the docket number of the new filing as well as the docket number of the case to which it is related (e.g., 22-CV-1234 [rel. 21-CV-4321]).
Document Type
Future Court Papers And Correspondence
Checked against the court's document on Oct 4, 2026Mandatory
Memoranda of at least 10 pages must include a table of contents and table of authorities, which do not count toward the word limit.
Memoranda of 10 pages or more shall contain a table of contents and a table of authorities, neither of which shall count against the word limit.
Document Type
Memorandum
Checked against the court's document on Oct 4, 2026Mandatory
A brief filed by an attorney or prepared with a computer must include a certificate stating compliance with the word limits and the document’s word count; the certifier may rely on the word-processing program’s count.
If a brief is filed by an attorney or prepared with a computer, it must include a certificate by the attorney, or party who is not represented by an attorney, that the document complies with the word-count limitations. The person preparing the certificate may rely on the word count of the word-processing program used to prepare the document. The certificate must state the number of words in the document.
Document Type
Brief
Checked against the court's document on Oct 4, 2026Mandatory
An opposing party must reproduce each entry of the moving party’s Rule 56.1 Statement and place its response directly beneath the entry.
Opposing parties must reproduce each entry in the moving party’s Rule 56.1 Statement and set out the opposing party’s response directly beneath it.
Document Type
Rule 56 1 Opposition Statement
Checked against the court's document on Oct 4, 2026Mandatory
Each memorandum of law must include a statement of facts and may not incorporate the entirety of a Rule 56.1 Statement by reference.
Each memorandum of law must include a statement of facts and may not simply incorporate by reference the entirety of a party’s Rule 56.1 Statement.
Document Type
Memorandum Of Law
Checked against the court's document on Oct 4, 2026Mandatory
A motion to amend a pleading must include a redline showing all differences between the operative and proposed amended pleadings.
When moving to amend any pleading, the moving party shall file with the motion a redline showing all differences between the operative pleading and the proposed amended pleading.
Document Type
Motion To Amend
Checked against the court's document on Oct 4, 2026Mandatory
Each factual assertion in a Rule 56.1 Statement must cite the relied-upon portions of the evidentiary record.
Each factual assertion in Rule 56.1 Statements must be followed by a citation to the portion(s) of the evidentiary record relied upon.
Document Type
Rule 56 1 Statement
Checked against the court's document on Oct 4, 2026Mandatory
A party seeking entry of a protective order must file an ECF letter certifying adoption of the Model Protective Order without alteration or explaining the reasons for alterations.
Additionally, the party or parties seeking entry of the protective order must file a letter on ECF either a) certifying that the parties have adopted, without alteration, the Court’s Model Protective Order, or b) if alterations were made, explaining the reasons for such alterations.
Document Type
Protective Order Letter
Checked against the court's document on Oct 4, 2026Mandatory
A party seeking a protective order must submit a proposed order that conforms as closely as possible to the Court’s Model Protective Order.
Any party seeking a protective order must submit a proposed protective order that conforms as closely as possible to the Court’s Model Protective Order, which is available on the Court’s public webpage at https://www.nysd.uscourts.gov/hon-jeannette-vargas.
Document Type
Proposed Protective Order
Checked and corrected to match the court's document on Oct 4, 2026Mandatory
The initial discovery letter-motion must provide details of each conference, identify participating attorneys, and state that impasse and anticipated court relief were communicated during the last conference.
The initial letter-motion must state: (1) the date(s), time(s), and duration of each meet-and- confer conference; (2) the names of the attorneys who participated; and (3) that the moving party informed the adversary during the last conference that the moving party believed the parties to be at an impasse and that the moving party would be requesting relief from the Court.
Document Type
Letter Motion
Checked against the court's document on Oct 4, 2026Mandatory
The parties must file a joint status letter two weeks after fact discovery closes, unless the Court orders another time, addressing the case status, settlement discussion, and consent to mediation or a magistrate judge settlement conference.
Two weeks following the close of fact discovery, or at a time otherwise ordered by the Court, the parties shall file a joint letter updating the Court on the status of the case, including but not limited to confirming that the one-hour settlement discussion occurred and stating whether all parties consent to mediation or a settlement conference to be held before the designated Magistrate Judge.
Document Type
Joint Status Letter
Checked against the court's document on Oct 4, 2026Mandatory
In a case without expert discovery, the letter must identify anticipated dispositive motions and, if applicable, propose a briefing schedule.
In a case without expert discovery, the letter shall notify the Court if any party anticipates filing a dispositive motion, and if so, set forth a proposed briefing schedule for any such motion(s).
Document Type
Joint Status Letter
Checked against the court's document on Oct 4, 2026Mandatory
The joint pretrial order must include the information required by Rule 26(a)(3) and the items enumerated by the Court.
The joint pretrial order shall include the information required by Fed. R. Civ. P. 26(a)(3) and the following:
Document Type
Joint Pretrial Order
Checked against the court's document on Oct 4, 2026Mandatory
When the parties conduct expert discovery, counsel must file a joint status letter within one week after expert discovery closes, unless the Court orders another time.
In cases in which the parties conduct expert discovery, no later than one week after the close of expert discovery, or at a time otherwise ordered by the Court, counsel for all parties must file a joint status letter.
Document Type
Joint Status Letter
Checked against the court's document on Oct 4, 2026Mandatory
Each party must file one memorandum of law supporting all of that party’s motions in limine, consistent with Rule 5(A).
Each party must file a single memorandum of law, consistent with Rule 5(A) above, in support of all motions in limine filed by that party.
Document Type
Motion In Limine
Checked against the court's document on Oct 4, 2026Mandatory
The parties must submit their joint, case-specific proposed voir dire questions in a single document.
The parties shall submit in a single document a set of joint case-specific proposed voir dire questions.
Document Type
Voir Dire Questions
Checked against the court's document on Oct 4, 2026Mandatory
A motion in limine must state that the meet-and-confer process occurred and was unsuccessful.
Any motion in limine must include a representation that the meet and-confer process occurred and was unsuccessful.
Document Type
Motion In Limine
Checked against the court's document on Oct 4, 2026Mandatory
The parties must submit one joint proposed verdict form that notes disagreements and, where applicable, cites authority supporting each party’s position.
The parties shall submit in a single document a joint proposed verdict form, noting any areas of disagreement between the parties and, if applicable, citing supporting authority in support of the parties’ respective positions.
Document Type
Verdict Form
Checked against the court's document on Oct 4, 2026Mandatory
Proposed findings of fact must be detailed and cite anticipated trial testimony and exhibits.
The proposed findings of fact must be detailed and include citations to the anticipated trial testimony and exhibits.
Document Type
Proposed Findings Conclusions
Checked against the court's document on Oct 4, 2026Mandatory
The parties must submit their joint request to charge in a single document.
The parties shall submit in a single document a joint request to charge.
Document Type
Jury Instructions
Checked against the court's document on Oct 4, 2026Mandatory
Disputed jury-instruction language must be highlighted or readily identifiable in track changes.
For any proposed request to charge on which the parties cannot agree, the disputed language must be highlighted or readily identifiable in track changes.
Document Type
Jury Instructions
Checked against the court's document on Oct 4, 2026Mandatory
To have the Court retain jurisdiction to enforce a settlement agreement, the parties must place its terms on the public record.
If the parties wish that the Court retain jurisdiction to enforce a settlement agreement, the parties must place the terms of their agreement on the public record.
Document Type
Settlement Agreement
Checked against the court's document on Oct 4, 2026Mandatory
The letter-motion must explain why sealing or redaction is justified under the standards in Section 10(C).
The letter-motion must explain why sealing or redaction is justified in light of the standards discussed in Section 10(C) above.
Document Type
Letter Motion
Checked against the court's document on Oct 4, 2026Mandatory
A default-judgment motion must include an attorney affidavit or declaration under Local Civil Rule 55.2(a)(1).
A. an attorney’s affidavit or declaration pursuant to Local Civil Rule 55.2(a)(1);
Document Type
Motion
Checked against the court's document on Oct 4, 2026Mandatory
A default-judgment request must include a certificate stating that all supporting documents were personally served on or mailed to the party against whom judgment is sought.
H. a certificate of service stating that all documents in support of the request for default judgment have been personally served on or mailed to the party against whom default judgment is sought, pursuant to Local Civil Rule 55.2(a)(3).
Document Type
Default Judgment
Checked against the court's document on Oct 4, 2026Important
Parties should not submit proposed stipulations or orders that purport to extend deadlines.
Parties should not submit proposed stipulations or proposed orders purporting to extend deadlines.
Document Type
Proposed Stipulation Or Order
Checked against the court's document on Oct 4, 2026Important
Requests for adjournments, extensions, and pre-motion conferences, including those concerning discovery disputes, should be filed as letter-motions.
In particular, all requests for adjournments, extensions, and pre-motion conferences (including pre-motion conferences with respect to discovery disputes) should be filed as letter-motions.
Document Type
Request
Checked against the court's document on Oct 4, 2026Important
If the non-moving party elects not to amend, the motion proceeds normally and the Court is unlikely to provide another opportunity to amend in response to deficiencies apparent from the fully briefed motion.
If the non-moving party elects not to file an amended pleading, the motion will proceed in the regular course, and the Court is unlikely to grant the non-moving party a further opportunity to amend to address the purported deficiencies made apparent by the fully briefed arguments in the moving party’s motion.
Document Type
Pleading
Checked against the court's document on Oct 4, 2026Important
Factual assertions in memoranda of law should cite underlying record evidence, not the Rule 56.1 Statement.
Moreover, all factual assertions in memoranda of law should be supported by citations to the underlying record evidence, not to the Rule 56.1 Statement.
Document Type
Memorandum Of Law
Checked against the court's document on Oct 4, 2026Important
If a proposed protective order deviates from the Model Protective Order, the parties should attach a blackline showing all changes to the letter.
If the proposed protective order does deviate from the Model Protective Order, the parties should include as an attachment to the letter a blackline showing all changes.
Document Type
Protective Order Letter
Checked against the court's document on Oct 4, 2026Important
The joint status letter should not identify any party that declined to consent.
The letter should not identify any party that has declined to consent.
Document Type
Joint Status Letter
Checked against the court's document on Oct 4, 2026Important
For disputed voir dire questions, each party should clearly state its proposed question and briefly explain why the Court should use it.
For any disputes, each party should clearly set forth its proposed question and briefly state why the Court should use it.
Document Type
Voir Dire Questions
Checked and corrected to match the court's document on Oct 4, 2026Important
Unless good cause exists, proposed voir dire questions should be limited to questions unique to the facts of the case.
Absent ===== PAGE 14 ===== good cause, proposed voir dire questions should include only those questions unique to the facts of the case being tried.
Document Type
Voir Dire Questions
Checked against the court's document on Oct 4, 2026Important
The parties should include a list of standard instructions they believe are appropriate for the Court to give.
The parties should, however, include a list of standard instructions that they believe are appropriate for the Court to give in the case.
Document Type
Jury Instructions
Checked against the court's document on Oct 4, 2026Important
Unless good cause exists, parties should omit proposed language for standard instructions because the Court is likely to use its own.
Absent good cause, the parties should not include proposed language for standard instructions (about, for example, the role of the Court and the jury, the standard of proof, what is evidence, etc.), as the Court is likely to use its own standard instructions.
Document Type
Jury Instructions
Checked against the court's document on Oct 4, 2026Important
The Court will not retain jurisdiction to enforce confidential settlement agreements.
Document Type
Settlement Agreement
Checked against the court's document on Oct 4, 2026Important
Each proposed jury instruction should cite its supporting authority.
Each proposed request to charge should cite to the supporting authority from which it is derived.
Document Type
Jury Instructions
Checked against the court's document on Oct 4, 2026Important
The required order must be shown when the equipment is brought into the Courthouse.
The Order must be shown upon bringing the equipment into the Courthouse.
Document Type
Court Order
Checked against the court's document on Oct 4, 2026Important
Unless the Court orders otherwise, letter-motions seeking leave to file differently must comply with Section 3(A).
Unless otherwise ordered by the Court, letter-motions seeking leave to file in a different manner shall comply with Section 3(A).
Document Type
Letter Motion
Checked against the court's document on Oct 4, 2026Important
If the party seeks to seal or redact the letter-motion itself, it should say so and provide the justification.
If the party believes that the letter-motion itself should be sealed or redacted, the letter-motion should so state and should provide the justification therefor.
Document Type
Letter Motion
Checked against the court's document on Oct 4, 2026Note
A party may request oral argument by placing “ORAL ARGUMENT REQUESTED” on the memorandum’s cover page.
A party may request oral argument by indicating “ORAL ARGUMENT REQUESTED” on the cover page of its memorandum of law.
Document Type
Memorandum
Checked and corrected to match the court's document on Oct 4, 2026Note
A party may file a short letter, not a letter-motion, explaining why oral argument would benefit the Court when the reason is not apparent from the briefing.
If a party believes that the Court would benefit from oral argument for a particular reason not obvious from the parties’ briefing, the party may file a short letter—not a letter- motion—explaining the reason(s).
Document Type
Letter
Checked against the court's document on Oct 4, 2026Note
The Court disfavors modifications to its Model Protective Order.
The Court disfavors modifications to the Court’s Model Protective Order.
Document Type
Proposed Protective Order
The quote is in the court's document. The summary is not checked yet.Mandatory?
Prior to any appearance before, or application made to, Judge Vargas in any civil matter in which the United States Attorney or an attorney from the U.S. Department of Justice represents a party—or in any event, no later than ten (10) calendar days from the assignment of any such matter to Judge Vargas—the Government attorney handling the matter shall file a letter on the docket indicating whether, based on the records of the U.S. Attorney's Office, the matter falls within the recusal parameters set forth above.
Summary: Government attorneys must file a docket letter indicating whether the matter falls within the recusal parameters before any appearance or application before Judge Vargas, or no later than 10 calendar days from assignment.
Document Type
Letter
Machine summary. Not checked yet.Mandatory?
Pro se parties are required to maintain their current mailing address on the docket at all times and must notify the Court of any change of address by filing a change of address form with the Pro Se Office.
Summary: Pro se parties must keep current address on docket and notify Pro Se Office of changes
Document Type
Change Of Address
Machine summary. Not checked yet.Mandatory?
Absent a pro se party consenting to receipt of electronic service, counsel in pro se cases must serve a pro se party with a paper copy of any document that is filed electronically and must file with the Court a separate Affidavit of Service. Submissions filed without proof of service that the pro se party was served will not be considered.
Summary: Paper service required for pro se parties unless they consent to electronic service, with affidavit of service.
Document Type
All
Filing & Service rules
Electronic Filing Rules
A request for a limited extension based on unforeseen circumstances must be made by letter-motion filed on ECF.
If something unforeseen arises, a party may seek a limited extension of the foregoing deadlines by letter-motion filed on ECF.
Checked against the court's document on Oct 4, 2026 · Civil cases
Page 3 | Fact Discovery
Adjournment and extension requests must be written and filed on ECF as letter-motions, not ordinary letters.
All requests for adjournments or extensions of time must be made in writing and filed on ECF as letter-motions, not as ordinary letters.
Checked against the court's document on Oct 4, 2026 · Civil cases
Page 3 | Requests for Adjournment or Extension of Time
Proposed orders to show cause, temporary restraining orders, stipulations, consent orders, and proposed judgments are to be filed electronically on ECF under the applicable instructions.
Proposed orders to show cause, temporary restraining orders, stipulations, consent orders and proposed judgments are to be filed electronically on ECF as explained in the SDNY Electronic Case Filing Rules and Instructions.
Checked against the court's document on Oct 4, 2026 · Civil cases
Page 6 | Proposed Orders and Stipulations
The proposed protective order must be filed on ECF in accordance with Rule 13.18 of the SDNY ECF Rules and Instructions.
The proposed protective order must be filed on ECF in accordance with Rule 13.18 of the SDNY ECF Rules and Instructions.
Checked against the court's document on Oct 4, 2026 · Civil cases
Page 8 | Protective Order
A request to stay discovery must be made in writing and filed on ECF as a letter-motion, not an ordinary letter.
If a party nonetheless seeks a stay of discovery, such request must be made in writing and filed on ECF as a letter-motion, not an ordinary letter.
Checked against the court's document on Oct 4, 2026 · Civil cases
Page 9 | 6. Discovery; A. Stay of Discovery
All counsel must promptly file a notice of appearance on ECF after removal.
Counsel for all parties must file on ECF a notice of appearance in this Court promptly upon removal.
Checked against the court's document on Oct 4, 2026 · Civil cases
Page 11
Unless the Court specifies otherwise, the parties must file a joint pretrial order on ECF within 30 days after discovery closes, or, if a dispositive motion is filed, within 30 days after the Court decides that motion.
Unless otherwise specified by the Court, within thirty (30) days after the close of discovery or if any dispositive motion is filed, within thirty (30) days from the Court’s decision on such motion, the parties shall file on ECF a joint pretrial order.
Checked against the court's document on Oct 4, 2026 · Civil cases
Page 11 | F. Joint Pretrial Order
Highlighted deposition transcripts must not be filed on ECF.
The highlighted deposition transcripts should not be filed on ECF.
Checked against the court's document on Oct 4, 2026 · Civil cases
Page 13 | Deposition Designations
As soon as the parties reach a settlement in principle, they must file a joint letter through ECF notifying the Court.
As soon as the parties reach an agreement to settle in principle, the parties must file a joint letter via ECF notifying the Court.
Checked against the court's document on Oct 4, 2026 · Civil cases
Page 14 | Settlements
A party seeking leave to file a document under seal must electronically file a letter motion on ECF.
The party shall electronically file a letter motion seeking leave to file a document under seal on ECF in accordance with Standing Order 19-MC-583 and Section 6 of the S.D.N.Y. Electronic Case Filing Rules and Instructions.
Checked against the court's document on Oct 4, 2026 · Civil cases
Page 16 | 10. Redactions and Filing Under Seal
A party seeking leave to file a redacted document must file a letter motion on ECF.
Where a party seeks leave to file a document in redacted form, the party shall file a letter motion seeking leave to file a document in redacted form on ECF in accordance with Standing Order 19-MC-583 and Section 6 of the S.D.N.Y. Electronic Case Filing Rules and Instructions.
Checked against the court's document on Oct 4, 2026 · Civil cases
Page 16 | 10. Redactions and Filing Under Seal
A party unable to e-file under seal or seeking not to e-file a document must request leave to file differently by email letter-motion.
Any party unable to comply with the requirement for electronic filing under seal on ECF, or who believes that a particular document should not be electronically filed at all, shall file a letter-motion by email, seeking leave of the Court to file in a different manner.
Checked against the court's document on Oct 4, 2026 · Civil cases
Page 17 | Submission by Email
A default-judgment motion must be filed on ECF only after the Clerk’s Certificate of Default has been obtained.
Only after obtaining a Clerk’s Certificate of Default should the party proceed to file a motion for default judgment on ECF pursuant to Federal Rule of Civil Procedure 55(b)(2) and Local Civil Rule 55.2.
Checked against the court's document on Oct 4, 2026 · Civil cases
Page 18 | Attachment A—Default Judgment Procedure
When permitted by the applicable S.D.N.Y. rules, letters seeking relief should be filed on ECF as letter-motions rather than ordinary letters.
When permitted by the S.D.N.Y. Local Rules and the S.D.N.Y. Electronic Case Filing Rules and Instructions, letters seeking relief should be filed on ECF as letter-motions, not as ordinary letters.
Checked against the court's document on Oct 4, 2026 · Civil cases
Page 5 | Motions and Specific Types of Filings — B. Letter-Motions
The TRO moving party should file the motion, supporting documents, and a proposed order on ECF in accordance with ECF procedures.
The moving party should then file a Motion for a Temporary Restraining Order, supporting documents and a proposed order on ECF in accordance with ECF procedures.
Checked against the court's document on Oct 4, 2026 · Civil cases
Page 8 | Applications for a Temporary Restraining Order
Unless otherwise expressly provided, all documents filed with the Court must be filed electronically.
In accordance with the S.D.N.Y. Electronic Case Filing Rules and Instructions, except as otherwise expressly provided, all documents filed with the Court must be filed electronically.
Not confirmed. Read the court's wording below. · Civil cases
Page 1 | Guidelines for All Submissions
Plaintiffs must ensure that a copy of the operative complaint is posted electronically to the ECF docket.
Plaintiffs shall ensure that a copy of the operative complaint is posted electronically to the docket on the ECF system.
Not confirmed. Read the court's wording below. · Civil cases
Page 10 | 8. Pre-Trial Procedures and Filings; B. Cases Removed from State Court
The proposed sealed document must be filed separately and contemporaneously under seal on ECF, with the appropriate restriction level, and electronically related to the motion or prior court order granting leave.
The proposed sealed document shall be separately and contemporaneously filed under seal on ECF (with the appropriate level of restriction) and electronically related to the motion (or to the relevant Court order if the Court previously granted leave to file the document under seal).
Not confirmed. Read the court's wording below. · Civil cases
Page 16 | 10. Redactions and Filing Under Seal
A party may file a pretrial memorandum of law when the joint pretrial order is filed if the party believes it would be useful to the Court.
At the time the joint pretrial order is filed, a party may file a pretrial memorandum of law if it believes it would be useful to the Court.
Not confirmed. Read the court's wording below. · Civil cases
Page 13 | Pretrial Memoranda of Law
Filing Timing and Cure Windows
A proposed order or stipulation regarding electronically stored information must be filed within 30 days of the order’s date.
Any proposed order or stipulation regarding electronically stored information shall be filed within 30 days of the date of this Order.
Checked against the court's document on Oct 4, 2026 · Civil cases
Page 3 | Civil Case Management Plan and Scheduling Order
Unless the Court orders otherwise, the joint pretrial order and Rule 8(F)–(I) submissions are due 30 days after all discovery closes, or 30 days after a decision on a filed dispositive motion.
Unless otherwise ordered by the Court, the joint pretrial order and additional submissions required by Rule 8(F)-(I) of the Court’s Individual Rules and Practices in Civil Cases shall be ===== PAGE 4 ===== due 30 days from the close of all discovery, or, if a dispositive motion has been filed, within 30 days of a decision on such motion.
Checked and corrected to match the court's document on Oct 4, 2026 · Civil cases
Page 3 | Post-Discovery Status Letters and Pretrial Submissions
An opposition to a letter must be filed within three business days after the letter motion is filed.
Any opposition to letters must be filed within three (3) business days of the filing party’s letter motion.
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Page 2 | Communications with Chambers
Within 10 days after a motion to dismiss is filed, the non-moving party must tell the Court whether it will amend its pleading or rely on the challenged pleading.
Upon the filing of a motion to dismiss, the non-moving party is required, within 10 days, to notify the Court whether it intends to file an amended pleading or rely on the pleading being attacked.
Checked and corrected to match the court's document on Oct 4, 2026 · Civil cases
Page 6 | Motion to Dismiss
Within 21 days after the non-moving party amends its pleading, the moving party may answer, file a new motion to dismiss, or notify the Court it will rely on its original motion.
If the non-moving party amends its pleading, within 21 days of such amendment, the moving party may file an answer, file a new motion to dismiss, or notify the Court that it will rely on the initially-filed motion to dismiss.
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Page 6 | Motion to Dismiss
Unless the Court orders otherwise, expert-exclusion motions under F.R.E. 702–705 and Daubert must be made by the dispositive-motion deadline and should not be treated as motions in limine.
Unless the Court orders otherwise, motions to exclude the testimony of experts, pursuant to F.R.E. 702– 705 and the Daubert v. Merrell Dow Pharmaceuticals, Inc., 509 U.S. 579 (1993), line of cases must be made by the deadline for dispositive motions and should not be treated as motions in limine.
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Page 8 | Exclude Testimony of Experts
Counsel for the removing party must file the state-court docket sheet within three calendar days after filing the notice of removal.
Counsel for the party or parties that removed the case must follow 28 U.S.C. § 1446(a) and file a copy of the state court docket sheet within three calendar days of filing the notice of removal.
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Page 10 | 8. Pre-Trial Procedures and Filings; B. Cases Removed from State Court
A response or opposition to a pretrial memorandum of law is due two weeks after the opening memorandum is filed.
Any response or opposition to a pretrial memorandum of law shall be due two weeks after the filing of the opening memorandum.
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Page 13 | Pretrial Memoranda of Law
Motion papers must be filed promptly after they are served.
Motion papers must be filed promptly after service.
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Page 5 | Motions and Specific Types of Filings — D. Filing of Motion Papers
If a motion remains undecided 60 days after it is fully briefed, the movant’s counsel must send the Court an alert letter.
If a motion is not decided within 60 days of the date that it was fully briefed, counsel for the movant shall send a letter to alert the Court.
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Page 6 | Failure of the Court to Schedule Argument or Decide a Motion
Counsel should obtain the Clerk’s Certificate of Default well before any court-imposed deadline for the default-judgment motion.
(Counsel should therefore seek and obtain a Clerk’s Certificate of Default well in advance of any Court-imposed deadline to move for default judgment.)
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Page 18 | Attachment A—Default Judgment Procedure
The motion-to-dismiss procedure does not change the deadline for responding to the motion.
This provision does not alter the time to file a response to the motion to dismiss.
Checked and corrected to match the court's document on Oct 4, 2026 · Civil cases
Page 6 | Motion to Dismiss
The recusal letter must be filed before any appearance before or application made to Judge Vargas, and in any event no later than 10 calendar days from assignment of the matter.
Prior to any appearance before, or application made to, Judge Vargas in any civil matter in which the United States Attorney or an attorney from the U.S. Department of Justice represents a party—or in any event, no later than ten (10) calendar days from the assignment of any such matter to Judge Vargas—the Government attorney handling the matter shall file a letter on the docket indicating whether, based on the records of the U.S. Attorney's Office, the matter falls within the recusal parameters set forth above.
The quote is in the court's document. The summary is not checked yet. · Civil cases
Page 1 | Individual Rules and Practices Regarding Civil Matters in which the United States Attorney for the Southern District of New York or the United States Department of Justice Represents a Party
Any proposed order or stipulation regarding electronically stored information must be filed within 30 days of the Order.
Any proposed order or stipulation regarding electronically stored information shall be filed within 30 days of the date of this Order.
Not confirmed. Read the court's wording below. · Civil cases
Page 2 | Fact Discovery
If applicable, the parties must submit a post-discovery joint status letter one week after expert discovery closes.
[If applicable] By _____________ [one week after the close of expert discovery], the parties shall submit a post-discovery joint status letter, as outlined in Section 8(e) of the Court’s Individual Rules and Practices in Civil Cases.
Not confirmed. Read the court's wording below. · Civil cases
Page 3 | Post-Discovery Status Letters and Pretrial Submissions
The parties must submit a post-fact-discovery joint status letter two weeks after fact discovery closes.
By _____________ [two weeks after the close of fact discovery], the parties shall submit a post-fact discovery joint status letter, as outlined in Section 8(d) of the Court’s Individual Rules and Practices in Civil Cases.
Not confirmed. Read the court's wording below. · Civil cases
Page 3 | Post-Discovery Status Letters and Pretrial Submissions
The parties must jointly file the specified jury-case pretrial documents on ECF and email Microsoft Word versions to Chambers no later than two weeks before trial.
No later than two weeks before trial, the parties shall jointly file on ECF and submit by email to VargasNYSDChambers@nysd.uscourts.gov a Microsoft Word version of the following documents:
Not confirmed. Read the court's wording below. · Civil cases
Page 13 | Additional Required Pretrial Filings in Jury Cases
Service and Proof of Service Rules
When the joint pretrial order is filed, the parties must file and serve motions on evidentiary issues or other matters that should be resolved in limine.
At the time the joint pretrial order is filed, the parties shall file and serve motions addressing any evidentiary issues or other matters which should be resolved in limine.
Checked and corrected to match the court's document on Oct 4, 2026 · Civil cases
Page 13 | Motions in Limine
In a non-jury case, each party must file and serve proposed findings of fact and conclusions of law when the joint pretrial order is filed.
At the time the joint pretrial order is filed in a non-jury case, each party shall file and serve proposed findings of fact and conclusions of law.
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Page 14 | Additional Required Pretrial Filings in Non-Jury Cases
Copies of the letter-motion must be delivered to all counsel simultaneously with the email submission.
Such letter-motions may be emailed to VargasNYSDChambers@nysd.uscourts.gov as text-searchable PDF attachments, with copies simultaneously delivered to all counsel.
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Page 17 | Submission by Email
All documents supporting a default-judgment request must be personally served on or mailed to the party against whom default judgment is sought.
H. a certificate of service stating that all documents in support of the request for default judgment have been personally served on or mailed to the party against whom default judgment is sought, pursuant to Local Civil Rule 55.2(a)(3).
Checked and corrected to match the court's document on Oct 4, 2026 · Civil cases
Page 19
Initial Rule 34 document requests must be served by the deadline set in the order, ordinarily no more than 30 days after the Initial Pretrial Conference absent exceptional circumstances.
Initial requests for production of documents pursuant to Fed. R. Civ. P. 34 shall be served no later than ___________________. [Absent exceptional circumstances, a date not more than 30 days following the Initial Pretrial Conference.]
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Page 2 | Fact Discovery
A counseled party moving for summary judgment must provide all other parties an electronic copy of its Rule 56.1 Statement in a standard word processing format.
Any party represented by counsel that moves for summary judgment shall provide all other parties with an electronic copy, in a standard word processing format, of the moving party’s Statement of Material Facts Pursuant to Local Civil Rule 56.1 (“Rule 56.1 Statement”).
Not confirmed. Read the court's wording below. · Civil cases
Page 7 | Summary Judgment
Initial interrogatories under Local Rule 33.3(a) must be served by the deadline set in the order, ordinarily no more than 30 days after the Initial Pretrial Conference absent exceptional circumstances.
Interrogatories pursuant to Local Rule 33.3(a) shall be served no later than ___________________. [Absent exceptional circumstances, a date not more than 30 days following the Initial Pretrial Conference.]
Not confirmed. Read the court's wording below. · Civil cases
Page 2 | Fact Discovery
For a TRO motion made on notice, the moving party should simultaneously serve the documents on any party who will not receive ECF electronic service.
Where the motion is made on notice to the other parties, the moving party should simultaneously serve the documents on any party that will not receive electronic service via ECF.
Not confirmed. Read the court's wording below. · Civil cases
Page 8 | Applications for a Temporary Restraining Order
Courtesy Copy Requirements
Parties should not submit courtesy copies unless the Court orders otherwise.
Unless the Court orders otherwise, parties should not submit courtesy copies of any submissions.
Checked and corrected to match the court's document on Oct 4, 2026 · Civil cases
Page 2 | Guidelines for All Submissions
Email documents to chambers simultaneously with ECF filing.
At the same time, the party should email to
Machine summary. Not checked yet. · Criminal cases
Page 8 | 10. Redactions and Filing Under Seal - D. Procedures for Filing Documents with Redactions
Sealing & Redaction Procedures
Redactions beyond those permitted by Rule 5.2 require individual court approval and must be narrowly tailored; party consent or a confidentiality agreement alone is insufficient.
C. Redactions and Sealed Filings Requiring Court Approval. All redactions other than those under Federal Rule of Civil Procedure 5.2 require Court approval. The Court will review each proposed redaction individually. To be approved, redactions must be narrowly tailored to serve whatever purpose justifies them and otherwise consistent with the presumption in favor of public access to judicial documents. See, e.g., Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110, 119–20 (2d Cir. 2006). In general, the parties’ consent or the fact that information is subject to a confidentiality agreement (or protective order) between litigants is not, by itself, a valid basis to overcome the presumption in favor of public access to judicial documents.
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Page 15 | 10. Redactions and Filing Under Seal
A party seeking sealing or redaction should meet and confer; when confidentiality is requested by another party or a third party, that requester must be notified to file an explanatory letter within three business days. The required letter motion and proposed sealed or redacted documents must be filed and linked on ECF as specified.
Any party seeking to file a document under seal or in redacted form shall proceed as follows: i. Meet and Confer. The party seeking leave to file sealed or redacted materials should meet and confer with any opposing party (or any third party seeking confidential treatment of the information) in advance to narrow the scope of the request. When a party seeks leave to file a document under seal or in redacted form on the ground that an opposing party or third party has requested it, the filing party shall notify the opposing party or third party that it must file, within three business days, a letter explaining the need to seal or redact the document. ii. Sealed Document(s). The party shall electronically file a letter motion seeking leave to file a document under seal on ECF in accordance with Standing Order 19-MC-583 and Section 6 of the S.D.N.Y. Electronic Case Filing Rules and Instructions. The letter motion itself shall be filed in public view, should explain the reasons for seeking to file the document under seal, and should not include confidential information. The proposed sealed document shall be separately and contemporaneously filed under seal on ECF (with the appropriate level of restriction) and electronically related to the motion (or to the relevant Court order if the Court previously granted leave to file the document under seal). Note that the summary docket text, but not the document itself, will be open to public inspection and, thus, the summary docket text should not include confidential information sought to be filed under seal. iii. Redacted Document(s). Where a party seeks leave to file a document in redacted form, the party shall file a letter motion seeking leave to file a document in redacted form on ECF in accordance with Standing Order 19-MC-583 and Section 6 of the S.D.N.Y. Electronic Case Filing Rules and Instructions. The letter motion itself shall be filed in public view, should explain the reasons for seeking to file the document in redacted form, and should not include confidential information. At the same time, the party shall (1) publicly file on ECF and electronically relate to the letter motion a copy of the document with the proposed redactions; and (2) file under seal on ECF (with the appropriate level of restriction) and electronically relate to the motion an unredacted copy of the document with the proposed redactions highlighted.
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Page 16 | 10. Redactions and Filing Under Seal
When seeking leave to file a redacted document, the party must simultaneously file the proposed-redaction version publicly and an unredacted version under seal on ECF, electronically relating each to the letter motion.
At the same time, the party shall (1) publicly file on ECF and electronically relate to the letter motion a copy of the document with the proposed redactions; and (2) file under seal on ECF (with the appropriate level of restriction) and electronically relate to the motion an unredacted copy of the document with the proposed redactions highlighted.
Checked and corrected to match the court's document on Oct 4, 2026 · Civil cases
Page 16 | 10. Redactions and Filing Under Seal
Parties may redact the specified sensitive information and information requiring caution without court approval.
B. Redactions Not Requiring Court Approval. Without Court approval, parties may redact the five categories of “sensitive information” and the six categories of information requiring caution (i.e., personal identifying number, medical records, treatment and diagnosis, employment history, individual financial information, proprietary or trade secret information and information regarding an individual’s cooperation with the government), as described in the Privacy Policy.
Checked and corrected to match the court's document on Oct 4, 2026 · Civil cases
Page 15 | 10. Redactions and Filing Under Seal
Sensitive personal information must be redacted unless relevant to the case.
Unless relevant to the case, parties must not include in submissions to the Court (1) social security numbers; (2) names of minor children; (3) dates of birth; (4) financial account numbers; or (5) home addresses. Pro se parties wishing to file a document already containing this information must submit a redacted version to the Pro Se Office.
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Redactions must be narrowly tailored and consistent with public access presumption.
To be approved, redactions must be narrowly tailored to serve whatever purpose justifies them and otherwise consistent with the presumption in favor of public access to judicial documents.
Machine summary. Not checked yet. · Criminal cases
Page 8 | 10. Redactions and Filing Under Seal - C. Redactions and Sealed Filings Requiring Court Approval
Court reviews each proposed redaction individually.
The Court will review each proposed redaction individually.
Machine summary. Not checked yet. · Criminal cases
Page 8 | 10. Redactions and Filing Under Seal - C. Redactions and Sealed Filings Requiring Court Approval
All redactions or sealing of public court filings require Court approval except for permitted categories.
Except for redactions permitted by the previous Paragraph, all redactions or sealing of public court filings require Court approval.
Machine summary. Not checked yet. · Criminal cases
Page 8 | 10. Redactions and Filing Under Seal - C. Redactions and Sealed Filings Requiring Court Approval
Parties' consent or confidentiality agreements alone don't justify sealing.
In general, the parties’ consent or the fact that information is subject to a confidentiality agreement (or protective order) between litigants is not, by itself, a valid basis to overcome the presumption in favor of public access to judicial documents.
Machine summary. Not checked yet. · Criminal cases
Page 8 | 10. Redactions and Filing Under Seal - C. Redactions and Sealed Filings Requiring Court Approval
Parties must avoid including sensitive information unless necessary in submissions.
The parties are referred to the E-Government Act of 2002 and the Southern District’s ECF Privacy Policy (“Privacy Policy”). The parties should not include, unless necessary, the five categories of “sensitive information” in their submissions (i.e., social security numbers, names of minor children [use the initials only], dates of birth [use the year only], financial account numbers and home addresses [use only the City and State]).
Machine summary. Not checked yet. · Criminal cases
Page 8 | 10. Redactions and Filing Under Seal - A. Privacy Policy
File redacted document version on ECF.
The party should file the redacted version of the document on ECF.
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Page 8 | 10. Redactions and Filing Under Seal - D. Procedures for Filing Documents with Redactions
File letter-motion seeking leave to redact if redactions require Court approval.
If the party is seeking leave of the Court to redact the document (i.e., if the redactions are not among the categories of redactions that can be made without Court approval), the party should simultaneously file on ECF a letter-motion seeking leave to file the document with those redactions.
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Page 8 | 10. Redactions and Filing Under Seal - D. Procedures for Filing Documents with Redactions
For entire sealed documents, email unredacted copy to chambers with letter-motion explaining sealing justification; no ECF filing initially.
Any party seeking leave to file under seal an entire submission (with or without exhibits) should not file anything on ECF in the first instance. Instead, the party should email an unredacted copy of the submission to VargasNYSDChambers@nysd.uscourts.gov and should include as an attachment to the e-mail a letter-motion seeking leave to file the document under seal. The letter-motion must explain why sealing is justified in light of the standards discussed in Section 10(C) above. If the party believes that the letter-motion itself should be sealed or redacted, the letter-motion should so state and should provide the justification therefor. The Court will include instructions for filing sealed or redacted versions of the document and accompanying letter-motion, if necessary, in any order disposing of the motion to seal.
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For sealed exhibits, file main document on ECF with 'SEALED' placeholder page and simultaneous letter-motion seeking leave.
Any party seeking leave to file an unsealed or redacted document with a fully sealed exhibit attached thereto should file the main document (in accordance with the procedures above, if the party seeks to do so with redactions) on ECF, accompanied by a single page marked “SEALED” in place of any exhibit that the party seeks leave to file under seal, regardless of the actual length of such exhibit. The party should simultaneously file a letter-motion seeking leave to file in that manner.
Machine summary. Not checked yet. · Criminal cases
Court may grant leave to redact or seal documents beyond sensitive information.
In limited circumstances, the Court may grant leave to a party to either redact information other than the sensitive information described in the preceding paragraph, or to file a document under seal. Information contained in a redacted or sealed document authorized by the Court is generally made available to the other parties in the case.
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Filing Bundling Requirements
After consolidation for all purposes under one docket number, future papers and correspondence should be filed only in that docket.
After two or more actions have been consolidated for all purposes under a single docket number pursuant to Rule 42(a)(2) of the Federal Rules of Civil Procedure, all future court papers and correspondence should be filed only in the docket under which the cases have been consolidated.
Not confirmed. Read the court's wording below. · Civil cases
Page 2 | Guidelines for All Submissions
Pre-Motion Conference Requirements
A party must confer with its adversary before applying for a temporary restraining order unless Rule 65(b)’s requirements are met.
A party must confer with their adversary before making an application for a temporary restraining order unless the requirements of Federal Rule of Civil Procedure 65(b) are met.
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Page 7 | Applications for a Temporary Restraining Order
As soon as a party decides to seek a TRO, it must file an ECF letter stating whether the adversary was notified and consents or Rule 65(b) is satisfied; an ex parte letter must be filed under seal.
As soon as a party decides to seek a temporary restraining order, that party must file a letter on ECF (under seal if proceeding ex parte) and state clearly whether: (1) it has notified its adversary and whether the adversary consents to temporary injunctive relief; or (2) the requirements of Federal Rule of Civil Procedure 65(b) are satisfied and no notice is necessary.
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Page 7 | Applications for a Temporary Restraining Order
If the notified adversary does not consent to temporary injunctive relief, the application must be filed at a time mutually agreeable to both parties.
If a party’s adversary has been notified but does not consent to temporary injunctive relief, the party seeking a restraining order must file the application at a time mutually agreeable to it and the adversary, so that the Court may have the benefit of advocacy from both sides in deciding whether to grant temporary injunctive relief.
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Page 8 | Applications for a Temporary Restraining Order
A plaintiff seeking default judgment must proceed by motion under Attachment A’s procedure.
A plaintiff seeking a default judgment must proceed by way of motion pursuant to the procedure set forth in Attachment A to these rules.
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Page 8 | Default Judgment Motions
A party wishing to file a motion in limine must first confer in good faith with the opposing party to try to resolve the dispute.
Any party wishing to file a motion in limine must first confer in good faith with the opposing party in an effort to resolve the dispute.
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Page 13 | Motions in Limine
Surreply memoranda are prohibited unless specifically permitted in an extraordinary situation for good cause.
Surreply memoranda are not allowed (unless specifically permitted in extraordinary situations for good cause).
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Page 5 | Motions and Specific Types of Filings — A. Memoranda of Law
Pre-motion conferences are generally not required, except for discovery disputes governed by Section 6.
Pre-motion conferences are not required, except for disputes concerning discovery, which are governed by Section 6 below.
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Page 5 | Motions and Specific Types of Filings — C. Pre-Motion Conferences in Civil Cases
For a discovery-stay request based on a contemplated or pending dispositive motion at the initial pretrial conference, the letter-motion should be filed no later than two weeks before the conference, the opposition should be filed one week after the letter-motion, and no reply is permitted.
Moreover, if the grounds for the requested stay of discovery is the filing of a dispositive motion that is either contemplated or pending at the time the Court holds the initial pretrial conference, the motion for a stay of discovery should be filed no later than two weeks prior to the date of the conference. The opposition to such a motion should be filed one week after the letter-motion is filed. No reply will be permitted.
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Page 9 | 6. Discovery; A. Stay of Discovery
Within one week after fact discovery closes, counsel must meet for at least one hour to discuss settlement.
No later than one week after the close of fact discovery, counsel for all parties must meet for at least one hour to discuss settlement.
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Page 11 | C. Post-Fact Discovery Settlement Discussions
A party seeking default judgment should not proceed by order to show cause.
A party seeking a default judgment should not proceed by order to show cause.
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Page 18 | Attachment A—Default Judgment Procedure
When a party fails to respond to a claim, the claimant should promptly seek default judgment if appropriate.
If a party fails to respond to a claim, the party asserting the claim should promptly move for entry of default judgment if appropriate.
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Page 18 | Attachment A—Default Judgment Procedure
When oral argument is requested, the Court decides whether to hear it and, if so, informs counsel of the argument date.
If oral argument is requested, the Court will determine whether argument will be heard and, if so, advise counsel of the argument date.
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Page 6 | Oral Argument on Motions
Summary judgment motions are discouraged in non-jury cases.
Summary judgment motions are discouraged in non-jury cases.
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Page 7 | Summary Judgment
If the meeting does not result in settlement, the parties should discuss whether mediation or a magistrate judge settlement conference would be productive.
If no settlement is reached during this meeting, the parties should discuss whether a mediation or referral to the magistrate judge for a settlement conference would be productive.
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Page 11 | C. Post-Fact Discovery Settlement Discussions
Opposition papers due within 30 days; reply papers due within 2 weeks.
Unless otherwise ordered by the Court, papers filed in opposition to a motion must be served and filed within 30 days of service of the motion papers, and reply papers, if any, must be served and filed within two weeks of receipt of opposition papers.
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If meet-and-confer does not resolve a discovery dispute, the moving party must promptly file an ECF letter-motion of no more than four pages explaining the dispute and requested relief.
If the meet-and-confer process does not resolve the dispute, the party seeking discovery must promptly submit a letter-motion to the Court via ECF, no longer than four pages (single spaced, with standard font and margins, inclusive of the signature block), explaining the nature of the dispute and why the party is entitled to relief.
Not confirmed. Read the court's wording below. · Civil cases
Page 9 | 6. Discovery; B. Discovery Disputes; ii. Letter-Motions
The opposing party must make itself available for a good-faith conference within three business days after a request.
Where a party raises a discovery dispute with the opposing party, the opposing party must make itself available to confer in good faith to resolve the dispute within three business days of a request for a conference.
Not confirmed. Read the court's wording below. · Civil cases
Page 9 | 6. Discovery; B. Discovery Disputes; i. Meet and Confer
An opposing party that wishes to respond must file its letter within two business days, unless the Court orders otherwise; no reply letter is permitted.
If the opposing party wishes to respond, it must do so in a letter not to exceed four pages (single spaced, with standard font and margins, inclusive of the signature block) within two business days, unless otherwise ordered by the Court. Reply letters are not permitted.
Not confirmed. Read the court's wording below. · Civil cases
Page 9 | 6. Discovery; B. Discovery Disputes; ii. Letter-Motions
Before bringing a motion under Rules 26–37 or Rule 45, a party must follow the specified discovery-dispute procedures.
Prior to bringing a motion pursuant to Rules 26 through 37 or Rule 45 of the Federal Rules of Civil Procedure, a party must follow the procedures set forth below.
Not confirmed. Read the court's wording below. · Civil cases
Page 9 | 6. Discovery; B. Discovery Disputes
Opposition papers to motions in limine are due in two weeks.
Any opposition papers will be due in two weeks.
Not confirmed. Read the court's wording below. · Civil cases
Page 13 | Motions in Limine
When failure to answer is the basis for default, the party must first seek a Clerk’s Certificate of Default under Local Civil Rule 55.1.
If a failure to answer is the basis for the default, the party seeking a default judgment must begin by seeking a Clerk’s Certificate of Default pursuant to Local Civil Rule 55.1.
Not confirmed. Read the court's wording below. · Civil cases
Page 18 | Attachment A—Default Judgment Procedure
Adjournment & Extension Requirements
A party seeking a limited extension because of an unforeseen circumstance must file an ECF letter-motion before the deadline and explain why discovery could not be completed despite due diligence.
If something unforeseen arises, a party may seek a limited extension of the foregoing deadlines by letter-motion filed on ECF. Any such motion must be filed before the relevant deadline and must explain why, despite the parties’ due diligence, discovery could not be completed by the relevant deadline.
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Page 3 | Fact Discovery
Except for the extensions allowed in paragraphs 5(i) and 6(e), dates may be modified or extended only by further court order for good cause; a written application must be made at least two business days before the relevant date expires.
This Order may not be modified or the dates herein extended, except as provided in paragraphs 5(i) and 6(e) or by further Order of the Court for good cause shown. Any application to modify or extend the dates herein shall be made in a written application in accordance with the Court’s Individual Rules and Practices and shall be made no fewer than two business days prior to the expiration of the date sought to be extended.
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Page 4 | Modification of Order
An adjournment or extension letter-motion must provide the original and requested dates, prior-request history, reasons, adversary’s position and any refusal reasons, and the next scheduled court appearance date.
The letter-motion must state: (1) the original date and the new date requested; (2) the number of previous requests for adjournment or extension; (3) whether these previous requests were granted or denied; (4) the reason for the extension or adjournment; (5) whether the adversary consents and, if not, the reasons given by the adversary for refusal to consent; and (6) the date of the parties’ next scheduled appearance before the Court.
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Page 3 | Requests for Adjournment or Extension of Time
Unless there is an emergency, extension and adjournment requests must be made as early as possible and at least 48 hours before the deadline or scheduled appearance.
Absent an emergency, any request for extension or adjournment shall be made as early as possible, and at least 48 hours prior to the deadline or scheduled appearance.
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Page 3 | Requests for Adjournment or Extension of Time
The interim expert-disclosure deadlines in paragraphs 6(c)–(d) may be extended by written consent of all parties without court application, provided expert discovery is completed by the date in paragraph 6(b).
e. The interim deadlines in paragraphs 6(c)–(d) may be extended by the written consent of all parties without application to the Court, provided that expert discovery is completed by the date set forth in paragraph 6(b).
Checked against the court's document on Oct 4, 2026 · Civil cases
Page 3 | Expert Discovery
The deadlines in paragraphs 5(b)–(h) may be extended by written consent of all parties without court application, provided fact discovery is completed by the date in paragraph 5(a).
i. Any of the deadlines in paragraphs 5(b)–(h) may be extended by the written consent of all parties without application to the Court, provided that all fact discovery is completed by the date set forth in paragraph 5(a).
Checked against the court's document on Oct 4, 2026 · Civil cases
Page 3 | Civil Case Management Plan and Scheduling Order
A request to extend the discovery-completion deadline is unlikely to be granted and must detail discovery requests, responses, and document production, including who acted and when.
A request to extend the deadline to complete all discovery is unlikely to be granted. But any such request shall include a statement as to what discovery requests have been propounded, who propounded each request, and on what date; what responses were made, who made each response, and on what date; and the volume of documents produced, who produced the documents, and on what date.
Checked against the court's document on Oct 4, 2026 · Civil cases
Page 3 | Requests for Adjournment or Extension of Time
Extension requests made after the original deadline has expired will ordinarily be denied.
Requests for extensions will ordinarily be denied if made after the expiration of the original deadline.
Checked against the court's document on Oct 4, 2026 · Civil cases
Page 3 | Requests for Adjournment or Extension of Time
Non-emergency requests to reschedule or extend must be made at least 48 hours in advance
Absent an emergency, any request for an extension or to reschedule a conference must be made at least 48 hours prior to the deadline or scheduled appearance.
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Page 2 | Communications with Chambers
Written requests to reschedule conferences or extend deadlines must include specific required elements
All requests to reschedule a conference or extend a deadline must be made in writing and must state: (1) the original date(s) of the conference or deadline; (2) the reasons for the requested extension; (3) whether the other party or parties consent and, if not, the reasons given for refusing to consent; and (4) the date of the next scheduled appearance before the Court as well as any other existing deadlines.
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Page 2 | Communications with Chambers
Adjournment/extension requests must be filed as letter-motions on ECF
All requests for adjournments or extensions of time must be made in writing and filed on ECF as letter-motions, not as ordinary letters.
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Page 3 | D. Requests for Adjournment or Extension of Time
Letter-motion for adjournment must include 6 specific elements
The letter-motion must state: (1) the original date and the new date requested; (2) the number of previous requests for adjournment or extension; (3) whether these previous requests were granted or denied; (4) the reason for the extension or adjournment; (5) whether the adversary consents and, if not, the reasons given by the adversary for refusal to consent; and (6) the date of the parties’ next scheduled appearance before the Court.
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Page 3 | D. Requests for Adjournment or Extension of Time
Sentencing adjournment requests require 72 hours advance notice
Requests for adjournment of sentencing shall be made at least 72 hours prior to the scheduled proceeding.
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Page 4 | D. Requests for Adjournment or Extension of Time
Sentencing adjournment requests must be made no later than 72 hours before the proceeding.
Any request for an adjournment of a sentencing should be made as early as possible, and no later than 72 hours before the sentencing proceeding, in accordance with Section 3(D).
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Page 7 | 9. Sentencing - A. Sentencing Adjournments
Extension requests after deadline are ordinarily denied
Requests for extensions will ordinarily be denied if made after the expiration of the original deadline.
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Page 4 | D. Requests for Adjournment or Extension of Time
Chambers Communication Rules
Unless an exception applies or the Court orders otherwise, communications with Chambers must be made by letter filed on ECF.
Except as provided herein or as otherwise ordered by the Court, communications with Chambers shall be by letter filed on ECF.
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Page 2 | Communications with Chambers
The letter-motion may be emailed to Chambers as a text-searchable PDF, with copies delivered to all counsel at the same time.
Such letter-motions may be emailed to VargasNYSDChambers@nysd.uscourts.gov as text-searchable PDF attachments, with copies simultaneously delivered to all counsel.
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Page 17 | Submission by Email
If proposed damages are supported by calculations, the original-format calculation files must be emailed to Chambers.
D. if the proposed damages are supported by calculations, native versions of the files with calculations (i.e., versions of the files in their original format, such as in “.xlsx”), which shall be emailed to Chambers at VargasNYSDChambers@nysd.uscourts.gov;
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Page 19
Except as provided in Sections 5(L) and 7(B), calls to Chambers are permitted only for urgent matters requiring immediate attention when filing a letter or letter motion is not feasible.
Except as provided in Section 5(L) and 7(B), calls to Chambers are permitted only in urgent situations requiring immediate attention, where submission of a letter or letter motion is not feasible.
Checked against the court's document on Oct 4, 2026 · Civil cases
Page 2 | Communications with Chambers
Faxes to Chambers are prohibited unless express prior permission is given for an unforeseeable emergency.
D. Faxes. Faxes to Chambers are not permitted without express prior permission, and only in cases of unforeseeable emergencies.
Checked and corrected to match the court's document on Oct 4, 2026 · Civil cases
Page 3 | Communications with Chambers
For a time-sensitive matter, if Chambers has not responded within two hours, the movant may call Chambers before the end of the business day.
If the matter is time sensitive and Chambers does not respond within two hours, the movant may call Chambers before the end of the business day.
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Page 8 | Applications for a Temporary Restraining Order
If the specified letter-motion procedures are not feasible for a dispute arising during a deposition, the parties may call Chambers during the deposition, but all attendees must be available and call jointly.
B. If a dispute arises during a deposition, and the letter-motion procedures in Paragraph 5 are not feasible to address it, the parties may call Chambers to raise the dispute with the Court during the deposition. If a party wishes to engage the Court in this manner, all parties in attendance at the deposition must make themselves available and call the Court jointly.
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Page 10 | 7. Conduct in Depositions
When the Standing Order requires permission, attorneys seeking to bring electronic devices should email Chambers a completed Model Court Order.
When Court permission is required under the Standing Order, attorneys seeking to bring electronic devices to the Court should email a completed Model Court Order to VargasNYSDChambers@nysd.uscourts.gov.
Checked against the court's document on Oct 4, 2026 · Civil cases
Page 17 | Use of Electronics—Electronic Devices in the Courtroom
Pro se parties must send all written communications to Pro Se Office, not chambers
All communications with the Court by a pro se party should be in writing and delivered in person, mailed, or emailed to the Pro Se Office following the instructions in Paragraph 2(B) below. No documents or court filings may be sent directly to Chambers.
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Page 1 | Communications with Chambers
Pro se parties cannot call chambers directly; must contact Pro Se Office
Pro se parties may not call the Court directly; any questions should be directed to the Pro Se Office at (212) 805-0175.
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Page 1 | Communications with Chambers
Broadcasting or recording court conferences is prohibited by law.
The broadcasting or recording of any court conference is prohibited by law.
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Page 5 | Conferences
The TRO moving party must email Chambers notice of the filing and the requested time frame for court action.
The moving party must email VargasNYSDChambers@nysd.uscourts.gov giving notice of the filing and the time frame requested for Court action.
Not confirmed. Read the court's wording below. · Civil cases
Page 8 | Applications for a Temporary Restraining Order
In civil cases with deposition designations in the joint pretrial order, the parties must jointly email complete, color-coded transcripts with margin-listed objections to Chambers no later than one week before the final pretrial conference.
In any civil case in which the parties have designated deposition testimony in the joint pretrial order, by no later than a week prior to the final pretrial conference, the parties shall jointly submit by email to VargasNYSDChambers@nysd.uscourts.gov the complete deposition transcripts with color-coded highlighting indicating the portions designated by each party (including any counter-designations) and the objections listed in the margins.
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Page 13 | Deposition Designations
AUSA must email Chambers immediately after case assignment with specific information and documents
Upon assignment of a criminal case to Judge Vargas, the Assistant United States Attorney shall immediately email Chambers to arrange for a prompt conference/arraignment. In the e-mail, the Assistant United States Attorney shall include (1) the name of the defendant(s); (2) defense counsel’s name and contact information; (2) whether the defendant(s) is/are detained (and, if so, the relevant defendant’s Reg. No.) or bailed; (3) whether any defendant requires an interpreter (and, if so, the relevant language); (4) the parties’ joint availability for a prompt conference/arraignment; (5) whether there is any reason a scheduling order should not be filed on the public docket; and (6) any other pertinent information. In addition, the Assistant United States Attorney shall attach to the e-mail PDFs of the indictment and any criminal complaint, if one exists.
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Page 2 | 3. Communications with Chambers
Communications with Chambers must be by ECF letter-motions, not ordinary letters
Except as provided herein or as otherwise ordered by the Court, communications with Chambers shall be by letter filed on ECF. Letters seeking relief (consistent with S.D.N.Y. Local Rules and the S.D.N.Y. Electronic Case Filing Rules and Instructions) should be filed as letter-motions on ECF, not ordinary letters.
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Page 2 | 3. Communications with Chambers
All communications with Chambers must be by letter or letter-motion on ECF
Any other communications with Chambers, including requests for extensions or adjournments, shall be by letter or letter-motion filed on ECF in accordance with Section 3(B).
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Page 3 | C. Telephone Calls
Faxes to Chambers require express permission and only for emergencies
Faxes to Chambers are not permitted without express prior permission, and only in cases of unforeseeable emergencies.
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Page 4 | G. Faxes
Technology walkthrough required at least one week before trial for AV equipment use.
If a party wishes to use audio-visual equipment at a hearing or trial, it is that party’s responsibility to ensure that any required approvals are obtained and that the necessary equipment is set up and working properly in advance of trial. The parties should contact Chambers by email and the Audio and Visual Department at 212-805-0134 to make the necessary arrangements for a technology walk-through and to test the equipment. The walkthrough should take place no later than one week in advance of the start of the trial or hearing.
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Attorneys must email completed Model Court Order for electronic devices at least 5 business days before trial/hearing.
Attorneys’ use of personal electronic devices (including mobile phones) and general purpose computing devices (such as laptops and tablets) within the Courthouse and its environs is governed by Standing Order M10-468. When Court permission is required under the Standing Order, attorneys seeking to bring electronic devices to the Court should email a completed Model Court Order to VargasNYSDChambers@nysd.uscourts.gov as early as possible, and no later than five business days before the relevant trial or hearing.
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Letters seeking relief should be filed on ECF as letter-motions rather than ordinary letters.
Letters seeking relief (consistent with S.D.N.Y. Local Rules and the S.D.N.Y. Electronic Case Filing Rules and Instructions) should be filed as letter-motions on ECF, not ordinary letters.
Not confirmed. Read the court's wording below. · Civil cases
Page 2 | Communications with Chambers
Correspondence between counsel must not be sent to the Court or filed on ECF unless submitted as an exhibit to an otherwise properly filed document.
Copies of correspondence between counsel shall not be sent to the Court or filed on ECF except as exhibits to an otherwise properly filed document.
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Page 2 | Communications with Chambers
Counsel should email Chambers an electronic copy of any proposed order in both Microsoft Word and PDF formats.
Counsel should also email an electronic copy of any proposed order to Chambers, in both Microsoft Word and PDF formats.
Not confirmed. Read the court's wording below. · Civil cases
Page 6 | Proposed Orders and Stipulations
Proposed findings and conclusions should also be emailed to Chambers in Microsoft Word format.
This document should also be submitted by email to VargasNYSDChambers@nysd.uscourts.gov in Microsoft Word format.
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Page 14 | Additional Required Pretrial Filings in Non-Jury Cases
Parties must not include substantive communications in the body of the cover email.
Parties shall not include substantive communications in the body of the email.
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Page 17 | Submission by Email
Wi-Fi access requires approval, limited to approved attorney, non-transferable, for assigned courtroom only.
If Wi-Fi is requested, counsel shall check the appropriate box on the form. If approved and signed by Judge Vargas, a copy of the Order will be sent to the requesting attorney, who will receive a network name, username, password and instructions from the District Executive’s Office on or before the first day of the scheduled proceeding. Wi-Fi access is limited to the approved attorney (who may not share their username or password with others) for the duration of the proceeding and for the assigned courtroom (unless Judge Vargas or another judicial officer grants permission for it to be used in another courtroom).
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Non-incarcerated pro se parties are encouraged to consent to electronic service
To ensure timely service of documents, including Court Orders, non-incarcerated pro se parties are encouraged to consent to receive electronic service through the ECF System.
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Page 2 | Filing of Papers and Service
Incarcerated parties may participate by telephone if unable to attend in-person conferences.
An incarcerated party may not be able to attend scheduled in-person conferences but may be able to participate by telephone.
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Page 5 | Conferences
Conferences may be held remotely or in person at specified courthouse.
Conferences may be held remotely or in person at the Daniel Patrick Moynihan Courthouse, 500 Pearl Street, New York, New York 10007.
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Page 5 | Conferences
Audio-only participants should spell proper names for court reporter.
The pro se litigant or counsel should spell any proper names for the court reporter.
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Page 5 | Conferences
Non-speaking attendees must have videos off and be muted during remote conferences.
Persons in attendance who will not be speaking must have their videos off and be muted for the duration of the conference.
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Page 5 | Conferences
Family member or representative may attend conference if incarcerated party cannot participate.
If an incarcerated party is unable to participate by telephone, a family member or a representative may attend or otherwise participate in the conference.
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Page 5 | Conferences
Conference notices docketed on ECF and mailed to pro se parties.
Notices scheduling a court conference will be docketed on ECF and mailed to the pro se party or parties.
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Page 5 | Conferences
Incarcerated pro se party without representative should write to Judge about conference issues.
If an incarcerated party does not have counsel and a representative cannot attend a conference, the pro se party should write to the Judge regarding any issue the pro se party wishes to have addressed at the conference.
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Page 5 | Conferences
Court will send conference transcript to incarcerated party.
The Court will also have a transcript of the conference sent to the incarcerated party.
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Page 5 | Conferences
Audio-only participants must identify themselves each time they speak for transcript accuracy.
To facilitate the creation of an accurate transcript if the conference is held on the record, the pro se litigant or counsel who are joining the conference audio-only are required to identify themselves every time they speak.
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Page 5 | Conferences
Audio-only participants should use landlines, headsets, and mute when not speaking.
If the pro se litigant or counsel joins the Remote Conference by audio-only, pro se litigant or counsel should dial-in using a landline whenever possible, should use a headset or handset instead of speakerphone, and must mute themselves whenever they are not speaking to eliminate background noise.
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Page 5 | Conferences
Remote conferences held via Microsoft Teams unless otherwise ordered.
Unless otherwise ordered by the Court, any Remote Conference will be held via a Microsoft Teams meeting organized by the Court.
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Page 5 | Conferences
Audio-only participants should avoid interrupting or speaking over each other.
The pro se litigant or counsel should also take special care not to interrupt or speak over one another.
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Page 5 | Conferences
Pro se parties should consult Court website for important information about pro se proceedings.
Pro se parties are directed to the Court’s website (https://www.nysd.uscourts.gov/prose/role-of-the-prose-intake-unit/contact) for other important information concerning proceeding pro se in this Court.
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Page 7 | Resources for Pro Se Parties
Pro Se Law Clinic available to assist unrepresented parties in civil cases.
There is a Pro Se Law Clinic in this District to assist parties in civil cases who do not have lawyers. The Clinic may be able to provide a pro se litigant with advice in connection with his or her case.
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Page 7 | Resources for Pro Se Parties
Parties should review the Individual Rules and Practices before calling with questions about the Court’s rules and practices.
Parties should review these Individual Rules and Practices before calling with questions about the Court’s rules and practices.
Not confirmed. Read the court's wording below. · Civil cases
Page 2 | Communications with Chambers
Large files that cannot be uploaded to ECF should be emailed to Chambers with specific information
If a party needs to submit large files that cannot be uploaded to ECF due to size, the party should email the Court at VargasNYSDChambers@nysd.uscourts.gov. The e-mail should copy all other counsel in the case and include the name and docket number of the case and the nature and size of the materials to be submitted electronically.
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Page 1 | 2. Guidelines for All Submissions
Confidential letters may be emailed as PDF attachments to Court
Letters containing confidential or sensitive information that cannot be filed on ECF may be sent by e-mail as a .pdf attachment to the Court
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Page 2 | 3. Communications with Chambers
Urgent matters may be communicated by phone to Chambers
For urgent matters, including to direct the Court’s notice to an ECF filing that requires immediate attention, call Chambers.
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Page 3 | C. Telephone Calls
Hand-delivered mail goes to Court Security Officers at Worth Street entrance
Hand-delivered mail should be left with the Court Security Officers at the Worth Street entrance of the Daniel Patrick Moynihan United States District Courthouse, 200 Worth Street, New York, NY 10007.
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Page 4 | F. Hand-Deliveries
Urgent hand-delivered letters require Chambers notification via Security Officers
If the hand delivered letter is urgent and requires the Court’s immediate attention, ask the Court Security Officers to notify Chambers that an urgent package has arrived that needs to be retrieved by Chambers staff immediately.
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Page 4 | F. Hand-Deliveries
Adverse bail determination appeals require contacting Chambers to arrange conference
A party who wishes to appeal an adverse bail determination by the Magistrate Judge should contact Chambers to arrange a conference for
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Page 5 | 5. Bail Modification or Appeal
Electronic device use governed by Standing Order M10-468; email completed Model Court Order to chambers for permission.
Attorneys’ use of personal electronic devices (including mobile phones) and general purpose computing devices (such as laptops and tablets) within the Courthouse and its environs is governed by Standing Order M10-468. When Court permission is required under the Standing Order, attorneys seeking to bring electronic devices to the Court should email a completed Model Court Order to VargasNYSDChambers@nysd.uscourts.gov. Chambers will coordinate with the District Executive’s Office to issue the Order bringing the equipment into the Courthouse.
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Junior Lawyer Participation Incentives
The Court encourages less experienced attorneys to participate, may grant oral argument to provide courtroom experience, and is amenable to allowing multiple attorneys to speak.
The Court encourages the participation of less experienced attorneys in all proceedings— including pretrial conferences, hearings on discovery disputes, and witness examinations at trial—particularly where that attorney played a substantial role in drafting the underlying filing or in preparing the relevant witness. The Court may be inclined to grant a request for oral argument where doing so would afford the opportunity for a junior attorney to gain courtroom experience. To facilitate this provision, the Court is amenable to permitting more than one attorney to speak at a conference or argument.
Checked and corrected to match the court's document on Oct 4, 2026 · Civil cases
Page 4 | Participation by Junior Attorneys