Judge Jennifer L. Rochon
Individual Rules, Standing Orders & Policies
- Rules last changed:
Limits & Logistics
Document Limits
Courtesy Copies
All filings
- 1 copy • Hand Delivery Or Mail • Upon Filing
- Always
- Hand Delivery • Upon Filing
Attorney filings
- 1 copy • With Reply
Brief
- 2 copies • Hand Delivery • When Fully Briefed
Courtesy copies
- 1 copy • Hand Delivery
Adjournments
- Modifications/extensions require written application at least two business days before deadline
- Adjournment of a court appearance must be requested at least two business days before the appearance, absent an emergency.
- Counsel may extend default brief deadlines by joint stipulation submitted to the Court no later than two business days before the brief is due.
- +3 more
- All adjournment or extension requests must be in writing and filed on ECF as letter motions.
- Adjournment or extension letter motions must state the original and new dates, prior request history, and the adversary's position.
- Conference adjournment requests must include three mutually agreeable alternative dates.
- +14 more
Request must include
- Extension requests must be made at least one business day before the deadline, absent unforeseen circumstances.
- Adjournment/extension requests require 48-hour advance notice (except emergencies).
Communication
Chambers
Clerk
Phone
Clerk
Phone
Chambers
Letter via ECF
Chambers
Letter via ECF
Intake Unit
Phone
Hand Delivery
Chambers
Page & Word Limits15 rules
Machine summary. Not checked yet.Mandatory?
Unless otherwise ordered by the Court, the Government shall make its expert disclosures 60 days before trial and the defendant shall make its expert disclosures 30 days before trial.
Summary: Government expert disclosures due 60 days before trial; defendant disclosures due 30 days before trial.
Structured details unavailable. See the source text.
Machine summary. Not checked yet.Mandatory?
Letters may not exceed three pages in length (exclusive of exhibits or attachments) without prior permission from the Court.
Summary: Letters are limited to three pages, excluding exhibits and attachments, unless the Court grants prior permission.
Letter
3 pages
Applies to: Attorney
Machine summary. Not checked yet.Mandatory?
At least ten days before the conference date, the parties must file on ECF: (1) a proposed Civil Case Management Plan and Scheduling Order, available on the Court’s website at (https://nysd.uscourts.gov/hon-jennifer-l-rochon); and (2) a joint letter, not to exceed three pages, describing the case, any contemplated motions, and the prospect for settlement.
Summary: The joint letter for the initial pretrial conference is limited to three pages.
Letter
3 pages
Applies to: Attorney
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 8,750 words, and reply memoranda are limited to 3,500 words.
Summary: Memoranda in support/opposition are limited to 8,750 words; reply memoranda are limited to 3,500 words.
Brief
8,750 words
Applies to: Attorney
Reply Brief
3,500 words
Applies to: Attorney
Machine summary. Not checked yet.Mandatory?
If this meet-and-confer process does not resolve the dispute, the party must submit a letter motion to the Court on ECF, no longer than three pages (excluding exhibits), explaining the nature of the dispute, the legal standards governing the issue, and case law, if any, supporting the party’s position.
Summary: Discovery dispute letter motions are limited to three pages (excluding exhibits).
Discovery Motion
3 pages
Applies to: Attorney
Machine summary. Not checked yet.Mandatory?
Opposition papers, no longer than 8,750 words, shall be filed within seven days. No replies are permitted.
Summary: Opposition to motions in limine limited to 8,750 words, filed within 7 days; no replies permitted.
Opposition
8,750 words
Applies to: Attorney
Machine summary. Not checked yet.Mandatory?
Motions in limine are limited to 8,750 words. Opposition papers, no longer than 8,750 words, may be filed within seven days. No replies are permitted.
Summary: Motions in limine limited to 8,750 words; opposition limited to 8,750 words filed within 7 days; no replies permitted.
Motion In Limine
8,750 words
Applies to: Attorney
Opposition
8,750 words
Applies to: Attorney
Machine summary. Not checked yet.Mandatory?
The Court encourages and appreciates brevity. 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. All memoranda of law must be in 12-point font or larger, including
Summary: Memoranda limited to 8,750 words (support/opposition) and 3,500 words (reply); 12-point font required.
Brief
8,750 words
Applies to: Attorney
Reply Brief
3,500 words
Applies to: Attorney
Machine summary. Not checked yet.Mandatory?
Letters may not exceed three pages in length (exclusive of exhibits or attachments) without prior permission from the Court.
Summary: Letters to the court are limited to 3 pages without prior permission.
Letter
3 pages
Applies to: Attorney
Machine summary. Not checked yet.Mandatory?
File and serve a pretrial memorandum of law no longer than 3,500 words in cases where a party believes it would be useful to the Court. Opposition to any pretrial memorandum, if any, may be no longer than 3,500 words and filed and served within seven days of any opening memoranda;
Summary: Pretrial memoranda limited to 3,500 words, opposition same limit, 7-day response time.
Pretrial Memorandum
3,500 words
Applies to: Attorney
Machine summary. Not checked yet.Mandatory?
The Court encourages and appreciates brevity. 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. All memoranda of law must be in 12-point font or larger, including
Summary: Memoranda of law limited to 8,750 words (support/opposition) and 3,500 words (reply); 12-point font or larger required.
Memorandum Of Law
8,750 words
Applies to: Attorney
3,500 words
Applies to: Attorney
Machine summary. Not checked yet.Mandatory?
Motions in limine are limited to 8,750 words. Opposition papers, no longer than 8,750 words, may be filed within seven days. No replies are permitted.
Summary: Motions in limine limited to 8,750 words, opposition papers same limit, no replies allowed.
Motion In Limine
8,750 words
Applies to: Attorney
Machine summary. Not checked yet.Mandatory?
The Government shall make its expert disclosures 60 days before trial and the defendant shall make its expert disclosures 30 days before trial.
Summary: Government expert disclosures due 60 days before trial; defendant disclosures due 30 days before trial.
Structured details unavailable. See the source text.
Machine summary. Not checked yet.Mandatory?
Unless otherwise ordered by the Court, a defendant’s sentencing submission shall be served on the Government and emailed to Chambers no later than two weeks before the date set for sentencing. Unless prior permission has been granted, sentencing memoranda are limited to 25 pages.
Summary: Defendant's sentencing submission due 2 weeks before sentencing, limited to 25 pages.
Sentencing Memorandum
25 pages
Applies to: Attorney
Machine summary. Not checked yet.Important?
File and serve a pretrial memorandum of law no longer than 3,500 words in cases where a party believes it would be useful to the Court. Opposition to any pretrial memorandum, if any, may be no longer than 3,500 words and filed and served within seven days of any opening memoranda;
Summary: Pretrial memoranda limited to 3,500 words (optional); opposition limited to 3,500 words filed within 7 days.
Pretrial Memorandum
3,500 words
Applies to: Attorney
Opposition
3,500 words
Applies to: Attorney
Document Format Requirements5 rules
Machine summary. Not checked yet.Mandatory?
If electronic devices are permitted inside the Courtroom, they MUST be kept silent at all times.
Summary: Electronic devices must be kept silent in courtroom if permitted
Machine summary. Not checked yet.Important?
When filling out the Civil Case Management Plan and Scheduling Order, download the form into Adobe Acrobat to complete it.
Summary: The Civil Case Management Plan and Scheduling Order form must be completed in Adobe Acrobat.
Machine summary. Not checked yet.Important?
All memoranda of law must be in 12-point font or larger
Summary: All memoranda of law must be in 12-point font or larger.
Machine summary. Not checked yet.Important?
All appendices to memoranda of law must be tabbed and indexed.
Summary: Appendices to memoranda of law must be tabbed and indexed.
Machine summary. Not checked yet.Important?
Any party moving for summary judgment must provide all other parties with an electronic copy, in Microsoft Word format, of the moving party's Statement of Material Facts Pursuant to Local Rule 56.1 ("Rule 56.1 Statement").
Summary: Moving parties must provide all other parties an electronic copy of the Rule 56.1 Statement in Microsoft Word format.
DOCX
Document Filing Requirements123 rules
Machine summary. Not checked yet.Mandatory?
Any written request for a bail modification by a defendant shall be filed on ECF as a letter-motion and shall indicate whether the Government and Pretrial Services Officer consent to the request.
Summary: Bail modification requests must be filed as letter-motions on ECF with consent indication.
Document Type
Letter Motion
Machine summary. Not checked yet.Mandatory?
A party who wishes to appeal an adverse bail determination by the Magistrate Judge should contact Chambers to arrange a conference for that purpose. The party that brings the appeal is directed to provide the Court no fewer than 24 hours before the conference with the transcript of argument on bail before the Magistrate Judge, any written submissions below as to bail, and Pretrial Services’ report as to the defendant.
Summary: Bail appeals require 24-hour advance submission of transcript, written submissions, and Pretrial Services report.
Document Type
Bail Appeal
Machine summary. Not checked yet.Mandatory?
The parties shall provide the Court with a flash drive containing electronic .pdf copies of all exhibits and 3500 material.
Summary: Parties must provide flash drive with PDF copies of all exhibits and 3500 material before trial.
Document Type
Exhibits And 3500 Material
Machine summary. Not checked yet.Mandatory?
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 and 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.
Summary: Settlement meeting and joint letter required one week after fact discovery closes
Document Type
Settlement Letter
Machine summary. Not checked yet.Mandatory?
The Court will conduct a post-discovery pre-trial conference on __________________ at __________. [To be completed by the Court.] No later than one week in advance of the conference, the parties are to submit a joint two-page letter updating the Court on the status of the case, including proposed deadlines for pretrial submissions and trial dates.
Summary: Joint two-page letter required one week before post-discovery pre-trial conference
Document Type
Pretrial Letter
Machine summary. Not checked yet.Mandatory?
If a party wishes to move for summary judgment or to exclude expert testimony, it must, no later than three weeks before the conference, file a letter as set forth in Section 3(I) of the Court's Individual Rules and Practices in Civil Cases, and any response letter shall be filed no later than two weeks before the conference.
Summary: Letters required for summary judgment or expert testimony motions per Section 3(I)
Document Type
Motion Letter
Machine summary. Not checked yet.Mandatory?
Unless otherwise ordered by the Court, the parties shall submit a Joint Pretrial Order prepared in accordance with Federal Rule of Civil Procedure 26(a)(3) and other pretrial submissions pursuant to the Court's Individual Rules and Practices in Civil Cases within 30 days of any decision on a summary judgment motion.
Summary: Joint Pretrial Order required within 30 days of summary judgment decision
Document Type
Joint Pretrial Order
Machine summary. Not checked yet.Mandatory?
The parties shall be ready for trial as of two weeks following the deadline for the proposed Joint Pretrial Order, even if trial is tentatively scheduled for a later date.
Summary: Parties must be ready for trial two weeks after Joint Pretrial Order deadline
Document Type
Trial Readiness
Machine summary. Not checked yet.Mandatory?
At least ten days before the conference date, the parties must file on ECF: (1) a proposed Civil Case Management Plan and Scheduling Order, available on the Court’s website at (https://nysd.uscourts.gov/hon-jennifer-l-rochon); and (2) a joint letter, not to exceed three pages, describing the case, any contemplated motions, and the prospect for settlement.
Summary: At least ten days before the initial pretrial conference, parties must file on ECF a proposed Civil Case Management Plan and Scheduling Order and a joint letter describing the case, contemplated motions, and settlement prospects.
Document Type
Pretrial Order
Machine summary. Not checked yet.Mandatory?
Such a letter must include a representation that the meet-and-confer process occurred and was unsuccessful.
Summary: Discovery dispute letters must include a representation that the meet-and-confer process occurred and was unsuccessful.
Document Type
Discovery Motion
Machine summary. Not checked yet.Mandatory?
As soon as a party decides to seek a temporary restraining order, that party must file a letter on ECF (or in person 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. The moving party must give notice of the time frame requested for Court action.
Summary: A party seeking a TRO must file a letter on ECF stating whether the adversary was notified and consents, or whether FRCP 65(b) is satisfied, and must give notice of the time frame requested for Court action.
Document Type
Letter
Machine summary. Not checked yet.Mandatory?
All proposed orders that parties wish the Court to sign should be filed in ECF as attachments or exhibits to an appropriate formal application to the Court seeking the endorsement of such order.
Summary: Proposed orders must be filed on ECF as attachments or exhibits to a formal application seeking endorsement.
Document Type
Proposed Order
Machine summary. Not checked yet.Mandatory?
The motion must be supported by the following papers: i. An attorney's affidavit or declaration setting forth: (a) The basis for entering a default judgment, including a description of the method and date of service of the summons and complaint; (b) The procedural history beyond service of the summons and complaint, if any; (c) Whether, if the default is applicable to fewer than all of the defendants, the Court may appropriately order a default judgment on the issue of damages prior to resolution of the entire action; (d) The proposed damages and the basis for each element of damages, including interest, attorney's fees, and costs; (e) Evidence in support of the proposed damages, including contemporaneous records and other such documentation; and (f) Legal authority for why an inquest into damages is or is not unnecessary; ii. A proposed default judgment; iii. Copies of all the operative pleadings; iv. A copy of the affidavit of service of the summons and complaint; and v. If failure to answer is the basis for the default, a Certificate from the Clerk of Court stating that no answer has been filed.
Summary: Default judgment motions must include an attorney's affidavit with specified content, a proposed default judgment, copies of pleadings, affidavit of service, and (if applicable) a Clerk's certificate of no answer.
Document Type
Default Judgment Motion
Machine summary. Not checked yet.Mandatory?
In any action in which subject matter jurisdiction is founded on diversity of citizenship pursuant to 28 U.S.C. § 1332, the party asserting the existence of such jurisdiction must include in their joint letter to the Court prior to the Initial Pretrial Conference the basis for that party's belief that diversity of citizenship exists. Where any party is a corporation, the letter must state both the place of incorporation and the principal place of business. In cases where any party is a partnership, limited partnership, limited liability company, or trust, the letter must identify and state the citizenship of each of the entity's members, shareholders, partners, and/or trustees.
Summary: In diversity cases, the party asserting jurisdiction must include in the joint letter prior to the Initial Pretrial Conference the basis for diversity, including corporate place of incorporation/principal place of business and entity member citizenship.
Document Type
Joint Letter
Machine summary. Not checked yet.Mandatory?
As soon as the parties reach an agreement to settle, the parties must email Chambers to alert the Court and file a joint letter on ECF promptly.
Summary: Parties must file a joint letter on ECF promptly upon reaching a settlement agreement.
Document Type
Joint Letter
Machine summary. Not checked yet.Mandatory?
The Joint Pretrial Order must include the information required by Federal Rule of Civil Procedure 26(a)(3) and the following: i. The full caption of the action; ii. The names, law firms, addresses, telephone numbers, and emails of trial counsel; iii. A brief statement by plaintiff as to the basis of subject matter jurisdiction, and a brief statement by each other party as to the presence or absence of subject matter jurisdiction.
Summary: The Joint Pretrial Order must include FRCP 26(a)(3) information plus fifteen specified items covering caption, counsel, jurisdiction, claims, trial details, witnesses, exhibits, damages, and consent statements.
Document Type
Pretrial Order
Machine summary. Not checked yet.Mandatory?
File and serve joint proposed jury instructions, verdict form, and voir dire questions. These joint submissions must consist of single documents, jointly composed, noting any areas of disagreement between the parties. The voir dire questions and jury instructions must include both the text of any requested question or instruction as well as a citation, if available, to the authority from which it derives. These documents should also be submitted by email to Chambers in Microsoft Word format;
Summary: Parties must file joint jury instructions, verdict form, and voir dire questions as single documents noting disagreements, with text and citations, and email to Chambers in Word format.
Document Type
Jury Instructions
Machine summary. Not checked yet.Mandatory?
Any motion in limine must include a representation that the meet-and-confer process occurred and was unsuccessful;
Summary: Motions in limine must include a representation that the meet-and-confer process occurred and was unsuccessful.
Document Type
Motion In Limine
Machine summary. Not checked yet.Mandatory?
The parties must provide the Court with a hard copy and Microsoft Word document listing all exhibits sought to be admitted. The list must contain four columns labeled as follows: (1) "Exhibit No."; (2) "Description" (of the exhibit); (3) "Date Identified"; and (4) "Date Admitted." The parties must complete the first two columns, but leave the third and fourth columns blank, for use by the Court.
Summary: Exhibit list must be provided to the Court in hard copy and Word format with four labeled columns; parties complete first two columns only.
Document Type
Exhibit List
Machine summary. Not checked yet.Mandatory?
Two business days before trial is scheduled to begin, the parties must jointly file a final list of all trial witnesses in the form provided by the Court's Individual Rule 5.A.x.
Summary: Parties must jointly file a final witness list two business days before trial in the form provided by Individual Rule 5.A.x.
Document Type
Witness List
Machine summary. Not checked yet.Mandatory?
Submit to the Court and serve on opposing counsel, but do not file on ECF, all deposition excerpts that will be offered as substantive evidence, as well as a one-page synopsis of those excerpts for each deposition. Each synopsis must include page citations to the pertinent pages of the deposition transcripts;
Summary: Deposition excerpts offered as evidence must not be filed on ECF; a one-page synopsis with page citations is required for each deposition.
Document Type
Deposition Excerpts
Machine summary. Not checked yet.Mandatory?
File and serve proposed findings of fact and conclusions of law. The proposed findings of fact must be detailed and include citations to the proffered trial testimony and exhibits. At the time of filing, parties should also submit copies of these documents to the Court by email both in .pdf format and as a Microsoft Word document;
Summary: Parties must file proposed findings of fact and conclusions of law with detailed citations, and email copies to the Court in PDF and Word format.
Document Type
Proposed Findings Conclusions
Machine summary. Not checked yet.Mandatory?
The parties must provide the Court with a hard copy and Microsoft Word document listing all exhibits sought to be admitted. The list must contain four columns labeled as follows: (1) "Exhibit No."; (2) "Description" (of the exhibit); (3) "Date Identified"; and (4) "Date Admitted." The parties must complete the first two columns but leave the third and fourth columns blank for use by the Court.
Summary: Exhibit list in non-jury cases must be provided to the Court in hard copy and Word format with four labeled columns; parties complete first two columns only.
Document Type
Exhibit List
Machine summary. Not checked yet.Mandatory?
Counsel seeking to bring a device into the Courthouse for an appearance must, at least three business days before the appearance, file a letter (not letter motion) and completed Electronic Devices General Purposes Form, available at https://nysd.uscourts.gov/forms/fillable-form-electronic-devices-general-purpose.
Summary: Counsel must file a letter (not a letter motion) and a completed Electronic Devices General Purposes Form to bring a device into the Courthouse for an appearance.
Document Type
Letter
Machine summary. Not checked yet.Mandatory?
Any pro se party that wishes to participate in electronic case filing (“e-filing”) on ECF must file a Motion for Permission for Electronic Case Filing (available at https://nysd.uscourts.gov/forms/motion-permission-electronic-case-filing-pro-se-cases and in the Pro Se Intake Unit). If the Court grants a motion to participate in “e-filing,” that party will not receive hardcopies of any document filed electronically via ECF.
Summary: Pro se parties must file motion for e-filing permission; granted parties receive no hardcopies.
Document Type
Motion
Machine summary. Not checked yet.Mandatory?
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: Counsel must serve paper copies to pro se parties and file Affidavit of Service.
Document Type
Affidavit Of Service
Machine summary. Not checked yet.Mandatory?
Within 30 days of the completion of discovery unless otherwise ordered by the Court, a pro se plaintiff shall file a concise, written Pretrial Statement. This Statement need take no particular form, but it must contain the following: 1) a statement of the facts plaintiff hopes to prove at trial; 2) a list of all documents or other physical objects that the plaintiff plans to put into evidence at trial; and 3) a list of the names and addresses of all witnesses plaintiff intends to have testify at trial. The Statement must be sworn by the plaintiff to be true and accurate based on the facts known by the plaintiff.
Summary: Pro se plaintiff must file Pretrial Statement within 30 days of discovery completion.
Document Type
Pretrial Statement
Machine summary. Not checked yet.Mandatory?
Parties who file a motion to dismiss, a motion for judgment on the pleadings, or a motion for summary judgment must provide the pro se party with a copy of the notices required under SDNY Local Civil Rules 12.1 or 56.2.
Summary: Must provide pro se party with notices under LR 12.1 or 56.2 for certain motions.
Document Type
Motion
Machine summary. Not checked yet.Mandatory?
If the case is to be tried before only a Judge without a jury, any parties represented by counsel must also file proposed findings of fact and conclusions of law at the time of filing the Pretrial Statement. If the case is to be tried before a jury, any parties represented by counsel must also file proposed voir dire questions, a proposed jury charge, and a proposed verdict form at the time of filing the Pretrial Statement. At the time of filing, a represented party should email these documents to the Court in both .pdf and Microsoft Word formats. The pro se party may file such documents, but is not required to do so and need not submit them by email.
Summary: Represented parties must file additional pretrial documents by email; pro se parties optional.
Document Type
Pretrial Statement
Machine summary. Not checked yet.Mandatory?
Counsel seeking to bring a device into the Courthouse for an appearance must, at least three business days before the appearance, file a letter (not letter motion) and completed Electronic Devices General Purposes Form, available at https://nysd.uscourts.gov/forms/fillable-form-electronic-devices-general-purpose.
Summary: Must file letter and form 3 business days before bringing devices to courthouse.
Document Type
Letter
Machine summary. Not checked yet.Mandatory?
If counsel seek to bring an electronic device to the walk-through or appearance, they must first complete the steps required by the Court’s Individual Rule 6.A.
Summary: Must complete Individual Rule 6.A steps before bringing devices to walk-through.
Document Type
Electronic Devices Form
Machine summary. Not checked yet.Mandatory?
Unless otherwise ordered by the Court, within 30 days from the Court’s decision on a summary judgment motion, the parties must file on ECF a proposed Joint Pretrial Order.
Summary: Joint Pretrial Order must be filed within 30 days of summary judgment decision.
Document Type
Joint Pretrial Order
Machine summary. Not checked yet.Mandatory?
A list of all trial witnesses, indicating whether such witnesses will testify in person or by deposition, whether such witnesses will require an interpreter (and, if so, which party will pay the costs for the interpreter), a brief summary of the substance of each witness’s testimony, and the expected duration of direct and cross-examination for each witness. Absent leave of Court, a witness listed by both sides may testify only once (with defendant permitted to go beyond the scope of the direct on cross-examination), and counsel should confer with respect to scheduling;
Summary: Witness list must include testimony method, interpreter needs, summary, and duration; witnesses listed by both sides may testify only once.
Document Type
Joint Pretrial Order
Machine summary. Not checked yet.Mandatory?
A statement of the damages claimed and any other relief sought, including the manner and method used to calculate any claimed damages and a breakdown of the elements of such claimed damages;
Summary: Damages statement must include calculation method and breakdown of claimed damages.
Document Type
Joint Pretrial Order
Machine summary. Not checked yet.Mandatory?
Unless otherwise ordered by the Court, at the time the joint pretrial order is filed in a jury case, the parties must: File and serve motions addressing any evidentiary issues or other matters
Summary: In jury cases, parties must file and serve motions addressing evidentiary issues when filing Joint Pretrial Order.
Document Type
Evidentiary Motions
Machine summary. Not checked yet.Mandatory?
A statement confirming that the parties have submitted all pretrial submissions and courtesy copies required herein.
Summary: Joint Pretrial Order must include statement confirming all required submissions and courtesy copies.
Document Type
Joint Pretrial Order
Machine summary. Not checked yet.Mandatory?
A list by each party of exhibits to be offered in its case in chief, with one asterisk indicating an exhibit to which a party objects on the grounds of authenticity and two asterisks indicating an exhibit to which a party objects to the admissibility of the exhibit. If a party objects to an exhibit, the objection should be noted by indicating the grounds for the objection, with citations to the Federal Rule of Evidence and any other authority. Objections not made will be waived. If any party believes that the Court should rule on the objection in advance of trial, that party should include a notation to that effect (e.g., “Advance Ruling Requested”) as well. In most cases, the Court will rule on relevance and authenticity objections at the time of trial;
Summary: Exhibit list must use asterisks for objections (1 for authenticity, 2 for admissibility) with FRE citations; objections not made are waived.
Document Type
Joint Pretrial Order
Machine summary. Not checked yet.Mandatory?
contain a table of contents, a table of authorities, and a certification of the word count, none of which will count against the word limit. All appendices to memoranda of law must be tabbed and indexed.
Summary: Memoranda must include TOC, TOA, and word count certification (excluded from word limit); appendices must be tabbed and indexed.
Document Type
Memorandum Of Law
Machine summary. Not checked yet.Mandatory?
At least ten days before the conference date, the parties must file on ECF: (1) a proposed Civil Case Management Plan and Scheduling Order, available on the Court’s website at (https://nysd.uscourts.gov/hon-jennifer-l-rochon); and (2) a joint letter, not to exceed three pages, describing the case, any contemplated motions, and the prospect for settlement.
Summary: Initial pretrial conference requires 10-day filing of case management plan and 3-page joint letter.
Document Type
Pretrial Conference
Machine summary. Not checked yet.Mandatory?
The Joint Pretrial Order must include the information required by Federal Rule of Civil Procedure 26(a)(3) and the following:
Summary: Joint Pretrial Order must include FRCP 26(a)(3) information plus additional requirements.
Document Type
Joint Pretrial Order
Machine summary. Not checked yet.Mandatory?
A designation by each party of deposition testimony to be offered in its case in chief and any counter-designations and objections by any other party. In addition to a designation list, the parties must provide the complete deposition transcript with color-coded highlighting indicating the portions designated by either party and the objections listed in the margins;
Summary: Deposition designations must include complete transcript with color-coded highlighting and margin objections.
Document Type
Joint Pretrial Order
Machine summary. Not checked yet.Mandatory?
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., 11-cv-01234 [rel. 10-cv-04321]).
Summary: Related cases must include both docket numbers in all filings.
Document Type
All
Machine summary. Not checked yet.Mandatory?
In accordance with the ECF Rules & Instructions, all attorneys representing parties are required to register promptly as ECF filers and to enter an appearance in the case.
Summary: All attorneys must register as ECF filers and enter appearance.
Document Type
Notice Of Appearance
Machine summary. Not checked yet.Mandatory?
In cases where any party is a partnership, limited partnership, limited liability company, or trust, the letter must identify and state the citizenship of each of the entity's members, shareholders, partners, and/or trustees.
Summary: Partnership/LLC/trust parties must state citizenship of all members
Document Type
Joint Letter
Machine summary. Not checked yet.Mandatory?
Where any party is a corporation, the letter must state both the place of incorporation and the principal place of business.
Summary: Corporate parties must state place of incorporation and principal place of business
Document Type
Joint Letter
Machine summary. Not checked yet.Mandatory?
In any action in which subject matter jurisdiction is founded on diversity of citizenship pursuant to 28 U.S.C. § 1332, the party asserting the existence of such jurisdiction must include in their joint letter to the Court prior to the Initial Pretrial Conference the basis for that party's belief that diversity of citizenship exists.
Summary: Diversity jurisdiction requires joint letter stating basis for citizenship diversity
Document Type
Joint Letter
Machine summary. Not checked yet.Mandatory?
The Joint Pretrial Order must include the information required by Federal Rule of Civil Procedure 26(a)(3) and the following:
Summary: Joint Pretrial Order must include FRCP 26(a)(3) information plus additional requirements.
Document Type
Joint Pretrial Order
Machine summary. Not checked yet.Mandatory?
Unless otherwise ordered by the Court, within 30 days from the Court’s decision on a summary judgment motion, the parties must file on ECF a proposed Joint Pretrial Order.
Summary: Joint Pretrial Order must be filed within 30 days of summary judgment decision.
Document Type
Joint Pretrial Order
Machine summary. Not checked yet.Mandatory?
A statement confirming that the parties have submitted all pretrial submissions and courtesy copies required herein.
Summary: Joint Pretrial Order must include statement confirming all required submissions.
Document Type
Joint Pretrial Order
Machine summary. Not checked yet.Mandatory?
If counsel seek to bring an electronic device to the walk-through or appearance, they must first complete the steps required by the Court’s Individual Rule 6.A.
Summary: Must complete Rule 6.A steps before bringing device to walk-through
Document Type
Electronic Device Request
Filing & Service rules
Electronic Filing Rules
Letters to the Court must be filed electronically on ECF; letters seeking relief should be filed as letter motions, not ordinary letters.
Letters must be filed electronically on the Electronic Case Filing system ("ECF"). Letters seeking relief (if consistent with the SDNY Local Rules and the SDNY ECF Rules and Instructions) should be filed on ECF as letter motions, not as ordinary letters.
Machine summary. Not checked yet. · Civil cases
Page 1 | 1.A
All attorneys must register promptly as ECF filers and enter an appearance in the case.
In accordance with the ECF Rules & Instructions, all attorneys representing parties are required to register promptly as ECF filers and to enter an appearance in the case.
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Page 2 | 1.H
Letter motions must be filed on ECF; all requests for adjournments, extensions, and pre-motion conferences must be filed as letter motions.
Letter motions must be filed on ECF in accordance with the SDNY Local Rules and the ECF Rules and Instructions. In particular, all requests for adjournments, extensions, and pre-motion conferences (including pre-motion conferences with respect to discovery disputes) must be filed as letter motions.
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Page 5 | H
The moving party should file the TRO motion, supporting documents, and proposed order on ECF.
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.
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Page 6 | L
Default judgment must be sought by motion on ECF under FRCP 55(b)(2) and Local Rule 55.2, not by order to show cause.
A plaintiff seeking a default judgment must proceed by filing a motion for default judgment on ECF pursuant to Federal Rule of Civil Procedure 55(b)(2) and SDNY Local Civil Rule 55.2. A plaintiff seeking a default judgment should not proceed by order to show cause.
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Page 7 | O. Default Judgments
All parties' counsel must file a notice of appearance on ECF promptly upon removal.
Counsel for all parties must file on ECF a notice of appearance in this Court promptly upon removal.
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Page 8 | 4. Other Pretrial Guidance - A. Cases Removed from State Court
The proposed Joint Pretrial Order must be filed electronically on ECF.
the parties must file on ECF a proposed Joint Pretrial Order
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Page 11 | 5. Trial Procedures
Documentary exhibits and demonstratives must not be filed on ECF; they are submitted to the Court and served on opposing counsel.
Submit to the Court and serve on opposing counsel, but do not file on ECF, all documentary exhibits and demonstratives.
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Page 13 | B
Letters solely between parties or not addressed to the Court may not be filed on ECF or sent to the Court, except as exhibits.
Letters solely between parties or their counsel or otherwise not addressed to the Court may not be filed on ECF or otherwise sent to the Court (except as exhibits to an otherwise properly filed document).
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Page 1 | 1.A
Counsel must keep ECF contact information current, check the docket regularly, and review actual court orders on ECF rather than relying solely on NEF descriptions.
for updating their contact information on ECF should it change; they should not file a letter motion advising the Court of the change. Counsel are also responsible for checking the docket sheet regularly, regardless of whether they receive an ECF notification of case activity. Under ECF Rule 4.3, counsel “have an obligation to review the Court’s actual order, decree, or judgment, as available on ECF, and should not rely on the description of such order, decree or judgment in the Notice of Electronic Filing (NEF) alone.”
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Page 3 | 1. Communications with Chambers
Filing Timing and Cure Windows
Opposing party must inform the Court within one business day of intent to respond and file the response within three business days; reply letters are not permitted.
If the opposing party wishes to respond to the letter, it must inform the Court within one business day that a responsive letter is forthcoming and file the letter within three business days. The same page limits and filing instructions apply. Reply letters are not permitted.
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Page 4 | 2.E Discovery Disputes
Removing party must file a copy of the state court docket sheet within three calendar days of 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 8 | 4. Other Pretrial Guidance - A. Cases Removed from State Court
Parties must file a proposed Joint Pretrial Order on ECF within 30 days of the Court's decision on a summary judgment motion.
Unless otherwise ordered by the Court, within 30 days from the Court's decision on a summary judgment motion, the parties must file on ECF a proposed Joint Pretrial Order.
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Page 11 | 5. Trial Procedures
The letter and completed Electronic Devices General Purposes Form must be filed at least three business days before the appearance.
Counsel seeking to bring a device into the Courthouse for an appearance must, at least three business days before the appearance, file a letter (not letter motion) and completed Electronic Devices General Purposes Form, available at https://nysd.uscourts.gov/forms/fillable-form-electronic-devices-general-purpose.
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Page 15 | 6. Policy on the Use of Electronic Devices
Motion papers must be filed promptly after service.
Motion papers must be filed promptly after service.
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Page 5 | E
Motions to exclude expert testimony must be made by the deadline for dispositive motions, not as a motion in limine.
Motions to exclude expert testimony must be made by the deadline for dispositive motions and should not be treated as a motion in limine.
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Page 6 | J
Service and Proof of Service Rules
After the Court sets a default judgment hearing, plaintiff must serve the motion papers and the Court's order, and file proof of service on ECF as directed.
If the Court issues such an order, the plaintiff must then serve on the party against whom default judgment is sought: (1) the motion for default judgment and supporting papers; and (2) the Court's order setting a date and time for the default judgment hearing. The plaintiff must file on ECF proof of such service on the docket in the manner and by the date specified in the Court's order setting the default judgment hearing.
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Page 8 | O. Default Judgments
Plaintiff must serve the default judgment motion and supporting papers and file an affidavit of service on ECF within 14 days of filing the motion.
The plaintiff must serve the motion for default judgment and supporting papers on the party against whom the default judgment is sought and file an affidavit of service on ECF within 14 days of filing the motion for default judgment.
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Page 8 | O. Default Judgments
Plaintiff's counsel (or Defendant's counsel in removed actions) must promptly distribute copies of the Notice of Initial Pretrial Conference to all parties.
Plaintiff’s counsel (or, in removed actions, Defendant’s counsel) is responsible for promptly distributing copies of the Notice to all parties.
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Page 3 | 2.D Initial Pretrial Conference
When a TRO motion is made on notice, the moving party should simultaneously serve documents on any party that will not receive electronic service via ECF.
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.
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Page 6 | L
Motions addressing evidentiary issues must be filed and served at the time the joint pretrial order is filed in a jury case.
File and serve motions addressing any evidentiary issues or other matters
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Page 12 | 5. Trial Procedures
Courtesy Copy Requirements
Government must email courtesy copies of plea agreements to Chambers within 3 business days before plea.
The Government shall provide a courtesy copy of the plea agreement, cooperation agreement, or Pimentel letter to the Court. These documents should be emailed to Chambers as soon as practicable, and no later than three business days before the scheduled plea.
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Page 3 | A. Plea / Cooperation Agreements and Pimentel Letters
Pretrial submissions require email to Chambers plus 2 courtesy hard copies in PDF and Word format.
At the time of filing, each party shall email to Chambers and supply Chambers with two courtesy hard copies of these materials in .pdf and, with the exception of in limine motions, Microsoft Word format.
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Page 4 | A. Pretrial Submissions
Two courtesy copies of the parties' briefing must be submitted by the movant when the reply is served, labeled, double-sided, three-hole punched, and tabbed (not in binders); courtesy copies of declarations or exhibits are not required.
Two courtesy copies of the parties' briefing must be submitted via mail or hand delivery by the movant at the time that the reply is served, not by each party at the time of filing. The Court does not require courtesy copies of supporting declarations or exhibits. All courtesy copies must be labeled as such and should be double-sided, three-hole punched, and tabbed such that they can be placed in binders. The copies should not, however, be submitted in binders.
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Page 5 | F
Two courtesy copies of all pretrial documents must be sent to Chambers via mail or hand delivery on the service/filing date; exhibits submitted electronically only.
Two courtesy copies of all documents identified in Sections 5.A-C above should be submitted to Chambers via mail or hand delivery on the date on which they are to be served or filed, except that counsel should submit exhibits only in electronic form.
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Page 14 | D
Pro se parties must file papers with Pro Se Intake Unit with one courtesy copy.
All papers to be filed with the Court by a pro se party, along with one courtesy copy of those papers, shall be delivered in person or by mail to the Pro Se Intake Unit, 500 Pearl Street, New York, NY 10007.
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Page 2 | Filing of Papers and Service
Non-pro se parties must submit courtesy copy with reply; no copies if all pro se.
One courtesy hard copy of all formal motion papers, marked as such, should be submitted to Chambers by the non-pro se party at the time the reply is due. Courtesy copies should not be submitted to Chambers at the time of filing. If all the parties are pro se, then no courtesy copies of formal motion papers are required.
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Courtesy copies must be labeled, double-sided, three-hole punched, and tabbed (not in binders).
All courtesy copies must be labeled as such and should be double-sided, three-hole punched, and tabbed such that they can be placed in binders but the copies should not be submitted in binders.
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Unredacted courtesy copies required for sealed/redacted filings, with redacted portions highlighted.
If the parties have redacted or filed under seal any portion of the motion papers or attendant exhibits, courtesy copies are to be unredacted, but the portions redacted from public filings should be highlighted.
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Two courtesy copies of memorandum of law required via mail/hand delivery when reply is served.
Two courtesy copies memorandum of law must be submitted via mail or hand delivery by the movant at the time that the reply is served, not by each party at the time of filing.
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Two courtesy copies required for documents in Sections 5.A-C, except exhibits in electronic form only.
Two courtesy copies of all documents identified in Sections 5.A-C above should be submitted to Chambers via mail or hand delivery on the date on which they are to be served or filed, except that counsel should submit exhibits only in electronic form.
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AUSA must immediately contact Chambers to arrange conference/arraignment and provide courtesy copies of Indictment and Complaint via email.
Upon assignment of a criminal case to Judge Rochon, the Assistant United States Attorney ("AUSA") shall immediately contact Chambers to arrange for a conference / arraignment. The AUSA shall provide a courtesy copy of the Indictment and the criminal Complaint, if one exists, to the Court as soon as practicable via email to the Chambers email address (RochonNYSDChambers@nysd.uscourts.gov).
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Page 1 | Communications with Chambers
Government must email courtesy copies of plea agreements to Chambers 3 business days before plea.
The Government shall provide a courtesy copy of the plea agreement, cooperation agreement, or Pimentel letter to the Court. These documents should be emailed to Chambers as soon as practicable, and no later than three business days before the scheduled plea.
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Page 3 | Guilty Pleas
Two courtesy hard copies required for pretrial submissions in PDF and Word format.
At the time of filing, each party shall email to Chambers and supply Chambers with two courtesy hard copies of these materials in .pdf and, with the exception of in limine motions, Microsoft Word format.
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Page 4 | Trials
Courtesy copies required for filings over 10 pages.
The filing party shall mail or hand deliver one courtesy hard copy to Chambers of any filing or submission greater than 10 pages in length at the time of its submission, unless otherwise addressed above.
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Page 6 | Courtesy Copies
Pro se parties must file papers with Pro Se Intake Unit with one courtesy copy.
All papers to be filed with the Court by a pro se party, along with one courtesy copy of those papers, shall be delivered in person or by mail to the Pro Se Intake Unit, 500 Pearl Street, New York, NY 10007.
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Page 2 | Filing of Papers and Service
Courtesy copies of letters filed on ECF should not be submitted.
Parties should not submit courtesy copies of letters filed on ECF.
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Page 1 | 1.A
Hand-delivered mail must go to the Worth Street courthouse entrance, not directly to Chambers, unless prior permission is given.
Hand-delivered mail should be taken to the Worth Street entrance of the Daniel Patrick Moynihan United States Courthouse, 200 Worth Street, New York, NY 10007, and may not be brought directly to Chambers (unless prior permission is given).
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Page 2 | 1.E
No courtesy copies required for supporting declarations or exhibits.
The Court does not require courtesy copies of supporting declarations or exhibits.
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Sealing & Redaction Procedures
Letters under seal or containing sensitive or confidential information must be filed on ECF per the Court's Standing Order and ECF Rules.
Letters to be filed under seal or containing sensitive or confidential information must be filed on ECF in conformity with the Court's Standing Order, 19-MC-00583, and ECF Rules & Instructions, Section 6.
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Page 1 | 1.A
Parties must redact five categories of sensitive information and may redact six categories requiring caution without Court approval, per FRCP 5.2 and the SDNY Privacy Policy.
The parties are referred to Federal Rule of Civil Procedure 5.2 and the SDNY ECF Privacy Policy ("Privacy Policy") and reminded not to include, unless necessary, the five categories of "sensitive information" in their submissions (i.e., social security numbers [use the last four digits only], names of minor children [use the initials only], dates of birth [use the year only], financial account numbers [use the last four digits only], and home addresses [use the City and State only]). Parties may redact the five categories of "sensitive information" and the six categories of information requiring caution (i.e., personal identifying number, medical records [including information regarding 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, without Court approval.
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Page 8 | 4. Other Pretrial Guidance - B. Redactions and Filing Under Seal
Sealed filing motions must be filed on ECF in public view with reasons, supporting papers filed separately, and the proposed sealed document contemporaneously filed under seal on ECF.
Motions or letter motions for approval of sealed filings in civil and miscellaneous cases and the subject documents, including the proposed sealed document(s), must be filed on ECF in conformity with the Court's Standing Order, 19-MC-00583, and Section 6 of the ECF Rules & Instructions (https://nysd.uscourts.gov/rules/ecf-related-instructions). The motion must be filed in public view, must explain the particular reasons for seeking to file that information under seal and should not include confidential information sought to be filed under seal. Supporting papers must be separately filed on ECF and may be filed under seal or redacted only to the extent necessary to safeguard information sought to be filed under seal. The proposed sealed document must be contemporaneously filed under seal on ECF and electronically related to the motion.
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Page 9 | B.iii(b)
All redactions require Court approval and must be narrowly tailored and consistent with the presumption of public access.
all redactions require Court approval. 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.
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Page 9 | B.iii
When sealing is at another party's request, that party must be notified to file a letter within three days explaining the need to seal or redact.
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 must notify the opposing party or third party that it must file, within three days, a letter explaining the need to seal or redact the document.
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Page 9 | B.iii(a)
Redacted filing motions must be filed on ECF in public view; the filing party must publicly file the redacted document and file under seal the unredacted version with redactions highlighted.
Motions or letter motions for approval to file a document in redacted form must be filed on ECF in conformity with the Court's Standing Order, 19-MC-00583, and Section 6 of the ECF Rules & Instructions (https://nysd.uscourts.gov/rules/ecf-related-instructions). The motion itself must 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 filing party must: (a) publicly file the document with the proposed redactions; and (b) file under seal a copy of the unredacted document with the proposed redactions highlighted. Both documents must be filed on ECF and related to the motion.
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Page 10 | B.iii(c)
Meet and confer required before filing sealed/redacted materials; opposing parties must respond within 3 days if requested by another party.
(a) 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 must notify the opposing party or third party that it must file, within three days, a letter explaining the need to seal or redact the document.
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Page 9 | (a) Meet and Confer
Procedures for filing sealed/redacted documents require meeting and confer, specific filing methods, and notification requirements.
Any party seeking to file a document under seal or in redacted form must proceed as follows:
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Page 9 | iii. Procedures for Filing Sealed / Redacted Documents
Sealed documents must be filed on ECF with public motion explaining reasons, supporting papers filed separately, and proposed sealed document filed under seal and related to motion.
(b) Sealed Document(s). Motions or letter motions for approval of sealed filings in civil and miscellaneous cases and the subject documents, including the proposed sealed document(s), must be filed on ECF in conformity with the Court's Standing Order, 19-MC-00583, and Section 6 of the ECF Rules & Instructions (https://nysd.uscourts.gov/rules/ecf-related-instructions). The motion must be filed in public view, must explain the particular reasons for seeking to file that information under seal and should not include confidential information sought to be filed under seal. Supporting papers must be separately filed on ECF and may be filed under seal or redacted only to the extent necessary to safeguard information sought to be filed under seal. The proposed sealed document must be contemporaneously filed under seal on ECF and electronically related to the motion. The summary docket text, but not the sealed
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Page 9 | (b) Sealed Document(s)
Paper filing of sealed documents requires motion for leave of court if unable to comply with ECF requirements.
(d) Submission by Paper. Any party unable to comply with the requirement for electronic filing under seal on ECF, or who has reason to believe that a particular document should not be filed on ECF, must move for leave of the Court to file on paper.
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Page 10 | (d) Submission by Paper
Redacted documents require public motion explaining reasons, public filing with proposed redactions, and sealed filing of unredacted version with redactions highlighted.
(c) Redacted Document(s). Motions or letter motions for approval to file a document in redacted form must be filed on ECF in conformity with the Court's Standing Order, 19-MC-00583, and Section 6 of the ECF Rules & Instructions (https://nysd.uscourts.gov/rules/ecf-related-instructions). The motion itself must 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 filing party must: (a) publicly file the document with the proposed redactions; and (b) file under seal a copy of the unredacted document with the proposed redactions highlighted. Both documents must be filed on ECF and related to the motion.
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Page 10 | (c) Redacted Document(s)
Sealed or confidential letters must follow specific filing procedures.
Letters to be filed under seal or containing sensitive or confidential information must be filed on ECF in conformity with the Court's Standing Order, 19-MC-00583, and ECF Rules & Instructions, Section 6.
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Page 1 | Communications with Chambers
Procedures for filing sealed or redacted documents
Any party seeking to file a document under seal or in redacted form must proceed as follows:
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Page 9 | iii. Procedures for Filing Sealed / Redacted Documents
Sealed documents must be filed on ECF following specific procedures
(b) Sealed Document(s). Motions or letter motions for approval of sealed filings in civil and miscellaneous cases and the subject documents, including the proposed sealed document(s), must be filed on ECF in conformity with the Court's Standing Order, 19-MC-00583, and Section 6 of the ECF Rules & Instructions (https://nysd.uscourts.gov/rules/ecf-related-instructions).
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Page 9 | iii. Procedures for Filing Sealed / Redacted Documents
Meet and confer required before filing sealed/redacted materials
(a) 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.
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Page 9 | iii. Procedures for Filing Sealed / Redacted Documents
Paper filing requires motion for leave of court
(d) Submission by Paper. Any party unable to comply with the requirement for electronic filing under seal on ECF, or who has reason to believe that a particular document should not be filed on ECF, must move for leave of the Court to file on paper.
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Page 10 | iii. Procedures for Filing Sealed / Redacted Documents
Redacted documents require public filing with proposed redactions and sealed unredacted copy
(c) Redacted Document(s). Motions or letter motions for approval to file a document in redacted form must be filed on ECF in conformity with the Court's Standing Order, 19-MC-00583, and Section 6 of the ECF Rules & Instructions (https://nysd.uscourts.gov/rules/ecf-related-instructions). The motion itself must 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 filing party must: (a) publicly file the document with the proposed redactions; and (b) file under seal a copy of the unredacted document with the proposed redactions highlighted. Both documents must be filed on ECF and related to the motion.
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Page 10 | iii. Procedures for Filing Sealed / Redacted Documents
Sensitive information categories must be redacted or limited in sentencing submissions.
For this reason, the parties are referred to the E-Government Act of 2002 and the SDNY’s ECF Privacy Policy (“Privacy Policy”) and reminded not to 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]).
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Page 5 | Privacy Policy
Redacted pages must be filed under seal; unredacted copy emailed to Chambers.
If any material is redacted from a publicly filed document, only those pages containing the redacted material will be filed under seal. The party shall email a copy of the unredacted material to Chambers for filing under seal.
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Page 5 | Redactions
Redactions beyond 12 categories require application filed with sentencing submission.
If redactions are sought beyond the 12 categories of information identified in the Privacy Policy, an application to do so must be served and filed at the time the sentencing submission is served. The application should clearly identify the redaction and explain the reasons for the redaction. The application will be addressed at the sentencing proceeding.
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Page 6 | Redactions
When motion papers are redacted or sealed, courtesy copies must be unredacted with the redacted portions highlighted.
If the parties have redacted or filed under seal any portion of the motion papers or attendant exhibits, courtesy copies are to be unredacted, but the portions redacted from public filings should be highlighted.
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Page 5 | F
Party consent or a confidentiality agreement alone is not a valid basis to overcome the presumption of public access to judicial documents.
In general, the parties' consent or the fact that information is subject to a confidentiality agreement 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 9 | B.iii
Parties seeking to file sealed or redacted materials should meet and confer with opposing parties in advance to narrow the scope.
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.
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Page 9 | B.iii(a)
Parties unable to e-file under seal on ECF, or who believe a document should not be filed on ECF, must move for leave to file on paper.
Any party unable to comply with the requirement for electronic filing under seal on ECF, or who has reason to believe that a particular document should not be filed on ECF, must move for leave of the Court to file on paper.
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Page 10 | B.iii(d)
Parties must redact sensitive information categories without court approval per FRCP 5.2 and SDNY Privacy Policy.
The parties are referred to Federal Rule of Civil Procedure 5.2 and the SDNY ECF Privacy Policy and reminded not to include, unless necessary, the five categories of 'sensitive information' in their submissions (i.e., social security numbers [use the last four digits only], names of minor children [use the initials only], dates of birth [use the year only], financial account numbers [use the last four digits only], and home addresses [use the City and State only]). Parties may redact the five categories of 'sensitive information' and the six categories of information requiring caution (i.e., personal identifying number, medical records [including information regarding 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, without Court approval.
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Redactions of sensitive information categories don't require court approval.
Parties may redact the five categories of “sensitive information” and the seven 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, without Court approval.
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Page 5 | Redactions
Filing Bundling Requirements
Motion papers must be filed promptly after service.
Motion papers must be filed promptly after service.
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Pre-Motion Conference Requirements
Parties must confer in good faith with the opposing party before raising a discovery dispute; the Court will not consider disputes without this conference.
Any party wishing to raise a discovery dispute with the Court must first confer in good faith with the opposing party, in person or by telephone, in an effort to resolve the dispute. The Court enforces this requirement in both counseled and pro se cases (except where not feasible, such as when the pro se litigant is incarcerated) and will not consider any discovery dispute where the moving party has not satisfied the good-faith conference requirement.
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Page 4 | 2.E Discovery Disputes
To move for summary judgment or exclude expert testimony, a party must file a pre-motion letter (max 3 pages) on ECF no later than three weeks before the post-discovery pretrial conference; other parties respond two weeks before the conference.
If a party wishes to move for summary judgment or to exclude expert testimony, it must, no later than three weeks before the post discovery pre-trial conference, request that the conference serve as a pre-motion conference. To so request, the moving party must file a letter on ECF, not to exceed three pages in length, setting forth the basis for the anticipated motion, including the legal standards governing the claims at issue. Other parties must respond two weeks before the conference.
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Page 5 | I
A party must confer with its adversary before applying for a temporary restraining order unless FRCP 65(b) requirements are met.
A party must confer with his or her 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 6 | L
Parties must meet and confer in good faith before filing a motion in limine, and the motion must state the conference occurred and was unsuccessful.
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. Any motion in limine must include a representation that the meet-and-confer process occurred and was unsuccessful;
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Page 13 | B
Discovery disputes require letter-motion (max 3 pages) and 5-day response.
If there are any discovery disputes, the parties are required to confer with one another in an effort to resolve the dispute without the need for Court intervention. If the parties are unable to resolve their dispute, either party may file a letter-motion, no longer than three pages and in accordance with Section 1 above, explaining the nature of the dispute and requesting an informal conference. If the opposing party wishes to respond to the letter, it must file a responsive letter within five business days, not to exceed three pages.
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Opposing party must notify Court within 1 business day and file response within 3 business days; reply letters not permitted.
If the opposing party wishes to respond to the letter, it must inform the Court within one business day that a responsive letter is forthcoming and file the letter within three business days. The same page limits and filing instructions apply. Reply letters are not permitted.
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Pre-motion conferences not required except for discovery motions and summary judgment motions.
Pre-motion conferences are not required, except for motions concerning discovery, which are governed by Section 2.E above, and for summary-judgment motions, which are governed by Section 3.I below.
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Good-faith conference required before filing discovery disputes; Court will not consider disputes without this requirement met.
Any party wishing to raise a discovery dispute with the Court must first confer in good faith with the opposing party, in person or by telephone, in an effort to resolve the dispute. The Court enforces this requirement in both counseled and pro se cases (except where not feasible, such as when the pro se litigant is incarcerated) and will not consider any discovery dispute where the moving party has not satisfied the good-faith conference requirement.
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Expert testimony exclusion motions must meet dispositive motion deadline, not treated as in limine.
Motions to exclude expert testimony must be made by the deadline for dispositive motions and should not be treated as a motion in limine.
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Pre-motion conference required for summary judgment/expert testimony motions, requested 3 weeks before post-discovery pretrial conference.
If a party wishes to move for summary judgment or to exclude expert testimony, it must, no later than three weeks before the post discovery pre-trial conference, request that the conference serve as a pre-motion conference.
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Pre-motion conferences are not required except for discovery motions and summary-judgment motions.
Pre-motion conferences are not required, except for motions concerning discovery, which are governed by Section 2.E above, and for summary-judgment motions, which are governed by Section 3.I below.
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Page 4 | 3.A Pre-Motion Conferences in Civil Cases
Good-faith conference requires meaningful dialogue, not just sending letters/emails; must attempt to resolve issues.
The moving party should note that “good-faith conference” does not mean that it has merely sent its adversary a letter or email, to which the adversary has not yet responded. The Court expects that, at a minimum, the moving party will have called its adversary and made efforts to engage in a meaningful dialogue, in an attempt to resolve any discovery issues.
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Pre-motion submissions not required for pro se parties.
Pre-motion submissions are not required from pro se parties for any motions.
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Court will discuss anticipated summary judgment motions at post-discovery pretrial conference.
The Court will review and discuss with counsel any anticipated summary-judgment motions at the post-discovery pretrial conference.
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Adjournment & Extension Requirements
Modifications/extensions require written application at least two business days before deadline
This Order may not be modified or the dates herein extended, except by further Order of the Court for good cause shown (except as provided in paragraphs 7(f) and 8(d)). 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 less than two business days prior to the expiration of the date sought to be extended.
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Page 4 | Paragraph 21
All adjournment or extension requests must be in writing and filed on ECF as letter motions.
All requests for adjournments or extensions of time must be made in writing and filed on ECF as letter motions.
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Page 2 | 1.F
Adjournment of a court appearance must be requested at least two business days before the appearance, absent an emergency.
If the request is for an adjournment of a court appearance, absent an emergency, the request must be made at least two business days prior to the scheduled appearance.
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Page 2 | 1.F
Extension requests must be made at least one business day before the deadline, absent unforeseen circumstances.
To be considered, extension requests must be made at least one business day prior to the deadline, absent unforeseen circumstances.
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Page 2 | 1.F
Adjournment or extension letter motions must state the original and new dates, prior request history, and the adversary's position.
The letter motion must state: (1) the original due date, the date or dates sought to be extended, and the new date the party now seeks through an adjournment or extension; (2) the number of previous requests for adjournment or extensions of time; (3) whether those previous requests were granted or denied; and (4) whether the adversary consents, and, if not, the reasons given by the adversary for refusing to consent.
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Page 2 | 1.F
Extension requests made after the original deadline will be denied absent extraordinary circumstances.
Absent extraordinary circumstances, requests for extensions will be denied if not made before the expiration of the original deadline.
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Page 2 | 1.F
Adjournment/extension requests must include specific required elements.
All requests for adjournments or extensions of time must be made in writing to the Pro Se Intake Unit, 500 Pearl Street New York, NY 10007 and must state: (1) the original date(s); (2) the number of previous requests for adjournment or extension; (3) whether these previous requests were granted or denied; (4) the reasons for the requested extension; (5) whether the adversary consents and, if not, the reasons given by the adversary for refusing to consent; and (6) the date of the parties’ next scheduled appearance before the Court.
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Page 2 | Communications with Chambers
Adjournment/extension requests require 48-hour advance notice (except emergencies).
Absent an emergency, any request for an extension or adjournment shall be made at least 48 hours prior to the deadline or scheduled appearance.
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Page 2 | Communications with Chambers
Opposition papers due in 4 weeks, reply papers in 2 weeks.
Unless otherwise ordered by the Court, opposing papers must be served and filed within four weeks 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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Defendant must file Pretrial Statement within 2 weeks of plaintiff's service.
Two weeks after service of plaintiff's Statement, the defendant must file and serve a similar Statement of its case containing the same information.
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Court appearance adjournments require 2 business days advance notice.
If the request is for an adjournment of a court appearance, absent an emergency, the request must be made at least two business days prior the scheduled appearance.
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Page 2 | Communications with Chambers
Affected adjournments require a revised case management plan.
If the requested adjournment or extension affects any other scheduled dates, a proposed Revised Civil Case Management Plan and Scheduling Order must be attached.
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Page 2 | Communications with Chambers
Conference adjournments require three alternative dates.
If the parties are requesting an adjournment of a conference, they must also provide three mutually agreeable alternative dates.
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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.
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Page 2 | Communications with Chambers
Adjournment requests must include original date, new date, previous requests, and adversary position.
The letter motion must state: (1) the original due date, the date or dates sought to be extended, and the new date the party now seeks through an adjournment or extension; (2) the number of previous requests for adjournment or extensions of time; (3) whether those previous requests were granted or denied; and (4) whether the adversary consents, and, if not, the reasons given by the adversary for refusing to consent.
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Page 2 | Communications with Chambers
TRO request must specify requested time frame for Court action.
The moving party must give notice of the time frame requested for Court action.
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Conference required before TRO application unless Rule 65(b) requirements met.
A party must confer with his or her 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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TRO letter must state adversary notification status and consent or Rule 65(b) satisfaction.
As soon as a party decides to seek a temporary restraining order, that party must file a letter on ECF (or in person 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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Adjournment requests must be made at least 48 hours in advance (72 hours for sentencing adjournments), except in emergencies.
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 and any request for adjournment of sentencing shall be made at least 72 hours prior to the scheduled proceedings.
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Page 1 | Communications with Chambers
Adjournment/extension requests must be filed as letter-motions on ECF, not ordinary letters.
All requests for adjournments or extensions of time must be made in writing and filed on ECF as letter-motions in accordance with Sections 2.B and 4.A, not as ordinary letters.
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Page 1 | Communications with Chambers
24-hour advance notice required for bail appeal conferences with specific materials.
A party who wishes to appeal an adverse bail determination by the Magistrate Judge should contact Chambers to arrange a conference for that purpose. The party that brings the appeal is directed to provide the Court no fewer than 24 hours before the conference with the transcript of argument on bail before the Magistrate Judge, any written submissions below as to bail, and Pretrial Services' report as to the defendant.
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Page 3 | Bail
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 2(E) above.
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Page 5 | Sentencing Adjournments
Applications to modify/extend dates must be made in writing at least 2 business days before expiration.
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 less than two business days prior to the expiration of the date sought to be extended.
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Adjournment/extension requests must be in writing to Pro Se Intake Unit with specific required elements.
All requests for adjournments or extensions of time must be made in writing to the Pro Se Intake Unit, 500 Pearl Street New York, NY 10007 and must state: (1) the original date(s); (2) the number of previous requests for adjournment or extension; (3) whether these previous requests were granted or denied; (4) the reasons for the requested extension; (5) whether the adversary consents and, if not, the reasons given by the adversary for refusing to consent; and (6) the date of the parties' next scheduled appearance before the Court.
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Page 2 | Communications with Chambers
If an adjournment or extension affects other scheduled dates, a proposed Revised Civil Case Management Plan and Scheduling Order must be attached.
If the requested adjournment or extension affects any other scheduled dates, a proposed Revised Civil Case Management Plan and Scheduling Order must be attached.
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Page 2 | 1.F
Conference adjournment requests must include three mutually agreeable alternative dates.
If the parties are requesting an adjournment of a conference, they must also provide three mutually agreeable alternative dates.
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Page 2 | 1.F
Counsel may extend default brief deadlines by joint stipulation submitted to the Court no later than two business days before the brief is due.
Counsel may extend the default deadlines by joint stipulation submitted to the Court no later than two business days before the brief is due.
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Page 11 | 5. Trial Procedures
Extension requests must be made before the original deadline.
Absent extraordinary circumstances, requests for extensions will be denied if not made before the expiration of the original deadline.
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Page 2 | Communications with Chambers
Extension requests made after original deadlines are ordinarily denied.
Requests for extensions will ordinarily be denied if made after the expiration of the original deadlines.
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Page 1 | Communications with Chambers
Counsel may extend brief deadlines by joint stipulation up to two business days before due date.
Counsel may extend the default deadlines by joint stipulation submitted to the Court no later than two business days before the brief is due.
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Chambers Communication Rules
Electronic devices require 3 business days advance notice with letter and form.
Counsel seeking to bring a device into the Courthouse for an appearance shall, at least three business days before the appearance, file a letter (not letter motion) and completed Electronic Devices General Purposes Form.
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Electronic devices must be kept on silent in the courtroom.
If electronic devices are permitted inside the Courtroom, they MUST be kept on silent at all times.
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Technology walk-through required 2 weeks before evidentiary hearing or trial.
At least two weeks prior to an evidentiary hearing or trial, counsel should contact Chambers by phone to coordinate a time for a technology walk-through of the Courtroom.
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Parties must email Chambers to alert the Court as soon as they reach a settlement agreement.
As soon as the parties reach an agreement to settle, the parties must email Chambers to alert the Court and file a joint letter on ECF promptly.
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Page 10 | C
Pro se parties must communicate with Pro Se Intake Unit in person or by mail, not Chambers.
All communications with the Court by a pro se party should be delivered in person or by mail. If delivered in person, the litigant should go to the Pro Se Intake Unit, United States Courthouse, 500 Pearl Street, Room 205, New York, NY 10007. For delivery by mail, the envelope should be addressed to the Pro Se Intake Unit, United States Courthouse, 500 Pearl Street, New York, NY 10007. No documents or court filings may be sent directly to Chambers. Pro se parties should not call or email Chambers and should communicate directly with the Pro Se Intake Unit.
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Page 2 | Communications with Chambers
Must contact chambers and AV department for tech walk-through before hearing/trial.
Prior to an evidentiary hearing or trial, counsel should contact Chambers by phone to coordinate a time for a technology walk-through of the Courtroom and then contact the Audio and Visual Department at 212-805-0134 to schedule the walk-through.
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Page 15 | Policy on the Use of Electronic Devices
Electronic devices must be kept silent in courtroom.
If electronic devices are permitted inside the Courtroom, they MUST be kept silent at all times.
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Page 15 | Policy on the Use of Electronic Devices
Remote conferences require joint letter 48 hours prior with counsel contact info; max 2 attorneys per party.
At least 48 hours before a scheduled remote conference, the parties must file a joint letter to the Court on ECF containing a list of the names, telephone numbers, and email addresses of counsel who may speak during the conference. Absent permission of the Court, no more than two attorneys may speak on behalf of either party.
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Hand deliveries must go to Worth Street entrance, not directly to chambers.
Hand-delivered mail should be taken to the Worth Street entrance of the Daniel Patrick Moynihan United States Courthouse, 200 Worth Street, New York, NY 10007, and may not be brought directly to Chambers (unless prior permission is given).
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Page 2 | Communications with Chambers
Must schedule technology walk-through 2 weeks before hearing/trial
At least two weeks prior to an evidentiary hearing or trial, counsel should contact Chambers by phone to coordinate a time for a technology walk-through of the Courtroom and then contact the Audio and Visual Department at 212-805-0134 to schedule the walk-through.
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Page 15 | B. Technology Walk-Through
Hand-delivered mail must be left with Court Security Officers at Worth Street entrance, not brought directly to Chambers (except for USAO or Federal Defenders).
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 and may not be brought directly to Chambers, except by representatives of the United States Attorney's Office or the Federal Defenders of New York.
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Page 1 | Communications with Chambers
Faxes to Chambers are not permitted.
Faxes to Chambers are not permitted.
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Page 1 | Communications with Chambers
Initial email to Chambers must include defendant name, defense counsel info, detention status, interpreter needs, and other pertinent information.
The email shall include: (1) the defendant's name; (2) defense counsel's name and contact information; (3) whether the defendant(s) is/are detained (and if so, the relevant defendant's Reg. No.) or bailed; (4) whether any defendant requires an interpreter (and if so, the relevant language); and (5) any other pertinent information.
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Page 1 | Communications with Chambers
Communications with Chambers must be filed as ECF letters unless sealed or containing sensitive/confidential information.
Communications with Chambers shall be by letter, filed on ECF, unless there is a request to file a letter under seal or a letter containing sensitive or confidential information.
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Page 1 | Communications with Chambers
Technology walk-through required 2 weeks before hearing/trial; contact Chambers by phone.
At least two weeks prior to an evidentiary hearing or trial, counsel should contact Chambers by phone to coordinate a time for a technology walk-through of the Courtroom and then contact the Audio and Visual Department at 212-805-0134 to schedule the walk-through.
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Page 6 | Technology Walk-Through
Electronic devices in courtroom must be on silent; non-compliance may result in forfeiture.
If electronic devices are permitted inside the Courtroom, they MUST be kept on silent at all times. Non-compliance with this rule may result in forfeiture of the device for the remainder of the proceedings.
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Page 6 | Electronic Devices in the Courthouse
Pro se parties must communicate with Pro Se Intake Unit in person or by mail; no direct contact with Chambers.
All communications with the Court by a pro se party should be delivered in person or by mail. If delivered in person, the litigant should go to the Pro Se Intake Unit, United States Courthouse, 500 Pearl Street, Room 205, New York, NY 10007. For delivery by mail, the envelope should be addressed to the Pro Se Intake Unit, United States Courthouse, 500 Pearl Street, New York, NY 10007. No documents or court filings may be sent directly to Chambers. Pro se parties should not call or email Chambers and should communicate directly with the Pro Se Intake Unit.
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Page 1 | Communications with Chambers
Non-compliance with electronic device rules may result in device forfeiture.
Non-compliance with this rule may result in forfeiture of the device for the remainder of the proceedings.
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Communications with the Court must be by letter, except as otherwise provided.
Except as otherwise provided below, communications with the Court must be by letter.
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Page 1 | 1.A
Telephone calls to Chambers are permitted only for emergencies requiring immediate attention.
Telephone calls to Chambers are permitted only in emergency situations requiring immediate attention.
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Page 1 | 1.B
Conferences are held in person; remote requests require a joint ECF letter at least three business days before the conference with good cause shown.
Unless the Court orders otherwise, all conferences will be held in person in Courtroom 20B of the Daniel Patrick Moynihan United States Courthouse, 500 Pearl Street, New York, NY. If counsel jointly requests that the conference be held remotely, they must, at least three business days before the conference, file a letter on ECF so requesting, with good cause shown.
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Page 3 | 2.A In Person Conferences
Counsel should contact Chambers by phone to coordinate a technology walk-through before an evidentiary hearing or trial, then contact the Audio and Visual Department at 212-805-0134 to schedule it.
Prior to an evidentiary hearing or trial, counsel should contact Chambers by phone to coordinate a time for a technology walk-through of the Courtroom and then contact the Audio and Visual Department at 212-805-0134 to schedule the walk-through.
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Page 15 | 6. Policy on the Use of Electronic Devices
Non-compliance may result in device forfeiture.
Non-compliance with this rule may result in forfeiture of the device for the remainder of the proceedings.
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Page 15 | Policy on the Use of Electronic Devices
Phone calls to chambers are only allowed for emergencies.
Telephone calls to Chambers are permitted only in emergency situations requiring immediate attention.
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Page 1 | Communications with Chambers
For urgent hand deliveries, notify court security officers to alert chambers.
If the hand-delivered material 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 2 | Communications with Chambers
For urgent hand-delivered letters, ask Court Security Officers to notify Chambers immediately.
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 1 | Communications with Chambers
Telephone calls to Chambers should only be used for urgent matters.
Telephone calls to Chambers should be reserved only for urgent matters.
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Page 1 | Communications with Chambers
WiFi requests must be indicated on the Electronic Devices form.
If WiFi is requested, counsel shall check the appropriate box on the form.
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Technical ECF filing questions should be directed to the ECF Help Desk.
Technical questions pertaining to ECF filings should be directed to the ECF Help Desk at helpdesk@nysd.uscourts.gov or (212) 805-0800.
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Page 2 | 1.D
Email Chambers at RochonNYSDChambers@nysd.uscourts.gov for scheduling and calendar matters.
For scheduling and calendar matters, email Chambers at RochonNYSDChambers@nysd.uscourts.gov.
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Page 2 | 1.D
Technical ECF questions should be directed to the ECF Help Desk.
Technical questions pertaining to ECF filings should be directed to the ECF Help Desk at helpdesk@nysd.uscourts.gov or (212) 805-0800.
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Page 2 | Communications with Chambers
Email chambers for scheduling and calendar matters.
For scheduling and calendar matters, email Chambers at RochonNYSDChambers@nysd.uscourts.gov.
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Page 2 | Communications with Chambers
Electronic device use governed by Standing Order M10-468.
Attorneys’ use of electronic devices (including mobile telephones, personal electronic devices, computers, and printers) within the Courthouse and its environs is governed by the Court’s Standing Order M10-468, available at https://nysd.uscourts.gov/forms/standing-order-electronic-devices-general-purpose.
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Page 6 | Electronic Devices in the Courthouse
Junior Lawyer Participation Incentives
The Court encourages junior attorney participation in all proceedings and permits more than one attorney to argue per party to create junior attorney opportunities.
The Court encourages the participation of less experienced attorneys in all proceedings – including pretrial conferences, hearings on discovery disputes, oral arguments, and examinations of witnesses at trial – particularly where the attorneys played a substantial role in drafting the underlying filing or in preparing the relevant witness. The Court is amenable to permitting more than one attorney to argue for one party if this creates an opportunity for a junior attorney to participate.
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Page 3 | 2.C Participation by Junior Attorneys
Oral argument not heard in pro se matters unless ordered.
Unless otherwise ordered by the Court, argument will not be heard in pro se matters.
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Junior attorneys encouraged to participate in proceedings; multiple attorneys may argue to enable junior participation.
The Court encourages the participation of less experienced attorneys in all proceedings – including pretrial conferences, hearings on discovery disputes, oral arguments, and examinations of witnesses at trial – particularly where the attorneys played a substantial role in drafting the underlying filing or in preparing the relevant witness. The Court is amenable to permitting more than one attorney to argue for one party if this creates an opportunity for a junior attorney to participate.
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Junior attorneys encouraged to participate in proceedings; multiple attorneys may argue if it allows junior participation.
The Court encourages the participation of less experienced attorneys in all proceedings – including pretrial conferences, hearings on discovery disputes, oral arguments, and examinations of witnesses at trial – particularly where the attorneys played a substantial role in drafting the underlying filing or in preparing the relevant witness. The Court is amenable to permitting more than one attorney to argue for one party if this creates an opportunity for a junior attorney to participate.
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