Court Rules
Judge

Judge Nelson S. Roman

Individual Rules, Standing Orders & Policies

Rules last changed:
Southern District of New York

Limits & Logistics

Document Limits

Memorandum Of Law
25 pgs
Rule 56 1 Statement
25 pgs
Pre Motion Response Letter
3 pgs
Deposition Synopsis
1 pgs

Courtesy Copies

Courtesy copies

  • 1 copy
  • 1 copy • Upon Filing

Binding: Bound

Exhibits

  • 1 copy • At Time Of Joint Pretrial Order Filing

Binding: Tabbed Three Ring

In Limine Motions

  • 1 copy • Email • Upon Filing
  • 1 copy • Mail • Upon Filing
  • 2 copies • Hand Delivery • Upon Filing

Binding: Bound

Motion

  • 1 copy • Mail • When Served On Other Parties

Adjournments

48Hoursnotice
  • Adjournment requests must be made 48 hours in advance; attach revised scheduling order if other dates affected.
  • Adjournment and extension requests must be made at least 48 hours before the original deadline.
Affects Other Dates
  • Extension requests must be made before original deadline expires; otherwise denied absent extraordinary circumstances.
  • Adjournment/extension requests must be faxed to Chambers with specific required information.
  • Conference with adversary required before TRO unless Rule 65(b) requirements met.
  • +2 more

Request must include

Original DateNumber Of Previous RequestsPrevious Requests Granted Or DeniedReason For RequestAdversary PositionProposed New Dates
2Business Daysnotice
  • Brief extensions by stipulation require 2 business days advance notice.
  • Default bankruptcy appeal brief deadlines may be extended by stipulation submitted to the Court no later than two business days before the brief is due.
4Weeksnotice
  • Opposition papers must be filed and served within 4 weeks of motion service.
2Weeksnotice
  • Reply papers must be filed and served within 2 weeks of opposition.
  • Other parties must file similar Pretrial Statement within 2 weeks of pro se party's service.
30Daysnotice
  • Pro se parties must file Pretrial Statement within 30 days of discovery completion.
  • Parties must submit proposed findings within 30 days of discovery completion for bench trials.

Communication

Email

Chambers

romannysdchambers@nysd.uscourts.gov
EmergenciesScheduling
No status inquiries
Phone

Chambers

(877) 336-1839
Scheduling
Phone

Pro Se Clinic

(212) 659-6190
Scheduling
Hours: by appointment only
Phone

Clerk

(914) 390-4178
Scheduling
Phone

Chambers

(914) 390-4177
Emergencies
Fax

Chambers

(914) 390-4179
No status inquiries
Letter via fax

Chambers

No status inquiries
Phone

Chambers

Scheduling
No status inquiries
Letter via ECF

Chambers

Scheduling
No status inquiries
Cases:
Filters:AllMandatoryImportantFormattingTRO/InjunctionMemorandaExhibitsECF FilingSummary JudgmentEvidence/WitnessesLetters

Page & Word Limits6 rules

Page LimitsCivil cases

The quote is in the court's document. The summary is not checked yet.Mandatory?

The opposing party shall submit a letter, also not to exceed three

Summary: The opposing party's pre-motion-conference response letter is also limited to three pages (sentence continues beyond this excerpt).

Pre Motion Response Letter

3 pages

NSR Roman Amended Individual Practices in Civil Cases 8-24-2026 · Aug 2026 · p. 2
|Sec3. Pleadings and Motions - A. Pre-Motion Conferences
Page LimitsCivil cases

The quote is in the court's document. The summary is not checked yet.Mandatory?

Any Rule 56.1 statement in support of a motion for summary judgment is limited to no more than 25 pages, unless leave of the Court to file a longer document is obtained at least one week prior to the due date of such motion for summary judgment.

Summary: A Rule 56.1 statement supporting summary judgment is limited to 25 pages unless leave to file a longer document is obtained at least one week before the motion's due date.

Rule 56 1 Statement

25 pages

NSR Roman Amended Individual Practices in Civil Cases 8-24-2026 · Aug 2026 · p. 3
|Sec3. Pleadings and Motions - G. Summary Judgment Motions
Page LimitsCivil cases

The quote is in the court's document. The summary is not checked yet.Mandatory?

Unless prior permission has been granted, memoranda of law in support of and in opposition to motions are limited to 25 pages, and reply memoranda are limited to 10 pages.

Summary: Memoranda of law in support of and in opposition to motions are limited to 25 pages and reply memoranda to 10 pages, unless prior permission has been granted.

Memorandum Of Law

25 pages

Reply Memorandum

10 pages

Page LimitsCivil cases

The quote is in the court's document. The summary is not checked yet.Mandatory?

Submit to the Court and serve on opposing counsel, but shall not electronically file, all deposition excerpts which will be offered as substantive evidence, as well as a one-page synopsis of those excerpts for each deposition.

Summary: A synopsis of deposition excerpts is limited to one page per deposition.

Deposition Synopsis

1 pages

Page LimitsCivil cases

Machine summary. Not checked yet.Mandatory?

Unless prior permission has been granted, memoranda of law in support of and in opposition to motions are limited to 25 pages, and reply memoranda are limited to 10 pages.

Summary: Memoranda of law limited to 25 pages, reply memoranda to 10 pages.

25 pages

Applies to: Attorney

Reply Memorandum

10 pages

Applies to: Attorney

Page LimitsCivil cases

Machine summary. Not checked yet.Mandatory?

Any Rule 56.1 statement in support of a motion for summary judgment is limited to no more than 25 pages, unless leave of the Court to file a longer document is obtained at least one week prior to the due date of such motion for summary judgment.

Summary: Rule 56.1 statements limited to 25 pages unless leave obtained one week prior.

Rule 56 1 Statement

25 pages

Applies to: Attorney

Document Format Requirements9 rules

FormattingCivil cases

The quote is in the court's document. The summary is not checked yet.Mandatory?

All memoranda of law shall be in 12-point font or larger and be double-spaced.

Summary: All memoranda of law must use 12-point font or larger and be double-spaced.

Typography
Size12 pt
Line SpacingDouble
FormattingCivil cases

The quote is in the court's document. The summary is not checked yet.Mandatory?

All appendices to memoranda of law must be tabbed and indexed.

FormattingCivil cases

The quote is in the court's document. The summary is not checked yet.Mandatory?

All courtesy copies must be clearly marked as such, bound, and tabbed.

FormattingCivil cases

The quote is in the court's document. The summary is not checked yet.Mandatory?

When seeking a preliminary injunction and/or temporary restraining order, the moving party must send all their papers (in text-searchable PDF format) to the Court by email, copying counsel for all relevant parties.

Summary: Papers seeking a preliminary injunction or TRO must be in text-searchable PDF format.

Required Format

PDF

NSR Roman Amended Individual Practices in Civil Cases 8-24-2026 · Aug 2026 · p. 4
|Sec3. Pleadings and Motions - I. Applications for Injunction and/or Temporary Restraining Order
FormattingCivil cases

The quote is in the court's document. The summary is not checked yet.Mandatory?

Briefs must be submitted in accordance with Federal Rules of Bankruptcy Procedure 8009–8010. Counsel may extend the default deadlines by stipulation submitted to the Court no later than two business days before the brief is due. The page limits in Local Rule 7.1(b) must be observed.

Summary: Bankruptcy appeal briefs must comply with FRBP 8009-8010 and the page limits of Local Rule 7.1(b).

FormattingCivil cases

Machine summary. Not checked yet.Mandatory?

All memoranda of law shall be in 12-point font or larger and be double-spaced. Memoranda of 10 pages or more shall contain a table of contents and a table of authorities, neither of which shall count against the page limit.

Summary: Memoranda must be 12-point font, double-spaced, with TOC and TOA for documents over 10 pages.

Typography
Size12 pt
Line SpacingDouble
Formatting

Machine summary. Not checked yet.Mandatory?

No papers, including courtesy hard copies of any filing or document, may be submitted to Chambers. All documents must be filed in text-searchable PDF Format on ECF or, if permitted or required under the Court’s Individual Rules and Practices, emailed to RomanNYSDChambers@nysd.uscourts.gov.

Summary: No paper submissions to chambers; all documents must be filed electronically in PDF format.

Required Format

PDF

NSR Roman COVID-19 Emergency Rules and Practices · Mar 2020 · p. 1
|SecNo Paper Submissions Absent Undue Hardship
Formatting

Machine summary. Not checked yet.Important?

In the event that a party or counsel is unable to submit a document electronically — either by ECF or email — the document may be mailed to the Court. To the maximum extent possible, however, this means of delivery should be avoided, as delivery of mail to the Court is likely to be delayed.

Summary: Documents may be mailed if electronic submission is impossible, but mail delivery is discouraged due to delays.

Required Format

Paper

NSR Roman COVID-19 Emergency Rules and Practices · Mar 2020 · p. 1
|SecNo Paper Submissions Absent Undue Hardship
Formatting

Machine summary. Not checked yet.Note?

All courtesy copies must be clearly marked as such, bound, and tabbed.

Summary: Courtesy copies must be marked, bound, and tabbed.

Document Filing Requirements68 rules

Filing RequirementsCivil cases

The quote is in the court's document. The summary is not checked yet.Mandatory?

The service and/or filing of any sur-reply memoranda, without prior permission of the Court, will be deemed a nullity.

Summary: Sur-reply memoranda may not be served or filed without prior permission of the Court, and unauthorized sur-replies are deemed a nullity.

Document Type

Sur Reply Memorandum

Specific requirements detailed in rule text.
Filing RequirementsCivil cases

The quote is in the court's document. The summary is not checked yet.Mandatory?

A party represented by counsel must submit a Rule 56.1 statement of material fact either in support of, or in opposition to a Rule 56 Summary Judgment Motion. See Fed. Rul. Civ. Pro. 56. The Rule 56.1 statement of material fact shall include proper citation(s) in support of the factual contention asserted.

Summary: A represented party must submit a Rule 56.1 statement of material fact in support of or opposition to a Rule 56 motion, with proper citations supporting each factual contention.

Document Type

Rule 56 1 Statement

Specific requirements detailed in rule text.
NSR Roman Amended Individual Practices in Civil Cases 8-24-2026 · Aug 2026 · p. 3
|Sec3. Pleadings and Motions - G. Summary Judgment Motions
Filing RequirementsCivil cases

The quote is in the court's document. The summary is not checked yet.Mandatory?

Discovery disputes are not to be raised by motion unless directed by the Court.

Summary: Discovery disputes may not be raised by motion unless the Court directs it.

Document Type

Discovery Motion

Specific requirements detailed in rule text.
NSR Roman Amended Individual Practices in Civil Cases 8-24-2026 · Aug 2026 · p. 3
|Sec3. Pleadings and Motions - C. Filing of Motion Papers
Filing RequirementsCivil cases

The quote is in the court's document. The summary is not checked yet.Mandatory?

Memoranda of 10 pages or more shall contain a table of contents and a table of authorities, neither of which shall count against the page limit.

Summary: Memoranda of 10 or more pages must contain a table of contents and a table of authorities, which do not count against the page limit.

Document Type

Memorandum Of Law

Content & Formatting
Table Of Authorities
Table Of Contents
Filing RequirementsCivil cases

The quote is in the court's document. The summary is not checked yet.Mandatory?

A plaintiff seeking a default judgment shall proceed by way of an order to show cause pursuant to the procedure set forth in Attachment A.

Summary: A plaintiff seeking a default judgment must proceed by order to show cause under the procedure in Attachment A.

Document Type

Default Judgment

Specific requirements detailed in rule text.
Filing RequirementsCivil cases

The quote is in the court's document. The summary is not checked yet.Mandatory?

Parties submitting papers in support of or in opposition to a motion for summary judgment shall submit only those exhibits necessary to decide the motion and should not submit, for example, entire deposition transcripts or every exhibit used at a deposition. The Court may strike documents that do not comply with these rules.

Summary: Summary judgment papers must include only the exhibits necessary to decide the motion, and the Court may strike non-complying documents.

Document Type

Summary Judgment Papers

Specific requirements detailed in rule text.
NSR Roman Amended Individual Practices in Civil Cases 8-24-2026 · Aug 2026 · p. 4
|Sec3. Pleadings and Motions - G. Summary Judgment Motions
Filing RequirementsCivil cases

The quote is in the court's document. The summary is not checked yet.Mandatory?

Counsel for all parties must file a notice of appearance in this Court promptly upon removal.

Document Type

Notice Of Appearance

Specific requirements detailed in rule text.
Filing RequirementsCivil cases

The quote is in the court's document. The summary is not checked yet.Mandatory?

The joint pretrial order shall include the information required by Federal Rule of Civil Procedure 26(a)(3) and the following:

Summary: The joint pretrial order must include the FRCP 26(a)(3) information plus twelve specified items, including the full caption, trial counsel information, jurisdiction statements, claims/defenses summaries, jury and magistrate-consent statements, stipulations, witness and exhibit lists with objection notation, deposition designations, damages statement, and unanimity-consent statement.

Document Type

Joint Pretrial Order

Content & Formatting
Caption
Exhibit List
Filing RequirementsCivil cases

The quote is in the court's document. The summary is not checked yet.Mandatory?

Each synopsis shall include page citations to the pertinent pages and lines of the deposition transcripts.

Summary: Each deposition synopsis must include page citations to the pertinent pages and lines of the deposition transcripts.

Document Type

Deposition Synopsis

Specific requirements detailed in rule text.
Filing RequirementsCivil cases

The quote is in the court's document. The summary is not checked yet.Mandatory?

Any party utilizing an AI tool in drafting a document which is to be submitted to the Court must inform the Court of its use and identify which portion of the document was created or generated with the use of the AI tool.

Summary: Any party that uses an AI tool in drafting a document submitted to the Court must disclose the AI use and identify which portions of the document were AI-generated.

Document Type

Any Document Submitted To Court

Content & Formatting
Ai Disclosure
NSR Roman Amended Individual Practices in Civil Cases 8-24-2026 · Aug 2026 · p. 8
|Sec7. Policy on the Use of Artificial Intelligence ("AI")
Filing RequirementsCivil cases

The quote is in the court's document. The summary is not checked yet.Mandatory?

Prepare an Order to Show Cause for default judgment and make the Order returnable before Judge Román in Courtroom 218. Leave blank the date, time and location of the conference. Judge Román will set the date and time when he signs the Order and will determine whether the conference will be held in-person or telephonically.

Summary: Default judgment must be sought via an Order to Show Cause made returnable before Judge Román in Courtroom 218, with the conference date, time, and location left blank for the Judge to set upon signing.

Document Type

Order To Show Cause

Specific requirements detailed in rule text.
Filing RequirementsCivil cases

The quote is in the court's document. The summary is not checked yet.Mandatory?

A. An attorney's affidavit setting forth: i. The basis for entering a default judgment, including a description of the method and date of service of the summons and complaint; ii. The procedural history beyond service of the summons and complaint, if any; iii. 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; iv. The proposed damages and the basis for each element of damages, including interest, attorney's fees, and costs; and v. Legal authority for why an inquest into damages would be unnecessary; vi. Copies of the pleadings and proof of service.

Summary: The attorney's affidavit supporting a default judgment must set forth the basis for default (including service method and date), procedural history, whether partial default on damages is appropriate, proposed damages with basis for each element, legal authority for why an inquest is unnecessary, and copies of the pleadings and proof of service.

Document Type

Attorney Affidavit

Specific requirements detailed in rule text.
Filing RequirementsCivil cases

The quote is in the court's document. The summary is not checked yet.Mandatory?

B. A proposed default judgment.

Summary: A proposed default judgment must be included among the supporting papers filed with the Order to Show Cause.

Document Type

Default Judgment Motion

Content & Formatting
Proposed Order
Filing RequirementsCivil cases

The quote is in the court's document. The summary is not checked yet.Mandatory?

D. If failure to answer is the basis for the default, the moving party must obtain a Certificate of Default from the Clerk of Court stating that no answer has been filed. Please review the Southern District of New York's Electronic Case Filing Rules & Instructions, Section 16.1, on obtaining a Clerk's Certificate of Default.

Summary: When failure to answer is the basis for the default, the moving party must obtain a Certificate of Default from the Clerk of Court stating that no answer has been filed, per SDNY ECF Rules & Instructions Section 16.1.

Document Type

Default Judgment Motion

Specific requirements detailed in rule text.
Filing RequirementsCivil cases

The quote is in the court's document. The summary is not checked yet.Mandatory?

C. A copy of the affidavit of service of the summons and complaint;

Summary: A copy of the affidavit of service of the summons and complaint must be included with the default judgment supporting papers.

Document Type

Default Judgment Motion

Specific requirements detailed in rule text.
Filing RequirementsCivil cases

The quote is in the court's document. The summary is not checked yet.Important?

After an action has been accepted as related to a prior filed action, all future court papers and correspondence must contain the docket number of the new action as well as the docket number of the related case (e.g., 11 Civ. 1234 [rel. 10 Civ. 4321]).

Summary: After a related-case assignment, all future court papers and correspondence must include both the new action's docket number and the related case's docket number.

Document Type

Court Papers And Correspondence

Content & Formatting
Case Number
Filing RequirementsCivil cases

The quote is in the court's document. The summary is not checked yet.Important?

All proposed orders that parties wish the Court to sign should be submitted as attachments or exhibits to an appropriate formal application to the Court seeking the endorsement of such order.

Summary: Proposed orders should be submitted as attachments or exhibits to a formal application seeking the Court's endorsement.

Document Type

Formal Application

Content & Formatting
Proposed Order
Filing RequirementsCivil cases

The quote is in the court's document. The summary is not checked yet.Important?

The parties proposed voir dire should include a paragraph (preferably one agreed upon by the parties and designated as such) for the Court to use during jury selection which provides a brief explanation of the case. If the parties cannot agree to a paragraph after good faith efforts, their respective proposed paragraphs (designated as such) should be set forth in their respective submissions.

Summary: Proposed voir dire must include a paragraph briefly explaining the case for use during jury selection, preferably agreed upon and designated as such; absent agreement after good faith efforts, each party's designated proposed paragraph must appear in its respective submission.

Document Type

Proposed Voir Dire

Specific requirements detailed in rule text.
NSR Roman Amended Individual Practices in Civil Cases 8-24-2026 · Aug 2026 · p. 6
|Sec5. Trial Procedures - C. Additional Submissions in Jury Cases
Filing RequirementsCivil cases

The quote is in the court's document. The summary is not checked yet.Important?

The proposed findings of fact should be detailed and should include citations to the proffered trial testimony and exhibits, as there may be no opportunity for post-trial submissions.

Summary: Proposed findings of fact must be detailed and include citations to the proffered trial testimony and exhibits because there may be no opportunity for post-trial submissions.

Document Type

Proposed Findings Of Fact

Specific requirements detailed in rule text.
Filing RequirementsCriminal cases

Machine summary. Not checked yet.Mandatory?

A firm trial date will be selected at a status conference. Prior to the conference, counsel shall confer and be prepared to propose to the Court a trial date and a schedule for any pretrial motions. Once a trial date is selected, it will not be moved absent exceptional circumstances.

Summary: Trial date set at status conference and will not be moved absent exceptional circumstances.

Document Type

Status Conference

Specific requirements detailed in rule text.
Filing RequirementsCriminal cases

Machine summary. Not checked yet.Mandatory?

Whenever Defense Counsel has received, or is receiving, a benefactor payment that subjects counsel to a conflict of interest, said counsel must inform the Court and request in writing a Curcio hearing.

Summary: Defense counsel must inform Court and request Curcio hearing for benefactor payment conflicts.

Document Type

Curcio Hearing Request

Specific requirements detailed in rule text.
Filing RequirementsCriminal cases

Machine summary. Not checked yet.Mandatory?

Counsel are required to register in accordance with the Procedures for Electronic Case Filing promptly after being retained or assigned.

Summary: Counsel must register for ECF promptly after being retained or assigned.

Document Type

General

Content & Formatting
Notice Of Electronic Filing
Filing RequirementsCriminal cases

Machine summary. Not checked yet.Mandatory?

In making discovery motions, counsel are expected to comply with Southern District Local Criminal Rule 16.1. Any discovery motion must contain the Rule 16.1 affidavit.

Summary: Discovery motions must comply with Local Criminal Rule 16.1 and include Rule 16.1 affidavit.

Document Type

Discovery Motion

Content & Formatting
Local Rule Certificate
Filing RequirementsCriminal cases

Machine summary. Not checked yet.Mandatory?

Defendants shall be prepared in advance of a guilty plea to give narrative allocutions that incorporate all the elements of the offense(s) to which they are pleading guilty.

Summary: Defendants must give narrative allocutions incorporating all elements of offense(s) before guilty plea.

Document Type

Guilty Plea

Specific requirements detailed in rule text.
Filing RequirementsCriminal cases

Machine summary. Not checked yet.Mandatory?

Any written request for a bail modification by a defendant shall indicate whether the Government and the Pre-Trial Services Officer consent to the request.

Summary: Bail modification requests must indicate Government and Pre-Trial Services Officer consent.

Document Type

Bail Modification Request

Specific requirements detailed in rule text.
Filing RequirementsCriminal cases

Machine summary. Not checked yet.Mandatory?

Defense counsel are expected to have reviewed any plea, cooperation or other agreement with the defendant—if necessary, with the assistance of an interpreter—prior to the time set for the conference with the Court.

Summary: Defense counsel must review plea/cooperation agreements with defendant before court conference.

Document Type

Plea Conference

Specific requirements detailed in rule text.
Filing RequirementsCriminal cases

Machine summary. Not checked yet.Mandatory?

Documents in the Public Record. The Court assumes that every document in a sentencing submission, including letters, will be filed in the public record either in paper form or through the ECF system, using the procedures described below.

Summary: All sentencing submission documents, including letters, will be filed in public record.

Document Type

Sentencing Submission

Specific requirements detailed in rule text.
Filing RequirementsCriminal cases

Machine summary. Not checked yet.Mandatory?

When a defendant is pleading guilty pursuant to a plea agreement or a cooperation agreement, a copy of the agreement must be received by Chambers before the scheduled plea. Where the government is providing a Pimentel letter, a copy of the Pimentel letter must also be received by Chambers before the scheduled plea.

Summary: Plea/cooperation agreements and Pimentel letters must be received by Chambers before scheduled plea.

Document Type

Guilty Plea

Specific requirements detailed in rule text.
Filing RequirementsCriminal cases

Machine summary. Not checked yet.Mandatory?

The defendant is responsible for filing all letters submitted on behalf of the defendant, including those from friends, relatives, etc. The Government is responsible for filing all letters from victims.

Summary: Defendant files letters from friends/relatives; Government files victim letters.

Document Type

Sentencing Letters

Specific requirements detailed in rule text.
Filing RequirementsCivil cases

Machine summary. Not checked yet.Mandatory?

All attorneys representing parties before Judge Román are required to register promptly as filing users on ECF and to file a notice of appearance.

Summary: All attorneys must register as ECF filing users and file notice of appearance.

Document Type

Notice Of Appearance

Content & Formatting
Notice Of Electronic Filing
Filing RequirementsCivil cases

Machine summary. Not checked yet.Mandatory?

All proposed orders, and stipulations requiring the Court’s signature, must be submitted directly to the Clerk via email, wpclerk@nysd.uscourts.gov. Do not file proposed orders and stipulations via ECF, and do not send courtesy copies to Chambers.

Summary: Proposed orders/stipulations requiring Court signature must be emailed to Clerk; do not file via ECF or send to Chambers.

Document Type

Proposed Order

Content & Formatting
Proposed Order
Filing RequirementsCivil cases

Machine summary. Not checked yet.Mandatory?

Sur-reply memoranda will not be accepted without prior permission of the Court.

Summary: Sur-replies require prior permission from the Court.

Document Type

Sur Reply

Specific requirements detailed in rule text.
Filing RequirementsCivil cases

Machine summary. Not checked yet.Mandatory?

Any party moving for summary judgment shall 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.

Summary: Electronic Word copy of Rule 56.1 statement required for all parties.

Document Type

Motion For Summary Judgment

Specific requirements detailed in rule text.
Filing RequirementsCivil cases

Machine summary. Not checked yet.Mandatory?

Parties submitting papers in support of or in opposition to a motion for summary judgment shall submit only those exhibits necessary to decide the motion and should not submit, for example, entire deposition transcripts or every exhibit used at a deposition.

Summary: Only necessary exhibits for summary judgment motions; no entire transcripts.

Document Type

Summary Judgment Motion

Specific requirements detailed in rule text.
Filing RequirementsCivil cases

Machine summary. Not checked yet.Mandatory?

A plaintiff seeking a default judgment shall proceed by way of an order to show cause pursuant to the procedure set forth in Attachment A.

Summary: Default judgments must be sought via order to show cause per Attachment A.

Document Type

Default Judgment

Specific requirements detailed in rule text.
Filing RequirementsCivil cases

Machine summary. Not checked yet.Mandatory?

All proposed orders that parties wish the Court to sign should be submitted as attachments or exhibits to an appropriate formal application to the Court seeking the endorsement of such order.

Summary: Proposed orders must be submitted as attachments to formal applications.

Document Type

Proposed Order

Specific requirements detailed in rule text.
Filing RequirementsCivil cases

Machine summary. Not checked yet.Mandatory?

all parties must file a notice of appearance in this Court promptly upon removal.

Summary: Notice of appearance required promptly upon removal.

Document Type

Notice Of Appearance

Specific requirements detailed in rule text.
Filing RequirementsCivil cases

Machine summary. Not checked yet.Mandatory?

Unless otherwise ordered by the Court, within 30 days after the date for completion of discovery, or, if a dispositive motion has been filed, within 30 days after a decision on the motion, the parties should electronically file via ECF a joint pretrial order and provide one courtesy copy to the Court.

Summary: Joint pretrial order due 30 days after discovery completion or dispositive motion decision.

Document Type

Joint Pretrial Order

Specific requirements detailed in rule text.
Filing RequirementsCivil cases

Machine summary. Not checked yet.Mandatory?

Submit to the Court and serve on opposing counsel, but shall not electronically file, all deposition excerpts which will be offered as substantive evidence, as well as a one-page synopsis of those excerpts for each deposition.

Summary: Deposition excerpts and synopses must be submitted to court and served but not filed electronically.

Document Type

Deposition Excerpts

Content & Formatting
Case Number
Judge Name
Filing RequirementsCivil cases

Machine summary. Not checked yet.Mandatory?

Each proposed jury instruction must contain a citation to the source or authority for the proposed instruction, or the request will be disregarded.

Summary: Proposed jury instructions must include citations or will be disregarded.

Document Type

Jury Instructions

Content & Formatting
Case Number
Judge Name
Filing RequirementsCivil cases

Machine summary. Not checked yet.Mandatory?

Each party shall file via ECF proposed findings of fact and conclusions of law, and provide two courtesy copies to the Court.

Summary: Proposed findings of fact and conclusions of law required via ECF with two courtesy copies.

Document Type

Proposed Findings Conclusions

Content & Formatting
Case Number
Judge Name
Filing RequirementsCivil cases

Machine summary. Not checked yet.Mandatory?

The proposed findings of fact should be detailed and should include citations to the proffered trial testimony and exhibits, as there may be no opportunity for post-trial submissions.

Summary: Proposed findings must be detailed with citations to testimony and exhibits.

Document Type

Proposed Findings Conclusions

Content & Formatting
Case Number
Judge Name
Filing RequirementsCivil cases

Machine summary. Not checked yet.Mandatory?

The original signed affidavits shall be brought to trial to be marked as exhibits.

Summary: Original signed affidavits must be brought to trial for marking as exhibits.

Document Type

Affidavit

Content & Formatting
Case Number
Judge Name
Filing RequirementsCivil cases

Machine summary. Not checked yet.Mandatory?

Submit to the Court and serve on opposing counsel, but shall not electronically file, copies of affidavits constituting the direct testimony of each trial witness, except for the direct testimony of (1) an adverse party, (2) a person whose attendance is compelled by subpoena, or (3) a person for whom the Court has agreed to hear direct testimony live at the trial.

Summary: Affidavits for direct testimony must be submitted to court and served but not filed electronically, with exceptions.

Document Type

Affidavit

Content & Formatting
Case Number
Judge Name
Filing RequirementsCivil cases

Machine summary. Not checked yet.Mandatory?

Proposed requests to charge and proposed verdict forms must be filed at least 15 days before the commencement of trial, or 30 days after the filing of the joint pretrial order if no date for trial has been fixed.

Summary: Proposed requests to charge and verdict forms due 15 days before trial or 30 days after joint pretrial order.

Document Type

Requests To Charge

Content & Formatting
Case Number
Judge Name
Filing RequirementsCivil cases

Machine summary. Not checked yet.Mandatory?

Three business days after the submission of such affidavits, counsel for each party shall submit a list of all affiants whom he or she intends to cross-examine at the trial.

Summary: List of affiants to be cross-examined due three business days after affidavit submission.

Document Type

Cross Examination List

Content & Formatting
Case Number
Judge Name
Filing RequirementsCivil cases

Machine summary. Not checked yet.Mandatory?

Each synopsis shall include page citations to the pertinent pages and lines of the deposition transcripts.

Summary: Deposition synopsis must include page and line citations.

Document Type

Deposition Synopsis

Content & Formatting
Case Number
Judge Name
Filing RequirementsCivil cases

Machine summary. Not checked yet.Mandatory?

Proposed voir dire questions must be filed on the day the joint pretrial order is filed.

Summary: Proposed voir dire questions due on day of joint pretrial order filing.

Document Type

Voir Dire Questions

Content & Formatting
Case Number
Judge Name
Filing RequirementsCivil cases

Machine summary. Not checked yet.Mandatory?

Any motions shall be filed in accordance with the Court’s Individual Practices.

Summary: Motions must be filed according to the Court's Individual Practices.

Document Type

Motion

Content & Formatting
Local Rule Certificate
nsrCivilCaseManagementPlanAndSchedulingOrder · Jan 2012 · p. 1
|SecCIVIL CASE DISCOVERY PLAN AND SCHEDULING ORDER
Filing Requirements

Machine summary. Not checked yet.Mandatory?

No later than one week before a scheduled appearance, counsel must confer and submit a letter to the Court indicating their views on whether the Court can, consistent with the U.S. Constitution, Federal Rules of Criminal Procedure (see, e.g., Rules 5(f), 10(b) & (c), and 43) and any other relevant law, conduct the matter by telephone or video and, if applicable, whether the Defendant either consents to appearing in that manner or to waiving his or her appearance altogether.

Summary: Counsel must submit letter one week before criminal case appearance indicating views on phone/video proceedings.

Document Type

Letter

Content & Formatting
Case Number
Judge Name
Filing Requirements

Machine summary. Not checked yet.Mandatory?

The original Statement must include an Affirmation of Service stating the date a copy was mailed to the other parties or their attorneys.

Summary: Original Pretrial Statement must include Affirmation of Service with mailing date.

Document Type

Pretrial Statement

Content & Formatting
Certificate Of Service
Filing Requirements

Machine summary. Not checked yet.Mandatory?

Counsel must follow Rule 1.A. of Judge Román's 'Individual Practices in Civil Cases.' In addition, counsel must mail copies to all pro se parties and attach to the communication with Chambers an Affidavit of Service affirming such mailing.

Summary: Counsel must mail copies to pro se parties and attach Affidavit of Service.

Document Type

Communication

Content & Formatting
Certificate Of Service
Filing Requirements

Machine summary. Not checked yet.Mandatory?

If there are other pro se parties, the party filing the papers must include an Affirmation of Service stating that he or she sent copies to all other pro se parties.

Summary: Pro se parties must include Affirmation of Service when other pro se parties exist.

Document Type

Filing

Content & Formatting
Certificate Of Service
Filing Requirements

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 Local Civil Rules 12.1 or 56.2.

Summary: Motions to dismiss, judgment on pleadings, or summary judgment require notice to pro se parties.

Document Type

Motion

Content & Formatting
Notice Of Electronic Filing
Filing Requirements

Machine summary. Not checked yet.Mandatory?

The Court will not consider submissions filed without proof that the pro se party was served with a paper copy.

Summary: Submissions without proof of paper service to pro se party will not be considered.

Document Type

Filing

Content & Formatting
Certificate Of Service

Filing & Service rules

Electronic Filing Rules

All letters must be filed on ECF unless they are under seal or contain sensitive or confidential information.

Unless there is a request to file a letter under seal or a letter contains sensitive or confidential information, all letters shall be filed on ECF.

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Page 1 | 1. Communications with Chambers - A. Letters

Requests for adjournment or extension of time must be filed on ECF and sent to Chambers by email.

All requests for adjournment or extension of time shall be filed on ECF and sent to Chambers by email

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Page 1 | 1. Communications with Chambers - D. Requests for Adjournments or Extensions of Time

Any attorney appearing before the Court must enter a Notice of Appearance on ECF.

Any attorney appearing before the Court shall enter a Notice of Appearance on ECF.

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Page 2 | 2. Conferences - B. Attendance by Principal Trial Counsel

All attorneys representing parties before Judge Román must promptly register as ECF Filers and file a notice of appearance.

All attorneys representing parties before Judge Román are required to register promptly as ECF Filers and must file a notice of appearance.

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Page 2 | 1. Communications with Chambers - G. ECF

All proposed orders and stipulations requiring the Court's signature must be filed on ECF.

All proposed orders, and stipulations requiring the Court's signature, must be filed on ECF.

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Page 2 | 1. Communications with Chambers - E. Proposed Orders and Stipulations

Motion papers must be filed via ECF promptly after reply papers have been served.

Motion papers shall be filed via ECF promptly after reply papers have been served.

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Page 3 | 3. Pleadings and Motions - C. Filing of Motion Papers

Parties must file all TRO/preliminary injunction papers on ECF as they are emailed to Chambers.

Additionally, parties must file all papers on ECF as they are emailed to Chambers.

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Page 4 | 3. Pleadings and Motions - I. Applications for Injunction and/or Temporary Restraining Order

Parties must electronically file the joint pretrial order via ECF.

Unless otherwise ordered by the Court, within 30 days after the date for completion of discovery, or, if a dispositive motion has been filed, within 30 days after a decision on the motion, the parties should electronically file via ECF a joint pretrial order and provide one courtesy copy to the Court.

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Page 5 | 5. Trial Procedures - A. Joint Pretrial Orders

Proposed voir dire questions, requests to charge, verdict forms, and any oppositions must be filed via ECF.

These submissions, including any oppositions, shall be filed via ECF and sent to Chambers by email, with one courtesy copy of each submitted to Chambers.

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Page 6 | 5. Trial Procedures - C. Additional Submissions in Jury Cases

Each party must electronically file proposed findings of fact and conclusions of law via ECF at the time the joint pretrial order is filed.

Electronically file via ECF proposed findings of fact and conclusions of law and provide one courtesy copy to the Court.

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Page 7 | E. Additional Submissions in Non-Jury Cases (i)

Affidavits constituting the direct testimony of trial witnesses must be submitted to the Court and served but not electronically filed, with exceptions for adverse parties, subpoenaed persons, and witnesses testifying live.

Submit to the Court and serve on opposing counsel, but shall not electronically file, copies of affidavits constituting the direct testimony of each trial witness, except for the direct testimony of (1) an adverse party, (2) a person whose attendance is compelled by subpoena, or (3) a person for whom the Court has agreed to hear direct testimony live at the trial.

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Page 7 | E. Additional Submissions in Non-Jury Cases (iii)

Deposition excerpts offered as substantive evidence and a one-page synopsis for each deposition must be submitted to the Court and served on opposing counsel but must not be electronically filed.

Submit to the Court and serve on opposing counsel, but shall not electronically file, all deposition excerpts which will be offered as substantive evidence, as well as a one-page synopsis of those excerpts for each deposition.

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Page 7 | E. Additional Submissions in Non-Jury Cases (ii)

The Order to Show Cause, proposed default judgment order, and all supporting papers must be filed on ECF in accordance with SDNY ECF Rules & Instructions Section 16.3.

File the Order to Show Cause, the proposed default judgment order, and all other supporting papers onto ECF in accordance with the Southern District of New York's Electronic Case Filing Rules & Instructions, Section 16.3.

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Page 9 | DEFAULT JUDGMENT PROCEDURE

Counsel must keep their ECF contact information current and regularly check the docket sheet even if they receive ECF notifications.

Counsel are responsible for updating their contact information on ECF, should it change, and they are responsible for checking the docket sheet regularly, regardless of whether they receive an ECF notification of case activity.

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Page 2 | 1. Communications with Chambers - G. ECF

Trial exhibits are not required to be electronically filed.

Exhibits need not be electronically filed.

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Page 7 | D. Trial Exhibits

Filing Timing and Cure Windows

The joint pretrial order is due within 30 days after completion of discovery or, if a dispositive motion was filed, within 30 days after decision on the motion, unless otherwise ordered.

Unless otherwise ordered by the Court, within 30 days after the date for completion of discovery, or, if a dispositive motion has been filed, within 30 days after a decision on the motion, the parties should electronically file via ECF a joint pretrial order and provide one courtesy copy to the Court.

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Page 5 | 5. Trial Procedures - A. Joint Pretrial Orders

Within three business days after submitting direct-testimony affidavits, each party must submit a list of affiants it intends to cross-examine at trial.

Three business days after the submission of such affidavits, counsel for each party shall submit a list of all affiants whom he or she intends to cross-examine at the trial.

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Page 7 | E. Additional Submissions in Non-Jury Cases (iii)

After the default judgment filings are filed on ECF, the Clerk of Court reviews them and parties must monitor the docket and make any revisions the Clerk indicates if filings are not approved as to form.

After the Order to Show Cause, the proposed default judgment order, and supporting documentation are filed on ECF, the Clerk of Court will review the filings. Please monitor the docket in case any of the filings are not approved as to form, and make any revisions as indicated by the Clerk of Court.

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Page 9 | DEFAULT JUDGMENT PROCEDURE

The Court sets the submission schedule for proposed voir dire questions, requests to charge, and verdict forms at the pretrial conference.

At the pretrial conference, the Court will set a schedule for submission of additional materials, including proposed voir dire questions, requests to charge, and verdict forms.

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Page 6 | 5. Trial Procedures - C. Additional Submissions in Jury Cases

Service and Proof of Service Rules

The summary judgment movant must provide all other parties an electronic Microsoft Word copy of its Rule 56.1 statement, and opposing parties must reproduce each entry directly beneath it.

Any party moving for summary judgment shall 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. Opposing parties shall reproduce to each entry directly beneath it.

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Page 3 | 3. Pleadings and Motions - G. Summary Judgment Motions

Deposition excerpts offered as substantive evidence and their synopses must be served on opposing counsel.

Submit to the Court and serve on opposing counsel, but shall not electronically file, all deposition excerpts which will be offered as substantive evidence, as well as a one-page synopsis of those excerpts for each deposition.

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Page 7 | E. Additional Submissions in Non-Jury Cases (ii)

Affidavits constituting the direct testimony of trial witnesses must be served on opposing counsel.

Submit to the Court and serve on opposing counsel, but shall not electronically file, copies of affidavits constituting the direct testimony of each trial witness, except for the direct testimony of (1) an adverse party, (2) a person whose attendance is compelled by subpoena, or (3) a person for whom the Court has agreed to hear direct testimony live at the trial.

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Page 7 | E. Additional Submissions in Non-Jury Cases (iii)

Once the filings are approved as to form and the Court issues its order, a copy of the scheduling order must be served on the opposing party and proof of service filed.

Once the filings are approved by the Clerk of Court as to their form, the Court will issue a order, including serving a copy of the scheduling order onto the opposing party and filings proof of service.

We could not find this wording in the court's document. Open the source before relying on it. · Civil cases

Page 9 | DEFAULT JUDGMENT PROCEDURE

Courtesy Copy Requirements

One courtesy hard copy of all motion papers must be mailed to Chambers when the papers are served on the other parties.

One courtesy hard copy of all motion papers shall be submitted via mail to Chambers when served on the other parties.

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Page 3 | 3. Pleadings and Motions - D. Courtesy Copies

One courtesy electronic copy of all pleadings must be emailed to Chambers as soon as practicable after filing.

One courtesy electronic copy of all pleadings shall be submitted via email to Chambers as soon as practicable after filing.

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Page 3 | 3. Pleadings and Motions - D. Courtesy Copies

Removing parties must provide the Court a courtesy copy of any pleading filed or served in state court, clearly marked as a courtesy copy, bound, and tabbed.

Counsel for the party or parties which removed the case must, in addition to providing a copy of all process, pleadings, and papers served upon the defendants pursuant to 28 U.S.C. § 1446(a), provide the Court with a courtesy copy of any pleading filed or served while the case remained in State court. All courtesy copies must be clearly marked as such, bound, and tabbed.

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Page 5 | B. Cases Removed from State Court

Parties must provide the Court one courtesy copy of the joint pretrial order.

Unless otherwise ordered by the Court, within 30 days after the date for completion of discovery, or, if a dispositive motion has been filed, within 30 days after a decision on the motion, the parties should electronically file via ECF a joint pretrial order and provide one courtesy copy to the Court.

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Page 5 | 5. Trial Procedures - A. Joint Pretrial Orders

Each party must also email one courtesy copy of all in limine motion papers to the Court on the date the papers are filed.

Each party shall mail to the Court one courtesy copy and email one courtesy copy of all motion papers on the date those papers are filed.

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Page 6 | 5. Trial Procedures - B. Motions in limine

Each party must mail one courtesy copy of all in limine motion papers to the Court on the filing date, clearly marked as a courtesy copy, bound, and tabbed.

Each party shall mail to the Court one courtesy copy and email one courtesy copy of all motion papers on the date those papers are filed. All mailed courtesy copies shall be clearly marked as such, bound, and tabbed.

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Page 6 | 5. Trial Procedures - B. Motions in limine

One courtesy copy of each jury-trial submission (including oppositions) must be submitted to Chambers.

These submissions, including any oppositions, shall be filed via ECF and sent to Chambers by email, with one courtesy copy of each submitted to Chambers.

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Page 6 | 5. Trial Procedures - C. Additional Submissions in Jury Cases

Each party must submit a tabbed and indexed binder containing one copy of each documentary exhibit to the Court when the joint pretrial order is filed.

At the time that the joint pretrial order is filed, each party shall submit to the Court a tabbed and indexed binder containing one copy of each documentary exhibit sought to be admitted.

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Page 7 | D. Trial Exhibits

One courtesy copy of the proposed findings of fact and conclusions of law must be provided to the Court.

Electronically file via ECF proposed findings of fact and conclusions of law and provide one courtesy copy to the Court.

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Page 7 | E. Additional Submissions in Non-Jury Cases (i)

Contact Deputy Clerk for scheduling; AUSA must submit courtesy copy of criminal complaint.

Scheduling. For scheduling please call Judge Román's Courtroom Deputy Clerk, Gina Sicora, at (914) 390-4178. Upon assignment of a criminal case to Judge Román, the parties should contact Ms. Sicora to set an appropriate date for an initial appearance. The A.U.S.A. shall at that time submit to Chambers a courtesy copy of the criminal complaint, if one exists.

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Page 1 | COMMUNICATIONS

One courtesy copy of pleadings, two of motion papers required for Chambers.

One courtesy copy of all pleadings shall be submitted to Chambers as soon as practicable after filing. Two courtesy copies of all motion papers shall be submitted to Chambers when served on the other parties.

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Page 3 | Pleadings and Motions

Courtesy copies must be marked, bound, and tabbed.

All courtesy copies must be clearly marked as such, bound, and tabbed.

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Page 3 | Pleadings and Motions

Courtesy copies required for pleadings filed in state court before removal.

Counsel for the party or parties which removed the case shall, in addition to providing a copy of all process, pleadings, and papers served upon the defendants pursuant to 28 U.S.C. § 1446(a), provide the Court with a courtesy copy of any pleading filed or served while the case remained in State court.

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Page 5 | B. Cases Removed from State Court

Two courtesy copies required for motions in limine, must be bound and tabbed.

Each party shall submit to the Court two courtesy copies of all motion papers on the date those papers are filed. All courtesy copies shall be clearly marked as such, bound, and tabbed.

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Provide courtesy copy of default judgment order and supporting documents to Court.

Provide the Court with a courtesy copy of the Order, supporting documents, and affidavit of service.

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Motion papers should include one courtesy copy for the Court.

If possible, motion papers should include one courtesy copy for the Court.

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Sealing & Redaction Procedures

Letters under seal or containing sensitive or confidential information must be delivered to the Court via email or mail, but not both.

Letters under seal or containing sensitive or confidential information shall be delivered to the Court via email or mail. Do not email and mail the same letter.

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Page 1 | 1. Communications with Chambers - A. Letters

Parties must comply with the E-Government Act of 2002 and the SDNY ECF Privacy Policy regarding privacy redactions in document submissions.

Regarding document submissions, the parties must comply with the E-Government Act of 2002 and the Southern District's ECF Rules & Instructions, Section 21, Privacy and Public Access to ECF Cases ("ECF Privacy Policy"). See also Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110 (2d Cir. 2006).

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Page 4 | 4. Other Pretrial Guidance - A. Redacting Personal Information

Parties may not include the five categories of sensitive information (social security numbers, minors' names, dates of birth, financial account numbers, home addresses) in submissions unless necessary, and must redact them in the specified manner.

Parties may not, unless necessary, include 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 4 | 4. Other Pretrial Guidance - A. Redacting Personal Information

Redactions within the eleven ECF Privacy Policy categories (e.g., an individual's cooperation with the government) may be made without an application to the Court, and only the pages containing redacted material are filed under seal.

regarding an individual's cooperation with the government) as described in the ECF Privacy Policy, without application to the Court. If any material is redacted from the publicly filed document, only those pages containing the redacted material will be filed under seal.

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Page 5 | Sealing/Redaction (ECF Privacy Policy, continuation from prior page)

Redactions beyond the eleven ECF Privacy Policy categories require an application sent to Chambers by email (copying opposing counsel) before filing, clearly identifying and explaining the redaction.

If a party redacts information beyond the eleven categories of information identified in the ECF Privacy Policy, an application to do so must be sent to Chambers by email, copying opposing counsel, prior to filing the redacted document on ECF. The application should clearly identify the redaction and explain the reasons for the redaction.

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Page 5 | Sealing/Redaction (ECF Privacy Policy, continuation from prior page)

Parties may redact the five sensitive-information categories and six caution categories (personal identifying number, medical records, employment history, etc.); the list continues beyond this excerpt.

Parties may redact the above five categories of "sensitive information" and the six categories of information requiring caution (i.e., personal identifying number; medical records, treatment and diagnosis; employment history; individual

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Page 4 | 4. Other Pretrial Guidance - A. Redacting Personal Information

Sensitive information (SSN, minor children names, DOBs, account numbers, home addresses) must be redacted unless necessary.

Parties may not, unless necessary, include 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 2 | SENTENCES

Applications required for redactions beyond ECF Privacy Policy categories.

If a party redacts information beyond the eleven categories of information identified in the ECF 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.

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Page 5 | A. Redacting Personal Information

Redacted pages containing sensitive information must be filed under seal.

Parties may redact the above five categories of 'sensitive information' and the six categories of information requiring caution (i.e., personal identifying number; medical records, treatment and diagnosis; employment history; individual financial information; proprietary or trade secret information; and information regarding an individual's cooperation with the government) as described in the ECF Privacy Policy, without application to the Court. If any material is redacted from the publicly filed document, only those pages containing the redacted material will be filed under seal.

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Page 5 | A. Redacting Personal Information

Parties must comply with ECF Privacy Policy for document submissions.

Regarding document submissions, the parties must comply with the E-Government Act of 2002 and the Southern District's ECF Rules & Instructions, Section 21, Privacy and Public Access to ECF Cases ('ECF Privacy Policy').

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Page 5 | A. Redacting Personal Information

Sensitive information categories must be redacted unless necessary.

Parties may not, unless necessary, include 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 | A. Redacting Personal Information

Filing Bundling Requirements

Parties must file a single consolidated motion in limine addressing all evidence they seek to exclude, rather than multiple motions.

Parties submitting motions in limine should file one consolidated motion to address all evidence they seek to exclude.

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Page 6 | 5. Trial Procedures - B. Motions in limine

Motion papers must be filed via ECF promptly after reply papers are served.

Motion papers shall be filed via ECF promptly after reply papers have been served.

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Page 3 | Pleadings and Motions

Pre-Motion Conference Requirements

A pre-motion conference is required before any motion (except pro hac vice, in limine, and TRO motions), arranged by a moving party letter of no more than three pages setting forth the basis for the anticipated motion.

A pre-motion conference with the Court is required before making any other motion, except motions for admission pro hac vice, motions in limine, and motions for temporary restraining orders. To arrange a pre-motion conference, the moving party shall submit a letter, not to exceed three pages, setting forth the basis for the anticipated motion.

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Page 2 | 3. Pleadings and Motions - A. Pre-Motion Conferences

Requesting a pre-motion conference for a proposed motion to dismiss stays the requesting party's deadline to move or answer, and the Court sets a new deadline.

If a pre-motion conference is requested in connection with a proposed motion to dismiss, the request will stay the deadline for the requesting party to move or answer, and a new deadline will be set by the Court.

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Page 3 | 3. Pleadings and Motions

Moving parties must confer with their adversary before applying for a temporary restraining order unless Rule 65(b)(1)(B) applies.

All moving parties must confer with their adversary before making an application for a temporary restraining order, unless the requirements of Rule 65(b)(1)(B) are met.

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Page 4 | 3. Pleadings and Motions - I. Applications for Injunction and/or Temporary Restraining Order

The Court sets the briefing schedule for motions in limine at the pretrial conference.

At the pretrial conference, the Court will set a briefing schedule for any motions the parties wish to file addressing evidentiary issues or other matters which should be resolved in limine.

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Page 6 | 5. Trial Procedures - B. Motions in limine

Substitution of counsel requires conference with Deputy Clerk.

When there is a substitution of Defense Counsel, counsel of record must contact the Deputy Clerk to schedule a conference. At the conference, the Court will address the application by also attend the conference.

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Page 2 | SUBSTITUTION OF COUNSEL

Pre-motion conference required for most motions except specified exceptions.

A pre-motion conference with the Court is required before making any other motion, except motions for admission pro hac vice, motions in limine, motions for reargument or reconsideration, and motions for temporary restraining orders or preliminary injunctions.

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Page 3 | Pleadings and Motions

Pre-motion letter (max 3 pages) required from both parties with 3 business day response time.

To arrange a pre-motion conference, the moving party shall submit a letter, not to exceed three pages, setting forth the basis for the anticipated motion. The opposing party shall submit a letter, also not to exceed three pages, setting forth its position within three business days from the service of the moving party’s letter.

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Page 3 | Pleadings and Motions

Pre-motion conference required for non-incarcerated pro se cases.

When no pro se party is incarcerated, any party wishing to file a motion must first write a letter to the Court requesting a pre-motion conference.

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Oral argument not permitted unless otherwise ordered.

Unless otherwise ordered, no oral argument will be heard.

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Adjournment & Extension Requirements

Adjournment and extension requests must be filed on ECF and emailed to Chambers, and must state the original dates, the number and outcomes of previous requests, the reason for the request, the adversary's position on consent, and, if the adversary consents, three mutually agreeable alternate conference dates (Thursdays or Fridays).

All requests for adjournment or extension of time shall be filed on ECF and sent to Chambers by email, stating as follows: (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 reason for the instant request, (5) whether the adversary consents, and, if not, the reasons given by the adversary for refusing to consent, and (6) if the adversary consents, three mutually agreeable alternate conference dates, which should be on a Thursday or Friday.

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Page 1 | 1. Communications with Chambers - D. Requests for Adjournments or Extensions of Time

Adjournment and extension requests must be made at least 48 hours before the original deadline.

Any request for adjournment or extension of time must be made at least 48 hours prior to the original deadline.

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Page 1 | 1. Communications with Chambers - D. Requests for Adjournments or Extensions of Time

Extension requests made after the original deadline has expired will be denied absent extraordinary circumstances.

Absent extraordinary circumstances, requests for extensions of time will be denied if not made before the expiration of the original deadline.

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Page 2 | 1. Communications with Chambers - D. Requests for Adjournments or Extensions of Time

Default bankruptcy appeal brief deadlines may be extended by stipulation submitted to the Court no later than two business days before the brief is due.

Counsel may extend the default deadlines by stipulation submitted to the Court no later than two business days before the brief is due.

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Page 5 | C. Bankruptcy Appeals

Adjournment requests must be made 48 hours in advance; attach revised scheduling order if other dates affected.

Any request for adjournments of conferences shall be made at least 48 hours prior to the scheduled appearance. If the requested adjournment or extension affects any other scheduled dates, a proposed Revised Scheduling Order must be attached.

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Page 2 | Communications with Chambers

Adjournment/extension requests must be faxed to Chambers with specific required information.

All requests for adjournments or extensions of time shall be sent to Chambers by fax and state: (1) the original date(s), (2) the number of previous requests for adjournment or extension, (3) whether

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Page 2 | Communications with Chambers

Extension requests must be made before original deadline expires; otherwise denied absent extraordinary circumstances.

Absent extraordinary circumstances, requests for extensions of time will be denied if not made before the expiration of the original deadline.

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Page 2 | Communications with Chambers

Conference with adversary required before TRO 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 Fed. R. Civ. P. 65(b) are met.

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Page 4 | Pleadings and Motions

Opposition papers must be filed and served within 4 weeks of motion service.

Unless otherwise ordered by the Court, papers filed in opposition to a motion must be filed and served within four weeks of the service of the motion papers.

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Reply papers must be filed and served within 2 weeks of opposition.

Reply papers, if any, must be filed and served within two weeks of receipt of the opposition papers.

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Other parties must file similar Pretrial Statement within 2 weeks of pro se party's service.

Two weeks after service of a pro se party's Statement, the other parties must file and serve a similar Statement containing the same information.

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Pro se parties must file Pretrial Statement within 30 days of discovery completion.

Within 30 days of the completion of discovery, a pro se party must file a concise, written Pretrial Statement, unless otherwise ordered by the Court.

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Parties must submit proposed findings within 30 days of discovery completion for bench trials.

Within 30 days of the completion of discovery, if the case is to be tried before a Judge without a jury, all parties represented by counsel must submit proposed findings of fact and conclusions of law.

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Brief extensions by stipulation require 2 business days advance notice.

Counsel may extend the default deadlines by stipulation submitted to the Court no later than two business days before the brief is due. The page limits in Local Rule 7.1(b) must be observed.

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Page 5 | C. Bankruptcy Appeals

Chambers Communication Rules

TRO/preliminary injunction papers must be emailed to the Court (copying all relevant counsel) with 'URGENT' in the subject line, a contact phone number, and the parties' telephone-conference availability; hand delivery requires advance permission.

When seeking a preliminary injunction and/or temporary restraining order, the moving party must send all their papers (in text-searchable PDF format) to the Court by email, copying counsel for all relevant parties. The email should (1) include the word "URGENT" in the subject line; (2) provide a telephone number at which the party (and any other relevant parties) can be reached; and (3) provide the relevant parties' availability for a telephone conference. Parties should not hand-deliver any documents without advance permission from the Court.

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Page 4 | 3. Pleadings and Motions - I. Applications for Injunction and/or Temporary Restraining Order

Jury-trial submissions (including any oppositions) must also be sent to Chambers by email.

These submissions, including any oppositions, shall be filed via ECF and sent to Chambers by email, with one courtesy copy of each submitted to Chambers.

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Page 6 | 5. Trial Procedures - C. Additional Submissions in Jury Cases

Telephone calls to Chambers at (914) 390-4177 are permitted only for urgent matters requiring immediate attention.

Telephone calls to Chambers are permitted only for urgent matters requiring immediate attention. In such rare situations, call Chambers (914) 390-4177.

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Page 1 | 1. Communications with Chambers - C. Telephone Calls

Communications with Chambers must be by letter, with copies simultaneously delivered to all counsel.

Except as otherwise provided below, communications with Chambers shall be by letter, with copies simultaneously delivered to all counsel.

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Page 1 | 1. Communications with Chambers - A. Letters

Correspondence between counsel must not be sent to the Court or filed on ECF, except as exhibits to an otherwise properly filed document.

Correspondence between counsel shall not be sent to the Court or filed on ECF (except as exhibits to an otherwise properly filed document.

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Page 1 | 1. Communications with Chambers - A. Letters

Chambers may be contacted by email at RomanNYSDChambers@nysd.uscourts.gov.

Chambers Email RomanNYSDChambers@nysd.uscourts.gov

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Page 1 | Chambers Email

Docketing, scheduling, and calendar matters should be directed to Courtroom Deputy Clerk Gina Sicora at (914) 390-4178.

Please call Gina Sicora, Courtroom Deputy Clerk, at (914) 390-4178.

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Page 1 | 1. Communications with Chambers - B. Docketing, Scheduling, and Calendar Matters

Parties may request oral argument by letter when their moving or opposing reply papers are filed, and the Court will decide whether argument will be heard.

Parties may request oral argument by letter at the time their moving or opposing reply papers are filed. The Court will determine whether argument will be heard and, if so, will advise counsel of the argument date.

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Page 3 | 3. Pleadings and Motions - E. Oral Argument on Motions

All non-scheduling/urgent communications must be in writing with docket number and NSR, faxed to Court.

Letters. Except for scheduling and urgent matters, all communication with the Court should be in writing and must contain the docket number for the case and the Court's initials (NSR). Letters should be faxed to the Court.

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Page 1 | COMMUNICATIONS

Civil case conferences are held by telephone using the court’s dedicated conference line.

In Civil Cases. Unless otherwise ordered by the Court, all conferences and proceedings in civil cases will be held by telephone. In some cases, the Court may direct one of the parties to set up a conference line. In all other cases, the parties should call into the Court’s dedicated conference line at (877) 336-1839, and enter Access Code 123-1334, followed by the pound (#) key.

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Page 1 | In Civil Cases

Criminal case conferences/proceedings held by phone/video; counsel must submit letter one week before appearance.

In Criminal Cases. To the maximum extent possible, all conferences and proceedings will be held by either telephone or video. No later than one week before a scheduled appearance, counsel must confer and submit a letter to the Court indicating their views on whether the Court can, consistent with the U.S. Constitution, Federal Rules of Criminal Procedure (see, e.g., Rules 5(f), 10(b) & (c), and 43) and any other relevant law, conduct the matter by telephone or video and, if applicable, whether the Defendant either consents to appearing in that manner or to waiving his or her appearance altogether.

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Page 1 | In Criminal Cases

TRO applications must be emailed in PDF format with urgent subject line and contact information.

Parties intending to file applications for TROs or other emergency relief must send all of their papers (in text-searchable PDF format) to the Court by email. The email should (1) include the word “URGENT” in the subject line; (2) provide a telephone number at which the party (and any other relevant parties) can be reached; and (3) provide the relevant parties’ availability for a telephone conference in the next few days.

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Page 2 | Applications for Temporary Restraining Orders (“TROs”)

Pro se parties must mail communications to Pro Se Intake Unit unless granted permission for electronic filing.

Pro se parties are encouraged to (1) consent to electronic service (via ECF or email); or (2) seek the Court’s permission to file documents through the ECF system or by email to the Court. Unless the Court grants permission to file documents electronically, all communications with the Court by a pro se party must be mailed to: Pro Se Intake Unit Charles L. Brieant Courthouse 300 Quarropas Street White Plains, NY 10601

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Page 2 | By Pro Se Parties

Hand deliveries to chambers require advance permission from the court.

Nothing may be delivered to Chambers absent advance permission from the Court.

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Page 2 | Hand Deliveries

Urgent matters require email to chambers with specific formatting requirements.

For urgent matters requiring immediate attention, parties should send an email to Chambers that (1) includes the word “URGENT” in the subject line; (2) specifies the case name and docket number; (3) briefly describes the nature of the issue; and (4) provides a telephone number at which the party (and any other relevant parties) can be reached.

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Page 2 | Urgent Matters

Telephone calls to chambers will not be answered; use ECF or email instead.

Telephone calls will not be answered. Thus, parties are encouraged to make any requests or inquiries to the Court through ECF or, if permitted or required under the Court’s Individual Rules and Practices, by email.

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Page 2 | Telephone Calls

Faxes are prohibited for all purposes.

Faxes are not permitted for any purposes.

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Page 2 | Faxes

AUSA must email court immediately upon new criminal case assignment to arrange conference.

Upon assignment of a new criminal case to Judge Román, the Assistant United States Attorney must immediately email the Court to arrange for a prompt conference.

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Page 2 | In New Criminal Cases

Pro se parties must file papers with Pro Se Office.

All papers to be filed with the Court by a pro se party, along with any courtesy copies of those papers, must be sent to the Pro Se Office.

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Pro se parties must file original with Pro Se Clerk and serve other pro se parties.

The pro se party must file an original of this Statement with the Pro Se Clerk and serve a copy on all other pro se parties.

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Pro se parties must mail all communications to Pro Se Clerk, not Chambers.

All communications with the Court by a pro se party must be mailed to the Pro Se Clerk. No document or filing should be sent directly to Chambers.

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Telephone calls to Chambers only for urgent matters requiring immediate attention.

Telephone Calls. Telephone calls to Chambers are permitted only for urgent matters requiring immediate attention. In such rare situations, call Chambers at (914) 390-4177.

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Page 1 | COMMUNICATIONS

Faxes to Chambers encouraged; max 5 pages without permission; must send copies to all counsel.

Faxes to Chambers in lieu of mail or hand deliveries are encouraged. The fax number is (914) 390-4179. Copies must be simultaneously faxed or delivered to all counsel. No document longer than five pages may be faxed without prior permission.

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Page 1 | Communications with Chambers

Email to Court requires prior approval; must identify authorizing person; subject line must include docket, parties, and subject.

If a party wishes to email a .pdf letter or document to the Court, it must obtain prior approval of the Court. The body of the email must clearly identify the person in Chambers who authorized permission to send it. The email subject line must state clearly (i) the docket number of the case, (ii) the party names, and (iii) the subject of the communication.

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Page 1 | Communications with Chambers

Fax letters to Chambers preferred; do not send duplicate mail/fax; do not send counsel correspondence to Court.

Letters sent to Chambers by fax are preferred. Do not both fax and mail the same letter. Copies of correspondence between counsel shall not be sent to the Court.

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Page 1 | Communications with Chambers

Pro Se Clinic provides telephone assistance only by appointment; call to schedule.

The New York Legal Assistance Group’s Pro Se Clinic has suspended all in-person client meetings until further notice. Limited-scope legal assistance will continue to be provided, but only by appointment and only over the telephone. To schedule an appointment, call (212) 659-6190 and leave a message specifying a call-back number.

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Page 2 | Pro Se Clinic

Initial case management conference scheduled; telephone arrangements for incarcerated parties.

The Court will schedule an initial case management conference. Arrangements will be made for incarcerated parties to appear by telephone.

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Junior Lawyer Participation Incentives

The Court encourages junior attorneys who worked on the case to take an active role during conferences.

However, the Court encourages junior attorneys who have worked on the case to take an active role during conferences.

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Page 2 | 2. Conferences - B. Attendance by Principal Trial Counsel

The Court strongly encourages relatively inexperienced attorneys to participate in all types of courtroom proceedings, including conferences and trials.

As a matter of policy, the Court supports the professional development of the next generation of litigators and strongly encourages the participation of relatively inexperienced attorneys in all types of courtroom proceedings, including conferences and trials.

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Page 2 | 2. Conferences - A. In General

The Court makes a greater effort to grant oral argument where a junior attorney will argue the motion.

In keeping with the Court's commitment to providing courtroom opportunities to less experienced attorneys, the Court will make a greater effort to grant argument where a junior attorney will argue the motion.

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Page 3 | 3. Pleadings and Motions - E. Oral Argument on Motions

Court encourages participation of inexperienced attorneys in courtroom proceedings.

As a matter of policy, the Court supports the professional development of the next generation of litigators and strongly encourages the participation of relatively inexperienced attorneys in all types of courtroom proceedings, including conferences and trials.

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Page 2 | Conferences

Principal trial counsel must appear at conferences; junior attorneys encouraged to take active role.

The attorney who will serve as principal trial counsel shall appear at all conferences with the Court. However, the Court encourages junior attorneys who have worked on the case to take an active role during conferences.

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Page 2 | Conferences

Oral argument may be requested by letter when filing reply papers.

Parties may request oral argument by letter at the time their moving or opposing reply papers are filed.

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Page 4 | Pleadings and Motions

Junior attorneys who assisted in case preparation are encouraged to participate in trial.

In accordance with its policy of promoting the professional development of relatively new litigators, the Court welcomes the active participation of junior attorneys who have assisted in the preparation of the case during trial.

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About United States District Judge Nelson S. Roman

**Judge Nelson S. Roman** was appointed to the Southern District of New York by President Barack Obama in 2013. Before joining the federal bench, Judge Roman served as an Associate Justice of the New York Supreme Court Appellate Division, First Department from 2009 to 2013 and as a Justice of the New York Supreme Court from 2003 to 2009. He served in various capacities in the New York City courts beginning in 1989, including as a Housing Court Judge and Civil Court Judge. **Education** - Brooklyn Law School, J.D., 1989 - Fordham University, B.A., 1984 **Career** - U.S. District Judge, Southern District of New York (2013–present) - Associate Justice, New York Supreme Court, Appellate Division, First Department (2009–2013) - Justice, New York Supreme Court, Civil Term, Bronx County (2003–2009) - Civil Court Judge, New York City, Bronx County (2001–2002) - Housing Court Judge, Civil Court of New York City, Bronx County (1998–2000) - Law Clerk to Hon. Jose A. Padilla, Jr., Civil Court of the City of New York (1995–1998) - Assistant District Attorney, Kings County (1989–1991, 1994–1995) - Special Narcotics Assistant District Attorney, New York City (1992–1994)

**Courthouse:** Hon. Charles L. Brieant Jr. Federal Building and Courthouse, 300 Quarropas St., White Plains, NY 10601-4150 **Chambers Staff** - Scheduling/Contact: Chambers contact via court website

Common questions about Judge Nelson S. Roman's rules

Are courtesy copies required for Judge Nelson S. Roman?

Courtesy-copy rule applies for criminal complaints. Details: 1 copy, delivery upon assignment, by chambers copy. Contact Deputy Clerk for scheduling; AUSA must submit courtesy copy of criminal complaint.

View ruleSource: page 1, section COMMUNICATIONS

Does Judge Nelson S. Roman require a pre-motion conference or letter before filing a motion?

Judge Nelson S. Roman's rules set a pre-motion procedure for substitution of counsels. Substitution of counsel requires conference with Deputy Clerk.

View ruleSource: page 2, section SUBSTITUTION OF COUNSEL

What page or word limits apply to memorandum of law before Judge Nelson S. Roman?

Judge Nelson S. Roman's rule states these limits: attorney: 25 pages; attorney: 10 pages. Memoranda of law limited to 25 pages, reply memoranda to 10 pages.

View ruleSource: page 3, section Pleadings and Motions

What page or word limits apply to rule 56 1 statement before Judge Nelson S. Roman?

Judge Nelson S. Roman's rule states these limits: attorney: 25 pages. Rule 56.1 statements limited to 25 pages unless leave obtained one week prior.

View ruleSource: page 4, section Pleadings and Motions

What formatting rules apply to filings before Judge Nelson S. Roman?

Judge Nelson S. Roman's formatting rule includes 12 point type, double spacing. Memoranda must be 12-point font, double-spaced, with TOC and TOA for documents over 10 pages.

View ruleSource: page 3, section Pleadings and Motions

What must be included with general filings before Judge Nelson S. Roman?

The rule requires notice of electronic filing. Counsel must register for ECF promptly after being retained or assigned.

View ruleSource: page 1, section ECF

What must be included with status conference filings before Judge Nelson S. Roman?

The rule requires proposed trial date and pretrial motion schedule. Trial date set at status conference and will not be moved absent exceptional circumstances.

View ruleSource: page 1, section PROCEDURE

How may parties contact Judge Nelson S. Roman's chambers?

The rule addresses letter fax communications. All non-scheduling/urgent communications must be in writing with docket number and NSR, faxed to Court.

View ruleSource: page 1, section COMMUNICATIONS

How does Judge Nelson S. Roman handle sealed or redacted filings?

Judge Nelson S. Roman's rules set procedures for sealed or redacted filings. Process: file redacted on ecf. Sensitive information (SSN, minor children names, DOBs, account numbers, home addresses) must be redacted unless necessary.

View ruleSource: page 2, section SENTENCES

How do I request an adjournment or extension before Judge Nelson S. Roman?

Requests should be made at least 48 hours in advance when this rule applies before Judge Nelson S. Roman. The request must include affects other dates. Adjournment requests must be made 48 hours in advance; attach revised scheduling order if other dates affected.

View ruleSource: page 2, section Communications with Chambers

Does Judge Nelson S. Roman require motion papers to be bundled?

Yes. Judge Nelson S. Roman requires bundling for covered papers. Motion papers must be filed via ECF promptly after reply papers are served.

View ruleSource: page 3, section Pleadings and Motions

Is electronic filing required before Judge Nelson S. Roman?

Yes. Electronic filing is required for the covered filings. All letters must be filed on ECF unless they are under seal or contain sensitive or confidential information.

View ruleSource: page 1, section 1. Communications with Chambers - A. Letters

What filing deadlines apply to pretrial order filings before Judge Nelson S. Roman?

The joint pretrial order is due within 30 days after completion of discovery or, if a dispositive motion was filed, within 30 days after decision on the motion, unless otherwise ordered.

View ruleSource: page 5, section 5. Trial Procedures - A. Joint Pretrial Orders

What rule applies to service for rule 56 1 statement before Judge Nelson S. Roman?

The rule addresses service method, recipient, or timing requirements. Details: method: e-service, recipient: all parties. The summary judgment movant must provide all other parties an electronic Microsoft Word copy of its Rule 56.1 statement, and opposing parties must reproduce each entry directly beneath it.

View ruleSource: page 3, section 3. Pleadings and Motions - G. Summary Judgment Motions

Does Judge Nelson S. Roman encourage junior lawyer participation?

Yes. Judge Nelson S. Roman's rules include a junior lawyer participation incentive. Oral argument may be requested by letter when filing reply papers.

View ruleSource: page 4, section Pleadings and Motions
Complete rules summary for Judge Nelson S. Roman

Counsel must register for ECF promptly after being retained or assigned.

Trial date set at status conference and will not be moved absent exceptional circumstances.

Defendants must give narrative allocutions incorporating all elements of offense(s) before guilty plea.

Contact Deputy Clerk for scheduling; AUSA must submit courtesy copy of criminal complaint.

Telephone calls to Chambers only for urgent matters requiring immediate attention.

Defense counsel must inform Court and request Curcio hearing for benefactor payment conflicts.

Substitution of counsel requires conference with Deputy Clerk.

Discovery motions must comply with Local Criminal Rule 16.1 and include Rule 16.1 affidavit.

Defense counsel must review plea/cooperation agreements with defendant before court conference.

Plea/cooperation agreements and Pimentel letters must be received by Chambers before scheduled plea.

Bail modification requests must indicate Government and Pre-Trial Services Officer consent.

All sentencing submission documents, including letters, will be filed in public record.

Defendant files letters from friends/relatives; Government files victim letters.

Sensitive information (SSN, minor children names, DOBs, account numbers, home addresses) must be redacted unless necessary.

All non-scheduling/urgent communications must be in writing with docket number and NSR, faxed to Court.

Motion papers must be filed via ECF promptly after reply papers are served.

Proposed orders must be submitted as attachments to formal applications.

Fax letters to Chambers preferred; do not send duplicate mail/fax; do not send counsel correspondence to Court.

Faxes to Chambers encouraged; max 5 pages without permission; must send copies to all counsel.

Counsel must update ECF contact info when changed and check docket sheet regularly.

Email to Court requires prior approval; must identify authorizing person; subject line must include docket, parties, and subject.

Adjournment requests must be made 48 hours in advance; attach revised scheduling order if other dates affected.

Extension requests must be made before original deadline expires; otherwise denied absent extraordinary circumstances.

Proposed orders/stipulations requiring Court signature must be emailed to Clerk; do not file via ECF or send to Chambers.

Related cases must include both docket numbers on all future court papers and correspondence.

All attorneys must register as ECF filing users and file notice of appearance.

Adjournment/extension requests must be faxed to Chambers with specific required information.

Pre-motion conference required for most motions except specified exceptions.

Pre-motion letter (max 3 pages) required from both parties with 3 business day response time.

Memoranda of law limited to 25 pages, reply memoranda to 10 pages.

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