Judge Ronnie Abrams
Individual Rules, Standing Orders & Policies
- Rules last changed:
Limits & Logistics
Document Limits
Courtesy Copies
All filings
- 1 copy
- Hand Delivery • Upon Filing
Courtesy copies
- 1 copy • Mail
Adjournments
- Adjournment/extension requests must include original due date, previous request history, and adversary consent details.
- Extension requests made after deadline expiration are ordinarily denied.
- Adjournment/extension requests must be filed as letter-motions on ECF with specific required elements
Request must include
- Adjournment requests for court conferences require 48-hour advance notice (except emergencies).
- Adjournment requests for court appearances require 48-hour advance notice absent emergency
- Bankruptcy appeal briefs must follow Fed. R. Bankr. P. 8015-18; extensions require joint request at least 2 business days before due date.
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Intake Unit
Chambers
Phone
Chambers
Page & Word Limits9 rules
Machine summary. Not checked yet.Mandatory?
Unless otherwise provided by the court, the length limitations for filings under this rule are as follows: if filed by an attorney or prepared with a computer, briefs in support of and in response to a motion may not exceed 3,500 words, and reply briefs may not exceed 1,750 words; if filed by a party who is not represented by an attorney and handwritten or prepared with a typewriter, briefs in support of and in response to a motion may not exceed 10 pages, and reply briefs may not exceed five pages. For any brief filed by an attorney or prepared with a computer, if the court expresses a limit on the length of the brief in pages, the filing party should treat it as a word limit of 350 words per page. These limits do not include the caption, any index, table of contents, table of authorities, signature blocks, or any required certificates, but do include material contained in footnotes or endnotes. To the extent the court permits a party to submit briefs longer than these limits, and expresses those limits in pages, each additional page must not contain more than 350 additional words if the brief is filed by an attorney or prepared with a computer.
Summary: For reconsideration motion briefs: attorney/computer-prepared support/response briefs limited to 3500 words, replies to 1750 words; pro se handwritten/typewriter briefs limited to 10 pages (support/response) and 5 pages (reply). Page limits convert to 350 words per page for attorney/computer briefs. Excludes caption, TOC, TOA, sig blocks, certificates; includes footnotes/endnotes.
Brief
3,500 words
Applies to: Attorney
Brief
3,500 words
Reply Brief
1,750 words
Applies to: Attorney
Reply Brief
1,750 words
Brief
10 pages
Applies to: Pro Se
Brief
10 pages
Applies to: Pro Se
Reply Brief
5 pages
Applies to: Pro Se
Reply Brief
5 pages
Applies to: Pro Se
Machine summary. Not checked yet.Mandatory?
If filed by an attorney or prepared with a computer, briefs in support of and in response to a motion (except for motions for reconsideration) may not exceed 8,750 words, and reply briefs may not exceed 3,500 words; if the court expresses a limit on the length of a brief in pages, the filing party should treat it as a word limit of 350 words per page. If filed by a party who is not represented by an attorney and handwritten or prepared with a typewriter, briefs in support of and in response to a motion may not exceed 25 pages, and reply briefs may not exceed 10 pages. These limits do not include the caption, any index, table of contents, table of authorities, signature blocks, or any required certificates, but do include material contained in footnotes or endnotes. To the extent the court permits a party to submit briefs longer than these limits, and expresses those limits in pages, each additional page must not contain more than 350 additional words if the brief is filed by an attorney or prepared with a computer.
Summary: Attorney-filed or computer-prepared briefs (except reconsideration support/response) are limited to 8750 words (support/response) and 3500 words (reply); pro se handwritten/typewriter briefs are limited to 25 pages (support/response) and 10 pages (reply); court-set page limits equal 350 words per page.
Brief
8,750 words
Applies to: Attorney
Brief
8,750 words
Reply Brief
3,500 words
Applies to: Attorney
Reply Brief
3,500 words
Brief
25 pages
Applies to: Pro Se
Brief
25 pages
Applies to: Pro Se
Reply Brief
10 pages
Applies to: Pro Se
Reply Brief
10 pages
Applies to: Pro Se
Machine summary. Not checked yet.Mandatory?
In limine motions shall be filed no later than three (3) weeks prior to the scheduled commencement of trial, and responses shall be filed no later than two (2) weeks prior to the scheduled commencement of trial.
Summary: In limine motions due 3 weeks before trial; responses due 2 weeks before trial.
In Limine Motion
Machine summary. Not checked yet.Mandatory?
Proposed voir dire questions, jury instructions, and verdict forms shall be filed no later than two (2) weeks prior to the scheduled commencement of trial.
Summary: Voir dire, jury instructions, and verdict forms due 2 weeks before trial.
Proposed Voir Dire
Machine summary. Not checked yet.Mandatory?
Unless otherwise ordered by the Court, papers filed in opposition to a motion must be served and filed within four (4) weeks of service of the motion papers, and reply papers, if any, must be served and filed within two (2) weeks of receipt of the opposition papers.
Summary: Opposition papers due within 4 weeks; reply papers due within 2 weeks of opposition.
Motion
Machine summary. Not checked yet.Mandatory?
As set forth in Local Civil Rule 7.1, if filed by an attorney or prepared with a computer, briefs in support of and in response to motions (except for motions for reconsideration) may not exceed 8,750 words, and reply briefs may not exceed 3,500 words. If filed by a party who is not represented by an attorney and handwritten or prepared with a typewriter, briefs in support of and in response to a motion may not exceed 25 pages, and reply briefs may not exceed 10 pages.
Summary: Pro se briefs: 25 pages (support/response), 10 pages (reply). Attorney/computer briefs: 8,750 words (support/response), 3,500 words (reply).
25 pages
Applies to: Pro Se
Reply Brief
10 pages
Applies to: Pro Se
Machine summary. Not checked yet.Mandatory?
reply briefs may not exceed 3,500 words.
Summary: Reply briefs limited to 3,500 words
Reply Brief
3,500 words
Applies to: Attorney
Machine summary. Not checked yet.Mandatory?
Per Local Civil Rule 7.1, memoranda of law in support of and in opposition to motions (except for motions for reconsideration) may not exceed 8,750 words, and reply briefs may not exceed 3,500 words.
Summary: Motion memoranda limited to 8,750 words; reply briefs limited to 3,500 words
Structured details unavailable. See the source text.
Machine summary. Not checked yet.Important?
Unless the Court orders otherwise, letters may not exceed five (5) pages in length.
Summary: Letters to chambers limited to 5 pages unless otherwise ordered
Letter
5 pages
Applies to: Attorney
Document Format Requirements4 rules
Machine summary. Not checked yet.Mandatory?
all text must be double-spaced, except for headings, text in footnotes, or block quotations, which may be single-spaced.
Summary: All document text must be double-spaced, except headings, footnotes, and block quotations which may be single-spaced.
Machine summary. Not checked yet.Mandatory?
all documents must have at least one-inch margins on all sides;
Summary: All documents must have margins of at least one inch on all sides.
Machine summary. Not checked yet.Mandatory?
all text must be 12-point type or larger, except for text in footnotes which may be 10-point type;
Summary: All document text must be 12-point type or larger, with footnotes permitted to be 10-point type.
Machine summary. Not checked yet.Mandatory?
a version of the new or proposed pleading that shows—through redlining, underlining, strikeouts, or other similar typographic method—all differences from the pleading that it is intended to amend or supplement.
Summary: Redline copies of proposed amended or supplemental pleadings must show all differences from the prior pleading using redlining, underlining, strikeouts, or similar typographic methods.
Document Filing Requirements49 rules
Machine summary. Not checked yet.Mandatory?
the certificate(s) of good standing may must have been issued within one year of filing.
Summary: Pro hac vice motions for non-DOJ federal agency attorneys require a local rule certificate of good standing issued within one year of filing.
Document Type
Pro Hac Vice Motion
Machine summary. Not checked yet.Mandatory?
If the office address of an attorney who is a member of the bar of this court, or who has been authorized to appear in a case in this court, changes, the attorney must immediately update the relevant information in the PACER system and serve and file a notice of change of address in each pending case in which the attorney has appeared.
Summary: Attorneys must update PACER and serve/file a notice of address change in all pending cases when their office address changes.
Document Type
Notice Of Change Of Address
Machine summary. Not checked yet.Mandatory?
Any document submitted in accordance with these requirements must be signed by the partylitigant in one of the following ways: (a) by signing the document and then scanning it; (b) by using a digital signature; or (c) by typing: “/s/ [Party’sLitigant’s Name].”
Summary: Pro se electronic filings must be signed via one of three methods: signed and scanned, digital signature, or /s/ Name.
Document Type
Pro Se Electronic Filing
Machine summary. Not checked yet.Mandatory?
(d) No ex parte order, or order to show cause to bring on a motion, will be granted, except upon a clear and specific showing by affidavit that contains good and sufficient reasons why a procedure other than by notice of motion is necessary and states whether a previous application for similar relief has been made.
Summary: Ex parte orders or orders to show cause require an affidavit with clear showing of need for non-notice motion and disclosure of prior similar applications.
Document Type
Affidavit
Machine summary. Not checked yet.Mandatory?
If a brief is filed by an attorney or prepared with a computer, the party must also provide a certificate of compliance as required by Local Civil Rule 7.1(c).
Summary: Briefs filed by an attorney or prepared on a computer require a local rule compliance certificate per Local Civil Rule 7.1(c).
Document Type
Brief
Machine summary. Not checked yet.Mandatory?
There must be served with the notice of motion a memorandum setting forth concisely the matters or controlling decisions which the moving party believes the court has overlooked.
Summary: Motions for reconsideration must be served with a memorandum concisely stating matters or controlling decisions the court allegedly overlooked.
Document Type
Notice Of Motion
Machine summary. Not checked yet.Mandatory?
A notice of motion, or an order to show cause signed by the court, which must specify the applicable rules or statutes pursuant to which the motion is brought, and must specify the relief sought by the motion;
Summary: Notice of motion or order to show cause must specify the applicable rules/statutes and the relief sought.
Document Type
Notice Of Motion
Machine summary. Not checked yet.Mandatory?
A memorandum of law, setting forth the cases and other authorities relied on in support of the motion, and divided, under appropriate headings, into as many parts as there are issues to be determined;
Summary: Memoranda of law must set forth all relied-upon authorities and be divided into issue-based parts.
Document Type
Brief
Machine summary. Not checked yet.Mandatory?
All oppositions and replies with respect to motions must comply with subsections (a)(2) and (3), and an opposing party who seeks relief that goes beyond the denial of the motion must also comply with subsection (a)(1).
Summary: Oppositions and replies must comply with memorandum and affidavit requirements; opposing parties seeking additional relief must also include a proper notice of motion.
Document Type
Opposition
Machine summary. Not checked yet.Mandatory?
Supporting affidavits and exhibits thereto containing any factual information and portions of the record necessary for the decision of the motion;
Summary: Supporting affidavits and exhibits must contain all necessary factual information and record portions for the motion decision.
Document Type
Supporting Affidavit
Machine summary. Not checked yet.Mandatory?
Unless ordered otherwise by the district judge to whom the appeal is assigned, appellate briefs on bankruptcy appeals must comply with the briefing format and length specifications set forth in Federal Rules of Bankruptcy Procedure 8015 to 8017.
Summary: Bankruptcy appeal appellate briefs must follow Fed. R. Bankr. P. 8015-8017 unless the assigned district judge orders otherwise.
Document Type
Appellate Brief
Machine summary. Not checked yet.Mandatory?
certificate by the attorney, or party who is not represented by an attorney, that the document complies with the word-count limitations. The person preparing the certificate may rely on the word count of the word-processing program used to prepare the document. The certificate must state the number of words in the document.
Summary: All briefs must include a signed certificate certifying compliance with word-count limits and stating the word count.
Document Type
Brief
Machine summary. Not checked yet.Mandatory?
MotionsWhen amending a pleading as a matter of course pursuant to Amend or Supplement Pleadings. All motions made by a represented party under Fed. R. Civ. P. 15(a)(1) or moving for leave to file an amended or supplemental pleading pursuant to Fed. R. Civ. P. 15(a)(2) or (d) ), a represented party must also include as an exhibitfile (1) a clean copy of the new or proposed amended or supplemental pleading; and (2) a version of the new or proposed pleading that shows—through redlining, underlining, strikeouts, or other similar typographic method—all differences from the pleading that it is intended to amend or supplement. A pro se party must include a proposed amended or supplemental pleading with a motion to amend or supplement but doesis not needrequired to provide a version showing all differences from the prior pleading.
Summary: Represented parties moving to amend or supplement pleadings under Fed. R. Civ. P. 15 must include clean and redline copies of the proposed pleading; pro se parties only need the proposed pleading.
Document Type
Motion
Machine summary. Not checked yet.Mandatory?
The papers opposing a motion for summary judgment must include a correspondingly numbered paragraph admitting or denying, and otherwise responding to, each numbered paragraph in the statement of the moving party, and if necessary, additional paragraphs containing a separate, short and concise statement of additional material facts as to which it is contended that there exists a genuine issue to be tried.
Summary: Opposition papers to a summary judgment motion must include a correspondingly numbered response to each paragraph of the movant's Rule 56.1 statement, plus additional paragraphs for the opponent's own material facts.
Document Type
Summary Judgment Opposition
Machine summary. Not checked yet.Mandatory?
Unless the court orders otherwise, on motion or on its own, any motion for summary judgment under Fed. R. Civ. P. 56 must be accompanied by a separate, short, and concise statement, in numbered paragraphs, of the material facts as to which the moving party contends there is no genuine issue to be tried. Failure to submit such a statement may constitute grounds for denial of the motion. This rule does not apply to claims brought under the Administrative Procedure Act or the Freedom of Information Act.
Summary: Summary judgment motions must be accompanied by a separate, numbered, concise statement of undisputed material facts, unless the claim is under APA or FOIA; failure to submit may result in motion denial.
Document Type
Summary Judgment Motion
Machine summary. Not checked yet.Mandatory?
A statement by the movant or opponent under Rule 56.1(a) and (b) may not be incorporated by reference into a memorandum of law required by Rule 7.1. Subsection (f) of the rule was amended to clarify that statements under Rule 56.1(a) and (b) may not be incorporated by reference into supporting memoranda and cannot be used to circumvent otherwise applicable word or page limits. For the avoidance of doubt, subsection (f) is not intended to prohibit a party from citing a statement under Rule 56.1(a) or (b) where appropriate to support facts or arguments set forth in a memorandum.
Summary: Rule 56.1 statements may not be incorporated by reference into memoranda of law; citing such statements is allowed where appropriate, and the statements may not be used to circumvent applicable page or word limits.
Document Type
Memorandum Of Law
Machine summary. Not checked yet.Mandatory?
In any case where all parties are represented by counsel, the counterstatement required by this rule must include each entry in the moving party’s statement and set out the opposing party’s response directly beneath it.
Summary: When all parties are represented by counsel, the Rule 56.1 counterstatement must include each entry of the movant's statement with the opposing party's response directly beneath.
Document Type
Rule 56 1 Counterstatement
Machine summary. Not checked yet.Mandatory?
Each statement by the movant or opponent under Rule 56.1(a) and (b), including each statement denying and controverting any statement of material fact, must be followed by citation to evidence that would be admissible and set forth as required by Fed. R. Civ. P. 56(c).
Summary: Each paragraph in a Rule 56.1 statement (movant or opponent) must be followed by a citation to admissible evidence as required by Fed. R. Civ. P. 56(c).
Document Type
Rule 56 1 Statement
Machine summary. Not checked yet.Mandatory?
Written communications should be filed on ECF.
Summary: Written communications must be filed on ECF.
Document Type
Written Communication
Machine summary. Not checked yet.Mandatory?
Whenever defense counsel has received, or is receiving, benefactor payments that subject counsel to a conflict of interest, said counsel must inform the Court and request a Curcio hearing in advance of the first conference.
Summary: Defense counsel must disclose benefactor payments and request Curcio hearing before first conference.
Document Type
Conflict Disclosure
Machine summary. Not checked yet.Mandatory?
Any discovery motion must contain the Rule 16.1 affidavit.
Summary: Discovery motions must include Rule 16.1 affidavit.
Document Type
Discovery Motion
Machine summary. Not checked yet.Mandatory?
When there is a substitution of defense counsel, counsel of record must contact the Courtroom Deputy to schedule a conference. At the conference, the Court will address the application by defense counsel to be relieved. The defendant, replacement counsel, and the AUSA must also attend the conference.
Summary: Substitution of counsel requires conference with defendant, new counsel, and AUSA.
Document Type
Substitution Of Counsel
Machine summary. Not checked yet.Mandatory?
If counsel intend to distribute copies of documentary exhibits to the jury, they are to make a separate copy for each juror.
Summary: Separate exhibit copy required for each juror.
Document Type
Exhibit Distribution
Machine summary. Not checked yet.Mandatory?
Briefs filed by an attorney or prepared with a computer must be accompanied by a certificate of compliance as required by Local Civil Rule 7.1(c).
Summary: Attorney/computer briefs must include certificate of compliance.
Document Type
Motion
Machine summary. Not checked yet.Mandatory?
A. Pretrial Statement. Unless otherwise ordered by the Court, within 30 days of the completion of discovery, a pro se party shall file a concise, written Pretrial Statement. This Statement need take no particular form, but it must contain the following: (1) a statement of the facts the pro se party hopes to prove at trial; (2) a list of all documents or other physical objects that the pro se party plans to put into evidence at trial; and (3) a list of the names and addresses of all witnesses the pro se party intends to have testify at trial. The Statement must be sworn by the pro se party to be true and accurate based on the facts known by the pro se party. The pro se party shall file an original of this Statement with the Pro Se Office and an Affidavit of Service or other statement affirming that the pro se party sent a copy to all other parties or their counsel if they are represented. Two weeks after service of the pro se party’s Statement, counsel for any represented party must file and serve a similar Statement containing the same information.
Summary: Pro se parties must file Pretrial Statement within 30 days of discovery completion with specific content requirements.
Document Type
Pretrial Statement
Machine summary. Not checked yet.Mandatory?
Two weeks after service of the pro se party’s Statement, counsel for any represented party must file and serve a similar Statement containing the same information.
Summary: Represented parties must file Pretrial Statement within 2 weeks of receiving pro se party's Statement.
Document Type
Pretrial Statement
Machine summary. Not checked yet.Mandatory?
At the time of filing the Pretrial Statement, any parties represented by counsel must also submit, if the case is to be tried before only a judge without a jury, proposed findings of fact and conclusions of law, or, if it will be tried before a jury, proposed voir dire questions and jury instructions. The pro se party may also file either proposed findings of fact and conclusions of law or proposed voir dire questions and jury instructions, but is not required to do so.
Summary: Represented parties must file proposed findings/jury instructions with Pretrial Statement; pro se parties may but are not required.
Document Type
Pretrial Statement
Machine summary. Not checked yet.Mandatory?
C. A proposed default judgment.
Summary: Proposed default judgment required with motion.
Document Type
Motion
Machine summary. Not checked yet.Mandatory?
B. A proposed order to show cause.
Summary: Proposed order to show cause required with default judgment motion.
Document Type
Motion
Machine summary. Not checked yet.Mandatory?
A plaintiff seeking a default judgment must proceed by filing on ECF a motion for default judgment pursuant to Federal Rule of Civil Procedure 55(b)(2) and Local Civil Rule 55.2. A plaintiff seeking a default judgment should not proceed by order to show cause.
Summary: Default judgment must be filed as motion, not order to show cause.
Document Type
Default Judgment
Machine summary. Not checked yet.Mandatory?
The motion for default judgment must be supported by the following papers:
Summary: Default judgment motion requires specific supporting papers.
Document Type
Motion
Machine summary. Not checked yet.Mandatory?
E. A copy of the affidavit of service of the summons and complaint.
Summary: Affidavit of service required with default judgment motion.
Document Type
Motion
Machine summary. 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 the Clerk of Court has entered default under Local Civil Rule 55.1; iv. whether the party seeking default judgment has complied with the Servicemembers Civil Relief Act, 50a U.S.C. § 521; v. if the party against whom judgment is sought is a minor or an incompetent person, whether they are represented by a general guardian, conservator, or other fiduciary who has appeared; vi. 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; vii. a statement of damages, sworn or affirmed to by one or more people with personal knowledge, in support of the request, showing the proposed damages and the basis for each element of damages, including interest, attorney’s fees, and costs; and viii. legal authority for why an inquest into damages would be unnecessary.
Summary: Attorney’s affidavit must include 8 specific elements for default judgment.
Document Type
Motion
Machine summary. Not checked yet.Mandatory?
D. Copies of all of the pleadings.
Summary: Copies of all pleadings required with default judgment motion.
Document Type
Motion
Machine summary. Not checked yet.Mandatory?
Prior to the hearing date, the plaintiff must file on ECF proof of service in the manner and by the date specified by the Court’s order setting the default judgment hearing.
Summary: Proof of service must be filed on ECF before hearing.
Document Type
Motion
Machine summary. Not checked yet.Mandatory?
If the Court issues such an order, the plaintiff should be prepared to serve on the defendant (a) a conforming copy of the motion and supporting papers and (b) the Court’s order setting the date and time for the default judgment hearing.
Summary: Plaintiff must serve motion and court order if hearing set.
Document Type
Motion
Machine summary. Not checked yet.Mandatory?
F. A certificate of service, executed by the plaintiff or plaintiff’s attorney, stating that the motion for default judgment, including the “Clerk’s Certificate of Default” and any papers required by Local Civil Rule 55.2, have been personally served on, or mailed to the last known residence (for an individual defendant) or business address (for other defendants) of, the party against whom default judgment is sought. If the mailing is returned, a supplemental certificate of service must be filed setting forth that fact, together with the reason provided for return, if any.
Summary: Certificate of service required for default judgment motion.
Document Type
Motion
Machine summary. Not checked yet.Mandatory?
G. A Certificate of Default from the Clerk of Court.
Summary: Clerk’s Certificate of Default required with motion.
Document Type
Motion
Machine summary. Not checked yet.Mandatory?
Any party unable to comply with the requirement for electronic filing under seal through the ECF system, or who believes that a particular document should not be electronically filed at all, shall file a letter-motion by e-mail, in accordance with Paragraph 1(A) above, seeking leave of the Court to file in a different manner.
Summary: Parties must file letter-motion by email to seek leave to file documents differently than standard ECF procedures.
Document Type
Letter Motion
Machine summary. Not checked yet.Mandatory?
The letter-motion must include a representation that the meet-and-confer process occurred and was unsuccessful.
Summary: Discovery dispute letters must certify that meet-and-confer process occurred and failed
Document Type
Discovery Dispute Letter
Machine summary. Not checked yet.Mandatory?
file joint proposed voir dire questions, a verdict form, and jury instructions. These joint submissions shall consist of single documents, jointly composed, noting any areas of disagreement between the parties.
Summary: In jury cases, parties must jointly file voir dire questions, verdict form, and jury instructions as single documents noting disagreements.
Document Type
Jury Preparation Documents
Machine summary. Not checked yet.Mandatory?
Except in pro se cases, the moving party shall provide all other parties with an electronic copy, in Word format, of the moving party’s Statement of Material Facts Pursuant to Local Civil Rule 56.1.
Summary: Moving party must provide electronic copy of Rule 56.1 statement in Word format to all parties (except pro se cases)
Document Type
Motion For Summary Judgment
Machine summary. Not checked yet.Mandatory?
Sur-reply memoranda will not be accepted without prior permission of the Court.
Summary: Sur-replies require prior court permission
Document Type
Sur Reply
Machine summary. Not checked yet.Mandatory?
Unless otherwise specified by the Court, within thirty (30) days after the close of discovery or if any dispositive motion is filed, within thirty (30) days from the Court’s decision on such motion, the parties shall submit a proposed joint pretrial order by email to Abrams_NYSDChambers@nysd.uscourts.gov.
Summary: Joint pretrial order must be submitted by email within 30 days after discovery closes or 30 days after dispositive motion decision.
Document Type
Joint Pretrial Order
Machine summary. Not checked yet.Important?
No party is to file an affidavit unless directed by the court.
Summary: Affidavits may only be filed if expressly directed by the court.
Document Type
Affidavit
Machine summary. Not checked yet.Important?
Sur-reply memoranda will not be accepted without prior permission of the Court.
Summary: Sur-reply memoranda require prior court permission.
Document Type
Motion
Machine summary. Not checked yet.Important?
Memoranda of 3,500 words or more shall contain a table of contents and a table of authorities, and shall conform to Local Civil Rule 11.1.
Summary: Memoranda of 3,500+ words require table of contents and table of authorities
Document Type
Motion Memorandum
Machine summary. Not checked yet.Important?
The Court will not retain jurisdiction to enforce confidential settlement agreements. If the parties wish that the Court retain jurisdiction to enforce a settlement agreement, the parties must place the terms of their agreement on the public record.
Summary: Court will not retain jurisdiction over confidential settlement agreements unless terms are placed on public record.
Document Type
Settlement Agreement
Machine summary. Not checked yet.Note?
Sealed documents must continue to be filed in the court's Electronic Case Filing (ECF) system in accordance with Local Civil Rule 5.2 and the ECF Rules & Instructions.
Summary: Sealed documents must continue to be filed in ECF system per Local Civil Rule 5.2
Document Type
Sealed Document
Filing & Service rules
Electronic Filing Rules
Attorneys for DOJ or Federal Defenders of NY must request e-filing privileges via PACER.
Those attorneys must request electronic filing privileges through the PACER website.
Machine summary. Not checked yet. · Court notice · Notice of rule changes; check the effective date before relying on it
Page 3 | The Eastern and Southern Districts of New York Invite Public Comment on Proposed Changes to the Courts’ Joint Local Rules
Counsel must e-file via ECF per court instructions, except when exempted by court order or Fed. R. Civ. P. 5.
Counsel must serve and file papers by following the instructions regarding ECF published on the website of each respective court, unless exempted from electronic filing by court order or Fed. R. Civ. P. 5.
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Page 4 | Signatures by Pro Se PartiesLitigants; Duty to Review Underlying Orders
Highly Sensitive Documents must be filed in hard copy per district orders.
Highly Sensitive Documents (HSDs) must be filed in hard copyhardcopy, in accordance with the order issued by each district governing those documents.
Machine summary. Not checked yet. · Court notice · Notice of rule changes; check the effective date before relying on it
Page 4 | Signatures by Pro Se PartiesLitigants; Duty to Review Underlying Orders
Unless exempt, all filing and service must be completed via the ECF electronic system.
(c) Unless otherwise exempt, filing and service must be accomplished via ECF.
Machine summary. Not checked yet. · Court notice · Notice of rule changes; check the effective date before relying on it
Page 5 | Local Civil Rule 6.1(c)
Presiding judges may grant e-filing privileges to pro se litigants; if not, electronic submissions are accepted per court website requirements.
InA judge presiding over a case wheremay grant electronic filing privileges to a pro se partylitigant. If a pro se litigant has not obtained electronic filing privileges in a case, the United States District Courts for the Eastern and Southern Districts of New York will accept electronic submissions from pro se parties without electronic filing privileges pursuant tothat litigant based on certain requirements that will be set forth on each Court’s public website.
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Page 4 | Signatures by Pro Se PartiesLitigants; Duty to Review Underlying Orders
Filing Timing and Cure Windows
Represented parties must file the amended or supplemental pleading within seven days of the order granting a Fed. R. Civ. P. 15(a)(2) or (d) motion.
The granting of a motion under Rule 15(a)(2) or (d) does not constitute the filing of the amended or supplemental pleading. Unless the court orders otherwise, a represented moving party must file the new pleading within seven days of the order granting the motion.
Machine summary. Not checked yet. · Court notice · Notice of rule changes; check the effective date before relying on it
Page 9 | Filing of Amended or Supplemental Pleading
Service and Proof of Service Rules
For civil motions not under Rule 6.1(a) and not habeas petitions, opposing papers must be served within 14 days of moving papers service.
(b) On all civil motions, petitions, and applications, other than those described in Rule 6.1(a), and other than petitions for writs of habeas corpus, (1) the moving papers must be served by the moving party on all other parties that have appeared in the action, (2) any opposing or response papers must be served within 14 days after service of the moving papers, and (3) any reply papers must be served within seven days after service of the answering papers. In computing periods of days, refer to Fed. R. Civ. P. 6.
Machine summary. Not checked yet. · Court notice · Notice of rule changes; check the effective date before relying on it
Page 5 | Local Civil Rule 6.1(b)
For motions under Fed. R. Civ. P. 26-37 and 45(d)(3), opposing papers must be served within 7 days of moving papers service, replies within 2 days of answering papers service; compute days per Fed. R. Civ. P. 6.
(a) On all motions and applications under Fed. R. Civ. P. 26 through 37 and 45(d)(3), (1) all motion papers must be served by the moving party on all other parties that have appeared in the action, (2) any opposing or response papers must be served within seven days after service of the moving papers, and (3) any reply papers must be served within two days after service of the answering papers. In computing periods of days, refer to Fed. R. Civ. P. 6.
Machine summary. Not checked yet. · Court notice · Notice of rule changes; check the effective date before relying on it
Page 5 | Local Civil Rule 6.1(a)
Motions for reconsideration must be served within 14 days of the entry of the challenged court order, unless otherwise provided.
Unless otherwise provided by the court or by statute or rule (such as Fed. R. Civ. P. 50, 52, and 59), a notice of motion for reconsideration must be served within 14 days after the entry of the court’s order being challenged.
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Page 6 | Local Civil Rule 6.2 (reconsideration)
When all parties are represented by counsel, the moving party for summary judgment must provide an electronic copy (standard word processing format) of their Statement of Material Facts to all other parties.
In any case where all parties are represented by counsel, any party moving for summary judgment must provide all other parties with an electronic copy, in a standard word processing format, of the moving party’s Statement of Material Facts.
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Page 13 | Judgment (e)
Filing Fees and Waivers
Pro hac vice admission fee is waived for non-DOJ federal agency attorneys; certificate of good standing issued within one year required.
Attorneys appearing for other federal agencies other than the Department of Justice must move for pro hac vice admission, but the fee requirement is waived, and the certificate(s) of good standing may must have been issued within one year of filing.
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Page 3 | The Eastern and Southern Districts of New York Invite Public Comment on Proposed Changes to the Courts’ Joint Local Rules
Courtesy Copy Requirements
AUSA must provide courtesy copies of Indictment and Complaint to Chambers promptly.
The Assistant United States Attorney ("AUSA") shall provide to Chambers, as soon as practicable, a courtesy copy of the Indictment and the Complaint, if one exists.
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Page 1 | Initial Matters
Two courtesy copies and Word email required for pretrial submissions.
At the time of filing, each party shall submit two courtesy copies of these materials to the Court. In addition, each party shall email those documents as a Microsoft Word document to Abrams_NYSDChambers@nysd.uscourts.gov.
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Page 2 | Trial Procedures
Government must provide 3 copies of witness/exhibit lists and 1 set of exhibits/materials at trial start.
At the start of trial, the Government shall provide the Court with three copies of the witness list and exhibit list and one set of pre-marked documentary exhibits and Section 3500 material assembled sequentially in a looseleaf binder, or in separate manila folders labeled with the exhibit numbers and placed in a suitable container for ready reference. In addition, each party shall email the documents to Abrams_NYSDChambers@nysd.uscourts.gov.
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Page 2 | Trial Procedures
Pro se parties must send all filings and courtesy copies to Pro Se Intake 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 Intake Office.
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Page 1 | Filing of Papers
All motion papers require one courtesy copy clearly marked as such.
All motion papers should include one courtesy copy. All courtesy copies shall be clearly marked as such.
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Page 2 | Motions
Courtesy copy required for motions with exhibits/voluminous record when reply is served
Under such circumstances, one courtesy copy of all motion papers, marked as such, should be submitted to the Court by the movant at the time the reply is served, in accordance with the SDNY policies regarding mail deliveries.
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No courtesy copies needed for letters filed on ECF.
Parties should not submit courtesy copies of letters filed on ECF.
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Page 1 | Communications with Chambers
Sealing & Redaction Procedures
Sealed court orders must be served by first-class mail or other secure means approved by judge
Sealed court orders will be served by first-class mail or other secure means approved by the issuing judge.
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Page 2 | New Service Procedure
Service of sealed documents must be done outside ECF with proof of service filed in ECF
Service must now be accomplished outside of ECF by other appropriate means as provided by the applicable Federal Rules of Procedure. Service of filed documents outside the ECF system must always be followed by the filing of proof of service in the ECF system.
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Page 2 | New Service Procedure
Sealed documents cannot be served via CM/ECF; must use other appropriate means.
Service of Sealed Documents Filed in CM/ECF – Because sealed documents filed in CM/ECF are no longer electronically accessible or viewable by non-court users, service of those documents can no longer be accomplished through CM/ECF. Parties must serve sealed documents by other appropriate means consistent with the applicable Federal Rules of Procedure.
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Page 3 | Service of Sealed Documents Filed in CM/ECF
Sealed orders must be served in paper form by first-class mail or other secure means.
Sealed orders of the court will be served in paper form by first-class mail or other secure means approved by the issuing judge.
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Page 3 | Service of Sealed Documents Filed in CM/ECF
Sealed/sensitive letters may be emailed as PDF with copies to all counsel.
Letters to be filed under seal or containing sensitive or confidential information may be emailed as a .pdf attachment to Abrams_NYSDChambers@nysd.uscourts.gov with a copy simultaneously delivered to all counsel.
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Page 1 | Communications with Chambers
All redactions or sealing of public court filings require court approval except for permitted categories
Except for redactions permitted by the previous Paragraph, all redactions or sealing of public court filings require Court approval.
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Two categories of information may be redacted without court approval: sensitive information and information requiring caution
There are two categories of information that may be redacted from public court filings without prior permission from the Court: “sensitive information” and information requiring “caution.”
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Meet and confer with opposing parties/third parties before seeking to file sealed/redacted materials
The party seeking leave to file sealed or redacted materials should meet and confer with any opposing party (or any third party seeking confidential treatment of the information) in advance to narrow the scope of the request.
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File letter-motion seeking leave to file document under seal on ECF following Standing Order 19-MC-583
The party shall electronically file a letter-motion seeking leave to file a document under seal on ECF in accordance with Standing Order 19-MC-583 and Section 6 of the S.D.N.Y. Electronic Case Filing Rules and Instructions.
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Sealed documents electronically filed are no longer accessible via ECF or PACER by non-court users
Sealed documents filed electronically will no longer be accessible or viewable through the ECF or PACER systems by non-court users.
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Page 1 | What's New
Service of sealed documents can no longer be done by electronic filing in ECF
Service of sealed documents will no longer be accomplished by electronically filing in the ECF system.
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Page 2 | New Service Procedure
Access to electronically filed sealed documents requires copy from adversary or paper request to clerk
To obtain access to an electronically filed sealed document, users should rely on the copy served by their adversary. A party with a right to access a sealed document may also request a paper copy by contacting the clerk's office.
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Page 2 | What's New
Parties must request paper copies of sealed documents from opposing counsel or clerk's office.
Additional Copies of Sealed Documents – Because sealed documents filed in CM/ECF are no longer electronically accessible or viewable by non-court users, a party with the right to access a sealed document in a case who requires a copy of a sealed document may contact opposing counsel or the clerk’s office to request a paper copy. Applicable copy fees will be applied to requests made to the court.
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Page 4 | Additional Copies of Sealed Documents
Pre-Motion Conference Requirements
Letter-motions are permitted for extensions, adjournments, pre-motion conferences, and nondispositive matters; other motions require judicial authorization.
Applications for extensions or adjournments, applications for a premotion conference, and similar nondispositive matters may be brought by letter-motion. Other motions cannot be brought by letter-motion unless authorized by the judge’s individual practices or order issued in a particular case.
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Page 8 | Letter-motions (e)
Discovery motions (Fed. R. Civ. P. 26-37, 45) require a pre-motion letter-motion for an informal conference before being heard, unless the presiding judge's individual practices dictate otherwise.
Unless the individual practices of the judge presiding over discovery require a different procedure, no motion under Fed. R. Civ. P. 26 through 37 inclusive and Fed. R. Civ. P. 45 will be heard unless counsel for the moving partymovant has first requested an informal conference with the court by letter-motion for a premotion discovery conference and that request has either been denied or the discovery dispute has not been resolved as a consequence of the conference.
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Page 10 | Discovery Motion Pre-Motion Conference Requirement
Entry of default under Rule 55(a) required before default judgment motion.
Before seeking a default judgment, a plaintiff must seek the entry of default under Fed. R. Civ. P. 55(a) by filing a “Request to Enter Default” and other supporting papers consistent with Local Civil Rule 55.1.
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Page 9 | DEFAULT JUDGMENT PROCEDURE
Requests for adjournments, extensions, and pre-motion conferences for discovery disputes must be filed as letter-motions via ECF
Letter-motions filed via ECF must comply with the S.D.N.Y. Local Rules and the S.D.N.Y. “Electronic Case Filing Rules and Instructions.” In particular, all requests for adjournments, extensions, and pre-motion conferences with respect to discovery disputes should be filed as letter-motions.
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Non-moving party must notify court within 14 days of motion to dismiss whether amending or relying on pleading
When a motion to dismiss is filed, the non-moving party must, within fourteen (14) days of receipt of the motion, notify the Court and its adversary in writing whether (i) it intends to file an amended pleading and when it shall do so, or (ii) it will rely on the pleading being attacked.
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Default judgments must be sought by motion following Attachment A procedure
A plaintiff seeking a default judgment must proceed by way of a motion pursuant to the procedure set forth in Attachment A.
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Court may set hearing date for default judgment.
The Court will review the motion for default judgment and, if appropriate, issue an order setting a date and time for a default judgment hearing.
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Page 10 | DEFAULT JUDGMENT PROCEDURE
Oral argument may be requested by filing letter on ECF when filing moving, opposing, or reply papers
Parties may request oral argument at the time they file their moving, opposing, or reply papers. They may do so by filing on ECF a letter specifically requesting oral argument.
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Adjournment & Extension Requirements
Adjournment requests for court conferences require 48-hour advance notice (except emergencies).
Absent an emergency, any request for adjournment of a court conference shall be made at least 48 hours prior to the scheduled appearance.
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Page 1 | Communications
Adjournment/extension requests must include original due date, previous request history, and adversary consent details.
All requests for adjournments or extensions of time must be made in writing and must state: (1) the original due date; (2) the number of previous requests for adjournments or extensions; (3) whether these previous requests were granted or denied; and (4) whether the adversary consents and, if not, the reasons given by the adversary for refusing to consent.
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Page 1 | Communications
Adjournment requests for court appearances require 48-hour advance notice absent emergency
If the request is for an adjournment of a court appearance, absent an emergency, the request shall be made at least 48 hours prior to the scheduled appearance.
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Adjournment/extension requests must be filed as letter-motions on ECF with specific required elements
D. Requests for Adjournments or Extensions of Time. All requests for adjournments or extensions of time must be made in writing and filed on ECF as letter-motions. (If such request contains sensitive or confidential information, it may be submitted by email and served on opposing counsel.) The letter-motion must state: (1) the original due date, (2) the number of previous requests for adjournments or extensions of time, (3) whether
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Bankruptcy appeal briefs must follow Fed. R. Bankr. P. 8015-18; extensions require joint request at least 2 business days before due date.
Briefs must be submitted in accordance with Fed. R. Bankr. P. 8015–18. Counsel may seek to extend these dates by joint request submitted to the Court no later than two business days before the brief is due.
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Extension requests made after deadline expiration are ordinarily denied.
Requests for extensions ordinarily will be denied if made after the expiration of the original deadline.
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Page 1 | Communications
Chambers Communication Rules
Opposing party must call chambers within 1 business day and respond by letter within 3 business days for discovery disputes
If the opposing party wishes to respond, it must call Chambers within one (1) business day to advise that a responsive letter will be forthcoming, and its response shall be by letter to the Court not exceeding three pages within three (3) business days of the filing of the original letter-motion.
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Substantive communications must be in letter body, not email body.
Parties shall not include substantive communications in the body of the email; such communications shall be included only in the body of the letter.
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Page 1 | Communications with Chambers
Sidebars discouraged; anticipate issues in advance.
Sidebars during jury trials are discouraged. Counsel are expected to anticipate any problems that might require argument and to raise those issues with the Court in advance of the time that the jury will be hearing the evidence.
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Page 2 | Trial Procedures
Questions about sealed documents should be directed to ECF Help Desk via email during business hours
Questions about the filing of and access to sealed documents may be directed to the court's ECF Help Desk. The Help Desk is available via email at helpdesk@nysd.uscourts.gov, Monday through Friday during business hours.
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Page 2 | Questions about the filing
Contact ECF Help Desk at helpdesk@nysd.uscourts.gov for questions about sealed documents.
Questions about Sealed Document Procedures – Questions about the filing of and access to sealed documents may be directed to the court’s ECF Help Desk. The Help Desk is available via email at helpdesk@nysd.uscourts.gov, Monday through Friday during business hours.
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Page 4 | Questions about Sealed Document Procedures
Jurors may deliberate on Fridays.
Jurors may deliberate on Fridays.
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Page 2 | Trial Procedures
Trials run Mon-Thu 10am-5pm; counsel meetings 9:30-10am.
Trials will generally be conducted Monday through Thursday from 10:00 a.m. to 5:00 p.m. The Court will be available to meet with counsel from 9:30 a.m. to 10:00 a.m.
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Page 2 | Trial Procedures
Sensitive letters may be emailed to chambers as searchable PDF with courtesy copies to counsel
Letters containing sensitive or confidential information that cannot be filed on ECF in accordance with the procedures set forth in Paragraph 5 below may be emailed to the Court (Abrams_NYSDChambers@nysd.uscourts.gov) as a text-searchable .pdf attachment with a copy simultaneously delivered to all counsel.
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