Southern District of New York Local Rules and Judge Filing Requirements

AI tools not prohibited but counsel must personally verify accuracy.

The cover email subject line should clearly identify the case caption, lead party names, docket number, and nature of the request.

Plaintiff has 21 days to amend pleading after motion to dismiss; original motion dismissed as moot if amended.

Attorneys need prior Court Order authorization to bring non-personal electronic equipment into the courthouse.

Class action settlement requires detailed financial disclosure.

Hand-delivered mail should be left with Court Security Officers at the specified entrance and may not be brought directly to Chambers, except by representatives of the U.S. Attorney’s Office or the Federal Defenders of New York.

Technical ECF questions should go to the ECF Help Desk, not Chambers.

Incarcerated parties may participate by telephone if unable to attend in-person conferences.

Requests to appear by telephone at conferences must be submitted via ECF at least two days before the scheduled conference date.

Emails to Chambers are only permitted for urgent matters requiring immediate attention or when otherwise expressly permitted by the Court in advance.

Sealed or sensitive letters may be emailed as text-searchable PDFs with specific subject line requirements.

Redactions/sealing must be narrowly tailored and consistent with public access presumption.

Parties unable to e-file under seal on ECF, or who believe a document should not be filed on ECF, must move for leave to file on paper.

Request leave to file on paper if unable to comply with electronic filing requirements.

FRCP 5.2 requires redaction of sensitive information without court approval.

Court appearance adjournments require 2 business days advance notice.

Interim discovery deadlines may be extended by written consent of all parties without court application, provided fact discovery is completed by the deadline.

Revised scheduling order required if adjournment affects other dates.

Sentencing adjournment requests must be made no later than 72 hours before the proceeding.

Adjournment requests require 48 hours notice (72 hours for sentencing), except in emergencies.

Patent cases require Rule 16 conference with pre-conference scheduling discussion.

Two sets of pre-motion letters required for motions to dismiss.

A party seeking default judgment should not proceed by order to show cause.

Discovery disputes require good faith conferral with Lead Trial Counsel participation, 2-business-day response requirement, and 10-business-day waiting period before filing with the Court.

Motion for default judgment required under FRCP 55(b)(2) and Local Rule 55.2(b); order to show cause not permitted.

The AUSA must provide chambers courtesy copies of the Indictment or Information and, if one exists, the Complaint as soon as practicable.

No courtesy copies required for letters filed on ECF.

Counsel must provide 2 pre-marked exhibit sets to the Court at least 5 days before the final pretrial conference.

Courtesy copies must be labeled, double-sided, three-hole punched, and tabbed (not in binders).

The non-pro-se party should submit one hard-copy courtesy copy of all formal motion papers, marked as a courtesy copy, to Chambers when the reply is due.

Defendant's combined summary judgment motion and opposition memorandum limited to 50 pages.

Letters to the Court are limited to 5 pages.

Opposition to letter-motions limited to 3 pages, due within 2 business days.

Memoranda in support/opposition are limited to 8,750 words; reply memoranda are limited to 3,500 words.

Fact discovery must be completed within 120 days of initial pretrial conference.

Each deposition testimony entry submitted with summary judgment motions must be separately tabbed and indexed.

Deposition indexes should be included with supplied depositions if available.

Speaking counsel must have video on and be unmuted when speaking; non-speaking counsel must have video off and remain muted.

Proposed jury charges/voir dire and proposed findings/conclusions must be submitted in hard copy and MS Word format.

Calculation files supporting proposed damages must be provided in their original format, such as .xlsx.

In jury cases, joint requests to charge, joint proposed verdict forms, and joint proposed voir dire questions must be filed simultaneously with the Joint Pretrial Order on the date set by the Court.

Counsel are prohibited from setting a return date for motions.

Opposition documents must be filed no less than two days before the scheduled trial date.

A response or opposition to a pretrial memorandum of law is due two weeks after the opening memorandum is filed.

The proposed order must be submitted five days before the previously excluded time expires.

Plaintiffs must ensure that a copy of the operative complaint is posted electronically to the ECF docket.

Discovery dispute letter-motions must be filed on ECF.

Letters should be filed electronically on ECF, except when a letter is requested to be filed under seal or contains sensitive or confidential information.

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

Motions for sealed or redacted filings must be electronically filed via the court’s ECF system per applicable rules and orders.

A party filing one of the specified motions must provide the pro se party with the notices required by Local Civil Rule 12.1 or 56.2.

Opposing parties are not required to serve responsive papers to motions for reconsideration unless directed by Judge McMahon.

All documents supporting a default-judgment request must be personally served on or mailed to the party against whom default judgment is sought.

The represented party must simultaneously mail a copy of the Proposed Case Management Plan for Pro Se Cases to the pro se party.

Affidavits of direct trial witness testimony must be served on opposing counsel.

Court encourages participation of inexperienced attorneys in courtroom proceedings.

Oral argument granted at judge's discretion

The Court may allow multiple lawyers for one party to argue when that creates an opportunity for a junior lawyer.

Junior members of legal teams are invited to address the Court at case management conferences so firms can give them training opportunities.

The Court encourages junior attorney participation in all proceedings and permits more than one attorney to argue per party to create junior attorney opportunities.

Motion papers must be filed on ECF only when fully briefed (except pro se).

Trials in civil consent cases scheduled for firm dates, rarely changed.

Motion papers must be filed promptly after service.

Submit two tabbed binders of exhibits before any hearing.

In non-ECF cases, letters should be bundled into one paper filing under a single cover.

Pro hac vice admission fee is waived for non-DOJ federal agency attorneys; certificate of good standing issued within one year required.