Court Rules
Magistrate Judge

Judge Sarah L. Cave

Individual Rules, Standing Orders & Policies

Rules last changed:
Southern District of New York

Limits & Logistics

Document Limits

Letter
1,050 wds
Letter Motion
1,050 wds
Pretrial Memorandum
8,750 wds
Settlement Conference Letter
4 pgs

Courtesy Copies

Courtesy copies

  • By Business Day Before Trial
  • Not required

Filings > 50 pages

  • 1 copy • Hand Delivery • Promptly After Filing

Adjournments

  • Parties may extend interim discovery deadlines by written consent without court application if the 6(A) fact discovery deadline is met.
  • Adjournment/extension requests must be filed as letter-motions with specific required elements.
  • Settlement conference adjournments must be filed as Letter-Motion on ECF
  • +1 more

Request must include

Reason For RequestOriginal DateNumber Of Previous RequestsPrevious Requests Granted Or DeniedAdversary PositionProposed Rescheduled DateProposed New Dates
48Hoursnotice
  • Adjournment requests must be made at least 48 hours in advance with 2 proposed dates.
Proposed New Dates
14Calendar Daysnotice
  • Adjournment requests must be made promptly; no reason needed if >14 days in advance, otherwise reasons required.
Reason For Request

Communication

Email

Chambers

Emergencies
Hours: at least 24 hours prior to the court proceeding
No status inquiries
Letter via ECF

Intake Unit

No status inquiries
Hand Delivery

Chambers

No status inquiries
Phone

Chambers

Technical Issues
Cases:
Filters:AllMandatoryImportantConferencesSettlementLettersDiscoveryElectronicsExhibitsMemorandaJPTO

Page & Word Limits5 rules

Page Limits

Machine summary. Not checked yet.Mandatory?

Letters may not exceed 1,050 words in length, exclusive of attachments, which should be kept to a minimum.

Summary: Letters to chambers are limited to 1,050 words (excluding attachments).

Letter

1,050 words

Applies to: Attorney

Page Limits

Machine summary. Not checked yet.Mandatory?

Letters in opposition and replies may not exceed 1,050 words in length exclusive of attachments, which should be kept to a minimum.

Summary: Letters in opposition and replies are limited to 1,050 words.

Letter Motion

1,050 words

Applies to: Attorney

Page Limits

Machine summary. Not checked yet.Mandatory?

No later than four business days before the conference, each party must send to the Court and opposing counsel a letter of no longer than four (4) pages marked “Confidential Materials For Use Only At Settlement Conference,” setting forth concisely the following: (1) a discussion of the relevant facts and applicable law, with an emphasis on the issues more pertinent to settlement, including a discussion of liability and damages in the event liability were established; (2) if non‐monetary relief—including a general or specific release of claims—is sought in addition to or instead of money damages, each party must set forth its position as to the provision of such relief; (3) the existence and amount of any lien(s) that may attach to the settlement proceeds; and (4) the history of settlement discussions, including any prior offers or demands.

Summary: Settlement conference letter must be 4 pages or less and include specific content

Settlement Conference Letter

4 pages

Applies to: Attorney

Page Limits

Machine summary. Not checked yet.Mandatory?

At the settlement conference, counsel for each side should expect to make a succinct presentation (10–15 minutes) in the presence of all parties and the Court summarizing the to consider for purposes of formulating a settlement position.

Summary: Settlement conference presentations limited to 10-15 minutes

Structured details unavailable. See the source text.

Page Limits

Machine summary. Not checked yet.Important?

In non‐jury cases, where ordered by the Court, parties must file proposed findings of fact and statements of law. If the parties believe it would be useful, they may file pretrial memoranda limited to 8,750 words.

Summary: Non-jury cases may file pretrial memoranda up to 8,750 words.

Pretrial Memorandum

8,750 words

Applies to: Attorney

Document Filing Requirements32 rules

Filing RequirementsCivil cases

Machine summary. Not checked yet.Mandatory?

In accordance with Federal Rule of Civil Procedure 26(f) and Judge Cave’s Individual Practices, the parties met on __________________ (at least one week before the Initial Case Management Conference) and exchanged communications thereafter. The parties now submit the following report for the Court’s consideration:

Summary: Rule 26(f) conference report must certify parties met at least one week before Initial Case Management Conference and include caption, case number, and judge name.

Document Type

Rule 26f Conference Report

Content & Formatting
Caption
Case Number
Judge Name
Certificate Of Conference
Filing RequirementsCivil cases

Machine summary. Not checked yet.Mandatory?

Counsel represent by their signature below that they have read and will comply with the above.

Summary: Rule 26(f) conference report requires counsel signature certifying compliance with court expectations.

Document Type

Rule 26f Conference Report

Specific requirements detailed in rule text.
Filing RequirementsCivil cases

Machine summary. Not checked yet.Mandatory?

No later than one week after the close of fact discovery, that is, by ____, the parties must file a joint letter on the docket certifying that fact is discovery is complete.

Summary: Parties must file a joint docket letter certifying fact discovery is complete no later than one week after fact discovery closes.

Document Type

Joint Letter

Specific requirements detailed in rule text.
Filing RequirementsCivil cases

Machine summary. Not checked yet.Mandatory?

No later than one week after the close of expert discovery, that is, by____, the parties must file a joint letter on the docket certifying that all discovery is complete. This letter should also state which dispositive motions, if any, each party intends to file.

Summary: Parties must file a joint docket letter certifying all discovery is complete and stating intended dispositive motions no later than one week after expert discovery closes.

Document Type

Joint Letter

Specific requirements detailed in rule text.
Filing Requirements

Machine summary. Not checked yet.Mandatory?

G. Citations. All moving papers, letter-motions, and letters filed on ECF or emailed to Chambers when permitted must be in searchable PDF form. When citing unreported cases, parties shall use Westlaw citations whenever possible. Citations to all documents filed on ECF must include the ECF document number and ECF page number. For example, citation to an exhibit accompanying a declaration would appear as “ECF No. 123-4 at 10,” rather than “Smith Decl. Ex. 4 at 10.”

Summary: Citations must be in searchable PDF and include ECF document/page numbers

Document Type

Moving Papers

Specific requirements detailed in rule text.
Filing Requirements

Machine summary. Not checked yet.Mandatory?

B. Confidentiality Stipulations and Protective Orders. In cases where confidential information will be exchanged, the parties must utilize the Court’s Model Confidentiality Stipulation and Proposed Protective Order found at www.nysd.uscourts.gov/hon-sarah-l-cave. The parties may apply for a protective order that differs from the Court’s model by submitting a letter request via ECF and attaching the proposed order showing in a blackline comparison how the proposed order differs from the Court’s model. The letter should explain why the modifications are needed and note any disagreements between the parties regarding the modifications from the Court’s model.

Summary: Must use Court's Model Confidentiality Stipulation and Protective Order; modifications require letter request via ECF

Document Type

Confidentiality Stipulation

Content & Formatting
Caption
Case Number
Judge Name
Filing Requirements

Machine summary. Not checked yet.Mandatory?

1. Pro Se Cases. Each party must submit a Case Report and Proposed Case Management Plan for Pro Se Cases one (1) week before the scheduled conference in conformance with the procedures in Section I above. The parties shall use the form Proposed Case Management Plan template for Pro Se Cases found at www.nysd.uscourts.gov/hon-sarah-l-cave.

Summary: Pro Se Cases must submit Case Report and Proposed Case Management Plan 1 week before conference

Document Type

Case Report

Content & Formatting
Caption
Case Number
Judge Name
Filing Requirements

Machine summary. Not checked yet.Mandatory?

A. Initial Case Management Conference. Except for Pro Se Cases, parties must confer and file a Report of Rule 26(f) Conference and Proposed Case Management Plan one (1) week before the Initial Case Management Conference. A template form for the Report of Rule 26(f) Conference and Proposed Case Management Plan is available at www.nysd.uscourts.gov/hon-sarah-l-cave.

Summary: Report of Rule 26(f) Conference and Proposed Case Management Plan due 1 week before Initial Case Management Conference

Document Type

Report Of Rule 26f Conference

Content & Formatting
Caption
Case Number
Judge Name
Filing Requirements

Machine summary. Not checked yet.Mandatory?

Memoranda of law may not exceed the limits set forth in Local Rule 7.1(c).

Summary: Memoranda of law must comply with Local Rule 7.1(c) limits.

Document Type

Memorandum Of Law

Content & Formatting
Local Rule Certificate
Filing Requirements

Machine summary. Not checked yet.Mandatory?

Memoranda of 3,500 words or more shall contain a table of contents and a table of authorities.

Summary: Memoranda over 3,500 words require table of contents and authorities.

Document Type

Memorandum Of Law

Content & Formatting
Table Of Authorities
Table Of Contents
Filing Requirements

Machine summary. Not checked yet.Mandatory?

As required by Local Civil Rule 7.2, counsel must provide a pro se litigant with printed copies of decisions cited in any submission that are unreported or reported exclusively on computerized databases.

Summary: Counsel must provide pro se litigants with printed copies of unreported or database-only decisions cited in submissions.

Document Type

Submission

Specific requirements detailed in rule text.
Filing Requirements

Machine summary. Not checked yet.Mandatory?

Unless otherwise ordered by the Court, the parties shall submit to the Court for its approval a Joint Pretrial Order within 30 days after the date for the completion of discovery, or, if a summary judgment motion has been filed, within 30 days after the decision on the motion.

Summary: Joint Pretrial Order must be submitted within 30 days after discovery completion or 30 days after summary judgment decision.

Document Type

Joint Pretrial Order

Specific requirements detailed in rule text.
Filing Requirements

Machine summary. Not checked yet.Mandatory?

Unless otherwise ordered, the following must be filed at the same time as the filing of the joint pretrial order: In jury cases, the parties must jointly file (a) requests to charge, (b) proposed voir dire questions, and (c) where applicable, a proposed special verdict form.

Summary: In jury cases, parties must jointly file requests to charge, proposed voir dire questions, and special verdict form with the Joint Pretrial Order.

Document Type

Joint Pretrial Order

Specific requirements detailed in rule text.
Filing Requirements

Machine summary. Not checked yet.Mandatory?

This letter must be received by the Court and opposing counsel no later than midnight four business days before the settlement conference. Counsel must immediately provide a copy of the opposing party’s letter to their client and/or insurer, and must also ensure before the conference that the client and/or insurer has read the opposing party’s letter.

Summary: Settlement conference letter must be submitted 4 business days before conference

Document Type

Settlement Conference Letter

Content & Formatting
Certificate Of Service
Filing Requirements

Machine summary. Not checked yet.Mandatory?

This letter, along with the Attendance Acknowledgment Form appended to the Settlement Conference Scheduling Order, must be sent to the Court by hand delivery or by email to: cave_nysdchambers@nysd.uscourts.gov.

Summary: Settlement conference letter must be sent by hand delivery or email to specific address

Document Type

Settlement Conference Letter

Content & Formatting
Case Number
Judge Name
Filing Requirements

Machine summary. Not checked yet.Mandatory?

The presence of each party (the client), in addition to counsel, is essential to the settlement process. Also, if an insurance company, litigation funder, or other individual or entity has any role in approving a settlement, the decision‐making representative of the insurer must attend in addition to the insured party.

Summary: Clients and decision-makers must attend settlement conference

Document Type

Settlement Conference

Specific requirements detailed in rule text.
Filing Requirements

Machine summary. Not checked yet.Mandatory?

Corporations, and any other party that is not a natural person, and insurers must send to the conference the person ultimately responsible within the organization for giving settlement authority, not someone who has received authority from someone else.

Summary: Corporations must send highest-level settlement authority to conference

Document Type

Settlement Conference

Specific requirements detailed in rule text.
Filing Requirements

Machine summary. Not checked yet.Mandatory?

If a party believes that the individuals scheduled to attend the conference on behalf of the opposing party do not comply with this requirement, that party shall immediately confer with the opposing party and inform the Court by letter promptly if no resolution is reached.

Summary: Parties must notify court if opposing party's representatives lack settlement authority

Document Type

Settlement Conference

Specific requirements detailed in rule text.
Filing Requirements

Machine summary. Not checked yet.Mandatory?

Because it is important that the decisionmakers on settlement hear their adversaries’ presentations and be available to answer questions from the Court, the person who attends the conference must be the person with ultimate responsibility for determining the amount of any settlement.

Summary: Settlement authority must be held by attending representatives

Document Type

Settlement Conference

Specific requirements detailed in rule text.
Filing Requirements

Machine summary. Not checked yet.Mandatory?

In these meetings, the parties and their counsel must be prepared to inform the Court of the amount of attorneys’ fees and expenses incurred to date, and an estimate of the remaining costs (including attorneys’ fees) of litigating the case to judgment, including appeal.

Summary: Parties must provide attorneys' fees and cost information during settlement conference

Document Type

Settlement Conference

Specific requirements detailed in rule text.
Filing Requirements

Machine summary. Not checked yet.Mandatory?

If a party does not speak fluent English, the party must bring an experienced simultaneous interpreter. Counsel may not serve as the interpreter.

Summary: Non-English speaking parties must bring professional interpreter

Document Type

Settlement Conference

Specific requirements detailed in rule text.
Filing Requirements

Machine summary. Not checked yet.Mandatory?

In cases where the City Comptroller has authority over settlement, the Assistant Corporation Counsel shall arrange in advance of the conference for a representative of the Comptroller either to attend the conference or to be available by telephone.

Summary: City Comptroller representatives must be available for NYC settlement cases

Document Type

Settlement Conference

Specific requirements detailed in rule text.
Filing Requirements

Machine summary. Not checked yet.Mandatory?

In these circumstances, if more than one individual will be appearing by telephone, the parties must immediately arrange for a toll‐free conference call number that the individuals and the Court may dial into for the conference.

Summary: Toll-free conference call required for multiple telephone attendees

Document Type

Settlement Conference

Specific requirements detailed in rule text.
Filing Requirements

Machine summary. Not checked yet.Mandatory?

If a defendant intends to claim that its financial situation is relevant to any potential or actual settlement offer (either based on the amount offered or a proposal to pay any portion in more than 30 days), the defendant shall inform plaintiff of this fact no later than fourteen (14) days before the conference. The parties should then discuss whether plaintiff seek proof of defendant’s claim and whether the defendant is willing to provide such proof, which must be provided at least three (3) days before the conference. A summary of any discussions on this topic shall be included in the letters required under paragraph 4 of this Standing Order.

Summary: Defendants must disclose financial claims 14 days before conference; proof required 3 days before; summary in paragraph 4 letters.

Document Type

Letter

Specific requirements detailed in rule text.
Filing Requirements

Machine summary. Not checked yet.Important?

The parties are reminded of their obligations to make certain disclosures regarding expert testimony pursuant to Fed. R. Civ. P. 26(a)(2) and to make disclosures regarding evidence that may be presented at trial pursuant to Fed. R. Civ. P. 26(a)(3). Failure to comply with these requirements may result in preclusion or other sanctions.

Summary: Parties must comply with expert testimony disclosure requirements under Fed. R. Civ. P. 26(a)(2) and evidence disclosure under Fed. R. Civ. P. 26(a)(3), with potential sanctions for non-compliance.

Document Type

Pretrial Disclosure

Specific requirements detailed in rule text.
Filing Requirements

Machine summary. Not checked yet.Important?

Any request to have a witness testify out of order and/or on a particular day must be included in the joint pretrial order. Untimely applications will be denied.

Summary: Requests for out-of-order witness testimony must be included in the joint pretrial order.

Document Type

Joint Pretrial Order

Specific requirements detailed in rule text.
Filing Requirements

Machine summary. Not checked yet.Important?

When a party’s case commences, that party is expected to have witnesses available to fill the trial day, which runs from 9:30 am to 5:00 pm, with a one‐hour lunch break. The parties are on notice that if a party does not have a witness available to testify, the Court may deem that party to have rested.

Summary: Parties must have witnesses available for full trial days (9:30 am - 5:00 pm).

Document Type

Trial Preparation

Specific requirements detailed in rule text.
Filing Requirements

Machine summary. Not checked yet.Important?

The Court prefers that counsel not use slideware or other summary presentations, although key evidence from discovery in the case, that has previously been disclosed to the opposing party at least five (5) days before the conference or is already in the possession of the opposing party, may be helpful.

Summary: Slideware discouraged for settlement conference presentations

Document Type

Settlement Conference Presentation

Specific requirements detailed in rule text.
Filing Requirements

Machine summary. Not checked yet.Note?

2. Attendance. Lead counsel for the parties are expected to attend the Initial Case Management Conference. Reasonable accommodations will be made for parties or their counsel who cannot attend in person on account of disability. An incarcerated party who is unable to attend this or other conferences may be able to participate by telephone. If appropriate, the Court’s scheduling order will outline the procedures for participation by telephone.

Summary: Lead counsel expected to attend Initial Case Management Conference; accommodations for disability or incarceration

Document Type

Initial Case Management Conference

Specific requirements detailed in rule text.
Filing Requirements

Machine summary. Not checked yet.Note?

Electronic copies of this joint submission should be submitted to the Court; counsel should contact Chambers for instructions on how to submit these materials.

Summary: Electronic copies of joint submissions must be submitted to the Court.

Document Type

Joint Submission

Specific requirements detailed in rule text.
Filing Requirements

Machine summary. Not checked yet.Note?

A client or insurer’s attendance by telephone may be permitted if the party lives and works more than 100 miles from the Courthouse and it would be a great hardship for the party to attend the conference on any date.

Summary: Telephone attendance permitted for parties over 100 miles away

Document Type

Settlement Conference

Specific requirements detailed in rule text.
Filing Requirements

Machine summary. Not checked yet.Note?

The scheduling of a settlement conference has no effect on any deadlines or other pending obligations in the action.

Summary: Settlement conference scheduling does not affect other deadlines or obligations.

Document Type

Settlement Conference

Specific requirements detailed in rule text.

Filing & Service rules

Filing Timing and Cure Windows

Parties must exchange privilege logs by a specified date if claiming privilege or work product protection.

To the extent that any party claims any privilege or work product protection, privilege logs will be exchanged by _____________________.

Machine summary. Not checked yet. · Civil cases

Page 3 | 6. Discovery Plan

Requests for admission must be served no later than 30 days before the fact discovery deadline.

Requests for admission must be served on or before , and in any event no later than 30 days before the fact discovery deadline.

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Page 3 | 6. Discovery Plan

Rule 26(e) supplementations must be made within a reasonable time after information discovery, and no later than the fact discovery deadline.

Supplementations under Rule 26(e) must be made within a reasonable period of time after discovery of such information, and in any event, no later than the fact discovery deadline.

Machine summary. Not checked yet. · Civil cases

Page 3 | 6. Discovery Plan

Subsequent requests for production must be served no later than 30 days before the fact discovery deadline.

All subsequent requests for production must be served no later than 30 days before the fact discovery deadline.

Machine summary. Not checked yet. · Civil cases

Page 3 | 6. Discovery Plan

Subsequent interrogatories must be served no later than 30 days before the fact discovery deadline.

All subsequent interrogatories must be served no later than 30 days before the fact discovery deadline.

Machine summary. Not checked yet. · Civil cases

Page 3 | 6. Discovery Plan

Initial interrogatories must be served on or before a specified date.

Initial sets of interrogatories shall be served on or before .

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Page 3 | 6. Discovery Plan

Pleading amendments after the Rule 15(a) deadline are only permitted with a showing of good cause under Rule 16(b)(4).

Amendment of pleadings after this date will be permitted only on a showing of “good cause” under Fed. R. Civ. P. 16(b)(4).

Machine summary. Not checked yet. · Civil cases

Page 4 | 8. Amendments to Pleadings

Service and Proof of Service Rules

A party receiving a Third Party production must provide a copy to all other parties.

Any party that receives a production from a Third Party must provide a copy of that production to all other parties in this action.

Checked against the court's document on Oct 4, 2026

Page 2 | Proposed Schedule

Courtesy Copy Requirements

Courtesy copies required for Letter-Motions with exhibits over 50 pages.

Courtesy copies of Letter‐Motions are not required unless the attached exhibits exceed 50 pages, in which case one (1) courtesy copy, marked as such on a cover page, should be submitted to Chambers promptly after filing.

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Page 5 | Courtesy Copies

Trial exhibits and deposition designations must be provided in tabbed binders by the business day before trial.

Unless otherwise ordered by the Court, no later than the business day before trial begins, each party must provide each other party, and the Court, with a tabbed binder or binders containing courtesy copies of its trial exhibits and deposition designations.

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Courtesy copies not required for formal motions unless requested.

Courtesy copies are not required and should not be submitted unless otherwise requested by the Court.

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Page 6 | Courtesy Copies

Sealing & Redaction Procedures

Filing under seal requires court permission.

Filing under seal requires permission of the Court. Unless otherwise ordered, any party wishing to file a document or

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Page 2 | I. Communications with Chambers

Motions for sealed/redacted filings must be filed electronically through ECF

2. Sealing/Redactions Requiring Court Approval. Motions or Letter- Motions for approval of sealed or redacted filings in civil and miscellaneous cases and the subject documents, including the proposed sealed document(s) must be filed electronically through the Court’s ECF system in conformity with the Court’s Standing Order, 19-mc-583, and ECF Rules & Instructions, Section 6, available at https://nysd.uscourts.gov/rules/ecf-related-instructions.

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Page 3 | I. Pretrial Procedures

Filing Bundling Requirements

Motions in limine must be filed with the Joint Pretrial Order.

In all cases, motions in limine addressing any evidentiary or other issues must be filed at the same time as the Joint Pretrial Order.

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Pre-Motion Conference Requirements

Unless the parties agree otherwise or the Court orders otherwise, non-party depositions must follow initial party depositions.

Absent an agreement between the parties or an order from the Court, non- party depositions shall follow initial party depositions.

Checked and corrected to match the court's document on Oct 4, 2026

Page 2 | Proposed Schedule

Discovery disputes must be filed as Letter-Motion (max 1,050 words) after meet and confer

2. Letter‐Motion for Discovery Conference. If the parties have met and conferred but were unable to resolve their dispute, the moving party must request a discovery conference with the Court, by Letter‐Motion, as required by Local Civil Rule 37.2. Counsel should select the “Letter‐ Motion” option—not “Motion to Compel”—when filing on ECF. Letter- Motions may not exceed 1,050 words in length, exclusive of attachments, which should be kept to a minimum, and must clearly set forth the issues in dispute and the relief sought. As part of the Letter‐Motion, the moving party must certify that the required in‐person or telephonic conference took place between counsel for the relevant parties and, in

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Page 4 | II. Pretrial Procedures

Must meet and confer in good faith before filing discovery dispute; letters/emails alone insufficient

C. Discovery Disputes. 1. Requirement to Meet and Confer. The Court will not hear any discovery dispute unless the moving party (including a non‐party seeking relief) has first conferred in good faith with any adverse party to resolve the dispute. An exchange of letters or emails alone does not satisfy this requirement. Counsel must respond promptly and in good faith to any request from another party to confer in accordance with this paragraph.

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Page 4 | II. Pretrial Procedures

Motions to dismiss or judgment on pleadings against pro se litigants must serve and file notice under Local Civil Rule 12.1 when referring to matters outside pleadings.

Where a party moves to dismiss or for judgment on the pleadings against a pro se litigant and refers to matters outside the pleadings, the party must serve and file the notice set forth in Local Civil Rule 12.1.

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Page 7 | E. Motions in Pro Se Cases

Summary judgment motions against pro se litigants must comply with Local Civil Rule 56.2 notice requirements.

Where a party seeks summary judgment against a pro se litigant, the party must also comply with the notice requirements of Local Civil Rule 56.2.

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Page 7 | E. Motions in Pro Se Cases

Court prefers conferences for discovery disputes in Letter-Motions.

The Court’s preference is to hold a conference with the parties to address discovery disputes raised by a Letter‐Motion.

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Page 5 | Discovery Conferences/Oral Argument on Letter-Motions

Pre-motion conference not required for non-discovery motions unless ordered.

For motions other than discovery motions, a pre‐motion conference is not required unless otherwise ordered. A party may request a pre‐motion conference by Letter‐Motion where counsel believes that an informal conference with the Court may obviate the need for the motion or reduce the issues in dispute.

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Page 6 | Motions Other Than Discovery Motions

Adjournment & Extension Requirements

Pre-sentence submissions for misdemeanors due 2 weeks before scheduled meeting.

Pre-sentence submissions for misdemeanors should be submitted no later than 2 weeks before the scheduled meeting.

Machine summary. Not checked yet. · Criminal cases

Page 1 | III. Misdemeanor Sentencing

Adjournment requests must be made at least 48 hours in advance with 2 proposed dates.

Absent unforeseeable emergencies, all requests for adjournment of a court conference or other court proceeding (including a telephonic court conference) must be made at least 48 hours in advance of the proceeding to be adjourned, and must include at least two (2) proposed dates, on which all counsel are available, for the adjourned proceeding.

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Page 2 | I. Communications with Chambers

Adjournment/extension requests must be filed as letter-motions with specific required elements.

Requests to adjourn any court conference or proceeding or to extend a deadline must be made by Letter‐Motion filed on ECF, after consultation with all parties, and must state: (1) the original date of the conference, proceeding or deadline; (2) the number of previous requests for adjournment or extension; (3) whether these previous requests were granted or denied; (4) the reason for the present request; (5) whether all affected parties consent; and (6) if not, the reasons given for refusing.

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Page 2 | I. Communications with Chambers

Settlement conference adjournments must be filed as Letter-Motion on ECF

Any application for adjournment or other modification of the conference must be submitted via Letter‐Motion on ECF in accordance with Magistrate Judge Cave’s Individual Practices, found at: https://www.nysd.uscourts.gov/hon‐sarah‐l‐cave.

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Page 1 | 4

Adjournment required if it would enable discovery or in-person attendance; within 45 days requires consultation and Letter-Motion; >45 days requires adjournment sine die with party positions.

The parties are required to seek an adjournment if (1) an adjournment would permit discovery or exchange of information that would make the conference more fruitful, or (2) for in‐person conferences, a client or insurer who would otherwise participate by telephone would be available to attend in person if the conference were held on another date. To seek a new date within 45 days of the originally‐scheduled conference, counsel must consult with all other counsel as to their, their clients’, and their insurer’s availability. The party must then file a Letter‐Motion via ECF in accordance with Magistrate Judge Cave’s Individual Practices proposing options for a new date and time and indicating that all parties are available. If the party wishes to postpone by more than 45 days, an adjournment sine die should be sought by Letter‐Motion, should provide the position of each party as to the request, and should specify an approximate time period when the conference should be held. The Court notes that the scheduled conference date is not changed unless and until the Court grants the written application to change the date.

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Adjournment requests must be made promptly; no reason needed if >14 days in advance, otherwise reasons required.

If counsel becomes aware of the need or potential need for an adjournment of the date of the conference, counsel must make an application for the adjournment as soon as counsel is aware of the need. If the application is made more than fourteen (14) days in advance of the conference, no cause need be provided. Otherwise, counsel must provide reasons for seeking the adjournment.

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Parties may extend interim discovery deadlines by written consent without court application if the 6(A) fact discovery deadline is met.

The following interim deadlines may be extended by the parties on written consent without application to the Court, provided that the parties meet the deadline for completing fact discovery set forth in paragraph 6(A) above.

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Page 3 | 6. Discovery Plan

Chambers Communication Rules

Email plea materials (indictment, plea agreement, elements, penalties) at least 24 hours before plea.

At least 24 hours in advance of a plea, the indictment/information, plea agreement, a summary of the elements of the offense(s), and the maximum and mandatory penalties for each crime/count should be emailed to CaveCriminalDuty@nysd.uscourts.gov.

Machine summary. Not checked yet. · Criminal cases

Page 1 | II. Pleas

Email Judge Cave for late-night or weekend warrant requests.

Late-night or weekend warrants. If you anticipate the need for a late-night or weekend warrant, please send Judge Cave an email at CaveCriminalDuty@nysd.uscourts.gov.

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Page 1 | I. Criminal Applications

Email arrest/search warrants (including cell site, triggerfish, GPS) to CaveCriminalDuty@nysd.uscourts.gov with agent and U.S. Attorney availability.

Warrants. Arrest and search warrants, including applications for cell site information, triggerfish, and GPS tracking, should be emailed to CaveCriminalDuty@nysd.uscourts.gov specifying the time that the agent and U.S. Attorney are available to swear out the complaint.

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Page 1 | I. Criminal Applications

Pro se parties must communicate with the Pro Se Intake Unit, not chambers.

By Standing Order, a pro se party must mail all communications with the Court to the Pro Se Intake Unit located at 40 Centre Street, Room 105, New York, NY 10007. A pro se party may not call or email Chambers or send any document or filing directly to Chambers.

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Page 2 | I. Communications with Chambers

Electronic device requests must be emailed to Court at least 24 hours before proceeding

H. Electronic Device Order Requests. Attorneys’ use of electronic devices (including mobile telephones, personal electronic devices, computers, and printers) within the Courthouse and its environs is governed by the Court’s Standing Order M10-468.4. Attorneys seeking to bring a device into the Courthouse shall submit a completed copy of the Electronic Devices General Purpose Form, available on the Court's website, to the Court by email at least 24 hours prior to the court proceeding. Requests for a so-ordered electronic device order are not filed on ECF.

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Page 3 | I. Pretrial Procedures

Hand deliveries must be left with Court Security Officers, not brought to chambers.

Where permitted by these Rules, hand deliveries should be left with the Court Security Officers at the Worth Street entrance of 500 Pearl Street and may not be brought directly to Chambers.

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Page 2 | I. Communications with Chambers

Urgent matters require filing a request on ECF before calling or emailing chambers.

If a matter requires urgent attention, the parties must first file a request for relief on the docket before alerting Chambers by telephone call or email.

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Page 2 | I. Communications with Chambers

Counsel must contact chambers if interpreter cannot be secured

Counsel should call Chambers if there is any difficulty securing an interpreter.

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Page 2 | 7c

Junior Lawyer Participation Incentives

Junior attorneys invited to argue Letter-Motions they helped prepare.

Junior attorneys are invited to argue Letter-Motions they have helped prepare. Firms are encouraged to provide this opportunity to junior attorneys for training purposes. The Court is amenable to permitting more than one lawyer to argue for one party if this creates an opportunity for a junior lawyer to participate.

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Page 5 | Discovery Conferences/Oral Argument on Letter-Motions

Junior attorneys invited to argue motions they helped prepare.

Junior attorneys are invited to argue motions they have helped prepare. Firms are encouraged to provide this opportunity to junior attorneys for training purposes. The Court is amenable to permitting more than one attorney to argue for one party if this creates an opportunity for a junior lawyer to participate.

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Page 6 | Oral Argument on Motions

About United States Magistrate Judge Sarah L. Cave

**Magistrate Judge Sarah L. Cave** was appointed to the Southern District of New York on October 1, 2019, filling the vacancy created by the retirement of the Honorable Henry B. Pitman. Before joining the bench, Judge Cave was a partner at Hughes Hubbard & Reed, where she spent 18 years and co-chaired the professional services practice group, personnel committee, and pro bono committee. She focused on complex commercial litigation including securities class actions, accountants' liability, and major financial crises litigation involving Lehman Brothers, MF Global, and Bernard L. Madoff Securities. **Education** - Colgate University, B.A. in political science, 1995 **Career** - U.S. Magistrate Judge, Southern District of New York (2019–present) - Partner, Hughes Hubbard & Reed, New York City (2007–2019) - Associate, Hughes Hubbard & Reed, New York City (2001–2007)

**Courthouse:** Daniel Patrick Moynihan United States Courthouse, 500 Pearl Street, New York, NY 10007-1312 **Courtroom:** 18A **Chambers Staff** - Scheduling/Contact: Cave_NYSDChambers@nysd.uscourts.gov

Common questions about Judge Sarah L. Cave's rules

Are courtesy copies required for Judge Sarah L. Cave?

Courtesy-copy rule applies when a filing is > 50 pages. Details: 1 copy, delivery promptly after filing, by hand delivery. Courtesy copies required for Letter-Motions with exhibits over 50 pages.

View ruleSource: page 5, section Courtesy Copies

Does Judge Sarah L. Cave require a pre-motion conference or letter before filing a motion?

The rule does not state that a pre-motion letter is required, but it sets the applicable pre-motion procedure. Must meet and confer in good faith before filing discovery dispute; letters/emails alone insufficient

View ruleSource: page 4, section II. Pretrial Procedures

What page or word limits apply to letter before Judge Sarah L. Cave?

Judge Sarah L. Cave's rule states these limits: attorney: 1050 words. Letters to chambers are limited to 1,050 words (excluding attachments).

View ruleSource: page 1, section I. Communications with Chambers

What page or word limits apply to letter motion before Judge Sarah L. Cave?

Judge Sarah L. Cave's rule states these limits: attorney: 1050 words. Letters in opposition and replies are limited to 1,050 words.

View ruleSource: page 5, section Briefing Schedule

What must be included with rule 26f conference report filings before Judge Sarah L. Cave?

The rule requires signature block. Rule 26(f) conference report requires counsel signature certifying compliance with court expectations.

View ruleSource: page 2, section The Court’s Expectations

What must be included with joint letter filings before Judge Sarah L. Cave?

The rule identifies required filing content or certificates. Parties must file a joint docket letter certifying fact discovery is complete no later than one week after fact discovery closes.

View ruleSource: page 3, section 6. Discovery Plan

How may parties contact Judge Sarah L. Cave's chambers?

The rule addresses email communications with Judge Sarah L. Cave's chambers. The rule lists email CaveCriminalDuty@nysd.uscourts.gov. Email arrest/search warrants (including cell site, triggerfish, GPS) to CaveCriminalDuty@nysd.uscourts.gov with agent and U.S. Attorney availability.

View ruleSource: page 1, section I. Criminal Applications

How does Judge Sarah L. Cave handle sealed or redacted filings?

A motion to seal is required for covered sealed filings before Judge Sarah L. Cave. Filing under seal requires court permission.

View ruleSource: page 2, section I. Communications with Chambers

How do I request an adjournment or extension before Judge Sarah L. Cave?

Requests should be made at least 14 calendar days in advance when this rule applies before Judge Sarah L. Cave. Pre-sentence submissions for misdemeanors due 2 weeks before scheduled meeting.

View ruleSource: page 1, section III. Misdemeanor Sentencing

Does Judge Sarah L. Cave require motion papers to be bundled?

Yes. Judge Sarah L. Cave requires bundling for covered papers. Motions in limine must be filed with the Joint Pretrial Order.

What filing deadlines does Judge Sarah L. Cave set?

Initial interrogatories must be served on or before a specified date.

View ruleSource: page 3, section 6. Discovery Plan

What rule applies to serving all parties before Judge Sarah L. Cave?

The rule addresses service method, recipient, or timing requirements. Details: recipient: all parties. A party receiving a Third Party production must provide a copy to all other parties.

View ruleSource: page 2, section Proposed Schedule

Does Judge Sarah L. Cave encourage junior lawyer participation?

Yes. Judge Sarah L. Cave's rules include a junior lawyer participation incentive. Junior attorneys invited to argue Letter-Motions they helped prepare.

View ruleSource: page 5, section Discovery Conferences/Oral Argument on Letter-Motions
Complete rules summary for Judge Sarah L. Cave

Email arrest/search warrants (including cell site, triggerfish, GPS) to CaveCriminalDuty@nysd.uscourts.gov with agent and U.S. Attorney availability.

Email Judge Cave for late-night or weekend warrant requests.

Email plea materials (indictment, plea agreement, elements, penalties) at least 24 hours before plea.

Pre-sentence submissions for misdemeanors due 2 weeks before scheduled meeting.

Rule 26(f) conference report requires counsel signature certifying compliance with court expectations.

Rule 26(f) conference report must certify parties met at least one week before Initial Case Management Conference and include caption, case number, and judge name.

Parties must file a joint docket letter certifying fact discovery is complete no later than one week after fact discovery closes.

Parties may extend interim discovery deadlines by written consent without court application if the 6(A) fact discovery deadline is met.

Initial interrogatories must be served on or before a specified date.

Subsequent interrogatories must be served no later than 30 days before the fact discovery deadline.

Requests for admission must be served no later than 30 days before the fact discovery deadline.

Subsequent requests for production must be served no later than 30 days before the fact discovery deadline.

Rule 26(e) supplementations must be made within a reasonable time after information discovery, and no later than the fact discovery deadline.

Parties must exchange privilege logs by a specified date if claiming privilege or work product protection.

Pleading amendments after the Rule 15(a) deadline are only permitted with a showing of good cause under Rule 16(b)(4).

Parties must file a joint docket letter certifying all discovery is complete and stating intended dispositive motions no later than one week after expert discovery closes.

Unless the parties agree otherwise or the Court orders otherwise, non-party depositions must follow initial party depositions.

A party receiving a Third Party production must provide a copy to all other parties.

Letters to chambers are limited to 1,050 words (excluding attachments).

Urgent matters require filing a request on ECF before calling or emailing chambers.

Pro se parties must communicate with the Pro Se Intake Unit, not chambers.

Adjournment/extension requests must be filed as letter-motions with specific required elements.

Adjournment requests must be made at least 48 hours in advance with 2 proposed dates.

Hand deliveries must be left with Court Security Officers, not brought to chambers.

Filing under seal requires court permission.

Motions for sealed/redacted filings must be filed electronically through ECF

Citations must be in searchable PDF and include ECF document/page numbers

Electronic device requests must be emailed to Court at least 24 hours before proceeding

Report of Rule 26(f) Conference and Proposed Case Management Plan due 1 week before Initial Case Management Conference

Pro Se Cases must submit Case Report and Proposed Case Management Plan 1 week before conference

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