Judge Frederic Block
Individual Rules, Standing Orders & Policies
Limits & Logistics
Document Limits
Adjournments
- Adjournment and extension requests must be in writing and include specified prior-request and adversary-position details, plus revised dates when other deadlines are affected.
Request must include
- Adjournment requests for court appearances must be made at least 48 hours in advance unless there is an emergency.
Communication
Phone
Chambers
Letter via ECF
Page & Word Limits1 rule
Unless prior permission has been granted, memoranda of law in support of and in opposition to motions are limited to 25 pages, and reply memoranda are limited to 10 pages.
Memorandum Of Law Support Or Opposition
25 pages
Document Format Requirements1 rule
Where exhibits are voluminous, they should be placed in binders with tabs.
Document Filing Requirements15 rules
The notice of motion and all supporting papers are to be served on the other parties along with a cover letter setting forth whom the movant represent and the papers being served. A copy of the cover letter only is to be electronically filed.
DocumentNotice Of Motion
The moving party shall be responsible for filing all motion papers via ECF.
DocumentMotion Papers
ii. The names, addresses (including firm names), and telephone and fax numbers of trial counsel.
DocumentJoint Pretrial Order
i. The full caption of the action.
DocumentJoint Pretrial Order
If the Court determines a joint pre-trial order is needed, then the joint pretrial order shall include the following:
DocumentJoint Pretrial Order
Each party must list its fact and expert witnesses and only listed witnesses may testify absent prompt notice and good cause.
viii. A list by each party as to the fact and expert witnesses whose testimony is to be offered in its case in chief, indicting whether such witnesses will testify in person or by deposition. Only listed witnesses will be permitted to testify except when prompt notice has been given and good cause shown.
DocumentJoint Pretrial Order
The joint pretrial order must include party jurisdiction statements with supporting statutes and jurisdictional facts.
iii. A brief statement by plaintiff as to the basis of subject matter jurisdiction, and a brief statement by each other party as to the presence or absence of subject matter jurisdiction. Such statements shall include citations to all statutes relied on and relevant facts as to citizenship and jurisdictional amount.
DocumentJoint Pretrial Order
ii. By claim, a detailed statement regarding damages and other relief sought;
DocumentPretrial Statement
i. On the Thursday before trial in jury cases, requests to charge and proposed voir dire questions.
DocumentJury Instructions
iv. In all cases, motions addressing any evidentiary or other issues which should be resolved in limine; and
DocumentMotion In Limine
iii. In non-jury cases, a statement of the elements of each claim or defense involving such party, together with a summary of the facts relied upon to establish each element;
DocumentNon Jury Pretrial Statement
(3) All exhibits must be pre-marked for the trial and exchanged with the other parties at least ten days before trial.
DocumentExhibits
Pretrial filings are due 15 days before trial, or 30 days after the final pretrial order if no trial date is set.
Unless otherwise ordered by the Court, each party shall file 15 days before the date of commencement of trial if such a date has been fixed, or 30 days after the filing of the final pretrial order if no trial date has been fixed;
DocumentPretrial Filings
Memoranda of 10 pages or more shall contain a table of contents.
DocumentMemorandum Of Law
The Court needs no copies of any exhibits.
DocumentExhibits
Filing & Service rules
Courtesy Copy Requirements
Courtesy copies are not required for motion papers.
Courtesy copies of all motion papers are not required.
Page 2 | Motions - Courtesy Copies
Filing Bundling Requirements
Motion papers must be held and filed only after briefing is complete.
No motions papers shall be filed until the motion has been fully briefed.
Page 2 | Motions - Filing of Motion Papers
Pre-Motion Conference Requirements
A pre-motion conference request requires a moving-party letter of up to 3 pages, and other parties may optionally file a response letter of up to 3 pages within 7 days.
To request a pre-motion conference, the moving party shall submit a letter not to exceed three (3) pages in length setting forth the basis for the anticipated motion. All parties so served may, but are not required to, serve and file a letter response, not to exceed three (3) pages within seven (7) days from service of the notification letter.
Page 2 | Motions - Pre-Motion Conference Requests in Civil Cases
Pre-motion conference letter requirements do not apply to Rule 50, Rule 59, and Rule 60 motions.
Note that these provisions do not apply to motions other than those specifically enumerated. For example, letters requesting pre-motion conferences do not apply to motions pursuant to Fed. R. Civ. P. 50, 59 and 60, and counsel should be aware that the Court of Appeals will not accept an argument that compliance with district court motion rules should excuse noncompliance with Fed. R. App. P. 4. (Cite).
Page 2 | Motions - Pre-Motion Conference Requests in Civil Cases
A pre-motion conference is required before filing motions, with discovery motions and listed case categories excluded from this requirement.
For discovery motions, follow Local Civil Rules 37.3 and 6.4. For motions other habeas corpus/prisoner petitions and Social Security and Bankruptcy appeals, a pre-motion conference with the court must be requested before making any motions.
Page 2 | Motions - Pre-Motion Conference Requests in Civil Cases
Adjournment & Extension Requirements
Adjournment requests for court appearances must be made at least 48 hours in advance unless there is an emergency.
If the request is for an adjournment of a court appearance, absent an emergency, it shall be made at least 48 hours prior to the scheduled appearance.
Page 1 | Communications With Chambers - Request for Adjournments or Extension of Time
Adjournment and extension requests must be in writing and include specified prior-request and adversary-position details, plus revised dates when other deadlines are affected.
All requests for adjournments or extensions of time must be in writing and state (1) the original date, (2) the number of previous requests for adjournment or extension, (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. If the requested adjournment or extension affects any other scheduled dates, a proposed revised dates must be provided.
Page 1 | Communications With Chambers - Request for Adjournments or Extension of Time
Chambers Communication Rules
Except as provided below, communications with chambers shall be by letter, with copies simultaneously delivered to all counsel. Copies of correspondence between counsel shall not be sent to the Court.
Except as provided below, communications with chambers shall be by letter, with copies simultaneously delivered to all counsel. Copies of correspondence between counsel shall not be sent to the Court.
Page 1 | Communications With Chambers
Fax communications with chambers require prior authorization.
Faxes to chambers are permitted only if prior authorization is obtained.
Page 1 | Communications With Chambers
Telephone calls to chambers are permitted, and docketing/scheduling/calendar matters should be directed to (718) 613-2425.
In addition to Paragraph 1(D) below: Telephone calls to chambers are permitted. For docketing, scheduling or calendar matters, call (718) 613-2425.
Page 1 | Communications With Chambers
Counsel may contact chambers by telephone or letter for pending-motion status and emergency or timing concerns.
Counsel are welcomed to contact chambers either by telephone or letter to inquire as to their pending motion or to notify the Court regarding any emergency or time concerns as to their pending motion.
Page 1 | Communications With Chambers
Parties may request oral argument by letter when filing a fully briefed motion.
The parties may request oral argument by letter at the time they file their fully briefed motion.
Page 3 | Motions