Judge Lara K. Eshkenazi

Faxes to Chambers are not permitted.

A party or the parties must immediately notify Chambers via email (Eshkenazi_Chambers@nyed.uscourts.gov) if any of the following events occur:

Pro se litigants should file any documents via hand delivery or U.S. mail to the designated “Pro Se clerk” in the Clerk’s office to the attention of Judge Eshkenazi and the presiding District Judge.

Litigants must make discovery motions by letter motion. Such letter motions may not exceed five (5) pages in length, exclusive of exhibits. A response not exceeding five (5) pages in length, exclusive of exhibits, must be served and filed within three (3) days of receipt of the letter motion.

All discovery letter motions and responses must use reasonable margins and a 12-point font.

When a dispute arises during a deposition that the parties cannot resolve themselves despite their best efforts, the parties must contact the Court immediately by e-mailing Eshkenazi_Chambers@nyed.uscourts.gov. The email should include a brief description of the dispute and a callback number. The parties must have the court reporter mark the transcript where the dispute arose and must move on to other issues in the deposition until such time as the Court can call back to address the dispute. When the Court returns the call, the court reporter must be present on the call to record any rulings. The parties must not discontinue the deposition while waiting for the Court to return the call.

Confidentiality orders should be in the form posted here: https://img.nyed.uscourts.gov/files/local_rules/ProtectiveOrder-LKE.pdf. If a party believes that changes to the form order are required due to the circumstances of the case, it may submit to the Court proposed changes via letter motion via ECF. The letter motion must not exceed three (3) pages and must explain the need for the changes, whether all parties consent to the proposed changes, and the bases for any objections to the proposed changes. The letter motion must attach as exhibits a clean copy of the proposed order and a redlined comparison between the proposed order and the Court’s form Protective Order. The redline should note any objections by any party to the proposed changes.

At least five (5) days prior to the settlement conference, the parties must submit ex parte settlement letters, not to exceed five (5) pages single-spaced, to Chambers via email (Eshkenazi Chambers@nyed.uscourts.gov). The ex parte settlement letters must include the communicated demand and offer as prescribed in Rule IV.B.1 above, the strengths and weaknesses of their case, and any legal arguments in support of their settlement position with citations to relevant authorities. Prior to the conference, the Court may schedule ex parte telephone calls with counsel after reviewing the statements.

A letter motion requesting a pre-motion conference is required before any dispositive motion may be filed. The request must be accompanied by a summary of the proposed motion, not to exceed five (5) pages. The opposing party must file a letter response within seven (7) days, not to exceed five (5) pages. Reply letters are prohibited absent permission of the Court.

The memoranda of law in support of and in opposition to dispositive motions are limited to twenty-five (25) pages, and reply memoranda are limited to ten (10) pages. All memoranda of law must be double spaced, use reasonable margins, and a 12-point font.