Judge Peggy Cross-Goldenberg
Individual Rules, Standing Orders & Policies
- Rules last changed:
Limits & Logistics
Document Limits
Courtesy Copies
Courtesy copies
- Upon request
Adjournments
- Adjournment and extension requests must be filed as ECF letter motions at least two business days in advance (absent emergency) and include specified details.
Communication
Chambers
Phone
Intake Unit
Phone
Chambers
Page & Word Limits1 rule
Each party’s portion of the joint submission shall be limited to two pages.
Joint Submission
2 pages
Document Format Requirements1 rule
Memoranda of law should conform to the length and formatting requirements of Local Rule 7.1.
Document Filing Requirements5 rules
Counsel representing parties in cases involving pro se litigants must send copies of documents filed by ECF to the pro se party and must file proof of service on ECF.
DocumentEcf Filing
Attorneys appearing before the Court must first enter a notice of appearance on ECF prior to their first appearance.
DocumentNotice Of Appearance
The joint discovery letter must include a brief statement of claims/defenses and describe conferral efforts.
The letter shall begin with a brief statement of the claims and defenses at issue in the case and must describe the parties’ efforts to confer and resolve the dispute without court intervention as required by Fed. R. Civ. P. 37(a)(1).
DocumentJoint Letter
Settlement statements must include specified negotiation history and case assessment content.
Each settlement statement must contain the last demand and offer made, a realistic assessment of the strengths and weaknesses of the case, information on what is important to the client, any barriers to settlement, and anything else that will assist the Court in helping the parties reach an agreement.
DocumentSettlement Statement
Parties must file a joint proposed pretrial order in the presiding District Judge’s required format by the applicable court-set deadline.
The parties must file a joint proposed pretrial order in the format prescribed by the presiding District Judge on or before the deadline set by the Court or as set forth in the presiding District Judge’s Individual Practices and Rules.
DocumentPretrial Order
Filing & Service rules
Courtesy Copy Requirements
D. No courtesy copies of electronic filings should be sent to Chambers absent a specific request from the Court.
D. No courtesy copies of electronic filings should be sent to Chambers absent a specific request from the Court.
Page 2 | I. COMMUNICATIONS WITH CHAMBERS
Filing Bundling Requirements
When parties consent to Judge Cross-Goldenberg, dispositive motion papers should not be held for full bundling before filing.
The moving party need not request a pre- motion conference or hold motion papers until all papers are complete (i.e., Judge Cross-Goldenberg does not follow a “bundling rule”).
Page 6 | B. Dispositive Motions
Pre-Motion Conference Requirements
Parties must attempt to resolve discovery disputes in good faith before filing a discovery motion.
Parties must make a good-faith effort to resolve disputes before making any discovery motion.
Page 4 | DISCOVERY
Unresolved discovery disputes must be presented in a single joint ECF filing requesting an informal discovery conference.
If the parties are unable to resolve a discovery dispute themselves, the parties must write to the Court and describe their dispute in a single, joint letter, filed on ECF as a “Motion” for an informal discovery conference.
Page 4 | DISCOVERY
Non-dispositive pretrial applications should generally be made by letter motion first, with formal motion briefing only if the Court directs it.
Parties should generally make such applications as letter motions in compliance with Local Civil Rule 7.1(e). If necessary, after submission of the letter motion, the Court may advise the moving party to file a formal motion pursuant to Local Civil Rules 6.1 and 7.1.
Page 6 | A. Non-Dispositive Motions
When parties consent to Judge Cross-Goldenberg, dispositive motions do not require a pre-motion conference.
The moving party need not request a pre- motion conference or hold motion papers until all papers are complete (i.e., Judge Cross-Goldenberg does not follow a “bundling rule”).
Page 6 | B. Dispositive Motions
Adjournment & Extension Requirements
Adjournment and extension requests must be filed as ECF letter motions at least two business days in advance (absent emergency) and include specified details.
All requests for the adjournment of a court date or any other change to a court conference (such as a request to appear by telephone) or for the extension of a court-ordered deadline must be by letter motion filed on ECF as a “Motion,” not as a “Letter” or “Status Report.” Absent an emergency, the motion must be made at least two business days prior to the conference. Each such motion must state: (1) the original date and the number of previous requests; (2) the reason for the request, which must demonstrate “good cause” if the request is for an extension of discovery, see Fed. R. Civ. P. 16(b)(4); and (3) whether the request is on consent and, if not, the reasons given for withholding consent.
Page 2 | I. COMMUNICATIONS WITH CHAMBERS
Chambers Communication Rules
Telephone contact with Chambers is allowed only for emergencies needing same-day attention.
Telephone calls to Chambers are permitted only in emergency situations requiring same-day attention.
Page 2 | I. COMMUNICATIONS WITH CHAMBERS
Confidential ex parte settlement statements must be sent by email to Chambers at least one week before the settlement conference unless the Court directs otherwise.
Confidential ex parte settlement statements must be emailed to Chambers at least one week before the conference, except as otherwise directed by the Court.
Page 4 | SETTLEMENT CONFERENCES
For unresolved deposition disputes, parties must immediately contact Chambers by email.
If a dispute arises during a deposition that the parties cannot resolve themselves despite their best efforts, the parties must contact Chambers immediately by email and by telephone.
Page 5 | B. Disputes During Ongoing Depositions
Except as provided below, communications with Chambers should be by ECF, using the appropriate event type and a brief description of the document.
Except as provided below, communications with Chambers should be by ECF, using the appropriate event type and a brief description of the document.
Page 1 | I. COMMUNICATIONS WITH CHAMBERS
Emails to Chambers are restricted to situations authorized by the rules or specific court direction.
Emails to Chambers (Cross-Goldenberg_Chambers@nyed.uscourts.gov) are permitted only as provided in these Rules or as otherwise directed by the Court.
Page 2 | I. COMMUNICATIONS WITH CHAMBERS
Pro se parties may call the Pro Se Office for case-related questions.
Pro se parties may call the Court’s Pro Se Office with case-related questions at (718) 613-2665.
Page 2 | I. COMMUNICATIONS WITH CHAMBERS