Courtesy copies are required only when requested by chambers. Courtesy copies must not be submitted unless the Court specifically requests them.
Judge Peggy Kuo's rules set a pre-motion procedure for discovery. Counsel must confer in person or by telephone before seeking court intervention on a discovery dispute.
Judge Peggy Kuo's rule states these limits: 3 pages. A joint discovery dispute letter is limited to three pages.
Judge Peggy Kuo's rule states these limits: 12 pages; 5 pages. For non-dispositive non-discovery motions, support/opposition memoranda are limited to 12 pages and reply memoranda to 5 pages, both double-spaced, unless prior permission is granted.
Judge Peggy Kuo's formatting rule includes if an exhibit is voluminous, it should be placed in a binder with tabs.. Voluminous exhibits should be organized in a tabbed binder.
The rule identifies required filing content or certificates. The proposed sealed documents must be attached to the motion seeking leave to file under seal.
The rule identifies required filing content or certificates. Each settlement statement must include prior demand/offer positions, case strengths and weaknesses, client priorities, settlement barriers, and other helpful settlement information.
Parties may contact Judge Peggy Kuo's chambers by phone only as allowed by the rule. Telephone calls to Chambers are prohibited except for matters requiring immediate attention.
A motion to seal is required for covered sealed filings before Judge Peggy Kuo. A motion for leave must be filed on ECF to submit documents under seal, following EDNY sealing instructions.
Judge Peggy Kuo's rules specify what an adjournment or extension request must include. The request must include original date, number of previous requests, and reason for request. Adjournment requests must state the original conference date, the number of prior requests, and the reason for the request.
Telephone calls to Chambers are prohibited except for matters requiring immediate attention.
Fax communications are prohibited unless Chambers gives prior permission.
All communications with Chambers must be made through ECF.
Email to Chambers is allowed only for confidential settlement statements or when otherwise directed by the Court.
Counsel are required to file all documents electronically through ECF.
For ECF technical issues, parties must call the ECF Help Desk and not Chambers.
A motion for leave must be filed on ECF to submit documents under seal, following EDNY sealing instructions.
The proposed sealed documents must be attached to the motion seeking leave to file under seal.
Courtesy copies must not be submitted unless the Court specifically requests them.
Confidential ex parte settlement statements must be emailed to Chambers at least seven business days before the settlement conference unless the Court directs otherwise.
Each settlement statement must include prior demand/offer positions, case strengths and weaknesses, client priorities, settlement barriers, and other helpful settlement information.
Adjournment or conference-change requests must be filed on ECF as a Motion using a letter format, not as an ECF Letter filing.
Adjournment requests must state the original conference date, the number of prior requests, and the reason for the request.
If an adjournment request affects other deadlines, a revised proposed discovery plan/scheduling order must be attached.
Adjournment requests must be filed at least two business days before the conference unless there is an emergency.
Counsel may not request adjournments by phone, though they may call attention to a last-minute emergency request after ECF filing.
Extension requests must be filed on ECF as a Motion using a letter format.
Extension requests must include the original deadline, reason, number of prior requests, and other parties’ consent position or efforts to obtain it.
If an extension affects other deadlines, the request must include a revised proposed discovery plan/scheduling order and should also seek adjournment of affected conferences.
Extension requests must be made at least two business days before the relevant deadline unless there is an emergency.
Any confidentiality order must use the Court’s proposed confidentiality order form from Chambers’ website.
Any proposed changes to the court’s confidentiality order must be clearly marked, such as by using Track Changes.
Counsel must confer in person or by telephone before seeking court intervention on a discovery dispute.
A joint discovery dispute letter is limited to three pages.
When a discovery dispute concerns specific requests, those requests should be attached to the joint letter.
Before filing a non-dispositive non-discovery motion, the movant must notify other parties at least two days in advance and offer an opportunity to consent.
A non-dispositive non-discovery motion must include a certification letter describing compliance and the other parties’ consent position or outreach efforts.
No court pre-motion conference is required for non-dispositive non-discovery motions.
Oppositions to non-dispositive non-discovery motions are due in 10 business days, and replies are due 5 business days later, unless otherwise ordered.
For non-dispositive non-discovery motions, support/opposition memoranda are limited to 12 pages and reply memoranda to 5 pages, both double-spaced, unless prior permission is granted.