Judge Ramon E. Reyes Jr.
Individual Rules, Standing Orders & Policies
- Rules last changed:
Limits & Logistics
Document Limits
Courtesy Copies
Exhibits
- 2 copies • During Direct Testimony
- 3 copies • Friday Before Trial
Binding: Tabbed Three Ring
Filings >= 50 pages
- 1 copy • Chambers Drop Off
Motion
- 1 copy
Adjournments
- All requests for adjournments or extensions of time relating to matters not referred to a Magistrate Judge (see Rule III) must be in writing and state: (i) the reason for the request; (ii) the original date; (iii) the number of previous requests for adjournments or extensions; (iv) whether any previous requests were granted or denied; (v) whether the adversary consents, and, if not, the reasons given by the adversary for refusing to consent; and (vi) proposed date(s) for adjournment or extension of time. If the requested adjournment or extension affects any other scheduled dates, the party seeking the adjournment should propose revisions of the additional affected dates.
- Adjournment requests within 24 hours of a court appearance require both ECF filing and a call to chambers.
- Requests for adjournments or extensions in arbitration or mediation proceedings are included among referred matters.
Request must include
- Sentencing adjournment applications must be written, filed at least five business days in advance, and include the reason plus the opposing party’s consent position and stated reasons for non-consent.
- Adjournment and extension requests must be made at least two business days in advance unless there is an emergency.
Communication
Chambers
Chambers
Phone
Chambers
Phone
Phone
Clerk
Phone
Clerk
Page & Word Limits5 rules
The response shall not exceed three (3) pages.
- Page limit
- Up to 3 pages
- Letter
To request a pre-motion conference, the moving party is to file and serve a letter, not to exceed four (4) pages, setting out the bases for the anticipated motion.
- Pre-motion conference letter
- Up to 4 pages
- Letter
Reply memoranda are limited to 3,500, not including tables of contents, tables of authorities, exhibits, appendices, or attachments.
- Reply memorandum
- Up to 3,500 words
Excluded from word count
- •Table of contents
- •Table of authorities
- •Exhibits
- •Appendices
- •Attachments
Support and opposition memoranda are capped at 8,750 words with listed exclusions unless prior permission is granted.
- Memorandum of law support or opposition
- Up to 8,750 words
Excluded from word count
- •Table of contents
- •Table of authorities
- •Exhibits
- •Appendices
- •Attachments
Court's wording
Unless prior permission has been granted, memoranda of law in support of and in opposition to motions are limited to 8,750 words, not including tables of contents, tables of authorities, exhibits, appendices, or attachments.
If the Court permits a party to submit briefs longer than these limits, each additional page must not contain more than 350 additional words.
Document Format Requirements4 rules
Memoranda must follow specific typography, margin, and text-searchable filing requirements.
- Font size
- 12 points
- Margins
- 1 inch
- Memorandum
Court's wording
All memoranda of law shall be produced in 12-point font, with footnotes in 10-point font, and shall have one-inch margins on all sides. All memoranda must be filed in a text-searchable format and must have the date of service printed on the front cover.
Requests to charge, proposed verdict sheets, and proposed voir dire questions in jury cases shall be filed on ECF and provided to chambers in PDF and Microsoft Word formats no later than two (2) weeks before trial, unless otherwise ordered by the Court.
All written submissions and supporting materials must be text-searchable, to the extent practicable.
Documents to be offered in evidence that contain multiple pages shall be paginated by counsel in advance of trial.
Document Filing Requirements26 rules
Proposed orders, jury instructions, and other writings a party requests that the Court adopt shall be filed on ECF and also provided via e-mail, in PDF and Microsoft Word format, to Reyes Chambers@nyed.uscourts.gov.
Each assertion in the Local Rule 56.1 statement must include a citation to specific evidentiary support from the record.
Opposition and reply papers shall be served on all parties, but only a copy of the opponent’s cover letter shall be filed via ECF. That filing shall be designated as a Letter on ECF.
The moving papers shall be served on all parties but only a copy of the movant’s cover letter shall be filed via ECF, and designated as a Letter.
statement shall quote verbatim the moving party’s Local Rule 56.1 statement and respond to each allegation immediately beneath each allegation.
Transcript excerpts must be limited to cited relevant testimony but still include all portions needed for completeness under Rule 106.
Court's wording
Parties shall file only the pages of transcripts containing relevant testimony cited in the memoranda or affidavits. However, excerpts must comply with Federal Rule of Evidence 106. Parties shall include the portion of the transcript necessary for completeness. If the transcript contains a discussion of a matter, include the whole discussion.
Parties shall include a declaration identifying each of the exhibits and the page ranges of the exhibits within the compiled PDF.
The parties must provide the Court with a copy of any plea agreement and elements sheet at least three (3) business days before a change-of- plea hearing.
Parties and Counsel: The names, addresses (including firm names), and telephone numbers of trial counsel.
Jurisdiction: A brief statement by the plaintiff explaining the basis of subject-matter jurisdiction, and a brief statement by the defendant on the presence or absence of subject-matter jurisdiction.
Caption: The full caption of the action.
- Document
- Pretrial order
Include
- •Caption
The pretrial order must list fact and expert witnesses with addresses and expected testimony, and unlisted witnesses are barred absent prompt notice and good cause.
Court's wording
Witnesses: A list of fact and expert witnesses whose testimony is to be offered in each party’s case in chief, along with the address of each witness and a brief narrative statement of the expected testimony of each witness. Only listed witnesses will be permitted to testify, except when prompt notice has been given and upon good cause shown.
Exhibits: A schedule listing exhibits to be offered into evidence and, if not admitted by stipulation, the party or parties that will be offering them. The schedule should not include exhibits that a party intends to use solely for impeachment and/or rebuttal purposes. Copies of statements proposed to be read to the jury as “learned treatises” under Federal Rule of Evidence 803(18) shall be listed as exhibits. The plaintiff’s exhibits shall be identified by numbers, and the defendant’s exhibits shall be identified by letters. Except for good cause shown, only exhibits listed will be received into evidence.
Consent to Trial by a Magistrate Judge: A statement as to whether all parties have consented to trial of the case by a magistrate judge. The statement shall not identify which parties have or have not consented.
Jury or Bench Trial & Trial Length: A statement by each party as to whether the case is to be tried with or without a jury, and the number of trial days needed.
The pretrial order must include each party’s claims/defenses summary with statutory citations and without evidentiary recitation.
Court's wording
Claims and Defenses: A brief summary by each party of the elements of its remaining asserted claims and defenses. These summaries shall include citations to all statutes relied on but should not recite evidentiary matters.
Provide pro se litigants with a copy of this Court’s individual rules and file a certificate of service as early as practicable in the litigation.
- Document
- Certificate
Include
- •Certificate of service
In habeas cases with pro se petitioners, the respondent must serve the petitioner with the answer and the state or federal court record when respondent files the answer and the record on ECF.
The notice of motion shall not contain a return date.
Each memorandum must include the date of service on its front cover.
Court's wording
All memoranda of law shall be produced in 12-point font, with footnotes in 10-point font, and shall have one-inch margins on all sides. All memoranda must be filed in a text-searchable format and must have the date of service printed on the front cover.
Parties must provide evidentiary citations, including specific transcript pages, in any submission that cites record material.
The exhibits shall be designated on ECF with short titles. E.g., “Ex. 1 – Doe Declaration,” rather than “Ex. 1.”
Motions in Limine: A list of motions in limine each party intends to file (pursuant to the deadline set forth in Rule V.B.1 below), with a brief description of each such motion.
Moreover, when preparing the record, the respondent shall include either a table of contents or an index of the record’s contents.
However, parties need not submit word-processing files of stipulations of dismissal, of settlement, or of motions for extensions of time unless specifically requested to do so.
Parties may request oral argument by noting “Oral Argument Requested” below the docket number on the moving or opposing papers.
- Document
- Moving or opposing papers
Include
- •Oral Argument Requested
Filing & Service rules
Courtesy Copy Requirements
One hard-copy courtesy copy is required for all briefed motions regardless of length.
Parties shall deliver to chambers one (1) courtesy hard copy of all briefed motions regardless of length (see Rule IV)
Page 3 | Courtesy Copies
Courtesy hard copies are required for other ECF submissions that are 50 pages or more, including exhibits and attachments.
and any other written submissions filed on ECF that are fifty (50) pages in length or more, including any exhibits or attachments.
Page 3 | Courtesy Copies
Courtesy copies must match the ECF-filed document with ECF header numbering, and electronic delivery does not satisfy the hard-copy requirement.
The courtesy copy should be a reproduction of the document as filed on ECF, with the ECF numbering appearing at the top of the page. The emailing of such submissions in PDF to chambers or the courtroom deputy, or the provision of such submissions in electronic format, e.g., on a flashdrive, does not satisfy this requirement.
Page 3 | Courtesy Copies
Parties must deliver three tabbed exhibit binders to the Court on the Friday before trial unless otherwise ordered.
The parties shall provide the Court with three tabbed binders containing copies of all exhibits on the Friday before trial, unless otherwise ordered by the Court. All exhibits must be pre-marked for the trial and placed in binders with tabs.
Page 12 | Filings Prior to Trial in Civil and Criminal Cases
When documentary evidence will be used in direct testimony, counsel must have two court copies plus at least one copy for the reporter, opposing counsel, and each juror.
When counsel anticipates that a witness will refer to documentary evidence during his or her direct testimony, counsel shall have (i) two copies of each document for the Court, and (ii) at least one copy each for the court reporter, each present opposing counsel, and each juror.
Page 12 | Filings Prior to Trial in Civil and Criminal Cases
Sealing & Redaction Procedures
A sealing motion and proposed sealed documents must be filed on ECF when seeking to file under seal.
Any party seeking to file a submission under seal shall file the proposed sealed document(s) and sealing motion on ECF in accordance with the instructions on the Eastern District’s website at:
Page 2 | Filing Under Seal
Filing Bundling Requirements
Motion papers are to be filed on ECF only after full briefing is complete.
After the motion has been fully briefed (i.e., the moving papers, opposition papers, and reply papers, if any, have been served), the moving party shall file all of the papers on ECF.
Page 7 | Motions
Bundled summary judgment motions must be filed in four docket entries with specified contents and order.
When filing a bundled motion for summary judgment, the papers shall be filed in four docket entries. The first shall contain the Notice of Motion. The second shall contain (i) the memorandum in support, (ii) the Local Rule 56.1 statement, (iii) the declaration listing the exhibits, and (iv) the exhibits (each uploaded as a separate attachment). The third shall contain the nonmovant’s filings in the same order. The fourth shall contain the reply.
Page 7 | Motions
Noncompliance with the Bundling Rule results in termination of the motion without prejudice.
Failure to abide by the Bundling Rule shall result in the termination of the motion without prejudice to refiling in compliance therewith.
Page 7 | Motions
The Bundling Rule has specific motion-type exemptions and does not apply in pro se cases.
The Bundling Rule does not apply to the following motions: (1) Motions for default judgment pursuant to Federal Rule of Civil Procedure 55(b)(2); (2) Post-trial and/or post-judgment motions under Rules 50(b) (for judgment as a matter of law), 52(b) (to amend or make additional findings), 59 (for a new trial) and 60 (for relief from a final judgment, order, or proceeding); (3) Motions for attorney’s fees pursuant to Rule 54(d)(2), if the motion is made before a notice of appeal has been filed and the Court has extended the time to appeal under Rule 58(e); and (4) Motions filed in cases where a party is proceeding pro se.
Page 7 | Motions
Pre-Motion Conference Requirements
Pre-motion conferences are required before specified motions in covered cases, with exemptions for bankruptcy, social security, habeas, and pro se matters.
Pre-motion conferences are not required in bankruptcy appeals, social security appeals, habeas cases, or cases in which one or more parties are proceeding pro se. In all other cases, a party must request a pre-motion conference before filing: a) Any motions pursuant to Rules 12, 19-21, 23-25, and 56 of the Federal Rules of Civil Procedure; b) Motions to stay; c) Motions to remand to state court; and d) Motions to compel arbitration;
Page 5 | IV. Motions - A. Pre-Motion Conferences
Parties must file a pre-motion response within five business days, limited to three pages, and include a Rule 56.1 counterstatement for Rule 56 motions.
All parties served with the moving party’s pre-motion-conference letter are required to serve and file a letter response within five (5) business days of service of the moving party’s letter. The response shall not exceed three (3) pages. If the movant is seeking to file a motion for summary judgment under Rule 56, the nonmovant’s response letter must include the nonmovant’s Local Rule 56.1 counterstatement.
Page 6 | IV. Motions - A. Pre-Motion Conferences
A pre-motion request requires a letter capped at four pages, with additional Rule 56.1 materials for summary judgment motions, and timely service of the letter counts as timely service of the motion under Rules 12 or 56.
to exceed four (4) pages, setting out the bases for the anticipated motion. If the motion is for summary judgment under Rule 56, the movant’s pre-motion conference letter must also include a copy of the movant’s Local Rule 56.1 statement and all exhibits in support of the anticipated motion. Each assertion in the Local Rule 56.1 statement must include a citation to specific evidentiary support from the record. Service of that letter within the time requirements of Federal Rule of Civil Procedure 12 or 56 shall constitute timely service of a motion made pursuant to those provisions.
Page 6 | IV. Motions - A. Pre-Motion Conferences
Motions in limine must be filed 30 days before trial, and responses are due 2 weeks after filing unless the Court orders otherwise.
Any motions addressing evidentiary or other issues that should be resolved in limine shall be filed thirty (30) days before the commencement of trial, unless otherwise ordered by the Court. Any responses are due two (2) weeks after the motions are filed.
Page 12 | Filings Prior to Trial in Civil and Criminal Cases
A party may bypass pre-motion procedures and file directly if delay would in good faith deprive a substantive right, but must include an explanation.
If a party wishing to file a motion concludes in good faith that delaying the filing of the motion in order to comply with the pre-motion conference requirements or any other aspect of these individual practices will deprive the party of a substantive right, the party may file the motion within the time required by the Federal Rules of Civil and/or Appellate Procedure, together with an explanation of the basis for the party’s conclusion.
Page 6 | IV. Motions - A. Pre-Motion Conferences
The Court may skip the conference and set briefing directly, and if a conference occurs the Court sets the briefing schedule there with prompt motion filing expected.
The Court may determine, after a pre-motion conference request is filed, that such a conference is unnecessary and may set a briefing schedule without holding a conference. If the Court holds a pre-motion conference, the Court will set a briefing schedule at the conference. Parties should anticipate a briefing schedule that will require the movant to file the motion within a short time after the pre-motion conference.
Page 6 | IV. Motions - B. Briefing Schedule
Adjournment & Extension Requirements
All requests for adjournments or extensions of time relating to matters not referred to a Magistrate Judge (see Rule III) must be in writing and state: (i) the reason for the request; (ii) the original date; (iii) the number of previous requests for adjournments or extensions; (iv) whether any previous requests were granted or denied; (v) whether the adversary consents, and, if not, the reasons given by the adversary for refusing to consent; and (vi) proposed date(s) for adjournment or extension of time. If the requested adjournment or extension affects any other scheduled dates, the party seeking the adjournment should propose revisions of the additional affected dates.
All requests for adjournments or extensions of time relating to matters not referred to a Magistrate Judge (see Rule III) must be in writing and state: (i) the reason for the request; (ii) the original date; (iii) the number of previous requests for adjournments or extensions; (iv) whether any previous requests were granted or denied; (v) whether the adversary consents, and, if not, the reasons given by the adversary for refusing to consent; and (vi) proposed date(s) for adjournment or extension of time. If the requested adjournment or extension affects any other scheduled dates, the party seeking the adjournment should propose revisions of the additional affected dates.
Page 3 | Requests for Adjournments or Extensions of Time
Adjournment and extension requests must be made at least two business days in advance unless there is an emergency.
Absent an emergency, requests for adjournments of court appearances and extensions of filing deadlines shall be made at least two (2) business days prior to the scheduled appearance or filing deadline.
Page 4 | Requests for Adjournments or Extensions of Time
Adjournment requests within 24 hours of a court appearance require both ECF filing and a call to chambers.
Any party seeking an adjournment of a court appearance within 24 hours of the appearance shall file its adjournment request on ECF and then call chambers to advise the Court of the request.
Page 4 | Requests for Adjournments or Extensions of Time
Sentencing adjournment applications must be written, filed at least five business days in advance, and include the reason plus the opposing party’s consent position and stated reasons for non-consent.
Applications regarding sentencing adjournments shall be made in writing at least five (5) business days prior to the date of sentencing and must state the reason for the request and whether the opposing party consents. If the opposing party does not consent, the application for adjournment must provide the reasons given by the opposing party for declining to consent.
Page 10 | Sentencing
Requests for adjournments or extensions in arbitration or mediation proceedings are included among referred matters.
L. Requests for adjournments or extensions of time in arbitration or mediation proceedings;
Page 5 | III. Matters Referred to Assigned Magistrate Judges
Chambers Communication Rules
Communications with chambers must be written and filed on ECF, with copies provided to parties not receiving automatic ECF notice.
All communications with chambers shall be in writing and filed on ECF, with copies simultaneously delivered to all parties who do not receive automatic notification through ECF.
Page 4 | Communications with Chambers
If a submission requires immediate attention, please notify chambers by telephone after filing on ECF.
If a submission requires immediate attention, please notify chambers by telephone after filing on ECF.
Page 4 | Communications with Chambers
ECF registration, filing, and technical questions should be directed to the ECF helpline, not chambers.
Parties are advised not to contact chambers with questions regarding ECF registration, filing, or other technical issues. For ECF assistance, please call the ECF helpline at (718) 613-2285.
Page 2 | Court Filings > Electronic Case Filing
If your submission requires immediate attention, please notify chambers by telephone after you file via ECF.
If your submission requires immediate attention, please notify chambers by telephone after you file via ECF.
Page 2 | Court’s Review of ECF Filings
Scheduling and calendar calls should go to the courtroom deputy at the listed number and are limited to 9:00 a.m. to 3:00 p.m. absent emergency.
For scheduling or calendar matters please call Courtroom Deputy Miriam Vertus at (718) 613-2123. Unless it is an emergency, telephone calls to the Courtroom Deputy are only permitted between 9:00 a.m. and 3:00 p.m.
Page 4 | Communications with Chambers
When pleading to an information, counsel should email the information to the listed chambers contacts at least three business days before the hearing.
If the defendant intends to waive the indictment and plead guilty to an information at the change-of-plea hearing, a copy of the information should also be provided to the Court at least three (3) business days before the hearing. The information should be sent by email to Courtroom Deputy Miriam Vertus at the address Miriam Vertus@nyed.uscourts.gov and Reyes Chambers@nyed.uscouts.gov
Page 10 | Guilty Pleas
Questions about CM/ECF docketing and filings may be directed by phone to the Court’s Docket Section.
For questions regarding CM/ECF Docketing and Filings, you may call the Court’s Docket Section at 718-613-2610.
Page 4 | Communications with Chambers
For technical assistance and Courtroom Technology call 718-613-2290.
For technical assistance and Courtroom Technology call 718-613-2290.
Page 4 | Communications with Chambers
Junior Lawyer Participation Incentives
Notifying the Court that motion argument will be handled by counsel with under five years of experience increases the chance of oral argument.
The likelihood of oral argument is increased if a party notifies the Court that the attorney who will argue the motion or opposition has less than five years of experience as a licensed attorney.
Page 9 | Oral Argument on Motions