Judge Alison J. Nathan

All Communications by Letter. Except as otherwise provided below in Rule 1.B and 1.C, all communications with the Court shall be by letter filed on ECF. This rule also applies to questions regarding the Undersigned’s Individual Rules. Parties should not call the Chambers telephone line except as directed in Rule 1.B. Letters may not exceed three pages in length (exclusive of exhibits or attachments). Any letter longer than one page must be double spaced. Letters solely between parties or their counsel or otherwise not addressed to the Court may not be filed on ECF or otherwise sent to the Court (except as exhibits to an otherwise properly filed document). Unless otherwise noted, parties should not submit courtesy copies of letters filed on ECF.

Letters may not exceed three pages in length (exclusive of exhibits or attachments). Any letter longer than one page must be double spaced.

Letter Requests to Seal Information. Letters that include requests to be filed under seal shall be emailed to the Court (ca02_AJNchambers@ca2.uscourts.gov) as .pdf attachments. The letter shall explain the basis for seeking sealing. Parties should not make any requests in the body of the email. Refer to Rule 4 for further instruction regarding requests for redactions and filing under seal. Any time a party also submit a copy of the document to the Court’s email address. Paper copies alone are insufficient.

ECF. In accordance with the ECF Rules, all attorneys representing parties before Judge Nathan are required to register promptly as ECF filers and to enter an appearance in the case. The pertinent instructions are available on the Court website (https://nysd.uscourts.gov/rules/ecf-related-instructions). Counsel are responsible for updating their contact information on ECF, should it change, and for checking the docket sheet regularly, regardless of whether they receive an ECF notification of case activity. Pursuant to ECF Rule 4.3, counsel “have an obligation to review the Court’s actual order, decree, or judgment, as available on ECF, and should not rely on the description of such order, decree or judgment in the Notice of Electronic Filing

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.

All appendices to memoranda of law must be tabbed and indexed.

Any Rule 56.1 statement in support of a motion for summary judgment is limited to no more than 25 pages unless leave of the Court to file a longer document is obtained at least one week prior to the due date of such motion for summary judgment.

An opposing party’s response to the moving party’s Rule 56.1 statement shall be no longer than 50 pages, unless leave of the Court to file a longer document is obtained at least one week prior to the due date of such submission.

If necessary, the opposing party may provide an additional Local Rule 56.1 statement containing a separate, short and concise statement of additional facts as to which it is contended that there exists a genuine issue to be tried. This submission shall be no longer than 25 pages.

A pre-motion conference with the Court is required before making any such motion. To arrange a pre-motion conference, the moving party shall submit a letter of not more than two pages setting forth the basis for the anticipated motion and explaining why exceptional circumstances justify submitting it before discovery closes. The opposing party may respond with a letter of not more than two pages within three days after the pre-motion letter is filed.

Defendant shall then submit a motion for summary judgment and a memorandum of law of no more than 50 pages supporting their motion and opposing Plaintiff’s motion. Defendant shall also file any Rule 56.1 statement in support of their motion, and any response to Plaintiff’s Rule 56.1 statement.

Plaintiff shall then file a memorandum of law of no more than 35 pages opposing Defendant’s motion and replying to Defendant’s opposition to Plaintiff’s motion.

Defendant shall then file a reply to Plaintiff’s opposition of no more than 10 pages.

A party must confer with its adversary before making an application for a temporary restraining order unless proceeding ex parte is justified by Fed. R. Civ. P. 65(b)(1). As soon as a party decides to seek a temporary restraining order, that party must file a letter on ECF (or by email if proceeding ex parte), or, in the case of a true emergency, email Chambers at ca02_AJNchambers@ca2.uscourts.gov and state clearly whether (i) it has notified its adversary, and whether the adversary consents to temporary injunctive relief; or (ii) the requirements of Fed. R. Civ. P. 65(b) are satisfied and no notice is necessary.

In any action in which subject matter jurisdiction is founded on diversity of citizenship pursuant to 28 U.S.C. § 1332, the party asserting the existence of such jurisdiction shall, prior to the Initial Pretrial Conference, submit to the Court a letter no longer than two pages explaining the basis for that party's belief that diversity of citizenship exists. Where any party is a corporation, the letter shall state both the place of incorporation and the principal place of business. In cases where any party is a partnership, limited partnership, limited liability company, or trust, the letter shall state the citizenship of each of the entity's members, shareholders, partners, and/or trustees.

In addition to filing these documents on ECF, parties should also submit copies of these documents to the Court by email (ca02_AJNchambers@ca2.uscourts.gov), as Microsoft Word documents.

At the time the Joint Pretrial Report is filed, each party shall email to the Court and serve on opposing counsel, but not electronically file, all deposition excerpts which will be offered as substantive evidence, as well as a one-page synopsis of those excerpts for each deposition. Each synopsis shall include page citations to the pertinent pages of the deposition transcripts.

If required by the Standing Order, counsel seeking to bring a device into the Courthouse shall submit a copy of the Electronic Devices General Purpose Form, available at https://nysd.uscourts.gov/node/766, to the Court by email at least two business days prior to the relevant trial or hearing.

All communications with the Court by a pro se party should be mailed to the Pro Se Intake Unit. No document or filing should be sent directly to Chambers.

All papers to be filed with the Court by a pro se party, along with any courtesy copies of those papers, should be sent to the Pro Se Intake Unit, Room 200, United States Courthouse, 500 Pearl Street, New York, New York 10007.

Memoranda of law in support of and in opposition to motions are limited to 25 pages, and reply memoranda are limited to 10 pages. All memoranda of law shall be in 12-point font or larger and be double-spaced.

Any Rule 56.1 statement in support of a motion for summary judgment is limited to no more than 25 pages unless leave of the Court to file a longer document is obtained at least one week prior to the due date of such motion for summary judgment. An opposing party’s response to the moving party’s Rule 56.1 statement shall be no longer than 50 pages, unless leave of the Court to file a longer document is obtained at least one week prior to the due date of such submission.