Court Rules
Common questions about Judge Barbara Moses's rules

Are courtesy copies required for Judge Barbara Moses?

Courtesy copies are required for all covered filings. Details: 1 copy, delivery within 1 business day, by hand delivery. Courtesy copies of all motion papers must be delivered to Chambers by the next business day.

View ruleSource: page 1, section STANDING ORDER REQUIRING THE FILING OF COURTESY COPIES

Does Judge Barbara Moses require a pre-motion conference or letter before filing a motion?

Judge Barbara Moses's rules set a pre-motion procedure for covered motions. Qualified immunity motions must be filed within 60 days with plaintiff's deposition testimony; no extensions granted.

What page or word limits apply to memorandum of law before Judge Barbara Moses?

Judge Barbara Moses' rule states these limits: 25 pages; 10 pages. Memoranda of law limited to 25 pages (support/opposition) and 10 pages (reply), except reconsideration motions.

What page or word limits apply to in limine motion before Judge Barbara Moses?

Judge Barbara Moses' rule states these limits: 5 pages. In limine motions limited to 5 pages with supporting affidavit.

What formatting rules apply to filings before Judge Barbara Moses?

Judge Barbara Moses' formatting rule includes other font, binding stapled, exhibits must be tabbed and indexed, and exhibits to legal memoranda must be bound separately. Exhibits must be tabbed and indexed; documents under 35 pages should be stapled; exhibits must be bound separately from briefs.

View ruleSource: page 10, section V. Pleadings and Motions

What must be included with final pretrial order filings before Judge Barbara Moses?

The rule requires local rule certificate, exhibit list, legal argument, table of contents, statement of facts, and table of authorities. Final Pre-trial Order must be filed 45 days after discovery deadline.

View ruleSource: page 2, section I. PROCEDURES FOR CASES IN WHICH THERE ARE NO PRO SE PARTIES

What must be included with joint pretrial order filings before Judge Barbara Moses?

The rule requires local rule certificate, exhibit list, legal argument, table of contents, statement of facts, and table of authorities. Joint Pre-Trial Order must be filed within 45 days of this order if discovery deadline has passed.

View ruleSource: page 2, section I. PROCEDURES FOR CASES IN WHICH THERE ARE NO PRO SE PARTIES

How may parties contact Judge Barbara Moses' chambers?

Parties may contact Judge Barbara Moses' chambers by letter fax only as allowed by the rule. Fax requests to chambers at 212-805-6426 in addition to ECF filing.

View ruleSource: page 1, section MODIFICATION TO EXISTING CIVIL SCHEDULING ORDERS AND RELATED MATTERS

How does Judge Barbara Moses handle sealed or redacted filings?

Judge Barbara Moses's rules set procedures for sealed or redacted filings. Process: file redacted on ecf. Sealed documents must be filed electronically on CM/ECF.

View ruleSource: page 10, section V. Pleadings and Motions

How do I request an adjournment or extension before Judge Barbara Moses?

Judge Barbara Moses's rules specify what an adjournment or extension request must include. The request must include reason for request and specificity of reasons. Requests for waiver of scheduling order must be in writing with specific reasons and faxed to chambers.

View ruleSource: page 1, section MODIFICATION TO EXISTING CIVIL SCHEDULING ORDERS AND RELATED MATTERS

Does Judge Barbara Moses require motion papers to be bundled?

No. The rule prohibits holding covered papers for bundling. Motion papers must be filed promptly after service; do not hold until all submissions are complete.

View ruleSource: page 10, section V. Pleadings and Motions
Complete rules summary for Judge Barbara Moses

Blanket extension for filing papers expires May 15, 2020; counsel must apply for extensions thereafter.

Deadlines in civil case management orders extended for total of 75 days.

Requests for waiver of scheduling order must be in writing with specific reasons and faxed to chambers.

Civil conferences available by phone/Skype; requests to Deputy Clerk at Mariela_DeJesus@nysd.uscourts.gov.

Fax requests to chambers at 212-805-6426 in addition to ECF filing.

Opposition papers must be filed on ECF and faxed to chambers within 48 hours if not joined by all counsel.

Courtesy copies of all motion papers must be delivered to Chambers by the next business day.

For urgent motions, deliver courtesy copies the same day filed to avoid delays.

Judge McMahon receives courtesy copies of motion papers from Judge Casey's chambers.

Judge McMahon does not routinely grant discovery adjournments or extensions.

Final Pre-trial Order must be filed 45 days after discovery deadline.

No additional discovery time granted if deadline has passed.

Joint Pre-Trial Order must be filed within 45 days of this order if discovery deadline has passed.

Joint Pre-Trial Order must include proposed jury instructions or findings of fact and conclusions of law.

Motions in limine should not be filed with Joint Pre-Trial Order.

Joint Pre-Trial Order must be filed even if summary judgment motion is pending.

Qualified immunity motions must be filed within 60 days with plaintiff's deposition testimony; no extensions granted.

Patent cases require status conference; continue discovery under existing order until conference.

IDEA/ERISA cases use summary judgment on administrative record instead of discovery schedule.

PSLRA cases require conference and schedule in accordance with statute.

Pro se cases must follow existing scheduling order; Magistrate Judge has authority.

If no scheduling order exists in pro se cases, Judge will conference and refer to Magistrate for discovery.

Pro se cases require separate pre-trial orders from pro se and represented parties; due 45 days after discovery deadline.

For incarcerated pro se parties, counsel must forward all case documents to chambers.

Courtesy copies required for motions

Pre-motion conference required before filing motions

Discovery disputes must be addressed in pre-motion conference

Adjournment/extension requests must be made in advance

Emergency communications allowed with chambers

All communications with chambers must be via ECF with courtesy copies to all parties; no correspondence between counsel to court.

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