Judge Jennifer E. Willis

Pro se parties may not contact the Court directly. All communications with the Court by a pro se party (including written, electronic, and telephone communications) should be addressed to the Pro Se Office.

No documents or court filings may be sent directly to Chambers. A pro se party may instead file papers with the Court by: i. Delivering them in person to the Pro Se Office at 40 Foley Square, Room 105, New York, New York 10007; ii. Mailing them to the Pro Se Intake Office at 500 Pearl Street, New York, New York 10007 (Attention: Pro Se Intake); iii. Emailing them as an attachment in PDF format to Temporary_Pro_Se_Filing@nysd.uscourts.gov, in which case the pro se party should follow the instructions contained in the April 1, 2020 Addendum to the S.D.N.Y. Electronic Case Filing Rules and Instructions; or iv. Filing them on ECF, if the pro se party has filed a Motion for Permission for Electronic Case Filing (available online and in the Pro Se Office) and been granted such permission by the Court.

All requests for discovery by a pro se party should be sent to counsel for the party from whom discovery is sought (if the party is represented by counsel). Discovery requests should not be sent to the Court.

In the event of any discovery disputes, the parties are required to confer in an effort to resolve the dispute without Court intervention. If the parties are unable to resolve their dispute, either party may file a letter-motion, not to exceed six double-spaced pages, explaining the nature of the dispute and requesting an informal conference.

Letters to the Court are permitted. Letters should be filed on ECF2 except for settlement conference submissions and in camera submissions. Letters may not exceed 3 singe-spaced pages in length (exclusive of exhibits). Parties shall not copy the Court on correspondence sent between counsel or the Parties.

Letter motions shall be filed on ECF in accordance with the S.D.N.Y. Local Rules. Requests that may be made by letter motion include requests for an adjournment, an extension, a pre-motion conference, sealing, and a settlement conference. Letter motions are limited to 3 single-spaced pages (not including exhibits). Courtesy copies of letter motions are not required unless exhibits, if any, exceed 25 pages.

Courtesy copies of letter motions are not required unless exhibits, if any, exceed 25 pages.

Emergency requests should be emailed to WillisNYSDChambers@nysd.uscourts.gov and filed on the docket citing the nature of the emergency.

Any party wishing to raise a discovery dispute with the Court must first confer in good faith with the opposing party, in person or by telephone, in an effort to resolve the dispute. If the meet-and-confer does not resolve the dispute, a party may submit a letter motion no longer than 3 single-spaced pages, explaining the nature of the dispute and requesting a conference. Such letter motion must state when the meet-and-confer occurred. Any responsive letter should be submitted within 3 business days after submission of the letter motion and should be no longer than 3 single-spaced pages. Failure to respond within 3 business days will result in a waiver of any objections. The Court will endeavor to resolve the issue without a conference and without the need for formal briefing. However, if formal briefing is required, the Court will either schedule a conference or set a schedule for such briefing.

If a dispute arises during a deposition, the Parties should attempt to proceed through as much of the deposition as possible that is unaffected by the dispute. Parties should not unilaterally terminate a deposition and the Court expects good faith efforts to resolve any disputes. After doing so, if the dispute cannot be resolved, the Parties should jointly contact the Court at (212) 805-0244. Chambers staff will take a message summarizing the dispute and check to see if Judge Willis is available to resolve the issue either through a video conference or a written order.

Communications with Chambers, including requests for extensions or adjournments, shall be by letter or letter-motion filed on ECF in accordance with these Rules and Practices.

For situations requiring immediate attention from the Court, counsel should call Chambers directly; in such situations, parties should email ReardenNYSDChambers@nysd.uscourts.gov requesting the Court’s contact information.

Faxes to Chambers are not permitted.

If the dispute is not resolved, the party may file a letter-motion on ECF pursuant to Rule 5.I below, not to exceed six double-spaced pages, explaining the nature of the dispute and requesting an informal conference.

If the opposing party wishes to respond to the letter-motion, it should promptly send an e-mail to Chambers, copying all counsel of record, to advise that a responsive letter will be forthcoming. Any such responsive filing shall not exceed six double-spaced pages and must be filed on ECF within three business days of the filing of the letter-motion.

The movant should then email ReardenNYSDChambers@nysd.uscourts.gov, giving notice of the filing and the time frame requested for Court action. Where the motion is made on notice, all parties should be copied on the email.

Unless prior permission has been granted, memoranda of law in support of and in opposition to motions are limited to 8,750 words, and reply memoranda are limited to 3,500 words.

Motion papers shall be filed promptly after service. Motion papers shall be accompanied by a letter no longer than three pages outlining the substantive argument advanced in the papers.

The requesting party’s memorandum of law shall also include the words “ORAL ARGUMENT REQUESTED” on the cover page.

The 56.1 Statement must be organized into numbered paragraphs, with each numbered paragraph setting forth only one factual assertion.

A pretrial memorandum of law in cases in which a party believes it would be useful to the Court, not to exceed 3,500 words (excluding the caption, any index, table of contents, table of authorities, signature blocks, or any required certificates but including material contained in footnotes or endnotes), absent leave of Court, addressing any issues of law that are expected to arise at or before trial.

A designation by each party of deposition testimony to be offered in its case-in-chief and any counter-designations and objections by any other party. In addition to a designation list, the parties shall provide the complete deposition transcripts with color-coded highlighting indicating the portions designated by each party and the objections listed in the margins.

Attorneys’ use of personal electronic devices (including mobile phones) and general purpose computing devices (such as laptops and tablets) within the Courthouse and its environs is governed by Standing Order M10-468. When Court permission is required under the Standing Order, attorneys seeking to bring electronic devices to the Court should email a completed Model Court Order to ReardenNYSDChambers@nysd.uscourts.gov five business days before the relevant trial or hearing.

iv. Submission by Email. Any party unable to comply with the requirement for electronic filing under seal on ECF, or who believes that a particular document should not be electronically filed at all, shall file a letter-motion by email, seeking leave of the Court to file in a different manner. Such letter-motions may be emailed to ReardenNYSDChambers@nysd.uscourts.gov as text-searchable PDF attachments, with copies simultaneously delivered to all counsel. In the subject line, the cover email should state clearly: (1) the caption of the case, including the lead party names and docket number; and (2) a brief description of the contents of the letter. Parties shall not include substantive communications in the body of the email. Unless otherwise ordered by the Court, letter-motions seeking leave to file in a different manner shall not exceed five double-spaced pages.

If the settlement letter and exhibits exceed 10 pages, the parties are required to submit a courtesy copy to the Court no later than one business day after submission of the letter.

The joint letter must not exceed three pages and should include, at a minimum, the following: (a) the history of settlement negotiations, if any, including any prior offers or demands; (b) each party’s evaluation of the settlement value of the case and the rationale for it; (c) any case law authority in support of your settlement position; and (d) any other facts that would be helpful to the Court in preparation for the conference.

The courtesy copy should be placed in well-organized three-ring binder(s). Where appropriate, the binder(s) shall be separated by tab dividers preceded by an exhibit list.

If a Party is submitting a video, the clip shall be provided on a thumb drive delivered to Chambers and labeled with a case name and docket number. Alternatively, the clip may be emailed to Chambers at WillisNYSDChambers@nysd.uscourts.gov.

When any government agency is a Party, counsel of record must be accompanied by a knowledgeable representative from the agency (or, if the agency official with knowledge is more than 100 miles from the Courthouse, the official must be available to participate by telephone).

In no circumstances will a telephone request for an adjournment be entertained.