Judge Jennifer E. Willis
Individual Rules, Standing Orders & Policies
- Rules last changed:
Limits & Logistics
Document Limits
Courtesy Copies
Courtesy copies
- 1 copy • Email
- 1 copy • Email • Upon Filing
Exhibits
- 1 copy
- 1 copy • Email
Binding: Three Ring Binder
Filings > 10 pages
- 1 copy • Within 1 Business Day
Filings > 25 pages
Adjournments
- Adjournment/extension requests must be ECF letter motions filed 2 business days before deadline with specific required elements
- Extension/adjournment requests must be made at least 2 business days before deadline.
- Requests for adjournments or extensions of time must be filed on ECF as letter motions at least 2 business days before the original deadline.
- Late extension requests are ordinarily denied.
- Extension requests for magistrate-referred matters go to the magistrate judge.
- If more than two business days are required to complete service of the motion for default judgment and supporting papers, the plaintiff should file a letter on ECF explaining why additional time is necessary and when the plaintiff anticipates service will be completed.
- +9 more
Request must include
- Counsel may seek to extend the default deadlines by submitting a stipulation on ECF (with a courtesy copy in Microsoft Word format emailed to ReardenNYSDChambers@nysd.uscourts.gov), not later than five business days before the brief is due.
- Settlement conference dates may be changed without cause if requested at least one week in advance via ECF letter-motion.
Communication
Chambers
Chambers
Phone
Chambers
Phone
Intake Unit
Letter via ECF
Chambers
Page & Word Limits13 rules
Letter motions (adjournment, extension, pre-motion conference, sealing, settlement) max 3 single-spaced pages, no courtesy copies unless exhibits >25 pages
- Page limit
- Up to 3 pages
- Format
- Single-spaced
- Letter motion
Court's wording
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.
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.
- Responsive filing for attorneys
- Up to 6 pages
Discovery dispute letter-motion limited to 6 double-spaced pages.
- Letter motion
- Up to 6 pages
- Discovery motions
Court's wording
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.
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.
- Memorandum of law
- Up to 8,750 words
- Reply memorandum
- Up to 3,500 words
Pretrial memorandum of law limited to 3,500 words in jury and non-jury cases.
- Pretrial memorandum
- Up to 3,500 words
Excluded from word count
- •Caption
- •Index
- •Table of contents
- •Table of authorities
- •Signature block
- •Certificates
Exception
More words with leave of court
Court's wording
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.
Letters may not exceed 3 single-spaced pages in length (exclusive of exhibits).
- Letter
- Up to 3 pages
- Format
- Single-spaced
Excluded from page count
- •Exhibits
Letter motions are limited to 3 single-spaced pages (not including exhibits).
- Letter motion
- Up to 3 pages
- Format
- Single-spaced
Excluded from page count
- •Exhibits
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.
- Responsive letter
- Up to 3 pages
- Format
- Single-spaced
- Discovery motions
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.
- Letter motion
- Up to 3 pages
- Format
- Single-spaced
- Discovery motions
Unless prior permission has been granted, memoranda of law in support of and in opposition to motions may not exceed 8,750 words, and reply briefs may not exceed 3,500 words.
- Memorandum
- Up to 8,750 words
- Reply brief
- Up to 3,500 words
The letter must be less than one page (unless otherwise authorized by the Court) and marked “Confidential Material for Use Only at Settlement Conference.”
- Page limit
- Fewer than 1 page
Joint settlement letter limited to 3 pages with specific content requirements.
- Joint settlement letter
- Up to 3 pages
Court's wording
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.
Neither party may take more than depositions. Absent an agreement between the parties or an order from the Court, non-party depositions shall follow initial party depositions.
Document Format Requirements10 rules
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.
- Line spacing
- Single
- Letter
Exception
Settlement conference submissions and in camera submissions
Joint proposed jury instructions must be emailed to Chambers in Word and PDF format with citations.
- File type
- Word
- Joint proposed jury instructions
Formatting
- •Email to Chambers
- •Provide both Word and PDF versions
- •Include citations to authority for each instruction
Court's wording
Joint proposed jury instructions, which should consist of a single document that includes the text of any requested instructions and citations to the authority from which each instruction derives and notes any areas of disagreement between the parties. A copy shall be emailed to Chambers in both Microsoft Word and .pdf format.
Joint proposed verdict form must be emailed to Chambers in Word and PDF format.
- File type
- Word
- Joint proposed verdict form
Formatting
- •Email to Chambers
- •Provide both Word and PDF versions
Court's wording
A joint proposed verdict form, which should consist of a single document that notes any areas of disagreement between the parties. A copy shall be emailed to Chambers in both Microsoft Word and .pdf format.
The 56.1 Statement must be organized into numbered paragraphs, with each numbered paragraph setting forth only one factual assertion.
briefs must be submitted in accordance with the Federal Rules of Bankruptcy Procedure.
All moving papers, letter-motions, and letters filed on ECF or emailed to chambers must be in searchable PDF form.
- File type
- Motion
- Letter
The typeface, margins and spacing of motion papers must conform to Local Civil Rule 11.1.
Video submissions must be on labeled thumb drive or emailed.
Formatting
- •Video on thumb drive
- •Email alternative
Court's wording
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.
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.
- Binding
- Three-ring binder
Formatting
- •Tab dividers
- •Exhibit list
Additionally, to the extent citing unreported cases, parties are requested to use Westlaw citations whenever possible.
Document Filing Requirements75 rules
Proposed Case Management Plan required one week before initial conference
- Document
- Case management plan
Must include
- •Rule 26(f) meeting report
Court's wording
Before the Initial Case Management Conference, parties must meet and confer on a discovery plan. One week before the scheduled conference, the parties shall file on ECF a Proposed Case Management Plan and Report of Rule 26(f) Meeting. Parties shall use the template available at https://nysd.uscourts.gov/hon-jennifer-e-willis.
Excel sheet required for specific motions with email submission to chambers
- Document
- Motion
Must include
- •Excel sheet
Court's wording
When a Party submits any of the following motions to Judge Willis, or within fourteen days of the referral of such a motion to Judge Willis, the moving Party shall submit an Excel sheet including the relevant calculations. An Excel sheet is required even if the motion was already submitted to a District Judge. Excel sheets are required for the following motions: 1) Inquests on Damages 2) Motions for Attorney’s Fees 3) FLSA Damages 4) IDEA Reimbursements. The Excel sheet should be emailed to WillisNYSDChambers@nysd.uscourts.gov and should CC all opposing counsel or the pro se litigant if they are unrepresented. A letter should also be filed on the docket providing the date and time the Excel sheet was emailed.
Pro se parties use different template and submit to Pro Se Intake Unit
- Document
- Case management plan
Must include
- •Pro se template
Court's wording
If any party is pro se, parties shall use the Proposed Case Management Plan for Pro Se Cases template available at https://nysd.uscourts.gov/hon-jennifer-e-willis. The pro se party should submit the Proposed Case Management Plan for Pro Se Cases to the Pro Se Intake Unit and the represented party should submit it via ECF and simultaneously mail a copy to the pro se party.
Joint Pretrial Order required within 30 days of discovery completion with specific content requirements
- Document
- Joint pretrial order
Must include
- •Full caption
- •Stipulations
- •Governing law
- •Claims defenses list
Court's wording
Unless otherwise ordered by the Court, within 30 days from the date of completion of discovery in a civil case, the parties shall submit to the Court for its approval a Joint Pretrial Order. In general, except in pro se cases, a Joint Pretrial Order shall include the following: a. The full caption of the action; b. The name, address, telephone number and email of each principal member of the trial team; c. A list of each claim and defense that will be tried and identification of the governing law (including applicable regulations) governing each such claim and defense; d. If applicable, a list of any claims and defenses asserted in the pleadings that are not to be tried; e. A list by each party of its trial witnesses that it, in good faith, expects to present, with an indication of whether the witnesses will testify in person or by deposition and the general subject area of the witness’s testimony and anticipated length of time needed for each witness; f. A statement as to how and when the parties will give notice to each other of the order of their trial witnesses and, if the parties cannot agree, the parties’ statement that they will agree to the Court’s default rule (i.e. that the parties shall advise each other by no later than 48 hours before the start of trial as to the order of their witnesses); g. A list by each party of exhibits that it, in good faith, expects to offer in its case in chief, together with any specific objections thereto; h. All stipulations or statements of fact or law on which the parties have agreed;
In cases where confidential information will be exchanged, the parties may utilize the Court’s model Protective Order, available at https://nysd.uscourts.gov/hon-jennifer-e-willis. Should the parties apply for a protective order that differs from the Court’s model, the parties should attach the proposed order showing a comparison of how the proposed order differs from the Court’s model.
At least 24 hours in advance of a plea, the indictment/information, plea agreement, a summary of the elements of the offense(s), and the maximum and mandatory penalties for each crime/count should be emailed to WillisCriminalDuty@nysd.uscourts.gov.
For diversity jurisdiction cases, joint letter must include corporate citizenship and partnership/entity member citizenship.
Court's wording
In cases invoking the Court’s diversity jurisdiction, the parties’ joint letter must state: a. If any party is a corporation, that party’s place of incorporation and the principal place of business, as defined in Hertz Corp. v. Friend, 559 U.S. 77 (2010). b. If any party is a partnership, limited partnership, limited liability company, or trust, the citizenship of each entity’s members, shareholders, partners, and/or trustees.
Such a letter-motion must include a representation that the parties engaged in a good faith meet-and-confer process that proved unsuccessful.
The attorney who will serve as principal trial counsel must appear at all conferences with the Court.
TRO application requires letter-motion stating adversary notification/consent or Rule 65(b) satisfaction.
Court's wording
In addition to filing the proposed temporary restraining order in accordance with the S.D.N.Y. Electronic Case Filing Rules and Instructions, the movant shall file a letter- motion stating whether: i. The adversary has been notified, and whether the adversary consents to temporary injunctive relief; or ii. The requirements of Federal Rule of Civil Procedure 65(b) are satisfied, and no notice is necessary.
Any party wishing to seek a temporary restraining order should file a motion for a temporary restraining order, supporting documents, and a proposed order on ECF in accordance with the procedures in the S.D.N.Y. Electronic Case Filing Rules and Instructions.
Should include
- •Proposed order
- •Supporting documents
At least one week before the final pretrial conference, the parties shall provide the Court with a digital copy of exhibits and demonstrative aids that they intend to use in their case in chief at trial, as well as an index. The parties shall email ReardenNYSDChambers@nysd.uscourts.gov requesting a link to upload these materials.
The index shall be marked as specified in paragraph 7.A.xii above.
Email exhibit list in Word and PDF format with four columns, completing only first two columns.
Court's wording
The parties shall also email a list of all exhibits sought to be admitted, both in Microsoft Word and .pdf format. The list shall be divided into four columns labeled as follows: (1) Exhibit Number; (2) Description (of the exhibit); (3) Date Identified; and (4) Date Admitted. The parties shall complete the first two columns but leave the third and fourth columns blank, for use by the Court.
Three business days before trial, submit two tabbed binders with one copy of each documentary exhibit to Chambers.
Court's wording
three business days prior to trial, the parties shall submit to Chambers physical copies of all documentary exhibits, organized by exhibit number. Hard copies of the exhibits shall be submitted to Chambers in a tabbed binder, containing one copy of each exhibit; the Court shall be provided with two hard copy sets.
Present approved electronic device order when bringing devices into Courthouse.
Court's wording
Upon the Court’s approval, Chambers will coordinate with the District Executive’s Office to issue the order and forward a copy to counsel. The order must be presented upon bringing the electronic device(s) into the Courthouse.
One week before trial, submit expert witness disclosures under FRCP 26(a)(2) or FRCrP 16.
Court's wording
At least one week before trial, each of the parties must submit to the Court any disclosures pertaining to expert witnesses under Federal Rule of Criminal Procedure 16 or Federal Rule of Civil Procedure 26(a)(2).
The motion must be supported by the following papers:
Obtain a Certificate of Default for each defaulting party pursuant to Federal Rule of Civil Procedure 55(a) and Local Civil Rule 55.1.
Plaintiff must serve motion and file affidavit of service within 2 business days.
- Document
- Motion for default judgment
Must include
- •Certificate of service
Court's wording
Within two business days of filing the motion for default judgment, the plaintiff must (1) serve the motion and all supporting papers on the party against whom a default judgment is sought, and (2) file an affidavit of service on ECF. The Court will not consider the motion for default judgment unless and until such affidavit of service is filed.
Proof of service required for court's default judgment hearing order.
Court's wording
The Court will review the motion for default judgment and, if appropriate, issue an order setting a date and time for a default judgment hearing. If the Court issues such an order, the movant must then serve on the party against whom default judgment is sought the Court’s order setting a date and time for the hearing. The plaintiff must file proof of such service on the docket in the manner and date specified in the Court’s order.
Opposing parties must reproduce each entry in the moving party’s Rule 56.1 Statement and set out the opposing party’s response directly beneath it.
Joint proposed voir dire questions, which should consist of a single document that includes the text of any requested questions and notes any areas of disagreement between the parties.
- Document
- Joint proposed voir dire
Should include
- •Areas of disagreement
- •Requested questions text
counsel for all parties must file notices of appearance in this Court promptly upon removal.
Where parties rely on deposition or hearing testimony, they should not include excerpts of transcripts as exhibits, but rather should include (only once) the entire transcript as an exhibit.
A statement of whether the parties consent to less than a unanimous verdict.
Trial witness list must include testimony method, interpreter needs, and summary.
Court's wording
A list of all trial witnesses, indicating whether such witnesses will testify in person or by deposition, whether such witnesses will require an interpreter (and, if so, which party will pay the costs for the interpreter), and a brief summary of the substance of each witness's testimony.
Joint proposed findings must be detailed with citations to trial testimony and exhibits.
- Document
- Joint proposed findings conclusions
Must include
- •Areas of disagreement
Court's wording
Joint proposed findings of fact and conclusions of law, which should be detailed and note any areas of disagreement between the parties and, for each proposed factual finding, shall include citations to the proffered trial testimony and exhibits.
Each factual assertion must be followed by citation(s) to the portion(s) of the evidentiary record relied upon.
Must include
- •Evidentiary record citations
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.
Proposed orders/stipulations/judgments must be ECF attachments with explanation.
- Document
- Proposed order
Must include
- •Attachment to application
Court's wording
All proposed orders, stipulations, and judgments must be submitted as attachments or exhibits to an application to the Court filed on ECF and must explain the purpose of the proposed order, stipulation, or judgment.
A statement of the damages claimed and any other relief sought, including the manner and method used to calculate any claimed damages and a breakdown of the elements of such claimed damages.
- Document
- Damages statement
Include
- •Damages breakdown
Parties may request oral argument by letter (filed on ECF) at the time of filing their moving, opposing, or reply papers. The letter shall detail why oral argument would be beneficial.
- Document
- Oral argument request
Must include
- •Letter
The response must state specifically what is admitted and what is disputed, and the basis for any dispute, citing specific portions of the evidentiary record relied upon.
Joint Pretrial Order must be filed within 30 days of discovery close or dispositive motion decision.
Court's wording
within 30 days of the close of discovery—or, if any dispositive motion is filed, within 30 days of the Court’s decision on such motion—the parties shall file on ECF, and email to the Court, a proposed Joint Pretrial Order
The requesting party’s memorandum of law shall also include the words “ORAL ARGUMENT REQUESTED” on the cover page.
- Document
- Memorandum of law
Must include
- •Oral argument requested
Exhibit list must use asterisk system and include objections with citations.
- Document
- Exhibit list
Must include
- •Objections with citations
Court's wording
A list of all proposed exhibits for each party's case-in-chief. The list shall (1) mark each exhibit with one asterisk indicating exhibits to which no party objects on grounds of authenticity, and two asterisks indicating exhibits to which no party objects on any ground; (2) for exhibits with objections other than authenticity, the objection should be noted by indicating the grounds for the objection, with citations to the Federal Rules of Evidence and any other authority (with any objections not made being deemed waived); and (3) state whether an outstanding motion in limine will resolve the objection.
Deposition designations require complete transcripts with color-coded highlighting.
- Document
- Deposition designations
Must include
- •Designation list
- •Complete transcripts
- •Objections in margins
- •Color coded highlighting
Court's wording
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.
Email Word copy of 56.1 statement to other parties.
- Document
- Summary judgment motion
Must include
- •Electronic copy to other parties
Court's wording
Any party moving for summary judgment shall provide all other parties with an electronic copy, in Microsoft Word format, of the moving party’s Statement of Material Facts Pursuant to Local Civil Rule 56.1.
Such letter motion must state when the meet-and-confer occurred.
Memoranda of 10 pages or more shall contain a table of contents and a table of authorities, neither of which shall count against the word limit.
- Document
- Memorandum
Must include
- •Table of contents
- •Table of authorities
Where a party seeks summary judgment against a pro se litigant, the party must also comply with the notice requirements of Local Civil Rule 56.2.
Where a party moves to dismiss or for judgment on the pleadings against a pro se litigant and refers to matters outside the pleadings, counsel must serve and file the notice set forth in Local Civil Rule 12.1.
Before the Initial Case Management Conference, parties must meet and confer on a discovery plan. One week before the scheduled conference, the parties shall file on ECF a Proposed Case Management Plan and Report of Rule 26(f) Meeting. Parties shall use the template available at https://nysd.uscourts.gov/hon-jennifer-e-willis.
If any party is pro se, parties shall use the Proposed Case Management Plan for Pro Se Cases template available at https://nysd.uscourts.gov/hon-jennifer-e-willis.
to Judge Willis, the moving Party shall submit an Excel sheet including the relevant calculations. An Excel sheet is required even if the motion was already submitted to a District Judge. Excel sheets are required for the following motions: 1) Inquests on Damages 2) Motions for Attorney's Fees 3) FLSA Damages 4) IDEA Reimbursements.
Except in pro se cases, the Joint Pretrial Order must include the caption, trial team contact information, claims and defenses with governing law, witness and exhibit lists, stipulations, a demonstratives exchange schedule, and proposed voir dire questions.
- Document
- Joint pretrial order
Must include
- •Caption
Court's wording
In general, except in pro se cases, a Joint Pretrial Order shall include the following: a. The full caption of the action; b. The name, address, telephone number and email of each principal member of the trial team; c. A list of each claim and defense that will be tried and identification of the governing law (including applicable regulations) governing each such claim and defense; d. If applicable, a list of any claims and defenses asserted in the pleadings that are not to be tried; e. A list by each party of its trial witnesses that it, in good faith, expects to present, with an indication of whether the witnesses will testify in person or by deposition and the general subject area of the witness's testimony and anticipated length of time needed for each witness; f. A statement as to how and when the parties will give notice to each other of the order of their trial witnesses and, if the parties cannot agree, the parties' statement that they will agree to the Court's default rule (i.e. that the parties shall advise each other by no later than 48 hours before the start of trial as to the order of their witnesses); g. A list by each party of exhibits that it, in good faith, expects to offer in its case in chief, together with any specific objections thereto; h. All stipulations or statements of fact or law on which the parties have agreed; i. A proposed schedule by which the parties will exchange demonstratives that the parties intend to use at trial, notify each other of any objections thereto, consult with each other regarding those objections, and notify the Court of any remaining disputes; j. Proposed voir dire questions;
Filing & Service rules
Electronic Filing Rules
Letter motions must be filed on ECF in accordance with the S.D.N.Y. Local Rules.
Letter motions shall be filed on ECF in accordance with the S.D.N.Y. Local Rules.
Page 1 | I. Communications with Chambers - B. Letter Motions
Sealed documents must be e-filed through ECF; a party unable to comply, or believing a document should not be e-filed, must move for leave to file on paper.
Any party unable to comply with the requirement for electronic filing under seal through the ECF system, or who has reason to believe that a particular document should not be electronically filed, must move for leave of the Court to file on paper.
Page 4 | E. Requests to File Materials Under Seal
In pro se cases, the pro se party submits the Proposed Case Management Plan for Pro Se Cases to the Pro Se Intake Unit while the represented party submits it via ECF.
The pro se party should submit the Proposed Case Management Plan for Pro Se Cases to the Pro Se Intake Unit and the represented party should submit it via ECF and simultaneously mail a copy to the pro se party.
Page 5 | III. Pre-Trial Practice - A. Initial Case Management Conference
Letters should be filed on ECF except for settlement conference submissions and in camera submissions.
Letters should be filed on ECF except for settlement conference submissions and in camera submissions.
Page 1 | I. Communications with Chambers - A. Letters
Trial exhibits are not required to be filed electronically on ECF.
Exhibits need not be filed electronically on ECF.
Page 7 | B. Courtesy Copies of Trial Exhibits
Filing Timing and Cure Windows
Pre-sentence submissions for misdemeanors should be submitted no later than 2 weeks before the scheduled sentencing.
Pre-sentence submissions for misdemeanors should be submitted no later than 2 weeks before the scheduled sentencing.
Criminal cases
Page 1 | III. Misdemeanor Sentencing
Pre-plea submissions must be emailed to WillisCriminalDuty@nysd.uscourts.gov at least 24 hours before the plea.
At least 24 hours in advance of a plea, the indictment/information, plea agreement, a summary of the elements of the offense(s), and the maximum and mandatory penalties for each crime/count should be emailed to WillisCriminalDuty@nysd.uscourts.gov.
Criminal cases
Page 1 | II. Pleas
Failure to respond to a discovery letter motion within 3 business days results in waiver of any objections.
Failure to respond within 3 business days will result in a waiver of any objections.
Page 2 | II. Motions - Discovery Motions
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.
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.
Page 2 | II. Motions - Discovery Motions
The Proposed Case Management Plan and Report of Rule 26(f) Meeting must be filed on ECF one week before the scheduled Initial Case Management Conference.
One week before the scheduled conference, the parties shall file on ECF a Proposed Case Management Plan and Report of Rule 26(f) Meeting.
Page 5 | III. Pre-Trial Practice - A. Initial Case Management Conference
In consent cases, the parties must submit a Joint Pretrial Order for the Court's approval within 30 days after completion of discovery, unless otherwise ordered.
Unless otherwise ordered by the Court, within 30 days from the date of completion of discovery in a civil case, the parties shall submit to the Court for its approval a Joint Pretrial Order.
Page 6 | IV. Pretrial Procedures - A. Joint Pretrial Orders in Civil Cases
In pro se cases, each party's Pretrial Statement is due within 30 days after the completion of discovery.
within 30 days after the completion of discovery each party shall file its own Pretrial Statement
Page 7 | Pretrial Order (continued)
Responsive letters to letter motions should be submitted within 3 business days after the letter motion is submitted.
Any responsive letter should be submitted within 3 business days after submission of the letter motion.
Page 3 | II. Motions
Service and Proof of Service Rules
If any other party is not an ECF user, a pro se party must send copies of any filing to that party and include proof of service.
If any other party is not a user of the ECF System (e.g., if there is another pro se party in the case), a pro se party must send copies of any filing to the party and include proof of service affirming that he or she has done so.
Page 1 | I. Communications with Chambers - Pro se Parties
Pro se parties must mail all communications with the Court to the Pro Se Intake Unit at 500 Pearl St., Room 230, New York, NY 10007.
By Standing order, a pro se party must mail all communications with the Court to the Pro Se Intake Unit located at 500 Pearl St., Room 230, New York, NY 10007.
Page 1 | I. Communications with Chambers - Pro se Parties
Counsel must provide pro se litigants with printed copies of any cited decisions reported exclusively in computerized databases, as required by Local Civil Rule 7.2.
As required by Local Civil Rule 7.2, counsel must provide a pro se litigant with printed copies of decisions cited in any submission that are reported exclusively in computerized databases.
Page 4 | F. Motions in Pro Se Cases
Each party must file an original Pretrial Statement with the Pro Se Office, serve a copy on all other parties or their counsel, and the original must indicate the date the copy was mailed.
The party must file an original Pretrial Statement with the Pro Se Office and serve a copy on all other parties or their counsel if represented. The original Pretrial Statement must indicate the date a copy was mailed to the other party or that party's attorney.
Page 7 | Pretrial Order (continued)
Submissions requiring immediate attention should be hand-delivered to the Pro Se Intake Unit.
Submissions requiring immediate attention should be hand-delivered to the Pro Se Intake Unit.
Page 1 | I. Communications with Chambers - Pro se Parties
Hand-delivered mail should be left with the Court Security Officers at the Worth Street entrance of 500 Pearl Street and may not be brought directly to Chambers.
Hand-delivered mail should be left with the Court Security Officers at the Worth Street entrance of 500 Pearl Street and may not be brought directly to Chambers.
Page 2 | I. Communications with Chambers - D. Hand Deliveries
The pro se party should submit the Proposed Case Management Plan for Pro Se Cases to the Pro Se Intake Unit and the represented party should submit it via ECF and simultaneously mail a copy to the pro se party.
The pro se party should submit the Proposed Case Management Plan for Pro Se Cases to the Pro Se Intake Unit and the represented party should submit it via ECF and simultaneously mail a copy to the pro se party.
Page 5 | III. Pre-Trial Practice - A. Initial Case Management Conference
Pro se communications with the Court are docketed upon receipt, and that docketing constitutes service on any ECF system user, unless the Court orders otherwise.
Unless the Court orders otherwise, all communications with the Court will be docketed upon receipt; such docketing shall constitute service on any user of the ECF system.
Page 1 | I. Communications with Chambers - Pro se Parties
Courtesy Copy Requirements
No courtesy copies for letter motions unless exhibits exceed 25 pages
Courtesy copies of letter motions are not required unless exhibits, if any, exceed 25 pages.
Page 1 | I. Communications with Chambers
Courtesy copy of hearing transcript required for chambers (pro se exempt)
When applicable, parties shall coordinate the ordering of a hearing transcript from the court reporter. The ordering party shall send a courtesy copy of the transcript to Chambers via email. Pro se parties are exempt from this Rule.
Page 6 | III. Pre-Trial Practice F. Hearing Transcripts
Courtesy copies of trial exhibits must be emailed and submitted in three-ring binder.
The parties shall each send a courtesy copy of all exhibits, pre-marked, to WillisNYSDChambers@nysd.uscourts.gov. Exhibits need not be filed electronically on ECF. The parties shall also each submit one hard copy of the pre-marking exhibits in a well-organized three-ring binder, separated by tab dividers.
Email text-searchable transcript copies to chambers if available.
The parties shall provide the Court by email with an electronic, text-searchable copy of the transcript, if such a copy is available.
Civil cases
Email Word versions of proposed orders/stipulations/judgments to chambers.
The parties must also email a Microsoft Word version of proposed orders, stipulations, and judgments to ReardenNYSDChambers@nysd.uscourts.gov.
Civil cases
Courtesy copies required for pleadings filed in state court before removal.
counsel for the removing party or parties must provide the Court with a courtesy copy of any pleading filed or served while the case remained in state court.
Civil cases
Email courtesy copies of fully submitted motions to chambers.
Once a motion has been fully submitted, the movant shall email a courtesy copy of all motion papers, including any oppositions, replies, declarations, and exhibits, to ReardenNYSDChambers@nysd.uscourts.gov.
Civil cases
Courtesy copies of the unredacted version of documents subject to a pending sealing application must be provided to Chambers.
The parties shall comply with such deadlines by filing the redacted version on ECF, serving the unredacted papers at issue on any opposing parties, and providing courtesy copies of the unredacted version to Chambers.
Page 4 | E. Requests to File Materials Under Seal
The party who orders a hearing transcript must email a courtesy copy of the transcript to Chambers; pro se parties are exempt.
When applicable, parties shall coordinate the ordering of a hearing transcript from the court reporter. The ordering party shall send a courtesy copy of the transcript to Chambers via email. Pro se parties are exempt from this Rule.
Page 6 | III. Pre-Trial Practice - F. Hearing Transcripts
Each party must send a courtesy copy of all pre-marked trial exhibits to the Chambers email address WillisNYSDChambers@nysd.uscourts.gov.
The parties shall each send a courtesy copy of all exhibits, pre-marked, to WillisNYSDChambers@nysd.uscourts.gov.
Page 7 | B. Courtesy Copies of Trial Exhibits
Each party must also submit one hard copy of the pre-marked exhibits in a well-organized three-ring binder separated by tab dividers.
The parties shall also each submit one hard copy of the pre- marking exhibits in a well-organized three-ring binder, separated by tab dividers.
Page 7 | B. Courtesy Copies of Trial Exhibits
Courtesy copies of trial exhibits must be sent to chambers email and submitted in three-ring binder.
The parties shall each send a courtesy copy of all exhibits, pre-marked, to WillisNYSDChambers@nysd.uscourts.gov. Exhibits need not be filed electronically on ECF. The parties shall also each submit one hard copy of the pre-marking exhibits in a well-organized three-ring binder, separated by tab dividers.
Page 7 | Courtesy Copies of Trial Exhibits
Courtesy copies required for settlement letters over 10 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.
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.
Page 1 | I. Communications with Chambers - B. Letter Motions
Large exhibits need not be emailed if available on ECF.
If exhibits to a motion are available on ECF and email transmission of the exhibits would be cumbersome (e.g., due to file size), the movant need not email the exhibit files to Chambers but should instead state in the email that the motion exhibits are available on ECF.
Civil cases
Sealing & Redaction Procedures
Any party seeking to file a document under seal or in redacted form shall proceed as follows: i. Meet and Confer. The party seeking leave to file sealed or redacted materials should meet and confer with any opposing party (or any third party seeking confidential treatment of the information) in advance to narrow the scope of the redaction or sealing request.
Any party seeking to file a document under seal or in redacted form shall proceed as follows: i. Meet and Confer. The party seeking leave to file sealed or redacted materials should meet and confer with any opposing party (or any third party seeking confidential treatment of the information) in advance to narrow the scope of the redaction or sealing request.
Civil cases
Redactions or sealing of public court filings require court approval unless permitted by Rule 9.A.
Except for redactions permitted by Rule 9.A, all redactions or sealing of public court filings require Court approval. To be approved, any redaction or sealing of a court filing must be narrowly tailored to serve whatever purpose justifies the redaction or sealing and must otherwise be consistent with the presumption in favor of public access to judicial documents. See, e.g., Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110, 119-20 (2d Cir. 2006). In general, the parties’ consent, or the fact that information is subject to a confidentiality agreement between litigants, is not sufficient to overcome the presumption in favor of public access to judicial documents. See, e.g., In re Gen. Motors LLC Ignition Switch Litig., No. 14-MD-2543 (JMF), 2015 WL 4750774, at *4 (S.D.N.Y. Aug. 11, 2015).
Civil cases
Sealed/redacted motions must comply with Rule 9.
When leave is sought to file a motion under seal or with redactions, the parties must comply with Rule 9.
Civil cases
Redacted documents require a letter-motion filed in public view, with the redacted version publicly filed and the unredacted version filed under seal on ECF.
iii. Redacted Document(s). Where a party wishes to file a document in redacted form, the party shall electronically file a letter-motion seeking leave to file a document in redacted form on ECF in accordance with Standing Order 19-MC-583 and Section 6 of the S.D.N.Y. Electronic Case Filing Rules and Instructions. The letter-motion itself shall be filed in public view, should explain the reasons for seeking to file the document in redacted form, and should not include confidential information. At the same time, the party shall: (1) publicly file on ECF and electronically relate to the letter-motion a copy of the document with the proposed redactions; and (2) file under seal on ECF (with the appropriate level of restriction) and electronically relate to the motion an unredacted copy of the document with the proposed redactions highlighted.
Civil cases
Parties may redact sensitive information and information requiring caution without court approval, following specific formatting rules.
Without prior permission from the Court, parties may redact two categories of information from public court filings: “sensitive information,” and information requiring “caution.” Unless necessary, parties should not include in public filings the five categories of “sensitive information” (i.e., social security numbers [use the last four digits only], names of minor children [use the initials only], dates of birth [use the year only], financial account numbers [use the last four digits only], and home addresses [use the City and State only]). Without Court approval, parties may also redact from public filings the six categories of information requiring “caution” described in the Privacy Policy (i.e., any personal identifying number, medical records [including information regarding treatment and diagnosis], employment history, individual financial information, proprietary or trade secret information, and information regarding an individual’s cooperation with the Government).
Civil cases
Sealed documents require a letter-motion filed in public view, with the sealed document filed separately under seal on ECF.
ii. Sealed Document(s). The party shall electronically file a letter-motion seeking leave to file a document under seal on ECF in accordance with Standing Order 19-MC-583 and Section 6 of the S.D.N.Y. Electronic Case Filing Rules and Instructions. The letter-motion itself shall be filed in public view, should explain the reasons for seeking to file the document under seal, and should not include confidential information. The proposed sealed document shall be separately and contemporaneously filed under seal on ECF (with the appropriate level of restriction) and electronically related to the motion (or to the relevant Court order, if the Court previously granted leave to file the document under seal). Note that the summary docket text, but not the document itself, will be open to public inspection and, thus, should not include confidential information sought to be filed under seal.
Civil cases
Parties unable to file electronically under seal may email letter-motions to chambers with specific formatting requirements.
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.
Civil cases
Confidential Materials may be redacted or filed under seal only as the Court directs upon appropriate application or as required by FRCP 5.2.
All Confidential Materials filed with the Court may be redacted or filed under seal only as the Court directs upon appropriate application by either party or as required by Federal Rule of Civil Procedure 5.2, which describes sensitive information that must be redacted from public court filings.
Page 3 | E. Requests to File Materials Under Seal
A party seeking to file redacted material based on a Confidential designation must request leave by letter motion explaining the reasons for sealing.
Any party wishing to file in redacted form any pleading, motion, memorandum, exhibit, or other document, or any portion thereof, based on a party's designation of information as Confidential, must make a specific request to the Court by letter motion explaining the reasons for seeking to file that submission under seal.
Page 3 | E. Requests to File Materials Under Seal
A pending sealing application does not toll deadlines; parties must file the redacted version on ECF, serve the unredacted papers on opposing parties, and provide courtesy copies of the unredacted version to Chambers.
The pendency of the application to seal does not affect any deadlines that may govern the proposed filing. The parties shall comply with such deadlines by filing the redacted version on ECF, serving the unredacted papers at issue on any opposing parties, and providing courtesy copies of the unredacted version to Chambers.
Page 4 | E. Requests to File Materials Under Seal
The letter motion to seal must be filed in public view, explain the reasons for sealing, and exclude the confidential information; supporting papers are filed separately and may be sealed or redacted only to the extent necessary.
The letter motion must be filed in public view, must explain the particular reasons for seeking to file that information under seal, and should not include confidential information sought to be filed under seal. Supporting papers must be filed separately and may be filed under seal or redacted only to the extent necessary to safeguard information to be filed under seal.
Page 4 | E. Requests to File Materials Under Seal
If sealing is approved no further submissions are required; if denied in part, the party must refile the document with modified redactions as directed by the Court.
If the Court approves the filing under seal, no further submissions shall be required. If the Court denies, in part, the motion for filing under seal, the party who made the submission shall be required to refile the document with modified redactions as directed by the Court.
Page 4 | E. Requests to File Materials Under Seal
The filing party must publicly file the redacted document and electronically file under seal the unredacted document with the proposed redactions highlighted.
The filing party shall also (a) publicly file the document with the proposed redactions, and (b) electronically file under seal a copy of the unredacted document with the proposed redactions highlighted.
Page 4 | E. Requests to File Materials Under Seal
The proposed sealed document must be contemporaneously filed under seal on ECF and electronically related to the letter motion, with a public docket text that excludes confidential information.
The proposed sealed document must be contemporaneously filed under seal in the ECF system and electronically related to the letter motion. The summary docket text, but not the sealed document, will be open to public inspection and should not include confidential information sought to be filed under seal.
Page 4 | E. Requests to File Materials Under Seal
Filing Bundling Requirements
After an action has been accepted as related to a prior filing, all future court papers and correspondence must contain the docket number of the new filing, as well as the docket number of the case to which it is related.
After an action has been accepted as related to a prior filing, all future court papers and correspondence must contain the docket number of the new filing, as well as the docket number of the case to which it is related.
Civil cases
Summary judgment generally not available in non-jury cases.
Absent good cause, the Court ordinarily will not permit summary judgment practice in a non-jury case.
Civil cases
Pre-Motion Conference Requirements
Pre-motion letters required for most motions before Judge Willis except specified exemptions
Pre-motion letters seeking a conference should propose a briefing schedule and are required where the proposed motion is returnable before Judge Willis, or where the proposed motion has been referred to Judge Willis, except that no pre- motion letter is required for (i) motions for admission pro hac vice, (ii) motions by litigants in actions where a party is both pro se and incarcerated, (iii) motions for reconsideration or reargument, (iv) motions for a new trial, (v) motions in limine, (vii) motions listed in Fed. R. App. P. 4(a)(4)(A), (viii) motions for recusal, (ix) habeas corpus petitions, (x) applications made by order to show cause, and (xi) Federal Rule of Civil Procedure 12(b)(6) motions to dismiss in lieu of an Answer.
Page 2 | II. Motions
Discovery disputes require meet-and-confer, then 3-page letter motion, 3-day response window, waiver for late response
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.
Page 2 | II. Motions
Non-discovery pre-motion conferences require letter motion following Individual Practice I.B requirements
To arrange a pre-motion conference for non- discovery matters, the moving party shall submit a letter motion in accordance with Individual Practice I.B. The letter motion should set forth the nature of the anticipated
Page 2 | II. Motions
The Notice will direct the parties to file on ECF, approximately one week prior to the conference, a joint proposed Case Management Plan and Scheduling Order (using Judge Rearden’s fillable Civil Case Management Plan and Scheduling Order), as well as a joint letter. At that time, one courtesy copy of the pleadings should also be emailed to ReardenNYSDChambers@nysd.uscourts.gov.
The Notice will direct the parties to file on ECF, approximately one week prior to the conference, a joint proposed Case Management Plan and Scheduling Order (using Judge Rearden’s fillable Civil Case Management Plan and Scheduling Order), as well as a joint letter. At that time, one courtesy copy of the pleadings should also be emailed to ReardenNYSDChambers@nysd.uscourts.gov.
Civil cases
Page 3 | 3. Conferences - B. Initial Case Management Conference
Good faith meet-and-confer required before filing discovery dispute letter-motion.
Any party wishing to raise a discovery dispute with the Court must first confer in good faith with the opposing party—in person, virtually, or by telephone—in an effort to resolve the dispute. Conferring in writing does not satisfy this requirement.
Civil cases
Page 3 | 3. Conferences - C. Discovery Disputes
Good faith meet-and-confer required before TRO application unless Rule 65(b) requirements met.
Unless the requirements of Federal Rule of Civil Procedure 65(b) are met, the movant shall confer with its adversary before making an application for a temporary restraining order or other emergency relief.
Civil cases
Page 4 | 4. Applications for Temporary Restraining Orders - B.
Motion for default judgment required under FRCP 55(b)(2) and Local Rule 55.2(b); order to show cause not permitted.
File a motion for default judgment pursuant to Federal Rule of Civil Procedure 55(b)(2) and Local Civil Rule 55.2(b). A party seeking a default judgment should not proceed by order to show cause.
Civil cases
Page 16 | DEFAULT JUDGMENT PROCEDURE
Motions in limine opposition due within 7 days, replies not permitted.
Motions addressing any evidentiary issues or other matters that should be resolved in limine. Opposition papers shall be filed within seven days thereafter. Replies will not be entertained.
Civil cases
Pre-motion conferences required only for discovery-related motions.
A pre-motion conference is required only for discovery-related motions (including discovery letter-motions addressed in Rule 3.C). A pre-motion conference will not be held for any other motion.
Civil cases
Responses to pretrial memorandum due within one week.
Responses or oppositions to those legal issues shall be filed within one week thereafter.
Civil cases
To arrange a pre-motion conference for non-discovery matters, the moving party shall submit a letter motion in accordance with Individual Practice I.B.
To arrange a pre-motion conference for non-discovery matters, the moving party shall submit a letter motion in accordance with Individual Practice I.B.
Page 2 | II. Motions - Motions other than Discovery Motions
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.
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.
Page 2 | II. Motions - Discovery Motions
Pre-motion letters proposing a briefing schedule are required for motions returnable before or referred to Judge Willis, except for pro hac vice, pro se incarcerated litigant, reconsideration/reargument, new trial, in limine, Fed. R. App. P. 4(a)(4)(A), recusal, habeas, order to show cause, and Rule 12(b)(6) motions filed in lieu of an Answer.
Pre-motion letters seeking a conference should propose a briefing schedule and are required where the proposed motion is returnable before Judge Willis, or where the proposed motion has been referred to Judge Willis, except that no pre-motion letter is required for (i) motions for admission pro hac vice, (ii) motions by litigants in actions where a party is both pro se and incarcerated, (iii) motions for reconsideration or reargument, (iv) motions for a new trial, (v) motions in limine, (vii) motions listed in Fed. R. App. P. 4(a)(4)(A), (viii) motions for recusal, (ix) habeas corpus petitions, (x) applications made by order to show cause, and (xi) Federal Rule of Civil Procedure 12(b)(6) motions to dismiss in lieu of an Answer.
Page 2 | II. Motions - A. Pre-Motion Conferences Letters in Civil Cases
Sur-reply memoranda will not be accepted unless the party first obtains permission of the Court.
Sur-reply memoranda will not be accepted without prior permission of the Court.
Page 3 | Memoranda of Law
The Parties themselves should not attend the call.
The Parties themselves should not attend the call.
If adversary notified but doesn’t consent to TRO, application must be heard at mutually agreeable time.
If the movant’s adversary has been notified but does not consent to temporary injunctive relief, the movant must bring the application to the Court at a mutually agreeable time, so that the Court may hear argument from both sides in reaching a determination.
Civil cases
Page 4 | 4. Applications for Temporary Restraining Orders - D.
Before filing a letter with the Court, the parties are expected to meet and confer regarding a briefing schedule for any anticipated motion.
In advance of filing a letter with the Court, the Parties are expected to meet and confer regarding a briefing schedule for any anticipated motion.
Page 2 | II. Motions - A. Pre-Motion Conferences Letters in Civil Cases
At the meet and confer held before filing the letter seeking leave to move for summary judgment, the Parties should discuss and prepare a joint submission indicating all facts that are not in dispute. If for any reason the Parties are unable to do so, they should submit a separate letter explaining why they should be relieved of that obligation.
At the meet and confer held before filing the letter seeking leave to move for summary judgment, the Parties should discuss and prepare a joint submission indicating all facts that are not in dispute. If for any reason the Parties are unable to do so, they should submit a separate letter explaining why they should be relieved of that obligation.
Page 3 | B. Summary Judgement Motions
Initial Rule 16 conference scheduled within one month of Answer filing.
The Court will generally schedule a Federal Rule of Civil Procedure 16 conference to take place within one month of the filing of an Answer to the Complaint.
Civil cases
Page 3 | 3. Conferences - B. Initial Case Management Conference
Pre-conference phone call scheduled approximately one week before conference.
The Court will schedule a pre-conference phone call between the Court and Counsel for the Parties approximately a week before the settlement conference.
Adjournment & Extension Requirements
Adjournment/extension requests must be ECF letter motions filed 2 business days before deadline with specific required elements
All requests for adjournments or extensions of time must be filed on ECF as letter motions at least 2 business days before the original deadline. The letter motion must state: (1) the original date(s); (2) the number of previous requests for adjournment or extension; (3) the reason for the extension; and (4) whether the adversary consents and, if not, the reasons given by the adversary for refusing to consent. Emergency requests should be emailed to WillisNYSDChambers@nysd.uscourts.gov and filed on the docket citing the nature of the emergency.
Page 2 | I. Communications with Chambers
Revised Scheduling Order in Word format required if extension affects other deadlines.
If the requested adjournment or extension would affect any other scheduled deadlines or dates, a proposed Revised Scheduling Order must be attached. A Microsoft Word version of the Revised Scheduling Order must be emailed to ReardenNYSDChambers@nysd.uscourts.gov.
Civil cases
Extension/adjournment requests must be made at least 2 business days before deadline.
All requests for extensions of time or adjournment of motions, pretrial conferences, or other matters must be made not less than two business days before the scheduled deadline or date.
Civil cases
Late extension requests are ordinarily denied.
Requests for extensions made after the expiration of the original deadline or date will ordinarily be denied.
Civil cases
Counsel may seek to extend the default deadlines by submitting a stipulation on ECF (with a courtesy copy in Microsoft Word format emailed to ReardenNYSDChambers@nysd.uscourts.gov), not later than five business days before the brief is due.
Counsel may seek to extend the default deadlines by submitting a stipulation on ECF (with a courtesy copy in Microsoft Word format emailed to ReardenNYSDChambers@nysd.uscourts.gov), not later than five business days before the brief is due.
Civil cases
Extension requests must include original date, previous requests, reasons, adversary consent, and impact on other deadlines.
All such requests must be made in writing and filed on ECF as letter-motions, and should state: (1) the original date; (2) the number of previous requests for adjournment or extensions of time; (3) whether those previous requests were granted or denied; (4) the reason(s) for the requested extension; (5) whether the adversary consents, and, if not, the reason(s) given by the adversary for declining to consent; and (6) the date of the parties’ next scheduled appearance before the Court, as well as any other existing deadlines, and whether the requested adjournment or extension would affect those other deadlines or any other scheduled dates.
Civil cases
Requests for adjournments or extensions of time must be filed on ECF as letter motions at least 2 business days before the original deadline.
All requests for adjournments or extensions of time must be filed on ECF as letter motions at least 2 business days before the original deadline.
Page 2 | I. Communications with Chambers - C. Requests for Adjournments or Extensions of Time
Adjournment and extension letter motions must state the original dates, the number of previous requests, the reason for the request, and the adversary's consent position.
The letter motion must state: (1) the original date(s); (2) the number of previous requests for adjournment or extension; (3) the reason for the extension; and (4) whether the adversary consents and, if not, the reasons given by the adversary for refusing to consent.
Page 2 | I. Communications with Chambers - C. Requests for Adjournments or Extensions of Time
Date changes required if adjournment enables necessary discovery or allows client to attend in person instead of by phone.
In addition, the parties are required to seek a change in the date if (a) an adjournment would permit necessary discovery or exchange of information that would make the conference more fruitful, or (b) a client who would otherwise be permitted to participate by telephone would be available to attend the conference were it held on another date.
Page 4 | Adjournments of Settlement Conferences
Adjournment requests require consultation with all parties, filing letter-motion on ECF, and Court approval.
To seek a change in date, the Party should first consult with all other counsel as to their and their clients' (and insurers' if applicable) availability on at least three dates. The Party must then file forthwith on ECF, as a letter-motion, a request to adjourn the settlement conference to the agreed-upon date and time. The conference date will not be deemed changed until Chambers receives the letter-motion and it is approved by the Court.
Page 5 | Adjournments of Settlement Conferences
If all parties advise the Court in writing that the case has settled prior to the scheduled conference, I will ordinarily adjourn the conference sine die. In these circumstances, the parties should file a letter-motion on ECF requesting an adjournment of the settlement conference sine die, and the Court will then issue a text-only order.
If all parties advise the Court in writing that the case has settled prior to the scheduled conference, I will ordinarily adjourn the conference sine die. In these circumstances, the parties should file a letter-motion on ECF requesting an adjournment of the settlement conference sine die, and the Court will then issue a text-only order.
Page 5 | Adjournments of Settlement Conferences
If more than two business days are required to complete service of the motion for default judgment and supporting papers, the plaintiff should file a letter on ECF explaining why additional time is necessary and when the plaintiff anticipates service will be completed.
If more than two business days are required to complete service of the motion for default judgment and supporting papers, the plaintiff should file a letter on ECF explaining why additional time is necessary and when the plaintiff anticipates service will be completed.
Civil cases
Page 17 | Default Judgment Procedure
Extension requests for magistrate-referred matters go to the magistrate judge.
Requests for extensions regarding a matter that has been referred to a Magistrate Judge shall be addressed to the assigned Magistrate Judge.
Civil cases
Emergency adjournment or extension requests should be emailed to chambers and filed on the docket citing the nature of the emergency.
Emergency requests should be emailed to WillisNYSDChambers@nysd.uscourts.gov and filed on the docket citing the nature of the emergency.
Page 2 | I. Communications with Chambers - C. Requests for Adjournments or Extensions of Time
Otherwise, counsel should set forth the reasons for seeking the change in date and must make the application by letter-motion as soon as counsel becomes aware of the need of or potential need for the change.
Otherwise, counsel should set forth the reasons for seeking the change in date and must make the application by letter-motion as soon as counsel becomes aware of the need of or potential need for the change.
Page 4 | Adjournments of Settlement Conferences
Last-minute adjournment requests are strongly disfavored and unlikely to be granted.
Requests for an adjournment on the eve of the scheduled settlement conference are strongly disfavored and not likely to be granted.
Page 4 | Adjournments of Settlement Conferences
Settlement conference dates may be changed without cause if requested at least one week in advance via ECF letter-motion.
A Party may make a written application by letter-motion filed on ECF consistent with Rule I.C. of the Court’s Individual Practices to adjourn or advance the date of the settlement conference without providing cause if the application for a change in date is made at least one week prior to the scheduled conference date.
Page 4 | Adjournments of Settlement Conferences
Chambers Communication Rules
Emergency requests should be emailed to WillisNYSDChambers@nysd.uscourts.gov and filed on the docket citing the nature of the emergency.
Emergency requests should be emailed to WillisNYSDChambers@nysd.uscourts.gov and filed on the docket citing the nature of the emergency.
Page 2 | I. Communications with Chambers
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.
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.
Page 5 | III. Pre-Trial Practice C. Deposition Disputes
If you anticipate the need for a late-night or weekend warrant, please send Judge Willis an email at WillisCriminalDuty@nysd.uscourts.gov, and call Judge Willis on her personal cell phone, available on the criminal duty roster.
If you anticipate the need for a late-night or weekend warrant, please send Judge Willis an email at WillisCriminalDuty@nysd.uscourts.gov, and call Judge Willis on her personal cell phone, available on the criminal duty roster.
Criminal cases
Page 1 | I. Criminal Applications - c. Late-night or weekend warrants
Applications for PEN registers, NDOs, and OCs that require Judge Willis's review and signature must be emailed to WillisCriminalDuty@nysd.uscourts.gov.
All applications requiring Judge Willis's review and signature should be sent to WillisCriminalDuty@nysd.uscourts.gov.
Criminal cases
Page 1 | I. Criminal Applications - b. PEN Registers, NDOs, and OCs
Arrest and search warrants, including applications for cell site information, triggerfish, and GPS tracking, should be emailed to WillisCriminalDuty@nysd.uscourts.gov.
Arrest and search warrants, including applications for cell site information, triggerfish, and GPS tracking, should be emailed to WillisCriminalDuty@nysd.uscourts.gov.
Criminal cases
Page 1 | I. Criminal Applications - a. Warrants
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.
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.
Civil cases
Page 4 | 4. Applications for Temporary Restraining Orders - E.
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.
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.
Civil cases
Page 12 | Policy on the Use of Electronic Devices
Faxes to chambers are prohibited.
Faxes to Chambers are not permitted.
Civil cases
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.
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.
Civil cases
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.
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.
Civil cases
Warrants. Arrest and search warrants, including applications for cell site information, triggerfish, and GPS tracking, should be emailed to WillisCriminalDuty@nysd.uscourts.gov. The cover email should specify the time that the agent and AUSA are available to swear out the complaint or affidavit.
Warrants. Arrest and search warrants, including applications for cell site information, triggerfish, and GPS tracking, should be emailed to WillisCriminalDuty@nysd.uscourts.gov. The cover email should specify the time that the agent and AUSA are available to swear out the complaint or affidavit.
Criminal cases
Page 1 | Criminal Applications
Plea materials must be emailed 24 hours in advance.
Pleas. At least 24 hours in advance of a plea, the indictment/information, plea agreement, a summary of the elements of the offense(s), and the maximum and mandatory penalties for each crime/count should be emailed to WillisCriminalDuty@nysd.uscourts.gov.
Criminal cases
Page 1 | Pleas
PEN Registers, NDOs, and OCs should be emailed to chambers.
PEN Registers, NDOs, and OCs. All applications requiring Judge Willis’s review and signature should be sent to WillisCriminalDuty@nysd.uscourts.gov.
Criminal cases
Page 1 | Criminal Applications
Late-night/weekend warrants require email and phone call to Judge.
Late-night or weekend warrants. If you anticipate the need for a late-night or weekend warrant, please send Judge Willis an email at WillisCriminalDuty@nysd.uscourts.gov, and call Judge Willis on her personal cell phone, available on the criminal duty roster.
Criminal cases
Page 1 | Criminal Applications
Pro se parties may not call Chambers or send any document or filing directly to Chambers.
A pro se party may not call Chambers or send any document or filing directly to Chambers.
Page 1 | I. Communications with Chambers - Pro se Parties
The Excel sheet should be emailed to WillisNYSDChambers@nysd.uscourts.gov and should CC all opposing counsel or the pro se litigant if they are unrepresented.
The Excel sheet should be emailed to WillisNYSDChambers@nysd.uscourts.gov and should CC all opposing counsel or the pro se litigant if they are unrepresented.
Page 5 | II. Motions
Government agencies must send knowledgeable representative or make official available by phone if over 100 miles away.
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).
Page 3 | Attendance of Parties Required
Telephone adjournment requests are never accepted; must be filed via ECF letter-motion.
In no circumstances will a telephone request for an adjournment be entertained.
Page 4 | Adjournments of Settlement Conferences
Parties must not copy the Court on correspondence exchanged between counsel or the parties.
Parties shall not copy the Court on correspondence sent between counsel or the Parties.
Page 1 | I. Communications with Chambers - A. Letters
To the extent Parties or counsel need electronic devices during any proceedings before the Court, the requesting party should complete the form at https://nysd.uscourts.gov/sites/default/files/2020-06/Electronic%20Dev.pdf and return it via email to Chambers, copying opposing counsel. Such electronic device request need not be filed on the docket. Electronic device requests should be submitted by close of business the day before any scheduled appearance.
To the extent Parties or counsel need electronic devices during any proceedings before the Court, the requesting party should complete the form at https://nysd.uscourts.gov/sites/default/files/2020-06/Electronic%20Dev.pdf and return it via email to Chambers, copying opposing counsel. Such electronic device request need not be filed on the docket. Electronic device requests should be submitted by close of business the day before any scheduled appearance.
Page 3 | D. Electronic Device Requests
If a deposition dispute cannot be resolved after good-faith efforts, the parties should jointly call Chambers at (212) 805-0244 so staff can relay the dispute to Judge Willis for resolution by video conference or written order.
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.
Page 5 | III. Pre-Trial Practice - C. Deposition Disputes
Email Chambers at ReardenNYSDChambers@nysd.uscourts.gov to request upload link for trial materials.
The parties shall email ReardenNYSDChambers@nysd.uscourts.gov requesting a link to upload these materials.
Civil cases
Page 11 | Trial Exhibits and Demonstrative Aids
For questions that cannot be answered by reference to these Rules or the S.D.N.Y. Local Rules, or for docketing, scheduling, or calendar matters, counsel may contact the Courtroom Deputy, Khalilah Williams.
For questions that cannot be answered by reference to these Rules or the S.D.N.Y. Local Rules, or for docketing, scheduling, or calendar matters, counsel may contact the Courtroom Deputy, Khalilah Williams.
Civil cases
Hand deliveries should be left with the Court Security Officers at the Worth Street entrance of the Courthouse. If a hand delivery requires the Court’s immediate attention, ask the Court Security Officers to notify Chambers that an urgent package has arrived.
Hand deliveries should be left with the Court Security Officers at the Worth Street entrance of the Courthouse. If a hand delivery requires the Court’s immediate attention, ask the Court Security Officers to notify Chambers that an urgent package has arrived.
Civil cases
Questions from pro se parties can be directed to the Pro Se Intake Unit at (212) 805-0175.
Questions can be directed to the Pro Se Intake Unit at (212) 805-0175.
Page 1 | I. Communications with Chambers - Pro se Parties
Requests for reasonable accommodations on account of disability or religion may be emailed to Judge Willis's chambers email address.
Requests for reasonable accommodations on account of disability or religion with respect to the Court's rules or in connection with any proceeding before Judge Willis may be emailed to WillisNYSDChambers@nysd.uscourts.gov.
Page 1 | Footnote 1
For docketing, scheduling, and calendar matters, parties may call Chambers at (212) 805-0244 between 9:00 AM and 5:00 PM or email WillisNYSDChambers@nysd.uscourts.gov.
For docketing, scheduling and calendar matters, call Chambers at (212) 805-0244 between 9:00 AM and 5:00 PM or email Chambers at WillisNYSDChambers@nysd.uscourts.gov.
Page 2 | I. Communications with Chambers - E. Calendar Matters
Parties more than 100 miles away may attend by phone with advance written application.
If a Party resides more than 100 miles from the Courthouse and it would be a great hardship for the Party to attend in person, upon written application in advance of the conference in the form of a letter-motion to be filed on ECF, I will sometimes excuse that Party’s presence but I will require that Party to be available by telephone throughout the settlement conference.
Page 3 | Attendance of Parties Required
Junior Lawyer Participation Incentives
Junior attorneys invited to address court at case management conferences
Junior members of legal teams are invited to address the Court at case management conferences. Firms are encouraged to provide this opportunity to junior attorneys for training purposes.
Page 5 | III. Pre-Trial Practice B. Case Management Conferences
Court encourages junior attorneys (under 5 years) to participate in courtroom proceedings and allows multiple attorneys to speak.
To assist in training the next generation of attorneys, the Court strongly encourages relatively inexperienced attorneys—in particular, attorneys with less than five years’ experience—to participate in all courtroom proceedings. Further, the Court is amenable to having multiple attorneys speak on behalf of a single party if doing so creates an opportunity for a lawyer who is relatively inexperienced.
Civil cases
Page 4 | 3. Conferences - D. Participation by Junior Attorneys
Oral argument requests are more likely to be granted when a lawyer who graduated law school within the previous five years is identified to argue, and junior attorneys are invited to argue motions they helped prepare.
Junior members of legal teams representing clients are invited to argue motions they have helped prepare and to question witnesses with whom they have worked. Firms are encouraged to provide this opportunity to junior attorneys for training purposes; a request for oral argument is more likely to be granted if a party identifies a lawyer to argue the motion who has graduated law school within the previous five years.
Page 3 | C. Oral Argument on Motions
Junior members of legal teams are invited to address the Court at case management conferences so firms can give them training opportunities.
Junior members of legal teams are invited to address the Court at case management conferences. Firms are encouraged to provide this opportunity to junior attorneys for training purposes.
Page 5 | III. Pre-Trial Practice - B. Case Management Conferences