Judge Ona T. Wang
Individual Rules, Standing Orders & Policies
- Rules last changed:
Limits & Logistics
Document Limits
Courtesy Copies
Administrative Agency Appeal Motions
- Within 2 Business Days
Binding: Three Ring Binder
Filings > 10 pages
- 1 copy • Within 1 Business Day
Adjournments
- Adjournment/extension requests must be filed as letter motions with specific required elements and 48-hour advance notice
Communication
Chambers
Intake Unit
Page & Word Limits6 rules
Attach a brief (limited to 3 pages) synopsis of the case
- Case synopsis
- Up to 3 pages
Letter motions limited to 1,500 words (single-spaced) or 5 pages (handwritten, pro se)
- Letter motion (computer-generated)
- Up to 1,500 words
- Letter motion (handwritten) for self-represented parties
- Up to 5 pages
- Format
- Single-spaced
Excluded from the limit
- •Exhibits
Court's wording
Letter motions are limited to 1,500 words, with single‐spaced text (not including exhibits, headings, captions, or signatures). If filed by a party not represented by an attorney and handwritten, letter motions may not exceed 5 pages.
Letters limited to 1,500 words (single-spaced) or 5 pages (handwritten, pro se)
- Letter (computer-generated) for attorneys
- Up to 1,500 words
- Letter (handwritten) for self-represented parties
- Up to 5 pages
- Format
- Single-spaced
Excluded from the limit
- •Exhibits
Court's wording
Word/Page Limit. Whether filed electronically or not, letters may not exceed 1,500 words, with single‐spaced text (exclusive of exhibits, headings, captions, and signatures). If filed by a party not represented by an attorney and handwritten, letters may not exceed 5 pages.
Pre-motion conference letters limited to 1,500 words, single-spaced, excluding exhibits/headings/captions/signatures
- Pre-motion letter
- Up to 1,500 words
- Format
- Single-spaced
Excluded from word count
- •Exhibits
Court's wording
Letters requesting a pre‐motion conference should summarize the basis of the motion and follow the procedures for communicating with the Court set forth in Section II. Letters may not exceed 1,500 words, with single‐spaced text (not including exhibits, headings, captions, or signatures). If filed by a party not represented by an attorney and
Sur‐reply memoranda will not be accepted without prior permission of the Court, and, if permitted, are not to exceed 2,500 words, or 10 pages if filed by a party not represented by an attorney.
- sur-reply memorandum for attorneys
- Up to 2,500 words
- sur-reply memorandum for self-represented parties
- Up to 10 pages
Word limits for memoranda of law (6,500/2,500 words) and page limits for pro se parties (25/10 pages)
- Memorandum of law for attorneys
- Up to 6,500 words
- Memorandum of law for self-represented parties
- Up to 25 pages
- Reply memorandum for attorneys
- Up to 2,500 words
- Reply memorandum for self-represented parties
- Up to 10 pages
Excluded from the limit
- •Caption
- •Index
- •Table of contents
- •Table of authorities
- •Signature block
- •Certificates
Court's wording
Unless prior permission has been granted, memoranda of law in support of and in opposition to motions are limited to 6,500 words, and reply memoranda are limited to 2,500 words, not including the caption, any index, table of contents, table of authorities, signature blocks, or any required certificates, but do include material contained in footnotes or endnotes. If filed by a party not represented by an attorney, memoranda of law in support of and in opposition to motions are limited to 25 pages, and reply memoranda are limited to 10 pages.
Document Format Requirements1 rule
If feasible, every submission should be in text‐searchable format created by converting the document electronically to .pdf by computer (that is, not by scanning a printed document). If a .pdf is created by scanning a printed document (for instance, in the case of a pre‐existing documentary exhibit), the party should use software to make the document text searchable whenever possible.
- File type
Formatting
- •Text-searchable
- •Electronically converted
- •Not scanned
Document Filing Requirements19 rules
Amended filings must include redlines showing differences from original versions.
- Document
- Amended filing
Must include
- •Redline
Court's wording
Any amended or corrected filing (including but not limited to amended pleadings) shall be filed with a redline showing all differences between the original and revised filing. Any motion to amend a pleading shall similarly be filed with a redline showing all differences between the operative pleading and the proposed amended pleading.
Counsel must serve pro se parties with paper copies and file proof of service; no courtesy copies needed.
- Document
- Electronic filing
Must include
- •Proof of service
Court's wording
Counsel must serve pro se parties with a paper copy of any document that is filed electronically or emailed and must separately file proof of service with the Court. No courtesy copies to the Court are necessary.
Letters seeking relief should be filed on ECF as letter‐motions, not as ordinary letters.
Where liability insurance is involved, a decision‐making representative of each carrier must attend unless specifically excused by the Court.
Where any government agency is a party, counsel of record must be accompanied by a knowledgeable representative from the agency.
Corporate parties or labor unions must send the person with decision‐making authority to settle the matter to the conference.
Settlement conference summary form and 3-page letter required 7 days before conference.
Court's wording
Unless otherwise directed by the Court, no later than 7 days before the Settlement Conference, each party must complete the Court’s Settlement Conference Summary Form found at https://nysd.uscourts.gov/hon‐ona‐t‐wang. Each party also must provide the Court with a letter, not to exceed three pages, summarizing: (1) the history of settlement discussions; (2) the issues in the case; (3) the settlement value of the case and rationale for it; (4) case law authority relevant to settlement discussions; and (5) any other facts that would be helpful to the Court in preparation for the conference.
In cases where the Comptroller of the City of New York has authority over settlement, the Assistant Corporation Counsel must make arrangements before the conference for a representative of the Comptroller either to attend the conference or to be available by telephone to approve any proposed settlement.
Parties must attend settlement conference in person; virtual attendance requires written request one week in advance.
Court's wording
The parties—not just the attorneys—must attend the Settlement Conference in person. In the event personal attendance is a hardship, a party may make a written request at least one week before the conference to attend virtually (or be excused from attendance).
Joint Pretrial Order must include caption, contact info, jurisdiction, claims/defenses, and damages calculations.
Court's wording
The proposed Joint Pretrial Order shall be signed by all parties and include the following: 1. The full caption of the action. 2. The names, addresses, telephone numbers (both office and mobile) and email addresses of each principal member of the trial team, and identification of each party’s lead trial counsel. 3. A brief statement by plaintiff (or, in a removed case, by defendant) as to the basis of subject matter jurisdiction, and a brief statement by each other party as to the presence or absence of subject matter jurisdiction, including citations to all statutes relied on and relevant facts, such as citizenship and jurisdictional amount. 4. A list and brief summary by each party of the claims and defenses that party has asserted that remain to be tried, and a list of any claims and defenses asserted in the pleadings that are not to be tried. Where applicable, the statements shall identify citations to all statutes relied on, but without recital of evidentiary matter. 5. With respect to each claim remaining to be tried, a brief statement listing each element or category of damages sought with respect to such claim (e.g., lost profits, back wages, medical costs, etc.) and a calculation of the amount of damages sought with respect to such element or category.
Joint Pretrial Order due within 30 days after discovery completion or summary judgment decision.
Court's wording
Unless otherwise ordered by the Court, the parties shall submit a Joint Pretrial Order within 30 days after the date for the completion of discovery, or, if a summary judgment motion has been filed, within 30 days after the decision on the motion.
Jury materials must be emailed as Word docs to chambers in addition to ECF filing.
Court's wording
In addition to filing on ECF the voir dire questions, requests to charge, and/or verdict sheets, electronic copies must also be submitted to the Court as Microsoft Word documents and sent via email to: Wang_NYSDChambers@nysd.uscourts.gov.
In addition to filing on ECF, these materials must also be submitted to the Court as Microsoft Word documents and sent via email to: Wang_NYSDChambers@nysd.uscourts.gov.
Pro se parties must file their own Pretrial Statement within 30 days of discovery completion or dispositive motion decision, containing facts, evidence list, and witness list.
- Document
- Pretrial statement
Must include
- •Statement of facts
Court's wording
In pro se cases, the parties are not required to prepare joint pretrial filings (but may do so jointly if feasible). Instead, within 30 days from the date for the completion of discovery in a civil case or, if a dispositive motion has been filed, within 30 days of a decision resolving the motion, the represented party(ies) shall submit the pretrial materials set forth in Section IV.b above. The pro se party shall file its own Pretrial Statement. The pro se party’s Pretrial Statement need take no particular form, but must be concise and contain: 1. a statement of the facts the party hopes to prove at trial; 2. a list of all documents or other physical objects that the party plans to put into evidence at trial; and 3. a list of the names and addresses of all witnesses the party intends to have testify at trial and the general subject matter of each witness’s expected testimony.
Memoranda of 2,500 words or more shall contain a table of contents and a table of authorities.
- Document
- Memorandum of law
Must include
- •Table of contents
- •Table of authorities
I understand my obligation to preserve – and am preserving – relevant information.
If a party fails to comply with the attendance requirements, that party may be required to reimburse all the other parties for their time and travel expenses and may face other sanctions.
The Court strongly prefers that the parties exchange at least one round of demand and offer before the first settlement conference call.
Each party must supply its own interpreter, if required.
Filing & Service rules
Courtesy Copy Requirements
The parties should not submit courtesy copies of any motion papers, except for cases regarding appeals of administrative agency determinations. Courtesy copies should be double‐sided and placed in well‐organized three‐ring binder(s). Where appropriate, the binder(s) shall be separated by tab dividers preceded by an exhibit list. Courtesy copies must be provided no later than two business days after the filing.
The parties should not submit courtesy copies of any motion papers, except for cases regarding appeals of administrative agency determinations. Courtesy copies should be double‐sided and placed in well‐organized three‐ring binder(s). Where appropriate, the binder(s) shall be separated by tab dividers preceded by an exhibit list. Courtesy copies must be provided no later than two business days after the filing.
Civil cases
A courtesy copy of Ex Parte Settlement Conference Summary Forms and Letters shall be submitted to the Court if the exhibits to the Letter exceed 10 pages. Courtesy copies must be provided no later than one business day after submission of the Form and Letter.
A courtesy copy of Ex Parte Settlement Conference Summary Forms and Letters shall be submitted to the Court if the exhibits to the Letter exceed 10 pages. Courtesy copies must be provided no later than one business day after submission of the Form and Letter.
Civil cases
Sealing & Redaction Procedures
Proposed sealed document must be filed under seal and related to motion
The proposed sealed document must be contemporaneously filed under seal in the ECF system and electronically related to the motion.
Civil cases
Sealed/redacted filings must be filed electronically through ECF system
Motions or Letter Motions for approval of sealed or redacted filings in civil and miscellaneous cases and the subject documents, including the proposed sealed document(s), must be filed electronically through the court’s ECF system in conformity with the court’s standing order, 19‐mc‐00583, and ECF Rules & Instructions, Section 6.
Civil cases
Redaction requests require public filing with redactions and sealed filing of unredacted version
Where the motion seeks approval to redact information from a document that is to be publicly filed, the filing party shall: (1) publicly file the document with the proposed redactions, and (2) electronically file under seal a copy of the unredacted document with the proposed redactions highlighted.
Civil cases
Paper filing requires motion for leave if unable to comply with electronic filing
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 to file in the traditional manner, on paper.
Civil cases
Motion to seal must be filed publicly and explain reasons without including confidential info
The 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.
Civil cases
Confidential materials may only be redacted/filed under seal with court direction
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.
Civil cases
If a request contains sensitive or confidential information, the requesting party should file (1) a redacted version of the letter on the public docket and (2) an accompanying motion to seal, in accordance with the procedures set forth below in § VI.
If a request contains sensitive or confidential information, the requesting party should file (1) a redacted version of the letter on the public docket and (2) an accompanying motion to seal, in accordance with the procedures set forth below in § VI.
Civil cases
Page 4 | Requests for Adjournments or Extensions of Time
Pre-Motion Conference Requirements
Pre-motion conference required for all motions except specific enumerated exceptions
A pre‐motion conference is required for all other motions except: (1) motions that are required by the Federal Rules of Appellate Procedure or the Federal Rules of Civil Procedure to be made by a certain time; (2) motions by litigants in actions where a party is incarcerated and pro se; (3) motions for reconsideration; (4) motions for a new trial; (5) motions in limine; (6) motions to dismiss habeas corpus petitions; and (7) motions for judgment on the pleadings and motions to dismiss under Fed. R. Civ. P. 12.
Civil cases
Page 6 | Pre-Motion Conferences
If a motion pursuant to Fed. R. Civ. P. 12(b) or 12(c) is contemplated, the parties shall meet and confer in advance so that the plaintiff or counterclaimant can consider whether they wish to amend the subject pleading before motion practice, and the parties must consider in good faith a stipulation permitting such amendment. If the parties are unable to reach a resolution, the parties shall submit a proposed briefing schedule to the Court. Counsel for the moving party shall include the following statement in the notice of motion: “This motion is made following the conference of counsel, which took place on [date]. Plaintiff [or Counterclaimant] declined an opportunity to amend.”
If a motion pursuant to Fed. R. Civ. P. 12(b) or 12(c) is contemplated, the parties shall meet and confer in advance so that the plaintiff or counterclaimant can consider whether they wish to amend the subject pleading before motion practice, and the parties must consider in good faith a stipulation permitting such amendment. If the parties are unable to reach a resolution, the parties shall submit a proposed briefing schedule to the Court. Counsel for the moving party shall include the following statement in the notice of motion: “This motion is made following the conference of counsel, which took place on [date]. Plaintiff [or Counterclaimant] declined an opportunity to amend.”
Civil cases
Page 6 | Motions
Motions in limine must be filed with proposed pretrial order; oppositions due within 2 weeks; no replies allowed.
Each party shall file and serve any motions in limine at the same time as the proposed pretrial order. Within two weeks of filing the proposed pretrial order, each party shall file and serve its opposition to any motion in limine. There shall be no replies for motions in limine.
Civil cases
Parties may request oral argument when the motion has been fully briefed. This request should be made by letter in accordance with the procedures set forth in Section II.
Parties may request oral argument when the motion has been fully briefed. This request should be made by letter in accordance with the procedures set forth in Section II.
Civil cases
If any counsel wishes for a conference to be conducted remotely (by telephone or video), they should confer with all other counsel and promptly file a letter‐motion to that effect. Even if a motion for a remote conference is on consent, the Court does not automatically grant such motions.
If any counsel wishes for a conference to be conducted remotely (by telephone or video), they should confer with all other counsel and promptly file a letter‐motion to that effect. Even if a motion for a remote conference is on consent, the Court does not automatically grant such motions.
Civil cases
Page 4 | In-Person Conferences
Adjournment & Extension Requirements
Adjournment/extension requests must be filed as letter motions with specific required elements and 48-hour advance notice
All requests for adjournments or extensions of time must be filed on ECF as letter motions. The letter‐motion must state: (1) the original date(s), with a citation to the ruling setting the original date; (2) the number of previous requests for adjournment or extension; (3) whether these previous requests were granted or denied; and (4) whether the adversary consents and, if not, the reasons given by the adversary for refusing to consent. If a conference must be rescheduled, counsel shall propose at least two alternative dates that fall in consecutive weeks. Absent good cause, any request for extension or adjournment shall be made at least 48 hours before the deadline or scheduled appearance.
Civil cases
Page 4 | Requests for Adjournments or Extensions of Time
Chambers Communication Rules
The Court has a file transfer protocol for the safe electronic transmission of large files. If a party needs to submit large files by email (as opposed to ECF), the party should email Chambers (at Wang_NYSDChambers@nysd.uscourts.gov) requesting a link to be used for such transfer. The email should include the name and docket number of the case and the nature and size of the materials to be submitted electronically.
The Court has a file transfer protocol for the safe electronic transmission of large files. If a party needs to submit large files by email (as opposed to ECF), the party should email Chambers (at Wang_NYSDChambers@nysd.uscourts.gov) requesting a link to be used for such transfer. The email should include the name and docket number of the case and the nature and size of the materials to be submitted electronically.
Civil cases
Page 2 | Guidelines for All Submissions
Letters which the Court has specifically directed be emailed directly to Chambers should be emailed as a .pdf attachment to Wang_NYSDChambers@nysd.uscourts.gov. E‐mails shall state in the subject line: (1) the caption of the case, including the lead party names and docket number, and (2) a brief description of the contents of the attachment. Confidential information should be clearly indicated as such in the letter.
Letters which the Court has specifically directed be emailed directly to Chambers should be emailed as a .pdf attachment to Wang_NYSDChambers@nysd.uscourts.gov. E‐mails shall state in the subject line: (1) the caption of the case, including the lead party names and docket number, and (2) a brief description of the contents of the attachment. Confidential information should be clearly indicated as such in the letter.
Civil cases
Page 2 | Communications with Chambers
Pro se parties must use Pro Se Intake Unit or ProSe@nysd.uscourts.gov; cannot contact Chambers directly.
By Standing Order, any pro se party who does not participate in Electronic Case Filing (“ECF”) must either (1) mail or hand deliver all communications with the Court to the Pro se Intake Unit located at 500 Pearl Street, Room 230, New York, NY 10007 or (2) email their correspondence in .pdf format to ProSe@nysd.uscourts.gov, including the docket number and case in the subject line of the cover email. Pro se parties may not call Chambers or send any document or filing directly to Chambers.
Civil cases
Page 2 | Communications with Chambers
Chambers prohibits fax submissions
Chambers does not accept submissions by fax.
Civil cases
Page 3 | Faxes
The Settlement Conference Summary Form and letter should be emailed to Wang_NYSDChambers@nysd.uscourts.gov.
The Settlement Conference Summary Form and letter should be emailed to Wang_NYSDChambers@nysd.uscourts.gov.
Civil cases
Page 9 | Ex Parte Settlement Conference Summary Form and Letter
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.
Civil cases
Page 3 | Hand Deliveries
Junior Lawyer Participation Incentives
Junior lawyers may participate in settlement conferences but must be supervised and prepared.
Junior members of legal teams are also invited to participate and speak in settlement conferences, but must be properly supervised and prepared. Sending a junior lawyer, alone, without sufficiently briefing the junior lawyer on the case and its history may be considered by the Court to be a failure to properly supervise the junior lawyer.
Civil cases
Page 9 | Attendance
Junior attorneys encouraged to argue motions they helped prepare
Junior members of legal teams 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. This court is amenable to permitting a number of lawyers to argue for one party if this creates an opportunity for a junior lawyer to participate.
Civil cases