Judge Philip M. Halpern

Except as otherwise set forth herein, telephone calls to chambers are permitted only in emergencies requiring immediate attention. The chambers phone number is (914) 390-4160. Emails or faxes to chambers are permitted only with prior authorization. Emailed or faxed submissions shall identify the authorizing individual in chambers. The chambers fax number is (914) 390-4193. In the event a party is directed to or must transmit an e-mail to Chambers, the e-mail address to be used is HalpernNYSDChambers@nysd.uscourts.gov. Copies of any communication with Chambers shall be simultaneously faxed, e-mailed, or hand-delivered to all counsel.

Emails or faxes to chambers are permitted only with prior authorization. Emailed or faxed submissions shall identify the authorizing individual in chambers. The chambers fax number is (914) 390-4193. In the event a party is directed to or must transmit an e-mail to Chambers, the e-mail address to be used is HalpernNYSDChambers@nysd.uscourts.gov.

to request a pre-motion conference, the movant shall file a letter to the Court, not exceeding 5 pages double-spaced, absent prior permission from the Court, setting forth the basis for the anticipated motion. Opposition letters, not exceeding 5 double-spaced pages, absent prior permission from the Court, shall be submitted within 5 business days after receipt of the movant’s letter. No reply letters will be permitted absent prior permission from the Court.

The plaintiff shall respond by similar letter, not exceeding 5 double-spaced pages, within 5 business days indicating the extent, if any, to which plaintiff concurs with defendant's objections and the amendments, if any, to be made to the complaint to address them, or the reasons and controlling authority that support the pleadings as filed.

The pre-motion letter shall be a joint letter from all counsel limited to five pages double-spaced outlining the discovery disputes sought to be addressed.

The Court encourages and appreciates brevity. Memoranda of law in support of and in opposition to motions shall comply with the formatting and length requirements set forth in Local Civil Rule 7.1. Unless prior permission has been granted, sur-reply memoranda will not be accepted. With respect to objections to Magistrate Judges' rulings, unless prior permission has been granted, memoranda of law (including responses) shall not exceed 15 pages.

A pretrial memorandum, no longer than 15 double-spaced pages, emphasizing the burden of proof associated with the claims for relief or defenses to be tried.

The Party or person producing or disclosing Discovery Material (“Producing Party”) may designate as Confidential only the portion of such material that it reasonably and in good faith believes consists of: (a) previously non-disclosed financial information (including without limitation profitability reports or estimates, percentage fees, design fees, royalty rates, minimum guarantee payments, sales reports, and sale margins); (b) previously non-disclosed material relating to ownership or control of any non-public company; (c) previously non-disclosed business plans, product-development information, or marketing plans; (d) any information of a personal or intimate nature regarding any individual; or (e) any other category of information this Court subsequently affords confidential status.

portions of deposition transcripts as Confidential Discovery Material either by: (a) indicating on the record during the deposition that a question calls for Confidential information, in which case the reporter will bind the transcript of the designated testimony in a separate volume and mark it as “Confidential Information Governed by Protective Order;” or (b) notifying the reporter and all counsel of record, in writing, within 30 days after a deposition has concluded, of the specific pages and lines of the transcript that are to be designated “Confidential,” in which case all counsel receiving the transcript will be responsible for marking the copies of the designated transcript in their possession or under their control as directed by the Producing Party or that person’s counsel. During the 30-day period following a deposition, all Parties will treat the entire deposition transcript as if it had been designated Confidential.