Southern District of New York Document Format Requirements

Required

Always

Margins

1 in

Format

PAPER

Faxes limited to 5 pages without special permission, only for urgent matters, adjournment requests, or technology requests.

Faxes may be sent only: for urgent matters requiring an immediate response from Chambers; to request an adjournment or extension of time as provided by Rule 1.D; or to make a technology request as provided by Rule 1.F. Faxes should be brief and may not exceed 5 pages without special permission from Chambers. Do not follow faxes with a hard copy.

Format

PDF

ECF required for civil/criminal cases filed after March 1, 2004; text-searchable format required.

ECF Cases. All civil and criminal cases (except pro se and special cases) filed on or after March 1, 2004 assigned to Judge Hellerstein are ECF cases. All counsel must register for ECF in each case pending before this Court. Counsel are responsible for checking their registered email and court docket sheet for memo-endorsements and orders. If counsel are not receiving such emails, please contact the ECF Help Desk at (212) 805-0800. All filings on ECF which can be made text-searchable shall be text-searchable.

Required

Always

Affidavits and exhibits must be tabbed on both original and courtesy copies.

All affidavits and exhibits shall be clearly identified by tabs on both original and courtesy copies.

Required

Always

All affidavits, exhibits, and motions must be bound.

All affidavits, exhibits, and motions shall be bound.

Required

Always

Exhibits must be marked sequentially without repeating numbers or letters.

Exhibits shall be marked sequentially such that no exhibit number or letter repeats, regardless of the affidavit to which it is attached.

Required

Always

Plaintiff exhibits marked with numbers, defendant exhibits with letters.

Exhibits for plaintiffs should be marked by numbers; exhibits for defendants should be marked by letters.

Required

Always

Courtesy copies must be submitted without plastic covers.

In any event, courtesy copies are to be submitted without plastic covers.

Format

DOCX

Pretrial submissions must be in hard copy and MS Word electronic format.

The submissions described in ii and iii above shall be in both hard copy and electronically in MS Word format (by email or CD-Rom).

Required

Always

Parties must bring loose-leaf exhibit binders to pretrial conference; defendants must not duplicate plaintiff exhibits.

plaintiffs and defendants shall bring to the conference loose-leaf exhibit binders of all exhibits they actually intend to offer at the trial. Defendants shall not duplicate exhibits identified by Plaintiffs.

Format

DOCX

Proposed jury charges/voir dire and proposed findings/conclusions must be submitted in hard copy and MS Word format.

The submissions described in ii and iii above shall be in both hard copy and electronically in MS Word format (by email or CD-Rom).

Margins

1 in

Motion papers must be single-sided, double-spaced, 12-point font or larger, with one-inch margins

Motion papers shall be single-sided, double-spaced, shall use 12-point font or larger (including footnotes), and shall have one-inch margins on all sides.

All text-containing documents must be text searchable

All pleadings, letters, motion papers, affidavits, or any other document containing text shall be text searchable.

Required

Always

Margins

1 in

Motion papers must be single-sided, double-spaced, 12-point font or larger, with one-inch margins; footnotes are discouraged.

Motion papers shall be single-sided, double-spaced, shall use 12-point font or larger (including footnotes), and shall have one-inch margins on all sides. Footnotes are discouraged.

Deposition transcripts must be submitted one-page-per-sheet with an index.

The parties shall submit the entire transcript of a witness' testimony in one-page-per-sheet format with an index.

Format

PDF

Joint pretrial order must be filed in both PDF and Microsoft Word format.

Unless otherwise ordered by the Court, within thirty days after the date for the completion of discovery, or within thirty days after the Court's decision on a dispositive motion, if any, the parties shall file with the Court, in both PDF format and as a Microsoft Word document

Exhibits must be pre-marked and assembled sequentially in a loose-leaf binder or labeled manila folders.

In all cases, one copy of each documentary exhibit sought to be admitted, pre-marked and assembled sequentially in a loose leaf binder or in separate manila folders labeled with the exhibit numbers and placed in a suitable container for ready reference.

ECF-filed courtesy copies submitted to Chambers must bear specific required markings.

Any courtesy copy submitted to Chambers that was originally filed on ECF must be clearly marked “Courtesy Copy,” “Original Filed by ECF,” and “Assigned Document Number [print or type assigned document number].”

Margins

1 in

Memoranda must use at least 12-point font and one-inch margins on all sides.

All memoranda of law should be in 12-point font or larger, with 1" margins on all sides.

ECF-filed courtesy copies must be marked with specific labels and document number.

Any courtesy copy submitted to Chambers that was originally filed on ECF must be clearly marked “Courtesy Copy,” “Original Filed by ECF,” and “Assigned Document Number [print or type assigned document number].”

Required

Always

Exhibits must be pre-marked with party and exhibit number (e.g., GX-1, PX-1, DX-1).

Exhibits must be pre-marked (that is, with exhibit stickers or the like) and should generally be labeled by party and exhibit number (e.g., “GX-1,” “PX-1,” “DX-1,” etc.) rather than letter (e.g., “DX-AA”).

Hard copy exhibits must be pre-marked and assembled in binders not exceeding 2.5 inches or in labeled manila folders within redweld folders.

Each hard copy shall be pre-marked (that is, with an exhibit sticker) and assembled sequentially in a loose-leaf binder (not to exceed 2-1/2 inches in thickness) or in separate manila folders labeled with the exhibit numbers and placed in redweld folders labeled with the case name and docket number

Format

PDF

Letter-motions must comply with S.D.N.Y. rules and be text-searchable

Letter-motions may be filed via ECF if they comply with the S.D.N.Y. Local Rules and the S.D.N.Y. Electronic Case Filing Rules and Instructions. In particular, in accordance with Paragraph 4(D) above, all requests for adjournments and extensions should be filed as letter-motions. All letter-motions should be text-searchable.

Hard copy exhibits should be pre-marked, assembled in binders (max 2.5 inches) or manila folders in redweld folders.

Where submitted in hard copy, exhibits and Section 3500 material should be pre-marked and assembled sequentially in a loose-leaf binder or binders (not to exceed 2-1/2 inches in thickness), or in separate manila folders labeled with the exhibit numbers and placed in redweld folders labeled with the case name and docket number.

Required

Always

Electronic devices prohibited in Judge Subramanian's courtroom

Electronic devices (including mobile telephones, personal electronic devices, computers, and printers) may not be used in Judge

Memoranda of law must be in 12-point font or larger, double spaced, and text-searchable.

All memoranda of law shall be in twelve-point font or larger, double spaced, and text-searchable.

Applies to

Amended filing

Amended filings and motions to amend pleadings must include a redline showing differences from the original document.

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.

Format

DOCX

Summary judgment moving parties must file Rule 56.1 Statement in Microsoft Word format; opposing parties must reproduce entries with responses directly below.

with an electronic copy, in Microsoft Word format, of the moving party’s Statement of Material Facts Pursuant to Local Civil Rule 56.1. 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.

Bankruptcy appeals must comply with FRBP 8014-8018 for briefing schedules, format, and length specifications.

The parties must comply with the briefing schedule and the format and length specifications set forth in the Federal Rules of Bankruptcy Procedure (8014–8018) unless otherwise ordered by the Court.

Parties may seek leave to submit hard copy exhibits if electronic copies are an undue burden; hard copies must be pre-marked and assembled in binders (max 2.5 inches) or labeled manila/redweld folders.

If submission of electronic copies would be an undue burden on a party, the party may seek leave of Court (by letter-motion filed on ECF) to submit prospective documentary exhibits in hard copy. Each hard copy shall be pre-marked (that is, with an exhibit sticker) and assembled sequentially in a loose-leaf binder (not to exceed 2-1/2 inches in thickness) or in separate manila folders labeled with the exhibit numbers and placed in redweld folders labeled with the case name and docket number;

Format

DOCX

Exhibit lists must be Microsoft Word documents emailed to the court.

a Microsoft Word document listing all exhibits sought to be admitted, emailed to the court.

Jury trials must attach joint requests to charge, verdict forms, and voir dire questions to the joint pretrial order, with differing proposals in track-change format supported by authority.

Unless otherwise ordered by the Court, in all jury trials, joint requests to charge, joint proposed verdict forms, and joint proposed voir dire questions shall be submitted as attachments to the proposed joint pretrial order, with any differing proposals displayed in track-change format and supported by authority or other justification.

Margins

1 in

Memoranda of 10+ pages require TOC/TOA; must be double-spaced, 12-pt font, 1-inch margins.

Memoranda of ten (10) pages or more shall contain a table of contents and table of authorities. All memoranda of law must be double-spaced and shall be in 12-point font or larger, with one-inch (1") margins on all sides. Footnotes may be single-spaced but must also be in 12-point font or larger.

Courtesy copies must be securely bound, flat, with preferred binding types; metal prong fasteners prohibited.

All courtesy copies submitted in connection with motions must be bound in any manner that is secure, does not obscure the text, and permits the document to lie reasonably flat when open. Parties should submit multiple volumes rather than large documents that do not lie reasonably flat when open. Preferred forms of binding are three-ring binders and spiral binding. Paper-and-plastic binding is acceptable as long as the pages will lay flat. Metal prong fasteners are not acceptable.

Courtesy copies must include ECF header unless not yet filed.

All courtesy copies must include the automatically generated ECF header (that is, the text – e.g., “Case 7:24-cv-1234-CS Document 100 Filed the ECF system), unless the papers have not yet been filed on the docket.

Margins

1 in

Exhibits must be separated by protruding tabs and double-sided when possible.

Exhibits should always be separated by protruding tabs. Sheets of paper inserted between exhibits (of any color) are not sufficient to divide the exhibits. To the extent possible, exhibits should be double-sided.

Required

Always

Exhibits must be tabbed and indexed; documents under 35 pages should be stapled; exhibits must be bound separately from briefs.

All exhibits must be tabbed and indexed. Documents under 35 pages should be stapled, not bound. Exhibits to legal memoranda must not be bound to the brief. Please bind them separately and submit them to the Court along with the brief.

Margins

1 in

Memoranda must use 12-point serif font, double-spaced, 1-inch margins, footnotes in 12-point if used.

Memoranda must utilize a 12-point serif font (e.g., Times New Roman) and must be double-spaced with margins of at least one inch all around. Footnotes should be avoided. If any footnotes are included, they must be in 12-point font.

Appendices over 5 pages must be bound separately, not affixed to brief.

If you are submitting an appendix to your brief of more than five pages, you must bind the appendix separately. Do not affix the appendix to your brief.

Required

Always

Exhibits must be pre-marked with PX/DX numbering, tabbed, and preferably bound.

All exhibits must be pre-marked, using the form PX-1 through PX-n and DX-1 through DX-n. If possible, exhibits should be bound or collated in a binder. Each exhibit should be tabbed. Exhibits containing multiple documents (e.g., multiple banks statements) are disfavored.

Required

Always

Format

PDF

Electronic documents must be produced as PDF/TIFF images if parties cannot agree on format, with original formatting and metadata preserved.

If the parties cannot agree to the format for document production, electronic documents shall be produced to the requesting party as image files (e.g., PDF or TIFF). When the image file is produced, the producing party must preserve the integrity of the electronic document’s contents, i.e., the original formatting of the document, its metadata and, where applicable, its revision history. After initial production in image file format is complete, a party must demonstrate particularized need for production of electronic documents in their native format.

Courtesy copies must be marked with case details, exhibits tabbed and indexed, and exhibits/appendices bound separately from memoranda.

Each courtesy copy must be clearly marked “Courtesy Copy” and must identify the case name, docket number, and ECF docket number or numbers corresponding to the submitted papers. All exhibits must be tabbed and indexed. Exhibits and appendices should be bound separately from the memorandum of law.

Exhibits must be tabbed, indexed, and bound separately from legal memoranda; documents under 35 pages must be stapled.

All exhibits must be tabbed and indexed. Documents under 35 pages should be stapled, not bound. Exhibits to legal memoranda must not be bound to the brief. Please bind them separately and submit them to the Court along with the brief.

Margins

1 in

Memoranda must use 12-point serif font, double spacing, 1-inch margins; footnotes must be 12-point and are discouraged.

Memoranda must utilize a 12-point serif font (e.g., Times New Roman) and must be double-spaced with margins of at least one inch all around. Footnotes should be avoided. If any footnotes are included, they must be in 12-point font.

Appendices to briefs over 5 pages must be bound separately and not affixed to the brief.

If you are submitting an appendix to your brief of more than five pages, you must bind the appendix separately. Do not affix the appendix to your brief.

Each deposition testimony entry submitted with summary judgment motions must be separately tabbed and indexed.

Each entry must be separately tabbed and indexed.

Joint pretrial orders must follow the outline attached as Annex A.

The pretrial order shall be prepared in accordance with the outline attached as Annex A.

Exhibits must be pre-marked as PX-1 to PX-n or DX-1 to DX-n, bound/collated if possible, individually tabbed, multi-document exhibits disfavored.

All exhibits must be pre-marked, using the form PX-1 through PX-n and DX-1 through DX-n. If possible, exhibits should be bound or collated in a binder. Each exhibit should be individually tabbed. Exhibits containing multiple documents (e.g., more than one bank statement) are disfavored.

Exhibits for civil evidentiary hearings must be pre-marked PX/DX-n, preferably bound in a binder with tabs, multi-document exhibits disfavored.

All exhibits must be pre-marked, using the form PX-1 through PX-n and DX-1 through DX-n. If possible, exhibits should be bound or collated in a binder. Each exhibit should be tabbed. Exhibits containing multiple documents (e.g., multiple banks statements) are disfavored.

Margins

1 in

Motion papers must comply with Local Civil Rule 11.1 formatting requirements.

Motion papers must conform to Local Civil Rule 11.1 of the S.D.N.Y. Local Rules.

Memoranda of law must be 12-point font or larger, double-spaced; footnotes may be single-spaced.

All memoranda of law shall be in twelve-point font or larger and double-spaced. All footnotes shall be in twelve-point font or larger and may be single-spaced.

Required

Always

All written submissions must be text-searchable.

Text Searchable Submissions. All written submissions and supporting materials must be text-searchable to the extent practicable.

Required

Always

Format

PDF

Pro se parties must email submissions in PDF format to Pro_Se_Filing@nysd.uscourts.gov

iii. emailing them as an attachment in PDF format to Pro_Se_Filing@nysd.uscourts.gov, in which case the pro se party should follow the instructions contained in Appendix C of the Court’s ECF Rules & Instructions, available at https://www.nysd.uscourts.gov/electronic-case-filing; or

Memoranda must be 12pt font, double-spaced, text-searchable, with TOC/TOA for 10+ pages

All memoranda of law shall be in twelve-point font or larger, double spaced, and text-searchable. Memoranda of ten pages or more shall contain a table of contents and a table of authorities, neither of which shall count against the page limit.

Required

Always

Margins

1 in

Exhibits must be pre-marked with stickers and labeled by party/exhibit number.

Exhibits must be pre-marked (that is, with exhibit stickers or the like) and should generally be labeled by party and exhibit number (e.g., “GX-1,” “PX-1,” “DX-1,” etc.) rather than letter (e.g., “DX-AA”).

Required

Always

Letters to Chambers must not exceed 2 pages.

Letters. Except as provided below, communications with Chambers should be by letter, which shall not exceed two pages in length.

Margins

1 in

Memoranda must be 12-point font or larger, double-spaced, with 1-inch margins.

All memoranda of law shall be in 12-point font or larger and be double-spaced, and shall have one inch margins on all sides.

Format

PAPER

Media files must be filed physically with Clerk (not ECF).

Because media files cannot currently be uploaded to ECF, a party submitting media files must also file them physically with the Clerk of Court.

Required

Always

Voluminous trial materials must be organized in tabbed binders with labeled spines.

Voluminous material should be organized in tabbed binders and the spines of the binders should be labeled to include the name of the case, the case number, and the nature of the materials included in the binder.

Required

Always

Format

PDF

All submissions must be text-searchable PDFs, not scanned documents.

A. Text-Searchable Submissions. 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.

Format

USB_DRIVE

Multi-media filings must be on USB drive and hand-delivered to 200 Worth Street.

Any audio, video, or other multi-media filings shall be submitted on a USB drive and hand-delivered to the 200 Worth Street entrance in accordance paragraph 2(C).

Format

DOCX

Proposed orders must be emailed to Chambers in both PDF and Word formats.

Counsel should also email an electronic copy of any proposed orders to Chambers, in both PDF and Word formats.

Memoranda of law must be 12-point font or larger, double spaced, and text-searchable.

All memoranda of law shall be in twelve-point font or larger, double spaced, and text-searchable.

Hard copy exhibits must be pre-marked, sequentially assembled in binders (max 2.5 inches) or manila folders in redweld folders.

Where submitted in hard copy, exhibits and Section 3500 material should be pre-marked and assembled sequentially in a loose-leaf binder or binders (not to exceed 2 1/2 inches in thickness), or in separate manila folders labeled with the exhibit numbers and placed in redweld folders labeled with the case name and docket number.

Required

Always

Mobile phones must be turned off in courtroom; non-compliance results in device forfeiture.

Attorneys in compliance with the Standing Order may bring mobile phones into the Courtroom, but the phones MUST be kept turned off at all times. Non-compliance with this rule will result in forfeiture of the device for the remainder of the proceedings.

Margins

1 in

Exhibit list must have 6 specific columns with defined labels.

The list shall contain six columns labeled as follows: (1) "Exhibit Number"; (2) "Description" (of the exhibit); (3) "Authenticity Objection"; (4) "Admissibility Objection"; (5) "Date Identified"; and (6) "Date Admitted."

Margins

1 in

First 4 columns of exhibit list must be completed by parties; last 2 left blank for Court.

The parties shall complete the first four columns, but leave the fifth and sixth columns blank, to be filled in by the Court during trial.

Margins

1 in

Exhibits must be pre-marked with stickers and labeled by party and number, not letters.

Exhibits must be pre-marked (that is, with exhibit stickers or the like) and should generally be labeled by party and exhibit number (e.g., "GX-1," "PX-1," "DX-1," etc.) rather than letter (e.g., "DX-AA").

Margins

0 in

Format

DOCX

Represented parties must email proposed voir dire, jury charge, and verdict form in Word format with Pretrial Statement.

At the time of filing, a represented party should e-mail these documents to the Court, in Microsoft Word format.

Memoranda must use 12-point Times New Roman font on 8½ x 11 paper.

Both the text and footnotes in such memoranda of law must be in 12 point type on 8½ by 11 inch paper (or the electronic equivalent), with Times New Roman type preferred.

Format

PDF

ECF documents must be word-searchable to the extent reasonably practicable.

All documents filed on ECF must be word-searchable to the extent reasonably practicable.

Required

Always

Paper submissions must be stapled, binder-clipped, spiral/wire-bound, or three-hole punched in binders.

All paper submissions shall be stapled, binder-clipped, spiral- or wire-bound, or three-hole punched and placed in binders.

Required

Always

Electronic devices must be kept silent in courtroom if permitted

If electronic devices are permitted inside the Courtroom, they MUST be kept silent at all times.

Required

Always

Format

PDF

All submissions must be text-searchable PDFs, not scanned documents.

A. Text Searchable Submissions. Judge Furman reads most submissions in electronic form using an iPad or computer. Accordingly, 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.

Format

PDF

Letter-motions must be text searchable.

All letter-motions should be text searchable.

Format

PDF

Memoranda of law must be 12-point font, double spaced, and text searchable.

All memoranda of law shall be in twelve-point font or larger, double spaced, and text-searchable.

Required

Always

Electronic devices require permission in Judge Furman's Courtroom

A. Use of Electronic Devices. Electronic devices (including mobile telephones, personal electronic devices, and computers) may not be used in Judge Furman's Courtroom without his permission.

Required

Always

Mobile phones must be turned off in courtroom even if permitted

If permitted by the Standing Order, mobile telephones are permitted inside the Courtroom, but they MUST be kept turned off at all times.

Required

Always

All written submissions must be text-searchable to the extent practicable.

b. Text Searchable Submissions. All written submissions and supporting materials must be text-searchable to the extent practicable.

Required

Always

Format

PDF

All documents must be filed electronically via ECF unless otherwise provided.

a. Electronic Case Filing ("ECF"). In accordance with the S.D.N.Y. Electronic Case Filing Rules and Instructions, except for as otherwise expressly provided, all documents filed with the Court must be filed electronically.

Format

PDF

Deposition transcripts for summary judgment must be text-searchable with index.

Deposition transcripts that are supplied in connection with a summary judgment motion, whether in whole or in part, should be text-searchable and include an index.

Required

Always

Margins

1 in

Format

PDF

Letters must be filed electronically on ECF (unless sealed or confidential), no courtesy copies, max 3 pages.

Letters should be filed electronically on ECF, unless there is a request to file a letter under seal or a letter contains sensitive or confidential information. For instructions on how to file electronically under seal, see Section 6 below. Courtesy copies are no longer accepted. Whether filed electronically or not, letters may not exceed 3 pages in length.

Required

Always

Format

PDF

Letters must be filed electronically on ECF unless sealed or confidential.

Letters should be filed electronically on ECF, unless there is a request to file a letter under seal or a letter contains sensitive or confidential information.

Motion papers must conform to Local Civil Rule 7.1(b) for typeface, margins, and spacing.

The typeface, margins, and spacing of motion papers must conform to Local Civil Rule 7.1(b).

Required

Always

Related cases require both docket numbers in all future filings.

After an action has been accepted as related to a prior case, 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 (e.g., 21-cv-1234 [rel. 20-cv-4321]).

Required

Always

Consolidated cases require filing only in consolidated docket with single docket number.

After two or more actions have been consolidated for all purposes under a single docket number pursuant to Rule 42(a)(2) of the Federal Rules of Civil Procedure, all future court papers and correspondence should be filed only in the docket under which the cases have been consolidated and should reference only that docket number.

Required

Always

Mobile phones must be turned off in courtroom; non-compliance results in forfeiture.

Attorneys in compliance with the Standing Order may bring mobile phones into the courtroom, but the phones must be turned off at all times. Non-compliance with this rule will result in forfeiture of the device for the remainder of the proceedings.

Format

ECF

Letter-motions must be filed via ECF and comply with S.D.N.Y. rules.

Letter-motions must be filed via ECF and must comply with the S.D.N.Y. Local Rules and the S.D.N.Y. ECF Rules and Instructions.

Margins

1 in

Motion papers must conform to Local Civil Rule 7.1 with specific formatting and word limits.

The typeface, margins, spacing, and length of motion papers must conform to Local Civil Rule 7.1 (or, in the case of motions for reconsideration, Local Civil Rule 6.3 and Rule 4(C) below). All text must be 12-point type or larger, except for text in footnotes which may be 10-point type; (2) all documents must have at least one-inch margins on all sides; (3) all text must be double-spaced, except for headings, text in footnotes, or block quotations, which may be single-spaced; (4) all memoranda of law are limited to 8,750 words, and reply briefs are limited to 3,500 words (if filed by a party who is not represented by an attorney and handwritten or prepared with a typewriter, briefs in support of and in response to a motion may not exceed 25 pages, and reply briefs may not exceed 10 pages).

Required

Always

Format

PDF

All documents must be filed on ECF or emailed to specific chambers address

All documents must be filed on ECF or, if permitted or required under these Individual Rules and Practices, emailed to KarasNYSDChambers@nysd.uscourts.gov.

Format

PDF

Exhibits must be filed on ECF or provided on portable media if not ECF-compatible

All exhibits in support of motions should be filed on ECF. Exhibits that cannot be submitted on ECF (e.g., media files) should be provided to the Court on portable electronic storage media (e.g., flash drive, portable hard drive, CD-ROM, DVD-ROM).

Margins

1 in

Memoranda must use 12-point font, double-spacing, and one-inch margins.

All memoranda of law shall be produced in a 12-point font, be double-spaced, and have one-inch margins on all sides.

Required

Always

Format

DOCX

No paper submissions allowed; all documents must be filed on ECF or emailed to chambers.

No papers, including courtesy hard copies of any filing or document, may be submitted to Chambers. All documents must be filed on ECF or, if permitted or required under the Court’s Individual Rules and Practices, emailed to woodnysdchambers@nysd.uscourts.gov.

Format

PDF

TRO applications must be emailed with URGENT subject line, contact info, and availability for conference.

Parties intending to file applications for TROs or other emergency relief must send all of their papers (in text-searchable PDF format) to the Court by email. The email should (1) include the word “URGENT” in the subject line; (2) provide a telephone number at which the party (and any other relevant parties) can be reached; and (3) provide the relevant parties’ availability for a telephone conference in the next few days. As noted above, parties should not hand-deliver any documents without advance permission.

Letter-motions must be text-searchable, max 5 pages, no courtesy copy to Chambers.

Letter-motions may be filed via ECF if they comply with the S.D.N.Y. Local Rules and the S.D.N.Y. Electronic Case Filing Rules and Instructions. In particular, in accordance with Paragraph 2(C) above, all requests for adjournments and extensions should be filed as letter-motions. All letter-motions should be text-searchable and may not exceed five (5) pages in length. A courtesy copy should not be provided to Chambers.

Required

Always

Format

ECF

No paper submissions to chambers unless specifically ordered or permitted.

No papers, including courtesy hard copies of any filing or document, may be submitted to Chambers unless specifically ordered by the Court or otherwise permitted by these Individual Practices.

Required

Always

Format

ECF

Letters to chambers must be ECF-filed, text-searchable, max 3 single-spaced pages.

All letters shall be filed on ECF in text-searchable form and should not exceed three single-spaced pages in length.

Required

Always

Format

PDF

All ECF filings must be in text-searchable format.

All documents (e.g., motions, briefs, and letters) filed by parties on ECF must be in text-searchable format.

Required

Always

Motions are to be filed without a return date.

Motions are to be filed without a return date.

Required

Always

Electronic devices prohibited in courtroom, robing room, and chambers.

Electronic devices – including cellular telephones, iPads, and laptops – are not permitted in Judge Kaplan’s courtroom, robing room or chambers.

Letters must be in at least 14-point type.

Letters shall be in at least 14-point type, both text and footnotes.

Memoranda must be in at least 12-point type.

Memoranda shall be in at least 12-point type, both text and footnotes.

Required

Always

Format

PDF

No paper submissions are accepted

2. No Paper Submissions .........................................................................................4

Required

Always

Hand-delivery of documents is prohibited.

As noted above, parties should not hand-deliver any documents.

Non-moving party must provide movant with unbound, double-sided, three-hole punched opposition/cross-motion papers.

The non-moving party shall provide the movant with an unbound set of its opposition and any cross-motion papers, double sided and three-hole punched.

All motion papers must be double-sided, three-hole punched, tabbed, and placed in binders in filing order.

All motion papers shall be doubled-sided, three-hole punched, tabbed and placed in binders in the order that they were filed.

Format

EXCEL

Cases with >15 exhibits require Excel index with hyperlinks.

For cases with more than 15 exhibits, the index shall be on an Excel spreadsheet in native format, with hyperlinks to the exhibits if possible.

Deposition designations must use different colors for each party.

The designations or counter-designations shall be made by highlighting in different colors for each party the relevant parts of the transcript.

Format

PDF

Deposition testimony must be submitted as flattened PDF, may use condensed format.

Such deposition testimony shall be submitted as a flattened PDF and may be submitted on the condensed (four pages to a page) version of the transcript.

Required

Always

Margins

1 in

Trial schedule: 5 hours daily from 10:00 AM with breaks, adjourning at 4:45 PM or later if needed.

Trial dates and times. Unless otherwise decided by the Court, the Court will hear five hours of testimony each day beginning at 10:00 A.M. with a one-hour lunch break and two fifteen-minute breaks. The trial generally will adjourn at approximately 4:45 P.M., but will go later if necessary. In all events, the jury will be seated promptly at 10:00 A.M.

Required

Always

Margins

1 in

Exhibits must be pre-marked; court time not used for marking exhibits.

Court time may not be used for marking exhibits. Exhibits shall be pre-marked, and if possible, will be pre-admitted in advance of the court session.

Required

Always

Interpreters must interpret simultaneously in civil cases; parties pay.

(g) Interpreters. All interpreters shall interpret simultaneously rather than consecutively, unless prior permission is granted. In civil cases, the parties are responsible for retaining and paying for interpreters.

Required

Always

Jury instructions must use plain language understandable to non-lawyers.

(a) General Matters. All instructions to the jury will be in plain language that is as understandable as possible to non-lawyers.

Required

Always

All written submissions and supporting materials must be text-searchable

All written submissions and supporting materials must be text-searchable to the extent practicable.

Required

Always

Margins

1 in

Format

PDF

All submissions must be filed on ECF and text-searchable

General Guidelines for All Submissions. ........................................................................ 3

Margins

1 in

Format

PDF

Letters must be filed on ECF as letter-motions, max 3 pages single-spaced without permission.

Letters must be filed electronically on ECF. Letters seeking relief should be filed on ECF as letter-motions, not as ordinary letters. Letters may not exceed three pages in length (single-spaced, with standard font and margins) without prior permission from Chambers.

Binder covers must clearly identify the case name and documents included.

Binders should include cover and spine sheets that clearly identify the full case name and the documents included within (e.g., “Plaintiff’s Opposition to Defendants’ Motion to Dismiss”);

Required

Always

Mobile phones must be silent in courtroom; no use at counsel tables without permission.

If permitted by the Standing Order, mobile telephones are permitted inside the Courtroom, but they must be kept silent (i.e., no notification sounds or vibrations) at all times. Absent permission from the Court, counsel may not use their phones at counsel tables during proceedings. Non-compliance with this rule may result in forfeiture of the device for the remainder of the proceedings.

Required

Always

Recording, transmitting, photographing, or video recording court proceedings is prohibited.

Devices may not be used to record or transmit any Court proceeding, and photographs or video recordings are not permitted.

Required

Always

Speaking counsel must have video on and be unmuted when speaking; non-speaking counsel must have video off and remain muted.

Counsel who will be speaking should have their video cameras on throughout the proceeding but should remain muted unless actively speaking. Counsel in attendance who will not be speaking must have their videos off and be muted for the duration of the conference.

Required

Always

Audio-only participants must use landline, headset, mute when not speaking, identify themselves, spell names, and avoid interruptions.

If counsel joins the Remote Conference by audio-only, counsel should dial-in using a landline whenever possible, should use a headset or handset instead of speakerphone, and must mute themselves whenever they are not speaking to eliminate background noise. To facilitate the creation of an accurate transcript if the conference is held on the record, counsel who are joining the conference audio-only are required to identify themselves every time they speak. Counsel should spell any proper names for the court reporter. Counsel should also take special care not to interrupt or speak over one another.

Required

Always

Broadcasting or recording court conferences is prohibited by law.

The broadcasting or recording of any court conference is prohibited by law.

Required

Always

Margins

1 in

Memoranda: 1-inch margins, double-spaced, 12-pt font, TOC/TOA for 10+ pages.

All memoranda of law shall be formatted with one-inch margins and double-spaced. All text must be in 12-point font or larger. Memoranda of 10 pages or more shall contain a table of contents and table of authorities.

Required

Always

Briefs: single-sided, stapled upper-left; exhibits in three-ring binder.

Briefs should be printed single-sided and stapled in the upper-left corner. If there are any exhibits or supplemental materials filed with that brief, the brief shall be placed in the front left pocket of a three-ring binder containing those materials, as described below;

Motion papers in three-ring binders must be double-sided, three-hole-punched, and separated by tabs.

In the three-ring binder, any affidavits, declarations, exhibits, or other motion papers filed with that brief should be printed double-sided, three-hole-punched, placed in the binder, and separated by binder tabs;

Binder tabs must identify documents by title or be numbered with a table of contents.

Binder tabs should either (a) identify the tabbed document by title (e.g., “Affidavit of Jane Doe”), or (b) be numbered, as long as a corresponding table of contents is included as the front page of the binder;

Required

Always

VeloBind and binder clips are prohibited for courtesy copies.

Do not VeloBind or binder clip any courtesy copies submitted to the Court.

Format

DOCX

Moving party must provide electronic copy of 56.1 statement in Microsoft Word format.

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 Rule 56.1 as to

Required

Always

Format

PDF

Pro se parties can file papers via mail, email (PDF), or ECF (if granted)

A pro se party may file papers with the Court by: (a) mailing or delivering them in person to the Pro Se Office (address listed above); (b) emailing them as an attachment in PDF format to Temporary_Pro_Se_Filing@nysd.uscourts.gov, in which case the pro se party should follow the instructions contained in the April 1, 2020 Addendum to the Court’s ECF Rules & Instructions; or (c) filing them on the electronic case filing system (“ECF”), if the pro se party has filed a motion to participate in ECF that has been granted by the Court.

Margins

1 in

Memoranda of law must have one-inch margins, double-spacing, 12-point font or larger, and be text-searchable.

All memoranda of law shall be formatted with one-inch margins and double-spaced. All memoranda of law shall be in twelve-point font or larger, double spaced, and text-searchable.

Required

Always

Letters to the court must not exceed 3 pages in length.

Letters. Except as otherwise provided below, communications with the Court should be by letter not to exceed three pages in length.

Memoranda of law must be 12-point font or larger, double-spaced, and text-searchable.

All memoranda of law shall be in 12-point font or larger, double-spaced, and text-searchable.

56.1 statements must be organized into numbered paragraphs with single factual assertions and citations.

The 56.1 Statement must be organized into numbered paragraphs and each numbered paragraph must contain only one factual assertion. Each factual assertion must be followed by a citation to the portion(s) of the evidentiary record relied upon.

Opposing parties must reproduce and respond to each entry in moving party's 56.1 statement (except pro se cases).

Except in pro se cases, opposing parties must reproduce each entry in the moving party's 56.1 Statement, and set out the opposing party's response directly beneath it. 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.

Opposing party may add additional numbered paragraphs; moving party must respond to additional assertions.

The response may go on to make additional factual allegations in paragraphs numbered consecutively to those of the moving party (i.e., they do not begin re-numbering at 1). If additional factual allegations are made by the opposing party, the moving party must file its own responsive 56.1 Statement addressing the additional assertions.

Multiple parties must coordinate 56.1 statements to avoid overlapping numbered paragraphs.

If multiple parties are submitting 56.1 Statements, they must coordinate their statements to provide for consecutive, non-overlapping, numbered paragraphs in their respective statements.

Required

Always

Format

PDF

No paper submissions to chambers; all documents must be filed electronically in PDF format.

No papers, including courtesy hard copies of any filing or document, may be submitted to Chambers. All documents must be filed in text-searchable PDF Format on ECF or, if permitted or required under the Court’s Individual Rules and Practices, emailed to RomanNYSDChambers@nysd.uscourts.gov.

Memoranda must be 12-point font, double-spaced, with TOC and TOA for documents over 10 pages.

All memoranda of law shall be in 12-point font or larger and be double-spaced. Memoranda of 10 pages or more shall contain a table of contents and a table of authorities, neither of which shall count against the page limit.

All dates in the Civil Case Management Plan must be typed, not handwritten.

ALL DATES MUST BE TYPED NOT HANDWRITTEN.

Required

Always

Format

PDF

No paper submissions allowed; all documents must be filed on ECF or emailed.

No papers, including courtesy hard copies of any filing or document, may be submitted to Chambers. All documents must be filed on ECF or, if permitted or required under the Court’s Individual Rules and Practices, emailed to EngelmayerNYSDChambers@nysd.uscourts.gov.

Required

Always

Format

PDF

TRO applications must be emailed in text-searchable PDF with URGENT subject and phone number.

Parties intending to file applications for TROs or other emergency relief must send all of their papers (in text-searchable PDF format) to the Court by email. The email should (1) include the word “URGENT” in the subject line; (2) provide a telephone number at

Memoranda must be 12-point font, double-spaced, with TOC/TOA for 10+ pages.

All memoranda of law shall be in 12-point font or larger and be double-spaced. Memoranda of 10 pages or more shall contain a table of contents and a table of authorities, neither of which shall count against the page limit.

Format

PDF

Letter-motions must be filed via ECF if they comply with S.D.N.Y. Local Rules.

Letter-motions must be filed via ECF if they comply with the S.D.N.Y. Local Rules and the S.D.N.Y. 'Electronic Case Filing Rules and Instructions.'

Applies to

Rule 56 1 statement

Format

DOCX

Rule 56.1 Statements for summary judgment must be provided to other parties in Microsoft Word format.

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 Rule 56.1.

Applies to

Brief

All memoranda of law must use 12-point or larger font and be double-spaced.

All memoranda of law shall be in 12-point font or larger and be double-spaced.

Applies to

Appendices

Appendices to memoranda of law must be tabbed and indexed.

All appendices to memoranda of law must be tabbed and indexed.

Applies to

Amended filing

Amended or corrected filings must include a redline showing differences from original.

Any amended or corrected filing shall be filed with a redline showing all differences between the original and revised filing.

Required

Always

Margins

1 in

Exhibits must be pre-marked with numbers for plaintiff/government and letters for defendants.

All exhibits should be pre-marked, and no trial time will be taken for this purpose. Plaintiff/Government shall mark exhibits as numbers and defendants shall use letters.

Required

Always

Exhibits must be cited by number or letter for clear record.

When referring to an exhibit, cite it by number or letter so that the record is clear as to what is being discussed.

Memoranda over 10 pages require TOC and TOA; 12-point font required.

Memoranda of 10 pages or more shall contain a table of contents and a table of authorities. Both the text and footnotes must be in 12-point font.

Margins

1 in

Memoranda must use double spacing, one-inch margins, 12-point font for text and footnotes (footnotes may be single-spaced).

Use double spacing, one-inch margins, and 12-point font for text and footnotes (footnotes may be single-spaced).

Required

Always

Format

ECF

Letters must be filed on ECF unless sealed or contain sensitive information.

Letters must be filed electronically on ECF unless there is a request to file a letter under seal or a letter contains sensitive or confidential information

Required

Always

Flash/thumb drives prohibited for submissions.

Parties may not submit materials on flash or thumb drives.

Margins

1 in

Memoranda must use 1-inch margins, double-spacing, Times New Roman 12pt, footnotes min 10pt

All memoranda must be formatted with one-inch margins and double-spaced and all text must be in Times New Roman, 12-point font. Footnotes may be in smaller font, but in no case smaller than 10-point font.

Exhibit list must be in large font with specific four-column format.

The exhibit list must be in large font and consist of a chart with four columns labeled: 'Exhibit Number,' 'Document Description,' 'Identified,' and 'Admitted' (with the last two columns left blank).

Format

EXCEL

Exhibit list must be emailed in PDF and Word/Excel formats.

The exhibit list must be emailed to the Court in both PDF and Microsoft Word or Microsoft Excel formats.

Margins

1 in

Memoranda must be double-spaced, 12-point font, with 1-inch margins.

Memoranda should be double-spaced and in 12-point font with 1-inch margins.

Format

DOCX

Pretrial submissions must be in hardcopy and electronic copy (Word format).

Unless otherwise ordered by the Court, all pretrial submissions shall be submitted in hardcopy and in electronic copy, formatted in Microsoft Word or a compatible word processing program (either on a CD-Rom accompanying the hardcopy or via email to ChambersNYSDMarrero@nysd.uscourts.gov).

Margins

1 in

Plaintiffs must pre-mark exhibits with “P. Ex. ___” numerals; defendants with “D. Ex. ___” letters.

In trial binders and on each document offered in evidence, plaintiffs are to pre-mark their exhibits using numerals preceded by “P. Ex. ___”; Defendants are to use letters preceded by “D. Ex.

Courtesy copies of motion papers must be securely bound (spiral or single upper left staple, not velobound), and large non-flat documents should be submitted as multiple volumes.

All courtesy hard copies of papers submitted in connection with motions must be bound in any manner that is secure, does not obscure the text, and permits the document to lie reasonably flat when open. Courtesy copies should be spiral-bound or be stapled using a single staple in the upper left-hand corner of the document. Courtesy copies should NOT be velobound. Also, rather than submitting large documents that do not lie reasonably flat when open, parties should submit multiple volumes.

Motions for reconsideration must comply with the formatting and length requirements of Local Civil Rule 6.3.

Motions for reconsideration shall comply with the formatting and length requirements set forth in Local Civil Rule 6.3.

Motion courtesy copies must be spiral-bound or single-stapled, not velobound.

All courtesy hard copies of papers submitted in connection with motions must be bound in any manner that is secure, does not obscure the text, and permits the document to lie reasonably flat when open. Courtesy copies should either be spiral-bound or be stapled using a single staple in the upper left-hand corner of the document. Courtesy copies should NOT be velobound.

Parties must strictly adhere to typeface, margin, and spacing requirements.

The Court expects parties to adhere strictly to the typeface, margin and spacing requirements of Local Civ. R. 7.1(b).

Trial exhibits must be provided in tabbed binders to all parties and the Court three court days before the final pretrial conference.

Three court days before the date set for the final pretrial conference, each party must provide each other party, and the Court, with a tabbed binder or binders containing copies of its trial exhibits and deposition designations.

Required

Always

Format

PDF

Letters filed on ECF must be in searchable PDF format.

All letters filed on ECF must be in searchable PDF form.

Format

PDF

All motions must be filed as searchable PDF

All motions and moving papers filed on ECF or emailed to chambers shall be in searchable PDF form.

Format

PDF

All motion papers must be in searchable PDF format.

All motion papers, letter-motions, and letters filed on ECF or emailed to Chambers must be in searchable PDF form.

Memoranda must be in 12-point font or larger and double-spaced.

All memoranda of law shall be in 12-point font or larger and be double-spaced.

Format

PDF

All motion papers must be in searchable PDF format.

All motion papers, letter-motions, and letters filed on ECF or emailed to Chambers must be in searchable PDF form.

PDFs must be created from word-processing files, not scanned documents.

PDF images may not be created by scanning paper documents.

Format

COMMON_MEDIA_FORMAT

Media files must be in common formats or include non-admin software.

A party submitting media files in connection with a motion must, to the extent possible, provide them in a format capable of being played using commonly available media players, e.g., Windows Media Player. If the media unavoidably requires special viewing software, that software must be provided to the Court in a form that does not require administrative privileges for installation or operation.

Format

PDF

Bankruptcy appeals briefs must follow Federal Rules of Bankruptcy Procedure.

briefs must be submitted in accordance with the Federal Rules of Bankruptcy Procedure.

Required

Always

56.1 statements must be numbered paragraphs with one factual assertion each.

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

Format

DOCX

Joint proposed verdict form must be emailed to Chambers in Word and PDF format.

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.

Format

DOCX

Joint proposed jury instructions must be emailed to Chambers in Word and PDF format with citations.

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.

Format

PDF

Letters to Court must be filed on ECF (except settlement/in camera), max 3 single-spaced pages, no copying Court on counsel correspondence

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.

Courtesy copies must be in three-ring binders with tab dividers and exhibit list.

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.

Video submissions must be on labeled thumb drive or emailed.

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.

Required

Always

All document text must be 12-point type or larger, with footnotes permitted to be 10-point type.

all text must be 12-point type or larger, except for text in footnotes which may be 10-point type;

Required

Always

Margins

1 in

All documents must have margins of at least one inch on all sides.

all documents must have at least one-inch margins on all sides;

Required

Always

All document text must be double-spaced, except headings, footnotes, and block quotations which may be single-spaced.

all text must be double-spaced, except for headings, text in footnotes, or block quotations, which may be single-spaced.

Redline copies of proposed amended or supplemental pleadings must show all differences from the prior pleading using redlining, underlining, strikeouts, or similar typographic methods.

a version of the new or proposed pleading that shows—through redlining, underlining, strikeouts, or other similar typographic method—all differences from the pleading that it is intended to amend or supplement.

Margins

1 in

Motion papers must use 12-point font (10-point footnotes), 1-inch margins, double-spacing (except headings/footnotes/quotes).

The typeface, margins, and spacing of all motion papers presented for filing must meet the following requirements: (1) all text must be 12-point type or larger, except for text in footnotes which may be 10-point type; (2) all documents must have at least one-inch margins on all sides; and (3) all text must be double-spaced, except for headings, text in footnotes, or block quotations, which may be single-spaced.

Required

Always

Margins

1 in

Format

PDF

Letters to court limited to 3 single-space pages (excluding exhibits).

Letters. Communications with the Court should be by letter filed on ECF except for settlement conference submissions and in camera submissions. Letters may not exceed 3 single-space pages in length (exclusive of exhibits).

Margins

1 in

Format

PDF

Letter motions limited to 3 single-space pages (excluding exhibits).

Letter motions shall be filed on ECF in accordance with the S.D.N.Y. Local Rules and the S.D.N.Y. Electronic Case Filing Rules and Instructions. Requests that may be made by letter motion include requests for a discovery conference to address a discovery dispute before formal motion practice, adjournments, extensions, pre-motion conferences, sealing, and requests for a settlement conference. Letter motions are limited to 3 single-space pages (not including exhibits).

Required

Always

Format

PAPER

Faxes require prior permission and are limited to 3 pages.

Faxes. No faxed communications shall be permitted without prior permission from Judge Parker's Chambers. Faxes must not exceed three pages.

Format

PDF

All moving papers, letter-motions, and letters must be searchable PDF.

All moving papers, letter-motions, and letters filed on ECF or emailed to chambers must be in searchable PDF form.

Hard copy of pre-marked exhibits must be submitted in three-ring binder with tab dividers.

The parties shall also each submit one hard copy of the pre-marked exhibits in a well-organized three-ring binder separated by tab dividers.

Required

Always

Courtesy copies must be in well-organized three-ring binders with tab dividers.

Courtesy copies should be placed in well-organized three-ring binder(s). Where appropriate, the binder(s) shall be separated by tab dividers preceded by an

Format

THUMB_DRIVE_OR_EMAIL

Video submissions must be on thumb drive or emailed to Chambers.

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 the Chambers email address noted above.

Required

Always

Format

PDF

Submissions should be text-searchable PDFs created electronically, not scanned documents.

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.

Required

Always

Electronic devices (cellphones, laptops, tablets) are not permitted during court proceedings and must be stored with court security.

Pursuant to Standing Order M10-468, electronic devices such as cellphones, laptops, and tablets are not permitted during proceedings before this Court. Electronic devices are typically stored with court security before attorneys may proceed into the courthouse.

Required

Always

Format

PDF

All motions and moving papers must be in searchable PDF format.

All motions and moving papers filed on ECF or emailed to chambers shall be in searchable PDF form.

Motion papers must comply with SDNY Local Civil Rule 7.1 for typeface, text size, margins, line-spacing, and word-count limits, and must include the required word-count certification.

The typeface, text size, margins, and line-spacing of motion papers must conform to S.D.N.Y. Local Civil Rule 7.1. As to length, parties must also adhere to the word-count limits of Local Civil Rule 7.1 and include the required certification.

Format

PDF

Moving papers, letter-motions, and letters must be in searchable PDF format.

All moving papers, letter-motions, and letters filed on ECF or emailed to chambers must be in searchable PDF form.

Format

PDF

Attachments to pro se email submissions to the Court must be in PDF format.

If emailing, the pro se party must include the docket number of the case in the re: line, and any attachment must be in PDF format.

Format

PDF

Moving papers, letter-motions, and letters filed on ECF or emailed to chambers must be searchable PDF.

All moving papers, letter-motions, and letters filed on ECF or emailed to chambers must be in searchable PDF form.

Required

Always

Format

PAPER

Audio/visual evidence must be submitted on password-free USB, not on ECF.

Audio/visual material cannot be filed on ECF. If a party wishes to submit audio or visual evidence for the Court’s consideration, the evidence should be submitted on a USB with no security measures (i.e., password protections).

Required

Always

Format

PDF

Sensitive/confidential letters must be emailed as PDF (not PDF/A) to chambers.

Ex parte settlement letters, proposed case management plans, or letters otherwise containing sensitive or confidential information should be emailed to Chambers as a .pdf (not .pdf/A) attachment to the address provided on the scheduling order.

Format

PDF

All moving papers, letter motions, and letters must be in searchable PDF format, not scanned images.

All moving papers, letter motions, and letters filed on ECF or emailed to chambers must be in searchable PDF form. Typically, this means that a document created using word-processing software must be converted to PDF from the original word-processing file. PDF images may not be created by scanning paper documents.

Required

Always

Margins

1 in

Courtesy copies must be double-sided with ECF header, tabs for exhibits, and bound if bulky.

Courtesy copies should be printed on double-sided paper, and should bear the ECF header generated at the time of electronic filing and include protruding tabs for any exhibits. Bulky materials should be neatly bound, or placed in 3-ring binders, with appropriate dividers.

Format

PDF

All moving papers, letter-motions, and letters must be in searchable PDF format.

All moving papers, letter-motions, and letters filed on ECF or emailed to Chambers must be in searchable PDF form.

Format

PDF

Letters filed on ECF must be in searchable PDF format.

All letters filed on ECF must be in searchable PDF form.

Required

Always

Hand deliveries must be left with Court Security Officers at Worth Street entrance.

Where permitted by these rules, hand-deliveries 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.

Required

Always

Letters to court must be filed on ECF and double-spaced if over one page

All communications with the Court must be submitted by letter and filed on ECF. Any letter that is longer than one page must be double spaced.

Sentencing submissions must be double spaced.

All sentencing submissions must be double spaced.

Appendices to memoranda of law must be tabbed and indexed.

All appendices to memoranda of law must be tabbed and indexed.

Mobile phones must be turned off in courtroom at all times.

If permitted by the Standing Order, mobile telephones are permitted inside the Courtroom, but they MUST be kept turned off at all times.

Format

DOCX

Requests to charge, verdict forms, and voir dire questions must be submitted as Microsoft Word documents.

In addition to filing these documents on ECF, parties should also submit copies of these documents to the Court by email (ca02_AJNchambers@ca2.uscourts.gov), as Microsoft Word documents.

Required

Always

Margins

1 in

Memoranda of law require 12pt font, double-spacing, 1-inch margins.

All memoranda of law shall (1) be produced in a font size of twelve point or higher, (2) be double-spaced, and (3) have one-inch margins on all sides.

Required

Always

Footnotes require 12pt font, single-spacing with 12pt space between.

Footnotes shall (1) be produced in a font size of twelve point or higher, and (2) be single-spaced with a twelve point space between footnotes appearing on the same page.

Format

DOCX

Proposed voir dire questions must be emailed to chambers in Word format.

Proposed voir dire questions – a copy of which shall be e-mailed to chambers in a Word version – which shall include the text of any requested question and should consist of a single document and note any areas of disagreement between the parties;

Format

DOCX

Proposed verdict form must be emailed to chambers in Word format.

A proposed verdict form – a copy of which shall be e-mailed to chambers in a Word version – which should consist of a single document and note any areas of disagreement between the parties;

Format

DOCX

Proposed jury instructions must be emailed to chambers in Word format with citations.

Proposed jury instructions – a copy of which shall be e-mailed to chambers in a Word version – which shall include the text of any requested instruction and a citation, if relevant, to the authority from which such instruction derives, and should consist of a single document and note any areas of disagreement between the parties;

Format

DOCX

Proposed findings of fact and conclusions of law must be emailed to chambers in Word format with record citations.

Proposed findings of fact and conclusions of law – a copy of which shall be e-mailed to chambers in a Word version – which should be detailed and note any areas of disagreement between the parties and, for each proposed factual finding, shall include citations to the record;

Documentary evidence must be compiled in tabbed binders organized by exhibit number.

All documentary evidence, which shall be compiled in tabbed binders containing all documentary exhibits organized by exhibit number. If the number of exhibits is so voluminous as to make compliance with this rule impractical, the parties shall contact the Court for guidance.

Required

Always

Court's exhibit copies must be in tabbed notebook or manila folders.

The Court's copies of the pre-marked exhibits should be assembled sequentially in a notebook and tabbed or, if a party prefers, each exhibit may be placed in a separate manila folder with number or letter visible on the lip, and the folder placed in a suitable container or box for ready reference.

Required

Always

Voluminous exhibits may be submitted by CD with Chambers approval.

In the event of an especially voluminous submission, and only with written approval from Chambers, parties may submit their exhibits by CD.

Required

Always

Format

PDF

All ECF filings capable of being text-searchable must be made text-searchable.

All filings on ECF which can be made text-searchable shall be text-searchable.

All affidavits, exhibits, and motions must be bound.

All affidavits, exhibits, and motions shall be bound.

Format

FAX

Fax communications of 6-20 pages only after hours without permission; permission needed during office hours.

Written communications of six (6) to twenty (20) pages may be faxed, without permission, only after hours: after 5:30 P.M through 8:30 A.M. the following morning. During office hours, between 8:30 A.M. and 5:30 P.M., permission to fax 6- to 20-page documents is necessary. No hard copy should be sent if a copy is sent by facsimile.

Format

FAX

Fax communications of 21+ pages require permission, granted only in urgent circumstances.

Written communications of twenty-one (21) pages or more may only be faxed with permission. Permission is likely to be granted only in urgent circumstances. No hard copy should be sent if permission is given to fax the document.

Footnotes are discouraged in motion papers

Footnotes are discouraged.

All exhibits must be tabbed and indexed.

All exhibits shall be tabbed and indexed.

Required

Always

All text-containing documents must be text searchable.

All pleadings, letters, motion papers, affidavits, or any other document containing text shall be text searchable.

Format

PDF

Courtesy-copy emails to Chambers must attach the filing as a PDF.

Generally, letters should be filed electronically on ECF and courtesy copies should be emailed to Chambers at ALCarterNYSDChambers@nysd.uscourts.gov as a .pdf attachment, with all counsel copied on the email.

Format

DOCX

The emailed jury pretrial submissions must be sent as single MS Word documents.

the proposed voir dire questions, requests to charge and verdict form should be emailed as single MS Word documents

Deposition indexes should be included with supplied depositions if available.

With respect to any deposition that is supplied, the index to the deposition should be included if it is available.

Parties should provide text-searchable electronic copies of relied-upon hearing or deposition transcripts if available, unless unduly burdensome.

The parties should provide the Court with a complete electronic, text-searchable copy of any hearing or deposition transcript on which the parties rely, if such a copy is available, unless doing so would be unduly burdensome.

Summary judgment memoranda must include background and facts sections, and should not incorporate Rule 56.1 statements by reference.

Memoranda of law should include sections discussing the relevant background and facts. Parties should not merely incorporate by reference their Local Rule 56.1 Statements or Counterstatements.

Required

Always

Personal electronic devices must be turned off in courtroom, not just silenced.

An attorney who meets those requirements may bring a Personal Electronic Device into the courtroom, but the device must be turned off (not merely placed in vibrate mode or otherwise silenced).

Required

Always

Related cases must include both docket numbers; consolidated cases use only consolidated docket number.

After an action has been accepted as related to a prior filing, all future court submissions must contain the docket number of the new filing as well as the docket number of the case to which it is related (e.g. 19 Civ. 1234 [rel. 18 Civ. 5678]); if two or more actions have been consolidated for all purposes under a single docket number pursuant to Federal Rule of Civil Procedure 42(a)(2), all future court submissions should be filed only in the docket under which the cases have been consolidated and should reference only that docket number.

Exhibits should be bound and individually tabbed.

If possible, exhibits should be bound or collated in a binder. Each exhibit should be individually tabbed.

Exhibits with multiple documents are disfavored.

Exhibits containing multiple documents (e.g., more than one bank statement) are disfavored.

Motion papers must be bound securely without obscuring text, lying flat when open.

Motion papers should be bound in any manner that is secure, does not obscure the text, and permits the document to lie reasonably flat when open.

Media files must be in common player-compatible format.

A party submitting media files in connection with a motion must, to the extent possible, provide them in a format capable of being played using commonly available media players, e.g., Windows Media Player.

Special media software must not require admin privileges.

If the media unavoidably requires special viewing software, that software must be provided to the Court in a form that does not require administrative privileges for installation or operation.

The Civil Case Management Plan and Scheduling Order form must be completed in Adobe Acrobat.

When filling out the Civil Case Management Plan and Scheduling Order, download the form into Adobe Acrobat to complete it.

All memoranda of law must be in 12-point font or larger.

All memoranda of law must be in 12-point font or larger

Appendices to memoranda of law must be tabbed and indexed.

All appendices to memoranda of law must be tabbed and indexed.

Format

DOCX

Moving parties must provide all other parties an electronic copy of the Rule 56.1 Statement in Microsoft Word format.

Any party moving for summary judgment must provide all other parties with an electronic copy, in Microsoft Word format, of the moving party's Statement of Material Facts Pursuant to Local Rule 56.1 ("Rule 56.1 Statement").

Required

Always

Large exhibit files may be submitted in hard copy with specific formatting requirements.

If the files are too large for submission by email, see Paragraph 1(C) above.) If submission of electronic copies would be an undue burden on a party, the party may seek leave of the Court (by letter-motion filed on ECF) to submit prospective documentary exhibits in hard copy. Each hard copy shall be pre-marked (that is, with an exhibit sticker) and assembled sequentially in a loose leaf binder (not to exceed 2 1/2 inches in thickness) or in separate manila folders labeled with the exhibit numbers and placed in redweld folders labeled with the case name and docket number;

Required

Always

Non-compliance with electronic device rules may result in device forfeiture

Non-compliance with this rule may result in forfeiture of the device for the remainder of the proceedings.

Required

Always

Large files require email request for transfer link with case details.

c. Submission of Large Electronic Files. 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 the Court (at ClarkeNYSDChambers@nysd.uscourts.gov) requesting a link to be used for such transfer. The email should include the name and docket number of the case as well as the nature and size of the materials to be submitted electronically. The Government may use USAfx.

Required

Always

All written submissions must be text-searchable.

All written submissions and supporting materials must be text-searchable to the extent practicable.

Side binding preferred for lengthy documents; velo binding discouraged; declarations double-sided, memoranda single-sided.

The moving party should note that for documents that are too lengthy to be stapled, the Court has a preference for binding on the side. Velo binding is discouraged. Parties are encouraged to print declarations with lengthy exhibits double sided, but memoranda of law should be single sided.

Format

PDF

Electronic submissions should be text-searchable PDFs where practicable.

All electronic submissions should be in the form of text-searchable .pdf documents, where practicable.

Format

PAPER

Documents may be mailed only if electronic submission is impossible, but mail delivery is discouraged due to delays.

In the event that a party or counsel is unable to submit a document electronically — either by ECF or email — the document may be mailed to the Court. To the maximum extent possible, however, this means of delivery should be avoided, as delivery of mail to the Court is likely to be delayed.

Format

PDF

Exhibits on ECF should be text-searchable when possible.

Exhibits filed on ECF should be in text-searchable format, where possible.

Format

PAPER

Only enumerated letter motions may be filed electronically; other letters must be mailed or delivered.

Letter motions enumerated in Section 13.1 of the ECF Rules and Instructions may be filed electronically. Other letters shall be mailed or sent by commercial courier to the undersigned or delivered to the court security officers at the Worth Street entrance, 200 Worth Street. Letters, other than enumerated letter motions, shall not be filed on the CM/ECF system.

Required

Always

Supreme Court case citations must include official reports and parallel cites to Supreme Court Reporter.

Citations to United States Supreme Court cases shall contain citations to the official reports and parallel cites to the Supreme Court Reporter, respectively.

Supreme Court case citations must include official reports and parallel cites to Supreme Court Reporter.

Citations to United States Supreme Court cases shall contain citations to the official reports and parallel cites to the Supreme Court Reporter, respectively.

Exhibits to memoranda must be tabbed and indexed.

All exhibits to memoranda and other papers should be tabbed and indexed.

Required

Always

Electronic devices are prohibited in courtroom, robing room, and chambers.

Electronic devices – including cellular telephones, iPads, and laptops – are not permitted in Judge Kaplan's courtroom, robing room or chambers.

Required

Always

Exhibits must be separated by index tabs for easy location.

In all submissions to Judge Stanton where exhibits are attached, the exhibits shall be separated by index tabs so that the particular exhibit may be readily located within the group of exhibits.

Required

Always

Letters to the court must not exceed 3 pages.

Communications with the Court should generally be by letter not to exceed three pages in length.

Format

PDF

TRO papers must be submitted in text-searchable PDF format.

Parties intending to file applications for TROs or other emergency relief must send all of their papers (in text-searchable PDF format) to the Court by email.

Format

PAPER

Documents may be mailed if electronic submission is impossible, but mail delivery is discouraged due to delays.

In the event that a party or counsel is unable to submit a document electronically — either by ECF or email — the document may be mailed to the Court. To the maximum extent possible, however, this means of delivery should be avoided, as delivery of mail to the Court is likely to be delayed.

Format

PAPER

Mailing documents is permitted only if electronic submission is impossible.

In the event that a party or counsel is unable to submit a document electronically — either by ECF or email — the document may be mailed to the Court. To the maximum extent possible, however, this means of delivery should be avoided, as delivery of mail to the Court is likely to be delayed.

Voluminous courtesy copies must be organized in binders or folders and arranged into two independent sets

Voluminous material may be organized either in binders or manila file folders, but in any event, the courtesy copies shall be separately arranged into two independent sets.

Margins

1 in

Motion courtesy copies must be securely bound, one-sided, and lie flat when open.

All courtesy hard copies of papers submitted in connection with motions must be bound in any manner that is secure, does not obscure the text, and permits the document to lie reasonably flat when open. Copies should be printed one-sided. Rather than submitting large documents that do not lie reasonably flat when open, parties should submit multiple volumes.

Required

Always

Mobile phones allowed in Courtroom but must be turned off.

Mobile phones are permitted inside the Courtroom, but they must be kept turned off at all times.

Large documents should be submitted in multiple volumes instead of one large document.

Rather than submitting large documents that do not lie reasonably flat when open, parties should submit multiple volumes.

Courtesy copies must include ECF header and protruding tabs for exhibits.

Courtesy copies should bear the ECF header generated at the time of electronic filing and include protruding tabs for any exhibits.

Bulky materials in courtesy copies should be bound or in 3-ring binders.

Bulky materials should be neatly bound or placed in 3-ring binders with appropriate dividers.

Required

Always

Personal electronic devices must be completely turned off in the courtroom.

An attorney who meets those requirements may bring a Personal Electronic Device into the courtroom, but the device must be turned off (not merely placed in vibrate mode or otherwise silenced).

Required

Always

Additional electronic device policies may be adopted by the court.

The court may adopt additional policies governing the possession or use of electronic equipment within the courthouse. Be sure to check the Court website or with the relevant courthouse to identify any additional policies.

Required

Always

Personal electronic devices must be completely turned off in courtroom.

An Attorney who meets those requirements may bring a Personal Electronic Device into the courtroom, but the device must be turned off (not merely placed on vibrate mode or otherwise silenced).

Required

Always

Non-compliance with electronic device rules may result in device forfeiture.

Non-compliance with this rule may result in forfeiture of the device for the remainder of the proceedings.

Parties should use the template form for the Proposed Case Management Plan and Report on Rule 26(f) Meeting.

The parties should use the template form Proposed Case Management Plan and Report on Rule 26(f) Meeting, which is available at https://nysd.uscourts.gov/hon-robyn-f-tarnofsky.

Letters longer than one page must be double-spaced.

Any letter filed with the Court that is longer than one page must be double spaced.

Letters over one page must be double-spaced.

Any letter filed with the Court that is longer than one page must be double spaced.

Letters longer than one page must be double spaced.

Any letter that is longer than one page must be double spaced.

Sentencing submissions must be double spaced.

All sentencing submissions must be double spaced.

Letters exceeding one page in length must be double spaced.

Any letter longer than one page must be double spaced.

Appendices to memoranda must be tabbed and indexed.

All appendices to memoranda of law must be tabbed and indexed.

Format

FAX

Fax communications of 6 pages or fewer without permission; no hard copy needed.

Written communications of six (6) pages or fewer may be faxed at any time without permission. No hard copy should be sent if a copy is sent by facsimile.

All letter-motions should be text-searchable.

All letter-motions should be text-searchable.

Memoranda must cite official reporters for NY and US Supreme Court cases; unreported non-Westlaw/Lexis cases require copy of case; avoid unofficial reporters.

You can save pages by not including citations to unofficial reporters. Citations to New York and United States Supreme Court cases shall contain citations to the official reporter. Citations to unreported cases not available on Westlaw or Lexis should be accompanied by a copy of the case cited.

Memoranda should not recite obvious standards for common motions (e.g., dismiss, summary judgment, reconsideration) to save pages.

You can also save pages by not telling the Court the obvious – there is no need to recite the standards for granting, e.g., a motion to dismiss, a motion for summary judgment, a motion for reconsideration.

Parties must meet and confer on document production format before Initial Discovery production, which does not delay deadlines without court order.

Prior to the production of documents by either Party to the other pursuant to the Initial Discovery Protocols, the Parties will meet and confer regarding the format (e.g. TIFF/text, searchable .pdf, Excel) for such production. This will not delay the timeframes for Initial Discovery absent ruling by the court.

Required

Always

Conferences may be held remotely or in Courtroom 905 at Thurgood Marshall Courthouse

Conferences may be held remotely or in person. In-person conferences will be held in Courtroom 905 of the Thurgood Marshall United States Courthouse, 40 Centre Street / 40 Foley Square, New York NY.

Required

Always

Format

PDF

Electronic copies of exhibits are encouraged.

Parties are encouraged to use electronic copies of exhibits as much as possible.

Required

Always

Margins

1 in

Format

PDF

Submissions should be text-searchable PDFs created electronically, not by scanning

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.

Format

DOCX

Represented parties should email proposed findings in Microsoft Word format.

At the time of filing, a represented party should e-mail this document to the Court in Microsoft Word format.

Required

Always

Submissions should be in text-searchable PDF format when feasible.

Judge Furman reads most submissions in electronic form using an iPad or computer. Accordingly, 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).

Required

Always

Format

PDF

Pro se parties may file papers in person, by mail, email (PDF), or ECF (with permission)

A pro se party may file papers with the Court by: i. delivering them in person to the Pro Se Office (address listed above); ii. mailing them to the Pro Se Office; iii. emailing them as an attachment in PDF format to Pro_Se_Filing@nysd.uscourts.gov, in which case the pro se party should follow the instructions contained in the April 1, 2020 Addendum to the Court’s ECF Rules & Instructions, available at https://www.nysd.uscourts.gov/electronic-case-filing; or iv. filing them on the ECF System if the pro se party has filed a motion to participate in ECF (available at http://nysd.uscourts.gov/file/forms/motion-for-permission-for-electronic-case-filing-for-pro-se-cases and in the Pro Se Office) and been granted such permission by the Court.

Required

Always

Electronic device use governed by Standing Order M10-468.

Attorneys’ use of mobile phones, personal electronic devices, and general-purpose computing devices such as laptops and tablets within the Courthouse and its environs is governed by Standing Order M10-468.

Required

Always

Format

PDF

Electronic submissions should be text-searchable PDFs where practicable.

All electronic submissions should be in the form of text-searchable .pdf documents, where practicable.

Letter-motions should be text-searchable where practicable.

If practicable, all letter-motions should be text-searchable.

PDFs uploaded to ECF should be text searchable where possible

Where possible, Parties should ensure that PDFs uploaded to ECF, such as memoranda, declarations, or exhibits, are text searchable.

Format

PDF

PDFs uploaded to ECF should be text searchable where possible.

Where possible, Parties should ensure that PDFs uploaded to ECF, such as memoranda, declarations, or exhibits, are text searchable.

Required

Always

Margins

1 in

Courtroom Deputy tracks time, reported periodically; time accrues when counsel addresses jury or presents deposition testimony.

Time will be kept by the Courtroom Deputy and reported on the record periodically and at the close of evidence on each trial day. Time will accrue when counsel is standing in the presence of the jury and during the presentation of a party's designated deposition testimony.

Margins

1 in

Bankruptcy appeals follow FRBP briefing schedule and format unless otherwise ordered.

The briefing schedule and format and length specifications set forth in the applicable provisions of Federal Rules of Bankruptcy Procedure shall govern unless otherwise ordered by the Court.

Required

Always

Margins

1 in

Courtesy copies must be marked, bound, and tabbed.

All courtesy copies must be clearly marked as such, bound, and tabbed.

Required

Always

Trial schedule: Mon-Fri 9:30 AM-4:30 PM with morning counsel meeting, lunch recess, and breaks.

Trials will generally be conducted Monday through Friday from 9:30 a.m. to 4:30 p.m. The Court will be available to meet with counsel from 9:00 a.m. to 9:30 a.m. Testimony will begin at 9:30 a.m. A luncheon recess will run from 12:45 p.m. to 2 p.m. One (1) 10-15 minute break will be given in the morning and afternoon.

Required

Always

Trials scheduled Monday-Thursday, 9:30 AM-5:00 PM with one-hour lunch break

Trials will generally be conducted Monday through Thursday from 9:30 a.m. to 5:00 p.m., with a one-hour break for lunch.

Required

Always

Format

PDF

Submissions should be text-searchable PDF, preferably created electronically rather than by scanning.

If feasible, a party should file its submission(s) 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.

Wi-Fi credentials for trial are valid for entire trial duration.

Note: If requesting Wi-Fi is being requested for trial purposes, the credentials will be valid for the duration of trial in its entirety.

Required

Always

Attorneys may use electronic devices in hallways outside courtroom but must be discreet.

Attorneys may use their devices in the hallway outside the courtroom (although not in the vestibule to the courtroom), but are asked to be discreet and to keep their voices down.

Use Westlaw citations for unreported cases when possible.

Additionally, to the extent citing unreported cases, parties are requested to use Westlaw citations whenever possible.

Westlaw citations preferred for unreported cases.

Additionally, to the extent citing unreported cases, parties are requested to use Westlaw citations whenever possible.

Required

Always

Format

PAPER

USB submissions can be mailed or delivered to courthouse mailroom.

The USB can be mailed to Chambers or delivered to the mailroom at the Thurgood Marshall Courthouse, 40 Foley Square, New York, NY 10007.

Courtesy copies must include ECF header and protruding tabs for exhibits.

Courtesy copies should bear the ECF header generated at the time of electronic filing and include protruding tabs for any exhibits.