Judge Valerie Figueredo

Any Personally Identifying Information (“PII”) (e.g., social security numbers, financial account numbers, passwords, and information that may be used for identity theft) exchanged in discovery shall be maintained by the receiving party in a manner that is secure and confidential and shared only with authorized individuals in a secure manner.

No later than seven days before the conference, each party must send to the Court a letter of no longer than five (5) pages marked “Confidential Materials for Use Only At Settlement Conference,” setting forth concisely the following: (1) a discussion of the relevant facts and applicable law, with an emphasis on the issues more pertinent to settlement, including a discussion of liability and damages in the event liability were established; (2) if non-monetary relief is sought in addition to or instead of money damages, each party must set forth its position as to the provision of such relief; (3) any case law authority relevant to settlement discussions; (4) the history of settlement discussions, if any, including any prior offers or demands; (5) the settlement value of the case and rationale for it; and (6) that party’s most recent demand or response to the most recent demand.

This letter must be received by the Court no later than midnight seven days before the settlement conference. This letter, along with the Acknowledgment Form that appears following this Standing Order, must be sent to the Court by email to: FigueredoNYSDchambers@nysd.uscourts.gov. A courtesy copy of the letter and any exhibits shall be submitted to the Court if the exhibits to the letter exceed 10 pages.

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

Memoranda of ten (10) pages or more shall contain a table of contents and a table of authorities.

Letters may not exceed 3 single-space pages in length (exclusive of exhibits).

Emails to Chambers are only permitted for urgent matters requiring immediate attention or when otherwise expressly permitted by the Court in advance.

No faxed communications shall be permitted without prior permission from Chambers.

Letter-Motions may not exceed three (3) pages in length, exclusive of attachments, which should be kept to a minimum.

Courtesy copies of Letter-Motions are not required unless the attached exhibits exceed 50 pages, in which case one (1) courtesy copy, marked as such on the cover page, should be submitted to Chambers promptly after filing.

Unless prior permission has been granted, memoranda of law in support of and in opposition to motions are limited to 25 pages, and reply memoranda are limited to ten (10) pages.