Hon. Sanket J. Bulsara — Individual Rules of Practice

Judge Bulsara Individual Practices (Civil)

May 19, 2026

Individual Practices for Civil and Criminal Cases

JUDGE SANKET J. BULSARA

Effective May 19, 2026

United States District Court for the Eastern District of New York

Central Islip

100 Federal Plaza

Courtroom 930

Central Islip, NY 11722

bulsara_chambers@nyed.uscourts.gov

Courtroom Deputy: Eddie Manson

Judge Bulsara Individual Practices (Civil)

May 19, 2026

CIVIL CASE PRACTICES AT A GLANCE

Individual

Issue Requirement Page

Practices

Written Must occur via letter filed

II.A 1

Communications on ECF.

Faxes Not permitted. II.A 1

Call only if parties cannot

appear due to emergency

and on the day of the

Telephone Calls II.B 1

conference. Telephone

calls to chambers,

Communications

otherwise prohibited.

with Chambers

Ex parte communication

prohibited. Certain

Email documents must be II.C 1

provided to Chambers via

email.

Submission of

Follow file transfer

Large Electronic II.D 2

protocol.

Files

Required for all cases.

ECF III.A 2

Pro se litigants exempt.

Required in every case

consistent with Local

Notices of

Civil Rule 1.4. “Of III.B 2

Appearance

counsel” appearances

prohibited.

Text Searchable

Preferred for ECF filings. III.C 2

Case Related Submissions

Filings

Counsel for represented

parties must mail hard

Pro Se Cases III.D 2

copies of papers to any

pro se litigant.

Voir dire; jury

instructions; verdict

Microsoft Word

forms; proposed findings III.E 2

Documents

should also be emailed to

Chambers.

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May 19, 2026

Individual

Issue Requirement Page

Practices

Required for all

memoranda of law, Rule

56.1 statements, and

Courtesy Copies III.F 3

exhibits to summary

judgment memoranda.

Otherwise not required.

Must follow procedures

Sealed or

set forth and satisfy III.G 3–4

Redacted Filings

Lugosch test.

Unpublished

Copies not required. III.H 4

Cases

Court does not

Settlement automatically retain

III.I 4

Agreements jurisdiction for

enforcement.

In person proceedings

only, except in certain pro

Location; Remote se matters. Held in

IV.A 4

Proceedings Courtroom 930 in the

Central Islip Courthouse,

unless otherwise ordered.

Must be made via letter

Court Requests for

motion, 48 hours prior to IV.B 4

Conferences Adjournments

the hearing.

Principal trial counsel

Attendance IV.C 4

required.

Court encourages

Participation participation of relatively IV.D 5

inexperienced counsel.

Magistrate Judge handles

all non-dispositive

Responsibilities pretrial matters and V.A 5

Magistrate

scheduling. Consult list

Judges

for specific matters.

Consent Strongly encouraged. V.B 6

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May 19, 2026

Individual

Issue Requirement Page

Practices

Must comply with

deadlines and word limits

set by Local Rule 72.1(b).

Objections or

Must have made V.C 6

Appeals

argument or presented

evidence to Magistrate

Judge in first instance.

Limited to 1750 words for

opening and response

briefs, and 1050 words for

reply. Permitted for

Letter Motions adjournments, venue, VI.A 6

remand, attorney’s fees

motions, Cheeks approval

in FLSA cases, and

ministerial maters.

Required only for non-

Premotion venue Rule 12 motions

VI.B 6–7

Conferences and motions to amend

pleadings.

Joint proposed schedule

should be filed for all

motions, except letter-

Briefing Schedule VI.C 7

motions, Rule 12 motions,

motions in limine and

Motions

Daubert motions.

Should be followed for all

motions except for letter-

Bundling Rule VI.D 7

motions and other

enumerated motions.

Memoranda in support

and opposition must

Word Limits VI.E 7

comply with word limits

in Local Rule 7.1(c).

Double spacing and 12-

Formatting and

point font (including VI.F 8

Citations

footnotes) required.

Oral Argument Typically not held. VI.G 8

Must be made via letter

Requests for

motion, 48 hours prior to VI.H 8

Extensions of Time

deadline.

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Judge Bulsara Individual Practices (Civil)

May 19, 2026

Individual

Issue Requirement Page

Practices

Require premotion

conferences; party in

opposition must inform

Rule 12 Motions about intent to amend; VI.I 8–9

premotion conference will

either set schedule or

decide motion.

Premotion settlement

conference required;

deadline for briefing

schedule is 30 days

following discovery close;

early summary judgment

motions discouraged;

Summary special requirements for

VI.J 9–10

Judgment Motions cross-motions; typically

not permitted in non-jury

cases; Rule 56.1

statements must comply

with Local Civil Rule;

wholesale filing of

exhibits or testimony

prohibited.

Premotion conference

Motions to Amend required; redlines VI.K 10–11

required.

Statements of facts and

Motions for Class

evidence relied on VI.L 11

Certification

required.

Absent order, must be

Motions to filed on same schedule as

VI.M 11–12

Exclude Experts summary judgment

motions.

Bankruptcy

Follow Rules 8014–8018. VI.O 12

Appeals

Orders to Show

Cause; Return Practice prohibited. VI.P 12

Date

Adverse party notice

Notice VII.A 12

required, unless exempt.

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May 19, 2026

Individual

Issue Requirement Page

Practices

Temporary

Email Chambers for

Restraining Email VII.B 12

scheduling of hearing.

Orders

Exempt; pro se litigant

permitted to receive ECF

ECF notice and submit VIII.A 12

electronically to Clerk’s

Office.

Pro Se Litigation

Must be mailed in hard

copy to pro se litigant;

Motion Papers Local Civil Rule 7.2, 12.1, VIII.B 12

and 56.2 compliance

certifications required.

Trial Date Two weeks notice only. IX.A 13

Due 30 days following

decision on dispositive

Joint Pretrial motion or following close

IX.B 13–14

Orders (“JPTO”) of discovery if no motion

filed. Consult list of

requirements.

Due with JPTO and

Exhibits submitted electronically IX.C 14

to Chambers.

Due 30 days following

filing of JPTO; subject to

word and format

Trial Procedures Motions in Limine IX.D.1 14–15

limitations; single

consolidated brief

required.

Requests to Due 30 days following

Charge; Voir Dire; filing of JPTO; must be IX.D.2 15

Verdict Forms joint.

Pretrial

Optional. IX.D.3 15

Memorandum

Deposition Must be submitted via

IX.D.4 15

Materials email.

Must be disclosed by end

Witnesses IX.E 15

of each trial day.

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Judge Bulsara Individual Practices (Civil)

May 19, 2026

Individual

Issue Requirement Page

Practices

Parties should consult

Technology courtroom deputy in IX.F 15

advance of trial date.

Time limits used in all

Time Limits IX.G 16

civil trials.

Proposed Findings Due 30 days following

of Fact and conclusion of trial

IX.H 16

Conclusions of testimony; responses due

Law 14 days thereafter.

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OVERVIEW OF SUMMARY JUDGMENT AND TRIAL DEADLINES

Presumptive Deadline Individual Practices

Summary Judgment

VI.J.2

(Briefing Schedule)

30 days following the close of discovery.

Daubert Motions VI.M

30 days following the close of discovery

Joint Pretrial Order or decision on summary judgment, IX.B

whichever is later.

Electronic Copies of Exhibits Submitted with JPTO. IX.C

Motions in Limine IX.D.1

Requests to Charge IX.D.2

Voir Dire IX.D.2

30 days following filing of JPTO.

Verdict Form IX.D.2

Pretrial Memo (Optional) IX.D.3

Deposition Materials IX.D.4

30 days following conclusion of trial

Proposed Findings of Fact

testimony; responses due 14 days IX.H

and Conclusions of Law

thereafter.

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INDIVIDUAL PRACTICES IN CIVIL CASES

I. SCOPE AND APPLICATION; WORD COUNTS; COMPUTING TIME

These Individual Practices and Rules apply to all civil cases before Judge Bulsara.

A party may seek leave, by filing a letter-motion, for a different rule or procedure to

apply to a particular case.

In computing time and deadlines set forth in these Individual Practices, parties

should consult Federal Rule of Civil Procedure 6.

II. COMMUNICATIONS WITH CHAMBERS

A. Written Communications. Except as otherwise provided below, any

communication with the Court must occur via letter filed on ECF. Except for

courtesy copies, which may be delivered to the Clerk’s Office at the Central Islip

courthouse, the Court does not accept hand delivery of any material. And the

Court does not accept faxes. Letter correspondence solely between counsel

should not be filed on ECF, unless as an exhibit to motion papers seeking relief

from the Court. To ensure timely evaluation, a party making an application for

relief via letter (such as a request for an adjournment) should file the document

as a letter-motion on ECF.

B. Telephone Calls and Case Related Inquiries. Telephone calls to

chambers are prohibited, except for emergency circumstances on the date of a

conference. Chambers should only be contacted if on the day of the conference,

the parties cannot appear due to an emergency and counsel wish to inform the

Court that an electronic application is forthcoming. In such a case, counsel may

contact Judge Bulsara’s case manager, Eddie Manson. For all other requests, the

parties must communicate with the Court by letter filed electronically on ECF.

For case-related questions including deadlines and confirmation of conference

dates, counsel should electronically access the docket sheet. For questions

regarding CM/ECF docketing and filings, counsel should call the Court’s

Docketing Section at (631) 712-6010. For technical assistance and courtroom

technology, counsel should call (631) 712-6070.

C. Emails to Chambers. The Court’s email address is

bulsara_chambers@nyed.uscourts.gov. Any request for an adjournment, even an

emergency request, should only be made by letter-motion filed on the docket,

not by email or telephone. The Court does not respond to email requests or

inquiries, or accept submissions via email, except as provided in these rules. Ex

parte emails to Chambers are not permitted and all emails must cc: all other

counsel in the case.

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D. Submission of Large Electronic Files. The Court has a file transfer

protocol for the safe electronic transmission of electronic files. If a party needs to

submit large files to the Court, or exhibits for trial, the party should email

Chambers indicating that they intend to submit large electronic file(s). The email

should include the name and docket number of the case and the nature of the

materials to be submitted electronically. The party should then follow the

protocol set forth here: https://evidence.nyed.uscourts.gov for submission.

III. CASE RELATED FILINGS

A. Requirement for ECF Use. Counsel in all cases are required to register for

Electronic Case Filing (“ECF”). Documents sent to the Court’s email address and

not contemporaneously filed on ECF will not be considered filed. ECF

procedures are available on the Eastern District of New York website. Chambers

staff are unable to assist with filing via ECF. For assistance, please call the ECF

helpline at (631) 712-6010. Because all orders issued by the Court will be

transmitted to counsel electronically, attorneys are responsible for keeping their

ECF registration current with the Clerk’s Office. Pro se litigants are exempt from

ECF filing requirements.

B. Notices of Appearance. Counsel are reminded of their obligations under

Local Civil Rule 1.4 to file a notice of appearance in civil cases. Only a party’s

counsel of record, or an attorney authorized to appear by the party (and not

simply by the party’s counsel of record) may appear in Court on behalf of a

party. An attorney acting “of counsel” for a party’s counsel of record may not

appear without the represented party’s explicit authorization, because such an

attorney has no authority to make binding representations on behalf of any

party. See N.Y. Rules of Pro. Conduct 1.2(c), 22 N.Y.C.R.R. § 1200 (requiring

client to give “informed consent” before an attorney may make a limited

appearance on the client’s behalf).

C. Text Searchable Submissions. If feasible, each submission on ECF should

be in a text-searchable format created by converting the document electronically

to PDF by computer (that is, not by scanning a printed document).

D. Cases Involving Pro Se Litigants. A party represented by counsel in a

case involving a pro se litigant must still file all documents electronically on ECF

and must also mail a hard copy of all documents to the pro se litigant. See § VIII

for additional rules regarding motions involving pro se litigants.

E. Microsoft Word Documents. In addition to filing the document on ECF, a

party should provide Microsoft Word versions of proposed (a) voir dire; (b) jury

instructions; (c) findings of fact and conclusions of law; and (d) verdict forms to

the Court through its email address. Other papers should not be emailed to

Chambers.

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F. Courtesy Copies. The parties should only provide paper courtesy copies

of memoranda of law and Rule 56.1 statements associated with any motion to the

Court on the day the motion is filed on ECF (and not before). The parties must

also submit courtesy copies of exhibits to summary judgment memoranda.

Parties are encouraged to use double-sided printing for their courtesy copies.

Such papers may be mailed; overnight, express, or hand delivery service is not

required. Courtesy copies of other papers—including letters, letter-motions,

objections, or appeals to decisions of a Magistrate Judge, exhibits to other

motions, notices of motions, proposed orders, or motions directed to the

Magistrate Judge—should not be provided, and need only be filed on ECF.

G. Sealed or Redacted Filings. There are limited categories of information

that may be redacted from public ECF filings without prior permission from the

Court: those items listed in Federal Rule of Civil Procedure 5.2. All other

redactions or sealing of filings require Court approval. In evaluating motions to

seal, the Court applies the Second Circuit’s test set forth in Lugosch v. Pyramid Co.,

435 F.3d 110 (2d Cir. 2006). Motions for redaction or sealing should comply with

the following procedure:

1. The party seeking leave to file sealed or redacted materials should meet and

confer with any opposing parties (or third parties seeking confidential

treatment of the information, if any) in advance to narrow the request.

2. A party seeking to file a redacted or sealed document should file a single

motion to seal that addresses every document (appended as separate exhibits)

for which sealing or redaction is sought.

3. The motion to seal should be accompanied by a memorandum of law that

explains why any material that is redacted or entirely shielded from public

view satisfies Lugosch. If the memorandum of law requires redaction, both

redacted and unredacted versions of the memorandum, the latter under seal,

should be filed. The memorandum must include an attorney certification that

the meet and confer required in Step 1 has been completed.

4. A public version of the motion to seal—and the underlying motion—should

be filed and must attach the exhibits containing limited redactions or an

indication that the entire document is sealed, as appropriate. A private

version of the motions should also be filed under seal with these same

documents unredacted in their entirety.

5. Any opposition to a motion to seal must be filed within three days of the

filing of the motion to seal and follow the procedures in steps (2) through (4)

above.

6. Motions must comply with the terms of any District-wide order concerning

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sealed documents, including Administrative Order No. 2025-13.

Broad treatment of all documents and sweeping justifications for sealing are

inconsistent with the requirement of narrow tailoring and are unlikely to have

merit. See Brown v. Maxwell, 929 F.3d 41, 48 (2d Cir. 2019) (“[I]n contravention of

our precedent, the District Court failed to review the documents individually

and produce specific, on-the-record findings that sealing is necessary to preserve

higher values. Instead, the District Court made generalized statements about the

record as a whole. This too was legal error.” (quotations and footnotes omitted));

e.g., Gannett Media Corp. v. United States, No. 22-2160, 2022 WL 17818626, at *3 (2d

Cir. Dec. 20, 2022) (“[B]road findings, however, are insufficient to justify the

redactions in the Sealed Submissions.”).

H. Unpublished Cases. If a party cites to a case not available in an official

reporter, but otherwise available on Westlaw, it need not file the authority on

ECF or provide a copy to Chambers.

I. Settlement Agreements. The Court will not automatically retain

jurisdiction to enforce confidential settlement agreements. If the parties move

the Court to retain jurisdiction to enforce a settlement agreement, the party must

file the unredacted version of the settlement agreement on ECF as an exhibit to

the proposed stipulation of dismissal, and provide good cause why the Court

should retain jurisdiction.

IV. COURT CONFERENCES

A. Location; Remote Proceedings. The Court conducts all conferences,

except certain pro se matters, in person. Requests for remote proceedings will be

denied. The parties should consult ECF to confirm the location of a conference.

Unless otherwise ordered, all in-person conferences will be held in Courtroom

930 in the Central Islip Courthouse.

B. Requests for Adjournments. Requests for adjournments must be filed

electronically as letter-motions. All requests for adjournments of a court

appearance must be made in writing, and absent an emergency, at least 48 hours

prior to the scheduled appearance. All requests for adjournments must state:

(1) the original date and proposed new date; (2) the reasons for the adjournment;

(3) whether the application is on consent; and (4) proposed dates for the revised

conference.

C. Who Must Attend. Absent leave of Court obtained prior to the

conference, the attorney who will serve as principal trial counsel must appear at

all conferences with the Court. In accordance with Section III.B the Court does

not permit “of counsel” appearances at Court conferences.

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D. Courtroom Opportunities for Relatively Inexperienced Attorneys. The

participation of relatively inexperienced attorneys in all court proceedings is

strongly encouraged. The Court is amenable to permitting a number of lawyers

to argue for one party if this creates an opportunity for a junior lawyer to

participate.

V. MAGISTRATE JUDGES

A. Allocation of Responsibilities to Magistrate Judges. Consistent with the

EDNY’s Division of Business Rule 2(b)(2), the assigned Magistrate Judge is

“empowered to act with respect to all non-dispositive pretrial matters.” As such,

any request for action (including rescheduling of a deadline or conference set by

the Magistrate Judge) on a non-dispositive matter should be addressed to the

assigned Magistrate Judge, not Judge Bulsara. The following matters will be

handled by the assigned Magistrate Judge:

1. Rule 16 initial conferences, discovery scheduling and management;

2. Extensions of time to serve, answer, or file amended pleadings;

3. Deposition disputes;

4. Confidentiality and protective orders;

5. Discovery motions, including motions to quash, enforce, or so-order Rule 45

subpoenas, except for subpoenas directing attendance of a witness at trial;

6. Motions related to the appearance of counsel, including for pro hac vice

admissions, to substitute, to withdraw, or to disqualify counsel, except when

such motions are made following the filing of the joint pretrial order;

7. Referrals of cases to the EDNY mediation or arbitration programs;

8. Settlement conferences;

9. Motions for conditional certification under the Fair Labor Standards Act;

10. Any motion to seal related to items (1) to (9); and

11. Any motion to stay, enforce, adjourn, or compel or request related to items (1)

to (10).

Motions for default judgment, to amend pleadings, or for attorney’s fees will be

handled by, and should be directed to, Judge Bulsara.

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B. Consent to Magistrate Judge Jurisdiction. The Court strongly encourages

parties to consent to Magistrate Judge jurisdiction over dispositive motions, for

trial, settlement approval, or for all purposes. In any case under the Direct

Assignment Program, which is indicated by a Clerk’s Notice on the docket, the

parties must file the “Direct Assignment Program Acknowledgement Form”

available at: https://www.nyed.uscourts.gov/bulletin-direct-assignment-

program.

C. Objections to or Appeal of Decisions, Orders, or Reports and

Recommendations Issued by Magistrate Judges. Any appeal or objection to

any action by a Magistrate Judge must comply with the deadlines and word

limits set forth in Local Civil Rule 72.1(b). Replies are not permitted. The Court

will summarily reject any objection or appeal based on arguments or evidence

not presented in the first instance to the Magistrate Judge. As such, any letter

objection or appeal must cite to the underlying record to demonstrate that the

argument or evidence was first presented to the Magistrate Judge. Any appeal

or objection must also comply with Federal Rule of Civil Procedure 72 and 28

U.S.C. § 636.

VI. MOTIONS

A. Letter Motions. Papers in support and in opposition to letter-motions are

limited to 1750 words, and 1050 words for reply briefs. Sur-replies are not

permitted. All letter-briefs must be in 12-point font (including footnotes). Only

the following motions may be made via letter-motion:

1. To adjourn a deadline or extend time;

2. To transfer venue;

3. For remand;

4. For an award of attorney’s fees;

5. For Cheeks approval in a Fair Labor Standards Act case; and

6. For ministerial matters consistent with Local Civil Rule 7.1(e).

Motions to amend may not be made via letter unless all parties consent to the

amendment.

B. Premotion Conferences. Premotion conferences are required for all

motions brought pursuant to Rule 12, except for such motions which must be

made via letter-motion under VI.A, and for motions to amend pleadings. No

other motion requires a premotion conference (for example, they are not required

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for summary judgment motions). Counsel who authored and signed the

premotion conference letter (or response) must appear at any conference held on

the request.

C. Briefing Schedule. For all motions, except for those requiring premotion

conferences, motions in limine, Daubert motions, or letter-motions, the parties

should file a joint proposed briefing schedule to be so-ordered by the Court.

Summary judgment briefing schedules must contain the date of the settlement

conference required by Section VI.J.1. For motions requiring premotion

conferences, the Court will set the briefing schedule at the conference; motions in

limine and Daubert motions are governed by Sections IX.D.1 and VI.M. The

deadline for a letter motion is governed by any applicable Rule of Civil

Procedure, Local Civil Rule 6.1, and any deadline set by this Court or the

assigned Magistrate Judge.

D. Bundling Rule. As a courtesy to the Court, no motion papers should be

filed on the docket until the motion is fully briefed. The parties should serve

their papers on the other parties in accordance with the briefing schedule, and

file a letter confirmation on the docket memorializing the same. Once the motion

is fully briefed, the moving party is responsible for filing the full set of motion

papers via ECF and providing a courtesy copy of all papers required by Section

III.F to the Court. For motions implicating Fed. R. App. P. 4(a)(4)(A) or similar

time-limiting rules of the Federal Rules of Civil or Appellate Procedure, if any

party concludes in good faith that delaying the filing of a motion will deprive the

party of a substantive right, this bundling rule does not apply; a party may file

the motion within the time required by the Federal Rules of Civil or Appellate

Procedure, together with an explanation of the basis for the conclusion. This

bundling rule does not apply to motions: (1) for default judgment pursuant to

Rule 55; (2) post-trial and/or post-judgment motions under Rules 50(b) (for

judgment as a matter of law), 52(b) (to amend or make additional findings), 59

(for a new trial), and 60 (for relief from a final judgment, order or proceeding); (3)

attorney’s fees pursuant to Rule 54(d)(2); (4) motions involving a pro se litigant;

or (5) letter-motions.

E. Word Limits. Unless the Court orders otherwise, memoranda of law

must comply with the word limits as set forth in Local Civil Rule 7.1(c) and the

requirement for a certification of compliance with the word limit. Memoranda of

law must include sections discussing the relevant background and facts. Parties

may not circumvent the word limit by putting relevant facts in a different

document. (For example, parties cannot incorporate by reference their Local

Rule 56.1 Statements or Counterstatements.) Motions for reconsideration must

comply with the word limits set forth in Local Civil Rule 6.3.

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F. Formatting and Citations. Case citations must contain pinpoint cites. All

memoranda of law must use reasonable margins, double spacing, and a

reasonable font of 12 point or larger, including for footnotes. Legal arguments

must be set forth in a memorandum of law rather than in affidavits, affirmations,

or declarations. Any papers not complying with these requirements will be

rejected. Citations to the docket should be made at the end of the sentence with

“Docket Entry (“DE”) [docket number].” Thereafter, any further citations to the

docket may be made with a short-cite at the end of the sentence with “DE [docket

number].” Parties must provide evidentiary citations, including references to

specific pages, in any submission that cites record material. Memoranda of 3500

words or more must contain a table of contents and a table of authorities, neither

of which shall count against the word limit.

G. Oral Argument. The Court does not typically hold oral argument. Parties

may request oral argument by filing a letter requesting the same upon filing of a

fully briefed motion, explaining the basis for the request.

H. Requests for Extensions of Time. Requests for extensions of time must

be filed electronically as letter-motions. All requests for extensions must be

made in writing, and absent an emergency, at least 48 hours prior to a filing

deadline. All requests for extensions of time must state: (1) the original deadlines

and proposed new deadlines; (2) the reasons for the extension; (3) whether the

application is on consent; and (4) proposed dates for the revised deadline.

I. Rule 12 Motions. The following rules apply to all motions under Federal

Rule of Civil Procedure 12, except motions which must be made by proceeding

via letter-motion:

1. A premotion conference (“PMC”) is required. See § VI.B. To arrange for such

a conference, the moving party should file a letter not exceeding 1750 words

setting forth the basis for the motion. No later than seven days following ECF

service, the non-moving party may file a letter not exceeding 1750 words

opposing the request and contesting the basis for the motion. PMC letters

must contain a certification of compliance with these word limits as set forth

in Local Civil Rule 7.1. Replies are not permitted.

2. Service of a letter requesting a premotion conference within the time

requirements of Federal Rule of Civil Procedure 12 will constitute timely

service of a motion made pursuant to this Rule.

3. When a motion to dismiss is filed, the non-moving party must, within 10 days

of receipt of the motion, notify the moving party (and the Court by filing a

letter on ECF) whether it intends to file an amended pleading or intends to

rely upon the pleading being attacked. Any amended pleading must comply

with Local Civil Rule 15.1, and the filing of any amended pleading—even if

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as of right—must include both a clean copy of the amended pleading, as well

as a version indicating all differences from the original pleading through

typographic methods such as redlining.

4. In appropriate cases, the Court may exercise its discretion to construe the

premotion letter as the motion itself.

5. Absent a statutory provision providing otherwise (e.g., the PSLRA), discovery

is not stayed automatically upon filing of a motion to dismiss or request for

premotion conference for such a motion. A party is obligated to seek a

discovery stay from the assigned Magistrate Judge if it wishes to suspend

discovery during the pendency of any motion.

J. Summary Judgment Motions.

1. Requirement of Pre-Motion Settlement Conference. Any party seeking to

file a motion for summary judgment must first have had a settlement

conference with the assigned Magistrate Judge. Failure to request and attend

such a conference precludes a party from moving for summary judgment. A

party opposing summary judgment may not decline to participate in a

settlement conference requested by the moving party, and doing so is

grounds for sanctions. See United States v. U.S. Dist. Ct. for N. Mar. I., 694 F.3d

1051, 1057 (9th Cir. 2012) (“[T]he district court has broad authority to compel

participation in mandatory settlement conference.”); Bulkmatic Transp. Co. v.

Pappas, No. 99-CV-12070, 2002 WL 975625, at *2 (S.D.N.Y. May 9, 2002) (“[I]t

is well established that a court can require parties to appear for a settlement

conference, and impose sanctions pursuant to Rule 16(f) if a party fails to do

so.”) (collecting cases). Attending a private mediation or one arranged

through the EDNY’s mediation program does not satisfy this requirement.

The assigned Magistrate Judge is empowered to hold the conference via

video or in-person (telephone conferences do not comply with this

requirement). This requirement does not apply to those cases exempt from

Rule 16 scheduling orders under Local Civil Rule 16.1.

2. Deadlines. Unless ordered otherwise by either Judge Bulsara or the assigned

Magistrate Judge, the deadline to submit a proposed summary judgment

briefing schedule is 30 days following the close of all discovery. Failure to

abide by this deadline will result in waiver of the right to make a summary

judgment motion. See Fed. R. Civ. P. 56(b). The schedule must contain the

date of the settlement conference required by Section VI.J.1.

3. Early Summary Judgment Motions. The Court strongly discourages

summary judgment motions made prior to the close of all discovery, though

the Court will consider such motions in exceptional circumstances. For such

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early summary judgment motions, contemporaneous with the filing of the

proposed briefing schedule, the moving party must file a letter no longer than

700 words directed to why early dispositive motion practice should be

permitted. Any party may file a response no longer than 700 words in

opposition no later than seven days after the first filing.

4. Cross Motions for Summary Judgment. In the case of cross-motions for

summary judgment, a consolidated briefing scheme applies. Plaintiff shall

serve a motion for summary judgment and supporting papers including a

memorandum of law no longer than 8750 words on the deadline ordered by

the Court. Defendant will then serve a motion for summary judgment and a

memorandum of law of no more than 17,500 words supporting their motion

and opposing Plaintiff’s motion. Plaintiff will then serve a memorandum of

law of no more than 12,250 words opposing Defendant’s motion and replying

to Defendant’s opposition to Plaintiff’s motion. Defendant shall then serve a

reply to Plaintiff’s opposition of no more than 3500 words. The papers will

then be filed on ECF pursuant to the bundling rule, see § VI.D, and courtesy

copies provided as set forth in Section III.F.

5. Non-Jury Cases. In any non-jury case, the Court will ordinarily not permit

summary judgment practice. In such a case, on the date for the submission of

a briefing schedule, the parties may submit a joint letter no longer than 700

words, explaining why such practice should be permitted.

6. Local Rule 56.1 Statements. Parties must prepare and submit Rule 56.1

statements consistent with the Local Rules.

7. Exhibits. Exhibits to summary judgment motions should be limited to those

documents or portions of testimony necessary to the disposition of motions.

For example, the parties should not file on ECF entire deposition transcripts

or all exhibits used at a deposition. Unnecessary filings will be stricken.

K. Motions to Amend.

1. A premotion conference is required. See § VI.B. To arrange for such a

conference, the moving party should file a letter not exceeding 1750 words

setting forth the basis for the motion. The party must also submit a redlined

version and a clean copy of the proposed amended pleading. No later than

seven days following ECF service, the non-moving party may file a letter not

exceeding 1750 words opposing the request and contesting the basis for the

motion. PMC letters must contain a certification of compliance with these

word limits as set forth in Local Civil Rule 7.1. Replies are not permitted.

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2. Compliance with Local Rule 15.1. Motions to amend must comply with

Local Civil Rule 15.1, which requires the motion to include a clean copy of the

proposed amended pleading, as well as a version indicating all differences

from the original pleading through typographic methods such as redlining.

3. Futility Arguments. Parties intending to oppose a motion to amend based

entirely on futility grounds are strongly advised to consider alternatively

bringing those arguments in a motion to dismiss. While “it is well

established that leave to amend a complaint need not be granted when

amendment would be futile,” Ellis v. Chao, 336 F.3d 114, 127 (2d Cir. 2003),

“[i]n the interests of judicial economy and in the absence of undue prejudice,

the Court may decline to engage in a detailed futility analysis where the

Court finds that these arguments are better suited for consideration in the

context of a motion to dismiss,” Env’t Sols. Assocs. Grp., LLC v. Conopoco, Inc.,

No. 20-CV-10699, 2021 WL 2075586, at *2 (S.D.N.Y. May 24, 2021) (citation

omitted). Parties opposing amendment should strongly consider consenting

to the amended complaint, see Fed. R. Civ. P. 15(a)(2), and raising any futility

arguments in the context of a Rule 12 motion. See, e.g., GGC Int’l Ltd. v. Ver,

No. 24-CV-0153, 2025 WL 81319, at *2–*3 (S.D.N.Y. Jan. 13, 2025) (granting

defendant’s motion to amend his answer and counterclaims and denying

plaintiff’s motion to dismiss without prejudice after establishing that doing so

would not prejudice plaintiff); Pitman v. Immunovant, Inc., No. 21-CV-0918,

2023 WL 1995018, at *6–*7 (E.D.N.Y. Feb. 14, 2023) (granting plaintiff leave to

amend and denying defendants’ motions to dismiss after finding that “the

better use of the parties’ and the Court’s resources is to have Plaintiff file a

third amended complaint drafted with consideration to Defendants’ motions

to dismiss”).

L. Motions for Class Certification. Motions for class certification must be

accompanied by a separate statement in numbered paragraphs of the facts and

evidence (including expert reports or testimony) on which the moving party

relies in its motion. Each statement must be accompanied by specific citations to

evidence in the record. The Court will not consider facts or evidence outside of

this statement or any unsupported allegation or claim. The papers in opposition

to a motion for class certification must also include a similar statement of the

facts relied on in opposition. The statement in opposition need not be

corresponding or respond to the movant’s statement.

M. Motions to Exclude Experts. Motions to exclude testimony of experts,

pursuant to Rules 702–705 of the Federal Rules of Evidence and Daubert v. Merrell

Dow Pharmaceuticals, 509 U.S. 579 (1993), must be made by the deadline for

briefing summary judgment motions and should not be treated as motions in

limine. In the proposed briefing schedule for summary judgment motions, the

parties may ask the Court to suspend briefing on motions related to experts, if

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good cause exists for such an adjournment until dispositive motions are

resolved.

N. Motions In Limine. See § IX.D.1.

O. Bankruptcy Appeals. Parties must comply with the briefing schedule and

the format and length specifications set forth in Federal Rules of Bankruptcy

Procedure 8014–8018, unless otherwise ordered by the Court.

P. Orders to Show Cause and Return Date. Parties should not proceed via

orders to show cause or set their own return dates for motions.

VII. TEMPORARY RESTRAINING ORDERS

A. Notification to Adverse Party. The party seeking a temporary restraining

order must file, with its motion papers, a letter indicating (a) whether and how it

has notified its adversary about the motion; or (b) why the requirements of

Federal Rule of Civil Procedure 65(b)(1) are satisfied, and notice to the adverse

party is not required. Where the motion is made on notice to the adverse party,

the moving party must serve the documents (as required by Fed. R. Civ. P. 4 or 5,

as applicable) on all defendants against whom relief is sought.

B. Email to Chambers. The moving party must upon filing of the TRO

papers send an email to Chambers indicating the timeframe requested for Court

action. The email should also provide counsel and witness availability for a

preliminary injunction hearing.

VIII. CASES INVOLVING PRO SE LITIGANTS

A. ECF. Pro se litigants are exempt from electronic filing. Pro se litigants

may receive ECF notifications of case activity by contacting the Clerk’s Office at

(631) 712-6060 and providing their email address. In lieu of bringing paper

copies of documents to the Courthouse for filing, pro se litigants may file

documents on ECF by submitting them to the Clerk’s Office at

https://prose.nyed.uscourts.gov/

B. Motion Papers. Counsel for parties in cases must mail hard copies of all

motion papers and filings to any pro se litigant, and file proof of service on ECF,

regardless of whether the pro se party has opted to receive ECF notifications.

Counsel are reminded of their obligations under Local Civil Rules 7.2, 12.1, and

56.2. Any motion implicating these Local Rules must be accompanied by a

certification of compliance with these requirements.

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IX. TRIAL PROCEDURES

A. Notice of Trial Date; Schedule of Trial Dates. Following submission of

the joint pretrial order, the Court may schedule the trial to commence with only

two weeks notice, and absent extraordinary circumstances, adjournments will

not be granted. The Court will typically begin trials on a Monday and sit for four

days per week.

B. Joint Pretrial Orders (“JPTO”). No later than 30 days after the date for

the completion of all discovery, or, in the event that a dispositive motion is filed,

no later than 30 days after the Court’s ruling on such a motion, the parties must

file on ECF, a proposed joint pretrial order that includes the following

information:

1. A current caption of the case (omitting entities or persons dismissed or

substituted);

2. The names, law firms, addresses, telephone numbers, and email addresses of

trial counsel;

3. A brief statement by plaintiff (or by defendant in a removed case) as to the

basis for subject matter jurisdiction, and a brief statement by each other party

as to the presence or absence of subject matter jurisdiction. Such statements

shall include citations to all statutes relied on and relevant facts as to

citizenship and jurisdictional amount;

4. A brief summary by each party of the claims and defenses it has asserted and

which remain to be tried, without recital of evidentiary matter, but including

citations to all statutes on which the party is relying;

5. A statement by each party as to whether the case is to be tried with or

without a jury, and the number of trial days needed;

6. A joint statement summarizing the nature of the case, to be read to potential

jurors during jury selection;

7. A list of people, places, and institutions (in alphabetical order) that are likely

to be mentioned during the course of the trial, to be read to potential jurors

during jury selection;

8. Any stipulations or statement of facts that have been agreed to by all parties.

In a jury case, the parties should memorialize any such statements in a

standalone document that can be marked and admitted at trial;

9. A list of all trial witnesses (in alphabetical order), indicating whether such

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witnesses will testify in person (or by deposition), whether such witnesses

will require an interpreter (and, if so, which party will pay the costs for the

interpreter), and a brief summary of the substance of each witness’s

testimony. Absent leave, a witness listed by both sides shall testify only once,

and the parties should confer on scheduling for such witnesses;

10. A designation by each party of deposition testimony to be offered in its case

in chief, with any cross-designations and objections by any other party. The

parties need not include deposition testimony marked solely for

impeachment purposes;

11. A list by each party of exhibits to be offered in evidence. The list must

include any exhibits that will be offered only on rebuttal, but does not need to

include exhibits to be used solely for impeachment purposes. If a party

objects to an exhibit, the objection must be noted and include a citation to the

Federal Rule of Evidence that is the basis for the objection. If any party

believes that the Court should rule on such an objection in advance of trial,

that party should include a notation to that effect (e.g., “Advance Ruling

Requested”).

12. A statement of the damages claimed and any other relief sought, including

the manner and method used to calculate any claimed damages and a

breakdown of such claimed damages; and

13. A statement of whether the parties consent to less than a unanimous verdict.

14. A list of agreed upon dates for commencement of trial in the six months

following submission of the joint pretrial order.

C. Electronic Copies of Exhibits. By the JPTO deadline, parties must also

submit (but not file on ECF): an electronic copy of each exhibit sought to be

admitted (with each filename corresponding to the relevant exhibit number—

e.g., “PX-1,” “DX-1,” etc.). The electronic copies should be submitted pursuant to

the protocol in Section II.D. 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 must be pre-marked (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.

D. Required Pretrial Filings. Each party must file on ECF within 30 days

after the filing of the JPTO, the following:

1. Motions in Limine. Each party must file a single memorandum of law,

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addressing all motions in limine filed by that party, and absent leave of Court,

subject to the word and format limitations in Sections VI.E and VI.F above.

Oppositions to the motions in limine are due no later than 14 days following

the filing of the opening brief. Replies are not permitted. No such motion

will be considered unless the moving party’s memorandum includes a

certification that, prior to filing the motion, the parties conferred, in person or

via video, in a good faith effort to resolve the issue(s) asserted in the motion

without the intervention of the Court and were unable to reach an agreement.

2. Requests to Charge; Voir Dire; Verdict Forms. In all jury cases, joint

requests to charge, joint proposed verdict forms, and joint voir dire questions

must be provided. Absent good reason, the parties should not include

proposed language for standard instructions (about, for example, the role of

the Court and the jury, the standard of proof, etc.), as the Court is likely to use

its own standard instructions; instead, the parties should include a list of

standard instructions that they believe are appropriate and focus their

attention on case-specific requests to charge. For any request to charge, voir

dire question, or verdict entry on which the parties cannot agree, each party

should clearly set forth its proposed charge or question, and briefly state why

the Court should use its proposed charge or question, with citations to

supporting authority. These documents should also be emailed to chambers

as Word documents by the deadline.

3. Pretrial Memorandum of Law. If a party believes that a pretrial

memorandum of law would be useful to the Court, it shall file such

memorandum of law on ECF. Rebuttal or reply memoranda are not

permitted, and any memorandum must comply with Section VI.

4. Deposition Materials. In any non-jury case, each party should submit via

email (but not file on ECF) all deposition excerpts which will be offered as

substantive evidence, as well as a one-page synopsis of those excerpts for

each deposition. Each synopsis must include page citations to the pertinent

pages of the deposition transcripts.

E. Witnesses. No later than the end of each trial day, counsel must notify

each other and the Court of witnesses to be called the next trial day.

F. Technology Needs. If a party wishes to use audio-visual equipment at a

hearing or trial, it is that party’s responsibility to ensure that any required

approvals are obtained and that the necessary equipment is set up and working

properly in advance of trial. The party should contact Judge Bulsara’s

Courtroom Deputy sufficiently in advance of trial to make the necessary

arrangements for a technology walkthrough and to test the equipment.

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G. Time Limits. In most civil cases, the Court will impose time limits on

both sides at the final pretrial conference. The parties’ opening statements (in

civil jury trials) and examinations of witnesses will count against their time. The

time limits do not apply to jury selection or to summations; the Court may

impose separate time limits for summations. The parties should be prepared to

address the issue of time limits at the final pretrial conference.

H. Proposed Findings of Fact and Conclusions of Law. Following a bench

trial, initial proposed findings are due 30 days following the conclusion of trial

testimony, and responsive submissions are due 14 days thereafter.

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CRIMINAL CASE PRACTICES AT A GLANCE

Individual

Issue Requirement Page

Practices

Written

Must occur via letter filed on ECF. II.A 1

Communications

Faxes Not permitted. II.A 1

Call only if parties cannot appear

due to emergency and on the day of

Telephone Calls II.B 1

the conference. Telephone calls to

Communications

chambers otherwise prohibited.

with Chambers

Ex parte communication prohibited.

Email Certain documents must be emailed II.C 1

to Chambers.

Submission of

Contact Chambers via email for

Large Electronic II.D 1

FTP link.

Files

ECF Required for all cases. III.A 2

Notices of Required in every case consistent

III.B 2

Appearance with Local Criminal Rule 1.2.

Text Searchable

Preferred for ECF filings. III.C 2

Submissions

Voir dire; jury instructions; verdict

Microsoft Word

forms should also be emailed to III.D 2

Case Related Documents

Chambers.

Filings

Required for all memoranda of law

longer than 10 pages/3500 words;

Courtesy Copies III.E 2

sentencing submissions; and 3500

material. Otherwise not required.

Sealed or Redacted Must follow procedures set forth

III.F 2–3

Filings and satisfy Lugosch test.

Unpublished Cases Copies not required. III.G 3

Initial Appearance

Handled by duty Magistrate Judge. IV.A 3

and Arraignment

Initial Status Counsel should email for

IV.B 3

Conference scheduling.

Case Scheduling

Trial Date Set at second status conference. IV.C 3

Must be made 72 hours in advance,

Request for

including for sentencing or pleas, IV.D 3–4

Adjournment

and in writing via letter-motion.

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Individual

Issue Requirement Page

Practices

Documents Plea agreement; information;

Emailed to Court waiver of indictment; and elements V.A 4

(in advance) sheet.

Pre-plea preparation strongly

Guilty Pleas Factual Allocution V.B 4

encouraged.

Documents

Executed plea agreement for filing

Emailed to Court V.C 4

under seal (no docket entry).

(following plea)

No page limits except for in limine

motions. Letters longer than 2

Page Limits and pages/700 words must be double

VI.A 4–5

Formatting spaced. 12 point font (including

footnotes) required for all

submissions.

Must comply with meet-and-confer

Letters, Motions,

Discovery Motions requirement of Local Criminal Rule VI.B 5

and Memoranda

16.1

Due no later than 45 days prior to

trial; must be consolidated briefs;

limited to 8750 words for opening

Motions in Limine VI.C 5

and response briefs and 3500 words

for reply; replies strongly

discouraged.

Requests to Charge; Due 14 days prior to trial; also must

Voir Dire; Verdict be emailed to Chambers in MS VII.A.1 5

Forms Word format.

Exhibit Lists Due 7 days prior to trial. VII.A.2 5

Electronic form due to Chambers 2

Exhibits VII.A.3 5

days prior to trial.

Trial Procedures

3500 Material Must be in hard copy. VII.A.4 6

Must be disclosed by end of each

Witnesses VII.B 6

trial day.

Parties should consult courtroom

Technology VII.C 6

deputy in advance of trial date.

21 days prior to sentencing for

Timing Defendant; 14 days prior to VIII.A 6

sentencing for Government.

Sentencing

Should be consolidated submission

Letters VIII.B 6

on ECF.

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INDIVIDUAL PRACTICES IN CRIMINAL CASES

I. SCOPE AND APPLICATION

These Individual Practices and Rules apply to all criminal cases before Judge

Bulsara. A party may seek leave, by filing a letter-motion, for a different rule or

procedure to apply to a particular case.

In computing time and deadlines set forth in these Individual Practices, parties

should consult Federal Rule of Criminal Procedure 45.

II. COMMUNICATION WITH CHAMBERS

A. Written Communications. Except as otherwise provided below, any

communication with the Court must occur via letter filed on ECF. Except for

courtesy copies, the Court does not accept hand delivery of any materials, which

must be provided to the Court Security Officers at the Central Islip Courthouse

lobby. And the Court does not accept faxes. A party making an application for

relief via letter (such as a request for an adjournment), should file the letter as a

letter-motion on ECF.

B. Telephone Calls and Case Related Inquiries. Telephone calls to

chambers are prohibited, except for emergency circumstances on the date of a

conference. Chambers should only be contacted if on the day of the conference,

the parties cannot appear due to an emergency and counsel wish to inform the

Court that an electronic application is forthcoming, in which case counsel may

contact Judge Bulsara’s deputy, Eddie Manson. Adjournment requests may not

be made telephonically.

C. Emails to Chambers. The Court’s email address is

bulsara_chambers@nyed.uscourts.gov. Any request for an adjournment, even an

emergency request, should only be made by letter, not email or telephone. The

Court does not respond to email requests or inquiries, or accept documents via

email, except for those matters detailed in these rules. Ex parte emails to

Chambers are not permitted, and absent good cause, all emails must cc: opposing

counsel.

D. Submission of Large Electronic Files. The Court has a file transfer

protocol for the safe electronic transmission of electronic files. If a party needs to

submit large files to the Court, or exhibits for trial, the party should email

Chambers indicating that they intend to submit large electronic file(s). The email

should include the name and docket number of the case and the nature of the

materials to be submitted electronically. The party should then follow the

protocol set forth here: https://evidence.nyed.uscourts.gov for submission.

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III. CASE RELATED FILINGS

A. Requirement for ECF Use. Counsel in all cases are required to register for

Electronic Case Filing (“ECF”). ECF procedures are available on the Eastern

District of New York website. Chambers staff are unable to assist with filing via

ECF. For assistance, please call the ECF helpline at (718) 613-2610. Because all

orders issued by the Court will be transmitted electronically, attorneys are

responsible for keeping their ECF registration current with the Clerk’s Office.

B. Notices of Appearance. Counsel are reminded of their obligations under

Local Criminal Rule 1.2 to file a notice of appearance in criminal cases.

C. Text searchable submissions. If feasible, each submission on ECF should

be in a text-searchable format created by converting the document electronically

to PDF by computer (that is, not by scanning a printed document).

D. Microsoft Word Documents. In addition to filing the document on ECF, a

party should provide Microsoft Word versions of proposed (a) voir dire; (b) jury

instructions; and (c) verdict forms to the Court’s email address.

E. Courtesy Copies. The parties must supply the Court with courtesy copies

of any memoranda longer than 3500 words (10 pages), sentencing submissions,

and 3500 material, all of which may be mailed to Chambers (express, overnight

or hand deliver are not required). Courtesy copies of any other material are not

required.

F. Sealed or Redacted Filings. There are limited categories of information

that may be redacted from public ECF filings without prior permission from the

Court: those items listed in Federal Rule of Civil Procedure 5.2. All other

redactions or filing seal of Court materials require Court approval. In evaluating

motions to seal, the Court applies the Second Circuit’s test set forth in Lugosch v.

Pyramid Co., 435 F.3d 110 (2d Cir. 2006). Motions for redaction or sealing should

comply with the following procedure:

1. A party seeking to file a redacted or sealed document should file a single

motion to seal that addresses every document (as separate exhibits) for which

sealing or redaction is sought.

2. A public version of the motion should attach the exhibits containing limited

redactions or an indication that the entire document is sealed, as appropriate.

A private version of the motion should be filed under seal with these same

documents unredacted in their entirety.

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3. The motion to seal should be accompanied by a memorandum of law that

explains why any material that is redacted or entirely shielded from public

view satisfies Lugosch. If the memorandum of law requires redaction, both

redacted and unredacted versions of the memorandum, the latter under seal,

should be filed.

4. Any opposition to a motion to seal must be filed within three days of the

filing of the motion to seal and follow the procedures in steps (2) through (3)

above.

Broad treatment of all documents and sweeping justifications for sealing are

inconsistent with the requirement of narrow tailoring and are unlikely to have

merit. See Brown v. Maxwell, 929 F.3d 41, 48 (2d Cir. 2019) (“[I]n contravention of

our precedent, the District Court failed to review the documents individually

and produce specific, on-the-record findings that sealing is necessary to preserve

higher values. Instead, the District Court made generalized statements about the

record as a whole. This too was legal error.” (quotations and footnotes omitted));

e.g., Gannett Media Corp. v. United States, No. 22-CV-2160, 2022 WL 17818626, at *3

(2d Cir. Dec. 20, 2022) (“[B]road findings, however, are insufficient to justify the

redactions in the Sealed Submissions.”).

G. Unpublished Cases. If a party cites to a case not available in an official

reporter, but otherwise available on Westlaw, it need not file the authority on

ECF or provide a copy to Chambers.

IV. CASE SCHEDULING

A. Initial Appearances and Arraignments. A defendant’s initial appearance

and any arraignment on an indictment (or superseding indictment) will take

place before the Magistrate Judge on duty.

B. Status Conferences. Following the assignment of a criminal case to Judge

Bulsara, the parties are directed to email chambers, cc:ing all counsel, requesting

an initial status conference.

C. Trial Dates. At the second status conference, the Court will generally set a

firm trial date. The parties should meet and confer to discuss potential trial

dates. Once a trial date has been set, it will only be adjourned in exceptional

circumstances.

D. Requests for Adjournments or Extensions of Time. Requests for

adjournments and for extensions of time—including for sentencing—must be

filed electronically as letter-motions. All requests for adjournments of a court

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conference, sentencing or plea hearing must be made in writing, and absent an

emergency, at least 72 hours prior to the scheduled appearance. All requests for

adjournments or extensions of time must state: (1) the original date and proposed

new date; (2) the reasons for the adjournment or extension; (3) whether the

application is on consent; and (4) proposed dates for the revised deadline or

conference.

V. PROCEDURES FOR GUILTY PLEAS

A. Documents in Advance of Change of Plea Hearing. The parties must

provide the Court with an electronic copy of the following documents at least

three calendar days prior to a change-of-plea hearing, and do so via email to

chambers:

1. Plea or cooperation agreement or Pimentel letter;

2. Information, if the defendant intends to plead guilty to a new charging

instrument;

3. An executed waiver of indictment form, if the defendant intends to plead

guilty to either an information or complaint; and

4. An elements sheet, that sets forth the elements of the offense to which the

defendant intends to plead guilty.

B. Preparation for Allocution. Defense counsel are expected to have

discussed the elements of the offense with their client and discuss the need to

have an narrative allocution that incorporates those elements. In the interest of

clarity and efficiency, counsel is encouraged to assist the defendant in writing an

allocution that can be read in open court during the plea proceeding.

C. Documents Following Plea Hearing. Counsel for the Government must

email Chambers with an executed copy of the plea agreement following

conclusion of the hearing and provide the document in PDF form.

VI. LETTERS, MOTIONS AND MEMORANDA

A. Page and Word Limits, Fonts, and Formatting. The Court encourages

and appreciates brevity. For criminal matters, except for motions in limine, as set

forth in in Section VI.C, the Court does not impose page or word count limits.

Any letter, motion, or submission of any kind, except for letters shorter than 700

words (2 pages) must use reasonable margins, double spacing, and a reasonable

font of 12 point or larger, including for footnotes. Case citations must contain

pinpoint cites. Legal arguments must be set forth in a memorandum of law

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rather than in affidavits, affirmations, or declarations. Any papers not

complying with these requirements will be rejected. Citations to the docket

should be made at the end of the sentence with “Docket Entry (“DE”) [docket

number].” Thereafter, any further citations to the docket may be made with a

short-cite at the end of the sentence with “DE [docket number].” Memoranda of

ten pages or more (3500 words) must contain a table of contents and a table of

authorities, neither of which shall count against any page limit.

B. Discovery Motions. All discovery motions must comply with Local

Criminal Rule 16.1 and contain a certification of the same in the motion papers.

Discovery motions should be filed as “letter-motions.”

C. Motions in Limine. Any motions in limine, including those directed at

evidentiary issues, must be filed no later than 45 days prior to the date of trial,

with any opposition due 14 days later, and any reply 7 days thereafter. Each

party must file a single consolidated memorandum of law in support of all

motions in limine filed by that party. Memoranda of law in support of and in

opposition to motions, except for letter-motions, are limited to 8750 words, and

reply memoranda are limited to 3500 words. The Court does not prohibit but

strongly discourages reply memoranda.

VII. TRIAL PROCEDURES

A. Required Pretrial Filings.

1. Requests to Charge; Voir Dire; Proposed Verdict Form. Any proposed

requests to charge, verdict forms, and voir dire questions must be filed on

ECF no later than 14 days prior to trial. Absent good reason, the parties

should not include proposed language for standard instructions (about, for

example, the role of the Court and the jury, the standard of proof, etc.), as the

Court is likely to use its own standard instructions; instead, the parties should

include a list of standard instructions that they believe are appropriate and

focus their attention on case-specific requests to charge. For any request to

charge each party should include citations to supporting authority. These

documents should also be emailed to Chambers.

2. Exhibit Lists. Any exhibit lists must be filed on ECF no later than 7 days

prior to trial, and emailed to chambers.

3. Electronic Copies of Exhibits. The parties must submit to the Court no later

than 2 days prior to trial (but not file on ECF): an electronic copy of each

exhibit sought to be admitted (with each filename corresponding to the

relevant exhibit number — e.g., “GX-1,” “DX-1,” etc.). If submission of

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Judge Bulsara Individual Practices (Criminal)

May 19, 2026

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.

4. Section 3500 Material. All 3500 Material must be provided to the Court no

later than 2 days prior to trial in hard copy, either assembled sequentially in a

binder, or in separately labelled manila folders and placed in redweld folders.

B. Witnesses. No later than the end of each trial day, counsel must notify

each other and the Court of witnesses to be called the next trial day.

C. Technology Needs. If a party wishes to use audio-visual equipment at a

hearing or trial, it is that party’s responsibility to ensure that any required

approvals are obtained and that the necessary equipment is set up and working

properly in advance of trial. A list of the technology already set-up in Courtroom

930 can be found in Attachment B. The party should contact Judge Bulsara’s

Courtroom Deputy sufficiently in advance of trial to make the necessary

arrangements for a technology walkthrough and to test the equipment.

VIII. SENTENCING

A. Timing of Submissions. A defendant’s sentencing memorandum is due

21 days prior to the date of sentencing. The Government’s sentencing

memorandum is due 14 days prior to the date of sentencing.

B. Sentencing Letters. Letters should be grouped and filed together as

attachments or exhibits to a sentencing memorandum. A defendant is

responsible for filing all letters submitted, including those from friends and

relatives.

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