Hon. Jennifer E. Willis — Individual Rules of Practice

August 2026

INDIVIDUAL PRACTICES IN CIVIL CASES1

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JENNIFER E. WILLIS, UNITED STATES MAGISTRATE JUDGE

Chambers Courtroom

United States District Court 40 Foley Square, Courtroom 228

Southern District of New York Tamika Kay, Courtroom Deputy

40 Foley Square, Room 425 (212) 805-3830

New York, NY 10007

(212) 805-0244

WillisNYSDChambers@nysd.uscourts.gov

Note on Consent Jurisdiction: If the parties wish to consent to having Judge Willis preside over

their case for all purposes, the necessary form is available at https://nysd.uscourts.gov/hon-

jennifer-e-willis. In consent cases, the Magistrate Judge assumes the role of the District Judge and

thus the right to a jury trial is preserved. Any appeal is directly to the Court of Appeals.

I. Communications with Chambers

A. Letters. Letters to the Court are permitted. Letters should be filed on ECF2 except for

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settlement conference submissions and in camera submissions. Letters may not exceed 3

single-spaced pages in length (exclusive of exhibits). Parties shall not copy the Court on

correspondence sent between counsel or the Parties.

Pro se Parties. By Standing order, a pro se party must mail all communications with the

Court to the Pro Se Intake Unit located at 500 Pearl St., Room 230, New York, NY 10007.

A pro se party may not call Chambers or send any document or filing directly to Chambers.

Submissions requiring immediate attention should be hand-delivered to the Pro Se Intake

Unit. Unless the Court orders otherwise, all communications with the Court will be

docketed upon receipt; such docketing shall constitute service on any user of the ECF

system. If any other party is not a user of the ECF System (e.g., if there is another pro se

party in the case), a pro se party must send copies of any filing to the party and include

proof of service affirming that he or she has done so. Questions can be directed to the Pro

Se Intake Unit at (212) 805-0175.

B. Letter Motions. Letter motions shall be filed on ECF in accordance with the S.D.N.Y.

Local Rules. Requests that may be made by letter motion include requests for an

adjournment, an extension, a pre-motion conference, sealing, and a settlement conference.

Letter motions are limited to 3 single-spaced pages (not including exhibits). Courtesy

copies of letter motions are not required unless exhibits, if any, exceed 25 pages.

1 Requests for reasonable accommodations on account of disability or religion with respect to the Court’s rules or in

connection with any proceeding before Judge Willis may be emailed to WillisNYSDChambers@nysd.uscourts.gov.

Counsel and parties are invited to inform the Court of their preferred pronouns.

2 ECF Rules and Instructions are available at https://www.nysd.uscourts.gov/rules/ecf-related-instructions.

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C. Requests for Adjournments or Extensions of Time. All requests for adjournments or

extensions of time must be filed on ECF as letter motions at least 2 business days before

the original deadline. The letter motion must state: (1) the original date(s); (2) the number

of previous requests for adjournment or extension; (3) the reason for the extension; and (4)

whether the adversary consents and, if not, the reasons given by the adversary for refusing

to consent. Emergency requests should be emailed to

WillisNYSDChambers@nysd.uscourts.gov and filed on the docket citing the nature of the

emergency.

D. Hand Deliveries. Hand-delivered mail should be left with the Court Security Officers at

the Worth Street entrance of 500 Pearl Street and may not be brought directly to Chambers.

E. Calendar Matters. For docketing, scheduling and calendar matters, call Chambers at

(212) 805-0244 between 9:00 AM and 5:00 PM or email Chambers at

WillisNYSDChambers@nysd.uscourts.gov.

II. Motions

A. Pre-Motion Conferences Letters in Civil Cases. In advance of filing a letter with the

Court, the Parties are expected to meet and confer regarding a briefing schedule for any

anticipated motion. Pre-motion letters seeking a conference should propose a briefing

schedule and are required where the proposed motion is returnable before Judge Willis, or

where the proposed motion has been referred to Judge Willis, except that no pre-motion

letter is required for (i) motions for admission pro hac vice, (ii) motions by litigants in

actions where a party is both pro se and incarcerated, (iii) motions for reconsideration or

reargument, (iv) motions for a new trial, (v) motions in limine, (vii) motions listed in Fed.

R. App. P. 4(a)(4)(A), (viii) motions for recusal, (ix) habeas corpus petitions, (x)

applications made by order to show cause, and (xi) Federal Rule of Civil Procedure

12(b)(6) motions to dismiss in lieu of an Answer.

Discovery Motions. Parties shall follow Local Rule 37.2, with the following

modifications. Any party wishing to raise a discovery dispute with the Court must first

confer in good faith with the opposing party, in person or by telephone, in an effort to

resolve the dispute. If the meet-and-confer does not resolve the dispute, a party may submit

a letter motion no longer than 3 single-spaced pages, explaining the nature of the dispute

and requesting a conference. Such letter motion must state when the meet-and-confer

occurred. Any responsive letter should be submitted within 3 business days after

submission of the letter motion and should be no longer than 3 single-spaced pages. Failure

to respond within 3 business days will result in a waiver of any objections. The Court will

endeavor to resolve the issue without a conference and without the need for formal briefing.

However, if formal briefing is required, the Court will either schedule a conference or set

a schedule for such briefing.

Motions other than Discovery Motions. To arrange a pre-motion conference for non-

discovery matters, the moving party shall submit a letter motion in accordance with

Individual Practice I.B. The letter motion should set forth the nature of the anticipated

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motion. Any responsive letter should be submitted within 3 business days after submission

of the letter motion.

Memoranda of Law. The typeface, margins and spacing of motion papers must conform

to Local Civil Rule 11.1. Unless prior permission has been granted, memoranda of law in

support of and in opposition to motions may not exceed 8,750 words, and reply briefs may

not exceed 3,500 words. Memoranda of 10 pages or more shall contain a table of contents

and a table of authorities, neither of which shall count against the word limit. Sur-reply

memoranda will not be accepted without prior permission of the Court. All moving papers,

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

form. Additionally, to the extent citing unreported cases, parties are requested to use

Westlaw citations whenever possible.

B. Summary Judgement Motions. At the meet and confer held before filing the letter

seeking leave to move for summary judgment, the Parties should discuss and prepare a

joint submission indicating all facts that are not in dispute. If for any reason the Parties

are unable to do so, they should submit a separate letter explaining why they should be

relieved of that obligation. Moreover, in their own briefs, the Parties should detail the facts

that they are relying upon in the facts section of their brief, and should not simply refer to

their Local Civil Rule 56.1 submissions or assume the Court has sufficient familiarity with

the facts of the case.

C. Oral Argument on Motions. Parties may request oral argument by noting such request

on their moving papers or filing a letter requesting the same. Junior members of legal

teams representing clients are invited to argue motions they have helped prepare and to

question witnesses with whom they have worked. Firms are encouraged to provide this

opportunity to junior attorneys for training purposes; a request for oral argument is more

likely to be granted if a party identifies a lawyer to argue the motion who has graduated

law school within the previous five years.

D. Electronic Device Requests. To the extent Parties or counsel need electronic devices

during any proceedings before the Court, the requesting party should complete the form at

https://nysd.uscourts.gov/sites/default/files/2020-06/Electronic%20Dev.pdf and return it

via email to Chambers, copying opposing counsel. Such electronic device request need

not be filed on the docket. Electronic device requests should be submitted by close of

business the day before any scheduled appearance.

E. Requests to File Materials Under Seal. All Confidential Materials filed with the Court

may be redacted or filed under seal only as the Court directs upon appropriate application

by either party or as required by Federal Rule of Civil Procedure 5.2, which describes

sensitive information that must be redacted from public court filings.

Any party wishing to file in redacted form any pleading, motion, memorandum, exhibit, or

other document, or any portion thereof, based on a party’s designation of information as

Confidential, must make a specific request to the Court by letter motion explaining the

reasons for seeking to file that submission under seal.

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The letter motion must be filed in public view, must explain the particular reasons for

seeking to file that information under seal, and should not include confidential information

sought to be filed under seal. Supporting papers must be filed separately and may be filed

under seal or redacted only to the extent necessary to safeguard information to be filed

under seal.

The proposed sealed document must be contemporaneously filed under seal in the ECF

system and electronically related to the letter motion. The summary docket text, but not

the sealed document, will be open to public inspection and should not include confidential

information sought to be filed under seal.

The filing party shall also (a) publicly file the document with the proposed redactions, and

(b) electronically file under seal a copy of the unredacted document with the proposed

redactions highlighted.

Any party unable to comply with the requirement for electronic filing under seal through

the ECF system, or who has reason to believe that a particular document should not be

electronically filed, must move for leave of the Court to file on paper.

The pendency of the application to seal does not affect any deadlines that may govern the

proposed filing. The parties shall comply with such deadlines by filing the redacted version

on ECF, serving the unredacted papers at issue on any opposing parties, and providing

courtesy copies of the unredacted version to Chambers.

If the Court approves the filing under seal, no further submissions shall be required. If the

Court denies, in part, the motion for filing under seal, the party who made the submission

shall be required to refile the document with modified redactions as directed by the Court.

F. Motions in Pro Se Cases. As required by Local Civil Rule 7.2, counsel must provide a

pro se litigant with printed copies of decisions cited in any submission that are reported

exclusively in computerized databases.

Where a party seeks summary judgment against a pro se litigant, the party must also

comply with the notice requirements of Local Civil Rule 56.2. Where a party moves to

dismiss or for judgment on the pleadings against a pro se litigant and refers to matters

outside the pleadings, counsel must serve and file the notice set forth in Local Civil Rule

12.1. In such situations, counsel is strongly encouraged to move in the alternative for

summary judgment so that the pro se litigant understands, based on the Local Civil Rule

56.1 submission, exactly what facts are relevant to the motion. Counsel is expected to meet

and confer and communicate with a pro se litigant in the same manner as they would other

counsel. Pro se litigants are expected to follow the Local Civil Rules, the Federal Rules

of Civil Procedure, and the Court’s Individual Practices herein.

G. Motions Requiring Submission of an Excel Sheet. When a Party submits any of the

following motions to Judge Willis, or within fourteen days of the referral of such a motion

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to Judge Willis, the moving Party shall submit an Excel sheet including the relevant

calculations. An Excel sheet is required even if the motion was already submitted to a

District Judge. Excel sheets are required for the following motions: 1) Inquests on

Damages 2) Motions for Attorney’s Fees 3) FLSA Damages 4) IDEA Reimbursements.

The Excel sheet should be emailed to WillisNYSDChambers@nysd.uscourts.gov and

should CC all opposing counsel or the pro se litigant if they are unrepresented. A letter

should also be filed on the docket providing the date and time the Excel sheet was emailed.

III. Pre-Trial Practice

A. Initial Case Management Conference. Before the Initial Case Management Conference,

parties must meet and confer on a discovery plan. One week before the scheduled

conference, the parties shall file on ECF a Proposed Case Management Plan and Report of

Rule 26(f) Meeting. Parties shall use the template available at

https://nysd.uscourts.gov/hon-jennifer-e-willis.

If any party is pro se, parties shall use the Proposed Case Management Plan for Pro Se

Cases template available at https://nysd.uscourts.gov/hon-jennifer-e-willis. The pro se

party should submit the Proposed Case Management Plan for Pro Se Cases to the Pro Se

Intake Unit and the represented party should submit it via ECF and simultaneously mail a

copy to the pro se party.

Lead counsel for the parties are expected to attend the Initial Case Management

Conference. Reasonable accommodations will be made for parties or their counsel who

cannot attend in person on account of disability. An incarcerated party who is unable to

attend this or other conferences will be able to participate by telephone or video.

B. Case Management Conferences. The Court shall hold regular case management

conferences. Counsel are expected to be prepared for such conferences and ready to

discuss the status of discovery, the potential for settlement, and any other issues. Junior

members of legal teams are invited to address the Court at case management conferences.

Firms are encouraged to provide this opportunity to junior attorneys for training purposes.

C. Deposition Disputes. If a dispute arises during a deposition, the Parties should attempt to

proceed through as much of the deposition as possible that is unaffected by the dispute.

Parties should not unilaterally terminate a deposition and the Court expects good faith

efforts to resolve any disputes. After doing so, if the dispute cannot be resolved, the Parties

should jointly contact the Court at (212) 805-0244. Chambers staff will take a message

summarizing the dispute and check to see if Judge Willis is available to resolve the issue

either through a video conference or a written order.

D. Confidentiality Stipulations and Orders. In cases where confidential information will

be exchanged, the parties may utilize the Court’s model Protective Order, available at

https://nysd.uscourts.gov/hon-jennifer-e-willis. Should the parties apply for a protective

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order that differs from the Court’s model, the parties should attach the proposed order

showing a comparison of how the proposed order differs from the Court’s model.

E. Electronic Discovery. The parties may utilize the model ESI Plan and Proposed Order, as

appropriate, available at https://nysd.uscourts.gov/hon-jennifer-e-willis. The model may

be modified to the extent appropriate for the case. The Parties should endeavor to agree

on an ESI Plan as early as possible in the case.

F. Hearing Transcripts. When applicable, parties shall coordinate the ordering of a hearing

transcript from the court reporter. The ordering party shall send a courtesy copy of the

transcript to Chambers via email. Pro se parties are exempt from this Rule.

IV. Pretrial Procedures

The following procedures apply only to those cases where the parties have consented

under 28 U.S.C. § 636(c) to have all proceedings, including trial, before Judge Willis.

A. Joint Pretrial Orders in Civil Cases. Unless otherwise ordered by the Court, within 30

days from the date of completion of discovery in a civil case, the parties shall submit to the

Court for its approval a Joint Pretrial Order. In general, except in pro se cases, a Joint

Pretrial Order shall include the following:

a. The full caption of the action;

b. The name, address, telephone number and email of each principal member of the

trial team;

c. A list of each claim and defense that will be tried and identification of the governing

law (including applicable regulations) governing each such claim and defense;

d. If applicable, a list of any claims and defenses asserted in the pleadings that are not

to be tried;

e. A list by each party of its trial witnesses that it, in good faith, expects to present,

with an indication of whether the witnesses will testify in person or by deposition

and the general subject area of the witness’s testimony and anticipated length of

time needed for each witness;

f. A statement as to how and when the parties will give notice to each other of the

order of their trial witnesses and, if the parties cannot agree, the parties’ statement

that they will agree to the Court’s default rule (i.e. that the parties shall advise each

other by no later than 48 hours before the start of trial as to the order of their

witnesses);

g. A list by each party of exhibits that it, in good faith, expects to offer in its case in

chief, together with any specific objections thereto;

h. All stipulations or statements of fact or law on which the parties have agreed;

i. A proposed schedule by which the parties will exchange demonstratives that the

parties intend to use at trial, notify each other of any objections thereto, consult

with each other regarding those objections, and notify the Court of any remaining

disputes;

j. Proposed voir dire questions;

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k. Proposed jury instructions;

l. Proposed verdict sheet;

m. The estimated length of trial; and

n. All other matters that the Court may have ordered or that the parties believe are

important to the efficient conduct of the trial, such as bifurcation or sequencing of

issues to be tried, anticipated in limine motions, and any technology needed for

trial.

In pro se cases, no Joint Pretrial Order is needed. Instead, within 30 days after the

completion of discovery each party shall file its own Pretrial Statement. The pro se party’s

Pretrial Statement need take no particular form, but must be concise and contain: (1) a

statement of the facts the party hopes to prove at trial; (2) a list of all documents or other

physical objects that the party plans to put into evidence at trial; and (3) a list of the names

and addresses of all witnesses the party intends to have testify at trial. The Statement must

be sworn by the party to be true and accurate based on the facts known by the party. The

party must file an original Pretrial Statement with the Pro Se Office and serve a copy on

all other parties or their counsel if represented. The original Pretrial Statement must

indicate the date a copy was mailed to the other party or that party’s attorney.

B. Courtesy Copies of Trial Exhibits. The parties shall each send a courtesy copy of all

exhibits, pre-marked, to WillisNYSDChambers@nysd.uscourts.gov. Exhibits need not be

filed electronically on ECF. The parties shall also each submit one hard copy of the pre-

marking exhibits in a well-organized three-ring binder, separated by tab dividers.

V. Settlement Conferences

The parties shall refer to the Court’s Standing Order for All Cases Referred for Settlement to

Magistrate Judge Jennifer E. Willis, available at https://nysd.uscourts.gov/hon-jennifer-e-willis,

for applicable guidelines.

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