Hon. John P. Cronan — Individual Rules of Practice

Revised

October 23, 2025

INDIVIDUAL RULES AND PRACTICES IN CIVIL CASES

JOHN P. CRONAN

UNITED STATES DISTRICT JUDGE

SOUTHERN DISTRICT OF NEW YORK

Chambers Courtroom

United States District Court Courtroom 12D

Southern District of New York 500 Pearl Street

500 Pearl Street, Room 1320 Meghan Henrich, Courtroom Deputy

New York, NY 10007

CronanNYSDChambers@nysd.uscourts.gov

Unless otherwise ordered by the Court, these Individual Rules and Practices shall apply to

all civil matters before Judge Cronan, except for civil cases involving pro se litigants.

1. Communications with Chambers

A. Letters. Except as otherwise provided below, communications with Chambers shall

be by letter, with copies simultaneously delivered to all counsel. Letters to the Court on behalf of

parties represented by counsel must be both docketed on ECF and e-mailed as a .pdf attachment

to the following address: CronanNYSDChambers@nysd.uscourts.gov. Counsel shall not provide

a hard copy of correspondence e-mailed to Chambers. Letters seeking relief should (if consistent

with the S.D.N.Y. Local Rules and the S.D.N.Y. ECF Rules and Instructions) be filed on ECF as

letter-motions, not as ordinary letters. Any response to a letter or letter-motion shall be filed within

two business days of the filing of the letter or letter-motion.

Counsel shall include the case caption and docket number in the subject line of every e-

mail sent to Chambers. All letters should be text-searchable where practicable. Unless otherwise

ordered by the Court, letters may not exceed three pages in length (single-spaced, 12-point font).

Letters to be filed under seal or containing sensitive or confidential information must be filed in

accordance with 4.A-B below. Copies of correspondence between counsel shall not be sent to the

Court or docketed on ECF, except if the correspondence is a relevant attachment to a filing.

B. Telephone Calls. For questions that cannot be answered by reference to these Rules

or the S.D.N.Y. Local Rules, or for docketing, scheduling, and calendar matters, counsel may

contact the Courtroom Deputy, Meghan Henrich. For situations requiring immediate attention

from the Court, counsel should call Chambers directly; in such situations, parties should email the

Chambers inbox requesting the Court’s contact information.

C. Faxes. Faxes to Chambers are not permitted.

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

at the Worth Street entrance of the Daniel Patrick Moynihan United States District Courthouse at

500 Pearl Street, New York, NY 10007 and may not be brought directly to Chambers. If the hand-

delivered letter is urgent and requires the Court’s immediate attention, the party should ask the

Court Security Officers to notify Chambers that an urgent package has arrived that needs to be

retrieved by Chambers staff immediately.

2. Rules for All Filings

A. Electronic Case Filing (“ECF”). In accordance with the S.D.N.Y. ECF Rules and

Instructions, all counsel must register promptly as ECF filers after being retained or assigned and

to enter an appearance in the case. Counsel can obtain instructions on how to register at

http://www.nysd.uscourts.gov/ecf_filing.php. Counsel are responsible for updating their contact

information on ECF, should it change, and they are responsible for checking the docket sheet

regularly, regardless of whether they receive an ECF notification of case activity.

If an ECF submission requires immediate attention from the Court, counsel should notify

Chambers by telephone after filing the submission via ECF.

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

practicable.

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

conform to Local Civil Rule 7.1(b). Unless prior permission has been granted, memoranda of law

in support of and in opposition to motions are limited to 8,750 words, and reply memoranda are

limited to 3,500 words. These limits do not include the caption, any index, table of contents, table

of authorities, signature blocks, or any required certificates, but do include material contained in

footnotes or endnotes. Memoranda of 10 pages or more shall contain a table of contents and a

table of authorities, and all memoranda must include a certificate by the attorney, or party who is

not represented by an attorney, that the document complies with the word-count limitations. These

limits do not apply to motions for reconsideration under Local Civil Rule 6.3; parties should refer

to that provision for applicable word or page limits and other information. Sur-reply memoranda

will not be accepted without prior permission of the Court. Motion papers shall be filed promptly

after service.

C. Unpublished Cases. Westlaw or Lexis citations shall be provided, if available, to cases

not available in an official reporter. Parties must provide copies of cases that are not available on

Westlaw or Lexis.

D. Courtesy Copies. Regarding all pleadings, correspondence, and motion papers,

including exhibits submitted in connection with a motion, a party shall submit an electronic

courtesy copy via e-mail to Chambers at the time the papers are served. Paper courtesy copies

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may be submitted only upon request from the Court. Courtesy copies should be marked as such

and shall be submitted to Chambers for both ECF and non-ECF designated cases.

Electronic courtesy copies of proposals for the Court to enter, including proposed orders

to show cause, temporary restraining orders, preliminary injunctions, stipulations, consent orders,

and default judgments, should be sent in both Microsoft Word and PDF formats.

E. Use of Artificial Intelligence (“AI”) Tools. Counsel is responsible for providing the

Court with complete and accurate representations of the record, the procedural history of the case,

and any cited legal authorities. All litigants are responsible for verifying the accuracy of any

output produced in whole or in part by an AI tool. Any attorney who signs a filing for which an

AI tool was used to prepare (including by appearing on the signature block of the filing) must

attach to the filing a signed certification (i) stating whether the litigant personally reviewed the

filing for accuracy of cited legal authorities and factual assertions and (ii) if so, describing in detail

the steps taken to verify the accuracy of all legal authorities and factual assertions generated by

the AI tool. An attorney who signs an AI-assisted filing, yet fails to review that filing for accuracy

or to provide the required certification, violates this Rule. The Court may impose sanctions on

counsel and/or strike the filing for failing to comply with this Rule. A model certification may be

found on the Court’s website (https://www.nysd.uscourts.gov/hon-john-p-cronan).

3. Rules for Specific Types of Filings

A. Complaints. Plaintiffs shall ensure that a copy of the operative complaint is posted

electronically to the docket on the ECF system. This requirement applies to all cases, including

removed cases. There is no need to submit courtesy copies of pleadings, unless immediate relief

is sought (e.g., a temporary restraining order).

If a party files an amended pleading, a courtesy copy of the pleading, in redline form to the

most recent operative pleading, shall be provided to the Court via email.

B. Requests for Adjournments or Extensions of Time. Requests for adjournments,

extensions of time, and extensions of word lengths in memoranda shall be made by letter, and not

by stipulation sent through the Orders and Judgments Clerk. Requests for adjournments or

extensions of time shall be filed on ECF as letter-motions, not as ordinary letters. All requests for

adjournments or extensions of time must state (1) the original date(s) set for the appearance or

deadline(s) and the new date(s) requested; (2) the reason(s) for the request; (3) the number of

previous requests for adjournment or extension; (4) whether these previous requests were granted

or denied; and (5) whether opposing counsel consents, and, if not, any reasons given by opposing

counsel for refusing to consent. If the requested adjournment or extension affects any other

scheduled dates or deadlines, a proposed Revised Case Management Plan and Scheduling Order

(reflecting only business days) must be attached.

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Absent compelling circumstances, a request for an extension or adjournment must be made

at least 48 hours (i.e., two business days) prior to the scheduled appearance or deadline. Requests

for extensions will ordinarily be denied if made after the expiration of the original deadline.

Requests for extensions of deadlines regarding a matter that has been referred to a Magistrate

Judge shall be directed to that assigned Magistrate Judge.

If a party seeks to extend the discovery deadlines for a case, the request must include (1) a

description of what discovery has already been completed; (2) a description of what discovery

remains to be taken; (3) why discovery was not completed by the time provided in the Case

Management Plan; and (4) why “good cause” exists to modify the scheduling order under Federal

Rule of Civil Procedure 16(b)(4). The Court requires a showing of good cause to modify a

previously set discovery deadline and failure to comply with this requirement will result in denial

of the request. Parties should not assume that such requests will be granted as a matter of course.

C. Related and Consolidated Cases. 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]). 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.

D. Certificates of Default. A party that intends to seek a certificate of default pursuant

to Rule 55(a) of the Federal Rules of Civil Procedure and Local Civil Rule 55.1 must notify the

Court of its intent to do so by filing a letter pursuant to 1.A above at least two business days before

filing for such a request with the Clerk of Court.

E. Default Judgments. A party seeking a default judgment must proceed by filing a

motion for default judgment on ECF pursuant to Rule 55(b)(2) of the Federal Rules of Civil

Procedure and Local Civil Rule 55.2(a)(2). A party seeking a default judgment must also file the

following materials, in addition to those specified in Local Civil Rule 55.2:

i. The required affidavit under Local Civil Rule 55.2(a)(1) with the following,

additional information:

a. the basis for entering a default judgment, including if appropriate a

description of the method and date of service of the summons and

complaint;

b. the procedural history beyond service of the summons and

complaint, if any;

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c. whether, if the default is applicable to fewer than all of the

defendants, the Court may appropriately order a default judgment

on the issue of damages prior to resolution of the entire action; and

d. if the party believes an inquest into damages is unnecessary, the

legal authority for that position;

ii. Copies of all the operative pleadings; and

iii. A copy of the Affidavit of Service of the summons and complaint.

The party must file the Affidavit of Service specified in Local Civil Rule 55.2(a)(3) on

ECF within two business days of filing the motion for default judgment. The Court will not

consider the motion for default judgment unless and until such Affidavit of Service is filed. If

more than two business days are required to complete service of the motion for default judgment

and supporting papers, the party should file a letter on ECF explaining why additional time is

necessary and when the party anticipates service will be completed. The Court will set deadlines

for opposition papers to default judgment and for any reply, and will schedule a hearing on the

default judgment motion.

F. Voluntary Dismissals. A plaintiff seeking to dismiss an action pursuant to Rule

41(a)(1)(A)(i) of the Federal Rules of Civil Procedure must file a notice of dismissal with the

Court. Parties seeking to dismiss an action under Rule 41(a)(1)(A)(ii) must file a stipulation of

dismissal signed by all parties who have appeared in the action, regardless of whether those parties

have been dismissed from the case. A stipulation of dismissal under Rule 41(a)(1)(A)(ii) must

contain handwritten signatures, not electronic signatures, of the parties. Neither a dismissal under

Rule 41(a)(1)(A)(i) nor Rule 41(a)(1)(A)(ii) requires an order from the Court. If the parties are

requesting dismissal pursuant to Rule 41(a)(2), however, the submission should contain a date and

signature line for the Court to “So Order.”

G. Settlement Agreements. The Court will not retain jurisdiction to enforce confidential

settlement agreements. If the parties wish the Court to retain jurisdiction to enforce a settlement

agreement, the parties must place the terms of their settlement agreement on the public record.

The parties may do this by providing a copy of the settlement agreement for the Court to endorse,

attaching the settlement agreement to their stipulation of settlement and dismissal, or including the

terms of their settlement agreement in their stipulation of settlement and dismissal.

H. Fair Labor Standards Act (“FLSA”) Settlement Agreements. Parties that seek to

settle FLSA claims through a stipulated dismissal with prejudice pursuant to Federal Rule of Civil

Procedure 41(a)(1)(A)(ii) must submit the settlement agreement and all other necessary

information for Court approval in accordance with Cheeks v. Freeport Pancake House, Inc., 796

F.3d 199 (2d Cir. 2015). The Court will not approve a settlement agreement that contains an overly

broad release clause or for which the parties fail to submit all necessary information, including,

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inter alia, the parties’ estimations for the plaintiff’s number of hours worked, applicable wages,

and a detailed breakdown of the justification for any requested attorneys’ fees. See, e.g.,

Fernandez v. 219 Dominican Valle Corp., No. 19 Civ. 9513 (JPC), 2021 WL 240721, at *2-4

(S.D.N.Y. Jan. 25, 2021). Parties that settle FLSA claims through a Federal Rule of Civil

Procedure 68(a) offer of judgment should not seek Court approval of the disposition. See Mei Xing

Yu v. Hasaki Rest., Inc., 944 F.3d 395, 411 (2d Cir. 2019).

I. Bankruptcy Appeals. Briefs must be submitted in accordance with Rules 8014-8018

of the Federal Rules of Bankruptcy Procedure. If the parties wish to extend these dates, they must

submit a joint request to the Court no later than 48 hours (i.e., two business days) before the brief

is due.

J. Deposition Transcripts. If the parties cite to deposition transcripts in their motion

papers, the parties, upon completion of briefing, must confer and submit a single consolidated copy

of each cited deposition transcript to the Court that includes all relevant portions of the cited

transcripts.

4. Redactions and Sealed Filings

A. Redactions Not Requiring Court Approval. Nothing herein is intended to alter or

modify the applicability of Rule 5.2 of the Federal Rules of Civil Procedure. The redactions

expressly authorized by Rule 5.2 may be made without application to the Court.

B. Procedures for Filing Sealed or Redacted Documents. Except for redactions

referenced in 4.A above, all redactions or sealing of public court filings require Court approval.

Any party seeking to file a document under seal or in redacted form shall proceed as follows:

i. Meet and Confer. The party seeking leave to file a document under seal

or in redacted form shall meet and confer with all other parties in the case

(as well as any third party seeking confidential treatment of the information)

in advance to narrow the scope of the request. In general, however, the

parties’ consent or the fact that information is subject to a confidentiality

agreement or protective order between litigants is not, by itself, a valid basis

to overcome the presumption in favor of public access to judicial

documents. See, e.g., In re Gen. Motors LLC Ignition Switch Litig., No. 14-

MD-2543 (JMF), 2015 WL 4750774, at *4 (S.D.N.Y. Aug. 11, 2015).

ii. Filing Sealed or Redacted Documents. Where a party seeks leave to file

a document under seal or in redacted form, the party shall file a letter-

motion seeking leave to do so on ECF in accordance with Standing Order

19-MC-583 and Section 6 of the S.D.N.Y. ECF Rules and Instructions. The

letter-motion itself shall be filed in public view, should explain the reasons

for seeking to file the document under seal or in redacted form, and should

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not include confidential information. Any application to file a document

under seal or in redacted form must demonstrate that the standards for

sealing have been met and specifically address Lugosch v. Pyramid Co. of

Onondaga, 435 F.3d 110 (2d Cir. 2006) and any other controlling authority.

The movant also may file a memorandum of law and an affidavit or

affidavits in support of the request for sealing or redacting. If approval for

redactions is sought, the application shall also include a proposed redacted

version of the document in question for public docketing.

When a party seeks leave to file a document under seal or in redacted form

on the ground that an opposing party or third party has requested it, the

opposing party or third party must file publicly on ECF, within three

business days, a letter explaining the need to seal or redact the document.

In the event there are grounds for sealing or redacting that cannot be

publicly disclosed, a party may file under seal on ECF (with appropriate

level of restriction) additional briefing further explaining those grounds,

along with a justification for the sealing of that briefing.

The subject document, in unredacted form, shall be contemporaneously

filed under seal on ECF (with the appropriate level of restriction) and

electronically related to the motion (or to the relevant Court order if the

Court previously granted leave to file the document under seal). Note that

the summary docket text, but not the document itself, will be open to public

inspection and therefore should not include confidential information sought

to be filed under seal.

When a party seeks to file a document in redacted form, the party also shall

e-mail to Chambers (CronanNYSDChambers@nysd.uscourts.gov) and to

the Courtroom Deputy, Meghan Henrich (Meghan_Henrich@nysd.uscourt

s.gov) an unredacted copy of the document highlighting the proposed

redactions.

iii. Submission by Alternative Method. Any party unable to comply with the

requirements for electronic filing under seal through the ECF system, or

who believes that a particular document should not be electronically filed

at all, may submit a letter-motion by e-mail seeking leave of the Court to

file in a different manner.

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5. Conferences

A. Attendance by Principal Trial Counsel. Absent leave of the Court, the attorney who

will serve as principal trial counsel must appear at all conferences with the Court. Any attorney

appearing before the Court must enter a notice of appearance on ECF.

B. Initial Case Management Conference. The Court will generally schedule a

conference pursuant to Rule 16(c) of the Federal Rules of Civil Procedure within three months of

the filing of the complaint or notice of removal. The Notice of Initial Case Management

Conference will be filed on ECF.

Plaintiff’s counsel is responsible for ensuring that all parties have received copies of the

Notice of Initial Case Management Conference. The Notice will direct the parties, inter alia, to

submit on ECF a joint letter as well as a proposed Civil Case Management Plan and Scheduling

Order attached as an exhibit to the joint letter. The parties shall use the form Proposed Case

Management Plan and Scheduling Order available at the Court’s website.

C. Discovery Disputes. Parties must follow Local Civil 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 this meet-and-confer process does not resolve the dispute, a party may raise the dispute with the

Court by filing a letter-motion on ECF, no longer than three pages, explaining the nature of the

dispute. Such a letter must include a representation that the meet-and-confer process occurred and

was unsuccessful. A party opposing the relief sought must file a response, not to exceed three

pages, within three business days. The Court will seek to resolve discovery disputes quickly, by

order or at an in-person or telephonic conference. Counsel are strongly urged to seek relief in

accordance with these procedures in a timely fashion. If a party waits until near the close of

discovery to raise an issue that could have been raised earlier, the Court is unlikely to grant

additional time for discovery.

6. Motions

A. Pre-Motion Letters in Civil Cases. Unless otherwise ordered by the Court, a party

seeking to file a motion must submit a pre-motion letter in accordance with 1.A above, not to

exceed three pages in length absent leave of the Court, notifying the Court of its anticipated motion,

summarizing the basis for the anticipated motion, and proposing a briefing schedule. All parties

served with the pre-motion letter must submit a letter response, also not to exceed three pages

absent leave of the Court, within three business days from the submission of the pre-motion letter.

Response letters may address arguments raised in the pre-motion letter, propose an alternative

briefing schedule, and indicate whether the party intends to oppose the contemplated motion or

intends to correct any possible deficiencies in lieu of motion practice, such as by filing, or seeking

leave to file, an amended complaint. A party’s submission of a pre-motion letter in connection

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with a pre-answer motion to dismiss will stay that party’s obligation to answer or move against the

complaint through the deadline to move to dismiss.

The above requirements shall not apply to motions previously authorized by the Court,

discovery motions or disputes (for which parties shall follow 5.C above), motions brought by order

to show cause, motions by incarcerated pro se litigants, motions for admission pro hac vice,

motions for reargument or reconsideration, motions for appointment of lead plaintiffs and counsel

in class actions, motions for remand, motions for a preliminary injunction, motions brought

pursuant to Local Rule 6.3, and motions described in Rule 6(b) of the Federal Rules of Civil

Procedure and Rule 4(a)(4)(A) of the Federal Rules of Appellate Procedure.

In the event a plaintiff files an amended complaint as of right pursuant to Rule 15(a)(1) of

the Federal Rules of Civil Procedure after a defendant has filed a motion to dismiss, that defendant

must file a letter with the Court within one week of the amendment, describing whether the

defendant seeks to refile the motion as to the amended complaint.

B. Filing of Motion Papers. Motion papers shall be filed promptly after service.

C. Oral Argument on Motions. Parties may request oral argument by letter at the time

their moving, opposing, or reply papers are filed. Oral argument will be held at the Court’s

discretion. If the Court determines that argument will be heard, the Court will advise counsel of

the argument date and time. Where junior lawyers are familiar with the matter under consideration,

but are not experienced in arguing before a court, they should be encouraged to actively participate.

If oral argument is granted, the Court is amendable to permitting more than one lawyer to argue

for a party, especially where it creates an opportunity for a junior lawyer to argue.

7. Pretrial Procedures in Civil Cases

A. Courtesy Copies. One courtesy copy of each submission described in 7.B–G below

should be provided to Chambers on the date that the submission is filed or served.

B. Joint Proposed Pretrial Orders. Unless otherwise ordered by the Court, within 30

days after the close of discovery or if any dispositive motion is filed, within 30 days from the

Court’s decision on such motion, the parties shall file on ECF a proposed joint pretrial order that

includes the information required by Rule 26(a)(3) of the Federal Rules of Civil Procedure and the

following:

i. The full caption of the action;

ii. The names, addresses (including firm names), telephone numbers, e-mail

addresses, and any fax numbers of trial counsel;

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iii. A brief statement by the plaintiff (or, in a removed case, by the defendant)

as to the basis of subject matter jurisdiction and a brief statement by each

other party as to the presence or absence of subject matter jurisdiction, each

of which shall include citations to all authority relied on and relevant facts

as to citizenship and jurisdictional amount;

iv. A brief summary by each party of the claims and defenses that the party has

asserted that remain to be tried—without recital of evidentiary matters but

with citations to all statutes on which the party has relied—and of any

claims and defenses that the party has previously asserted that are not to be

tried;

v. 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;

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

jurors during jury selection;

vii. A list of people, places, and institutions that are likely to be mentioned

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

selection;

viii. A statement as to whether all parties have consented to a trial of the case by

a magistrate judge, without identifying which party or parties have or have

not so consented;

ix. Any stipulations of fact or law that have been agreed upon by the parties.

In a jury case, the parties should memorialize any such stipulations or

agreed statements of fact or law in a standalone document that can be

marked and admitted at trial;

x. A list of all trial witnesses, indicating whether such 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 of the

Court, a witness listed by both sides shall testify only once, with any

defendant permitted to go beyond the scope of the direct examination on

cross examination, and counsel should confer with respect to scheduling;

xi. A designation by each party of deposition testimony to be offered in the

party’s case-in-chief, with any cross-designations and objections by any

other party. For any deposition with objections, the parties shall also

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provide the full transcript of that deposition, unless otherwise ordered by

the Court;

xii. A list by each party of exhibits to be offered in the party’s case-in-chief. If

a party objects to an exhibit, the objection should be noted by indicating 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”) as well;

xiii. 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 the elements of such claimed damages; and

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

C. Required Pretrial Filings in Jury Cases. Unless otherwise ordered by the Court, in

jury cases, the parties shall jointly file the following submissions at the same time as the Joint

Proposed Pretrial Order. The parties must meet and confer in an effort to reach agreement with

respect to these submissions:

i. Joint proposed voir dire questions—a copy of which shall be e-mailed to

Chambers in Word and .pdf versions—which shall include the text of any

requested questions and should consist of a single document that notes any

areas of disagreement between the parties;

ii. A joint proposed verdict form—a copy of which shall be e-mailed to

Chambers in Word and .pdf versions—and which should consist of a single

document that notes any areas of disagreement between the parties;

iii. Joint proposed jury instructions—a copy of which shall be e-mailed to

Chambers in Word and .pdf versions—and which shall include the text of

any requested instructions and citations, if relevant, to the authority from

which such instruction derives, and should consist of a single document that

notes any areas of disagreement between the parties;

iv. Motions addressing any evidentiary or other issues that should be resolved

in limine, with oppositions to such motions due one week after the lead

motions and no replies allowed absent leave of the Court; and

v. In cases in which a party believes it would be useful to the Court, a pretrial

memorandum of law, not to exceed 3,500 words (excluding the caption, any

index, table of contents, table of authorities, signature blocks, or any

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required certificates, but including material contained in footnotes or

endnotes) absent leave of the Court, addressing any issues of law that are

expected to arise at or before trial, with any responses or oppositions to

those legal issues due one week later.

D. Required Pretrial Filings in Non-Jury Cases. Unless otherwise ordered by the Court,

in non-jury cases, the parties shall file the following submissions at the same time as the Joint

Proposed Pretrial Order:

i. Joint proposed findings of fact and conclusions of law—a copy of which

shall be e-mailed to Chambers in .pdf 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;

ii. Motions addressing any evidentiary or other issues that should be resolved

in limine, with oppositions to such motions due one week after the lead

motions and no replies allowed absent leave of the Court; and

iii. In cases in which a party believes it would be useful to the Court, a pretrial

memorandum of law, not to exceed 3,500 words (excluding the caption, any

index, table of contents, table of authorities, signature blocks, or any

required certificates, but including material contained in footnotes or

endnotes) absent leave of the Court, addressing any issues of law that are

expected to arise at or before trial, with any responses or oppositions to

those legal issues due one week later.

E. Additional Submissions in Non-Jury Cases. In addition, at the time the Joint Pretrial

Order is filed, each party shall serve the following submissions, one courtesy copy of which the

party shall also submit to Chambers:

i. Affidavits—the originals of which shall be marked as exhibits at trial—

constituting the direct testimony of each trial witness, except for testimony

of an adverse party, a person whose attendance must be compelled by

subpoena, or a person for whom a party has requested and from whom the

Court has agreed to hear direct testimony during the trial; and

ii. All deposition excerpts that will be offered as substantive evidence, as well

as a one-page synopsis of those excerpts for each deposition (with citations

to the pertinent pages of the deposition transcript).

F. Courtesy Copies of Documentary Evidence. All exhibits must be pre-marked in

advance of trial. Unless otherwise ordered by the Court, in both jury and non-jury trials, three

days prior to trial, each party shall submit to Chambers a flash drive containing electronic copies

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of all documentary exhibits organized by exhibit number and a document listing all exhibits sought

to be admitted. The list of all exhibits sought to be admitted shall be separated into four columns

labeled: (1) Exhibit Number; (2) Description (of the exhibit); (3) Date Identified; and (4) Date

Admitted. If the number of exhibits is so voluminous as to make compliance with this rule

impractical, the parties shall contact the Court for guidance.

8. Policy on the Use of Electronic Devices

A. 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.

B. Mobile Phones. 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.

* * *

If you have any questions after reading these Individual Rules and Practices, please contact

Meghan Henrich, Courtroom Deputy.

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