Hon. Ona T. Wang — Individual Rules of Practice

Individual Practices in Civil Cases

Ona T. Wang, United States Magistrate Judge

Chambers Courtroom

United States District Court Daniel Patrick Moynihan Courthouse

500 Pearl Street 500 Pearl Street, Courtroom 20D

New York, NY 10007 New York, NY 10007

Wang_NYSDChambers@nysd.uscourts.gov

Civil cases come before magistrate judges in one of two ways: for one or more specific

purposes pursuant to an order of reference by the assigned district judge, or, on

consent of the parties, for all purposes pursuant to 28 U.S.C. § 636(c). When a district

judge approves an all‐purposes consent form signed by counsel and/or self‐represented

parties, the magistrate judge assumes the role of the district judge and may conduct all

proceedings. The right to a jury trial is preserved, and any appeal is directly to the Court

of Appeals.

It is the uniform practice of the magistrate judges in the Southern District of New York

to schedule trials in civil consent cases for firm dates, rather than requiring counsel to

be available for trial on short notice. Additionally, because magistrate judges rarely try

criminal cases, such firm trial dates are unlikely to be changed to accommodate criminal

trials.

Unless otherwise ordered by Judge Wang, civil matters before her shall be conducted in

accordance with the following practices.1 These practices are applicable to cases before

Judge Wang if the matter is within the scope of the District Judge’s order of reference or

if the parties consent to magistrate judge jurisdiction for all purposes pursuant to

28 U.S.C. § 636(c). Should the parties wish to have Judge Wang hear their case for all

purposes, the necessary form is available at: https://nysd.uscourts.gov/hon‐ona‐t‐wang.

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

in connection with any proceeding before Judge Wang may be emailed to:

Wang_NYSDChambers@nysd.uscourts.gov.

United States Magistrate Judge Ona T. Wang

Individual Practices in Civil Cases

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April 9, 2025

I. Guidelines for All Submissions.

a. Text Searchable Submissions. If feasible, every submission should be in text‐searchable

format created by converting the document electronically to .pdf by computer (that is,

not by scanning a printed document). If a .pdf is created by scanning a printed

document (for instance, in the case of a pre‐existing documentary exhibit), the party

should use software to make the document text searchable whenever possible.

b. Amended or Corrected Filings. Any amended or corrected filing (including but not

limited to amended pleadings) shall be filed with a redline showing all differences

between the original and revised filing. Any motion to amend a pleading shall similarly

be filed with a redline showing all differences between the operative pleading and the

proposed amended pleading.

c. Submission of Large Electronic Files. The Court has a file transfer protocol for the safe

electronic transmission of large files. If a party needs to submit large files by email (as

opposed to ECF), the party should email Chambers (at

Wang_NYSDChambers@nysd.uscourts.gov) requesting a link to be used for such

transfer. The email should include the name and docket number of the case and the

nature and size of the materials to be submitted electronically.

II. Communications with Chambers.

a. Letters. In general, communications with the Court should be by letter filed on the

docket.

Represented Parties. Letters which the Court has specifically directed be emailed

directly to Chambers should be emailed as a .pdf attachment to

Wang_NYSDChambers@nysd.uscourts.gov. E‐mails shall state in the subject line: (1)

the caption of the case, including the lead party names and docket number, and (2)

a brief description of the contents of the attachment. Confidential information

should be clearly indicated as such in the letter. Counsel must serve pro se parties

with a paper copy of any document that is filed electronically or emailed and must

separately file proof of service with the Court. No courtesy copies to the Court are

necessary. This rule does not apply to ex parte settlement correspondence, which

is governed by the rules set forth below in § VII.

Pro se/Self‐Represented Parties. By Standing Order, any pro se party who does not

participate in Electronic Case Filing (“ECF”) must either (1) mail or hand deliver all

communications with the Court to the Pro se Intake Unit located at 500 Pearl Street,

Room 230, New York, NY 10007 or (2) email their correspondence in .pdf format to

ProSe@nysd.uscourts.gov, including the docket number and case in the subject line of

the cover email. Pro se parties may not call Chambers or send any document or filing

directly to Chambers. Submissions requiring immediate attention should be hand‐

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delivered to the Pro se Intake Unit. Unless the Court orders otherwise and except for

the Proposed Case Management Plan, 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. Copies of

correspondence between a pro se party and opposing parties shall not be sent to the

Court.

Any nonincarcerated pro se party who wishes to participate in electronic case filing

(“ECF”) must file a Motion for Permission for Electronic Case Filing, available in the

Pro se Intake Unit or at https

//nysd.uscourts.gov/node/844.

Any nonincarcerated pro se party who wishes to receive documents in their case

electronically (by e‐mail) instead of by regular mail may consent to electronic service

by filing a Pro se (Nonprisoner) Consent & Registration Form to Receive Documents

Electronically, available in the Pro se Intake Unit or at

https://nysd.uscourts.gov/node/845.

Word/Page Limit. Whether filed electronically or not, letters may not exceed 1,500

words, with single‐spaced text (exclusive of exhibits, headings, captions, and

signatures). If filed by a party not represented by an attorney and handwritten, letters

may not exceed 5 pages.

Letters solely between parties or their counsel or otherwise not addressed to the

Court may not be filed on ECF or otherwise sent to the Court (except as exhibits to an

otherwise properly filed document).

b. Letter Motions. Letter motions must be filed by ECF in accordance with the S.D.N.Y.

Local Rules and the S.D.N.Y. Electronic Case Filing Rules and Instructions. Parties shall

file as letter‐motions all requests for adjournments, extensions, pre‐motion conferences

(including pre‐motion conferences with respect to discovery disputes), and requests for

a settlement conference.

Letter motions are limited to 1,500 words, with single‐spaced text (not including

exhibits, headings, captions, or signatures). If filed by a party not represented by an

attorney and handwritten, letter motions may not exceed 5 pages.

c. 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.

d. Faxes. Chambers does not accept submissions by fax.

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

extensions of time must be filed on ECF as letter motions. The letter‐motion must state:

(1) the original date(s), with a citation to the ruling setting the original date; (2) the

number of previous requests for adjournment or extension; (3) whether these previous

requests were granted or denied; and (4) whether the adversary consents and, if not,

the reasons given by the adversary for refusing to consent. If a conference must be

rescheduled, counsel shall propose at least two alternative dates that fall in consecutive

weeks. Absent good cause, any request for extension or adjournment shall be made at

least 48 hours before the deadline or scheduled appearance.

If a request contains sensitive or confidential information, the requesting party should

file (1) a redacted version of the letter on the public docket and (2) an accompanying

motion to seal, in accordance with the procedures set forth below in § VI.

f. ECF. In accordance with the Electronic Case Filing Rules and Instructions, counsel are

required to register promptly as ECF filers and to enter an appearance in the case. The

pertinent instructions are available on the Court website, at

https://nysd.uscourts.gov/electronic‐case‐filing. Counsel are responsible for updating

their contact information on ECF, should it change, and they are responsible for

checking the docket regularly, regardless of whether they receive an ECF notification of

case activity. For questions about ECF rules and procedures, please contact the ECF help

desk at (212) 805‐0800.

g. Electronic Device Orders. Orders permitting an attorney to bring an electronic device to

Court may be found on the forms page of the SDNY website

(https://nysd.uscourts.gov/forms) and is titled “Fillable Forms for Electronic Devices

General Purpose.” Please note that only attorneys are eligible for such an order. These

orders should not be filed on ECF. Once completed, they may be emailed to Chambers

(Wang_NYSDChambers@nysd.uscourts.gov) for Court approval (and the Court will then

email back to counsel a copy of the signed order if approved).

III. Conferences

a. In‐Person Conferences. Unless otherwise ordered by the Court, all in‐person

conferences will be held in Courtroom 20D of the Daniel Patrick Moynihan United States

Courthouse, 500 Pearl Street, New York NY. If any counsel wishes for a conference to be

conducted remotely (by telephone or video), they should confer with all other counsel

and promptly file a letter‐motion to that effect. Even if a motion for a remote

conference is on consent, the Court does not automatically grant such motions.

b. Teleconferences. Unless otherwise ordered by the Court, any proceeding held by

telephone will be held on the Chambers telephone line or via Teams. Instructions will

be provided to counsel before the conference.

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IV. Pre‐Trial Practice.

a. Initial Case Management Conference. Except for Complex Cases and Pro se Cases,

parties must confer and then file a Report of Rule 26(f) Conference and Proposed Case

Management Plan one week before the Initial Case Management Conference. A

template form for the Report of Rule 26(f) Conference and Proposed Case Management

Plan is available at https

//nysd.uscourts.gov/hon‐ona‐t‐wang.

Complex Cases. Parties must confer and file at least one week before the Initial Case

Management Conference an Initial Report that includes the parties’ positions on the

applicable topics included on the “Initial Pretrial Conference Topics List for Complex

Cases” at Appendix A. The parties must also file a joint Report of Rule 26(f) Conference

and Proposed Civil Case Management Plan and Scheduling Order, available at

https://nysd.uscourts.gov/hon‐ona‐t‐wang.

Pro se Cases. The parties each must submit their Proposed Case Management Plan for

Pro se Cases one week before the scheduled conference in conformance with the

procedures in Section II above. The parties shall use the form Proposed Case

Management Plan template for Pro se Cases found at https://nysd.uscourts.gov/hon‐

ona‐t‐wang.

Attendance. Counsel for the parties who attend the Initial Case Management

Conference must be able to discuss the case and agree to proposed interim deadlines

and schedules. Additionally, an incarcerated party who is unable to attend this or other

conferences may be able to participate by telephone. If appropriate, the Court’s

scheduling order will outline the procedures for participation by telephone.

b. Discovery Disputes. Parties shall follow Local Rule 37.2 with the following modifications.

Any party wishing to raise a discovery dispute with the Court must first meet and 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, the party may

submit an ECF letter‐motion to the Court or, if applicable, to the Pro se Intake Clerk, no

longer than 1,500 words, single‐spaced, explaining the nature of the dispute and

requesting a conference. Such letter must include a representation that the meet‐and‐

confer process occurred, including when and whether it was in person or over the

telephone. Any responsive letter should be submitted within three business days after

submission of the letter‐motion. Discovery motions should address the Federal Rules of

Civil Procedure, in particular Rule 26(b)(1), to the extent applicable.

c. Confidentiality Stipulations and Orders. In cases where confidential information will be

exchanged, the parties must utilize the Court’s model Stipulation and Proposed

Protective Order found at https

//nysd.uscourts.gov/hon‐ona‐t‐wang; provided,

however, the parties may apply for a protective order that differs from the Court’s

model by submitting a letter request via ECF and attaching the proposed order showing

in a blackline comparison how the proposed order differs from the Court’s model. The

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letter should explain why the modifications are needed and note any disagreements

between the parties regarding the modifications from the Court’s model.

d. Electronic Discovery. The parties are encouraged to utilize the model Joint Electronic

Discovery Submission and Proposed Order, as appropriate, found at

https://nysd.uscourts.gov/hon‐ona‐t‐wang. This model may be modified to the extent

appropriate.

e. Status Conferences. Unless otherwise directed by the Court, the parties shall file a joint

proposed agenda at least 3 business days before any status conference, and, where

applicable, a short statement of each party’s position.

V. Motions.

a. Letter‐Motions. Letters seeking relief should be filed on ECF as letter‐motions, not as

ordinary letters.

b. Conferences of Counsel Before Filing Motions Under Rule 12(b) or (c). Except in cases

involving pro se parties, if a motion pursuant to Fed. R. Civ. P. 12(b) or 12(c) is

contemplated, the parties shall meet and confer in advance so that the plaintiff or

counterclaimant can consider whether they wish to amend the subject pleading before

motion practice, and the parties must consider in good faith a stipulation permitting

such amendment. If the parties are unable to reach a resolution, the parties shall submit

a proposed briefing schedule to the Court. Counsel for the moving party shall include

the following statement in the notice of motion: “This motion is made following the

conference of counsel, which took place on [date]. Plaintiff [or Counterclaimant]

declined an opportunity to amend.”

c. Pre‐Motion Conferences. For motions concerning discovery disputes, see Section IV(b)

above. A pre‐motion conference is required for all other motions except: (1) motions

that are required by the Federal Rules of Appellate Procedure or the Federal Rules of

Civil Procedure to be made by a certain time; (2) motions by litigants in actions where a

party is incarcerated and pro se; (3) motions for reconsideration; (4) motions for a new

trial; (5) motions in limine; (6) motions to dismiss habeas corpus petitions; and (7)

motions for judgment on the pleadings and motions to dismiss under Fed. R. Civ. P. 12.

If the assigned district judge has a rule on premotion conference letters for dispositive

motions that conflicts with my practice, parties must comply with the district judge’s

rule, even if the district judge has referred the dispositive motion to me for a report and

recommendation.

Letters requesting a pre‐motion conference should summarize the basis of the motion

and follow the procedures for communicating with the Court set forth in Section II.

Letters may not exceed 1,500 words, with single‐spaced text (not including exhibits,

headings, captions, or signatures). If filed by a party not represented by an attorney and

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handwritten, letters may not exceed five pages. Within 3 business days of receipt of the

letter, each opposing party may submit a written response of no more than 3 pages. The

Court may hold a conference, or issue a briefing schedule if the Court finds that a

conference is not necessary.

d. 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 6,500

words, and reply memoranda are limited to 2,500 words, not including 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. If filed by a

party not represented by an attorney, memoranda of law in support of and in

opposition to motions are limited to 25 pages, and reply memoranda are limited to 10

pages.

Memoranda of 2,500 words or more shall contain a table of contents and a table of

authorities. Sur‐reply memoranda will not be accepted without prior permission of the

Court, and, if permitted, are not to exceed 2,500 words, or 10 pages if filed by a party

not represented by an attorney. All appendices to memoranda of law must be indexed.

e. Filing of Confidential Material. 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. For further directions on how to file under seal, see Section VI below.

To avoid the unnecessary filing of documents under seal, counsel for the parties will

discuss, in good faith, the need to file Confidential Materials under seal. If the parties

agree in writing that a particular document that has been designated Confidential

Material shall not be filed under seal, that document can be filed without redaction and

such filing will not be a breach of any Stipulation of Confidentiality.

f. Oral Argument on Motions. Parties may request oral argument when the motion has

been fully briefed. This request should be made by letter in accordance with the

procedures set forth in Section II.

Junior members of legal teams 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. This 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. The ultimate decision of who speaks on

behalf of the client is for the lawyer in charge of the case, not for the court.

Nothing in my Individual Practices supersedes a specific time period for filing a motion

specified by statute or Federal Rule—including, but not limited to, Fed. R. Civ. P. 50,

52, 54, 59, and 60, and Fed. R. App. P. 4—where failure to comply with the specified

time period could result in forfeiture of a substantive right.

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VI. Filing Under Seal in Civil and Miscellaneous Cases.

a. Sealing/Redactions Not Requiring Court Approval. Federal Rule of Civil Procedure 5.2

describes sensitive information that must be redacted from public court filings without

seeking prior permission from the Court.

b. Sealing/Redaction Requiring Court Approval. Motions or Letter Motions for approval

of sealed or redacted filings in civil and miscellaneous cases and the subject documents,

including the proposed sealed document(s), must be filed electronically through the

court’s ECF system in conformity with the court’s standing order, 19‐mc‐00583, and ECF

Rules & Instructions, Section 6.

The 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 separately filed electronically

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

information sought to be filed under seal. Any motion to seal should address the Court

of Appeals’ opinions in Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110 (2d Cir. 2006)

and Bernstein v. Bernstein Litowitz Berger & Grossman LLP, 814 F.3d 132 (2d Cir. 2016).

If a request for redactions is based on another party’s designation of information as

Confidential, the parties shall confer and jointly submit the request for redactions.

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

system and electronically related to the 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.

Where the motion seeks approval to redact information from a document that is to be

publicly filed, the filing party shall: (1) publicly file the document with the proposed

redactions, and (2) electronically file under seal a copy of the unredacted document

with the proposed redactions highlighted. Both documents must be electronically filed

through the ECF system and related to the motion.

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 to file in the traditional manner, on

paper.

VII. Settlement Conferences.

The Court believes the parties should fully explore settlement at the earliest practical

opportunity. Early consideration of settlement allows the parties to avoid the

substantial cost, expenditure of time, and uncertainty that are typically part of the

litigation process. Even for those cases that cannot be resolved, early consideration of

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settlement can provide the parties with a better understanding of the factual and legal

nature of their dispute and streamline the issues to be litigated. The following

procedures apply to Settlement Conferences:

a. Confidentiality. All settlement conferences, whether by phone or in person, are “off the

record” and strictly confidential. All communications relating to settlement may not be

used in discovery and will not be admissible at trial.

b. Preliminary Settlement Conference Telephone Call(s). The Court will schedule one or

more telephone calls before an in‐person conference to discuss issues pertinent to

settlement. and may try to resolve the case without need for an in‐person settlement

conference. The Court strongly prefers that the parties exchange at least one round of

demand and offer before the first settlement conference call.

c. Ex Parte Settlement Conference Summary Form and Letter. Unless otherwise directed

by the Court, no later than 7 days before the Settlement Conference, each party must

complete the Court’s Settlement Conference Summary Form found at

https://nysd.uscourts.gov/hon‐ona‐t‐wang. Each party also must provide the Court with

a letter, not to exceed three pages, summarizing: (1) the history of settlement

discussions; (2) the issues in the case; (3) the settlement value of the case and rationale

for it; (4) case law authority relevant to settlement discussions; and (5) any other facts

that would be helpful to the Court in preparation for the conference. Parties may attach

exhibits to their letters to the extent they believe the exhibits would aid settlement

discussions. In FLSA cases, the parties shall include damages calculations with their ex

parte submissions. In all other cases, such a submission is highly encouraged but not

required unless otherwise requested. The Settlement Conference Summary Form and

letter should be emailed to Wang_NYSDChambers@nysd.uscourts.gov.

d. Attendance. The parties—not just the attorneys—must attend the Settlement

Conference in person. In the event personal attendance is a hardship, a party may make

a written request at least one week before the conference to attend virtually (or be

excused from attendance). Each party must supply its own interpreter, if required.

Corporate parties or labor unions must send the person with decision‐making authority

to settle the matter to the conference. Where liability insurance is involved, a decision‐

making representative of each carrier must attend unless specifically excused by the

Court. Where any government agency is a party, counsel of record must be

accompanied by a knowledgeable representative from the agency. In addition, in cases

where the Comptroller of the City of New York has authority over settlement, the

Assistant Corporation Counsel must make arrangements before the conference for a

representative of the Comptroller either to attend the conference or to be available by

telephone to approve any proposed settlement.

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Junior members of legal teams are also invited to participate and speak in settlement

conferences, but must be properly supervised and prepared. Sending a junior lawyer,

alone, without sufficiently briefing the junior lawyer on the case and its history may be

considered by the Court to be a failure to properly supervise the junior lawyer.

e. Consequences of Non‐Compliance with Attendance Requirement. If a party fails to

comply with the attendance requirements, that party may be required to reimburse all

the other parties for their time and travel expenses and may face other sanctions.

VIII. Pretrial Procedures in Consent Cases.

a. Joint Pretrial Orders in Civil Cases. Unless otherwise ordered by the Court, the parties

shall submit a Joint Pretrial Order within 30 days after the date for the completion of

discovery, or, if a summary judgment motion has been filed, within 30 days after the

decision on the motion. The proposed Joint Pretrial Order shall be signed by all parties

and include the following:

1. The full caption of the action.

2. The names, addresses, telephone numbers (both office and mobile) and

email addresses of each principal member of the trial team, and

identification of each party’s lead trial counsel.

3. A brief statement by plaintiff (or, in a removed case, by 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, including

citations to all statutes relied on and relevant facts, such as citizenship and

jurisdictional amount.

4. A list and brief summary by each party of the claims and defenses that party

has asserted that remain to be tried, and a list of any claims and defenses

asserted in the pleadings that are not to be tried. Where applicable, the

statements shall identify citations to all statutes relied on, but without recital

of evidentiary matter.

5. With respect to each claim remaining to be tried, a brief statement listing

each element or category of damages sought with respect to such claim (e.g.,

lost profits, back wages, medical costs, etc.) and a calculation of the amount

of damages sought with respect to such element or category.

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

without a jury, and the anticipated number of trial days needed. If a jury trial,

this statement shall also indicate whether the parties agree to a non‐

unanimous verdict pursuant to Federal Rule of Civil Procedure 48. If the

parties do not agree on length of trial, each party shall give their estimate

and the basis for that estimate.

7. Any stipulations or agreed‐to statements of fact or law and a brief

description of any dispute regarding choice of law.

8. A statement by each party as to the witnesses whose testimony is to be

offered in its case in chief, with a brief statement of: the general subject

area(s) of each witness’s testimony, the expected duration of their

testimony, and whether such witnesses will testify in person or by

deposition. If two or more witnesses will testify to the same facts, state why

their testimony will not be cumulative. Absent extraordinary circumstances,

a party may not call as a witness in its case in chief any person not listed in

the Joint Pretrial Order.

9. A designation by each party of deposition testimony to be offered in that

party’s case in chief, referencing page and line numbers, with any cross‐

designations and objections by any other party. If there is no objection or

cross‐designation, the Court will deem the opposing party to have waived

any such objection or cross‐designation. Absent extraordinary circumstances,

a party may not offer in its case in chief deposition testimony that is not

listed in the Joint Pretrial Order.

10. A list by each party of exhibits to be offered in its case in chief. Each exhibit

shall be pre‐marked (plaintiff to use numbers, defendant to use letters). For

each exhibit as to which there is an objection, the party objecting must

briefly specify, next to the listing for that exhibit, the nature of the party’s

objection (e.g., “authenticity,” “hearsay,” “Rule 6 403”). Any objection not

listed shall be deemed waived. Absent extraordinary circumstances, a party

may not offer in its case in chief any exhibit not listed in the Joint Pretrial

Order.

11. A proposed schedule by which the parties will exchange demonstrative

exhibits 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.

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

are important to the efficient conduct of the trial.

13. The Proposed Pretrial Order shall be filed by ECF.

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IX. Additional Pretrial Filings in Civil Cases.

Unless otherwise ordered by the Court, the following shall be filed at the same time as

the proposed joint pretrial order:

a. Jury Cases.

1. Each party must file a Trial Memorandum of Law addressing each issue of law

that the party expects to arise at or before trial.

2. The parties must jointly prepare and submit proposed Jury Materials

consisting of:

 proposed voir dire questions to be asked of prospective jurors;

 proposed jury instructions (with each instruction separately

numbered and beginning on a separate page, and the source or basis

for seeking the instruction identified in a footnote); and

 a proposed verdict form.

3. To the extent a party objects to another party’s requested voir dire

questions, jury instructions, or proposed verdict form, that party must: (i) set

forth the grounds for the objection; and (ii) if applicable, propose an

alternative (all in the same document so that the Court can compare the

parties’ respective proposals).

4. All jury instructions, objections, and alternative proposals must include

citation to supporting authority.

5. In addition to filing on ECF the voir dire questions, requests to charge, and/or

verdict sheets, electronic copies must also be submitted to the Court as

Microsoft Word documents and sent via email to:

Wang_NYSDChambers@nysd.uscourts.gov.

b. Non‐Jury Cases.

1. Each party must file a Trial Memorandum of Law identifying the issues,

summarizing facts and applicable law, and addressing any evidentiary issues.

2. The Court may also ask each party to file Proposed Findings of Fact and

Conclusions of Law before and/or after trial.

3. In addition to filing on ECF, these materials must also be submitted to the

Court as Microsoft Word documents and sent via email to:

Wang_NYSDChambers@nysd.uscourts.gov.

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c. Motions in Limine. Each party shall file and serve any motions in limine at the same time

as the proposed pretrial order. Within two weeks of filing the proposed pretrial order,

each party shall file and serve its opposition to any motion in limine. There shall be no

replies for motions in limine.

d. Pro se Cases. In pro se cases, the parties are not required to prepare joint pretrial filings

(but may do so jointly if feasible). Instead, within 30 days from the date for the

completion of discovery in a civil case or, if a dispositive motion has been filed, within 30

days of a decision resolving the motion, the represented party(ies) shall submit the

pretrial materials set forth in Section IV.b above. The pro se 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 and the general subject matter of each witness’s expected

testimony.

The Pretrial Statement must be sworn or affirmed by the pro se party to be true and

accurate based on the facts known by the party. The pro se party must file an original

Pretrial Statement with the Pro se Office (see Section II(a)) 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.

X. Courtesy Copies.

a. Filings. The parties should not submit courtesy copies of any motion papers, except for

cases regarding appeals of administrative agency determinations. Courtesy copies

should be double‐sided and placed in well‐organized three‐ring binder(s). Where

appropriate, the binder(s) shall be separated by tab dividers preceded by an exhibit list.

Courtesy copies must be provided no later than two business days after the filing.

b. Settlement Conference Materials. A courtesy copy of Ex Parte Settlement Conference

Summary Forms and Letters shall be submitted to the Court if the exhibits to the Letter

exceed 10 pages. Courtesy copies must be provided no later than one business day after

submission of the Form and Letter.

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United States Magistrate Judge Ona T. Wang

Individual Practices in Civil Cases

Updated

April 9, 2025

Appendix A

Initial Pretrial Conference Topics List for Complex Cases

1. Proportionality assessment of “the needs of the case, amount in controversy,

the parties’ resources, the importance of the issues at stake in the action, and

the importance of the discovery in resolving the issues” (see Rule 26(b)(2)(C)

(iii)).

2. Possible limitations on document preservation (including electronically

stored information).

3. Appropriateness of initial disclosures pursuant to Rule 26(a)(1). Is there some

readily identifiable document or category of documents that should be produced

immediately in lieu of initial disclosures?

4. Possibility of a stay or limitation of discovery pending a dispositive motion.

5. Preliminary issues that are likely to arise that will require court intervention.

6. Discovery issues that are envisioned.

7. Proposed discovery including:

A. limitations on types of discovery beyond those in the Rules (i.e.,

waiver of interrogatories, requests for admission, expert depositions);

B. limitations on scope of discovery;

C. limitations on timing and sequence of discovery;

D. limitations on restoration of electronically‐stored information;

E. agreement to allow depositions of trial witnesses named if not already deposed;

F. preservation depositions; and

G. foreign discovery and issues anticipated.

8. Schedule (as appropriate and possibly excluding public agency cases) including:

A. date(s) for completion of discovery, including a protocol and schedule

for electronic discovery;

B. date(s) for dispositive motions;

C. date(s) for exchange for expert reports;

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United States Magistrate Judge Ona T. Wang

Individual Practices in Civil Cases

Updated

April 9, 2025

D. date(s) for exchange of witness lists; and

E. date (s) for Joint Preliminary Trial Reports and Final Joint Trial Reports.

9. Issues to be tried, including ways in which issues can be narrowed to make trial

more meaningful and efficient; as well as whether there are certain issues as to

which a mini‐ trial would be helpful.

10. Bifurcation.

11. Class certification issues.

12. Whether the parties recommend that expert discovery precede or follow any

summary judgment practice.

13. Settlement/mediation and the timing of discussions about settlement.

14. Pleadings, including sufficiency and amendments, and the likelihood and

timing of amendments.

15. Joinder of additional parties and the likelihood and timing of joinder of

additional parties.

16. Expert witnesses (including necessity or waiver of expert depositions).

17. Damages (computation issues and timing of damages discovery).

18. Final pretrial order (including possibility of waiver of order).

19. Possible trial‐ready date.

20. Court logistics and mechanics (e.g., communication with the court, streamlined

motion practice, pre‐motion conferences, etc.).

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