Hon. Paul A. Crotty — Individual Rules of Practice

Revised

January 21, 2020

INDIVIDUAL PRACTICES OF JUDGE PAUL A. CROTTY, U.S.D.J

Chambers Courtroom Deputy

United States District Court David Gonzalez, Courtroom Deputy

Southern District of New York Courtroom 14-C

500 Pearl Street, Chambers 1350 500 Pearl Street

New York, NY 10007 (212) 805-6312

E-Mail: CrottyNYSDChambers@nysd.uscourts.gov David_C_Gonzalez@nysd.uscourts.gov

Fax: (212) 805-6304 (e-mail preferred)

Rule #1 - Communications with Chambers

A.Letters

Except as otherwise provided below, ALL communications with Chambers shall be by letter. Letters shall be

filed on ECF in accordance with Section 13.1 of the ECF Rules & Procedures. A hard copy of any letter filed

on ECF shall also be mailed to Chambers. Any letter to the Court must not exceed 3 pages in length. This does

not include any exhibits that may be attached to a letter. All letters must comply with SDNY Local Rule

11.1(b):

“The typeface, margins, and spacing of all documents presented for filing must meet the

following requirements: (1) all text must be 12-point type or larger, except for text in footnotes

which may be 10-point type; (2) all documents must have at least one-inch margins on all sides;

(3)all text must be double-spaced, except for headings, text in footnotes, or block quotations,

which may be single-spaced.”

B.Telephone Calls

Telephone calls to Chambers should be made only in emergency situations requiring immediate attention. In

such situations only, call the Courtroom Deputy, Mr. David C. Gonzalez, at (212) 805-6312. Any voice

messages should be brief, and provide the case caption/number and a brief description of the emergency (see

Rule 1D for further information on contacting Mr. Gonzalez).

C.Faxes

See Rule 1A above. Faxes to Chambers are permitted (e-mail is preferred) only if copies are also

simultaneously faxed or delivered to all counsel. No document longer than ten (10) pages may be faxed without

prior authorization. Do not follow with a hard copy.

D. Docketing, ECF and other Procedural Questions

For Docketing, ECF and other Procedural Questions please contact the SDNY Clerk’s Office. In the event of

an emergency or no response from the departments listed on the Court’s web site, you may as a last resort e-

mail the Courtroom Deputy, Mr. David C. Gonzalez, at: David_C_Gonzalez@nysd.uscourts.gov.

E. Requests for Adjournments or Extensions of Time

Letter requests for adjournments will not be granted unless counsel requesting the adjournment complies with

this rule. All requests for adjournments or extensions of time must state (1) the original date(s), (2) the number

of any previous requests for adjournment or extension, (3) whether these previous requests were granted or

denied, (4) whether the adversary consents, and, if not, the reasons given by the adversary for refusing to

consent, and (5) if the adversary consents, counsel shall confer amongst each other and propose three (3)

alternate conference dates. If the requested adjournment or extension affects any other scheduled dates, a

proposed Revised Scheduling Order should be attached. Any request for adjournments of court conferences

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shall be made at least 48 hours prior to the scheduled appearance. The Court will not advise the parties by

telephone or mail of the disposition of requests for extensions and adjournments. Counsel are responsible for

checking the docket sheet in the Clerk's office in person, by use of a service, or through use of the Court's ECF

system.

F. Contacting Counsel

If the Court requires information from attorneys / litigants on a pending case, the Courtroom Deputy will

contact the attorneys/litigants via e-mail. All Counsel should routinely check their e-mail for communication

from the Courtroom Deputy. The Court contacts attorneys/litigants with the e-mail address of the Courtroom

Deputy: David_C_Gonzalez@nysd.uscourts.gov.

Rule # 2 - Courtesy Copies

A. Pleadings

One (1) courtesy copy of pleadings (example: Complaint, Rule 7.1, Answer), marked as such, shall be

submitted to Chambers as soon as practical after filing, in accordance with the SDNY policies regarding mail

deliveries. See Rule 1A with respect to courtesy copies of letters and Rule 3I with respect to courtesy copies of

all motion papers.

B. Motions

See Rule 3(I) below.

Rule # 3 - Motion Rules at a Glance

A. Pre-Motion Conferences in Civil Cases

As described below (Rule 3C and 3D), a pre-motion conference with the Court is required before making any

motion, except:

1. Motions brought on by Order to Show Cause (See Rule 3F)

2. Motions in criminal cases.

3. Motions by Pro Se Litigants

4. Motions for Admission Pro Hac Vice

5. Motions for Reconsideration

6. Motions for Default Judgment (See Rule 3L)

7. Motions for Appointment of Lead Plaintiff

B. Pre-Motion Conference Letter in Lieu of Answer

The time to Answer a Complaint is preserved as long as the defendant files a pre-motion conference letter by

the date the Answer is due.

C. Discovery Motions

Discovery disputes arising under Rules 26 through 37 or Rule 45 of the Federal Rules of Civil Procedure shall

be heard only if the moving party has first conferred in good faith by telephone or in person with all other

relevant parties in an effort to resolve the dispute. If this conference has not resolved the issue(s) raised, the

moving party must inform the relevant parties during the conference that the moving party intends to seek relief

from the Court on such issue(s). The moving party must thereafter promptly request a conference with the

Court. To request a conference with the Court, the moving party shall file a letter, not to exceed three (3) pages

in length and in compliance with Local Rule 11.1(b), setting forth the basis of the discovery dispute and the

need for the anticipated motion. The letter must certify that the required in-person or telephonic conference

took place between counsel and the relevant parties. The letter must also state the date of such conference and

provide the adversary’s position as to each issue being raised (as stated by the adversary during the in-person or

telephonic conference). These requirements are not satisfied by attaching copies of correspondence between

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counsel. The party opposing the requested relief should file a letter within three (3) business days (also not to

exceed three (3) pages in length). The letters should be filed in accordance with Section 13.1 of the ECF Rules.

D. Motions other than Discovery Motions

To arrange a pre-motion conference, the moving party shall file a letter, not to exceed three (3) pages in length

and in compliance with Local Rule 11.1(b), setting forth the basis for the anticipated motion. Other parties shall

respond within three (3) business days. The moving party should not submit a reply letter unless the Court

requests it. Once the Court is ready to schedule the pre-motion conference, the Courtroom Deputy will post the

date on ECF.

E. Return Date

All motions should be made without a return date.

F. Orders to Show Cause and Temporary Restraining Orders

All applications for orders to show cause and temporary restraining orders first shall be brought to the Orders

and Appeals Clerk for approval and then to Chambers, provided that in ECF cases, counsel shall adhere to any

instructions given by the Clerk’s Office with respect to such applications. Applications for temporary

restraining orders will be entertained only after notice to the adversary, absent a persuasive showing that the

giving of notice itself is likely to result in immediate and irreparable injury.

G. Memoranda of Law

Unless prior permission has been granted, memoranda of law in support of and in opposition to motions are

limited to twenty-five (25) pages, and reply memoranda are limited to ten (10) pages. Memoranda of ten (10)

pages or more shall contain a table of contents.

H. Filing Motion Papers

Motion papers shall be filed promptly on ECF after service according to any schedule set by the Court.

I. Courtesy Copies of Motion Papers

Two (2) courtesy copies of all motion papers, marked as such, shall be submitted to Chambers at the time the

papers are served, in accordance with the SDNY policies regarding mail deliveries.

J. Bankruptcy Appeals

Counsel shall provide Chambers with two (2) courtesy copies of their briefs, and counsel for appellant shall

provide Chambers with one (1) courtesy copy of the record, immediately upon the filing of the originals with

the Clerk of Court. The page limits applicable to memoranda of law on motions apply to briefs on bankruptcy

appeals.

K. Oral Argument on Motions

The Court will contact the parties after the motion has been fully briefed regarding an oral argument date.

L. Default Judgments

1. Applications. An application for a default judgment must comply with Local Civil Rules 55.1 and 55.2 and

will not be accepted absent the submission of a proposed form of default judgment and an affidavit containing

the following:

a. A description of the nature of the claim;

b. A description of the legal and factual basis of the Court’s subject matter jurisdiction;

c. A description of the legal and factual basis of the Court’s personal jurisdiction over the defendant;

d. A statement that the defendant is not an infant or an incompetent;

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e. The annexation of a certificate of default stating that the defendant was properly served and failed to

answer or appear, signed and stamped by the Clerk of Court; and

f. The annexation of documentation, if any, substantiating the claim.

2. Relief. If a party seeks an award of damages or attorney’s fees and expenses, the party must also include:

a. A request for an amount equal to or less than the principal amount demanded in the Complaint;

b. Definitive information and documentation such that the amount provided for in the proposed

judgment can be calculated. (If this requirement cannot be satisfied, a default judgment may be

granted as to liability, and damages will be determined by an inquest/hearing);

c. An affidavit representing that no part of the judgment sought has been paid, other than as indicated

in the motion;

d. Any request for interest on the principal amount may not exceed 9% simple interest, unless a legal or

factual basis is demonstrated for a different rate;

e. An affidavit setting forth the legal and factual basis for any claim of attorneys’ fees and expenses,

and the hours spent by each attorney, the reasonable hourly rate for each attorney, a description of

services and the dates on which the services were rendered and a description of the expenses; and

f. The calculations made in arriving at the proposed judgment amount.

M. Pro Hac Vice Motions

Procedures on filing a Pro Hac Vice Motion can be found by visiting the SDNY website.

N. Settlement Agreements

Unless the Court orders otherwise, the Court will not retain jurisdiction to enforce confidential settlement

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

parties must place the terms of their agreement on the public record. The parties may either provide a copy of

the settlement agreement for the Court to endorse or include the terms of their settlement agreement in their

stipulation of settlement and dismissal.

O. Failure of the Court to Decide a Motion

If a motion is not decided within 120 days of the time it is fully submitted, counsel for either party may send a

letter to the Court to call this fact to the Court’s attention.

Rule # 4 - Electronic Cases

A. Registration

Counsel for all parties are required to register as filing users in accordance with the Procedures for Electronic

Case Filing located on the SDNY website.

B. ECF Notice

All Civil and Criminal cases (except Pro Se cases) filed on or after March 1, 2004 that are assigned to Judge

Crotty are Electronic Case Filings. All counsel must register for ECF and file a Notice of Appearance in each

case pending before this Court. Counsel are responsible for checking their registered e-mail and docket sheet

for Orders and Notices. If you are not receiving copies of Orders or Notices, please contact the ECF Help Desk

at (212) 805-0800, or in person on the third floor of the courthouse.

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Rule # 5 - Rulings

A. Notice of Rulings in ECF Cases

In ECF cases, notice of opinions, orders, and stipulations is given through the ECF system. NO OTHER

MEANS OF NOTIFICATION WILL BE USED.

Rule # 6 – Conferences & Other Court Proceedings

A. Conference Location

All conferences will be held in Courtroom 14-C unless otherwise indicated.

B. Transcript of Conference/Hearing

A SDNY Court Reporter will appear for all matters.

C. Initial Conference/Arraignment in a Criminal Case

Upon the assignment of a criminal case to Judge Crotty, the Assistant United States Attorney shall immediately

provide a copy (see Rule 1A) of the Indictment and Complaint to Chambers and arrange, via email with the

Deputy Clerk Mr. Gonzalez, for a prompt initial conference at which the defendant and defense counsel will be

present in order to set a discovery schedule, motion schedule or trial date. The defendant shall be arraigned in

Magistrate Court if bail has not been set. If bail has been set or if the defendant is remanded, Judge Crotty will

preside over the arraignment.

D. Guilty Pleas

Guilty pleas will ordinarily be taken by Judge Crotty and not assigned to Magistrate Judges by standing order.

Defense counsel are expected to have reviewed any plea, cooperation or other agreement if necessary, with the

assistance of an interpreter – with the defendant prior to the time set for the conference with the Court.

Defendants shall be prepared in advance of their pleas by their attorneys to give narrative allocutions that

incorporate all the elements of the offense(s) to which they are pleading guilty. Where a defendant is pleading

guilty pursuant to a plea agreement or a cooperation agreement, a copy of the agreement which is signed by the

defendant and the defendant’s attorney must be received by Chambers no fewer than two business days before

the scheduled plea. Where a defendant is pleading guilty pursuant to a Pimentel letter, a copy of the Pimentel

letter must be received by Chambers no fewer than two business days before the scheduled plea.

E. Bail Modifications

Any written request for a bail modification shall indicate whether the Government (AUSA) and the Pre-Trial

Services Officer consent to the request.

F. Sentencing

Unless directed otherwise, all sentencing submission must be filed and submitted to the Court three business

days in advance of the sentencing fate.

The Court assumes that every document in a sentencing submission, including letters, will be filed in the public

record either in paper form or through the ECF system, using the procedures described below. The defendant is

responsible for filing all letters submitted on behalf of the defendant, including those from friends, relatives, etc.

The Government is responsible for filing all letters from victims.

In this regard, the parties are referred to E-Government Act of 2002 and the Southern District’s ECF Privacy

Policy (“Privacy Policy”) and reminded not, unless necessary, to include the five categories of “sensitive

information” in their submissions (i.e., social security numbers, names of minor children [use the initials only],

dates of birth [use the year only], financial account numbers, and home addresses [use only the City and State]).

Parties may redact the five categories of “sensitive information” and the six categories of information requiring

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caution (i.e., personal identifying number, medical records, treatment and diagnosis, employment history,

individual financial information, proprietary or trade secret information, and information regarding an

individual’s cooperation with the government) as described in the Privacy Policy, without application to the

Court.

If any material is redacted from the publicly filed document, only those pages containing the redacted material

will be filed under seal. Bring a copy of those pages to the sentencing proceeding, marked to indicate what

information has been redacted from the publicly filed materials, to give to the Court for filing under seal.

1. Paper Filing

If letters are filed as hard copies, a party shall group all letters together in a single paper filing under a cover

marked SENTENCING MEMORANDUM with the caption and docket number clearly indicated and submit it

to the Clerk’s Office.

2. ECF Filing

If letters are filed electronically, they must be grouped and filed together as attachments to a single document

marked SENTENCING MEMORANDUM with the caption and docket number clearly indicated.

If a party redacts information beyond the eleven categories of information identified in the Privacy Policy, an

application to do so must be served and filed at the time the sentencing submission is served. The application

should clearly identify the redaction and explain the reasons for the redaction. The application will be

addressed at the sentencing proceeding.

G. Initial Conference in a Civil Case

The parties shall file on ECF a joint letter two (2) business days prior to the conference addressing 1-7 below in

separate paragraphs. If the parties are unable to agree on a joint letter, each party shall file its own letter. For

the Court’s convenience, the parties are requested to set forth the date and time of the conference in the opening

paragraph of the joint letter. The parties shall agree on a Civil Case Management Plan which can be found at:

http://www.nysd.uscourts.gov/judge/Crotty. See Rule 1A with respect to filing.

1. The names, addresses (including firm names), e-mail addresses, telephone, and fax numbers of trial

counsel;

2. A brief description of the case, including the factual and legal bases for the claim(s) and defense(s);

3. A brief statement by plaintiff 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. Such statements shall

include citations to all statutes relied on and relevant facts as to citizenship and jurisdictional

amount;

4. A brief summary by each party of the claim(s) and defense(s) that party has asserted which remain to

be tried, without recital of evidentiary matter but including citations to all statutes relied on. Such

summaries shall identify all claims and defenses previously asserted which are not to be tried;

5. Any contemplated motions;

6. 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; and

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7. A statement as to whether or not all parties have consented to trial of the case by a magistrate judge

(without identifying which parties have or have not so consented). If the parties are unable to agree

on a joint letter, each party shall submit its own letter.

Rule #7 Electronic Filing Under Seal

A. 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 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.

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: (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.

Both documents must be electronically filed through the ECF system and related to the motion

The proposed sealed/redacted document, a copy of the motion to seal and any supporting papers

must be contemporaneously submitted to the Court in paper form, by hand delivery or mail. Digital copies

of these documents must also be emailed to chambers (outside the ECF system) at

David_C_Gonzalez@nysd.uscourts.gov.

Rule #8 Trial / Hearing Procedures

A. Exhibits

1. All Exhibits are to be pre-marked. Plaintiff/Government shall mark the exhibits as numbers and

Defendant shall use letters. Ideally, all should be marked before trial, but in all cases, exhibits must

be marked no later than the morning of the session of the trial at which they are to be used. No trial

time shall be taken for this purpose.

2. Counsel are responsible for marking their own exhibits. Counsel must give two (2) copies of each

exhibit to the Court (one for the Judge; the other for the Law Clerk) before using it at trial. Counsel

must exchange copies of their trial exhibits before trial begins. The Court/Law Clerk copies of the

pre-marked exhibits should be assembled sequentially in a notebook and tabbed. If an individual

exhibit has multiple pages, the pages should be paginated.

3. On the day of trial, counsel shall bring additional pre-marked copies for use by witnesses, the

Courtroom Deputy, and opposing parties.

4. Counsel shall also provide copies to the Court of any depositions which are intended to be offered, in

whole or part, into evidence. Depositions are not generally to be offered in their entirety. Copy the

relevant pages only, staple the extracts from each deposition, and offer each as an exhibit.

5. Generally, each side of the case keeps track of its own exhibits.

B. Witnesses

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All witnesses should be identified in the Joint Pretrial Order in civil cases. Failure to list a witness may result in

preclusion of that witness. A person who is expected to testify as a witness should not be present in the

Courtroom during the examination of evidence (or have access to a transcript or summary of that evidence); but

this rule is not applicable to professional persons who are engaged to provide testimony based on their

specialized knowledge, and each party may have one representative in the Courtroom.

C. Court Reporter

Please respect the Court Reporter’s function. If the spelling of names of people, places, or things is unusual,

give a list of such words to the Court Reporter at the start of trial. Speak distinctly; do not speak while someone

else is speaking. When referring to an exhibit, use its number or letter so that the record is clear as to what is

being discussed. Answers given by a witness relating to distances in the Courtroom or objects before the

witness should be clarified by a statement for the record so that the transcript will convey a clear report of what

took place at trial. When depositions or documents are read, the reader should proceed slowly enough for the

Court Reporter to record what is being said. Depositions are to be read by stating the word “Question” and then

reading the question, then stating the word “Answer” and then reading the answer.

D. Interpreter:

Counsel should advise interpreters not to engage in a dialogue with the witness. Counsel should also remind

interpreters to interpret the witness’s testimony word for word. Should the interpreter not understand the

witness, the interpreter should so inform the Court immediately so that their inability to understand the witness

and interpret their response to a particular question becomes part of the record.

E. Conduct During Trial/Hearing

Counsel shall comply with the following guidelines:

1. Please be on time for each court session. Trial engagements take precedence over any other

business. If you have matters in other Courtrooms, arrange in advance to have them continued or

have a colleague handle them for you.

2. Court time may not be used for marking exhibits. Exhibits must be marked in advance of the court

session.

3. Stand whenever you address the Court, especially when making an objection.

4. Please question the witnesses from the podium only, unless the Court gives you permission to

approach the witness. Do not pace about the Courtroom when questioning witnesses.

5. If you intend to question a witness about a group of documents, avoid delay by having all the

documents with you when you start the examination.

6. Please commence cross-examination without preliminaries.

7. Please make your objection short and to the point. Unless specifically directed by the Court to do so,

do not argue the objection. Please do not interrupt a question to make your objection.

8. Please address all remarks to the Court, not to opposing counsel.

9. Please maintain professional decorum. Do not engage in disparaging or disrespectful personal

remarks or acrimony toward opposing counsel or witnesses.

10. Please refer to all persons, including witnesses, other counsel, and parties by their surnames and not

by their first names.

11. No one at counsels’ table should gesture, make facial expressions, audible comments, or the like, as

manifestations of approval or disapproval to the testimony of witnesses, or to a ruling or statement

by the Court.

12. Only one attorney for each party shall examine, or cross-examine, each witness. The attorney stating

objections, if any, during direct examination, shall be the attorney recognized for cross-examination.

13. In examining a witness, counsel should not repeat or echo the answer given by the witness.

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14. Please do not run out of witnesses. The Court will advise counsel of its schedule, and counsel

should be prepared with witnesses to proceed continuously to the end of trial without interruption.

(If a witness is not available, trial will proceed, and the witness’s testimony may be precluded.)

F. Requirements Before A Trial.

Unless ordered otherwise, the Joint Pretrial Order (civil cases), Proposed Voir Dire and Proposed Request to

Charge are due three business days before the Final Pretrial Conference date. For civil cases, see Appendix A

for the form of the Joint Pretrial Order. Any motions in limine must be fully briefed three business days before

the final pretrial conference.

G. Trial/Hearing Schedule

Trials will generally be conducted Monday through Friday from 9:30 a.m. to 4:30 p.m. The Court will be

available to meet with counsel from 9:00 a.m. to 9:30 a.m. Testimony will begin at 9:30 a.m. A luncheon recess

will run from 12:45 p.m. to 2 p.m. One (1) 10-15 minute break will be given in the morning and afternoon.

Appendix A – Form of Pretrial Order

UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF NEW YORK

[caption] XX Civ. XXXX (PAC)

The parties having conferred among themselves and with the Court pursuant to Fed. R. Civ. P. 15, the

following statements, directions, and agreements are adopted as the Pretrial Order herein.

I. NATURE OF THE CASE

[Set forth a brief statement of the general nature of the action and the relief sought by each party.]

II. JURY / NON-JURY

[State whether a jury is demanded, whether there is any dispute as to whether the action should be tried by a

jury, and the estimated length of trial.]

III. STIPULATED FACTS

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[Set forth any stipulated or agreed upon statements of fact.]

IV. PARTIES’ CONTENTIONS

The pleadings are deemed amended to embrace the following, and only the following contentions of the

parties:

A. Plaintiff’s Contentions

[Set forth a brief statement of the plaintiff’s contentions as to all ultimate issues of fact and law.]

B. Defendant’s Contentions

[Set forth a brief statement of the defendant’s contentions as to all ultimate issues of fact and law.]

V. ISSUES TO BE TRIED

[In non-jury cases, each party shall submit a separate statement of the proposed findings of fact and conclusions

of law.]

[In all cases, each party shall submit a pretrial memorandum addressing all questions of law expected to arise at

trial.]

VI. PLAINTIFF’S EXHIBITS

VII. DEFENDANT’S EXHIBITS

[Each side shall list all exhibits it intends to offer on its case in chief. The list shall include a description of each

exhibit. All exhibits shall be premarked. If an exhibit is not listed below, it may be used at trial only (a) for

cross-examination purposes or (b) if good cause is shown for its exclusion from the pretrial order.]

VIII. STIPULATIONS AND OBJECTIONS TO EXHIBITS

[If there are to be objections, such objections should be noted with an asterisk, and the grounds for the objection

(authenticity, relevancy, etc.) specified. Any objections not set forth herein will be considered waived absent

good cause shown.]

[The parties shall set forth any stipulations with respect to the authenticity and admissibility of exhibits and

indicate all objections to exhibits and grounds therefor.]

IX. PLAINTIFF’S WITNESS LIST

X. DEFENDANT’S WITNESS LIST

[Each party shall list the witnesses it intends to call on its case in chief and, if a witness’s testimony will be

offered by deposition, shall designate by page and line numbers the portions of the deposition transcript it

intends to offer. Each party shall set forth any objections it has to deposition testimony designated by the other

and the basis therefore. The witnesses listed may be called at trial. If a witness is not identified, the witness

shall not be permitted to testify on either party’s case in chief absent good cause shown.]

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XI. MOTIONS IN LIMINE

[In all cases, counsel shall submit a list of all motions addressing any evidentiary or other issues that should be

resolved in limine.]

XII. ADDITIONAL REQUIREMENTS IN JURY CASES

[In jury cases, counsel shall provide the court with requests to charge and voir dire questions. The parties must

submit a single, unified set of proposed jury instructions on the law applicable to the specific case. Where an

instruction is not agreed upon, the parties should indicate who is proposing the instruction, as well as the legal

basis for the instruction and for the other party’s opposition to the instruction. Where applicable, counsel shall

also submit a proposed special verdict form.]

XIII. RELIEF SOUGHT

[The plaintiff shall set forth the precise relief sought, including each element of damages. If plaintiff seeks an

injunction, the proposed form of injunction shall be set forth or attached.]

SO ORDERED

__________________________

PAUL A. CROTTY

United States District Judge

Dated: New York, New York

, 20XX

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