Hon. Valerie Figueredo — Individual Rules of Practice

Updated September 17, 2026

INDIVIDUAL PRACTICES IN CIVIL CASES

VALERIE FIGUEREDO, UNITED STATES MAGISTRATE JUDGE

Chambers Courtroom

Daniel Patrick Moynihan Courthouse Daniel Patrick Moynihan Courthouse

500 Pearl Street, Room 1660 500 Pearl Street, Courtroom 17A

New York, New York 10007 New York, New York 10007

FigueredoNYSDChambers@nysd.uscourts.gov

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

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

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

is before Judge Figueredo for all purposes pursuant to 28 U.S.C. § 636(c). Otherwise, the

practices of the District Judge to whom the case is assigned apply.

I. Communications with Chambers

a. Letters. Communications with the Court should be by letter, via electronic case

filing (“ECF”), without email or other copy to Chambers. Letters may not exceed

3 single-space pages in length (exclusive of exhibits). All letters filed on ECF

must be in searchable PDF form. Any letter containing sensitive or confidential

information that a party does not wish to appear on the docket should follow the

procedures outlined in Section I.G. below.

b. Emails & Faxes. Emails to Chambers are only permitted for urgent matters

requiring immediate attention or when otherwise expressly permitted by the Court

in advance. In any other circumstances, requests or questions to Chambers should

be made by letter only. No faxed communications shall be permitted without prior

permission from Chambers.

c. Telephone Calls. If you are encountering difficulties using ECF, call the ECF

help desk at (212) 805-0800.

d. Pro Se Parties. By Standing Order, a pro se party must mail all communications

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

York, NY 10007. A pro se party may not call Chambers or send any document or

filing directly to Chambers. Submissions requiring immediate attention should be

hand-delivered to the Pro Se Intake Unit. Unless the Court orders otherwise, all

communications with the Court will be docketed upon receipt; such docketing

1 Requests for reasonable accommodations on account of disability or religion with respect to the

Court’s rules or in connection with any proceeding before Judge Figueredo may be emailed to

FigueredoNYSDChambers@nysd.uscourts.gov. Counsel and parties are also invited to inform

the Court of their preferred pronouns.

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. Questions can be

directed to the pro se unit at (212) 805-0175. Any nonincarcerated pro se party

who wishes to participate in 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 email) 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.

e. Requests for Adjournments or Extensions of Time. Requests to adjourn a court

conference or court proceeding (including a telephonic court conference) or to

extend a deadline must be made by Letter-Motion, after consultation with all

affected parties, and must state: (1) the original date of the conference, proceeding

or deadline; (2) the number of previous requests for an adjournment or extension;

(3) the reason for the requested extension; and (4) whether all affected parties

consent and, if not, the reasons given by the adversary for refusing to consent.

Absent unforeseeable emergencies, all requests for an adjournment of a court

conference or other court proceeding (including a telephonic conference) must be

made at least 72 hours in advance of the proceeding to be adjourned and must

include at least two (2) proposed dates, on which all counsel are available, for the

adjourned proceeding.

f. Hand Deliveries. Where permitted by these rules, hand-deliveries 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.

g. Electronic Filing Under Seal. These procedures only apply to motions and

applications before Judge Figueredo. Filing under seal requires permission of the

Court. Unless otherwise ordered, any party wishing to file a document or portion

thereof under seal must comply with the following procedures on or before the

date on which the relevant filing is due.

1. 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 Court

permission. Parties should also consult the S.D.N.Y. Electronic Case

Filing Rules & Instructions, Rules 21.3 and 21.4, available at

https://www.nysd.uscourts.gov/rules/ecf-related-instructions.

2. Sealing/Redactions Requiring Court Approval. Motions or Letter-

Motions for approval of sealed or redacted filings in civil and

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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-583, and

ECF Rules & Instructions, Section 6, available at

https://nysd.uscourts.gov/rules/ecf-related-instructions.

h. Docketing, Scheduling, and Calendar Matters. For docketing, scheduling, and

calendar matters, email FigueredoNYSDChambers@nysd.uscourts.gov.

i. Citations. All moving papers, letter-motions, and letters filed on ECF or emailed

to Chambers must be in searchable PDF form. When citing unreported cases,

citations shall be to Westlaw. If an unreported case is not available on Westlaw,

the party must attach the case(s) to their papers as an exhibit. Citations to all

documents filed on ECF must include the ECF docket number and ECF page

number. For example, citations to an exhibit accompanying a declaration would

appear as “ECF No. 123-4 at 10,” rather than as “Smith Decl. Ex. 4 at 10.”

II. Pretrial Procedures

a. Initial Case Management Conference. Except for Pro Se Cases, parties must

meet and confer on a discovery plan before the Initial Case Management

Conference. One week before the Initial Case Management Conference, the

parties must file on ECF a Report on Rule 26(f) Conference and Proposed Case

Management Plan. A template form for the Report of Rule 26(f) Conference and

Proposed Case Management Plan is available at

https://www.nysd.uscourts.gov/hon-valerie-figueredo

1. Pro Se Cases. Each party must submit a Case Report and Proposed Case

Management Plan for Pro Se Cases one week before the scheduled

conference in conformance with the procedures in Section I above. The

parties shall use the form Proposed Case Management Plan template for

Pro Se Cases found at https://www.nysd.uscourts.gov/hon-valerie-

figueredo

2. Attendance. Lead counsel for the parties is expected to attend the

Initial Case Management Conference. Reasonable accommodations will

be made for parties or their counsel who cannot attend in person on

account of disability. An incarcerated party who is unable to attend this

or other conferences may be able to participate by telephone. If

appropriate, the Court’s scheduling order will outline the procedures for

participation by telephone.

b. Confidentiality Stipulations and Protective Orders. In cases where confidential

information will be exchanged, the parties must utilize the Court’s model

Protective Order found at https://nysd.uscourts.gov/rules/ecf-related-instructions;

provided, however, the parties may apply for a protective order that differs from

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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 letter should explain why the modifications are

needed and note any disagreements between the parties regarding the

modifications from the Court’s model.

c. Discovery Disputes.

1. Requirement to Meet and Confer. The Court will not hear any

discovery dispute unless the moving party (including a non-party

seeking relief) has first conferred in good faith with any adverse party to

resolve the dispute. An exchange of letters or emails alone does not

satisfy this requirement. Counsel must respond promptly and in good

faith to any request from another party to confer in accordance with this

paragraph.

2. Letter-Motion for Discovery Conference. If the meet-and-confer

process does not resolve the discovery dispute, the moving party must

request a discovery conference with the Court, by Letter-Motion, as

required by Local Civil Rule 37.2. Counsel should select the “Letter-

Motion” option when filing on ECF. Letter-Motions may not exceed

three (3) pages in length, exclusive of attachments, which should be kept

to a minimum. The Letter-Motion must clearly set forth the issues in

dispute and the relief sought. Additionally, in the Letter-Motion, the

moving party must certify that the required in-person or telephonic

conference took place between counsel for the relevant parties and, in

particular must state: (1) the date and time of such conference; (2) the

approximate duration of the conference; (3) the names of the attorneys

who participated in the conference; (4) the adversary’s position as to

each issue being raised (as stated by the adversary during the in-person

or telephone conference); and (5) that the moving party informed the

adversary during the conference that the moving party believed the

parties to be at an impasse and that the moving party would be

requesting a conference with the Court. Simply attaching copies of

correspondence between counsel does not satisfy these requirements.

3. Briefing Schedule. Any responsive letter should be submitted within

three (3) business days after submission of the Letter-Motion.

4. Courtesy Copies. Courtesy copies of Letter-Motions are not required

unless the attached exhibits exceed 50 pages, in which case one (1)

courtesy copy, marked as such on the cover page, should be submitted to

Chambers promptly after filing. Courtesy copies should bear the ECF

header generated at the time of electronic filing and include protruding

tabs for any exhibits.

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5. Discovery Conference/Oral Argument on Letter-Motions. The

Court’s preference is to hold a conference with the parties to address

discovery disputes raised by a Letter-Motion. The Court will endeavor to

resolve the issue during a conference without the need for formal

briefing. However, if formal briefing is required, the Court will set a

schedule for such briefing at the conference.

III. Motions Other than Discovery Motions.

a. Briefing Schedule. Unless the Court has ordered or approved otherwise,

opposition and reply papers with respect to formal motions will be due in

accordance with Local Civil Rule 6.1. The parties are strongly encouraged to

agree on a reasonable briefing schedule before the moving papers are filed. If the

parties have agreed to such a schedule, the parties must request the Court’s

approval of their alternate schedule, either in the moving party’s notice of motion

or by Letter-Motion as soon as agreement is reached. Should the parties thereafter

agree to modify their briefing schedule, they must promptly request the Court’s

approval of the new schedule by Letter-Motion. The Court must approve the

alternate or new briefing schedule; otherwise, the parties must adhere to the

schedule as enumerated in Local Civil Rule 6.1.

A premotion conference is not required before a party may file a motion (other

than a discovery motion). A party, however, may request a premotion conference

by Letter-Motion where counsel believes that an informal conference with the

Court may obviate the need for the motion or reduce the issues in dispute.

Counsel should select the “Letter-Motion” option on ECF for filing such a request

for a conference.

b. Memoranda of Law. A memorandum of law must accompany all motions and

oppositions thereto. See Local Civil Rule 7.1. The memorandum of law must set

forth all pertinent facts, which may not be accomplished by incorporating by

reference other documents, such as affidavits or statements under Local Civil

Rule 56.1. Instead, the memorandum must contain a fact section that sets forth all

facts relevant to the motion and, for each factual statement, provides one or more

citations (with specific page or paragraph numbers) to pleadings, declarations,

affidavits, or other documents that have been separately filed. The typeface,

margins, and spacing of motion papers must conform to Local Civil Rule 11.1.

Unless prior permission has been granted, memoranda of law in support of and in

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

ten (10) pages. Memoranda of ten (10) pages 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.

c. Courtesy Copies. Unless otherwise requested by the Court, courtesy copies

should not be submitted. If requested, courtesy copies should bear the ECF header

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generated at the time of electronic filing and include protruding tabs for any

exhibits.

d. Oral Argument on Motions. Parties may request oral argument by Letter-

Motion. Counsel should select the “Letter-Motion” option on ECF for filing such

a request. The Court will determine whether argument will be heard and, if so,

will advise counsel of the argument date and time.

Junior attorneys are invited to argue motions they have helped prepare. Firms are

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

The Court is amenable to permitting more than one lawyer to argue for one party

if this creates an opportunity for a junior lawyer to participate.

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

provide a pro se litigant with printed copies of decisions cited in any submission

that are unreported or reported exclusively on computerized databases. Where a

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

comply with the notice requirements for Local Civil Rule 56.2. Where a party

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

refers to matters outside the pleadings, counsel must serve and file the notice set

forth in Local Civil Rule 12.1. In such situations, counsel is strongly encouraged

to move in the alternative for summary judgment so that the pro se litigant

understands, based on the Local Civil Rule 56.1 submission, which facts are

relevant to the motion.

IV. Pretrial Procedures for Consent Cases

a. Applicability. The procedures set out below apply only to cases in which the

parties have consented pursuant to 28 U.S.C. § 636(c) to have all proceedings,

including trial, occur before Judge Figueredo.

b. Pretrial Disclosures. The parties are reminded of their obligations to make

certain disclosures regarding expert testimony pursuant to Fed. R. Civ. P. 26(a)(2)

and to make disclosures regarding evidence that may be presented at trial pursuant

to Fed. R. Civ. P. 26(a)(3). Failure to comply with these requirements may result

in preclusion or other sanctions.

c. Joint Pretrial Order. Unless otherwise ordered by the Court, the parties shall

submit to the Court for its approval 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.

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

email addresses of each principal member of the trial team.

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

asserted that remain to be tried, including citations to all statutes relied

on, but without recital of evidentiary matter.

4. 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

and a calculation of the amount of damages sought with respect to such

element or category.

5. 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.

6. Any stipulations or agreed-to statements of fact or law.

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

offered in its case in chief, indicating whether such witnesses will testify

in person or by deposition. 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.

8. 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.

9. 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

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.

10. 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.

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

believe are important to the efficient conduct of the trial.

d. Pro Se Cases. No Joint Pretrial Order is required in pro se cases. Instead, within

30 days after the completion of discovery each party shall file its own Pretrial

Statement. The pro se party’s Pretrial Statement must be concise and contain the

following: (1) a statement of the facts the party hopes to prove at trial; (2) a list of

all documents or other physical objects that the party plans to put into evidence at

trial; and (3) a list of the names and addresses of all witnesses the party intends to

have testify at trial. The Pretrial Statement must be sworn by the party to be true

and accurate based on the facts known by the party. The party must file an

original Statement with the Court’s Pro Se Office and serve a copy on all other

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

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

e. Filings Before Trial. Unless otherwise ordered, the following must be filed at the

same time as the filing of the Joint Pretrial Order:

1. Jury Cases. In jury cases, the parties must jointly file (a) proposed jury

instructions, (b) proposed voir dire questions, and (c) where applicable, a

proposed verdict form. To the extent a party objects to another party’s

requested jury charge, voir dire questions, or verdict form, the joint

submission should include the objecting party’s (1) grounds for

objection (or refer to the joint pretrial memorandum for a full discussion

of the objection), and (2) proposed alternative. All requests to charge,

objections, and alternatives must include citations to controlling

authority. In addition to filing on ECF the voir dire questions, requests to

charge, and/or verdict sheets, electronic copies of this joint submission

must also be sent to Chambers. The electronic copies should be sent as

Microsoft Word documents via email to:

FigueredoNYSDChambers@nysd.uscourts.gov

2. Nonjury Cases. In nonjury cases, parties must file proposed findings of

fact and conclusions of law. In addition, each party must file a trial

memorandum of law identifying the issues, summarizing the facts and

applicable law, and addressing any evidentiary issues. In addition to

filing on ECF, these materials must also be submitted to the Court as

Mircrosoft Word documents and sent via email to:

FigueredoNYSDChambers@nysd.uscourts.gov

3. In all cases, motions in limine addressing any evidentiary or other issues

must be filed at the same time as the Joint Pretrial Order.

f. Marking Exhibits for Trial. Unless otherwise ordered by the Court, no later than

two (2) business days before trial begins, each party must provide each other

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party, and the Court, with a tabbed binder or binders containing courtesy copies of

its trial exhibits and deposition designations.

g. Witnesses at Trial. When a party’s case commences, that party is expected to

have witnesses available to fill the trial day, which runs from 9:00 am to 5:00 pm,

with a one‐hour lunch break. The parties are on notice that if a party does not

have a witness available to testify, the Court may deem that party to have rested.

Any request to have a witness testify out of order and/or on a particular day must

be included in the joint pretrial order. Untimely applications will be denied.

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