Hon. Stewart D. Aaron

C. Requests For Adjournments Or Extensions Of Time. Requests to adjourn a court 1 Requests for reasonable accommodations on account of disability with respect to these rules may be sent by email to Aaron_NYSDChambers@nysd.uscourts.gov. 2 A Motion for Permission for Electronic Case Filing may also be found at: https://nysd.uscourts.gov/sites/default/files/2019-04/2012-prosemotionecffiling-final.pdf. 3 A Pro Se (Non-Prisoner) Consent & Registration Form to Receive Documents Electronically may also be found at: https://nysd.uscourts.gov/sites/default/files/2018-06/proseconsentecfnotice-final.pdf. 2 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 adjournment or extension; (3) whether these previous requests were granted or denied; (4) the reason for the present request; (5) whether all affected parties consent; and (6) if not, the reasons given for refusing. If the requested adjournment or extension affects any other scheduled dates, a proposed Revised Scheduling Order must be attached. All requests for extension of a deadline must be made in advance of the deadline to be extended. Absent unforeseeable emergencies, all requests for an adjournment of a court conference or other court proceeding (including a telephonic court conference) must be made at least 72 hours in advance of the proceeding to be adjourned, and must include at least two proposed dates, on which all counsel are available, for the adjourned proceeding. Source ↗

4 2. Courtesy Copies. Courtesy copies of Letter-Motions are not required unless the attached exhibits exceed ten pages, in which case one courtesy copy, marked as such, should submitted to Chambers promptly after filing. Courtesy copies should be printed on double-sided paper, and should bear the ECF header generated at the time of electronic filing and include protruding tabs for any exhibits. Bulky materials should be neatly bound, or placed in 3-ring binders, with appropriate dividers. Source ↗

II. Discovery Disputes A. Requirement To Meet And Confer. No discovery dispute shall be heard unless the moving party (including a non-party seeking relief) has first conferred in good faith with the adverse party or parties by telephone or in person in an effort 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. Source ↗

aced. 6 Unless prior permission has been granted, memoranda of law in support of and in opposition to motions may not exceed 8,750 words, and reply memoranda may not exceed 3,500 words.7 These limits do not include the caption, any index, table of contents, table of authorities, signature blocks, or any required certificates, but do include material contained in footnotes or endnotes. If a brief is filed by an attorney or prepared with a computer, it must include a certificate by the attorney, or party who is not represented by an attorney, that the document complies with the word‐count limitations. The person preparing the certificate may rely on the word count of the word‐processing program used to prepare the document. The certificate must state the number of words in the document. To the extent the court permits a party to submit briefs longer than these limits, and expresses those limits in pages, each additional page must not contain more than 350 additional words if the brief is filed by an attorney or prepared with a computer. Source ↗

D. Oral Argument On Motions. Parties may request oral argument by letter. The Court will determine whether argument will be heard and, if so, will advise counsel of the argument date and time. As with Letter-Motions, junior members of legal teams representing clients 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 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 7 If the memoranda of law is filed by a party who is not represented by an attorney and is handwritten or prepared with a typewriter, briefs in support of and in response to a motion may not exceed 25 pages, and reply briefs may not exceed 10 pages. 8 If a party is proceeding pro se, one courtesy copy of all formal motion papers, marked as such, should be submitted to Chambers by the non-pro se party at the time the reply is due. 7 speaks on behalf of the client is for the lawyer in charge of the case, not for the Court. Source ↗

III. Motions (Other Than Discovery Motions) For motions other than discovery motions, a pre-motion conference is not required. A pre-motion conference may be requested 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. Source ↗

• 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. 9