Judge John P. Cronan — United States District Court, Southern District of New York

Individual Rules and Practices in Civil Cases

Revised: October 23, 2025

INDIVIDUAL RULES AND PRACTICES IN CIVIL CASES

JOHN P. CRONAN UNITED STATES DISTRICT JUDGE SOUTHERN DISTRICT OF NEW YORK

Chambers

Courtroom United States District Court

Courtroom 12D Southern District of New York

500 Pearl Street

500 Pearl Street, Room 1320

Meghan Henrich, Courtroom Deputy New York, NY 10007

CronanNYSDChambers@nysd.uscourts.gov

Unless otherwise ordered by the Court, these Individual Rules and Practices shall apply to all civil matters before Judge Cronan, except for civil cases involving pro se litigants.

Communications with Chambers

A. Letters. Except as otherwise provided below, communications with Chambers shall be by letter, with copies simultaneously delivered to all counsel. Letters to the Court on behalf of parties represented by counsel must be both docketed on ECF and e-mailed as a .pdf attachment to the following address: CronanNYSDChambers@nysd.uscourts.gov. Counsel shall not provide a hard copy of correspondence e-mailed to Chambers. Letters seeking relief should (if consistent with the S.D.N.Y. Local Rules and the S.D.N.Y. ECF Rules and Instructions) be filed on ECF as letter-motions, not as ordinary letters. Any response to a letter or letter-motion shall be filed within two business days of the filing of the letter or letter-motion.

Counsel shall include the case caption and docket number in the subject line of every e- mail sent to Chambers. All letters should be text-searchable where practicable. Unless otherwise ordered by the Court, letters may not exceed three pages in length (single-spaced, 12-point font).
Letters to be filed under seal or containing sensitive or confidential information must be filed in accordance with 4.A-B below. Copies of correspondence between counsel shall not be sent to the Court or docketed on ECF, except if the correspondence is a relevant attachment to a filing.

B. Telephone Calls. For questions that cannot be answered by reference to these Rules or the S.D.N.Y. Local Rules, or for docketing, scheduling, and calendar matters, counsel may contact the Courtroom Deputy, Meghan Henrich. For situations requiring immediate attention from the Court, counsel should call Chambers directly; in such situations, parties should email the Chambers inbox requesting the Court’s contact information.

C. Faxes. Faxes to Chambers are not permitted.

D. Hand Deliveries. Hand-delivered mail should be left with the Court Security Officers at the Worth Street entrance of the Daniel Patrick Moynihan United States District Courthouse at 500 Pearl Street, New York, NY 10007 and may not be brought directly to Chambers. If the hand- delivered letter is urgent and requires the Court’s immediate attention, the party should ask the Court Security Officers to notify Chambers that an urgent package has arrived that needs to be retrieved by Chambers staff immediately.

Rules for All Filings

A. Electronic Case Filing (“ECF”). In accordance with the S.D.N.Y. ECF Rules and Instructions, all counsel must register promptly as ECF filers after being retained or assigned and to enter an appearance in the case. Counsel can obtain instructions on how to register at http://www.nysd.uscourts.gov/ecf_filing.php. Counsel are responsible for updating their contact information on ECF, should it change, and they are responsible for checking the docket sheet regularly, regardless of whether they receive an ECF notification of case activity.

If an ECF submission requires immediate attention from the Court, counsel should notify Chambers by telephone after filing the submission via ECF.

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

B. Memoranda of Law. The typeface, margins, and spacing of motion papers must conform to Local Civil Rule 7.1(b). Unless prior permission has been granted, memoranda of law in support of and in opposition to motions are limited to 8,750 words, and reply memoranda are limited to 3,500 words. These limits do not include the caption, any index, table of contents, table of authorities, signature blocks, or any required certificates, but do include material contained in footnotes or endnotes. Memoranda of 10 pages or more shall contain a table of contents and a table of authorities, and all memoranda must include a certificate by the attorney, or party who is not represented by an attorney, that the document complies with the word-count limitations. These limits do not apply to motions for reconsideration under Local Civil Rule 6.3; parties should refer to that provision for applicable word or page limits and other information. Sur-reply memoranda will not be accepted without prior permission of the Court. Motion papers shall be filed promptly after service.

C. Unpublished Cases. Westlaw or Lexis citations shall be provided, if available, to cases not available in an official reporter. Parties must provide copies of cases that are not available on Westlaw or Lexis.

D. Courtesy Copies. Regarding all pleadings, correspondence, and motion papers, including exhibits submitted in connection with a motion, a party shall submit an electronic courtesy copy via e-mail to Chambers at the time the papers are served. Paper courtesy copies

may be submitted only upon request from the Court. Courtesy copies should be marked as such and shall be submitted to Chambers for both ECF and non-ECF designated cases.

Electronic courtesy copies of proposals for the Court to enter, including proposed orders to show cause, temporary restraining orders, preliminary injunctions, stipulations, consent orders, and default judgments, should be sent in both Microsoft Word and PDF formats.

E. Use of Artificial Intelligence (“AI”) Tools. Counsel is responsible for providing the Court with complete and accurate representations of the record, the procedural history of the case, and any cited legal authorities. All litigants are responsible for verifying the accuracy of any output produced in whole or in part by an AI tool. Any attorney who signs a filing for which an AI tool was used to prepare (including by appearing on the signature block of the filing) must attach to the filing a signed certification (i) stating whether the litigant personally reviewed the filing for accuracy of cited legal authorities and factual assertions and (ii) if so, describing in detail the steps taken to verify the accuracy of all legal authorities and factual assertions generated by the AI tool. An attorney who signs an AI-assisted filing, yet fails to review that filing for accuracy or to provide the required certification, violates this Rule. The Court may impose sanctions on counsel and/or strike the filing for failing to comply with this Rule. A model certification may be found on the Court’s website (https://www.nysd.uscourts.gov/hon-john-p-cronan).

Rules for Specific Types of Filings

A. Complaints. Plaintiffs shall ensure that a copy of the operative complaint is posted electronically to the docket on the ECF system. This requirement applies to all cases, including removed cases. There is no need to submit courtesy copies of pleadings, unless immediate relief is sought (e.g., a temporary restraining order).

If a party files an amended pleading, a courtesy copy of the pleading, in redline form to the most recent operative pleading, shall be provided to the Court via email.

B. Requests for Adjournments or Extensions of Time. Requests for adjournments, extensions of time, and extensions of word lengths in memoranda shall be made by letter, and not by stipulation sent through the Orders and Judgments Clerk. Requests for adjournments or extensions of time shall be filed on ECF as letter-motions, not as ordinary letters. All requests for adjournments or extensions of time must state (1) the original date(s) set for the appearance or deadline(s) and the new date(s) requested; (2) the reason(s) for the request; (3) the number of previous requests for adjournment or extension; (4) whether these previous requests were granted or denied; and (5) whether opposing counsel consents, and, if not, any reasons given by opposing counsel for refusing to consent. If the requested adjournment or extension affects any other scheduled dates or deadlines, a proposed Revised Case Management Plan and Scheduling Order (reflecting only business days) must be attached.

Absent compelling circumstances, a request for an extension or adjournment must be made at least 48 hours (i.e., two business days) prior to the scheduled appearance or deadline. Requests for extensions will ordinarily be denied if made after the expiration of the original deadline.
Requests for extensions of deadlines regarding a matter that has been referred to a Magistrate Judge shall be directed to that assigned Magistrate Judge.

If a party seeks to extend the discovery deadlines for a case, the request must include (1) a description of what discovery has already been completed; (2) a description of what discovery remains to be taken; (3) why discovery was not completed by the time provided in the Case Management Plan; and (4) why “good cause” exists to modify the scheduling order under Federal Rule of Civil Procedure 16(b)(4). The Court requires a showing of good cause to modify a previously set discovery deadline and failure to comply with this requirement will result in denial of the request. Parties should not assume that such requests will be granted as a matter of course.

C. Related and Consolidated Cases. After an action has been accepted as related to a prior case, all future court papers and correspondence must contain the docket number of the new filing as well as the docket number of the case to which it is related (e.g., 21-cv-1234 [rel. 20-cv- 4321]). After two or more actions have been consolidated for all purposes under a single docket number pursuant to Rule 42(a)(2) of the Federal Rules of Civil Procedure, all future court papers and correspondence should be filed only in the docket under which the cases have been consolidated and should reference only that docket number.

D. Certificates of Default. A party that intends to seek a certificate of default pursuant to Rule 55(a) of the Federal Rules of Civil Procedure and Local Civil Rule 55.1 must notify the Court of its intent to do so by filing a letter pursuant to 1.A above at least two business days before filing for such a request with the Clerk of Court.

E. Default Judgments. A party seeking a default judgment must proceed by filing a motion for default judgment on ECF pursuant to Rule 55(b)(2) of the Federal Rules of Civil Procedure and Local Civil Rule 55.2(a)(2). A party seeking a default judgment must also file the following materials, in addition to those specified in Local Civil Rule 55.2:

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

a. the basis for entering a default judgment, including if appropriate a description of the method and date of service of the summons and complaint;

b. the procedural history beyond service of the summons and complaint, if any;

c. whether, if the default is applicable to fewer than all of the defendants, the Court may appropriately order a default judgment on the issue of damages prior to resolution of the entire action; and

d. if the party believes an inquest into damages is unnecessary, the legal authority for that position;

ii. Copies of all the operative pleadings; and

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

The party must file the Affidavit of Service specified in Local Civil Rule 55.2(a)(3) on ECF within two business days of filing the motion for default judgment. The Court will not consider the motion for default judgment unless and until such Affidavit of Service is filed. If more than two business days are required to complete service of the motion for default judgment and supporting papers, the party should file a letter on ECF explaining why additional time is necessary and when the party anticipates service will be completed. The Court will set deadlines for opposition papers to default judgment and for any reply, and will schedule a hearing on the default judgment motion.

F. Voluntary Dismissals. A plaintiff seeking to dismiss an action pursuant to Rule 41(a)(1)(A)(i) of the Federal Rules of Civil Procedure must file a notice of dismissal with the Court. Parties seeking to dismiss an action under Rule 41(a)(1)(A)(ii) must file a stipulation of dismissal signed by all parties who have appeared in the action, regardless of whether those parties have been dismissed from the case. A stipulation of dismissal under Rule 41(a)(1)(A)(ii) must contain handwritten signatures, not electronic signatures, of the parties. Neither a dismissal under Rule 41(a)(1)(A)(i) nor Rule 41(a)(1)(A)(ii) requires an order from the Court. If the parties are requesting dismissal pursuant to Rule 41(a)(2), however, the submission should contain a date and signature line for the Court to “So Order.”

G. Settlement Agreements. The Court will not retain jurisdiction to enforce confidential settlement agreements. If the parties wish the Court to retain jurisdiction to enforce a settlement agreement, the parties must place the terms of their settlement agreement on the public record.
The parties may do this by providing a copy of the settlement agreement for the Court to endorse, attaching the settlement agreement to their stipulation of settlement and dismissal, or including the terms of their settlement agreement in their stipulation of settlement and dismissal.

H. Fair Labor Standards Act (“FLSA”) Settlement Agreements. Parties that seek to settle FLSA claims through a stipulated dismissal with prejudice pursuant to Federal Rule of Civil Procedure 41(a)(1)(A)(ii) must submit the settlement agreement and all other necessary information for Court approval in accordance with Cheeks v. Freeport Pancake House, Inc., 796 F.3d 199 (2d Cir. 2015). The Court will not approve a settlement agreement that contains an overly broad release clause or for which the parties fail to submit all necessary information, including,

inter alia, the parties’ estimations for the plaintiff’s number of hours worked, applicable wages, and a detailed breakdown of the justification for any requested attorneys’ fees. See, e.g., Fernandez v. 219 Dominican Valle Corp., No. 19 Civ. 9513 (JPC), 2021 WL 240721, at *2-4 (S.D.N.Y. Jan. 25, 2021). Parties that settle FLSA claims through a Federal Rule of Civil Procedure 68(a) offer of judgment should not seek Court approval of the disposition. See Mei Xing Yu v. Hasaki Rest., Inc., 944 F.3d 395, 411 (2d Cir. 2019).

I. Bankruptcy Appeals. Briefs must be submitted in accordance with Rules 8014-8018 of the Federal Rules of Bankruptcy Procedure. If the parties wish to extend these dates, they must submit a joint request to the Court no later than 48 hours (i.e., two business days) before the brief is due.

J. Deposition Transcripts. If the parties cite to deposition transcripts in their motion papers, the parties, upon completion of briefing, must confer and submit a single consolidated copy of each cited deposition transcript to the Court that includes all relevant portions of the cited transcripts.

Redactions and Sealed Filings

A. Redactions Not Requiring Court Approval. Nothing herein is intended to alter or modify the applicability of Rule 5.2 of the Federal Rules of Civil Procedure. The redactions expressly authorized by Rule 5.2 may be made without application to the Court.

B. Procedures for Filing Sealed or Redacted Documents. Except for redactions referenced in 4.A above, all redactions or sealing of public court filings require Court approval.
Any party seeking to file a document under seal or in redacted form shall proceed as follows:

i. Meet and Confer. The party seeking leave to file a document under seal or in redacted form shall meet and confer with all other parties in the case (as well as any third party seeking confidential treatment of the information) in advance to narrow the scope of the request. In general, however, the parties’ consent or the fact that information is subject to a confidentiality agreement or protective order between litigants is not, by itself, a valid basis to overcome the presumption in favor of public access to judicial documents. See, e.g., In re Gen. Motors LLC Ignition Switch Litig., No. 14- MD-2543 (JMF), 2015 WL 4750774, at *4 (S.D.N.Y. Aug. 11, 2015).

ii. Filing Sealed or Redacted Documents. Where a party seeks leave to file a document under seal or in redacted form, the party shall file a letter- motion seeking leave to do so on ECF in accordance with Standing Order 19-MC-583 and Section 6 of the S.D.N.Y. ECF Rules and Instructions. The letter-motion itself shall be filed in public view, should explain the reasons for seeking to file the document under seal or in redacted form, and should

not include confidential information. Any application to file a document under seal or in redacted form must demonstrate that the standards for sealing have been met and specifically address Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110 (2d Cir. 2006) and any other controlling authority.
The movant also may file a memorandum of law and an affidavit or affidavits in support of the request for sealing or redacting. If approval for redactions is sought, the application shall also include a proposed redacted version of the document in question for public docketing.

When a party seeks leave to file a document under seal or in redacted form on the ground that an opposing party or third party has requested it, the opposing party or third party must file publicly on ECF, within three business days, a letter explaining the need to seal or redact the document.

In the event there are grounds for sealing or redacting that cannot be publicly disclosed, a party may file under seal on ECF (with appropriate level of restriction) additional briefing further explaining those grounds, along with a justification for the sealing of that briefing.

The subject document, in unredacted form, shall be contemporaneously filed under seal on ECF (with the appropriate level of restriction) and electronically related to the motion (or to the relevant Court order if the Court previously granted leave to file the document under seal). Note that the summary docket text, but not the document itself, will be open to public inspection and therefore should not include confidential information sought to be filed under seal.

When a party seeks to file a document in redacted form, the party also shall e-mail to Chambers (CronanNYSDChambers@nysd.uscourts.gov) and to the Courtroom Deputy, Meghan Henrich (Meghan_Henrich@nysd.uscourt s.gov) an unredacted copy of the document highlighting the proposed redactions.

iii. Submission by Alternative Method. Any party unable to comply with the requirements for electronic filing under seal through the ECF system, or who believes that a particular document should not be electronically filed at all, may submit a letter-motion by e-mail seeking leave of the Court to file in a different manner.

Conferences

A. Attendance by Principal Trial Counsel. Absent leave of the Court, the attorney who will serve as principal trial counsel must appear at all conferences with the Court. Any attorney appearing before the Court must enter a notice of appearance on ECF.

B. Initial Case Management Conference. The Court will generally schedule a conference pursuant to Rule 16(c) of the Federal Rules of Civil Procedure within three months of the filing of the complaint or notice of removal. The Notice of Initial Case Management Conference will be filed on ECF.

Plaintiff’s counsel is responsible for ensuring that all parties have received copies of the Notice of Initial Case Management Conference. The Notice will direct the parties, inter alia, to submit on ECF a joint letter as well as a proposed Civil Case Management Plan and Scheduling Order attached as an exhibit to the joint letter. The parties shall use the form Proposed Case Management Plan and Scheduling Order available at the Court’s website.

C. Discovery Disputes. Parties must follow Local Civil Rule 37.2 with the following modifications. Any party wishing to raise a discovery dispute with the Court must first confer in good faith with the opposing party, in person or by telephone, in an effort to resolve the dispute.
If this meet-and-confer process does not resolve the dispute, a party may raise the dispute with the Court by filing a letter-motion on ECF, no longer than three pages, explaining the nature of the dispute. Such a letter must include a representation that the meet-and-confer process occurred and was unsuccessful. A party opposing the relief sought must file a response, not to exceed three pages, within three business days. The Court will seek to resolve discovery disputes quickly, by order or at an in-person or telephonic conference. Counsel are strongly urged to seek relief in accordance with these procedures in a timely fashion. If a party waits until near the close of discovery to raise an issue that could have been raised earlier, the Court is unlikely to grant additional time for discovery.

Motions

A. Pre-Motion Letters in Civil Cases. Unless otherwise ordered by the Court, a party seeking to file a motion must submit a pre-motion letter in accordance with 1.A above, not to exceed three pages in length absent leave of the Court, notifying the Court of its anticipated motion, summarizing the basis for the anticipated motion, and proposing a briefing schedule. All parties served with the pre-motion letter must submit a letter response, also not to exceed three pages absent leave of the Court, within three business days from the submission of the pre-motion letter.
Response letters may address arguments raised in the pre-motion letter, propose an alternative briefing schedule, and indicate whether the party intends to oppose the contemplated motion or intends to correct any possible deficiencies in lieu of motion practice, such as by filing, or seeking leave to file, an amended complaint. A party’s submission of a pre-motion letter in connection

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

The above requirements shall not apply to motions previously authorized by the Court, discovery motions or disputes (for which parties shall follow 5.C above), motions brought by order to show cause, motions by incarcerated pro se litigants, motions for admission pro hac vice, motions for reargument or reconsideration, motions for appointment of lead plaintiffs and counsel in class actions, motions for remand, motions for a preliminary injunction, motions brought pursuant to Local Rule 6.3, and motions described in Rule 6(b) of the Federal Rules of Civil Procedure and Rule 4(a)(4)(A) of the Federal Rules of Appellate Procedure.

In the event a plaintiff files an amended complaint as of right pursuant to Rule 15(a)(1) of the Federal Rules of Civil Procedure after a defendant has filed a motion to dismiss, that defendant must file a letter with the Court within one week of the amendment, describing whether the defendant seeks to refile the motion as to the amended complaint.

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

C. Oral Argument on Motions. Parties may request oral argument by letter at the time their moving, opposing, or reply papers are filed. Oral argument will be held at the Court’s discretion. If the Court determines that argument will be heard, the Court will advise counsel of the argument date and time. Where junior lawyers are familiar with the matter under consideration, but are not experienced in arguing before a court, they should be encouraged to actively participate.
If oral argument is granted, the Court is amendable to permitting more than one lawyer to argue for a party, especially where it creates an opportunity for a junior lawyer to argue.

Pretrial Procedures in Civil Cases

A. Courtesy Copies. One courtesy copy of each submission described in 7.B–G below should be provided to Chambers on the date that the submission is filed or served.

B. Joint Proposed Pretrial Orders. Unless otherwise ordered by the Court, within 30 days after the close of discovery or if any dispositive motion is filed, within 30 days from the Court’s decision on such motion, the parties shall file on ECF a proposed joint pretrial order that includes the information required by Rule 26(a)(3) of the Federal Rules of Civil Procedure and the following:

i. The full caption of the action;

ii. The names, addresses (including firm names), telephone numbers, e-mail addresses, and any fax numbers of trial counsel;

iii. A brief statement by the plaintiff (or, in a removed case, by the defendant) as to the basis of subject matter jurisdiction and a brief statement by each other party as to the presence or absence of subject matter jurisdiction, each of which shall include citations to all authority relied on and relevant facts as to citizenship and jurisdictional amount;

iv. A brief summary by each party of the claims and defenses that the party has asserted that remain to be tried—without recital of evidentiary matters but with citations to all statutes on which the party has relied—and of any claims and defenses that the party has previously asserted that are not to be tried;

v. A statement by each party as to whether the case is to be tried with or without a jury, and the number of trial days needed;

vi. A joint statement summarizing the nature of the case, to be read to potential jurors during jury selection;

vii. A list of people, places, and institutions that are likely to be mentioned during the course of the trial, to be read to potential jurors during jury selection;

viii. A statement as to whether all parties have consented to a trial of the case by a magistrate judge, without identifying which party or parties have or have not so consented;

ix. Any stipulations of fact or law that have been agreed upon by the parties.
In a jury case, the parties should memorialize any such stipulations or agreed statements of fact or law in a standalone document that can be marked and admitted at trial;

x. A list of all trial witnesses, indicating whether such witnesses will testify in person or by deposition, whether such witnesses will require an interpreter (and, if so, which party will pay the costs for the interpreter), and a brief summary of the substance of each witness’s testimony. Absent leave of the Court, a witness listed by both sides shall testify only once, with any defendant permitted to go beyond the scope of the direct examination on cross examination, and counsel should confer with respect to scheduling;

xi. A designation by each party of deposition testimony to be offered in the party’s case-in-chief, with any cross-designations and objections by any other party. For any deposition with objections, the parties shall also

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

xii. A list by each party of exhibits to be offered in the party’s case-in-chief. If a party objects to an exhibit, the objection should be noted by indicating the Federal Rule of Evidence that is the basis for the objection. If any party believes that the Court should rule on such an objection in advance of trial, that party should include a notation to that effect (e.g., “Advance Ruling Requested”) as well;

xiii. A statement of the damages claimed and any other relief sought, including the manner and method used to calculate any claimed damages and a breakdown of the elements of such claimed damages; and

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

C. Required Pretrial Filings in Jury Cases. Unless otherwise ordered by the Court, in jury cases, the parties shall jointly file the following submissions at the same time as the Joint Proposed Pretrial Order. The parties must meet and confer in an effort to reach agreement with respect to these submissions:

i.
Joint proposed voir dire questions—a copy of which shall be e-mailed to Chambers in Word and .pdf versions—which shall include the text of any requested questions and should consist of a single document that notes any areas of disagreement between the parties;

ii. A joint proposed verdict form—a copy of which shall be e-mailed to Chambers in Word and .pdf versions—and which should consist of a single document that notes any areas of disagreement between the parties;

iii. Joint proposed jury instructions—a copy of which shall be e-mailed to Chambers in Word and .pdf versions—and which shall include the text of any requested instructions and citations, if relevant, to the authority from which such instruction derives, and should consist of a single document that notes any areas of disagreement between the parties;

iv.
Motions addressing any evidentiary or other issues that should be resolved in limine, with oppositions to such motions due one week after the lead motions and no replies allowed absent leave of the Court; and

v. In cases in which a party believes it would be useful to the Court, a pretrial memorandum of law, not to exceed 3,500 words (excluding the caption, any index, table of contents, table of authorities, signature blocks, or any

required certificates, but including material contained in footnotes or endnotes) absent leave of the Court, addressing any issues of law that are expected to arise at or before trial, with any responses or oppositions to those legal issues due one week later.

D. Required Pretrial Filings in Non-Jury Cases. Unless otherwise ordered by the Court, in non-jury cases, the parties shall file the following submissions at the same time as the Joint Proposed Pretrial Order:

i. Joint proposed findings of fact and conclusions of law—a copy of which shall be e-mailed to Chambers in .pdf version—which should be detailed and note any areas of disagreement between the parties and, for each proposed factual finding, shall include citations to the record;

ii. Motions addressing any evidentiary or other issues that should be resolved in limine, with oppositions to such motions due one week after the lead motions and no replies allowed absent leave of the Court; and

iii. In cases in which a party believes it would be useful to the Court, a pretrial memorandum of law, not to exceed 3,500 words (excluding the caption, any index, table of contents, table of authorities, signature blocks, or any required certificates, but including material contained in footnotes or endnotes) absent leave of the Court, addressing any issues of law that are expected to arise at or before trial, with any responses or oppositions to those legal issues due one week later.

E. Additional Submissions in Non-Jury Cases. In addition, at the time the Joint Pretrial Order is filed, each party shall serve the following submissions, one courtesy copy of which the party shall also submit to Chambers:

i. Affidavits—the originals of which shall be marked as exhibits at trial— constituting the direct testimony of each trial witness, except for testimony of an adverse party, a person whose attendance must be compelled by subpoena, or a person for whom a party has requested and from whom the Court has agreed to hear direct testimony during the trial; and

ii. All deposition excerpts that will be offered as substantive evidence, as well as a one-page synopsis of those excerpts for each deposition (with citations to the pertinent pages of the deposition transcript).

F. Courtesy Copies of Documentary Evidence. All exhibits must be pre-marked in advance of trial. Unless otherwise ordered by the Court, in both jury and non-jury trials, three days prior to trial, each party shall submit to Chambers a flash drive containing electronic copies

of all documentary exhibits organized by exhibit number and a document listing all exhibits sought to be admitted. The list of all exhibits sought to be admitted shall be separated into four columns labeled: (1) Exhibit Number; (2) Description (of the exhibit); (3) Date Identified; and (4) Date Admitted. If the number of exhibits is so voluminous as to make compliance with this rule impractical, the parties shall contact the Court for guidance.

Policy on the Use of Electronic Devices

A. Standing Order M10-468. Attorneys’ use of mobile phones, personal electronic devices, and general-purpose computing devices such as laptops and tablets within the Courthouse and its environs is governed by Standing Order M10-468.

B. Mobile Phones. Attorneys in compliance with the Standing Order may bring mobile phones into the courtroom, but the phones must be turned off at all times. Non-compliance with this rule will result in forfeiture of the device for the remainder of the proceedings.

If you have any questions after reading these Individual Rules and Practices, please contact Meghan Henrich, Courtroom Deputy.

Individual Rules and Practices in Criminal Cases

Revised: March 14, 2025

INDIVIDUAL RULES AND PRACTICES IN CRIMINAL CASES

JOHN P. CRONAN UNITED STATES DISTRICT JUDGE SOUTHERN DISTRICT OF NEW YORK

Chambers

Courtroom United States District Court

Courtroom 12D Southern District of New York

500 Pearl Street

500 Pearl Street, Room 1320

Meghan Henrich, Courtroom Deputy New York, NY 10007

CronanNYSDChambers@nysd.uscourts.gov

Unless otherwise ordered by the Court, these Individual Rules and Practices shall apply to all criminal matters before Judge Cronan.

Communications with Chambers

A. Arraignment and Initial Pretrial Conference. Upon assignment of a criminal case to Judge Cronan, the Assistant United States Attorney (“AUSA”) shall immediately call Chambers to arrange for a court appearance, at which the defendant with counsel will be present, which will consist of the defendant’s arraignment and an initial pretrial conference. At this court appearance, the Court most likely will set a discovery and motion schedule. The AUSA shall e-mail a courtesy copy of the Indictment and the criminal Complaint, if one exists, to the Court (CronanNYSDChambers@nysd.uscourts.gov) as soon as practicable.

B. Telephone Calls. Most communications with Chambers, including requests for extensions or adjournments, shall be by letter or letter-motion filed on the Electronic Case Filing (“ECF”) system in accordance with 1.C and 3.A below. For questions that cannot be answered by reference to these Rules or the S.D.N.Y. Local Rules, or for docketing, scheduling, and calendar matters, counsel may contact the Courtroom Deputy, Meghan Henrich. For situations requiring immediate attention from the Court, counsel should call Chambers directly; in such situations, parties should email the Chambers inbox requesting the Court’s contact information.

C. Letters. Any letter to the Court shall be filed on ECF and also e-mailed as a .pdf attachment to the Court (CronanNYSDChambers@nysd.uscourts.gov) with a copy simultaneously delivered to all counsel. Letters should not exceed five pages in length (single-spaced, 12-point font) absent leave of the Court. E-mails shall state clearly 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 letter. Parties shall not include substantive communications in the body of the e-mail; such communications shall be included only in the body of the letter. Copies of correspondence

between counsel shall not be sent to the Court or docketed on ECF, except if the correspondence is a relevant attachment to a filing. Letters seeking relief, including requests for extensions, adjournments, or bail modification, shall be filed on ECF as letter-motions and not as ordinary letters. For letters to be filed under seal or containing sensitive or confidential information, please refer to 9.A through 9.C below.

D. Faxes. Faxes to Chambers are not permitted.

E. Requests for Adjournments or Extensions of Time. Requests for adjournments or extensions of time must be made in writing and filed on ECF as letter-motions in accordance with 2.A below, not as ordinary letters. All requests for adjournments or extension of time must state (1) the original date(s) set for the appearance or deadline(s) and the new date(s) requested; (2) the reason(s) for the request; (3) the number of previous requests for an adjournment or extension; (4) whether these previous requests were granted or denied; and (5) whether opposing counsel consents and, if not, any reasons given by opposing counsel for refusing to consent.

If a party seeks an exclusion of time under the Speedy Trial Act, 18 U.S.C. § 3161, the party should also include the grounds that would permit the Court to make an independent finding whether to exclude time in conformance with 18 U.S.C. § 3161. Additionally, the party seeking exclusion of time must confer with the opposing party and indicate in its letter-motion whether the opposing party consents. Any party opposing the request may file a short opposition within two business days.

Absent compelling circumstances, a request for an extension or adjournment must be made at least 48 hours (i.e., two business days) prior to the deadline or scheduled appearance. Requests for extensions will ordinarily be denied if made after the expiration of the original deadlines.

F. Docketing of Letters. Absent a request to file a letter under seal, the parties should assume that any substantive letter received by the Court, whether by regular mail, hand delivery, or e-mail, that is not filed on ECF will be docketed by the Court.

G. Hand Deliveries. Hand-delivered mail should be left with the Court Security Officers at the Worth Street entrance of the Daniel Patrick Moynihan United States District Courthouse at 500 Pearl Street, New York, NY 10007, and may not be brought directly to Chambers, except by representatives of the United States Attorney’s Office or the Federal Defenders of New York.
Hand deliveries are continuously retrieved from the Worth Street entrance by Courthouse mail staff. If the hand-delivered letter is urgent and requires the Court’s immediate attention, the party should ask the Court Security Officers to notify Chambers that an urgent package has arrived that needs to be retrieved by Chambers staff immediately.

Rules for All Filings A. Electronic Case Filing (ECF). In accordance with the S.D.N.Y. ECF Rules and Instructions, all counsel are required to register promptly as ECF filers after being retained or assigned and to enter an appearance in the case. Counsel can obtain instructions on how to register at http://www.nysd.uscourts.gov/ecf_filing.php. Counsel are responsible for updating their contact information on ECF, should it change, and they are responsible for checking the docket sheet regularly, regardless of whether they receive an ECF notification of case activity.

If an ECF submission requires immediate attention from the Court, counsel should notify Chambers by telephone after filing the submission via ECF.

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

B. Memoranda of Law. There is no limitation on the number of pages or words for memoranda of law in criminal cases. Memoranda of law of 10 pages or more shall contain a table of contents and a table of authorities. Motion papers shall be filed promptly after service.

C. Unpublished Cases. Westlaw or Lexis citations shall be provided, if available, to cases not available in an official reporter. Parties must provide copies of cases that are not available on Westlaw or Lexis.

D. Courtesy Copies. Regarding all motion papers, including exhibits submitted in connection with a motion, a party shall submit an electronic courtesy copy via e-mail to Chambers at the time the papers are served. A paper copy should not be submitted to Chambers unless requested by the Court.

Motions

A. Letter-Motions. Letter-motions must be filed via ECF and must comply with the S.D.N.Y. Local Rules and the S.D.N.Y. ECF Rules and Instructions. As set forth in 1.E, all requests for adjournments and extensions should be filed as letter-motions. If practicable, all letter-motions should be text-searchable.

B. Discovery Motions. In making discovery motions, counsel must comply with Local Criminal Rule 16.1, including by providing an affidavit pursuant to Local Rule 16.1.

Defense Counsel

A. Benefactor Payments. Whenever defense counsel has received, or is receiving, a benefactor payment that subjects counsel to a conflict of interest, said counsel must inform the Court and request a hearing pursuant to United States v. Curcio, 680 F.2d 881 (2d Cir. 1982), at the first conference.

B. Other Conflicts. Counsel have an obligation to promptly inform the Court upon learning of any other conflict of interest, whether a potential or actual conflict, and to request a Curcio hearing if appropriate.

C. Substitution of Counsel. When there is a request for substitution of defense counsel, counsel of record must file a letter-motion on ECF in accordance with 3.A above to request that a conference be scheduled as soon as possible. At the conference, the Court will address the application by defense counsel to be relieved. Counsel of record (i.e., current counsel), the defendant, replacement counsel, and the AUSA must attend the conference.

Bail Modifications and Appeals

A. Bail Modifications. Any written request for a bail modification by a defendant shall be filed on ECF as a letter-motion in accordance with 3.A above and shall indicate whether the Government and Pretrial Services Officer consent to the request.

B. Bail Appeals. A party who wishes to appeal an adverse bail determination by the Magistrate Judge should contact Chambers to arrange a conference for that purpose. Unless otherwise ordered, the party bringing the appeal must provide to the Court, no fewer than 24 hours before the conference, the transcript of the argument on bail before the Magistrate Judge, and any written submissions before the Magistrate Judge as to bail.

Guilty Pleas

A. Plea/Cooperation Agreements and Pimentel Letters. When a defendant is pleading guilty pursuant to a plea agreement or a cooperation agreement, a copy of the agreement ordinarily must be received by Chambers at least two business days before the scheduled plea. Where the Government is providing a Pimentel letter, a copy of the letter ordinarily must be received by Chambers no fewer than two business days before the scheduled plea. These documents should be e-mailed to the Court at CronanNYSDChambers@nysd.uscourts.gov.

B. Preparation for Allocution. Prior to the date set for the plea, defense counsel is expected to have reviewed with the defendant—if necessary, with the assistance of an interpreter— any Pimentel letter or plea, cooperation, or other agreement, as well as the rights the defendant would be waiving by pleading guilty. The parties should execute any plea or cooperation agreement prior to the time set for plea. The defendant should also be prepared in advance of a guilty plea to give a narrative allocution that incorporates all of the elements of the offense(s) to which the defendant is pleading guilty.

The Court further expects that defense counsel will have determined whether detention of the defendant is required upon entry of a guilty plea pursuant to 18 U.S.C. § 3143(a)(2) and other provisions of the Bail Reform Act, and to prepare the defendant for the possibility of detention commencing at the end of the plea proceeding.

Trials

A. Pre-Trial Deadlines and Submissions. The Court’s practice is to enter an order scheduling a final pretrial conference and setting deadlines for the submission of proposed jury voir dire, proposed requests to charge, proposed verdict forms, and any motions in limine.

B. Proposed Voir Dire, Jury Instructions, and Verdict Forms. At the time of filing, each party should e-mail courtesy copies of its proposed jury voir dire, jury instructions, and verdict form in Microsoft Word format to Chambers at CronanNYSDChambers@nysd.uscourts.gov. In their proposed voir dire, parties should include a brief description of the case and a list of names and places likely to be mentioned at trial, both to be read to prospective jurors during jury selection. In their proposed jury instructions, the parties are not required to submit proposed language for standard instructions—for example, the role of the Court and the jury, the standard of proof, etc.—but may do so if they desire.

C. Exhibit Lists. Unless otherwise ordered, no later than one week before trial, each party shall e-mail to the Court at CronanNYSDChambers@nysd.uscourts.gov a Microsoft Word document listing all exhibits sought to be admitted. The list shall be separated into four columns labeled (1) Exhibit Number; (2) Description (of the exhibit); (3) Date Identified; and (4) Date Admitted. The submitting party shall complete the first two columns, but leave the third and fourth columns blank, to be filled in by the Court during trial.

D. Exhibits and 3500 Material. Unless otherwise ordered, no later than the Friday before the start of trial, each party must provide the Court with a flash drive containing the exhibit list with a brief description of each exhibit and .pdf copies of pre-marked documentary exhibits, as well as Section 3500 material from the Government, in sequential order separated by numbered parts. Unless otherwise ordered, the parties shall not submit hard copies of these materials.

Sentencing

A. Sentencing Submissions. Unless otherwise ordered by the Court, a defendant’s sentencing submission shall be served on the Government and e-mailed to Chambers no later than two weeks before the date set for sentencing. The Government’s sentencing submission shall be served on the defendant and e-mailed to Chambers no later than one week before the date set for sentencing. For the sentencing of a cooperating witness for whom the Government will be making a motion pursuant to U.S.S.G. § 5K1.1 and 18 U.S.C. § 3553(e), however, the Government’s sentencing submission shall be filed no later than two weeks in advance of sentencing. Any proposed redaction in or sealing of sentencing submissions must comply with 9.A through 9.C below. If a party does not intend to file a substantive sentencing submission, the party shall file and serve a letter to that effect.

B. ECF Filing. Every document in a sentencing submission is to be filed through ECF, except if filed under seal or in unredacted form, in accordance with 9.A through 9.C below. Letters

should be grouped and filed together as attachments to a single document marked “SENTENCING SUBMISSION” with the caption and docket number clearly indicated.

Redactions and Sealed Filings

A. Redactions Not Requiring Court Approval. The parties are referred to the E- Government Act of 2002 and the Southern District’s ECF Privacy Policy (“Privacy Policy”).
There are two categories of information that may be redacted from public court filings without prior permission from the Court: “sensitive information” and information requiring “caution.”
Parties should not include in their public filings, unless necessary, the five categories of “sensitive information” (i.e., social security numbers [use the last four digits only], names of minor children [use the initials only], dates of birth [use the year only], financial account numbers [use the last four digits only], and home addresses [use only the City and State]). Parties may also, without prior approval from the Court, redact from their public filings the six categories of information requiring “caution” described in the Privacy Policy (i.e., any personal identifying number, medical records [including information regarding treatment and diagnosis], employment history, individual financial information, proprietary or trade secret information, and information regarding an individual’s cooperation with the government).

B. Procedures for Filing Redacted Documents. Except for redactions referenced in 9.A above, all redactions of public court filings require Court approval. Any party seeking to file a document in redacted form shall proceed in the following three steps:

i. ECF Filing of the Redacted Document(s). The party should file the redacted version of the document publicly on ECF.

ii. Filing or E-mailing a Letter-Motion Seeking Leave to File with Redactions.
The party should simultaneously file on ECF a letter-motion seeking leave to file the document with those redactions. The letter-motion must explain the purpose of the redactions, and demonstrate why the redactions are narrowly tailored to serve whatever purpose justifies the redacting or sealing and must be otherwise consistent with the presumption in favor of public access to judicial documents. See, e.g., United States v. Amodeo, 71 F.3d 1044, 1048-53 (2d Cir. 1995); Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110, 119-26 (2d Cir. 2006). In general, the parties’ consent or the fact that information is subject to a confidentiality agreement or protective order between litigants is not, by itself, a valid basis to overcome the presumption in favor of public access to judicial documents. See, e.g., In re Gen. Motors LLC Ignition Switch Litig., No. 14- MD-2543 (JMF), 2015 WL 4750774, at *4 (S.D.N.Y. Aug. 11, 2015).

The party should seek to draft the letter-motion in a form that can be filed publicly on ECF. If, however, the party believes that the letter-motion itself should be sealed or redacted, the party should include an unredacted copy of

the letter-motion as an attachment to the e-mail described in 9.B.iii below and— if possible—file a redacted version of the letter-motion publicly on ECF.

iii. E-mailing of Documents to Chambers. Simultaneously, the party should e- mail to Chambers (CronanNYSDChambers@nysd.uscourts.gov) and to the Courtroom Deputy, Meghan Henrich (Meghan_Henrich@nysd.uscourts.gov) (1) a clean (i.e., unredacted) copy of the document; (2) a copy of the document highlighting the information that has been redacted in the ECF filing; and (3) an unredacted copy of the letter-motion described in 9.B.ii above, should the party also be seeking leave to file that letter-motion with redactions under seal.

C. Procedure for Filing Sealed Documents. Any party seeking to file a document under seal shall proceed as follows:

i. Sealing Exhibits. Any party seeking leave to file an unsealed or redacted document with a fully sealed exhibit attached thereto should file the main document (in accordance with the procedures in 9.B above, if the party seeks to do so with redactions) on ECF, accompanied by a single page marked “SEALED” in place of any exhibit that the party seeks leave to file under seal, regardless of the actual length of such exhibit. The party should simultaneously file a letter-motion seeking leave to file in that manner according to the procedure described in 9.B.ii and 9.B.iii above.

ii. Sealing Entire Documents. Any party seeking leave to file under seal an entire submission (with or without exhibits) should not file anything on ECF in the first instance. The party should instead e-mail an unredacted copy of the submission to Chambers (CronanNYSDChambers@nysd.uscourts.gov) and to the Courtroom Deputy, Meghan Henrich (Meghan_Henrich@nysd.uscourts.gov) and include as an attachment to the e- mail a letter-motion seeking leave to file in that manner addressing the standards set forth in 9.B.ii above. See, e.g., Amodeo, 71 F.3d at 1048-53; Lugosch, 435 F.3d at 119-26.

D. Filing Instructions. The Court will include any further instructions, including for the filing sealed or redacted versions of the document(s) and the accompanying letter-motion, in its order disposing of the application to redact or seal.

Policy on the Use of Electronic Devices

A. Standing Order M10-468. Attorneys’ use of mobile phones, personal electronic devices, and general purpose computing devices such as laptops and tablets within the Courthouse and its environs is governed by Standing Order M10-468.

B. Mobile Phones. Attorneys in compliance with the Standing Order may bring mobile phones into the courtroom, but the phones must be turned off at all times. Non-compliance with this rule will result in forfeiture of the device for the remainder of the proceedings.

If you have any questions about these practices, please contact Meghan Henrich, Courtroom Deputy.

Individual Rules and Practices for Pro Se Litigants

Revised: October 23, 2025

INDIVIDUAL RULES AND PRACTICES FOR PRO SE LITIGANTS

JOHN P. CRONAN UNITED STATES DISTRICT JUDGE SOUTHERN DISTRICT OF NEW YORK

Chambers

Courtroom United States District Court

Courtroom 12D Southern District of New York

500 Pearl Street

500 Pearl Street, Room 1320

Meghan Henrich, Courtroom Deputy New York, NY 10007

CronanNYSDChambers@nysd.uscourts.gov

Pro Se Intake Unit Mailing Address Pro Se Intake Unit United States District Court
Southern District of New York Daniel Patrick Moynihan United States Courthouse 500 Pearl Street New York, NY 10007
(212) 805-0175

Unless otherwise ordered by the Court, these Individual Practices apply to all civil cases involving pro se litigants (that is, litigants without counsel) before Judge Cronan.

Pro Se Law Clinic

Pro se parties should take note that there is a Pro Se Law Clinic in this District which is designed to assist non-incarcerated people who are parties in civil cases and do not have lawyers. The Clinic may be able to provide a non-incarcerated pro se litigant with advice in connection with his or her case. The Pro Se Law Clinic is run by a private organization called the New York Legal Assistance Group; it is not part of, or run by, the Court (and, among other things, therefore cannot accept filings on behalf of the Court, which must still be made by any unrepresented party through the Pro Se Intake Unit, whose address is above). The Clinic is located in the Thurgood Marshall United States Courthouse, 40 Centre Street, New York, New York, in Room LL22, which is just inside the Pearl Street entrance to that Courthouse.

Communications with Chambers

A. Communications Generally. All communications with the Court by a pro se party, including letter-motions, should be (1) mailed to the Pro Se Intake Unit, Daniel Patrick Moynihan United States Courthouse, 500 Pearl Street, New York, New York 10007 or (2) delivered in person to the drop box in the lobby of the United States Courthouse at 500 Pearl Street, New York, New

York, or the United States Courthouse at 300 Quarropas Street, White Plains, New York. Unless otherwise ordered by the Court, no correspondences, documents, or court filings, may be emailed or otherwise sent directly to Chambers. Any questions should be directed to the Pro Se Intake Unit at (212) 805-0175; pro se parties may not call the Court directly.

Unless the Court orders otherwise, all communications with the Court will be docketed upon receipt; such docketing shall constitute service on any user of the Electronic Case Filing (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 that party and include an Affidavit of Service or other statement affirming that it has done so. Copies of correspondence between a pro se party and opposing parties shall not be sent to the Court.

B. Requests for Adjournments or Extensions of Time. Requests for adjournments or extensions of time must be made in writing. All requests for adjournments or extensions of time must state (1) the original date(s) set for the appearance or deadline(s) and the new date(s) requested; (2) the reason(s) for the request; (3) the number of previous requests for adjournment or extension; (4) whether these previous requests were granted or denied; and (5) whether the opposing party consents, and, if not, the reasons given by the opposing party for refusing to consent.

Requests for extensions of deadlines regarding a matter that has been referred to a Magistrate Judge shall be directed to that assigned Magistrate Judge.

Absent compelling circumstances, any request for extension or adjournment must be made at least 48 hours prior to the deadline or scheduled appearance. Requests for extensions will ordinarily be denied if made after the expiration of the original deadline.

3.     Filing of Papers and Service 
   

A. Papers Filed by a Pro Se Party. All papers to be filed with the Court by a pro se party, along with one courtesy copy of those papers, shall be (1) mailed to the Pro Se Intake Unit, Daniel Patrick Moynihan United States Courthouse, 500 Pearl Street, New York, New York 10007 or (2) delivered in person to the drop box in the lobby of the United States Courthouse at 500 Pearl Street, New York, New York, or the United States Courthouse at 300 Quarropas Street, White Plains, New York. Any pro se party that wishes to participate in electronic case filing (“e- filing”) must file a Motion for Permission for Electronic Case Filing (available at https://nysd.uscourts.gov/forms/motion-permission-electronic-case-filing-pro-se-cases and in the Pro Se Intake Unit). If the Court grants a motion to participate in “e-filing,” that party will not receive hard copies of any document filed electronically via ECF.

B. Service on a Pro Se Party. Unless a pro se party has consented to electronic service, counsel in pro se cases must serve a pro se party with a paper copy of any document that is filed electronically and must file with the Court a separate Affidavit of Service.
Submissions filed without proof of service that the pro se party was served will not be considered.

C. Use of Artificial Intelligence (“AI”) Tools. All litigants, including pro se litigants, are responsible for providing the Court with complete and accurate representations of the record, the procedural history of the case, and any cited legal authorities. Pro se litigants therefore are responsible for verifying the accuracy of any output produced in whole or in part by an AI tool. If a pro se litigant uses an AI tool in preparing any filing, the litigant must attached to the filing a signed certification (i) stating whether the litigant personally reviewed the filing for accuracy of cited legal authorities and factual assertions and (ii) if so, describing in detail the steps taken to verify the accuracy of all legal authorities and factual assertions generated by the AI tool. A pro se litigant’s failure to review an AI-assisted filing for accuracy, or to provide the required certification, violates this Rule. The Court may impose sanctions and/or strike the filing for failure to comply with this Rule. A model certification may be found on the Court’s website (https://www.nysd.uscourts.gov/hon-john-p-cronan).

4.     Discovery 
   

All requests for discovery by a pro se party should be sent to counsel for the party from whom discovery is sought. Discovery requests should not be sent to the Court.

If there are any discovery disputes, the parties are required to confer with one another to try to resolve the dispute without the need for Court intervention. If the parties are unable to resolve their dispute, either party may file a letter-motion, no longer than three pages and in accordance with Paragraph 2(a) above, to raise the dispute with the Court. The letter-motion shall explain the nature of the dispute as well as the efforts to resolve the dispute and why they were unsuccessful. If the opposing party wishes to respond to the letter, it must promptly file a responsive letter, also not to exceed three pages. The Court will seek to resolve discovery disputes quickly, by order or at an in-person or telephonic conference. Parties are strongly urged to seek relief in accordance with these procedures in a timely fashion. If a party waits until near the close of discovery to raise an issue that could have been raised earlier, the Court is unlikely to grant additional time for discovery.

5.     Motions 
   

A. Filing and Service. Unless otherwise ordered by the Court, papers filed in opposition to a motion must be served and filed within 30 days of service of the motion papers, and reply papers, if any, must be served and filed within two weeks of receipt of opposition papers.

B. Pro Se Notices. Parties who file a motion to dismiss, a motion for judgment on the pleadings, or a motion for summary judgment must provide the pro se party with a copy of the notices required under Local Civil Rules 12.1 or 56.2.

C. Courtesy Copy. One courtesy hard 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. Courtesy copies should not be submitted to Chambers at the time of filing. If all the parties are pro se, then no courtesy copies of formal motion papers are required.

D. Oral Argument. Oral argument on a motion will only occur if ordered by the Court.

6.     Initial Case Management Conference 
   

Absent a motion to dismiss, the Court will typically schedule an initial case management conference within three months of the filing of the complaint. The Notice of Initial Pretrial Conference will be docketed on ECF and mailed to the pro se party or parties, unless the pro se party has consented to electronic service, in which case the party will only receive electronic notification via ECF.

The Court will set a schedule for the case at the initial case management conference. In most cases, the Court will give the parties four months (from the date of the conference) to complete all discovery, and set a deadline for the filing of any motions for summary judgment 30 days after the close of discovery. In advance of the initial case management conference, the parties should, if practicable, confer with one another to determine if such a schedule would be appropriate or if there is anything unusual about the case that would require more time and be prepared to discuss those issues at the conference. The Court will issue a written order memorializing all dates and deadlines following the conference.

An incarcerated party may not be able to attend this or other conferences, but may be able to participate by telephone. If an incarcerated party does not have counsel and is unable to participate by telephone, a family member or a representative may attend the conference. In such instances, the incarcerated party may write to the Court in advance of the conference regarding any issue the pro se party wishes to have addressed at the conference. If a representative is designated, he or she should contact Chambers to determine the time and location of the conference.

7.     Trial Documents 
   

A. Pretrial Statement. Unless otherwise ordered by the Court, within 30 days of the completion of all discovery or, if a summary judgment motion is filed, within 30 days of the Court’s ruling on summary judgment, the plaintiff in a pro se case shall file a concise, written Pretrial Statement. This Statement need take no particular form, but it must contain the following: (1) a statement of the facts the plaintiff hopes to prove at trial; (2) a list of all documents or other physical objects that the plaintiff plans to put into evidence at trial; and (3) a list of the names and addresses of all witnesses the plaintiff intends to have testify at trial. The Statement must be sworn by the plaintiff to be true and accurate based on the facts known by the plaintiff. If pro se, the plaintiff shall file an original of this Statement, plus one courtesy copy, with the Pro Se Intake Unit. Two weeks after service of the plaintiff’s Statement, the defendant must file and serve a similar Statement of its case containing the same information.

B. Other Pretrial Filings. If the case is to be tried before only Judge Cronan without a jury, any parties represented by counsel must also file proposed findings of fact and conclusions of law at the time of filing the Pretrial Statement. If the case is to be tried before a jury, any parties represented by counsel must also file proposed voir dire questions, a proposed jury charge, and a proposed verdict form at the time of filing the Pretrial Statement. At the time of filing, a represented party should e-mail these documents to the Court (Cronan_NYSDChambers@ nysd.uscourts.gov), in both .pdf and Microsoft Word formats. The pro se party may file such

documents, but is not required to do so, and need not submit them by e-mail. If the pro se party elects to file such documents, that party should do so via the Pro Se Intake Unit, as outlined in 3.A above.

Civil Case Management Plan and Scheduling Order

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK

Plaintiff(s), -v-

Defendant(s).

X : : : : : : : : : : X

CV
(JPC) CIVIL CASE MANAGEMENT PLAN AND SCHEDULING ORDER

This Civil Case Management Plan (the “Plan”) is submitted by the parties in accordance with Rule 26(f)(3) of the Federal Rules of Civil Procedure.

All parties [consent /do not consent ] to conducting all further proceedings before a United States Magistrate Judge, including motions and trial. 28 U.S.C. § 636(c). The parties are free to withhold consent without adverse substantive consequences.

Settlement discussions [have /have not ] taken place.

The parties [have /have not ] conferred pursuant to Rule 26(f) of the Federal Rules of Civil Procedure.

Unless a party amends a pleading as a matter of course pursuant to Federal Rule of Civil Procedure 15(a)(1), amended pleadings may not be filed and additional parties may not be joined except with leave of the Court. Any motion for leave to amend or to join additional parties shall be filed by _ . [Absent exceptional circumstances, a date not more than 30 days following the date of this Order.]

Initial disclosures pursuant to Rule 26(a)(1) of the Federal Rules of Civil Procedure shall be completed no later than days from the date of this Order. [Absent exceptional circumstances, fourteen (14) days.]

Fact Discovery

a. All fact discovery shall be completed no later than
. [A period not to exceed 120 days, unless the Court finds that the case presents unique complexities or other exceptional circumstances.]

b. Initial requests for production of documents shall be served by

.

c. Interrogatories shall be served by
.

d. Depositions shall be completed by ____________________. (i) Absent an agreement between the parties or an order from the Court, depositions are not to be held until all parties have responded to initial requests for document production. (ii) There is no priority in deposition by reason of a party’s status as a plaintiff or a defendant. (iii) Absent an agreement between the parties or an order from the Court, non- party depositions shall follow initial party depositions.

e. Requests to admit shall be served by ____________________.

f. Any of the deadlines in paragraphs 6(b) through 6(e) may be extended by the written consent of all parties without application to the Court, provided that all fact discovery is completed by the date set forth in paragraph 6(a).

Expert Discovery

a. All expert discovery, including expert depositions, shall be completed no later than ____________________. [Absent exceptional circumstances, a date forty-five (45) days from the date in paragraph 6(a) (i.e., the completion of all fact discovery).]

b. Plaintiff’s expert disclosures pursuant to Rule 26(a)(2) of the Federal Rules of Civil Procedure shall be made on or before ____________________.

c. Defendant’s expert disclosures pursuant to Rule 26(a)(2) of the Federal Rules of Civil Procedure shall be made on or before ____________________.

d. The interim deadlines in paragraphs 7(b) and 7(c) may be extended by the written consent of all parties without application to the Court, provided that expert discovery is completed by the date set forth in paragraph 7(a).

All motions and applications shall be governed by the Court’s Individual Rules and Practices in Civil Cases.

Any discovery disputes shall be addressed according to 5.C of the Court’s Individual Rules and Practices in Civil Cases.

All discovery must be completed by ____________________. [This date should be the later of the dates in 6(a) and 7(a) above.]

All counsel must meet in person to discuss settlement within fourteen (14) days following the close of fact discovery. If the parties believe that a referral to the assigned Magistrate Judge for a settlement conference or to the Court-annexed mediation program would assist in these discussions, the parties should file a letter with the Court to that effect.

Unless otherwise ordered by the Court, within thirty (30) days after the close of discovery or, if a dispositive motion has been filed, within thirty (30) days of a decision on such motion, the parties shall submit a proposed Joint Pretrial Order prepared in accordance with Rule 26(a)(3) of the Federal Rules of Civil Procedure and 7.B of the Court’s Individual Rules and Practices in Civil Cases. The parties shall follow the Court’s Individuals Rules and Practices in Civil Cases for any submissions that must be made at the time of the Joint Pretrial Order, including any motions in limine.
13. In accordance with 7.C of the Court’s Individual Rules and Practices in Civil Cases, counsel are required to meet and confer on a joint submission of proposed voir dire questions, jury instructions, and verdict form, noting any points of disagreement in the joint submission. Jury instructions may not be submitted after the Joint Pretrial Order due date, unless they meet the standard of Rule 51(a)(2)(A) of the Federal Rules of Civil Procedure. If this action is to be tried to the Court, proposed findings of fact and conclusions of law should be submitted on the Joint Pretrial Order due date in accordance with 7.D of the Court’s Individual Rules and Practices in Civil Cases.

The parties shall be ready for trial as of two weeks following the deadline for the proposed Joint Pretrial Order.

This case [is /is not ] to be tried to a jury.

Counsel for the parties have conferred and their best estimate of the length of trial is ____________________.

Other issues to be addressed at the Initial Pretrial Conference, including those set forth in Rule 26(f)(3) of the Federal Rules of Civil Procedure, are set forth below.

Next Steps: [To be completed by the Court.]

  The next Case Management Conference is scheduled for ____________________ at 
                   ____________________. 

                   The parties shall submit a joint status letter to the Court no later than _____________,  

advising the Court as to whether the parties request a referral to the assigned Magistrate Judge for a settlement conference or to the Court-annexed mediation program, whether any party plans to file a post-discovery motion, the anticipated grounds for any such motion, and the opposing party’s anticipated grounds for opposing the motion. In the event any party plans to file a post-discovery motion, the joint status letter will satisfy the Court’s pre-motion letter requirement.

This Order may not be modified or the dates herein extended, except by further Order of this Court for good cause shown. Any application to modify or extend the dates herein (except as provided in paragraph 6(f) and 7(d)) shall be made in a written application in accordance with Court’s Individual Rules and Practices in Civil Cases and shall be made no less than two (2) business days prior to the expiration of the date sought to be extended.

SO ORDERED.

JOHN P. CRONAN United States District Judge Dated:

New York, New York

Model Certification Regarding Use of Artificial Intelligence in Filings

Revised: October 23, 2025

Model Certification Regarding Use of Artificial Intelligence in Filings

Case Name:

Case Number: _________________________

I, __________________________ [print name], certify that, with respect to the filing submitted in this case on ______________ [date] and titled _________________________ _________________________, I used an artificial intelligence (“AI”) tool in preparing the filing.

I further certify that:

1. ☐ I personally reviewed the filing for accuracy. ☐ I did not personally review the filing for accuracy (failure to do so violates the Court’s Rules).
2. If I reviewed the filing for accuracy, I took the following steps to verify the accuracy of all cited legal authorities and factual assertions generated by the AI tool:

I understand that I remain individually responsible for verifying the accuracy of any output produced by an AI tool, and that failure to comply with the Court’s Rules may result in the filing being stricken and/or the imposition of sanctions.

Signed: ______________________________________ Date: ___________________

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