Hon. George B. Daniels

II. COMMUNICATIONS WITH CHAMBERS A. Letters. All communications with Chambers shall be filed by letter electronically on ECF. In addition, the following rules apply: i. Letters submitted to Chambers shall state clearly in the subject line: (1) the caption of the case, including the docket number and names of the lead parties; and (2) a brief description of the contents of the letter. Letters that pertain to multiple cases shall list all relevant docket numbers in the subject line. ii. In multi-defendant criminal matters, letters that pertain only to an individual defendant shall identify the docket number specific to that individual defendant (e.g., 1:14-cr-12345-01) and include the defendant's name. iii. Copies of correspondence solely between counsel shall not be filed on ECF or sent to Chambers (except as exhibits to a properly filed document). B. Telephone Calls. Telephone calls to Chambers are permitted only in emergency situations requiring immediate attention. i. The following calls to Chambers are never permitted: 1. Ex parte calls (absent extraordinary justification, counsel for all affected parties should be on the line when a call to Chambers is placed, except that similarly situated parties may designate a lead counsel to represent them on such a call); 2. Calls from pro se litigants (pro se litigants should call the Office of Pro Se Litigation at (212) 805-0175 for questions regarding their cases); 3. Calls requesting substantive or procedural legal advice; 4. Calls requesting updates regarding the status of filings; and 5. Questions about how to file case documents electronically. Electronic Case Filing questions should be directed to the ECF Help Desk at (212) 805-0136.

D. Filing Under Seal/Redactions i. Sealing/Redactions Not Requiring Court Approval. The parties are referred to the E-Government Act of 2002, Rule 5.2 of the Federal Rules of Civil Procedure 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 this 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 Court approval, 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). ii. Sealing/Redactions Requiring Court Approval. Except for redactions permitted by the previous Paragraph, all redactions or sealing of public court filings require Court approval. To be approved, any redaction or sealing of a court filing must be narrowly tailored to serve whatever purpose justifies the redaction or sealing and must be otherwise consistent with the presumption in favor of public access to judicial documents. See, e.g., Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110, 119-20 (2d Cir. 2006). In general, the parties' consent or the fact that information is subject to a confidentiality agreement 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). Any party seeking to file a document under seal or in redacted form shall proceed as follows: 1. Meet and Confer. The party seeking leave to file sealed or redacted materials should meet and confer with any opposing parties (or any third party seeking confidential treatment of the information) in advance to narrow the scope of the request. When a party seeks leave to file sealed or redacted materials on the ground that an opposing party or third party has requested it, that party shall notify the opposing party or third party that it must file, within three days, a letter explaining the need to seal or redact the materials. 2. Sealed Document(s). The party shall electronically file a letter motion seeking leave to file a document under seal on ECF in accordance with Standing Order 19-MC-583 and Section 6 of the S.D.N.Y. Electronic Case Filing 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, and should not include confidential information. The proposed sealed document shall be separately and 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 this 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, thus, the summary docket text should not include confidential information sought to be filed under seal. 3. Redacted Document(s). Where a party seeks leave to file a document in redacted form, the party shall electronically file a letter motion seeking leave to file a document in redacted form on ECF in accordance with Standing Order 19-MC-583 and Section 6 of the S.D.N.Y. Electronic Case Filing Rules and Instructions. The letter motion itself shall be filed in public view, should explain the reasons for seeking to file the document in redacted form, and should not include confidential information. At the same time, the party shall (1) publicly file on ECF and electronically relate to the letter motion a copy of the document with the proposed redactions; and (2) file under seal on ECF (with the appropriate level of restriction) and electronically relate to the motion an unredacted copy of the document with the proposed redactions highlighted. iii. Submission by Other Manner. Any party unable to comply with the requirement for electronic filing under seal through the ECF system, or who believes that a particular document should not be electronically filed at all, must move for leave of the Court to file in the traditional manner, on paper.

A. Pre-Motion Conferences in Civil Cases. For discovery motions, follow Local Civil Rule 37.2. For motions other than discovery motions, pre-motion conferences are not required.