Civil Case Discovery Plan and Scheduling Order

Revised May 2, 2022

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK ---------------------------------------------------X

                                     Plaintiff(s), 

v.

                                      Defendant(s). 

---------------------------------------------------X

    CIVIL CASE DISCOVERY PLAN 
    AND SCHEDULING ORDER 

     _____CV_______(PMH) 

This Civil Case Discovery Plan and Scheduling Order is adopted, after consultation with counsel and any unrepresented parties, pursuant to Fed. R. Civ. P. 16 and 26(f):

1. All parties [consent] [do not consent] to conducting all further proceedings before a Magistrate Judge, including motions and trial, pursuant to 28 U.S.C. § 636(c). The parties are free to withhold consent without adverse substantive consequences. (If all parties consent, the remaining paragraphs of this form need not be completed and the parties shall file a fully executed Notice, Consent, and Reference of a Civil Action to a Magistrate Judge (form AO 85) using the ECF Filing Event “Proposed Consent to Jurisdiction by US Magistrate Judge” prior to the Initial Pretrial Conference at which time such scheduled conference will be cancelled.)

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

3. Amended pleadings may not be filed and additional parties may not be joined except with leave of the Court. Any motion to amend or to join additional parties shall be filed by ____________________. (Absent exceptional circumstances, 30 days from date of this Order.)

4. Initial disclosures pursuant to Fed. R. Civ. P. 26(a)(1) shall be completed by ____________________. (Absent exceptional circumstances, 14 days from date of this Order.)

5. Fact Discovery

a. All fact discovery shall be completed by ____________________. (Absent exceptional circumstances, a period not to exceed 120 days from date of this Order.)

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

c. Interrogatories shall be served by ____________________.

d. Non-expert depositions shall be completed by ____________________.

e. Requests to admit shall be served by ____________________.

f. Any of the interim deadlines in paragraphs 5(b) through 5(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 5(a).

6. Expert Discovery

a. All expert discovery, including expert depositions, shall be completed by ____________________. (Absent exceptional circumstances, 45 days from date in paragraph 5(a); i.e., the completion of all fact discovery.)

b. Plaintiff’s expert disclosures pursuant to Fed. R. Civ. P. 26(a)(2) shall be made by ____________________.

c. Defendant’s expert disclosures pursuant to Fed. R. Civ. P. 26(a)(2) shall be made by ____________________.

d. The interim deadlines in paragraphs 6(b) and 6(c) may be extended by the written consent of all parties without application to the Court, provided that all expert discovery is completed by the date set forth in paragraph 6(a).

7. Additional provisions required by Fed. R. Civ. P. 26(f) and agreed upon by the parties are attached hereto and made a part hereof.

8. ALL DISCOVERY SHALL BE COMPLETED BY ____________________. (Absent exceptional circumstances, this date should align with the close of expert discovery.)

9. The parties shall file a joint letter concerning settlement/mediation by _______________. (Unless otherwise ordered by the Court, within 14 days after the close of fact discovery).

10.   a.  Counsel for the parties have discussed an informal exchange of information in aid  
       of an early settlement of this case and have agreed upon the following: 
    

b. Counsel for the parties have discussed the use of the following alternate dispute resolution mechanisms for use in this case: (i) a settlement conference before a Magistrate Judge; (ii) participation in the District’s Mediation Program; and/or (iii) retention of a privately retained mediator. Counsel for the parties propose the following alternate dispute resolution mechanism for this case: ________________

c. Counsel for the parties recommend that the alternate dispute resolution mechanism designated in paragraph b, be employed at the following point in the case (e.g. within the next sixty days; after the deposition of plaintiff is completed (specify date); after the close of fact discovery)___________________________________

d. The use of any alternative dispute resolution mechanism does not stay or modify any date in this Order.

11. All motions and applications shall be governed by the Court’s Individual Practices, including the requirement of a pre-motion conference before a motion for summary judgment is filed.

12. Unless otherwise ordered by the Court, within 30 days after the date for the completion of discovery, or, if a dispositive motion has been filed, within 30 days after a decision on the motion, the parties shall submit to the Court for its approval a Joint Pretrial Order prepared in accordance with the Court’s Individual Practices. The parties shall also comply with the Court’s Individual Practices with respect to the filing of other required pretrial documents.

13. The parties have conferred and their present best estimate of the length of the trial is ____________________.

14. This Civil Case Discovery Plan and Scheduling Order may not be modified or the dates herein extended without leave of the Court or the assigned Magistrate Judge acting under a specific order of reference (except as provided in paragraphs 5(f) and 6(d) above).

15. The Magistrate Judge assigned to this case is the Honorable ______________________________.

16. If, after the entry of this Order, the parties consent to trial before a Magistrate Judge, the Magistrate Judge will schedule a date certain for trial and will, if necessary, amend this Order consistent therewith.

17. The next case management conference is scheduled for __________________ at __________. (The Court will set this date at the initial conference.)

Dated: White Plains, New York

SO ORDERED:

Philip M. Halpern United States District Judge

Individual Practices in Civil Cases

Revised January 6, 2025 INDIVIDUAL PRACTICES IN CIVIL CASES PHILIP M. HALPERN, UNITED STATES DISTRICT JUDGE SOUTHERN DISTRICT OF NEW YORK

Chambers Hon. Charles L. Brieant Jr. Federal Building and Courthouse 300 Quarropas Street, Room 530 White Plains, New York 10601
Phone: (914) 390-4160

Courtroom Courtroom 520 Michael Frankel, Courtroom Deputy Clerk Phone: (914) 390-4154

Email: HalpernNYSDChambers@nysd.uscourts.gov Unless otherwise ordered, the following Individual Practices apply to all civil matters before Judge Halpern:
1. Communications with Chambers
A. Contact with Chambers. Except as otherwise set forth herein, telephone calls to chambers are permitted only in emergencies requiring immediate attention. The chambers phone number is (914) 390-4160. Emails or faxes to chambers are permitted only with prior authorization. Emailed or faxed submissions shall identify the authorizing individual in chambers. The chambers fax number is (914) 390-4193. In the event a party is directed to or must transmit an e-mail to Chambers, the e-mail address to be used is HalpernNYSDChambers@nysd.uscourts.gov. Copies of any communication with Chambers shall be simultaneously faxed, e-mailed, or hand- delivered to all counsel.
B. Letters and Letter-Motions. Except as otherwise provided below, communications with the Court shall be by letter. Unless there is a request to file a letter under seal, letters and letter-motions shall be filed electronically on ECF, and must comply with the SDNY Local Rules and Electronic Case Filing Rules and Instructions.

Letters to be filed under seal shall be filed in accordance with Rule 5 below. Letters solely between parties or their counsel or otherwise not addressed to the Court shall not be filed on ECF or sent to the Court (except as exhibits to an otherwise properly filed document).

C. Requests for Adjournments or Extensions of Time. All requests for adjournments or extensions of time shall be made in writing and filed on ECF as letter-motions in accordance with Rule 1(B) above. The letter-motion shall state: (1) the original date(s); (2) the reason 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 adversary consents and, if not, the reasons given by the adversary for refusing to consent. If the requested adjournment or extension affects any other scheduled dates, a proposed schedule shall be included in the letter. If the parties jointly request extensions of discovery deadlines set forth in the operative Civil Case Discovery Plan and Scheduling Order, the parties shall attach to the letter-motion a proposed revised Civil Case Discovery Plan and Scheduling Order.

Absent an emergency, any request for adjournments or extensions must be made at least 48 hours prior to the scheduled appearance or deadline. Requests for extensions will ordinarily be denied if made after the expiration of the original deadline.
D. Related Cases. After an action has been accepted as related to a prior filing, all future court papers and correspondence shall contain the docket number of both the new action and the docket number of the case to which it is related (e.g., 13-CV-1234 [rel. 12-CV-4321]).
E. CM/ECF. In accordance with the Electronic Case Filing Rules & Instructions, counsel are required to register as ECF filers and enter an appearance in the case before the initial conference. Instructions are available on the Court website at https://nysd.uscourts.gov/electronic-case-filing.
F. Letter-Motions. Letters requesting relief, such as requests for adjournments, extensions of time, and conferences (including pre-motion conferences) are considered letter-motions. A letter-motion must be filed via ECF and identified as a LETTER- MOTION using the ECF Filing Event MOTION, in compliance with the SDNY Local Rules and the SDNY Electronic Case Filing Rules & Instructions.
G. Other Letters Filed on ECF. Letters that are informational in nature, such as, for example, status reports regarding mediation or settlement, and that do not request relief should be filed using the ECF Filing Event LETTER listed under OTHER DOCUMENTS.
H. Courtesy Copies. Except as expressly indicated herein concerning marked pleadings, motions, pre-trial submissions, and bankruptcy appeals, do not provide courtesy copies of documents filed via ECF.
I. Proposed Form of Confidentiality Order. For all cases that warrant the entry of a confidentiality order, the parties shall submit to the Court for signature the proposed stipulated confidentiality agreement and protective order available on this Court’s Individual Judge’s page on the S.D.N.Y. public website. The parties shall not deviate from the Court’s form except for good cause shown which shall be set forth in a letter filed via ECF for the Court’s consideration.

Conferences
A. Attendance by Principal Trial Counsel. The attorney who will serve as principal trial counsel shall appear at all conferences. Barring extraordinary circumstances, parties will not be permitted to appear at conferences telephonically.
B. Initial Conference. The Court will generally schedule a Fed. R. Civ. P. 16(c) conference within 2 months after service on defendants has been effectuated or a notice of removal has been filed, and all defendants have filed a response to the pleading. The Notice of Initial Conference will be docketed on ECF, and plaintiff’s counsel (or, in a

matter removed from state court, defense counsel) is directed to promptly distribute copies to all parties.
If an initial conference has not been scheduled within 2 months after the service of the commencement papers or the filing of the notice of removal (and all defendants have filed a response to the pleading), counsel shall send a letter to alert the Court.
The Notice will direct the parties to submit, one week prior to the conference date, a proposed Civil Case Discovery Plan and Scheduling Order, which is available on Judge Halpern’s individual page on the S.D.N.Y. website. If defense counsel has not appeared at least one week prior to the conference date, plaintiff’s counsel is directed to submit a letter requesting an adjournment and informing the Court of the status of defense counsel’s appearance and whether plaintiff intends to seek a default judgment.
In any action in which subject-matter jurisdiction is founded on diversity of citizenship pursuant to 28 U.S.C. § 1332, the party asserting the existence of such jurisdiction shall, one week prior to the initial conference, file via ECF a letter no longer than 2 double-spaced pages explaining the basis for that party’s assertion that diversity of citizenship exists and that the amount in controversy exceeds $75,000. Where any party is a corporation, the letter shall state both the place of incorporation and the principal place of business. In cases where any party is a partnership, limited partnership, limited liability company, or trust, the letter shall state the citizenship of each of the entity’s members, shareholders, partners, and/or trustees. See Fed. R. Civ. P. 7.1(a)(2).
C. Pre-Motion Conference. A pre-motion conference is required prior to the filing of any motion, except in pro se cases, post-judgment motions, motions for reargument or reconsideration, motions for admission pro hac vice, motions for attorneys’ fees, motions for remand, motions to appoint lead plaintiff and lead defense counsel in class actions, objections to Magistrate Judges’ rulings, motions for sanctions, motions to withdraw as counsel, in forma pauperis motions, petitions to confirm or compel arbitration, or where a delay in filing might result in the loss of a right.
Except for discovery-related motions (see Rule 4(D)), to request a pre-motion conference, the movant shall file a letter to the Court, not exceeding 5 pages double- spaced, absent prior permission from the Court, setting forth the basis for the anticipated motion. Opposition letters, not exceeding 5 double-spaced pages, absent prior permission from the Court, shall be submitted within 5 business days after receipt of the movant’s letter. No reply letters will be permitted absent prior permission from the Court. As applicable, the parties must also comply with the additional rules set forth below for motions seeking a default judgment, motions to dismiss, discovery- related motions, motions for summary judgment, or motions for temporary restraining orders. Thereafter, the Court shall notify the parties of the date set for the pre-motion conference.

In pro se cases, the party contemplating a motion shall still file a pre-motion letter and the opposing party shall still file an opposition letter in accordance with this Rule. However, the Court may, in its discretion, waive the pre-motion conference.
Counsel should note that in all cases where a pre-motion letter is required, the pre- motion letter may be construed, at the discretion of the Court, as the motion itself. Arguments not raised in the pre-motion letters or during the pre-motion conference shall be deemed waived. See In re Best Payphones, Inc., 450 F. App’x 8, 15 (2d Cir. 2011) (upholding construction of pre-motion letter as motion). 3. Pleadings

A. Subject-Matter Jurisdiction. The plaintiff shall include in its pleading allegations setting forth the basis for this Court’s exercise of subject-matter jurisdiction.

B. Courtesy Copies of Pleadings. As soon as practicable, and after answers and/or replies are filed, each party shall provide a courtesy copy of that party’s marked pleading to the Court. Partial admissions or denials shall be underscored and denoted as such.

Motions

A. Courtesy Copies. As soon as practicable, the parties shall provide courtesy copies to chambers of all motion papers, including all declarations and affidavits with exhibits.
One copy of such papers, with the exhibits tabbed and indexed, shall be mailed to Chambers at the time of filing. In lieu of mailing, if hand-delivered, courtesy copies should be delivered to the Clerk’s Office on the first floor of the courthouse, not to Chambers. Courtesy copies may not be submitted through the ECF system or by e- mail. Courtesy copies should be clearly marked as such.

All courtesy hard copies of papers submitted in connection with motions must be bound in any manner that is secure, does not obscure the text, and permits the document to lie reasonably flat when open. Copies should be printed one-sided. Rather than submitting large documents that do not lie reasonably flat when open, parties should submit multiple volumes.

B. Motions for Default Judgments. A plaintiff seeking a default judgment shall proceed by way of order to show cause, pursuant to the procedure set forth in Attachment A.
C. Motions to Dismiss.
i. In the case of a motion to dismiss, the parties shall exchange 2 sets of pre- motion letters.
ii. First: Before the time to file a responsive pleading has expired, the defendant shall send plaintiff a letter not exceeding 5 double-spaced pages, seeking a

more definite statement or setting forth the specific pleading deficiencies in the complaint and other reasons or controlling authorities that defendant contends would warrant dismissal.
The plaintiff shall respond by similar letter, not exceeding 5 double-spaced pages, within 5 business days indicating the extent, if any, to which plaintiff concurs with defendant’s objections and the amendments, if any, to be made to the complaint to address them, or the reasons and controlling authority that support the pleadings as filed. The parties shall not submit copies of these letters to the Court.
If the time to amend the complaint has expired, the plaintiff may seek leave to amend to address deficiencies identified in this first exchange of letters. Such leave to amend should be sought before the second exchange of letters described in Rule 4(C)(iii) below. Under these circumstances, the Court will liberally grant the plaintiff leave to amend and will grant the defendant an extension of time to answer the complaint as appropriate. This practice may be especially effective as to certain types of motions frequently made that may be avoidable by pre-motion communication between the parties, with or without the Court’s involvement, including but not limited to the following: naming a wrong defendant, misnaming a defendant, failing to name a necessary or indispensable party, failing to exhaust available remedies, absolute immunity, expiration of the statute of limitations as to some or all of the claims asserted, failure to satisfy a prerequisite to litigation such as a Right to Sue Letter, and failure to plead the particulars of a fraud claim under Fed. R. Civ. P. Rule 9(b).
A plaintiff seeking leave to amend shall follow Rule 2(C) for the submission of pre-motion letters and shall annex both a clean and redlined version of the proposed amended pleading, and shall otherwise comply with Local Civil Rule 15.1. This first exchange does not stay the time to answer or move to dismiss. iii. Second: If, after the first exchange of letters, the defendant still wishes to file a motion to dismiss, the parties shall follow the steps set forth in Rule 2(C) above for pre-motion letters which shall be filed with the Court, including in pro se cases. Transmittal of a pre-motion letter for a proposed motion pursuant to Fed. R. Civ. P. 12(b) stays the time to answer or move to dismiss until further order of the Court.
iv. If a motion to dismiss is filed, the plaintiff has a right to amend its pleading within twenty-one days, pursuant to Fed. R. Civ. P. 15(a)(1)(B). Counsel should note that the Court will not countenance gamesmanship in connection with topics raised by the exchange of letters made pursuant to Rule 4(c)(ii) above. If the plaintiff elects not to amend its pleading, no further opportunities to amend to address the deficiencies identified by the motion to dismiss will

ordinarily be granted absent good cause, and the motion will proceed in the normal course, pursuant to the briefing schedule set by the Court. If the plaintiff does amend its pleading, the movant shall, within twenty-one days of such amendment: (1) file an answer; (2) file a new motion to dismiss in accordance with these Rules; or (3) file a letter with the Court stating that it relies on the previously filed motion to dismiss. If the movant files an answer or a new motion to dismiss, the Court shall dismiss the original motion to dismiss as moot without further notice to the parties.
D. Discovery Motions. For discovery-related motions, follow Local Civil Rule 37.2, which requires the moving party to request a conference with the Court before the filing of any such motion. The pre-motion letter shall be a joint letter from all counsel limited to five pages double-spaced outlining the discovery disputes sought to be addressed. Strict adherence to Fed. R. Civ. P. 37(a)(1), the “meet and confer” rule, is required. The parties should be prepared to describe the time, place, and duration of the meeting, and to identify the counsel involved.
E. Summary Judgment Motions.
i. Absent good cause, the Court will not ordinarily have summary judgment practice in a non-jury case.
ii. Except in pro se cases, any party wishing to move for summary judgment, prior to requesting a pre-motion conference, shall first provide all other parties with an electronic copy of its Statement of Material Facts pursuant to Local Civil Rule 56.1. The movant must simultaneously provide the other parties any admissible evidence cited in its 56.1 Statement that has not previously been produced during discovery. Service of the Rule 56.1 Statement does not operate to toll or otherwise extend the deadline set forth in Fed. R. Civ. P. 56(b).
iii. The movant’s Rule 56.1 Statement shall be organized first by facts applicable to all claims for relief and then by claim(s) for relief or defenses (as applicable), setting forth the particular facts applicable to the elements of the claims for relief or defenses at issue.
iv. The Rule 56.1 Statement shall be served on all other parties sufficiently in advance of the deadline to move for summary judgment under Fed. R. Civ. P. 56(b). Within two weeks of such service, opposing parties shall reproduce each entry in the movant’s Rule 56.1 Statement and set out the opposing party’s response directly beneath it. Should the non-movant deem a counterstatement of facts necessary to address facts applicable to claims for relief or defenses, such counterstatement shall be set forth at the end of the Rule 56.1 Statement and shall be served upon the movant for inclusion of its responses. The Rule 56.1 Statement with responses, together with any counterstatement and responses, shall be set out in a single document.

v. The Rule 56.1 Statement with responses (combined, including any counterstatement and responses) shall not exceed 25 double-spaced pages without prior permission of the Court. vi. Each citation to evidence required by Local Civil Rule 56.1(d) must identify, when applicable, specific portions of the record, including page, line, and paragraph numbers. vii. A marked pleading shall be submitted by the moving party, if one has not already been provided to the Court. viii. Pursuant to Rule 2(C) above, the prospective movant shall file a pre-motion letter informing the Court of the basis for its anticipated motion for summary judgment, and attaching the single document representing their Rule 56.1 Statement and the opposing party’s responses thereto. In pro se cases, the prospective movant is still required to file a Rule 56.1 statement with its pre- motion letter. No evidence shall be submitted with the pre-motion summary judgment letter. Transmittal of a pre-motion letter for a proposed motion pursuant to Fed. R. Civ. P. 56, together with the Rule 56.1 Statement with responses, stays the time to file a motion for summary judgment until further order of the Court. Opposition letters in conformance with Rule 2(C) shall be filed with Court within 5 business days after receipt of the prospective movant’s letter. In pro se cases, the opposition letter shall include opposition to the prospective movant’s Rule 56.1 statement. The Court shall notify the parties of the date set for the pre-motion conference in accordance with Rule 2(C). ix. The Rule 56.1 statement filed with the pre-motion letter shall, should a motion for summary judgment be filed, be modified only to the extent of properly referencing the affidavits, exhibits, and other citations to the documents actually submitted in support of the motion. x. Following the pre-motion conference, should a motion for summary judgment be filed, in addition to evidence relating to the Rule 56.1 Statement and/or opposition thereto, any deposition or hearing transcript supplied in connection therewith shall be submitted in its entirety and in a one-page-per-sheet format with an index.

xi. Except in pro se cases, the parties should provide the Court with an electronic, text-searchable courtesy copy of any hearing or deposition transcript, or portion thereof, on which the parties rely on such summary judgment motion, if a copy is available, unless doing so would be unduly burdensome. Parties may provide these materials on a CD or DVD (not by email). xii. In pro se cases, strict compliance with S.D.N.Y. Local Civil Rule 56.2 is required.

F. Motions Brought by Order to Show Cause and for Emergency Relief, Including Temporary Restraining Orders. Ordinarily, motions should be made by Notice of Motion. However, a motion for a preliminary injunction and/or temporary restraining order should be brought by Order to Show Cause and not filed as a motion.
The Court generally will not sign an Order to Show Cause, with or without a request for emergency relief, prior to a conference with the parties. A party seeking the issuance of an Order to Show Cause, with or without a request for emergency relief, shall request such a conference by letter-motion in accordance with Rule 2(C). The moving party shall confer with its adversary before making an application including emergency relief and/or for a temporary restraining order, unless the requirements of Fed. R. Civ. P. 65(b) are met.
As soon as a party decides to seek a temporary restraining order, he or she shall, in addition to filing the proposed temporary restraining order in accordance with the Electronic Filing Rules then in effect, file a letter-motion via ECF stating whether: (1) he or she has notified the adversary and if the adversary consents to temporary injunctive relief or (2) the requirements of Rule 65(b) are satisfied and no notice is necessary. If a party’s adversary has been notified of the requested emergency relief or temporary injunctive relief but does not consent, the party seeking such relief shall indicate same in their letter and provide alternative dates and times for the Court to determine a time mutually agreeable to the Court, the party, and its adversary, so that the Court may have the benefit of advocacy from both sides in deciding whether to issue the requested Order to Show Cause and/or grant emergency or temporary injunctive relief.
G. Hearings on Motions for Preliminary Injunction. In the event the Court schedules a hearing on a party’s motion for a preliminary injunction, at least one week prior to the hearing, the parties shall each submit a statement identifying:
i. The names, addresses (including firm names), email addresses, and office and mobile telephone and fax numbers of counsel that will be appearing;
ii. The elements of the claim(s) the moving party has asserted with reference to evidentiary support for each party’s position; iii. A list of the witnesses each party expects to call, including a very brief description of the witness’s role and/or the subject matter of his or her anticipated testimony, the amount of court time needed for each witness, and a statement as to whether any other party objects to the witness; iv. A list by each party of exhibits to be offered, with a notation indicating exhibits to which there is an objection and the basis therefor. The failure to include a notation and basis may be deemed a waiver of any objection. Exhibits should be pre-marked: Plaintiff’s exhibits shall be designated by number and Defendant’s by letter.

The Court will ordinarily require that the parties submit post-hearing briefs in accordance with Rule 4(H) or as otherwise directed by the Court. There shall be no wholesale filing of deposition transcripts or other discovery responses as exhibits. H. Memoranda of Law.
i. A memorandum of law shall accompany motion and opposition papers. The memorandum shall set forth all facts relevant to the motion and, for each factual statement, provide one or more citations to declarations, affidavits, or other evidence in the records. The parties’ memoranda of law shall include citations to the underlying exhibits supporting their propositions. In the case of summary judgment motions, factual statements must be supported by citations to both the record evidence and the Rule 56.1 statement, if contained therein.
ii. The Court encourages and appreciates brevity. Memoranda of law in support of and in opposition to motions shall comply with the formatting and length requirements set forth in Local Civil Rule 7.1. Unless prior permission has been granted, sur-reply memoranda will not be accepted. With respect to objections to Magistrate Judges’ rulings, unless prior permission has been granted, memoranda of law (including responses) shall not exceed 15 pages. iii. After any initial preliminary statement or factual recitation, if any, Point I of all memoranda of law shall set forth the standard of review and the burden of proof associated with the issues presented. I. Exhibits. All exhibits shall be tabbed, indexed, and submitted in compliance with Local Civil Rule 7.1(a)(3). J. Format. All papers shall conform to Local Civil Rule 7.1. Footnotes are discouraged.
K. Text Searchable. All pleadings, letters, motion papers, affidavits, or any other document containing text shall be text searchable.
L. Oral Argument on Motions. The Court does not ordinarily hear oral argument on motions; however, oral argument is encouraged on substantive motions, and the parties may request oral argument by letter at the time moving, opposing, or reply papers are filed. The Court will determine whether oral argument will be heard and, if so, will notify counsel of the date and time.
M. Participation of Junior Attorneys. To assist in the training of the next generation of attorneys, the Court strongly encourages relatively inexperienced attorneys—in particular, attorneys with less than 5 years’ experience—to participate in all courtroom proceedings including the oral argument of motions before the Court. Further, the Court is amenable to having multiple attorneys speak for one party if it creates an

opportunity for a lawyer who is relatively inexperienced. However, all attorneys appearing should have the degree of authority consistent with the proceeding.
N. Motions to Exclude Testimony of Experts. Motions to exclude testimony of experts pursuant to Rules 702–705 of the Federal Rules of Evidence and the Daubert v. Merrell Dow Pharmaceuticals, Inc., 509 U.S. 579 (1993) line of cases, shall be made as motions in limine for trial (see Rule 6(B)(iii)), unless for good cause shown, resolution of the motion is required to determine a summary judgment or other dispositive motion. 5. Electronic Filing Under Seal

A. Sealing/Redactions Not Requiring Court Approval. Fed. R. Civ. P. 5.2 describes sensitive information that must be redacted from public court filings without seeking prior permission from the Court. Such sensitive information includes: Social Security numbers; names of minor children; dates of birth; and financial account numbers.
Other information that should be treated with caution and may warrant a motion for approval of sealed or redacted filing includes: personal identifying numbers (“PINs”); medical records, treatment and diagnosis; employment history; individual financial information; proprietary or trade secret information; home addresses; and information regarding an individual’s cooperation with the government. Sensitive information and information requiring caution must not be included in any document filed with the Court unless such inclusion is necessary and relevant to the case. If such information must be included, personal identifiers must be partially redacted in accordance with the above-cited rules and policies in order to protect any privacy interest.
B. Sealing/Redaction Requiring Court Approval. Motions or letter-motions for approval of sealed or redacted filings in civil and miscellaneous cases and the subject documents, including the proposed sealed document(s), must be filed electronically through the court’s ECF system in conformity with the court’s standing order, 19-mc- 00583, and ECF Rules & Instructions, sections 6 and 21.
The motion must be filed in public view, must explain the reasons for seeking to file that information under seal and should not include confidential information sought to be filed under seal. Supporting papers must be separately filed electronically and may be filed under seal or redacted only to the extent necessary to safeguard information sought to be filed under seal.
The proposed sealed document must be contemporaneously filed under seal in the ECF system and electronically related to the motion. The summary docket text, but not the sealed document, will be open to public inspection and should not include confidential information sought to be filed under seal.

Where the motion seeks approval to redact information from a document that is to be publicly filed, the filing party shall: (a) publicly file the document with the proposed redactions, and (b) electronically file under seal a copy of the unredacted document with the redactions highlighted. Both documents must be electronically filed through the ECF system and related to the motion.
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., 2015 WL 4750774, at *4 (S.D.N.Y. Aug. 11, 2015). The party seeking leave to file sealed or redacted materials should meet and confer with any opposing parties (or third parties seeking confidential treatment of the information, if any) in advance to narrow the scope of the request.
Any party unable to comply with the requirement for electronic filing under seal through the ECF system, or who has reason to believe that a particular document should not be electronically filed, must move for leave of the Court to file in the traditional manner, on paper. In that case, paper copies shall be served contemporaneously upon all other parties. 6. Pre-Trial Procedures

A. Joint Pretrial Orders in Civil Cases. Unless otherwise ordered by the Court, within 30 days after the deadline for completion of discovery in a civil case, or, if a dispositive motion has been filed, within 30 days after a decision on the motion, the parties shall submit to the Court for its approval a Joint Pretrial Order, with one courtesy hard copy for Chambers. In pro se cases, it is the responsibility of the counseled party to advise the pro se party of this obligation. The Joint Pretrial Order shall include the information required by Fed. R. Civ. P. 26(a)(3) and the following:

i. The full caption of the action.

ii. The amount of trial time that each party anticipates needing for their case in chief.

iii. The names, addresses (including firm names), email addresses, and office and mobile telephone and fax numbers of trial counsel.

iv. A brief statement by plaintiff as to the basis of subject-matter jurisdiction, and a brief statement by each other party as to the presence or absence of subject- matter jurisdiction. Such statements shall include citations to all statutes relied on and relevant facts as to citizenship and jurisdictional amount.

v. An itemization by each party of the claims and defenses that party has asserted that remain to be tried, without recital of evidentiary matter but including citations to all statutes relied on. The parties shall also itemize all claims and defenses previously asserted that are not to be tried.

vi. 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.

vii. A statement as to whether all parties have consented to trial of the case by a magistrate judge (without identifying which parties have or have not so consented).

viii. Any stipulations or agreed statements of fact or law.

ix. A list of the witnesses each party expects to call on its case in chief, including a very brief description of the witness’s role and/or the subject matter of his or her anticipated testimony, the amount of court time needed for each witness, and a statement as to whether any other party objects to the witness.

x. For testimony to be taken from unavailable witnesses pursuant to Fed. R. Civ. P. 32(a)(4), a page and line designation by each party of witness deposition testimony to be offered in its case in chief, with any cross-designations and objections by any other party.

xi. A list by each party of exhibits to be offered in its case in chief, with a notation indicating the basis for admissibility of each exhibit with citation to Fed. R. Evid., as well as a notation indicating exhibits to which there is an objection and the basis therefor. The failure to include a notation and basis may be deemed a waiver of any objection.

xii. A statement of the relief sought, including damages claimed, itemizing each component or element of the damages sought with respect to each claim, and including the manner and method used to calculate the claimed damages.

xiii. A statement as to whether the parties consent to a less than unanimous verdict.

B. Filings Prior to Trial in Civil Cases. Unless otherwise ordered by the Court, each party shall file the following documents (and submit one courtesy hard copy to Chambers) 21 days before the date of commencement of trial if such a date has been fixed, or 30 days after the filing of the Joint Pretrial Order if no date has been fixed:

i. In jury cases, proposed joint voir dire questions, joint requests to charge, and a joint verdict form. The parties’ proposed voir dire and jury instructions shall each consist of a single document, noting any areas of disagreement between the parties. The proposed jury instructions shall include both the text of any requested instruction as well as a citation to the authority from which it derives. Each proposed jury instruction must contain a citation to the source/authority for the proposed instruction, or the request will be disregarded. In addition to

being filed in the normal manner, joint voir dire questions, joint requests to charge, and a joint verdict form should be emailed to Judge Halpern’s law clerk at the Chambers e-mail address provided above in Word format.

ii. In non-jury cases, or for any non-jury issues to be decided in a jury trial context, proposed findings of fact and conclusions of law. Proposed findings of fact should be detailed and cite whenever possible to evidence expected to be presented at trial. Proposed findings of fact should address each factual element of the claim for relief or defense at issue. Proposed conclusions of law should include a statement of the elements of each claim for relief or defense.

iii. In all cases, where necessary, motions addressing any evidentiary or other issues that should be resolved in limine. A single motion addressing appropriate evidentiary or other in limine issues may be filed and shall comply with applicable provisions of Individual Practices Rule 4.

iv. In any case in which any party believes it would be useful, a pretrial memorandum, no longer than 15 double-spaced pages, emphasizing the burden of proof associated with the claims for relief or defenses to be tried.

C. Filings in Opposition. Unless otherwise ordered by the Court, any party may file (and submit one courtesy hard copy to Chambers) the following documents within one week of the filing of any document described in Rule 6(B) above:

i. Opposition to any motion in limine.

ii. Opposition to any legal argument made in a pretrial memorandum.

iii. Opposition to proposed findings of fact and conclusions of law by placing the opposing finding of fact or conclusion of law immediately below the fact or conclusion to which there is objection.

D. Additional Submissions in Non-Jury Cases. Unless otherwise ordered by the Court, each party shall submit to the Court (including 2 courtesy copies to Chambers) and serve, but not file, the following materials 21 days before the date of commencement of trial if such a date has been fixed, or 30 days after the filing of the Joint Pretrial Order if no date has been fixed:

i. Copies of affidavits constituting the direct testimony of each trial witness, except for the testimony of an adverse party, a person whose attendance is compelled by subpoena, or a person for whom the Court has agreed to hear direct testimony during the trial. Three business days after submission of such affidavits, counsel for each party shall submit a list of all affiants whom he or she intends to cross-examine at trial. Unless otherwise ordered by the Court, only those witnesses (as opposed to parties) who will be cross-examined need to appear at trial. Counsel shall ensure such witnesses are available so as not to delay the trial. The original signed affidavits shall be marked as exhibits at trial.

ii. All deposition excerpts which will be offered as substantive evidence, as well as a 1-page synopsis (with page and line references) of those excerpts for each deposition.

iii. All documentary exhibits.

Post-Trial Procedures. Counsel are responsible for raising promptly any issue concerning the accuracy of transcripts certified by the Court Reporter to be used for purposes of appeal. Counsel perceiving an error that is material shall stipulate to the appropriate correction or, if agreement cannot be reached, shall proceed by motion on notice. Non-material defects (e.g., syntax, spelling or punctuation) should be ignored.

Orders and Stipulations of Settlement. Should the parties request, the Court will consider so-ordering the parties’ stipulations of settlement, including the retention of continuing jurisdiction for the enforcement of same.

Bankruptcy Appeals. Briefs shall be submitted in accordance with Federal Rules of Bankruptcy Procedure 8015 through 8018 unless otherwise ordered by the Court. One courtesy copy of the briefs and the bankruptcy record on appeal, marked as such, shall be submitted to chambers by the appellant at the time the reply is due.

ATTACHMENT A DEFAULT JUDGMENT PROCEDURE

1. After obtaining a Clerk’s Certificate of Default (see SDNY Electronic Case Filing Rules & Instructions, Section 16.1), prepare a proposed Order to Show Cause Without Emergency Relief and make the Order returnable before Judge Halpern in Courtroom 520 of the Hon. Charles L. Brieant Jr. Federal Building and Courthouse, 300 Quarropas Street, White Plains, New York 10601. Leave blanks for the Court to fill in (i) the date and time of the hearing, (ii) the date by which opposing papers must be served and filed, and (iii) the date by which the moving party must serve the Order and supporting documents on the non-moving party.

2. Electronically file the proposed Order to Show Cause Without Emergency Relief using the ECF Filing Event found under PROPOSED ORDERS.

3. Electronically file the following documents as separate ECF Filing Events:

a. an attorney’s affidavit, attaching true and correct copies of all necessary supporting exhibits, setting forth clearly:

i. why a default judgment is appropriate, including a description of the method and date of service of the original summons and complaint; ii. 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 liability and/or damages prior to the resolution of the entire action (see Fed. R. Civ. P. Rule 54(b));
iii. when applicable, legal authority for why an inquest is unnecessary; and

iv. when applicable, the basis for an award of attorney’s fees and costs.

b. an affidavit from a party with personal knowledge of damages and the basis for each element of damages, including interest, attorney’s fees, and costs (unless requesting an inquest), attaching exhibits as necessary to support the basis therefor;

c. when applicable, a Statement of Damages in accordance with Local Civil Rule 55.2(c);

d. a memorandum of law (see Rule 4(H)) explaining how service of process was proper under the Federal Rules of Civil Procedure and how the moving party’s proof satisfies the burden of proof associated with the request; and

e. a proposed default judgment, using the ECF Filing Event found under PROPOSED ORDERS.

4. After Judge Halpern signs and dockets the Order to Show Cause, serve a copy of the Order and attachments on defendant(s) as directed. At least 3 business days before the hearing date, electronically file proof of service of the signed Order to Show Cause.

Model Confidentiality Stipulation and Proposed Protective Order

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK Plaintiff(s),

• against - Defendant(s). STIPULATED CONFIDENTIALITY AGREEMENT AND
  PROTECTIVE ORDER __ Civ.
  _ (PMH)

PHILIP M. HALPERN, United States District Judge:

WHEREAS, all the parties to this action (collectively the “Parties” and individually a “Party”) request that this Court issue a protective order pursuant to Federal Rule of Civil Procedure 26(c) to protect the confidentiality of nonpublic and competitively sensitive information that they may need to disclose in connection with discovery in this action; WHEREAS, the Parties, through counsel, agree to the following terms; and WHEREAS, this Court finds good cause exists for issuance of an appropriately tailored confidentiality order governing the pretrial phase of this action,

IT IS HEREBY ORDERED that any person subject to this Order – including without limitation the Parties to this action (including their respective corporate parents, successors, and assigns), their representatives, agents, experts and consultants, all third parties providing discovery in this action, and all other interested persons with actual or constructive notice of this Order — will adhere to the following terms, upon pain of contempt: 1. With respect to “Discovery Material” (i.e., information of any kind produced or disclosed in the course of discovery in this action) that a person has designated as

“Confidential” pursuant to this Order, no person subject to this Order may disclose such Confidential Discovery Material to anyone else except as this Order expressly permits: 2. The Party or person producing or disclosing Discovery Material (“Producing Party”) may designate as Confidential only the portion of such material that it reasonably and in good faith believes consists of: (a) previously non-disclosed financial information (including without limitation profitability reports or estimates, percentage fees, design fees, royalty rates, minimum guarantee payments, sales reports, and sale margins); (b) previously non-disclosed material relating to ownership or control of any non-public company; (c) previously non-disclosed business plans, product-development information, or marketing plans; (d) any information of a personal or intimate nature regarding any individual; or (e) any other category of information this Court subsequently affords confidential status. 3. With respect to the Confidential portion of any Discovery Material other than deposition transcripts and exhibits, the Producing Party or its counsel may designate such portion as “Confidential” by: (a) stamping or otherwise clearly marking as “Confidential” the protected portion in a manner that will not interfere with legibility or audibility; and (b) producing for future public use another copy of said Discovery Material with the confidential information redacted.

A Producing Party or its counsel may designate deposition exhibits or portions of deposition transcripts as Confidential Discovery Material either by: (a) indicating on the record during the deposition that a question calls for Confidential information, in which case the reporter will bind the transcript of the designated testimony in a separate volume and mark it as “Confidential Information Governed by Protective Order;” or (b) notifying the reporter and all counsel of record, in writing, within 30 days after a deposition has concluded, of the specific pages and lines of the transcript that are to be designated “Confidential,” in which case all counsel receiving the transcript will be responsible for marking the copies of the designated transcript in their possession or under their control as directed by the Producing Party or that person’s counsel. During the 30-day period following a deposition, all Parties will treat the entire deposition transcript as if it had been designated Confidential. 5. If at any time before the trial of this action a Producing Party realizes that it should have designated as Confidential some portion(s) of Discovery Material that it previously produced without limitation, the Producing Party may so designate such material by so apprising all prior recipients in writing. Thereafter, this Court and all persons subject to this Order will treat such designated portion(s) of the Discovery Material as Confidential. 6. Nothing contained in this Order will be construed as: (a) a waiver by a Party or person of its right to object to any discovery request; (b) a waiver of any privilege or protection; or (c) a ruling regarding the admissibility at trial of any document, testimony, or other evidence. 7. Where a Producing Party has designated Discovery Material as Confidential, other persons subject to this Order may disclose such information only to the following persons:

(a) the Parties to this action, their insurers, and counsel to their insurers;

(b) counsel retained specifically for this action, including any paralegal, clerical, or other assistant that such outside counsel employs and assigns to this matter; (c) outside vendors or service providers (such as copy-service providers and document-management consultants) that counsel hire and assign to this matter; (d) any mediator or arbitrator that the Parties engage in this matter or that this Court appoints, provided such person has first executed a Non-Disclosure Agreement in the form annexed as an Exhibit hereto; (e) as to any document, its author, its addressee, and any other person indicated on the face of the document as having received a copy; (f) any witness who counsel for a Party in good faith believes may be called to testify at trial or deposition in this action, provided such person has first executed a Non-Disclosure Agreement in the form annexed as an Exhibit hereto; (g) any person a Party retains to serve as an expert witness or otherwise provide specialized advice to counsel in connection with this action, provided such person has first executed a Non-Disclosure Agreement in the form annexed as an Exhibit hereto; (h) stenographers engaged to transcribe depositions the Parties conduct in this action; and

(i) this Court, including any appellate court, its support personnel, and court reporters. 8. Before disclosing any Confidential Discovery Material to any person referred to in subparagraphs 7(d), 7(f), or 7(g) above, counsel must provide a copy of this Order to such person, who must sign a Non-Disclosure Agreement in the form annexed as an Exhibit hereto stating that he or she has read this Order and agrees to be bound by its terms. Said counsel must retain each signed Non-Disclosure Agreement, hold it in escrow, and produce it to opposing counsel either before such person is permitted to testify (at deposition or trial) or at the conclusion of the case, whichever comes first. 9. In accordance with Rule 5 of this Court’s Individual Practices, any party filing documents under seal must simultaneously file with the Court a letter brief and supporting declaration justifying – on a particularized basis – the continued sealing of such documents. The parties should be aware that the Court will unseal documents if it is unable to make “specific, on the record findings . . . demonstrating that closure is essential to preserve higher values and is narrowly tailored to serve that interest.” Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110, 120 (2d Cir. 2006).

The Court also retains discretion whether to afford confidential treatment to any Discovery Material designated as Confidential and submitted to the Court in connection with any motion, application, or proceeding that may result in an order and/or decision by the Court. All persons are hereby placed on notice that the Court is unlikely to seal or otherwise afford confidential treatment to any Discovery Material introduced in evidence at trial, even if such material has previously been sealed or designated as Confidential.

In filing Confidential Discovery Material with this Court, or filing portions of any pleadings, motions, or other papers that disclose such Confidential Discovery Material (“Confidential Court Submission”), the Parties shall publicly file a redacted copy of the Confidential Court Submission via the Electronic Case Filing System. The Parties shall file an unredacted copy of the Confidential Court Submission under seal with the Clerk of this Court, and the Parties shall serve this Court and opposing counsel with unredacted courtesy copies of the Confidential Court Submission. 12. Any Party who objects to any designation of confidentiality may at any time before the trial of this action serve upon counsel for the Producing Party a written notice stating with particularity the grounds of the objection. If the Parties cannot reach agreement promptly, counsel for all affected Parties will address their dispute to this Court in accordance with paragraph 4(D) of this Court’s Individual Practices. 13. Any Party who requests additional limits on disclosure (such as “attorneys’ eyes only” in extraordinary circumstances), may at any time before the trial of this action serve upon counsel for the recipient Parties a written notice stating with particularity the grounds of the request. If the Parties cannot reach agreement promptly, counsel for all affected Parties will address their dispute to this Court in accordance with paragraph 4(D) of this Court’s Individual Practices. 14. Recipients of Confidential Discovery Material under this Order may use such material solely for the prosecution and defense of this action and any appeals thereto, and not for any business, commercial, or competitive purpose or in any other litigation proceeding. Nothing contained in this Order, however, will affect or restrict the rights of any Party with respect to its own documents or information produced in this action.

Nothing in this Order will prevent any Party from producing any Confidential Discovery Material in its possession in response to a lawful subpoena or other compulsory process, or if required to produce by law or by any government agency having jurisdiction, provided that such Party gives written notice to the Producing Party as soon as reasonably possible, and if permitted by the time allowed under the request, at least 10 days before any disclosure. Upon receiving such notice, the Producing Party will bear the burden to oppose compliance with the subpoena, other compulsory process, or other legal notice if the Producing Party deems it appropriate to do so. 16. Each person who has access to Discovery Material designated as Confidential pursuant to this Order must take all due precautions to prevent the unauthorized or inadvertent disclosure of such material. 17. If, in connection with this litigation, a party inadvertently discloses information subject to a claim of attorney-client privilege or attorney work product protection ("Inadvertently Disclosed Information"), such disclosure shall not constitute or be deemed a waiver or forfeiture of any claim of privilege or work product protection with respect to the Inadvertently Disclosed Information and its subject matter. 18. If a disclosing party makes a claim of inadvertent disclosure, the receiving party shall, within five business days, return or destroy all copies of the Inadvertently Disclosed Information, and provide a certification of counsel that all such information has been returned or destroyed. 19. Within five business days of the notification that such Inadvertently Disclosed Information has been returned or destroyed, the disclosing party shall produce a privilege log with respect to the Inadvertently Disclosed Information. 20. The receiving party may move the Court for an Order compelling

production of the Inadvertently Disclosed Information. The motion shall be filed under seal, and shall not assert as a ground for entering such an Order the fact or circumstances of the inadvertent production. 21. The disclosing party retains the burden of establishing the privileged or protected nature of any Inadvertently Disclosed Information. Nothing in this Order shall limit the right of any party to request an in camera review of the Inadvertently Disclosed Information. 22. Within 60 days of the final disposition of this action – including all appeals – all recipients of Confidential Discovery Material must either return it – including all copies thereof – to the Producing Party, or, upon permission of the Producing Party, destroy such material – including all copies thereof. In either event, by the 60-day deadline, the recipient must certify its return or destruction by submitting a written certification to the Producing Party that affirms that it has not retained any copies, abstracts, compilations, summaries, or other forms of reproducing or capturing any of the Confidential Discovery Material. Notwithstanding this provision, the attorneys that the Parties have specifically retained for this action may retain an archival copy of all pleadings, motion papers, transcripts, expert reports, legal memoranda, correspondence, or attorney work product, even if such materials contain Confidential Discovery Material. Any such archival copies that contain or constitute Confidential Discovery Material remain subject to this Order. 23. This Order will survive the termination of the litigation and will continue to be binding upon all persons to whom Confidential Discovery Material is produced or disclosed. 24. This Court will retain jurisdiction over all persons subject to this Order to the extent necessary to enforce any obligations arising hereunder or to impose sanctions for

any contempt thereof.

SO STIPULATED AND AGREED.

Dated: Dated:

Dated: New York, New York

SO ORDERED.

Philip M. Halpern United States District Judge

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK Plaintiff(s),

• against - Defendant(s). NON-DISCLOSURE AGREEMENT

Civ.
(PMH)

I,
, acknowledge that I have read and understand the Protective Order in this action governing the non-disclosure of those portions of Discovery Material that have been designated as Confidential. I agree that I will not disclose such Confidential Discovery Material to anyone other than for purposes of this litigation and that at the conclusion of the litigation I will return all discovery information to the Party or attorney from whom I received it. By acknowledging these obligations under the Protective Order, I understand that I am submitting myself to the jurisdiction of the United States District Court for the Southern District of New York for the purpose of any issue or dispute arising hereunder and that my willful violation of any term of the Protective Order could subject me to punishment for contempt of Court.

Dated:

Notice, Consent and Reference of a Civil Action to a Magistrate Judge

AO 85 (Rev. 01/09) Notice, Consent, and Reference of a Civil Action to a Magistrate Judge UNITED STATES DISTRICT COURT for the __________ District of __________ ) ) ) ) ) Plaintiff v. Civil Action No. Defendant NOTICE, CONSENT, AND REFERENCE OF A CIVIL ACTION TO A MAGISTRATE JUDGE Notice of a magistrate judge’s availability. A United States magistrate judge of this court is available to conduct all proceedings in this civil action (including a jury or nonjury trial) and to order the entry of a final judgment. The judgment may then be appealed directly to the United States court of appeals like any other judgment of this court. A magistrate judge may exercise this authority only if all parties voluntarily consent. You may consent to have your case referred to a magistrate judge, or you may withhold your consent without adverse substantive consequences. The name of any party withholding consent will not be revealed to any judge who may otherwise be involved with your case. Consent to a magistrate judge’s authority. The following parties consent to have a United States magistrate judge conduct all proceedings in this case including trial, the entry of final judgment, and all post-trial proceedings. Parties’ printed names Signatures of parties or attorneys Dates Reference Order IT IS ORDERED: This case is referred to a United States magistrate judge to conduct all proceedings and order the entry of a final judgment in accordance with 28 U.S.C. § 636(c) and Fed. R. Civ. P. 73. Date: District Judge’s signature Printed name and title Note: Return this form to the clerk of court only if you are consenting to the exercise of jurisdiction by a United States magistrate judge. Do not return this form to a judge. Southern District of New York (PMH) Philip M. Halpern, U.S.D.J Print Save As... Reset

SDNY Announces Hon. Philip M. Halpern to Sit Temporarily in Manhattan

United States District Court Southern District Of New York Colleen McMahon Chief Judge

Ruby J. Krajick Clerk of Court

5 0 0 P e a r l S t r e e t , N e w Y o r k , N Y 1 0 0 0 7
3 0 0 Q u a r r o p a s S t r e e t , W h i t e P l a i n s , N Y 1 0 6 0 1
https://www.nysd.uscourts.gov/

NOTICE TO THE BAR

CONTACT: March 12, 2020

Office of the Clerk of Court, (212) 805-0140

SDNY Announces Hon. Philip M. Halpern
To Sit Temporarily in Manhattan

Effective Monday, March 16, 2020, The Hon. Philip M. Halpern will begin work as a United States District Judge. Judge Halpern’s duty station will be the Charles L. Brieant Federal Building and Courthouse in White Plains. Due to construction at the White Plains courthouse, Judge Halpern will be temporarily sitting in the Daniel Patrick Moynihan Courthouse in lower Manhattan until further notice. Details on Judge Halpern's case assignments and place of holding court may be found in the accompanying Standing Order of the court.

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Case 1:20-mc-00150-CM Document 1 Filed 03/12/20 Page 1 of 1

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