Hon. Robert W. Lehrburger

A. Letters. In general, communications with the Court should be by letter. Except as provided below, all letters should be filed electronically on ECF (i.e., Electronic Case Filing), without email or other copy to Chambers. 1. Represented Parties. The following types of letters should be emailed to Chambers as a .pdf attachment: Letters filed by counsel under seal; Ex parte settlement letters; Letters otherwise containing confidential information. In pro se cases, unless the pro se party has filed a fully executed Consent To Electronic Service form, counsel for the represented party must serve the pro se party with a paper copy of any legal document that is filed on ECF or emailed to the Court and must separately file proof of service. 2. Unrepresented Pro Se Parties. By Standing Order, a pro se party must mail or email all communications with the Court to the Pro Se Intake Unit located at 500 Pearl Street, Room 200, New York, NY 10007, ProSe@nysd.uscourts.gov. A pro se party may not call Chambers or send any document or filing directly to Chambers. 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 ECF system. If any additional unrepresented party has not filed a fully executed Consent To Electronic Service form, a pro se party must mail or deliver copies of any filing to that party and include proof of service affirming that he or she has done so. Copies of correspondence between a pro se party and opposing parties should not be sent to the Court. Any non-incarcerated pro se party who wishes to participate in electronic case filing ("ECF") must file a Motion for Permission for Electronic Case Filing, available in the Pro Se Intake Unit or at https://nysd.uscourts.gov/prose. Any non-incarcerated pro se party who wishes to receive documents in their case by email instead of by regular mail may consent to electronic service by filing a Pro Se (Non-prisoner) Consent & Registration Form to Receive Documents Electronically, available in the Pro Se Intake Unit or at https://nysd.uscourts.gov/prose. 3. Page Limit for Letters. Letters may not exceed 3 single-space pages in length (exclusive of exhibits). 4. Letters Between Parties. Letters solely between parties or their counsel or otherwise not addressed to the Court may not be filed on ECF or otherwise sent to the Court (except as exhibits to an otherwise properly filed document). B. Hand Deliveries. Hand-delivered mail should be left with the Court Security Officers at the Worth Street entrance of 500 Pearl Street and may not be brought directly to Chambers. If the hand-delivered letter is urgent and requires immediate attention, ask the Court Security Officers to notify Chambers that an urgent package has arrived. C. Telephone Calls: For administrative, scheduling, and calendar matters that do not request a ruling from the Court, Chambers may be called between 9:00 a.m. and 4:00 p.m.

A. Sealing/Redactions Not Requiring Court Approval. Federal Rule of Civil Procedure 5.2 describes sensitive information that must be redacted from public court filings. No Court approval is required for these redactions. B. Sealing/Redactions Requiring Court Approval. 1. Initial Filing Process. Any party wishing to file a document under seal or in redacted form shall (1) file on ECF a redacted copy of the document, (2) file on ECF a sealed copy of the document, and (3) submit to Chambers an unredacted copy by email. 2. Service On Parties. Pursuant to S.D.N.Y. Standing Order M10-468, sealed documents are not accessible or viewable on ECF; accordingly, parties must separately serve opposing counsel with any sealed materials in a manner other than the ECF system. 3. Meet and Confer Requirement. Within 5 business days of the ECF-filing of the redacted document(s), the parties must confer in good faith as to whether any or all of the redacted material may or must be filed without redaction. If the parties reach agreement that all redacted material may or must be unredacted, the parties shall file on ECF unredacted copies of the previously redacted documents and so inform the Court. 4. When Motion Required. A motion is required whenever one or more parties seek to maintain sealed material. If the parties cannot agree to unredact all redacted material, then, within 3 business days of the parties' meet and confer, the party seeking to preserve confidentiality must make a specific request to the Court by letter motion. If more than one party seeks to preserve confidentiality, the parties shall confer and submit a joint letter. Any party opposing the request to file under seal must submit a responding letter within 3 business days after submission of the letter by the party seeking to preserve confidentiality. 5. What Must Be Included In Motion. Any letter motion requesting that material remain under seal must explain the reasons for seeking to file the material under seal and address the request in light of the Court of Appeals' opinions in Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110 (2d Cir. 2006) and Bernstein v. Bernstein Litowitz Berger & Grossman LLP, 814 F.3d 132 (2d Cir. 2016). Any sealing request shall include the requesting party's proposed redactions. 6. Motion Filing Process. The letter motion to seal (and any response) must be filed on ECF in public view and should not itself include confidential material for which sealing is sought. Any supporting papers or attachments that contain confidential material may be filed under seal or redacted to the extent necessary to safeguard that information. At the time the letter motion is filed it should be designated as related to the documents filed under seal in the initial filing process. 7. Unredaction. If the Court directs that any previously redacted material be unredacted, the party who submitted the previously redacted document shall, within 3 business days after the Court's unredaction order, file on ECF the documents complying with the Court's order. 8. Inability to Comply. 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 by letter motion for leave of Court to file non-electronically.

D. Discovery Disputes. Parties shall follow S.D.N.Y. Local Rule 37.2 with the following modifications. Any party wishing to raise a discovery dispute with the Court must first meet and confer in good faith with the opposing party, in person or by telephone or video conferencing, in an effort to resolve the dispute. If this meet-and-confer process does not resolve the dispute, the party may file a letter motion with the Court or, if applicable, to the Pro Se Intake Clerk, no longer than 3 single-space pages, explaining the nature of the dispute and requesting a conference. Such letter must include a representation that the meet-and-confer process occurred, including when and whether it was in person or over the telephone. Any responsive letter should be submitted within 3 business days following submission of the letter motion. The Court retains discretion to rule on the dispute based on the parties’ letter submissions, without more formal briefing, and with or without a conference. If any party believes that more formal briefing is warranted, that party must make a separate application to the court explaining why more formal briefing is warranted. 5 Lehrburger Individual Rules 2025.9.30 Parties shall keep in mind Rule 1 of the Federal Rules of Civil Procedure, which requires the Court and the parties to construe, administer, and employ the rules of procedure to secure the just, speedy, and inexpensive determination of every action. Parties also shall keep in mind Rule 26(b)(1) of the Federal Rules of Civil Procedure, which provides that “[p]arties may obtain discovery regarding any non-privileged matter that is relevant to any party’s claim or defense and proportional to the needs of the case, considering the importance of the issues at stake in the action, the amount in controversy, the parties’ relative access to relevant information, the parties’ resources, the importance of the discovery in resolving the issues, and whether the burden or expense of the proposed discovery outweighs its likely benefit.” Discovery motions should address these rules to the extent applicable.