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S.D.N.Y. · Judge Parker · Practice Guide

Hon. Katharine H. Parker

All local rules for S.D.N.Y., integrated with this judge's published requirements.

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Before You File
Ex parte applications
🏛 S.D.N.Y. local rule

(d) No ex parte order, or order to show cause to bring on a motion, will be granted, except upon a clear and specific showing by affidavit that contains good and sufficient reasons why a procedure other than by notice of motion is necessary and states whether a previous application for similar relief has been made. Local Civil Rule 6.1(d) ↗

Contacting chambers
👤 Judge Parker — standing order

Communications with the Court should be by letter filed on ECF except for settlement conference submissions and in camera submissions. Letters may not exceed 3 single-space pages in length (exclusive of exhibits). §I.d: 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. §I.e: No faxed communications shall be permitted without prior permission from Judge Parker's Chambers. Faxes must not exceed three pages. §I.f: As a general rule, and except as otherwise specified herein, no physical/paper courtesy copies of documents filed on ECF should be sent to Judge Parker.

Drafting the Motion
Length limits — motion, opposition, reply
🏛 S.D.N.Y. local rule
Motion

(c) Length of Memoranda of Law. If filed by an attorney or prepared with a computer, briefs in support of and in response to a motion (except for motions for reconsideration) may not exceed 8,750 words, and reply briefs may not exceed 3,500 words. Local Civil Rule 7.1(c) ↗

Opposition

(c) Length of Memoranda of Law. If filed by an attorney or prepared with a computer, briefs in support of and in response to a motion (except for motions for reconsideration) may not exceed 8,750 words, and reply briefs may not exceed 3,500 words. Local Civil Rule 7.1(c) ↗

Reply

(c) Length of Memoranda of Law. If filed by an attorney or prepared with a computer, briefs in support of and in response to a motion (except for motions for reconsideration) may not exceed 8,750 words, and reply briefs may not exceed 3,500 words. Local Civil Rule 7.1(c) ↗

Filing & Scheduling
Briefing schedule & hearing date
🏛 S.D.N.Y. local rule
Notice period

Except for letter-motions as permitted by Local Civil Rule 7.1(d), and unless provided otherwise by statute or rule, or by the court in a judge’s individual practices or in a direction in a particular case, motion papers must be served and filed as follows: (a) On all motions and applications under Fed. R. Civ. P. 26 through 37 and 45(d)(3), (1) all motion papers must be served by the moving party on all other parties that have appeared in the action, (2) any opposing or response papers must be served within seven days after service of the moving papers, and (3) any reply papers must be served within two days after service of the answering papers. In computing periods of days, refer to Fed. R. Civ. P. 6. (b) On all civil motions, petitions, and applications, other than those described in Rule 6.1(a), and other than petitions for writs of habeas corpus, (1) the moving papers must be served by the moving party on all other parties that have appeared in the action, (2) any opposing or response papers must be served within 14 days after service of the moving papers, and (3) any reply papers must be served within seven days after service of the answering papers. Local Civil Rule 6.1 (introductory clause) and 6.1(a)-(b) ↗

Hearing days

Silent on fixed motion hearing days. Local Civil Rules 6.1, 7.1 (silent) ↗

Proposed orders
🏛 S.D.N.Y. local rule

Local Civil Rule 77.1. Submission of Orders, Judgments and Decrees Proposed orders, judgments, and decrees must be presented as directed by the ECF rules published on the website of each respective court. Local Civil Rule 77.1 ↗

Filing under seal
👤 Judge Parker — standing order

Any party wishing to file in redacted form any pleading, motion, memorandum, exhibit, or other document, or any portion thereof, based on a party's designation of information as Confidential, must make a specific request to the Court by letter motion explaining the reasons for seeking to file that submission under seal and addressing 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). Letter Motions for approval of sealed or redacted filings must be filed electronically through ECF in conformity with standing order 19-mc-00583. The motion must be filed in public view, must explain the particular reasons for seeking to file that information under seal, and should not include confidential 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 Hearing
Oral argument
🏛 S.D.N.Y. local rule

Silent on oral argument default. Local Civil Rules 6.1, 7.1 (silent) ↗

Discovery
Discovery dispute procedure
👤 Judge Parker — standing order

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, the party may submit an ECF letter-motion to the Court, 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 and state when it occurred. Any responsive letter should be submitted within 3 business days after submission of the letter-motion. The Court will endeavor to resolve the issue during a conference without the need for formal briefing. However, if formal briefing is required, the Court will set a schedule for such briefing at the conference.

More from Judge Parker’s procedures
👤 Judge Parker — standing order
Adjournment extension procedure

Absent good cause, any request for extension or adjournment shall be made at least 48 hours or 2 business days, whichever is greater, before the deadline or scheduled appearance. All requests for adjournments or extensions of time must be filed on ECF as letter-motions. The letter-motion must state: (1) the original date(s); (2) the number of previous requests for adjournment or extension; and (3) whether the adversary consents and, if not, the reasons given by the adversary for refusing to consent. Source ↗

Initial conference timing

Before the Initial Case Management Conference, parties must meet and confer on a discovery plan. One week before the scheduled conference, the parties shall file on ECF Proposed Case Management Plan and Report on Rule 26(f) Meeting. Lead counsel for the parties are expected to attend the Initial Case Management Conference. Source ↗

Motion word page limits

The formatting and length of motion papers must conform to Local Civil Rule 7.1. Memoranda of law may only exceed the length limitations set forth under Local Civil Rule 7.1 if prior permission has been granted. Memoranda of 10 pages or more shall contain a table of contents and a table of authorities, neither of which shall count against the word limit. Sur-reply memoranda will not be accepted without prior permission of the Court. All moving papers, letter-motions, and letters filed on ECF or emailed to chambers must be in searchable PDF form. Source ↗

Oral argument procedure

Parties may request oral argument when the motion has been fully briefed. This request should be made by letter in accordance with the procedures set forth in Section I. Source ↗

Pre motion procedure

Except in cases involving pro se parties, if a motion pursuant to Fed. R. Civ. P. 12(b) or 12(c) is contemplated, the plaintiff or counterclaimant must indicate whether it wishes to amend the subject pleading before motion practice, and the parties must consider in good faith a stipulation permitting such amendment. If the parties are unable to reach a resolution, counsel for the moving party shall include the following statement in the notice of motion: 'This motion is made following the conference of counsel, which took place on [date]. Plaintiff [or Counter Claimant] declined an opportunity to amend.' §III.b: A pre-motion conference is required for all motions except (i) letter motions; (ii) motions required by the Federal Rules to be made by a certain time; (iii) motions by incarcerated pro se litigants; (iv) motions for reconsideration; (v) motions for a new trial; (vi) motions in limine; (vii) motions to dismiss habeas corpus petitions; (viii) motions for default; and (ix) motions for judgment on the pleadings or summary judgment in social security cases. Letters requesting a pre-motion conference should summarize the basis of the motion and may not exceed 3 pages. Within 3 business days of receipt, each opposing party may submit a written response of no more than 3 pages. Source ↗

Know Before You Go
👤 Judge Parker — deviations that burn people
  • [AI Rule (separate document, Nov. 12 2025)]: Federal Rule of Civil Procedure 11 imposes a duty on attorneys and pro se litigants to certify that they have conducted a reasonable inquiry and have determined that any papers filed with the court are well grounded in fact and that they have verified all cited sources for accuracy. See Cooter & Gell v. Hartmarx Corp., 496 U.S. 384, 393 (1990). Although the use of ChatGPT and other such generative artificial intelligence ('AI') tools is not prohibited, unqualified reliance on such tools may result in filings replete with misrepresentations and fabricated case law. Failure to exercise due care in reviewing and filing work product created with the assistance of generative AI tools may violate Rule 11 and other applicable standards of practice and expose the filer to sanctions or other corrective or disciplinary action. See, e.g., Park v. Kim, 91 F.4th 610, 614 (2d Cir. 2024).
  • [Key Traps -- Individual Practices]: (1) NO courtesy copies of ECF-filed documents (§I.f). (2) Pre-motion conference required for almost all formal motions -- 3-page letter request, adversary gets 3-day response (§III.b). (3) Rule 12(b)/(c) motions require amendment conference + certification in notice of motion (§III.a). (4) Settlement conferences: parties (not just attorneys) must attend in person; corporate must send decision-maker (§V.f). (5) Sealing requires Lugosch + Bernstein analysis in letter-motion (§III.d).
content assembled from published local rules & standing orders · click any section in the rail for the full treatment
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