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

Hon. Edgardo Ramos

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

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

Affidavit with good and specific reasons required; state if prior application made. Local Civil Rule 6.1(d) ↗

Contacting chambers
👤 Judge Ramos — standing order

1. Communications with Chambers A. Letters. Except as otherwise provided below, communications with chambers shall be by letter, filed electronically via ECF. Letters seeking relief should be filed as letter-motions in accordance with Section 1.E below. Letters between or among counsel shall not be filed on ECF or otherwise sent to the Court (except as exhibits to an otherwise properly filed document). Letters to be filed under seal shall follow the procedure for Electronic Filing Under Seal in Civil and Miscellaneous Cases in accordance with Section 3 of this document. Parties shall not submit courtesy copies of letters that are filed as described above.

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

Memoranda of law in support of or in opposition to a motion limited to 25 pages; reply memoranda limited to 10 pages S.D.N.Y. L.R. 7.1(b) ↗

Opposition

8,750 words maximum for opposition brief. Local Civil Rule 7.1(c) ↗

Reply

3,500 words maximum for reply brief. Local Civil Rule 7.1(c) ↗

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

Opposition due 14 days after service; reply due 7 days after opposition. Local Civil Rule 6.1(b) ↗

Hearing days

Silent on fixed motion hearing days. The joint local rules establish no motion-day calendar. LCR 7.1 governs motion practice (content, formatting, and briefing deadlines) but sets no court hearing dates; any hearing is scheduled at each judge's discretion per their individual practices. Local Civil Rule 7.1 ↗

Proposed orders
🏛 S.D.N.Y. local rule

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 Ramos — standing order

D. Oral Argument on Motions. Parties may request oral argument by letter at the time their moving, opposing or reply papers are filed. The Court will determine whether argument will be heard and, if so, will advise counsel of the date and time.

The Hearing
Oral argument
🏛 S.D.N.Y. local rule

Motions are decided on submission unless the court schedules oral argument; contact chambers to request oral argument S.D.N.Y. L.R. 7.1(b) ↗

Discovery
Discovery referral procedure
🏛 S.D.N.Y. local rule

Must first request informal conference by letter before filing discovery motion. Local Civil Rule 37.2 ↗

Discovery dispute procedure
👤 Judge Ramos — standing order

H. Urgent Communications. As a general matter, materials filed via ECF are reviewed by the Court the business day after they have been filed. If a submission requires immediate attention, please notify Chambers by email after you file the submission via ECF.

Know Before You Go
👤 Judge Ramos — deviations that burn people
  • §2.A: A. Pre-Motion Conference in Civil Cases. i. For discovery motions, follow Local Civil Rule 37.2, requiring the moving party to request an informal conference with the Court before the filing of any such motion. 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. ii. A pre-motion conference with the Court is required before making any other motion, except where a litigant believes that delay in filing the motion might result in the loss of a right or where a litigant seeks to make a motion in a case involving an incarcerated pro se litigant, motion for admission pro hac vice, motion for reargument or reconsideration, or motion for temporary restraining order or preliminary injunction. To arrange a pre-motion conference, the moving party shall submit a letter, not to exceed three pages, setting forth the basis for the anticipated motion. The opposing party shall submit a letter, also not to exceed three pages, setting forth its position within three business days from the service of the moving party's letter. If a pre-motion conference is requested in connection with proposed motion to dismiss, the request will stay the deadline for the requesting party to move or answer, and a new deadline will be set at the conference.
  • §6: Default Judgments. A party that wishes to obtain a default judgment must proceed by way of order to show cause. Follow the Default Judgment Procedure, attached hereto as Attachment A.
content assembled from published local rules & standing orders · click any section in the rail for the full treatment
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