Hon. Lorna G. Schofield

2. Agreements to Settle The parties shall email Chambers at Schofield_NYSDChambers@nysd.uscourts.gov immediately upon reaching an agreement to settle. 3. Requests for Adjournments and Extensions of Time All requests for adjournments or extensions of time shall be made at least two business days before the date to be extended. Any such request shall be made as a letter motion filed via ECF except as provided above. The body of the letter shall state: (1) the original due date, the date sought to be extended and the new date the party now seeks; (2) the number of previous requests for adjournment or extension of time; (3) whether these previous requests were granted or denied; and (4) 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, the parties shall indicate the new proposed dates. Requests for adjournment of court conferences shall be made by noon at least two business days before the scheduled appearance. Absent extraordinary circumstances, requests for extension of time will be denied if not made before the expiration of the original deadline. Source ↗

sd.uscourts.gov requesting a link to upload these courtesy copies. If any exhibits are of a kind that is filed with the Clerk of Court but not filed on ECF, such as audio or video files, the parties shall use the email address above to request a link to transmit an electronic copy to the Court. Although the Court does not ordinarily grant such requests, any application to exceed the limitations of exhibits and/or affidavits shall be by letter to the Court filed on ECF and shall contain: (i) a detailed request for relief specifying the additional documents or pages that the party seeks to file, and (ii) an explanation as to why the relief is necessary. Source ↗

D. Pretrial Conferences and Related Filings 1. Attendance by Principal Trial Counsel The attorney who will serve as principal trial counsel shall appear at all conferences with the Court. 2. Initial Case Management Conference and Plan The Court generally will schedule a Federal Rule of Civil Procedure 16(c) conference within two months of the filing of the complaint. The Notice of Initial Pretrial Conference will be docketed on ECF and will direct the parties, inter alia, to file a joint letter and a joint proposed Civil Case 14 Management Plan and Scheduling Order at least one week before the conference date. The parties shall use the form Proposed Case Management Plan and Scheduling Order available at the Court’s website (https://nysd.uscourts.gov/hon-lorna-g-schofield). After the Initial Pretrial Conference, the Court will issue a scheduling order, adopting and/or modifying the dates the parties set forth in their Proposed Case Management Plan. Source ↗

3. Discovery Motions Parties shall follow Local Rule 37.2 with the following modifications: Any party wishing to raise a discovery dispute with the Court first shall confer in good faith with the opposing party, in-person or by telephone, in an effort to resolve the dispute. If this process does not resolve the dispute, the party shall file on ECF a letter motion for a pre-motion discovery conference with the Court, as provided in Section III.A.1 above. The Court will seek to resolve the discovery dispute quickly and likely will convene a telephone conference on short notice or an in-person conference when practical. Source ↗

B. Motion Submissions and Argument 1. Memoranda of Law All written motions and cross-motions shall be accompanied by a memorandum of law. Local Rule 7.1 specifies the requirements for motion papers, including typeface (12-point font or larger), margins (1 inch or more) and spacing (double spaced). Unless prior permission has been granted, memoranda of law in support of, and in opposition to, motions are limited to 8,750 words, and reply memoranda are limited to 3,500 words. Memoranda of 2,500 words or more shall include a table of contents and a table of authorities, neither of which shall count toward the word limit. These limits do not apply to memoranda in support of or in opposition to a motion for reargument or reconsideration, which are limited to 3,500 words, and reply memoranda, which are limited to 1,750 words; memoranda in support of or in opposition to in limine motions, which shall not exceed 1,500 words; or objections or responses to objections to a Magistrate Judge’s Report and Recommendation, which shall not exceed 2,500 words. These limits do not include the caption, any index, table of contents, table of authorities, signature blocks, or any required certifications, but do include material contained in footnotes or endnotes. If a memorandum of law is filed with a computer, the party shall also file a certificate of compliance as required by Local Civil Rule 7.1(c). These limits do not apply to Bankruptcy Appeals. 10 The briefing schedule, format and length specifications set forth in Federal Rule of Bankruptcy Procedure 8015 shall govern unless otherwise ordered by the Court. Source ↗

B. Motion Submissions and Argument 1. Memoranda of Law All written motions and cross-motions shall be accompanied by a memorandum of law. Local Rule 7.1 specifies the requirements for motion papers, including typeface (12-point font or larger), margins (1 inch or more) and spacing (double spaced). Unless prior permission has been granted, memoranda of law in support of, and in opposition to, motions are limited to 8,750 words, and reply memoranda are limited to 3,500 words. Memoranda of 2,500 words or more shall include a table of contents and a table of authorities, neither of which shall count toward the word limit. These limits do not apply to memoranda in support of or in opposition to a motion for reargument or reconsideration, which are limited to 3,500 words, and reply memoranda, which are limited to 1,750 words; memoranda in support of or in opposition to in limine motions, which shall not exceed 1,500 words; or objections or responses to objections to a Magistrate Judge’s Report and Recommendation, which shall not exceed 2,500 words. These limits do not include the caption, any index, table of contents, table of authorities, signature blocks, or any required certifications, but do include material contained in footnotes or endnotes. If a memorandum of law is filed with a computer, the party shall also file a certificate of compliance as required by Local Civil Rule 7.1(c). These limits do not apply to Bankruptcy Appeals. 10 The briefing schedule, format and length specifications set forth in Federal Rule of Bankruptcy Procedure 8015 shall govern unless otherwise ordered by the Court. Source ↗

The parties may request oral argument by filing on ECF a letter to Chambers no later than the date the last brief is filed in connection with the motion. The Court will determine whether argument will be heard and, if so, will advise counsel of the argument date. The Court ordinarily does not hear oral argument. A request for oral argument is more likely to be granted if counsel identifies one or two lawyers out of law school for five years or less who will argue the entirety of the motion and references this rule in the request. Source ↗

2. Discovery Motions Parties shall follow Section III.C.3 below and Local Rule 37.2 before making any discovery motion. III. MOTION RULES AND PROCEDURES A. Pre-Motion Conference 1. Pre-Motion Conference Generally Required Before bringing any motion (except certain motions listed below), a party shall file a letter motion on ECF requesting a pre-motion conference. This letter shall be filed at least 10 business days before the proposed conference date and shall identify all of the issues in dispute and explain the legal and other grounds for the motion. No later than five business days after receipt of the letter, subject to any superseding deadline ordered by the Court, an adversary wishing to oppose the motion shall file on ECF a written response. Each party shall file a single letter not to exceed 1,200 words, not including any attached exhibits, for each pre-motion conference. Source ↗

• nd Federal Rule of Appellate Procedure 4 -- where failure to comply with the specified time period could result in forfeiture of a substantive right. 2. Section 1983 Cases Cases designated for participation in the Plan for Certain Section 1983 Cases Against the City of New York will proceed under the Plan, except that the plaintiff may request and obtain document discovery in addition to what is provided in paragraph 5 of the Plan, if the discovery is otherwise permissible and would be useful in evaluating the case for the settlement conference. Any dispute concerning discovery shall be handled as provided in Section III.C.3 below and Local Rule 37.2. The Plan can be found at https://nysd.uscourts.gov/rules/proposed-amendments.