Hon. Arun Subramanian

to be retrieved by Chambers staff immediately. E. Requests for Adjournments or Extensions of Time. All requests for adjournments or extensions of time must be made in writing and filed on ECF as letter-motions, not as ordinary letters, proposed stipulations, or proposed orders. The letter-motion must state: (1) the original date(s); (2) the number of previous requests for adjournment or extension; (3) whether these previous requests were granted or denied; (4) the reasons for the requested extension; (5) whether the adversary consents and, if not, the reasons given by the adversary for refusing to consent; and (6) the date of the parties’ next scheduled appearance before the Court as well as any other existing deadlines. If the extension will affect any other deadlines in the case, the party seeking the extension should propose amendments to those deadlines as well. Requests for extensions of deadlines regarding a matter that has been referred to a Magistrate Judge shall be addressed to that assigned Magistrate Judge. Any request for extension or adjournment shall be made at least two business days prior to the deadline or scheduled appearance. Requests for extensions will ordinarily be denied if made after this deadline. Source ↗

B. Amended or Corrected Filings. Any amended or corrected filing (including but not limited to amended pleadings) shall be filed with a redline showing all differences between the original and revised filing. Any motion to amend a pleading shall similarly be filed with a redline showing all differences between the operative pleading and the proposed amended pleading. Source ↗

K. Preliminary Injunction Motions. The Court generally follows the procedure for the conduct of non-jury trials described in Paragraph 10(E) below. L. Default Judgment Motions. If a party fails to respond to a claim, the party asserting the claim should promptly move for entry of default judgment if appropriate. A party seeking a default judgment must proceed by filing a motion for default judgment on ECF pursuant to Federal Rule of Civil Procedure 55(b)(2) and Local Civil Rule 55.2(b). A party seeking a default judgment should not proceed by order to show cause. The motion must be supported by the following papers: i. if failure to answer is the basis for the default, a Certificate from the Clerk of Court stating that no answer has been filed; ii. an attorney’s affidavit or declaration setting forth: 1. the basis for entering a default judgment, including a description of the method and date of service of the summons and complaint; 2. the procedural history beyond service of the summons and complaint, if any; 9 3. legal authority for why such service was proper; 4. whether, if the default is applicable to fewer than all counterparties, the Court may appropriately order a default judgment on the issue of damages prior to resolution of the entire action; 5. the proposed damages and the basis for each element of damages, including interest, attorney’s fees, and costs; and 6. legal authority for why an inquest into damages would be unnecessary; iii. if the proposed damages are supported by calculations, native versions of the files with calculations (i.e., versions of the files in their original format, such as in “.xlsx”), which shall be emailed to Chambers; iv. a proposed default judgment; v. copies of all the operative pleadings; and vi. a copy of the affidavit of service of the summons and complaint. Source ↗

Silent on discovery_letter_page_limit. Source ↗

4 D. Initial Case Management Conference. In most cases, the Court will schedule a Federal Rule of Civil Procedure 16(c) conference to occur no more than three months after the filing of the complaint or notice of removal. Plaintiff’s counsel (or, in a matter removed from state court, defense counsel) is directed to promptly notify all counsel of the Notice of Initial Pretrial Conference. In most cases, the Notice will direct the parties to submit on ECF a joint letter as well as a proposed Civil Case Management Plan and Scheduling Order attached as an exhibit to the joint letter, no later than Thursday of the week prior to the conference date. This must be filed on ECF as a letter motion- not a standard letter. The parties shall use the form Proposed Case Management Plan and Scheduling Order available at the Court’s website. The Court will set a schedule for the case at the initial case management conference. In most cases, the Court will give the parties four months (from the date of the conference) to complete all discovery, set a deadline for the filing of any motions for summary judgment, and set a date on which trial will commence. Source ↗

Silent on lead_trial_counsel_details. Source ↗

5. Discovery Disputes A. Parties must follow Local Civil Rule 37.2 with the following modifications. Special rules regarding disputes raised during depositions are addressed in Paragraph 6. B. Any party wishing to raise a discovery dispute with the Court must first confer in good faith with the opposing party—in person, by videoconference, or by telephone—to resolve the dispute. This process must include at least one conference among Lead Trial Counsel for the parties involved in the dispute. Source ↗

3. Communications with Chambers A. Letters. Except as otherwise provided below, communications with the Court should be by letter, filed electronically on ECF. Letters seeking relief should be filed on ECF as letter-motions in accordance with Paragraph 8(A) below, not as ordinary letters. Unless otherwise ordered by the Court, letters may not exceed three pages in length. Source ↗

, unless doing so would be unduly burdensome. vi. Memoranda of law should include sections discussing the relevant background and facts. Parties should not merely incorporate by reference their Local Rule 56.1 Statements or Counterstatements. Source ↗

Silent on mtd_element_chart_details. Source ↗

cheduling Order available at the Court’s website. The Court will set a schedule for the case at the initial case management conference. In most cases, the Court will give the parties four months (from the date of the conference) to complete all discovery, set a deadline for the filing of any motions for summary judgment, and set a date on which trial will commence. Source ↗

8. Motions A. Letter-Motions. When permitted by the S.D.N.Y. Local Rules and the S.D.N.Y. Electronic Case Filing Rules and Instructions, letters seeking relief should be filed on ECF as letter-motions, not as ordinary letters. Source ↗

• 2. Guidelines for All Submissions A. Designation of Lead Trial Counsel. At the outset of each case, or upon reassignment of a matter to this Court, each party must identify to the Court one individual who shall serve as Lead Trial Counsel for that party. This designation must be provided to the Court in the party’s first submission (including in reassigned cases). The designation of Lead Trial Counsel cannot be changed absent prior approval by the Court. As specified below, Lead Trial Counsel is required to personally attend all conferences before the Court and to be personally involved in discovery disputes before they are brought to the Court.