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

Hon. Richard J. Sullivan

Verified 2026-09-04verify at the court's site ↗

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 Sullivan — standing order

comply with the following rules and practices: 1. Communications with Chambers A. Letters. Except as otherwise provided below, communications with chambers shall be by letter, with copies simultaneously delivered to all counsel. Letters on behalf of parties represented by counsel must be both docketed on ECF and e-mailed as a PDF attachment to the following address: CA02_RJSChambers@ca2.uscourts.gov. Copies of correspondence between counsel shall not be sent to the Court or docketed on ECF. Pro se litigants may send letters by regular mail, but must send all letters to the Pro Se Intake Unit, not to chambers. Other than orders to show cause, documents should not be delivered directly to chambers without prior permission, including by Assistant United States Attorneys and Federal Defenders. Counsel shall include the case caption and docket number in the subject line of every e-mail sent to chambers. Counsel shall not provide a hard copy of correspondence e-mailed to chambers.

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 Sullivan — standing order

3. Sealing No document may be filed with the Clerk under seal without an order of this Court addressing the specific documents to be sealed. Any application to seal shall be accompanied by an affidavit or affidavits and a memorandum of law, demonstrating that the standards for sealing have been met and specifically addressing Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110 (2d Cir. 2006), in a civil case or United States v. Amodeo, 71 F.3d 1044 (2d Cir. 1995), in a criminal case, and any other controlling authority. The application shall also include a proposed redacted version of the document(s) in question for public docketing. Nothing herein is intended to alter or modify the applicability of Federal Rule of Civil Procedure 5.2. The redactions expressly authorized by Rule 5.2 may be made without application to the Court.

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 Sullivan — standing order

s an opportunity for a junior lawyer to argue. G. Discovery Disputes. Unless otherwise directed, and before making any discovery motion, counsel should describe their discovery disputes in a single letter, jointly composed, not to exceed five pages. Separate and successive letters will not be read. Before filing the joint letter, the parties shall confer in an effort to resolve the dispute without court action, and the joint letter shall describe the time, place and duration of such discussions, naming the counsel involved. The joint letter shall also describe concisely the issues in dispute and the respective positions of each party, citing the applicable authority that the respective parties claim for support. As a general matter, affidavits and exhibits are not permitted in connection with discovery dispute letters without prior written request and permission. However, when the dispute concerns the refusal to respond to a specific written request, the parties shall attach that request. If an opposing party refuses to participate in writing a joint letter or does not provide its portion of a joint letter within 72 hours of a party’s request, a party may submit a letter without the opposing party’s contribution and shall attach a copy of the correspondence seeking the opposing party’s contribution. Judge Sullivan Individual Practices Page 4

Know Before You Go
👤 Judge Sullivan — deviations that burn people
  • §1.A: A. Letters. Except as otherwise provided below, communications with chambers shall be by letter, with copies simultaneously delivered to all counsel. Letters on behalf of parties represented by counsel must be both docketed on ECF and e-mailed as a PDF attachment to the following address: CA02_RJSChambers@ca2.uscourts.gov. Copies of correspondence between counsel shall not be sent to the Court or docketed on ECF. Pro se litigants may send letters by regular mail, but must send all letters to the Pro Se Intake Unit, not to chambers. Other than orders to show cause, documents should not be delivered directly to chambers without prior permission, including by Assistant United States Attorneys and Federal Defenders. Counsel shall include the case caption and docket number in the subject line of every e-mail sent to chambers. Counsel shall not provide a hard copy of correspondence e-mailed to chambers. §1.C: C. Requests for Extensions. Requests for adjournments, extensions of time, extensions of page lengths in memoranda, etc., shall be made by letter, and not by stipulation sent through the Orders and Judgments Clerk. Absent an emergency, such requests must be received in chambers at least two business days prior to the scheduled appearance or deadline. All requests for adjournments or extensions of time must state (1) the original date set for the appearance or deadline, (2) the reason(s) for the request, (3) the number of previous requests for adjournment or extension, (4) whether these previous requests were granted or denied, and (5) whether the adversary consents, and, if not, the reasons given by the adversary for refusing to consent. If the * Although Judge Sullivan sits on the United States Court of Appeals for the Second Circuit, he maintains a sizeable docket of cases on the United States District for the Southern District of New York. These Rules and Practices pertain solely to those district court cases. For appellate cases involving Judge Sullivan, parties are expected to comply with the Federal Rules of Appellate Procedure and the Local Rules of the United States Court of Appeals for the Second Circuit. Judge Sullivan Individual Practices Page 2 requested adjournment or extension affects any other scheduled dates, a proposed Revised Scheduling Order must be attached. §2.A: A. Pre-Motion Conferences in Civil Cases. For discovery motions or disputes, follow Rule 2.G. below. For motions other than discovery motions, a pre-motion conference with the Court is required before making any motion, except motions previously authorized by the Court, motions brought by order to show cause, motions by incarcerated pro se litigants, motions for admission pro hac vice, motions for re-argument or reconsideration, motions for appointment of lead plaintiffs and counsel in class actions, motions for remand, motions for a preliminary injunction, motions brought pursuant to Local Rule 6.3, and motions described in Rule 6(b) of the Federal Rules of Civil Procedure and Rule 4(a)(4)(A) of the Federal Rules of Appellate Procedure. To arrange a pre-motion conference, the moving party shall submit a letter in accordance with Rule 1.A, not to exceed three pages in length, setting forth the basis for the anticipated motion. The letter shall include citations to relevant authority and should provide a brief overview of the anticipated motion. All parties served with the letter must submit a letter response, not to exceed three pages, within three business days from submission of the notification letter. Response letters shall directly address the arguments and authorities set forth in the moving party’s letter. No party shall submit a reply letter. As a general matter, affidavits and exhibits are not permitted in connection with pre-motion letters without prior written request and permission. However, when submitting a pre-motion letter regarding a request to amend a pleading, the moving party shall attach: (1) the proposed amended pleading, and (2) a blackline comparison of the operative pleading and proposed amended pleading. A party’s submission of a pre-motion letter seeking leave to file a pre-answer motion to dismiss will stay that party’s obligation to answer or move against the complaint through the date of the pre-motion conference. Judge Sullivan Individ §2.D: D. Courtesy Copies. Regarding all motion papers, including exhibits submitted in connection with a motion, a party shall submit a hard courtesy copy and, via e-mail, an electronic courtesy copy thereof to chambers at the time the papers are served. As for pleadings and correspondence (e.g., letter motions), a party need only e-mail a courtesy copy to chambers. Courtesy copies should be marked as such and shall be submitted to chambers for both ECF and non-ECF designated cases. §2.G: G. Discovery Disputes. Unless otherwise directed, and before making any discovery motion, counsel should describe their discovery disputes in a single letter, jointly composed, not to exceed five pages. Separate and successive letters will not be read. Before filing the joint letter, the parties shall confer in an effort to resolve the dispute without court action, and the joint letter shall describe the time, place and duration of such discussions, naming the counsel involved. The joint letter shall also describe concisely the issues in dispute and the respective positions of each party, citing the applicable authority that the respective parties claim for support. As a general matter, affidavits and exhibits are not permitted in connection with discovery dispute letters without prior written request and permission. However, when the dispute concerns the refusal to respond to a specific written request, the parties shall attach that request. If an opposing party refuses to participate in writing a joint letter or does not provide its portion of a joint letter within 72 hours of a party’s request, a party may submit a letter without the opposing party’s contribution and shall attach a copy of the correspondence seeking the opposing party’s contribution. Judge Sullivan Individual Practices Page 4 §2.H: H. Affidavits and Exhibits. Parties are limited to a total of five affidavits each in support of or in opposition to a motion. Affidavits may not exceed ten double-spaced pages. Parties are limited to a total of fifteen exhibits, including exhibits attached to an affidavit, in support of or in opposition to any motion. Each exhibit – other than the complaint – is limited to fifteen pages. If possible, the exhibits should be excerpted to include only the relevant material. As noted above, no affidavits or exhibits are permitted in connection with pre-motion letters or discovery dispute letters without prior written request and permission.
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