Hon. Analisa Torres

I.C. Requests for Adjournments or Extensions of Time. All requests for adjournments or extensions of time shall be made in writing and filed on ECF as letter motions. The letter motion shall state: (1) the original date(s); (2) the reason 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 requested adjournment or extension affects any other scheduled dates, a proposed schedule shall be included in the letter. Absent an emergency, any request for adjournments or extensions must be made at least 48 hours prior to the scheduled appearance or deadline. Requests for extensions will ordinarily be denied if made after the expiration of the original deadline. Source ↗

I.B. Except as provided in Rule V(G), no papers, including courtesy hard copies of any filing or document, may be submitted to chambers. All documents must be filed on ECF or, if permitted or required under these rules, emailed to the Court. In the event that a party or counsel is unable to submit a document electronically—either by ECF or email—the document may be mailed to the Court. To the maximum extent possible, however, this means of delivery should be avoided, as delivery of mail to the Court may be delayed. Source ↗

II.D. Discovery Disputes. If this meet-and-confer process does not succeed, the parties shall describe the dispute in a single joint letter to the Court, normally not exceeding six pages. Source ↗

II.B. Scheduling Order. The Court shall generally request a jointly proposed Case Management Plan and Scheduling Order pursuant to Federal Rule of Civil Procedure 16(b) within two months after the filing of the complaint or notice of removal. If a deadline for submitting the proposed Case Management Plan and Scheduling Order has not been set within two months after the filing of the complaint or notice of removal, counsel shall send a letter to alert the Court. Source ↗

III.D. Memoranda of Law. Memoranda of law in support of and in opposition to motions are limited to 8,750 words. These limits do not include the caption, any index, table of contents, table of authorities, signature blocks, or any required certificates, but they do include material contained in footnotes or endnotes. Source ↗

III.D. Memoranda of Law. Reply memoranda are limited to 3,500 words. These limits do not include the caption, any index, table of contents, table of authorities, signature blocks, or any required certificates, but they do include material contained in footnotes or endnotes. Source ↗

III.B. Special Rules for Motions to Dismiss. In the case of a motion to dismiss, the parties shall exchange two sets of pre-motion letters. First: Before the time to file a responsive pleading has expired, the defendant shall send plaintiff a letter not exceeding three single-spaced pages, seeking a more definite statement or setting forth the specific pleading deficiencies in the complaint and other reasons or controlling authorities that defendant contends would warrant dismissal. The plaintiff shall respond by similar letter within five business days. The parties shall not submit copies of these letters to the Court. Second: If, after the first exchange of letters, the defendant still wishes to file a motion to dismiss, the parties shall follow the steps set forth in Rule III(A) above for pre-motion letters. Transmittal of a pre-motion letter for a proposed motion under Federal Rule of Civil Procedure 12(b) stays the time to answer or move to dismiss until further order of the Court. Source ↗

III.J. Oral Argument of Motions. Parties may request oral argument by letter filed with the Court at the time their moving, opposing, or reply papers are filed. The Court typically does not hold oral argument on motions, but it will notify counsel if oral argument is required. III.K. Participation of Junior Attorneys. Given the decline in cases going to trial, opportunities for courtroom advocacy are increasingly rare. To assist in the training of the next generation of attorneys, the Court strongly encourages relatively inexperienced attorneys to participate in all courtroom proceedings. Further, the Court is amenable to having multiple attorneys speak for one party if it creates an opportunity for a lawyer who is relatively inexperienced. However, all attorneys appearing should have the degree of authority consistent with the proceeding. Source ↗

III.A. Pre-Motion Letters in Civil Cases. A pre-motion letter is required prior to the filing of any motion, except motions with a jurisdictional time limit as provided by the Federal Rules of Appellate Procedure, post-judgment motions, motions brought on by a court order to show cause, motions for reargument or reconsideration, motions by incarcerated pro se litigants, motions for admission pro hac vice, motions for attorneys' fees, motions for remand, motions to appoint lead plaintiff and lead defense counsel in securities class actions, objections to magistrate judges' rulings, motions for sanctions, motions to withdraw as counsel, motions for reduction of sentence, in forma pauperis motions, petitions to confirm or compel arbitration, or where a delay in filing might result in the loss of a right. The movant shall file a letter with the Court, normally not exceeding four pages, setting forth the basis for the anticipated motion. Opposition letters, normally not exceeding four pages, shall be submitted within five business days after receipt of the movant's letter. Source ↗

III.C. Special Rules for Summary Judgment Motions. Absent good cause, the Court shall not ordinarily have summary judgment practice in a non-jury case. Source ↗

• 1. Pre-motion letters are required before virtually ANY motion -- the exceptions list is long but narrow. Filing a motion without a pre-motion letter first is a procedural violation that will likely result in the motion being struck or returnable. (SS III(A))
• 2. Motions to dismiss trigger a mandatory TWO-round pre-motion exchange. The first round (defendant deficiency letter -> plaintiff response within 5 business days) is NOT filed with the Court. Only after that exchange does the second round of pre-motion letters go to the Court. Missing the first exchange, or filing the second-round letter before the first exchange is complete, violates SS III(B).
• 3. Discovery disputes require a JOINT LETTER from both parties (normally not exceeding 6 pages), not separate moving and opposition letters. Submitting a unilateral discovery letter-motion is procedurally incorrect under SS II(D). The joint letter must identify the time, place, duration, and counsel involved in the meet-and-confer.
• 4. Summary judgment practice is ordinarily unavailable in a non-jury case absent good cause under SS III(C)(i). Filing a summary judgment motion in a bench trial without first obtaining leave from the Court is improper.
• 5. Principal trial counsel -- not just any attorney -- must appear at all conferences. Sending a different attorney to a conference without Court approval violates SS II(A).
• 6. The AI rule (SS VII) names specific tools (ChatGPT, Harvey, CoCounsel, Google Bard) and explicitly ties non-compliance to Rule 11 sanctions. Failure to confirm accuracy of AI-generated source material is explicitly sanctionable.
• 7. No papers of any kind -- including courtesy hard copies -- may be submitted to chambers. Everything goes on ECF or, where permitted, by email. (SS I(B))