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

Hon. Jennifer E. Willis

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

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

(d) No ex parte order, or order to show cause to bring on a motion, will be granted, except upon a clear and specific showing by affidavit that contains good and sufficient reasons why a procedure other than by notice of motion is necessary and states whether a previous application for similar relief has been made. Local Civil Rule 6.1(d) ↗

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

(c) Length of Memoranda of Law. If filed by an attorney or prepared with a computer, briefs in support of and in response to a motion (except for motions for reconsideration) may not exceed 8,750 words, and reply briefs may not exceed 3,500 words. Local Civil Rule 7.1(c) ↗

Opposition

(c) Length of Memoranda of Law. If filed by an attorney or prepared with a computer, briefs in support of and in response to a motion (except for motions for reconsideration) may not exceed 8,750 words, and reply briefs may not exceed 3,500 words. Local Civil Rule 7.1(c) ↗

Reply

(c) Length of Memoranda of Law. If filed by an attorney or prepared with a computer, briefs in support of and in response to a motion (except for motions for reconsideration) may not exceed 8,750 words, and reply briefs may not exceed 3,500 words. Local Civil Rule 7.1(c) ↗

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

Except for letter-motions as permitted by Local Civil Rule 7.1(d), and unless provided otherwise by statute or rule, or by the court in a judge’s individual practices or in a direction in a particular case, motion papers must be served and filed as follows: (a) On all motions and applications under Fed. R. Civ. P. 26 through 37 and 45(d)(3), (1) all motion papers must be served by the moving party on all other parties that have appeared in the action, (2) any opposing or response papers must be served within seven days after service of the moving papers, and (3) any reply papers must be served within two days after service of the answering papers. In computing periods of days, refer to Fed. R. Civ. P. 6. (b) On all civil motions, petitions, and applications, other than those described in Rule 6.1(a), and other than petitions for writs of habeas corpus, (1) the moving papers must be served by the moving party on all other parties that have appeared in the action, (2) any opposing or response papers must be served within 14 days after service of the moving papers, and (3) any reply papers must be served within seven days after service of the answering papers. Local Civil Rule 6.1 (introductory clause) and 6.1(a)-(b) ↗

Hearing days

Silent on fixed motion hearing days. Local Civil Rules 6.1, 7.1 (silent) ↗

Proposed orders
🏛 S.D.N.Y. local rule

Local Civil Rule 77.1. Submission of Orders, Judgments and Decrees 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 Willis — standing order

y party unable to comply with the requirement for electronic filing under seal through the ECF system, or who has reason to believe that a particular document should not be electronically filed, must move for leave of the Court to file on paper. The pendency of the application to seal does not affect any deadlines that may govern the proposed filing. The parties shall comply with such deadlines by filing the redacted version on ECF, serving the unredacted papers at issue on any opposing parties, and providing courtesy copies of the unredacted version to Chambers. If the Court approves the filing under seal, no further submissions shall be required. If the Court denies, in part, the motion for filing under seal, the party who made the submission shall be required to refile the document with modified redactions as directed by the Court.

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

Silent on oral argument default. Local Civil Rules 6.1, 7.1 (silent) ↗

Discovery
Discovery dispute procedure
👤 Judge Willis — standing order

discovery dispute with the Court must first confer in good faith with the opposing party, in person or by telephone, in an effort to resolve the dispute. If the meet-and-confer does not resolve the dispute, a party may submit a letter motion no longer than 3 single-spaced pages, explaining the nature of the dispute and requesting a conference. Such letter motion must state when the meet-and- confer occurred. Any responsive letter should be submitted within 3 business days after submission of the letter motion and should be no longer than 3 single-spaced pages. Failure to respond within 3 business days will result in a waiver of any objections. The Court will endeavor to resolve the issue without a conference and without the need for formal briefing. However, if formal briefing is required, the Court will either schedule a conference or set a schedule for such briefing. Motions other than Discovery Motions. To arrange a pre-motion conference for non- discovery matters, the moving party shall submit a letter motion in accordance with Individual Practice I.B. The letter motion should set forth the nature of the anticipated May 2025 3 motion. Any responsive letter should be submitted within 3 business days after submission of the letter motion. Memoranda of Law. The typeface, margins and spacing of motion papers must conform to Local Civil Rule 11.1. Unless prior permission has been granted, memoranda of law in support of and in opposition to motions may not exceed 8,750 words, and reply briefs may not exceed 3,500 words. Memoranda of 10 pages or more shall contain a table of contents and a table of authorities, neither of which shall count against the word limit. Sur-reply memoranda will not be accepted without prior permission of the Court. All moving papers, letter-motions, and letters filed on ECF or emailed to chambers must be in searchable PDF form. Additionally, to the extent citing unreported cases, parties are requested to use Westlaw citations whenever possible.

More from Judge Willis’s procedures
👤 Judge Willis — standing order
Adjournment extension procedure

May 2025 2 C. Requests for Adjournments or Extensions of Time. All requests for adjournments or extensions of time must be filed on ECF as letter motions at least 2 business days before the original deadline. The letter motion must state: (1) the original date(s); (2) the number of previous requests for adjournment or extension; (3) the reason for the extension; and (4) whether the adversary consents and, if not, the reasons given by the adversary for refusing to consent. Emergency requests should be emailed to WillisNYSDChambers@nysd.uscourts.gov and filed on the docket citing the nature of the emergency. Source ↗

Courtesy copies details

d to the other party or that party’s attorney. B. Courtesy Copies of Trial Exhibits. The parties shall each send a courtesy copy of all exhibits, pre-marked, to WillisNYSDChambers@nysd.uscourts.gov. Exhibits need not be filed electronically on ECF. The parties shall also each submit one hard copy of the pre-marking exhibits in a well-organized three-ring binder, separated by tab dividers. Source ↗

Oral argument procedure

icient familiarity with the facts of the case. C. Oral Argument on Motions. Parties may request oral argument by noting such request on their moving papers or filing a letter requesting the same. Junior members of legal teams representing clients are invited to argue motions they have helped prepare and to question witnesses with whom they have worked. Firms are encouraged to provide this opportunity to junior attorneys for training purposes; a request for oral argument is more likely to be granted if a party identifies a lawyer to argue the motion who has graduated law school within the previous five years. Source ↗

Pre motion procedure

A. Pre-Motion Conferences Letters in Civil Cases. In advance of filing a letter with the Court, the Parties are expected to meet and confer regarding a briefing schedule for any anticipated motion. Pre-motion letters seeking a conference should propose a briefing schedule and are required where the proposed motion is returnable before Judge Willis, or where the proposed motion has been referred to Judge Willis, except that no pre- motion letter is required for (i) motions for admission pro hac vice, (ii) motions by litigants in actions where a party is both pro se and incarcerated, (iii) motions for reconsideration or reargument, (iv) motions for a new trial, (v) motions in limine, (vii) motions listed in Fed. Source ↗

Know Before You Go
👤 Judge Willis — deviations that burn people
  • Pre-motion letter or conference required before filing most motions. Filing without the required pre-motion step will likely result in the motion being returned.
  • All letters must be filed on ECF. Do not send letters directly to chambers by email unless specifically authorized.
  • All adjournment and extension requests must be filed on ECF as letter-motions, not as ordinary letters or proposed stipulations.
content assembled from published local rules & standing orders · click any section in the rail for the full treatment
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