Hon. Gregory H. Woods

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 by letter and must state: (1) the original due date; (2) the number of previous requests for adjournment or extension of time; (3) the reason for the current request; (4) whether the adversary consents and, if not, the reason given by the adversary for refusing to consent; and (5) proposed alternative dates. If the requested adjournment or extension affects any other scheduled dates, a proposed Revised Civil Case Management Plan and Scheduling Order must be submitted as an attachment to the request. Absent an emergency, the request must be made at least two business days prior to the original due date. Source ↗

3. Motions A. Memoranda of Law. Unless prior permission has been granted, memoranda of law in support of and in response to a motion must comply with Local Civil Rule 7.1. In addition, memoranda of 10 pages or more must contain a table of contents and a table of authorities. Source ↗

D. Initial Case Management Conference. The Court will generally schedule a Federal Rule of Civil Procedure 16(c) conference within three months of the filing of the complaint or notice of removal. If a conference has not been scheduled within three months of the filing of the complaint or notice of removal, counsel must advise the Court by letter on ECF. 4 The Clerk’s Office will email a notification to counsel when notice of the conference is docketed. Plaintiff’s counsel (or, in a matter removed from state court, defense counsel) is responsible for promptly distributing copies of the notice to all parties. The notice will direct the parties, inter alia, to submit via ECF at least one week prior to the conference a joint letter. The notice will also direct the parties to email to WoodsNYSDChambers@nysd.uscourts.gov an editable version of their joint proposed Case Management Plan and Scheduling Order, available at https://nysd.uscourts.gov/hon-gregory-h-woods. i. All parties should be prepared to discuss at the initial pretrial conference any pending or anticipated motions as well as the basis for subject matter jurisdiction. ii. In cases invoking the Court’s diversity jurisdiction: a. if any party is a corporation, the parties should be prepared to discuss both the place of incorporation and the principal place of business, as defined in Hertz Corp. v. Friend, 559 U.S. 77 (2010). b. if any party is a partnership, limited partnership, limited liability company, or trust, the parties should be prepared to discuss the citizenship of each of the entity’s members, shareholders, partners, and/or trustees. Source ↗

3. Motions A. Memoranda of Law. Unless prior permission has been granted, memoranda of law in support of and in response to a motion must comply with Local Civil Rule 7.1. In addition, memoranda of 10 pages or more must contain a table of contents and a table of authorities. Source ↗

file them physically with the Clerk of Court. C. Oral Argument on Motions. Parties may request oral argument by indicating “Oral Argument Requested” on the cover of their moving, opposing, or reply memoranda. The Court will determine whether argument will be heard and may order argument sua sponte. Source ↗

bers, shareholders, partners, and/or trustees. E. Pre-Motion Conferences. Pre-motion submissions are required for motions to dismiss, motions for summary judgment, motions for judgment on the pleadings, motions to compel arbitration, motions to certify collective or class actions, motions for sanctions, motions to amend a complaint or answer, motions concerning discovery, and motions to remand to state court. Pre-motion submissions do not stay any future deadlines, except that a pre-motion submission regarding 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. i. To request a pre-motion conference, except for motions concerning discovery, counsel for the movant must submit a letter setting forth the grounds for the proposed motion. If the motion is not on consent, any opposing party must submit a letter setting forth its position within five days after the request is received. Letters submitted pursuant to this section must comply with the procedures set forth above in Rule 1(A), except that exhibits to letters are not permitted under this section. The Court will promptly determine whether to hold a pre-motion conference in the matter. ii. To request a pre-motion conference concerning discovery, counsel must submit a single, jointly composed letter describing their discovery dispute(s). Letters submitted pursuant to this section must comply with the procedures set forth above in Rule 1(A), except that letters under this section must be no longer than 5 pages total, excluding exhibits. Strict adherence to Fed. Source ↗

• l apply to all teleconferences with the Court: i. Counsel should use a landline whenever possible, should use a headset instead of speakerphone, and must mute themselves whenever they are not speaking to eliminate background noise. In addition, counsel should not use voice-activated systems that do not allow the user to know when someone else is trying to speak at the same time. ii. To facilitate orderly teleconferences and the creation of an accurate transcript where a teleconference is held on the record, counsel are required to identify themselves every time they speak. Counsel should spell any proper names for the court reporter. Counsel should also take special care not to interrupt or speak over one another. iii. The recording of any court conference is prohibited by law. iv. Like in-person conferences, telephone conferences are open to the public. Members of the public or the press may join a telephone conference using the dial-in information above.