judge console · S.D.N.Y.
S.D.N.Y. · Judge Abrams · Practice Guide

Hon. Ronnie Abrams

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 Abrams — standing order

§1.A: A. Letters. Except as otherwise provided below, communications with the Court shall be by letter, filed electronically on ECF. Parties should not submit courtesy copies of letters filed on ECF. Letters containing sensitive or confidential information that cannot be filed on ECF in accordance with the procedures set forth in Paragraph 5 below may be emailed to the Court (Abrams_NYSDChambers@nysd.uscourts.gov) as a text-searchable .pdf attachment with a copy simultaneously delivered to all counsel. Any such email shall state clearly in the subject line: (1) the caption of the case, including the lead party names and docket number, and (2) a brief description of the contents of the letter. Parties shall not include substantive communications in the body of the email; such communications shall be included only in the body of the attached letter. Unless the Court orders otherwise, letters may not exceed five (5) pages in length. Letters solely between parties or their counsel or otherwise not addressed to the Court may not be filed on ECF or otherwise sent to the Court (except as exhibits to an otherwise properly filed document).

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 Abrams — standing order

A. G. Oral Argument on Motions. Parties may request oral argument at the time they file their moving, opposing, or reply papers. They may do so by filing on ECF a letter specifically requesting oral argument. The Court will determine whether argument will be heard and, if so, will advise counsel of the argument date.

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 Abrams — standing order

ps://nysd.uscourts.gov/electronic-case-filing. 3. Discovery Disputes. The parties shall follow Local Civil Rule 37.2 with the following modifications. Any party wishing to raise a 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 this meet-and-confer process does not resolve the dispute, the party may file on ECF a letter-motion to the Court, no longer than three (3) pages, explaining the nature of the dispute and requesting an informal conference. The letter-motion must include a representation that the meet-and-confer process occurred and was unsuccessful. If the opposing party wishes to respond, it must call Chambers within one (1) business day to advise that a responsive letter will be forthcoming, and its response shall be by letter to the Court not exceeding three pages within three (3) business days of the filing of the original letter-motion.

Know Before You Go
👤 Judge Abrams — deviations that burn people
  • 1. Discovery response must call Chambers FIRST: '§3: If the opposing party wishes to respond, it must call Chambers within one (1) business day to advise that a responsive letter will be forthcoming.' Practitioners who file a response without calling first are non-compliant.
  • 2. Courtesy copies triggered only by volume: '§4.B: Courtesy copies are not required unless the motion includes numerous exhibits and/or a voluminous record.' Filing them by default signals unfamiliarity with the rules.
  • 3. Motion to dismiss triggers 14-day notification obligation: '§4.C: When a motion to dismiss is filed, the non-moving party must, within fourteen (14) days of receipt of the motion, notify the Court and its adversary in writing whether (i) it intends to file an amended pleading and when it shall do so, or (ii) it will rely on the pleading being attacked.' This is separate from the response deadline.
  • 4. Settlement agreements not confidentially enforceable: '§5.B: The Court will not retain jurisdiction to enforce confidential settlement agreements. If the parties wish that the Court retain jurisdiction to enforce a settlement agreement, the parties must place the terms of their agreement on the public record.'
  • 5. Sealing requires Lugosch showing -- consent is not enough: '§5.A.ii: the parties' consent or the fact that information is subject to a confidentiality agreement between litigants is not, by itself, a valid basis to overcome the presumption in favor of public access.'
content assembled from published local rules & standing orders · click any section in the rail for the full treatment