§2.A: A. Letters. Except as otherwise provided below, all communications with the Court should be by letter. Letters must be filed electronically on ECF unless there is a request to file a letter under seal or a letter contains sensitive or confidential information (see Rule 5, below). Absent a request to file a letter under seal, any substantive letter or email received by the Court that is not filed electronically on ECF will be docketed by the Court. Copies of correspondence between counsel must not be filed on ECF or otherwise sent to the Court (except as exhibits to an otherwise properly filed document). In all correspondence with the Court containing a request, the requesting party must indicate whether its adversary consents to the request. Unless otherwise ordered by the Court or in exceptional circumstances, letters should generally not exceed five pages in length.

§5.B.i (Rule 5.2(a) redactions): Redactions made pursuant to Federal Rule of Civil Procedure 5.2(a) do not require Court approval, but the parties must either file the unredacted document(s) under seal on ECF or email the unredacted document(s) to Chambers, at CaproniNYSDChambers@nysd.uscourts.gov. §5.B.ii (all other sealing): Any party wishing to file any document, or any portion thereof, in redacted form or under seal for reasons other than Rule 5.2(a) of the Federal Rules of Civil Procedure must file a letter motion requesting permission from the Court to do so. The letter must explain why sealing is appropriate in light of the presumption of access discussed by the Second Circuit in Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110, 119-20 (2d Cir. 2006). The letter must also indicate whether the opposing party consents to the proposed sealing or redaction. §5.B.iii (procedure): (a) File, in public view on ECF, the letter motion requesting sealing or redaction. (b) File, as a separate entry on ECF, any papers in support of the letter motion. (c) File, under seal on ECF, the documents that are the subject of the sealing or redaction request. If a party is filing a motion for redactions, the proposed redactions must be highlighted in the unredacted document(s) filed under seal. (d) File, in public view on ECF, the redacted versions of any documents that are the subject of a motion to redact.

§3.B: Any party wishing to raise a discovery dispute with the Court must first meet and confer in good faith with the opposing party, in person or by telephone, in an effort to resolve the dispute. If this process fails and the Court's intervention is required, the parties must jointly call Chambers to hold a joint teleconference with the Court for prompt resolution of the dispute. The parties should email the Chambers inbox requesting the Court's contact information; mark the Re line of the email 'Discovery Dispute.' When calling Chambers to resolve a discovery dispute, counsel for all parties must appear on the line and be prepared to: (a) provide a brief synopsis of the dispute to a law clerk; (b) propose mutually convenient times for a teleconference with Judge Caproni; and (c) state whether the parties would like the call to be recorded or transcribed. All teleconferences will be conducted off the record unless all parties consent otherwise. The Court will determine during the teleconference whether written submissions will be required. Parties should not make written submissions regarding discovery disputes absent Court permission.