2. Communications with Chambers a. Letters and Letter-Motions. Except as otherwise provided below, communications with Chambers shall be by letter filed on ECF. Letters seeking relief (if consistent with Local Civil Rule 7.1) should be filed as letter-motions on ECF, not ordinary letters. Any opposition shall be filed on ECF within three business days of the filing party’s letter-motion. This provision does not alter the joint letter requirement for discovery disputes set forth in Individual Rule 4(k). Letters may not exceed 1,050 words in length (exclusive of exhibits or attachments) without prior permission from the Court. For any emails to Chambers permitted under these Rules, counsel should include in the subject line: (1) the case caption, (2) docket number and (3) a brief description of the party’s request. Parties shall not include substantive communications in the body of the email, only in the attached letter. Copies of correspondence between counsel shall not be sent to the Court or filed on ECF except as exhibits to an otherwise properly filed document. b. Telephone Calls. Telephone calls to Chambers should be reserved for urgent matters. In such situations, call the Clerk’s Office at (212) 805-0136. You may request to be transferred to Chambers from there. c. Faxes. Faxes to Chambers are not permitted without express prior permission, and only in cases of unforeseeable emergencies. d. Hand Deliveries. Hand-delivered mail should be left with the Court Security Officers at the Charles

home addresses [use only the City and State]). b. Redactions Not Requiring Court Approval. Without Court approval, parties may redact the five categories of “sensitive information” and the six categories of information requiring caution (i.e., personal identifying number, medical records, treatment and diagnosis, employment history, individual financial information, proprietary or trade secret information and information regarding an individual’s cooperation with the government), as described in the Privacy Policy. c. Redactions and Sealed Filings Requiring Court Approval. Except for redactions permitted by the eleven categories of information identified in the Privacy Policy, all redactions or sealing of public court filings require Court approval. To be approved, any redaction or sealing of a court filing must be narrowly tailored to serve whatever purpose justifies the redaction or sealing and must otherwise be consistent with the presumption in favor of public access to judicial documents. d. Procedure for Filing Documents with Redactions. Any party seeking to file a document with partial redactions must follow the following three steps: i. Meet and Confer. The party seeking leave to file redacted materials should meet and confer with any opposing party (or any third party seeking confidential treatment of the information) in advance to narrow the scope of the request. When a party seeks leave to file a document in redacted form on the ground that an opposing party or third party has requested it, the filing party shall notify the opposing party or third party that it must file on ECF, within three business days of the filing party’s letter-motion seeking leave to file in redacted form, a letter explaining the need to redact the document. ii. Filing a Letter-Motion Seeking Leave to File with Redactions. If the party is seeking leave of the Court to redact the document (i.e., if the redactions are not among the categories of redactions that can be made without Court approval), the party should simultaneously file on ECF a letter-motion seeking leave to file the document with those redactions in accordance with Standing Order 19-MC-583 and Section 6 of the S.D.N.Y. Electronic Case Filing Rules and Instructions. The letter-motion itself shall be filed in public view and should not include confidential information. The letter-motion must explain the purpose of the redactions, and why the redactions are consistent with the standards set forth in Section 5(c) above. 10 iii. ECF Filing of Redacted Document(s). At the same time, the party shall: (1) publicly file on ECF and electronically relate to the letter-motion a copy of the document with the proposed redactions; and (2) file under seal on ECF (with the appropriate level of restriction) and electronically relate to the motion an unredacted copy of the document with the proposed redactions highlighted. e. Procedure for Filing Sealed Documents. Any party seeking to file a document under seal must

mbers, in both Microsoft Word and PDF formats. k. Discovery Disputes. Parties must 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, virtually or by telephone, in an effort to resolve the dispute. If this meet-and-confer process does not resolve the dispute, counsel shall promptly file on ECF a single letter-motion, jointly composed, no longer than 1,750 words, explaining the nature of the dispute and, if applicable, requesting an informal conference. Separate and successive letters will not be read. The letter must state (1) the position the parties started with at the beginning of the meet and confer; (2) each party’s final proposed compromise; and (3) why the opposing side finds the compromise position insufficient. Any letter-motion that fails to include this information will be denied. Strict adherence to Federal Rule of Civil Procedure 37(a)(1), the “meet and confer” rule, is required, and should be described in the joint submission as to time, place and duration, naming the counsel involved in the discussion. The joint letter shall set forth, with specificity, the requested discovery that each dispute involves and the respective position of each party, citing the applicable authority that the respective parties claim for support. If an opposing party refuses to participate in writing a joint letter or does not provide its portion of a joint letter within 72 hours of a party’s request, a party may submit a letter without the opposing party’s contribution and shall attach a copy of the correspondence seeking the opposing party’s contribution. The Court will seek to resolve discovery disputes quickly, by order (based on the letter alone) or in a conference. Counsel should seek relief in accordance with these procedures in a timely fashion; if a party waits until near the close of discovery to raise an issue that could have been raised earlier, the party is unlikely to be granted the relief that it seeks or more time for discovery.