1. Communications with Chambers A. Letters. Except as otherwise provided below, communications with Chambers shall be by letter, with copies simultaneously delivered to all counsel. Letters to the Court on behalf of parties represented by counsel must be both docketed on ECF and e-mailed as a .pdf attachment to the following address: CronanNYSDChambers@nysd.uscourts.gov. Counsel shall not provide a hard copy of correspondence e-mailed to Chambers. Letters seeking relief should (if consistent with the S.D.N.Y. Local Rules and the S.D.N.Y. ECF Rules and Instructions) be filed on ECF as letter-motions, not as ordinary letters. Any response to a letter or letter-motion shall be filed within two business days of the filing of the letter or letter-motion. Counsel shall include the case caption and docket number in the subject line of every e- mail sent to Chambers. All letters should be text-searchable where practicable. Unless otherwise ordered by the Court, letters may not exceed three pages in length (single-spaced, 12-point font). Letters to be filed under seal or containing sensitive or confidential information must be filed in accordance with 4.A-B below. Copies of correspondence between counsel shall not be sent to the Court or docketed on ECF, except if the correspondence is a relevant attachment to a filing.

sealing of public court filings require Court approval. Any party seeking to file a document under seal or in redacted form shall proceed as follows: i. Meet and Confer. The party seeking leave to file a document under seal or in redacted form shall meet and confer with all other parties in the case (as well as any third party seeking confidential treatment of the information) in advance to narrow the scope of the request. In general, however, the parties’ consent or the fact that information is subject to a confidentiality agreement or protective order between litigants is not, by itself, a valid basis to overcome the presumption in favor of public access to judicial documents. See, e.g., In re Gen. Motors LLC Ignition Switch Litig., No. 14- MD-2543 (JMF), 2015 WL 4750774, at *4 (S.D.N.Y. Aug. 11, 2015). ii. Filing Sealed or Redacted Documents. Where a party seeks leave to file a document under seal or in redacted form, the party shall file a letter- motion seeking leave to do so on ECF in accordance with Standing Order 19-MC-583 and Section 6 of the S.D.N.Y. ECF Rules and Instructions. The letter-motion itself shall be filed in public view, should explain the reasons for seeking to file the document under seal or in redacted form, and should 7 not include confidential information. Any application to file a document under seal or in redacted form must demonstrate that the standards for sealing have been met and specifically address Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110 (2d Cir. 2006) and any other controlling authority. The movant also may file a memorandum of law and an affidavit or affidavits in support of the request for sealing or redacting. If approval for redactions is sought, the application shall also include a proposed redacted version of the document in question for public docketing. When a party seeks leave to file a document under seal or in redacted form on the ground that an opposing party or third party has requested it, the opposing party or third party must file publicly on ECF, within three business days, a letter explaining the need to seal or redact the document. In the event there are grounds for sealing or redacting that cannot be publicly disclosed, a party may file under seal on ECF (with appropriate level of restriction) additional briefing further explaining those grounds, along with a justification for the sealing of that briefing. The subject document, in unredacted form, shall be contemporaneously filed under seal on ECF (with the appropriate level of restriction) and electronically related to the motion (or to the relevant Court order if the Court previously granted leave to file the document under seal). Note that the summary docket text, but not the document itself, will be open to public inspection and therefore should not include confidential information sought to be filed under seal. When a party seeks to file a document in redacted form, the party also shall e-mail to Chambers (CronanNYSDChambers@ny

duling Order available at the Court’s website. C. 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 or by telephone, in an effort to resolve the dispute. If this meet-and-confer process does not resolve the dispute, a party may raise the dispute with the Court by filing a letter-motion on ECF, no longer than three pages, explaining the nature of the dispute. Such a letter must include a representation that the meet-and-confer process occurred and was unsuccessful. A party opposing the relief sought must file a response, not to exceed three pages, within three business days. The Court will seek to resolve discovery disputes quickly, by order or at an in-person or telephonic conference. Counsel are strongly urged to 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 Court is unlikely to grant additional time for discovery.