§I.A: Letters may not exceed 5 pages in length. Unless accompanied by a request to file under seal, letters shall be filed electronically on ECF. Please do not provide courtesy copies of letters. See Rule II below regarding sealing requests. Include the case number on all letters. Copies of letters to the Court shall be simultaneously delivered to all counsel, whether via ECF notification or other means. Copies of correspondence between counsel shall not be sent to the Court. Refer to Rule IV(E) below for letters concerning discovery disputes.

§II.A: A. Sealing/Redactions Not Requiring Court Approval. Federal Rule of Civil Procedure 5.2 describes sensitive information that must be redacted from public court filings without seeking prior permission from the Court. Such sensitive information includes: Social Security numbers; names of minor children; dates of birth; and financial account numbers. Other information that should be treated with caution and may warrant a motion for approval of sealed or redacted filing includes: personal identifying numbers (PIN numbers); medical records, treatment and diagnosis; employment history; individual financial information; proprietary or trade secret information; home addresses; and information regarding an individual’s cooperation with the government. Sensitive information and information requiring caution must not be included in any document filed with the Court unless such inclusion is necessary and relevant to the case. If such information must be included, personal identifiers must be partially redacted in accordance with the above-cited rules and policies in order to protect any privacy interest.

§IV.E: E. Discovery Disputes. Unless otherwise directed, counsel should describe their discovery disputes in a single letter, jointly composed. Strict adherence to Fed. R. Civ. P. 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 describe concisely the issues in dispute and the respective position of each party, with citations for supporting authority. Letters regarding discovery disputes should be filed in accordance with Rule I(A) above. Where a formal discovery motion is necessary, follow Local Civil Rule 37.2. 5 F. Protective Orders. Parties who wish to obtain a protective order shall consult the Court’s Model Protective Order, which is available on the Court’s website (https://nysd.uscourts.gov/hon-paul-g-gardephe). The proposed protective order should be filed on ECF as an attachment to a cover letter in accordance with Rule I(A) above, and with Rule 18 of the Southern District of New York Electronic Case Filing Rules & Instructions, which is available at https://nysd.uscourts.gov. If the protective order proposed by the parties deviates from the Court’s Model Protective Order, a blackline showing all deviations shall be provided as a separate exhibit.