2. Communications with Chambers a. Letters and Letter-Motions. i. Unless otherwise provided below, communications with Chambers shall be by letter filed on ECF. Letters seeking relief (consistent with S.D.N.Y. Local Rules and the S.D.N.Y. Electronic Case Filing Rules and Instructions) should be filed as letter-motions on ECF, not ordinary letters. ii. Letters may not exceed three pages in length (exclusive of exhibits or attachments) without prior permission from the Court. iii. 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. iv. Any request for relief shall be accompanied by a statement as to whether the opposing party consents to the requested relief and, if not, the reasons given by the adversary for refusing to consent. b. Telephone Calls. Chambers is not accepting telephone calls at this time. Technical questions pertaining to ECF filings should be directed to the ECF Help Desk at helpdesk@nysd.uscourts.gov or (212) 805-0800. c. Faxes. Faxes to Chambers are not permitted without express prior permission. d. Hand Deliveries. Hand-delivered mail should be left with the Court Security Officers at the Worth Street entrance (200 Worth Street, New York, NY 10007) of the Daniel Patrick Moynihan United States District Courthouse. If the hand- delivered letter is urgent and requires the Court’s immediate attention, ask the Court Security Officers to notify Chambers that an urgent package has arrived that needs to be retrieved by Chambers staff immediately. e. Requests for Adjournments or Extensions of Time. i. All requests for adjournments or extensions of time must be made in writing and filed on ECF as letter-motions per Section 2(a) of these Rules, not as ordinary letters. ii. Absent an emergency, any request for extension or adjournment shall be made as early as possible, and at least two business days before the deadline or scheduled appearance. Extension requests will ordinarily be denied if made after the expiration of the original deadline. The letter-motion must state: (1) the original date and the new date requested; (2) the number of previous requests for adjournment or extension; (3) whether these previous requests were granted or denied; (4) the reason for the extension or adjournment; (5) whether the adversary 3 consents and, if not, the reasons given by the adversary for refusal to consent; and (6) the date of the parties’ next scheduled appearance before the Court. iii. If the requested adjournment or extension affects any other scheduled dates, a proposed Revised Civil Case Management Plan and Scheduling Order must be attached, specifying all of the proposed changes (e.g., with a redline showing the differences between the operative Scheduling Order—see Section 3(c) below—and the proposed Revised Scheduling Order). iv. A request for an adjournment of a conference must also include three alternative conference dates that are mutually ag

6. Redactions and Filing Under Seal a. Privacy Policy. The parties are referred to Federal Rule of Civil Procedure 5.2 and the S.D.N.Y. ECF Privacy Policy (“Privacy Policy”). b. Redactions Not Requiring Court Approval. There are two categories of information that may be redacted from public court filings without prior permission from the Court: “sensitive information” and information requiring “caution.” Parties should not include in their public filings, unless necessary, the five categories of “sensitive information,” i.e., • social security numbers (use the last four digits only), • names of minor children (use the initials only), • dates of birth (use the year only), • financial account numbers (use the last four digits only), and • home addresses (use only the City and State). Parties may also, without prior Court approval, redact from their public filings the six categories of information requiring “caution” described in the Privacy Policy, i.e., 12 • any personal identifying number, • medical records (including any information regarding medical treatment, including for substance abuse, and diagnosis), • employment history, • individual financial information, • proprietary or trade secret information, and • information regarding an individual’s cooperation with the government. 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. In general, 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 to judicial documents. d. Procedures for Filing Sealed or Redacted Documents. Any party seeking leave to file a document under seal or in redacted form shall proceed as follows: i. Meet and Confer. The party 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 under seal or 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, within three business days, a letter explaining the need to seal or redact the document. ii. Sealed Document(s). The party shall file a letter-motion seeking leave to file a document wholly under seal on ECF 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, should explai

soft Word and PDF formats. k. Discovery Disputes. Parties must follow Local Civil Rule 37.2 with the following modifications. i. Any party wishing to raise a discovery dispute with the Court must first confer in good faith with the opposing party—in person, by videoconference, or by telephone—to resolve the dispute. Where a party raises a discovery dispute with the opposing party, the opposing party must make itself available to confer in good faith to resolve the dispute within two business days of a request for a conference. ii. If the meet-and-confer process does not resolve the dispute, the party seeking discovery may file on ECF a letter-motion, no longer than three pages, explaining the nature of the dispute and, if applicable, why the party is entitled to relief and requesting a conference before the Court. iii. Any letter-motion seeking relief must state: (1) the date and time of each conference conducted pursuant to Section 4(k)(i) above; (2) the 8 adversary’s position as to each issue being raised; and (3) that the moving party informed the adversary during the last conference that the moving party believed the parties to be at an impasse and that the moving party would be requesting a conference with the Court. iv. Any opposition to a letter-motion seeking relief shall be filed as a letter, not to exceed three pages, within three business days. v. 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. vi. Privilege Logs and Privilege Log Disputes. Privilege logs should be sufficiently detailed to enable the receiving party to evaluate a claim of privilege, including identification of attorneys involved in the relevant documents or communications. Privilege logs must be promptly produced and updated on a rolling basis as documents are produced. Each log and update must include a certification from counsel that counsel has reviewed the withheld or redacted documents, and that there is a good-faith basis to assert privilege over those documents. Disputes related to privilege logs are subject to the Rules governing discovery disputes specified in Section 4(k). On its own initiative, the Court may order in camera production to the Court of unredacted documents from the producing party’s log where a dispute is raised.