HON. KENNETH M. KARAS MEMORANDUM TO ALL LITIGANTS Re: Individual Rules of Practice Date: April 20, 2026 Unless otherwise ordered, Parties and counsel with matters before Judge Karas shall conduct themselves in accordance with the following practices:

§IX.A.i: 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. ii. Sealing/Redaction Requiring Court Approval. Motions or Letter Motions for approval of sealed or redacted filings in civil and miscellaneous cases 8 and the subject documents, including the proposed sealed document(s), may be filed electronically through the court’s ECF system in conformity with the court’s standing order, 19-mc-00583, and ECF Rules & Instructions, section 6. The motion must be filed in public view, must explain the particular reasons for seeking to file that information under seal and should not include confidential information sought to be filed under seal. Supporting papers must be separately filed electronically and may be filed under seal or redacted only to the extent necessary to safeguard information sought to be filed under seal. When using the electronic method, the proposed sealed document must be contemporaneously filed under seal in the ECF system and electronically related to the motion. The summary docket text, but not the sealed document, will be open to public inspection and should not include confidential information sought to be filed under seal. Where the motion seeks approval to redact information from a document that is to be publicly filed, the filing party shall: (a) publicly file the document with the proposed redactions, and (b) electronically file under seal a copy of the unredacted document with the proposed redactions highlighted. Both documents must be electronically filed through the ECF system and related to the motion.

§II.A: A. Pre-motion Conferences in Civil Cases. For discovery motions, follow Local Civil Rule 37.2. For motions other than discovery motions, a pre-motion conference with the Court is required for making any motion, except motions brought on by Order To Show Cause, motions by incarcerated pro se litigants, motions for admission pro hac vice, motions for reargument, motions for class certification, and motions described in Rule 6(b) of the Federal Rules of Civil Procedure and Rule 4(a)(4)(A) of the Federal Rules of Appellate Procedure. For motions to dismiss in lieu of an answer in fully counseled cases, the movant must send a pre-motion letter to the nonmovant, copy the Court, and file it on the docket. The letter shall include each specific argument and relevant case law supporting the movant’s position as to why the complaint may fail or partially fail as a matter of law. The filing of such a letter stays the time to answer or move until further order of the Court. Within seven days, the nonmovant shall respond by similar letter, indicating either that they will amend their pleading (with a proposed deadline for filing the amended pleading) or that they do not see a need to amend, citing the relevant case law that supports their position. Should the nonmovant choose not to amend in response to movant’s letter, the Court will then schedule a pre-motion conference to discuss the issues and potentially set a briefing schedule. If a complaint is ultimately dismissed on the grounds set forth in the movant’s initial letter, it may be dismissed with prejudice as the nonmovant already had a chance to research the movant’s arguments and amend as needed. To arrange a pre-motion conference for all other forms of motions that require them, the moving Party shall submit a letter (consistent with the procedures described above) not to exceed three pages in length (using normal margins and font) setting forth the basis for the anticipated motion. All Parties so served must submit a letter response, not to exceed three pages, within seven days from service of the notification letter. 3 To arrange a pre-motion conference for motions governed by a Scheduling Order, the moving Party must submit its initial letter two weeks prior to the motion deadline established by the Order. Where a pre-motion conference is not required, motions should be filed when served. It is essential that all Parties filing or responding to a pre-motion letter contemporaneously file a notice of appearance with the Clerk’s Office (although a Party contesting jurisdiction need only file a limited notice of appearance). This ensures that litigants are notified of any instructions or scheduling orders issued by the Court. Further, the Court expects each litigant to fulfill the duties of S.D.N.Y. ECF Procedure 9 by regularly reviewing the docket sheets of any open case in which she or he has appeared.