§1.A: Parties shall send to Chambers a hard copy of all letters. Copies of letters to Chambers shall simultaneously be delivered to all counsel in no less speedy a manner than the method of delivery to the Court. Counsel shall not copy the Court on correspondence between and among them. Parties are not permitted to file letter motions and briefs in lieu of formal motions, unless special permission to do so is granted. §1.B: Copies of all documents shall either be mailed to Chambers or left with the Court Security Officer at the Worth Street entrance of the Courthouse. Papers shall not be delivered directly to Chambers unless special permission to do so is granted. §1.B.i: Faxes may be sent only: for urgent matters requiring an immediate response from Chambers; to request an adjournment or extension of time as provided by Rule 1.D; or to make a technology request as provided by Rule 1.F. Faxes should be brief and may not exceed 5 pages without special permission from Chambers. Do not follow faxes with a hard copy. §1.C: Phone calls are not permitted (i) to seek adjournments, (ii) for inquiries as to the status of a pending motion, (iii) for oral interpretation or clarification of written orders, or (iv) to seek guidance on procedures that are governed by these Individual Rules, the Local Rules of this Court, or the Federal Rules.

G. Redactions and Filing Under Seal. The parties must adhere to the procedures set forth in the Appendix to these Rules.

D. Discovery Disputes. Parties shall follow S.D.N.Y. Local Rule 37.2 with the following modifications. Any party wishing to raise a discovery dispute with the Court must first meet and confer in good faith with the opposing party, in person or by telephone or video conferencing, in an effort to resolve the dispute. If this meet-and-confer process does not resolve the dispute, the party may file a letter motion with the Court or, if applicable, to the Pro Se Intake Clerk, no longer than 3 single-space pages, explaining the nature of the dispute and requesting a conference. Such letter must include a representation that the meet-and-confer process occurred, including when and whether it was in person or over the telephone. Any responsive letter should be submitted within 3 business days following submission of the letter motion. The Court retains discretion to rule on the dispute based on the parties’ letter submissions, without more formal briefing, and with or without a conference. If any party believes that more formal briefing is warranted, that party must make a separate application to the court explaining why more formal briefing is warranted. 5 Lehrburger Individual Rules 2025.9.30 Parties shall keep in mind Rule 1 of the Federal Rules of Civil Procedure, which requires the Court and the parties to construe, administer, and employ the rules of procedure to secure the just, speedy, and inexpensive determination of every action. Parties also shall keep in mind Rule 26(b)(1) of the Federal Rules of Civil Procedure, which provides that “[p]arties may obtain discovery regarding any non-privileged matter that is relevant to any party’s claim or defense and proportional to the needs of the case, considering the importance of the issues at stake in the action, the amount in controversy, the parties’ relative access to relevant information, the parties’ resources, the importance of the discovery in resolving the issues, and whether the burden or expense of the proposed discovery outweighs its likely benefit.” Discovery motions should address these rules to the extent applicable.