§1.A: A. No Paper Submissions Absent Undue Hardship. No papers, including courtesy hard copies of any filing or document, may be submitted to Chambers unless specifically ordered by the Court or otherwise permitted by these Individual Practices. All documents must be filed on ECF or, if permitted or required under the Court’s Individual Practices, emailed to LimanNYSDChambers@nysd.uscourts.gov. In the event that a party or counsel is unable to submit a document electronically— either by ECF or email—the document may be mailed to the Court. To the maximum extent possible, however, this means of delivery should be avoided.

H. Redactions and Filing Under Seal i. Redactions/Sealing 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. ii. Redaction/Sealing Requiring Court Approval. Except for redactions permitted by Paragraph 2(H)(i), all redactions require Court approval. To be approved, redactions must be narrowly tailored to serve whatever purpose justifies them and otherwise consistent with the presumption in favor of public access to judicial documents. See, e.g., Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110, 119–20 (2d Cir. 2006). In general, 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., 2015 WL 4750774, at *4 (S.D.N.Y. Aug. 11, 2015). A party seeking to file a document with redactions or under seal must follow the procedures set forth in Attachment A (see pages 16–17 of these Individual Practices).

, each such difference and the reasons for it. C. Discovery Disputes in Non-Pro Se Cases. Notwithstanding Local Rule 37.2, discover disputes shall be governed by the following procedures. Any party wishing to raise a discovery dispute with the Court must first attempt to confer in good faith with the opposing party, in person or by telephone, to try and resolve the dispute. If, after attempting to meet and confer, the dispute has not been resolved, any party may file a letter-motion on ECF, no longer than three single-spaced pages, explaining the nature of the dispute and the relief requested. Such letter shall include a certification that it has, in good faith, conferred or attempted to confer with the party failing to make disclosure or discovery pursuant to Federal Rule of Civil Procedure 37(a)(1). If the opposing party wishes to respond to the letter-motion, the opposition (which should take the form of a letter, not to exceed three single-spaced pages) must be filed 12 on ECF within two business days. Counsel should be immediately prepared to discuss with the Court the matters raised by such letters, as the Court will seek to resolve discovery disputes quickly by order, conference, or telephone. The Court may seek such resolution before any opposition is submitted. Counsel is expected to be available to meet and confer within 48 hours of receiving a request from the initiating party. If counsel for the non-moving party fails to meet and confer within 48 hours of a request, then counsel for the moving party will be deemed to have satisfied the obligation to attempt in good faith to meet and confer and may file the letter on ECF referred to in the paragraph above. The non-moving party should be aware that, if it has failed to meet and confer, the Court will reserve its discretion to permit the moving party a short reply.