§I.A: All communications with Chambers on any subject must be in writing and filed via ECF, with copies delivered simultaneously to all counsel or pro se parties. Do not send copies of correspondence between counsel to the Court. Courtesy hard copies of all pleadings and all papers filed in connection with a motion are required (see Part V.A). Do not send emails to any email address in chambers. Any email sent to a chambers email address will be ignored. Telephone calls to Chambers are not permitted, except in the case of a real emergency. Judge McMahon's deputy clerk and law clerks will not discuss cases or clarify rules over the telephone. Any requests for clarification should be submitted in writing. §I.B: If a submission requires more immediate attention [than normal ECF review on the next business day], please notify Chambers by telephone after you file your submission on ECF. In case of a real emergency, the attorney for a represented party in a civil matter may call (212) 805-6325, and should include opposing counsel on the call. §I.C: Courtesy copies of motions and supporting papers may not be faxed to Chambers unless the Court specifically directs that fax be used. No document longer than 10 pages may be faxed without prior authorization.

§VI: The below addendum must be incorporated before Judge McMahon will sign a Stipulation and Confidentiality Order: 18 THE FOLLOWING ADDENDUM IS DEEMED INCORPORATED INTO THE PARTIES’ STIPULATION AND CONFIDENTIALITY ORDER The parties understand that the Court’s “so ordering” of this stipulation does not make the Court a party to the stipulation or imply that the Court agrees that documents designated as “Confidential” by the parties are in fact confidential. It has been this Court’s consistent experience that confidentiality stipulations are abused by parties and that much material that is not truly confidential is designated as such. The Court does not intend to be a party to such practices. The Court operates under a presumption that the entire record should be publicly available. The Court does not ordinarily file decisions under seal or redact material from them. If the Court issues a decision in this case that refers to “confidential” material under this stipulation, the decision will not be published for ten days. The parties must, within that ten-day period, identify to the Court any portion of the decision that one or more of them believe should be redacted, provide the Court with the purportedly confidential material, and explain why that material is truly confidential. The Court will then determine whether the material is in fact genuinely deserving of confidential treatment. The Court will only redact portions of a publicly available decision if it concludes that the material discussed is in fact deserving of such treatment. The Court’s decision in this regard is final. If this addendum is acceptable to the parties, the Court will sign their proposed confidentiality stipulation, subject to the addendum. If this addendum is not acceptable, the Court will not sign the stipulation, and should allegedly confidential material be produced, the parties will be referred to the magistrate judge for a document by document review and decision on whether that document should be subject to confidential treatment. VII. Pretrial and Trial Rules and Procedures A. Discovery Schedule Parties must exchange the discovery required under Federal Rule of Civil Procedure 26(a) within 30 days after service of the answer on the last plaintiff to be served or by the date specified in a Court-approved case management order. Notices inviting the parties to stipulate to a discovery schedule will be sent to plaintiff’s counsel (or, in the case of removed actions, defendant’s counsel) shortly after the filing of the action. 19 If the parties can agree upon a schedule providing for prompt completion of discovery, (i.e., within six months of the commencement of the action) the Court ordinarily will incorporate the agreement in a Scheduling Order. Otherwise, the Court will impose a schedule at the initial pretrial conference, held approximately 90 days after the complaint is filed. PLEASE NOTE: Judge McMahon does not routinely extend discovery deadlines. Do not wait until the end of the discovery period to serve discovery requests or schedule depositions, or you may be precluded from completing discovery. Delaying service of the complaint for 90 days after filing could result in having only one or two months to complete all discovery.

§V.B: When the first discovery dispute arises, file a letter to Chambers via ECF and ask for an order of reference to the Magistrate Judge. Thereafter, take all discovery disputes directly to the Magistrate Judge. Should either party file Objections to an order of the Magistrate Judge pursuant to Fed. R. Civ. P. 72, that party should also file a letter addressed to Judge McMahon to notify her that Rule 72 Objections were filed.