1. Written or E-mail Communications (a) All communications with Chambers must be by means of joint telephone calls, as described in Rule 2, infra. Correspondence with the Court (whether by letter, email, or otherwise), filing correspondence on ECF or docketing correspondence with the Clerk of Court, and copying the Court on correspondence with others, is strictly forbidden, except as specifically authorized by these rules or expressly requested by the Court. Even if the Court emails an order, opinion, or other communication to the parties, the parties may not respond by email unless the Court directs them to do so. (b) Where specifically authorized by these rules or expressly requested by the Court, e-mail communication shall be sent to RakoffNYSDChambers@nysd.uscourts.gov as .pdf attachments with copies simultaneously delivered to all counsel. Emails shall state clearly in the subject line (i) the full caption of the case, including the party names and docket number, and (ii) the contents of the email. 2. Oral Communication; Motions and Applications (a) No ex parte communication with Chambers is permitted. Counsel for all affected parties must be on the line whenever a telephone call to Chambers is placed. The Judge and/or his clerks are normally available to receive telephone calls between 9:00 a.m. - 12:30 p.m. and 1:30 p.m. - 5:30 p.m. If calling within these hours, counsel need not schedule a telephone call to Chambers in advance.

§14(a): All parties that wish to propose a protective order must, after receiving the Court’s permission in accordance with Rule 2(b), supra, submit a proposed protective order that conforms as closely as possible with the Court’s Model Protective Order, which is available on the Judge’s website. If the parties alter the Court’s Model Protective Order in any way other than conforming the caption and signatures, they must provide a redline indicating all such modifications by email to Chambers. (b) Unless the Protective Order approved in a case provides 13 otherwise, parties must request the Court’s permission, in accordance with Rule 2(b), supra, to file documents under seal. The Court’s Model Protective Order does not provide such permission. Parties are expected to provide the Court with notice at least three business days before the relevant filing deadline if they wish to file documents under seal. (c) No document may be filed under seal without prior application to the Court as described above. After obtaining the Court’s leave, the document must be filed under seal in the ECF system. Where a party has received approval to redact information from a document that is to be publicly filed, that party shall publicly file the document with the redactions, and electronically file under seal a copy of the unredacted document. Both documents must be electronically filed through the ECF system. When filing documents under seal, parties are expected to provide the Court electronic copies of the underlying documents via email. If hard copies are necessary, they will be requested.