comply with the following rules and practices: 1. Communications with Chambers A. Letters. Except as otherwise provided below, communications with chambers shall be by letter, with copies simultaneously delivered to all counsel. Letters on behalf of parties represented by counsel must be both docketed on ECF and e-mailed as a PDF attachment to the following address: CA02_RJSChambers@ca2.uscourts.gov. Copies of correspondence between counsel shall not be sent to the Court or docketed on ECF. Pro se litigants may send letters by regular mail, but must send all letters to the Pro Se Intake Unit, not to chambers. Other than orders to show cause, documents should not be delivered directly to chambers without prior permission, including by Assistant United States Attorneys and Federal Defenders. Counsel shall include the case caption and docket number in the subject line of every e-mail sent to chambers. Counsel shall not provide a hard copy of correspondence e-mailed to chambers.

3. Sealing No document may be filed with the Clerk under seal without an order of this Court addressing the specific documents to be sealed. Any application to seal shall be accompanied by an affidavit or affidavits and a memorandum of law, demonstrating that the standards for sealing have been met and specifically addressing Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110 (2d Cir. 2006), in a civil case or United States v. Amodeo, 71 F.3d 1044 (2d Cir. 1995), in a criminal case, and any other controlling authority. The application shall also include a proposed redacted version of the document(s) in question for public docketing. Nothing herein is intended to alter or modify the applicability of Federal Rule of Civil Procedure 5.2. The redactions expressly authorized by Rule 5.2 may be made without application to the Court.

s an opportunity for a junior lawyer to argue. G. Discovery Disputes. Unless otherwise directed, and before making any discovery motion, counsel should describe their discovery disputes in a single letter, jointly composed, not to exceed five pages. Separate and successive letters will not be read. Before filing the joint letter, the parties shall confer in an effort to resolve the dispute without court action, and the joint letter shall describe the time, place and duration of such discussions, naming the counsel involved. The joint letter shall also describe concisely the issues in dispute and the respective positions of each party, citing the applicable authority that the respective parties claim for support. As a general matter, affidavits and exhibits are not permitted in connection with discovery dispute letters without prior written request and permission. However, when the dispute concerns the refusal to respond to a specific written request, the parties shall attach that request. If an opposing party refuses to participate in writing a joint letter or does not provide its portion of a joint letter within 72 hours of a party’s request, a party may submit a letter without the opposing party’s contribution and shall attach a copy of the correspondence seeking the opposing party’s contribution. Judge Sullivan Individual Practices Page 4