Judge Edgardo Ramos
Individual Rules, Standing Orders & Policies
- Rules last changed:
Limits & Logistics
Document Limits
Courtesy Copies
Courtesy copies
- 1 copy
- 1 copy • Upon Filing
- 2 copies
- 2 copies • At Time of Filing Joint Pretrial Statement
- 2 copies • Upon Filing
- As Soon as Practicable
- Hand Delivery
Indictment, Information, Complaint
Letter
- Not required
Motion
- 1 copy
- 1 copy • As Soon as Practicable
Adjournments
- Revised Scheduling Order required if adjournment affects other dates.
- Absent extraordinary circumstances, requests for extensions will be denied if not made before the expiration of the original deadline.
- Adjournment/extension requests must be filed as letter-motions with specific required elements.
- +2 more
Request must include
- Adjournment requests for court appearances require at least 48 hours notice absent emergency.
- Adjournment requests for court appearances require 48-hour advance notice.
- Counsel may extend the dates provided therein by stipulation submitted to the Court no later than two business days before the brief is due.
Communication
Chambers
Phone
Chambers
Page & Word Limits2 rules
Motion memoranda limited to 25 pages (support/opposition) and 10 pages (reply); formatting requirements include 12-point font, double-spacing, 1-inch margins.
Court's wording
Unless prior permission has been granted, memoranda of law in support of and in opposition to motions are limited to 25 pages, and reply memoranda are limited to 10 pages. Memoranda of 10 pages or more shall contain a table of contents. All memoranda of law shall be in 12-point font or larger and be double-spaced, and shall have one inch margins on all sides.
Unless prior permission has been granted, memoranda of law in support of and in opposition to motions are limited to 25 pages, and reply memoranda are limited to 10 pages.
- Page limit
- Up to 25 pages
- Opposition
Document Format Requirements2 rules
All memoranda of law shall be in 12-point font or larger and be double-spaced, and shall have one inch margins on all sides.
- Font size
- At least 12 points
- Line spacing
- Double
- Margins
- 1 inch
Motion papers should be bound in any manner that is secure, does not obscure the text, and permits the document to lie reasonably flat when open.
- Binding
- Securely bound
- Motion
Formatting
- •Does not obscure text
Document Filing Requirements26 rules
All proposed orders, judgments and stipulations requiring the Court's signature, must be filed electronically on the court's ECF system.
If the requested adjournment or extension affects any other scheduled dates, a proposed Revised Scheduling Order must be attached.
Unless prior permission has been granted, sur-reply memoranda will not be accepted.
Memoranda of 10 pages or more shall contain a table of contents.
Must include
- •Table of contents
Except for pro se litigants, the moving party shall provide all other parties with an electronic copy of the moving party's Statement of Material Facts pursuant to Local Civil Rule 56.1.
Joint pretrial statements must include full caption and complete trial counsel contact information.
- Document
- Pretrial order
Must include
- •Caption
Court's wording
The joint pretrial statement shall include the information required by Fed. R. Civ. P. 26(a)(3) and the following: i. The full caption of the action. ii. The names, addresses (including firm names), e-mail addresses, and telephone and fax numbers of trial counsel.
A statement as to whether the parties consent to a less than unanimous verdict.
Joint pretrial statements must list expected witnesses with descriptions and objection status.
Court's wording
A list of the witnesses each party expects to call on its case in chief, including a very brief description of the witness's role and/or the subject matter of his or her anticipated testimony, and a statement as to whether any other party objects to the witness.
A statement by each party as to whether the case is to be tried with or without a jury, and the number of trial days needed.
A designation by each party of deposition testimony to be offered in its case in chief, with any cross-designations and objections by any other party.
Any stipulations or agreed statements of fact or law.
Joint pretrial statements must itemize damages sought with calculation methodology.
Court's wording
A statement of the relief sought, including damages claimed, itemizing each component or element of the damages sought with respect to each claim, and including the manner and method used to calculate the claimed damages.
Joint pretrial statements must include statements on subject matter jurisdiction with statute citations and jurisdictional facts.
Court's wording
and a brief statement by each other party as to the presence or absence of subject matter jurisdiction. Such statements shall include citations to all statutes relied on and relevant facts as to citizenship and jurisdictional amount.
Joint pretrial statements must summarize remaining claims/defenses with statute citations and identify claims no longer being tried.
Court's wording
A brief summary by each party of the claims and defenses that party has asserted that remain to be tried, without recital of evidentiary matter but including citations to all statutes relied on. The parties shall also identify all claims and defenses previously asserted that are not to be tried.
Joint pretrial statements must list exhibits with star notation for objections.
Court's wording
A list by each party of exhibits to be offered in its case in chief, with one star indicating exhibits to which no party objects on grounds of authenticity, and two stars indicating exhibits to which no party objects on any ground.
A statement as to whether all parties have consented to trial of the case by a magistrate judge (without identifying which parties have or have not so consented).
Each proposed jury instruction must contain a citation to the source/authority for the proposed instruction, or the request will be disregarded.
A party shall group all letters together in a single paper filing under a cover marked SENTENCING MEMORANDUM with the caption and docket number clearly indicated
- Document
- Sentencing memorandum
Must include
- •Caption
- •Case number
A party shall group and file the letters together as attachments to a single document marked SENTENCING MEMORANDUM with the caption and docket number clearly indicated.
- Document
- Sentencing memorandum
Must include
- •Caption
- •Case number
Defendant's sentencing submission due 2 weeks before sentencing; Government's due 1 week before.
Court's wording
A defendant's sentencing submission shall be served two weeks in advance of the date set for sentence. The Government's sentencing submission shall be served one week in advance of the date set for sentence.
Unless prior permission has been granted, sur-reply memoranda will not be accepted.
Non-pro se parties must exchange Rule 56.1 statements for summary judgment motions.
Court's wording
Except for pro se litigants, the moving party shall provide all other parties with an electronic copy of the moving party's Statement of Material Facts pursuant to Local Civil Rule 56.1. Opposing parties must reproduce each entry in the moving party's Rule 56.1 Statement, and set out the opposing party's response directly beneath it.
The joint pretrial statement shall include the information required by Fed. R. Civ. P. 26(a)(3) and the following:
All proposed orders, judgments and stipulations requiring the Court’s signature, must be filed electronically on the court’s ECF system.
With respect to any deposition transcript that is supplied, whether in whole or in part, in connection with a summary judgment motion, the index to the deposition should be included if it is available.
Memoranda of 10 pages or more shall contain a table of contents.
Must include
- •Table of contents
Filing & Service rules
Courtesy Copy Requirements
Courtesy copies of letters are prohibited.
Parties shall not submit courtesy copies of letters that are filed as described above.
Page 1 | Communications with Chambers
One courtesy hard copy of motion papers (except pro hac vice and letter-motions) must be submitted to chambers as soon as practicable after filing, marked clearly, delivered to Court Security Officers if hand-delivered.
One courtesy hard copy of all motion papers (with the exception of motions for admission pro hac vice and letter-motions), shall be submitted to chambers as soon as practicable after filing. Courtesy copies should be clearly marked as such. If hand-delivered, courtesy copies should be brought to the Court Security Officers at the Worth Street entrance to 500 Pearl Street, not to chambers.
Page 2 | Courtesy Copies
Parties must provide electronic text-searchable courtesy copy of transcripts relied upon for summary judgment.
Except for pro se litigants, the parties shall provide the Court with an electronic, text-searchable courtesy copy of any hearing or deposition transcript, or a portion thereof, on which the parties rely, if such a copy is available, unless doing so would be unduly burdensome.
Page 4 | Special Rules for Summary Judgment Motions
Courtesy copy transcripts must be provided on CD only, not DVD, memory stick, or email.
Parties shall provide these materials on a CD only, not on a DVD or memory stick and not by e-mail.
Page 4 | Special Rules for Summary Judgment Motions
Joint pretrial statements in civil cases require one courtesy hard copy for chambers, due 30 days after discovery or dispositive motion decision.
Unless otherwise ordered by the Court, within 30 days after the date for completion of discovery in a civil case, or, if a dispositive motion has been filed, within 30 days after a decision on the motion, the parties shall file a joint pretrial statement, with one courtesy hard copy for chambers.
Page 5 | Joint pretrial statements in Civil Cases
any party may file, and submit one courtesy hard copy to chambers, the following documents within one week of the filing of any document described in section 4.B above
any party may file, and submit one courtesy hard copy to chambers, the following documents within one week of the filing of any document described in section 4.B above
Page 7 | Filings in Opposition
Certain trial documents must be served but not filed, with two courtesy copies submitted to chambers.
At the time the joint pretrial statement is filed, each party shall serve, but not file, the following documents, and submit two courtesy hard copies to chambers
Page 7 | Additional Submissions in Non-Jury Cases
Parties must submit two courtesy hard copies of trial documents to chambers 15 days before trial or 30 days after the joint pretrial statement.
each party shall file the following documents, and submit two courtesy hard copies to chambers, 15 days before the date of commencement of trial if such a date has been fixed, or 30 days after the filing of the joint pretrial statement if no date has been fixed
Page 7 | Trial Preparation
The Assistant United States Attorney ("AUSA") shall provide to chambers, as soon as practicable, a courtesy copy of the Indictment or Information, and a courtesy copy of the Complaint, if one exists.
The Assistant United States Attorney ("AUSA") shall provide to chambers, as soon as practicable, a courtesy copy of the Indictment or Information, and a courtesy copy of the Complaint, if one exists.
Page 8 | Criminal Cases
The parties should provide the Court with one courtesy copy of each submission when it is served.
The parties should provide the Court with one courtesy copy of each submission when it is served.
Page 11 | SENTENCING PROCEDURES
At the time the joint pretrial statement is filed, each party shall serve, but not file, the following documents, and submit two courtesy hard copies to chambers
At the time the joint pretrial statement is filed, each party shall serve, but not file, the following documents, and submit two courtesy hard copies to chambers
One courtesy copy required for all motions except pro hac vice and letter-motions.
One courtesy hard copy of all motion papers (with the exception of motions for admission pro hac vice and letter-motions), shall be submitted to chambers as soon as practicable after filing.
Except for pro se litigants, the parties shall provide the Court with an electronic, text-searchable courtesy copy of any hearing or deposition transcript, or a portion thereof, on which the parties rely, if such a copy is available, unless doing so would be unduly burdensome. (Parties shall provide these materials on a CD only, not on a DVD or memory stick and not by e-mail.)
Except for pro se litigants, the parties shall provide the Court with an electronic, text-searchable courtesy copy of any hearing or deposition transcript, or a portion thereof, on which the parties rely, if such a copy is available, unless doing so would be unduly burdensome. (Parties shall provide these materials on a CD only, not on a DVD or memory stick and not by e-mail.)
Transcript courtesy copies must be provided on CD only, not DVD, memory stick, or email.
Parties shall provide these materials on a CD only, not on a DVD or memory stick and not by e-mail.
Unless otherwise ordered by the Court, any party may file, and submit one courtesy hard copy to chambers, the following documents within one week of the filing of any document described in section 4.B above
Unless otherwise ordered by the Court, any party may file, and submit one courtesy hard copy to chambers, the following documents within one week of the filing of any document described in section 4.B above
AUSA must provide courtesy copies of plea agreements to chambers promptly.
The AUSA shall provide a courtesy copy of any plea agreement or related documents to chambers as soon as practicable.
Joint pretrial statement required within 30 days of discovery completion or dispositive motion decision, with courtesy copy for chambers.
Unless otherwise ordered by the Court, within 30 days after the date for completion of discovery in a civil case, or, if a dispositive motion has been filed, within 30 days after a decision on the motion, the parties shall file a joint pretrial statement, with one courtesy hard copy for chambers.
Two courtesy hard copies to chambers required 15 days before trial or 30 days after joint pretrial statement
each party shall file the following documents, and submit two courtesy hard copies to chambers, 15 days before the date of commencement of trial if such a date has been fixed, or 30 days after the filing of the joint pretrial statement if no date has been fixed
Failure to deliver courtesy copies may delay court's attention to documents.
PLEASE NOTE: If a courtesy copy of a document filed on ECF is not delivered to chambers, it may not come to the Court’s attention in a timely manner.
Courtesy hard copy should be accompanied by electronic copy on portable media (CD/DVD preferred).
Whenever possible, the courtesy hard copy should be accompanied by an electronic copy submitted on any portable media (CD/DVD preferred).
Page 2 | Courtesy Copies
No courtesy copies required for letters filed on ECF.
Parties shall not submit courtesy copies of letters that are filed as described above.
Electronic copy on CD/DVD preferred with courtesy hard copy.
Whenever possible, the courtesy hard copy should be accompanied by an electronic copy submitted on any portable media (CD/DVD preferred).
If hand-delivered, courtesy copies should be brought to the Court Security Officers at the Worth Street entrance to 500 Pearl Street, not to chambers.
If hand-delivered, courtesy copies should be brought to the Court Security Officers at the Worth Street entrance to 500 Pearl Street, not to chambers.
Sealing & Redaction Procedures
Sealed letters must follow the Electronic Filing Under Seal procedure in Section 3.
Letters to be filed under seal shall follow the procedure for Electronic Filing Under Seal in Civil and Miscellaneous Cases in accordance with Section 3 of this document.
Page 1 | Communications with Chambers
FRCP 5.2 information must be redacted without prior 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.
Page 4 | Electronic Filing Under Seal in Civil and Miscellaneous Cases
Motions for sealed/redacted filings must be filed via ECF per standing order 19-mc-00583.
Motions or Letter Motions for approval of sealed or redacted filings in civil and miscellaneous cases and the subject documents, including the proposed sealed document(s), must be filed electronically through the court's ECF system in conformity with the court's standing order, 19-mc-00583, and ECF Rules & Instructions, section 6.
Page 4 | Electronic Filing Under Seal in Civil and Miscellaneous Cases
To request redaction approval, file redacted version publicly and unredacted version with highlights under seal.
Where the motion seeks approval to redact information from a document that is to be publicly filed, the filing party shall: (a) publicly file the document with the proposed redactions, and (b) electronically file under seal a copy of the unredacted document with the proposed redactions highlighted. Both documents must be electronically filed through the ECF system and related to the motion.
Page 5 | Sealing Procedures
Sealed documents must be filed contemporaneously in ECF with public docket text that excludes confidential information.
The proposed sealed document must be contemporaneously filed under seal in the ECF system and electronically related to the motion. The summary docket text, but not the sealed document, will be open to public inspection and should not include confidential information sought to be filed under seal.
Page 5 | Sealing Procedures
Redacted pages must be filed under seal and a marked copy delivered to the Court at sentencing.
If any material is redacted from the publicly filed document, only those pages containing the redacted material will be filed under seal. Bring a copy of those pages to the sentencing proceeding, marked to indicate what information has been redacted from the publicly filed materials, to give to the Court for filing under seal.
Page 11 | SENTENCING PROCEDURES
Sealed documents must be contemporaneously filed under seal in ECF and electronically related to the motion.
The proposed sealed document must be contemporaneously filed under seal in the ECF system and electronically related to the motion.
For redactions in publicly filed documents, file redacted version publicly and unredacted version under seal with highlights.
Where the motion seeks approval to redact information from a document that is to be publicly filed, the filing party shall: (a) publicly file the document with the proposed redactions, and (b) electronically file under seal a copy of the unredacted document with the proposed redactions highlighted.
Parties unable to file electronically under seal must move for leave to file on paper.
Any party unable to comply with the requirement for electronic filing under seal through the ECF system, or who has reason to believe that a particular document should not be electronically filed, must move for leave of the Court to file in the traditional manner, on paper.
Supporting papers may be filed under seal or redacted only as necessary to protect confidential information.
Supporting papers must be separately filed electronically and may be filed under seal or redacted only to the extent necessary to safeguard information sought to be filed under seal.
Sealed letters must follow ECF sealing procedures.
Letters to be filed under seal shall follow the procedure for Electronic Filing Under Seal in Civil and Miscellaneous Cases in accordance with Section 3 of this document.
Parties unable to file electronically under seal must seek leave to file on paper.
Any party unable to comply with the requirement for electronic filing under seal through the ECF system, or who has reason to believe that a particular document should not be electronically filed, must move for leave of the Court to file in the traditional manner, on paper.
Page 5 | Sealing Procedures
Pre-Motion Conference Requirements
Opposing party must submit response letter within 3 business days, limited to 3 pages.
The opposing party shall submit a letter, also not to exceed three pages, setting forth its position within three business days from the service of the moving party's letter.
Page 3 | Pre-Motion Conference in Civil Cases
Pre-motion letter required, limited to 3 pages, stating basis for anticipated motion.
To arrange a pre-motion conference, the moving party shall submit a letter, not to exceed three pages, setting forth the basis for the anticipated motion.
Page 3 | Pre-Motion Conference in Civil Cases
Pre-motion conference required for most motions with specific exemptions.
A pre-motion conference with the Court is required before making any other motion, except where a litigant believes that delay in filing the motion might result in the loss of a right or where a litigant seeks to make a motion in a case involving an incarcerated pro se litigant, motion for admission pro hac vice, motion for reargument or reconsideration, or motion for temporary restraining order or preliminary injunction.
Page 3 | Pre-Motion Conference in Civil Cases
Pre-motion conference required for discovery motions per Local Civil Rule 37.2.
For discovery motions, follow Local Civil Rule 37.2, requiring the moving party to request an informal conference with the Court before the filing of any such motion.
Page 3 | Pre-Motion Conference in Civil Cases
Pre-motion conference required before most motions, with specific exceptions.
A pre-motion conference with the Court is required before making any other motion, except where a litigant believes that delay in filing the motion might result in the loss of a right or where a litigant seeks to make a motion in a case involving an incarcerated pro se litigant, motion for admission pro hac vice, motion for reargument or reconsideration, or motion for temporary restraining order or preliminary injunction.
Pre-motion letter (max 3 pages) required from moving party; opposition letter (max 3 pages) due within 3 business days.
To arrange a pre-motion conference, the moving party shall submit a letter, not to exceed three pages, setting forth the basis for the anticipated motion. The opposing party shall submit a letter, also not to exceed three pages, setting forth its position within three business days from the service of the moving party's letter.
Pre-motion conference request for motion to dismiss stays deadline to move or answer.
If a pre-motion conference is requested in connection with proposed motion to dismiss, the request will stay the deadline for the requesting party to move or answer, and a new deadline will be set at the conference.
Page 3 | Pre-Motion Conference in Civil Cases
Oral argument may be requested by letter when filing motion papers; Court decides whether to grant.
Parties may request oral argument by letter at the time their moving, opposing or reply papers are filed. The Court will determine whether argument will be heard and, if so, will advise counsel of the date and time.
Adjournment & Extension Requirements
Adjournment/extension requests must be in writing filed as letter-motions on ECF, including original date, prior requests, reasons, adversary consent, etc.
requests for adjournments or extensions of time shall be in writing and filed on ECF as letter- motions (if consistent with the S.D.N.Y. Local Rules and the S.D.N.Y. “Electronic Filing Rules and Instructions”), and must include: i. the original date; ii. the number of previous requests for adjournment or extension, and the reason(s) therefor; iii. whether the previous requests were granted or denied; iv. the reason for the instant request; and v. whether the adversary consents, and, if not, the reasons given by the adversary for refusing to consent.
Page 2 | Adjournments and Extensions
Adjournment requests for court appearances require at least 48 hours notice absent emergency.
If the request is for an adjournment of a court appearance, absent an emergency, the request shall be made at least 48 hours prior to the scheduled appearance.
Page 2 | Adjournments and Extensions
Extension requests denied if not made before original deadline expires, absent extraordinary circumstances.
Absent extraordinary circumstances, requests for extensions will be denied if not made before the expiration of the original deadline.
Page 2 | Adjournments and Extensions
Adjournment requests for court appearances require 48-hour advance notice.
If the request is for an adjournment of a court appearance, absent an emergency, the request shall be made at least 48 hours prior to the scheduled appearance.
Revised Scheduling Order required if adjournment affects other dates.
If the requested adjournment or extension affects any other scheduled dates, a proposed Revised Scheduling Order must be attached.
Absent extraordinary circumstances, requests for extensions will be denied if not made before the expiration of the original deadline.
Absent extraordinary circumstances, requests for extensions will be denied if not made before the expiration of the original deadline.
Adjournment/extension requests must be filed as letter-motions with specific required elements.
adjournments or extensions of time shall be in writing and filed on ECF as letter- motions (if consistent with the S.D.N.Y. Local Rules and the S.D.N.Y. “Electronic Filing Rules and Instructions”), and must include: i. the original date; ii. the number of previous requests for adjournment or extension, and the reason(s) therefor; iii. whether the previous requests were granted or denied; iv. the reason for the instant request; and v. whether the adversary consents, and, if not, the reasons given by the adversary for refusing to consent.
Counsel may extend the dates provided therein by stipulation submitted to the Court no later than two business days before the brief is due.
Counsel may extend the dates provided therein by stipulation submitted to the Court no later than two business days before the brief is due.
Page 8 | Bankruptcy Appeals
Chambers Communication Rules
Proposed jury instructions must be e-mailed to Judge Ramos' law clerk in addition to normal filing.
In addition to being filed in the normal manner, proposed jury instructions should be e-mailed to Judge Ramos' law clerk. Counsel should send an email to chambers to make arrangements for same.
Page 7 | Trial Preparation
Email to court requires prior permission.
Except as otherwise provided in Section 1.A. above, if a party wishes to e-mail a .pdf document to the Court, it must obtain prior permission.
Faxes to chambers are prohibited.
Faxes to chambers are not permitted.
Except as otherwise provided in Section 1.A. above, if a party wishes to e-mail a .pdf document to the Court, it must obtain prior permission. E-mails should indicate who in chambers provided such permission, and must be copied to all counsel. If a document is e-mailed to chambers, do NOT also send a hard copy.
Except as otherwise provided in Section 1.A. above, if a party wishes to e-mail a .pdf document to the Court, it must obtain prior permission. E-mails should indicate who in chambers provided such permission, and must be copied to all counsel. If a document is e-mailed to chambers, do NOT also send a hard copy.
Page 1 | Communications with Chambers
Faxes to chambers are prohibited.
Faxes to chambers are not permitted.
Page 1 | Communications with Chambers
Phone calls to chambers only allowed for immediate attention situations.
Telephone calls to chambers are permitted only in situations requiring immediate attention.
Page 1 | Communications with Chambers
Do not send hard copy if document is emailed.
If a document is e-mailed to chambers, do NOT also send a hard copy.
Docketing, scheduling, and calendar matters should be emailed to chambers.
Please email chambers at ChambersNYSDRamos@nysd.uscourts.gov.
Page 1 | Communications with Chambers
Notify Chambers by email after ECF filing if submission requires immediate attention.
If a submission requires immediate attention, please notify Chambers by email after you file the submission via ECF.
Page 3 | Communications with Chambers
Parties may request oral argument by letter when filing motion papers.
Parties may request oral argument by letter at the time their moving, opposing or reply papers are filed.
Page 4 | Oral Argument on Motions
Questions about sentencing procedures may be sent via email to chambers.
If you have any questions about these procedures, send an email to chambers.
Page 12 | SENTENCING PROCEDURES
Junior Lawyer Participation Incentives
Junior lawyers not experienced in courtroom argument may be encouraged to participate, and the Court permits more than one lawyer to argue for a party when it creates opportunities for junior lawyers.
Encouraged Participation of Junior Members of Legal Teams. Due to the decline of trials, opportunities to train junior lawyers in courtroom skills have become increasingly rare. Accordingly, where junior lawyers are familiar with the matter under consideration, but are not experienced in arguing before a court, they should be encouraged to actively participate. In such circumstances, where it creates an opportunity for a junior lawyer to argue, this Court is amenable to permitting more than one lawyer to argue for one party.
Page 9 | Encouraged Participation of Junior Members of Legal Teams
Court encourages junior lawyer participation and allows multiple attorneys to argue.
Due to the decline of trials, opportunities to train junior lawyers in courtroom skills have become increasingly rare. Accordingly, where junior lawyers are familiar with the matter under consideration, but are not experienced in arguing before a court, they should be encouraged to actively participate. In such circumstances, where it creates an opportunity for a junior lawyer to argue, this Court is amenable to permitting more than one lawyer to argue for one party.