--- title: "Arun Srinivas Subramanian | KnowJudges" canonical: "https://knowjudges.com/kyj/judge/arun-srinivas-subramanian" page_type: "judge_profile" updated: "2026-10-09" --- # Arun Srinivas Subramanian U.S. District Court for the Southern District of New York · Judge ## Profile - Court: U.S. District Court for the Southern District of New York - State: New York - Role: Judge - Service status: active - Last verified: 2026-07-25 ## Summary Official judge-specific and circuitwide procedural guidance has been located for this profile. ## Biography ### Professional career - U.S. District Judge for the Southern District of New York, appointed by President Joe Biden in 2023 and confirmed by the Senate 59–37 - Law clerk, Hon. Ruth Bader Ginsburg, Supreme Court of the United States, 2006-2007 - Justice Ruth Bader Ginsburg, U.S. Supreme Court (2006–2007) - Law clerk, Hon. Gerard E. Lynch, U.S. District Court for the Southern District of New York, 2005-2006 - Law clerk, Hon. Dennis Jacobs, U.S. Court of Appeals for the Second Circuit, 2004-2005 ### Education ### Additional information - Private practice, New York City, 2007-2023 - From 2007 to 2023, he practiced commercial and bankruptcy law at Susman Godfrey LLP in New York City - Born in 1979 in Pittsburgh, Pennsylvania to Indian Tamil parents, Subramanian earned a B.A. in 2001 from Case Western Reserve University, summa cum laude, and a J.D. in 2004 from Columbia Law School, where he held the role of executive editor of the Columbia Law Review. - Date of birth: 1979 - He received the James Kent Scholar and Harlan Fiske Stone Scholar honors - Birth place: Pittsburgh ## Before you appear - Read the judge-specific standing order first when one is listed. - Check the docket and case orders for requirements that supersede broader guidance. - Confirm current remote-access and courtroom technology arrangements before the proceeding. ## Courtroom Rules ### electronic devices Scope: judge specific Electronic devices may not be used in Judge Subramanian's courtroom without permission. Evidence excerpt: Electronic devices (including mobile telephones, personal electronic devices, and computers) may not be used in Judge Subramanian’s Courtroom without his permission. [Judge Subramanian's Individual Practices in Civil Cases](https://www.nysd.uscourts.gov/sites/default/files/practice_documents/AS%20Subramanian%20Civil%20Individual%20Practices.pdf) Source checked: 2026-07-26 ### civil remote testimony Scope: courtwide In federal district-court civil proceedings, testimony is ordinarily taken in open court; remote contemporaneous testimony requires good cause in compelling circumstances and appropriate safeguards. Evidence excerpt: For good cause in compelling circumstances and with appropriate safeguards, the court may permit testimony in open court by contemporaneous transmission from a different location. [Federal Rule of Civil Procedure 43(a), Testimony in Open Court](https://www.uscourts.gov/forms-rules/current-rules-practice-procedure/federal-rules-civil-procedure) Source checked: 2026-07-26 ### criminal recording and broadcasting Scope: courtwide Federal district courts may not permit courtroom photography or broadcasting during criminal judicial proceedings unless a statute or another federal rule provides an exception. Evidence excerpt: Except as otherwise provided by a statute or these rules, the court must not permit the taking of photographs in the courtroom during judicial proceedings or the broadcasting of judicial proceedings from the courtroom. [Federal Rule of Criminal Procedure 53, Courtroom Photographing and Broadcasting Prohibited](https://www.uscourts.gov/court-records/access-court-proceedings/remote-public-access-proceedings/history-cameras-broadcasting-and-remote-public-access-courts) Source checked: 2026-07-26 ## Sources - [Official profile](https://www.fjc.gov/node/13367441) - [Official roster](https://www.fjc.gov/node/13367441) - [Federal Judicial Center biography](https://www.fjc.gov/node/13367441) - [Judge Subramanian's Individual Practices in Civil Cases](https://www.nysd.uscourts.gov/sites/default/files/practice_documents/AS%20Subramanian%20Civil%20Individual%20Practices.pdf) - [Federal Rule of Civil Procedure 43(a), Testimony in Open Court](https://www.uscourts.gov/forms-rules/current-rules-practice-procedure/federal-rules-civil-procedure) - [Federal Rule of Criminal Procedure 53, Courtroom Photographing and Broadcasting Prohibited](https://www.uscourts.gov/court-records/access-court-proceedings/remote-public-access-proceedings/history-cameras-broadcasting-and-remote-public-access-courts) - [Judge Arun Srinivas Subramanian](https://www.fjc.gov/node/13367441) - [Wikidata: Arun Subramanian](https://www.wikidata.org/wiki/Q113681951) ## JSON-LD ```json { "@context": "https://schema.org", "@graph": [ { "@type": "WebPage", "@id": "https://knowjudges.com/kyj/judge/arun-srinivas-subramanian", "url": "https://knowjudges.com/kyj/judge/arun-srinivas-subramanian", "name": "Arun Srinivas Subramanian | KnowJudges", "description": "Arun Srinivas Subramanian, U.S. District Court for the Southern District of New York. 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Counsel can obtain instructions on how to register at https://nysd. uscourts.gov/electronic-case-filing. See document heading and cited passage; do not apply outside the issuing part or proceeding. [Official rules document](https://www.nysd.uscourts.gov/sites/default/files/practice_documents/AS%20Criminal%20Individual%20Practices%20Feb%20%2726%20Revision.pdf) · Source page 1 · Collected 2026-10-27 #### Filing and working copies 3. No Courtesy Copies. Unless the Court orders otherwise, parties should not submit courtesy copies of any submissions, including sentencing submissions. See document heading and cited passage; do not apply outside the issuing part or proceeding. [Official rules document](https://www.nysd.uscourts.gov/sites/default/files/practice_documents/AS%20Criminal%20Individual%20Practices%20Feb%20%2726%20Revision.pdf) · Source page 1 · Collected 2026-10-27 #### Communications with chambers A. Initial Pretrial Conference. Upon assignment of a criminal case to Judge Subramanian, the Assistant United States Attorney shall immediately email Chambers to arrange for a prompt conference/arraignment. In the email, the Assistant United States Attorney shall include: (1) the name of the defendant(s); (2) defense counsel’s name and contact information; (3) whether the defendant(s) is/are detained (and, if so, the relevant defendant’s Reg. No.) or bailed; (4) whether any defendant requires an interpreter (and, if so, the relevant language); and (5) any other pertinent information. In addition, the Assistant United States Attorney shall attach to the email PDFs of the indictment and the criminal complaint if they exist. See document heading and cited passage; do not apply outside the issuing part or proceeding. [Official rules document](https://www.nysd.uscourts.gov/sites/default/files/practice_documents/AS%20Criminal%20Individual%20Practices%20Feb%20%2726%20Revision.pdf) · Source page 1 · Collected 2026-10-27 #### Adjournments B. Telephone Calls. Any other communications with Chambers, including requests for extensions or adjournments, shall be by letter or letter-motion filed on ECF in accordance with Paragraphs 4(C) and 6(A). For questions that See document heading and cited passage; do not apply outside the issuing part or proceeding. [Official rules document](https://www.nysd.uscourts.gov/sites/default/files/practice_documents/AS%20Criminal%20Individual%20Practices%20Feb%20%2726%20Revision.pdf) · Source page 1 · Collected 2026-10-27 #### Adjournments C. Letters. Except for matters requiring immediate attention or as otherwise provided below, communications with the Court should be by letter filed on ECF. Letters seeking relief, including requests for extensions, adjournments, or bail modification, should be filed on ECF as letter-motions in accordance with Paragraph 6(A) below, not as ordinary letters. See document heading and cited passage; do not apply outside the issuing part or proceeding. [Official rules document](https://www.nysd.uscourts.gov/sites/default/files/practice_documents/AS%20Criminal%20Individual%20Practices%20Feb%20%2726%20Revision.pdf) · Source page 2 · Collected 2026-10-27 #### Communications with chambers Any letter to be filed under seal or containing sensitive or confidential information may be emailed as a text-searchable PDF attachment to the Court with a copy simultaneously delivered to all counsel (unless the submission is being made ex parte). Any such email shall state clearly in the subject line: (1) the caption of the case, including the lead party names and docket number; and (2) a brief description of the contents of the letter. Parties shall not include substantive communications in the body of the email; such communications shall be included only in the letter itself. See document heading and cited passage; do not apply outside the issuing part or proceeding. [Official rules document](https://www.nysd.uscourts.gov/sites/default/files/practice_documents/AS%20Criminal%20Individual%20Practices%20Feb%20%2726%20Revision.pdf) · Source page 2 · Collected 2026-10-27 #### Trial exhibits and witnesses Whether filed electronically or not, letters (together with any related exhibits) may not exceed 10 pages in length. See document heading and cited passage; do not apply outside the issuing part or proceeding. [Official rules document](https://www.nysd.uscourts.gov/sites/default/files/practice_documents/AS%20Criminal%20Individual%20Practices%20Feb%20%2726%20Revision.pdf) · Source page 2 · Collected 2026-10-27 #### Adjournments D. Requests for Adjournments or Extensions of Time. All requests for adjournments or extensions of time must be made in writing and filed on ECF as letter-motions in accordance with Paragraph 6(A), not as ordinary letters. See document heading and cited passage; do not apply outside the issuing part or proceeding. [Official rules document](https://www.nysd.uscourts.gov/sites/default/files/practice_documents/AS%20Criminal%20Individual%20Practices%20Feb%20%2726%20Revision.pdf) · Source page 2 · Collected 2026-10-27 #### Adjournments (If a request contains sensitive or confidential information, it may be submitted by email in lieu of being filed electronically.) The letter-motion must state: (1) the original date(s); (2) the number of previous requests for adjournment or extension; (3) whether these previous requests were granted or denied; (4) the reason for the extension or adjournment; (5) whether the adversary consents and, if not, the reasons given by the adversary for refusing to consent; and (6) the date of the parties’ next scheduled appearance before the Court. If a party seeks an exclusion of time under the Speedy Trial Act, 18 U.S.C. § 3161, the party should submit to the Court by email a proposed order (in Microsoft Word format) along with its request for adjournment or extension. See document heading and cited passage; do not apply outside the issuing part or proceeding. [Official rules document](https://www.nysd.uscourts.gov/sites/default/files/practice_documents/AS%20Criminal%20Individual%20Practices%20Feb%20%2726%20Revision.pdf) · Source page 2 · Collected 2026-10-27 #### Adjournments Absent an emergency, any request for extension or adjournment shall be made at least 48 hours prior to the deadline or scheduled appearance, and any request for adjournment of sentencing shall be made at least 72 hours prior to the scheduled proceeding. Requests for extensions will ordinarily be denied if made after the deadlines for extension or adjournment requests specified in this Paragraph. See document heading and cited passage; do not apply outside the issuing part or proceeding. [Official rules document](https://www.nysd.uscourts.gov/sites/default/files/practice_documents/AS%20Criminal%20Individual%20Practices%20Feb%20%2726%20Revision.pdf) · Source page 2 · Collected 2026-10-27 #### Communications with chambers E. Faxes. Faxes are not permitted except with prior approval of Chambers. See document heading and cited passage; do not apply outside the issuing part or proceeding. [Official rules document](https://www.nysd.uscourts.gov/sites/default/files/practice_documents/AS%20Criminal%20Individual%20Practices%20Feb%20%2726%20Revision.pdf) · Source page 2 · Collected 2026-10-27 #### Conferences and appearances No later than 24 hours prior to a scheduled status conference, the parties shall jointly write to the Court to provide any updates and preview what they wish to discuss at the conference. See document heading and cited passage; do not apply outside the issuing part or proceeding. [Official rules document](https://www.nysd.uscourts.gov/sites/default/files/practice_documents/AS%20Criminal%20Individual%20Practices%20Feb%20%2726%20Revision.pdf) · Source page 3 · Collected 2026-10-27 #### Conferences and appearances A. Benefactor Payments. Whenever defense counsel has received, or is receiving, a benefactor payment that subjects counsel to a conflict of interest, said counsel must inform the Court and request a Curcio hearing at the first conference. See document heading and cited passage; do not apply outside the issuing part or proceeding. [Official rules document](https://www.nysd.uscourts.gov/sites/default/files/practice_documents/AS%20Criminal%20Individual%20Practices%20Feb%20%2726%20Revision.pdf) · Source page 3 · Collected 2026-10-27 #### Motion practice C. Substitution of Counsel. When there is a substitution of defense counsel, counsel of record must file a letter-motion on ECF in accordance with Paragraph 6(A) to request that a conference be scheduled as soon as possible. See document heading and cited passage; do not apply outside the issuing part or proceeding. [Official rules document](https://www.nysd.uscourts.gov/sites/default/files/practice_documents/AS%20Criminal%20Individual%20Practices%20Feb%20%2726%20Revision.pdf) · Source page 3 · Collected 2026-10-27 #### Conferences and appearances At the conference, the Court will address the application by defense counsel to be relieved. Counsel of record (i.e., current counsel), the defendant, replacement counsel, and the Assistant United States Attorney must also attend the conference. See document heading and cited passage; do not apply outside the issuing part or proceeding. [Official rules document](https://www.nysd.uscourts.gov/sites/default/files/practice_documents/AS%20Criminal%20Individual%20Practices%20Feb%20%2726%20Revision.pdf) · Source page 3 · Collected 2026-10-27 #### Adjournments A. Letter-Motions. Letter-motions may be filed via ECF if they comply with the S.D.N.Y. Local Rules and the S.D.N.Y. Electronic Case Filing Rules and Instructions. In particular, in accordance with Paragraph 4(D) above, all requests for adjournments and extensions should be filed as letter-motions. All letter-motions should be text-searchable. See document heading and cited passage; do not apply outside the issuing part or proceeding. [Official rules document](https://www.nysd.uscourts.gov/sites/default/files/practice_documents/AS%20Criminal%20Individual%20Practices%20Feb%20%2726%20Revision.pdf) · Source page 3 · Collected 2026-10-27 #### Motion practice B. Memoranda of Law. Unless prior permission has been granted, memoranda of law in support of and in opposition to motions are limited to 8,750 words, and reply memoranda are limited to 3,500 words. All memoranda of law shall be in twelve-point font or larger, double spaced, and text-searchable. Sur-reply memoranda will not be accepted without prior permission of the Court. All appendices to memoranda of law must be indexed. See document heading and cited passage; do not apply outside the issuing part or proceeding. [Official rules document](https://www.nysd.uscourts.gov/sites/default/files/practice_documents/AS%20Criminal%20Individual%20Practices%20Feb%20%2726%20Revision.pdf) · Source page 3 · Collected 2026-10-27 #### Motion practice C. Discovery Motions. In making discovery motions, counsel must comply with See document heading and cited passage; do not apply outside the issuing part or proceeding. [Official rules document](https://www.nysd.uscourts.gov/sites/default/files/practice_documents/AS%20Criminal%20Individual%20Practices%20Feb%20%2726%20Revision.pdf) · Source page 3 · Collected 2026-10-27 #### Motion practice Southern District Local Criminal Rule 16.1. Any discovery motion must contain the Rule 16.1 affidavit. See document heading and cited passage; do not apply outside the issuing part or proceeding. [Official rules document](https://www.nysd.uscourts.gov/sites/default/files/practice_documents/AS%20Criminal%20Individual%20Practices%20Feb%20%2726%20Revision.pdf) · Source page 4 · Collected 2026-10-27 #### Motion practice Any written request for a bail modification by a defendant shall be filed on ECF as a letter-motion (not an ordinary letter) and shall indicate whether the Government and the Pre-Trial Services Officer consent to the request. See document heading and cited passage; do not apply outside the issuing part or proceeding. [Official rules document](https://www.nysd.uscourts.gov/sites/default/files/practice_documents/AS%20Criminal%20Individual%20Practices%20Feb%20%2726%20Revision.pdf) · Source page 4 · Collected 2026-10-27 #### Communications with chambers A. Plea Agreements and Pimentel Letters. When a defendant is pleading guilty pursuant to a plea agreement or a cooperation agreement, a copy of the agreement, signed or unsigned, ordinarily must be received by Chambers at least two business days before the scheduled plea. Where the Government is providing a Pimentel letter, a copy of the Pimentel letter must be received by Chambers at least two business days before the scheduled plea. These documents should be emailed to the Court. See document heading and cited passage; do not apply outside the issuing part or proceeding. [Official rules document](https://www.nysd.uscourts.gov/sites/default/files/practice_documents/AS%20Criminal%20Individual%20Practices%20Feb%20%2726%20Revision.pdf) · Source page 4 · Collected 2026-10-27 #### Motion practice A. Trial Dates. Judge Subramanian’s general practice will be to set a trial date at the second pretrial conference (after the filing of any defense motions). In advance of that conference, counsel should confer with respect to when they would want to have the trial and should advise the Courtroom Deputy. See document heading and cited passage; do not apply outside the issuing part or proceeding. [Official rules document](https://www.nysd.uscourts.gov/sites/default/files/practice_documents/AS%20Criminal%20Individual%20Practices%20Feb%20%2726%20Revision.pdf) · Source page 4 · Collected 2026-10-27 #### Filing and working copies C. Proposed Voir Dire, Jury Instructions, and Verdict Forms. The parties should include in their proposed voir dire a brief description of the case and a list of names and places likely to be mentioned at trial, both to be read to prospective jurors during jury selection. At the time of filing, each party should See document heading and cited passage; do not apply outside the issuing part or proceeding. [Official rules document](https://www.nysd.uscourts.gov/sites/default/files/practice_documents/AS%20Criminal%20Individual%20Practices%20Feb%20%2726%20Revision.pdf) · Source page 4 · Collected 2026-10-27 #### Communications with chambers D. Exhibits and 3500 Material. Before trial, each party must provide the Court with one copy of all documentary exhibits and Section 3500 material. If feasible, the parties should submit copies of each documentary exhibit and Section 3500 material in electronic form (with each filename corresponding to the relevant exhibit number — e.g., “GX-1,” “DX-1,” etc.). If submission of electronic copies in this manner would be an undue burden on a party, the party may seek leave of Court (by letter-motion filed on ECF) to submit materials on a CD or DVD (not a flash drive) or in hard copy. Where submitted in hard copy, exhibits and Section 3500 material should be pre-marked and assembled sequentially in a loose-leaf binder or binders (not to exceed 2-1/2 inches in thickness), or in separate manila folders labeled with the exhibit numbers and placed in redweld folders labeled with the case name and docket number. See document heading and cited passage; do not apply outside the issuing part or proceeding. [Official rules document](https://www.nysd.uscourts.gov/sites/default/files/practice_documents/AS%20Criminal%20Individual%20Practices%20Feb%20%2726%20Revision.pdf) · Source page 5 · Collected 2026-10-27 #### Trial exhibits and witnesses E. Exhibit Lists. Before trial, each party shall email to the Court a Microsoft Word document listing all exhibits sought to be admitted. The list shall contain four columns labeled as follows: (1) “Exhibit Number”; (2) “Description” (of the exhibit); (3) “Date Identified”; and (4) “Date Admitted.” The submitting party shall complete the first two columns, but leave the third and fourth columns blank, to be filled in by the Court during trial. See document heading and cited passage; do not apply outside the issuing part or proceeding. [Official rules document](https://www.nysd.uscourts.gov/sites/default/files/practice_documents/AS%20Criminal%20Individual%20Practices%20Feb%20%2726%20Revision.pdf) · Source page 5 · Collected 2026-10-27 #### Trial exhibits and witnesses F. Other Trial Rules and Procedures. In addition to the foregoing, counsel shall familiarize themselves with, and abide by, Judge Subramanian’s Individual Practices for Trials, available at https://nysd.uscourts.gov/hon-arun- subramanian. See document heading and cited passage; do not apply outside the issuing part or proceeding. [Official rules document](https://www.nysd.uscourts.gov/sites/default/files/practice_documents/AS%20Criminal%20Individual%20Practices%20Feb%20%2726%20Revision.pdf) · Source page 5 · Collected 2026-10-27 #### Adjournments A. Sentencing Adjournments. Any request for an adjournment of a sentencing should be made as early as possible, and no later than 72 hours before the sentencing proceeding, in accordance with Paragraph 4(D) above. See document heading and cited passage; do not apply outside the issuing part or proceeding. [Official rules document](https://www.nysd.uscourts.gov/sites/default/files/practice_documents/AS%20Criminal%20Individual%20Practices%20Feb%20%2726%20Revision.pdf) · Source page 5 · Collected 2026-10-27 #### Filing and working copies B. Sentencing Submissions. Unless prior permission has been granted, sentencing memoranda are limited to 25 pages. Unless otherwise ordered by the Court, a defendant’s sentencing submission shall be filed and served two weeks in advance of the date set for sentencing. The Government’s sentencing submission shall be filed and served one week in advance of the date set for sentencing. If a party does not intend to file a substantive sentencing submission, the party shall file and serve a letter to that effect. See document heading and cited passage; do not apply outside the issuing part or proceeding. [Official rules document](https://www.nysd.uscourts.gov/sites/default/files/practice_documents/AS%20Criminal%20Individual%20Practices%20Feb%20%2726%20Revision.pdf) · Source page 5 · Collected 2026-10-27 #### Filing and working copies C. ECF Filing. Except for submissions to be filed under seal or in redacted form, every document in a sentencing submission, including letters, must be filed on ECF. Letters should be grouped and filed together as attachments to a single document marked SENTENCING SUBMISSION with the caption and docket number clearly indicated. The defendant is responsible for filing all letters See document heading and cited passage; do not apply outside the issuing part or proceeding. [Official rules document](https://www.nysd.uscourts.gov/sites/default/files/practice_documents/AS%20Criminal%20Individual%20Practices%20Feb%20%2726%20Revision.pdf) · Source page 5 · Collected 2026-10-27 #### Filing and working copies A. Redactions Not Requiring Court Approval. The parties are referred to the E- Government Act of 2002 and the S.D.N.Y. ECF Privacy Policy (“Privacy Policy”). There are two categories of information that may be redacted from public court filings without prior permission from the Court: “sensitive information” and information requiring “caution.” Parties should not include in their public filings, unless necessary, the five categories of “sensitive information” (i.e., social security numbers [use the last four digits only], names of minor children [use the initials only], dates of birth [use the year only], financial account numbers [use the last four digits only], and home addresses [use only the City and State]). Parties may also, without prior Court approval, redact from their public filings the six categories of information requiring caution described in the Privacy Policy (i.e., any personal identifying number, medical records [including information regarding treatment and diagnosis], employment history, individual financial information, proprietary or trade secret information, and information regarding an individual’s cooperation with the government). See document heading and cited passage; do not apply outside the issuing part or proceeding. [Official rules document](https://www.nysd.uscourts.gov/sites/default/files/practice_documents/AS%20Criminal%20Individual%20Practices%20Feb%20%2726%20Revision.pdf) · Source page 6 · Collected 2026-10-27 #### Filing and working copies B. Redactions and Sealed Filings Requiring Court Approval. Except for redactions permitted by the previous Paragraph, all redactions or sealing of public court filings require Court approval. To be approved, any redaction or sealing of a court filing must be narrowly tailored to serve whatever purpose justifies the redaction or sealing and must be otherwise consistent with the presumption in favor of public access to judicial documents. In general, parties’ consent or the fact that information is subject to a confidentiality agreement between litigants is not, by itself, a valid basis to overcome the presumption in favor of public access to judicial documents. See document heading and cited passage; do not apply outside the issuing part or proceeding. [Official rules document](https://www.nysd.uscourts.gov/sites/default/files/practice_documents/AS%20Criminal%20Individual%20Practices%20Feb%20%2726%20Revision.pdf) · Source page 6 · Collected 2026-10-27 #### Filing and working copies i. ECF Filing of the Redacted Document(s). The party should file the redacted version of the document on ECF. See document heading and cited passage; do not apply outside the issuing part or proceeding. [Official rules document](https://www.nysd.uscourts.gov/sites/default/files/practice_documents/AS%20Criminal%20Individual%20Practices%20Feb%20%2726%20Revision.pdf) · Source page 6 · Collected 2026-10-27 #### Motion practice ii. Filing or Emailing of a Letter-Motion Seeking Leave to File with Redactions. If the party is seeking leave of the Court to redact the document (i.e., if the redactions are not among the categories of redactions that can be made without Court approval), the party should simultaneously file on ECF a letter-motion seeking leave to file the document with those redactions. The letter-motion must explain the purpose of the redactions, and why the redactions are consistent with the standards discussed in Paragraph 10(B) above. (The party should endeavor to draft the letter-motion in a form that can be filed publicly See document heading and cited passage; do not apply outside the issuing part or proceeding. [Official rules document](https://www.nysd.uscourts.gov/sites/default/files/practice_documents/AS%20Criminal%20Individual%20Practices%20Feb%20%2726%20Revision.pdf) · Source page 6 · Collected 2026-10-27 #### Motion practice on ECF. If, however, the party believes that the letter-motion itself should be sealed or redacted, the party should include an unredacted copy of the letter-motion as an attachment to the email described in Paragraph 11(C)(iii) below, and—if possible—file a redacted version of the letter-motion on ECF.) See document heading and cited passage; do not apply outside the issuing part or proceeding. [Official rules document](https://www.nysd.uscourts.gov/sites/default/files/practice_documents/AS%20Criminal%20Individual%20Practices%20Feb%20%2726%20Revision.pdf) · Source page 7 · Collected 2026-10-27 #### Motion practice (3) an unredacted copy of the letter-motion seeking leave to file should the party also be seeking leave to file that letter-motion with redactions or under seal. See document heading and cited passage; do not apply outside the issuing part or proceeding. [Official rules document](https://www.nysd.uscourts.gov/sites/default/files/practice_documents/AS%20Criminal%20Individual%20Practices%20Feb%20%2726%20Revision.pdf) · Source page 7 · Collected 2026-10-27 #### Trial exhibits and witnesses i. Sealing Exhibits. Any party seeking leave to file an unsealed or redacted document with a fully sealed exhibit attached thereto should file the main document (in accordance with the procedures above, if the party seeks to do so with redactions) on ECF, accompanied by a single page marked “SEALED” in place of any exhibit that the party seeks leave to file under seal, regardless of the actual length of such exhibit. See document heading and cited passage; do not apply outside the issuing part or proceeding. [Official rules document](https://www.nysd.uscourts.gov/sites/default/files/practice_documents/AS%20Criminal%20Individual%20Practices%20Feb%20%2726%20Revision.pdf) · Source page 7 · Collected 2026-10-27 #### Motion practice The party should simultaneously file a letter-motion seeking leave to file in that manner according to the procedure described in Paragraphs 11(C)(ii)–(iii) above. See document heading and cited passage; do not apply outside the issuing part or proceeding. [Official rules document](https://www.nysd.uscourts.gov/sites/default/files/practice_documents/AS%20Criminal%20Individual%20Practices%20Feb%20%2726%20Revision.pdf) · Source page 7 · Collected 2026-10-27 #### Communications with chambers ii. Sealing Entire Documents. Any party seeking leave to file under seal an entire submission (with or without exhibits) should not file anything on ECF in the first instance. Instead, the party should email an unredacted copy of the submission to Chambers and should include as an attachment to the email a letter-motion seeking leave to file the document under seal. The letter-motion must explain why sealing is justified considering the standards discussed in Paragraph 11(B) above. See document heading and cited passage; do not apply outside the issuing part or proceeding. [Official rules document](https://www.nysd.uscourts.gov/sites/default/files/practice_documents/AS%20Criminal%20Individual%20Practices%20Feb%20%2726%20Revision.pdf) · Source page 7 · Collected 2026-10-27 #### Motion practice If the party believes that the letter-motion itself should be sealed or redacted, the letter-motion should so state and should provide the justification therefor. The Court will include instructions for filing sealed or redacted versions of the document and accompanying letter- motion, if necessary, in any order disposing of the motion to seal. See document heading and cited passage; do not apply outside the issuing part or proceeding. [Official rules document](https://www.nysd.uscourts.gov/sites/default/files/practice_documents/AS%20Criminal%20Individual%20Practices%20Feb%20%2726%20Revision.pdf) · Source page 7 · Collected 2026-10-27 #### Communications with chambers A. Use of Electronic Devices. Electronic devices (including mobile telephones, personal electronic devices, computers, and printers) may not be used in Judge See document heading and cited passage; do not apply outside the issuing part or proceeding. [Official rules document](https://www.nysd.uscourts.gov/sites/default/files/practice_documents/AS%20Criminal%20Individual%20Practices%20Feb%20%2726%20Revision.pdf) · Source page 7 · Collected 2026-10-27 #### Communications with chambers Subramanian’s Courtroom without his permission. More broadly, the use of any such devices within the Courthouse and its environs is governed by the Court’s Standing Order M10-468. If required by the Standing Order, counsel seeking to bring a device into the Courthouse shall submit an Electronic Device and Wi-Fi Access Request Form, available on the Court’s website, to the Court by email as early as possible — and certainly no later than three business days before the start of the trial or hearing. Requests submitted later than three business days prior to the relevant trial or hearing may be denied on that basis alone. If permitted by the Standing Order, mobile telephones are permitted inside the Courtroom, but they MUST be always turned off. Non-compliance with this rule may result in forfeiture of the device for the remainder of the proceedings. See document heading and cited passage; do not apply outside the issuing part or proceeding. [Official rules document](https://www.nysd.uscourts.gov/sites/default/files/practice_documents/AS%20Criminal%20Individual%20Practices%20Feb%20%2726%20Revision.pdf) · Source page 8 · Collected 2026-10-27 #### Communications with chambers Parties must act with the highest degree of professionalism and courtesy in their dealings with other parties, the Court and Court staff, and anyone else involved in the litigation. Abusive conduct of any kind will not be tolerated and should promptly be brought to the Court’s attention. For the avoidance of doubt, this provision applies to discovery communications and conduct in depositions. See document heading and cited passage; do not apply outside the issuing part or proceeding. [Official rules document](https://www.nysd.uscourts.gov/sites/default/files/practice_documents/AS%20Subramanian%20Civil%20Individual%20Practices.pdf) · Source page 1 · Collected 2026-10-27 #### Discovery A. Designation of Lead Trial Counsel. At the outset of each case, or upon reassignment of a matter to this Court, each party must identify to the Court one individual who shall serve as Lead Trial Counsel for that party. This designation must be provided to the Court in the party’s first submission (including in reassigned cases). The designation of Lead Trial Counsel cannot be changed absent prior approval by the Court. As specified below, Lead Trial Counsel is required to personally attend all conferences before the Court and to be personally involved in discovery disputes before they are brought to the Court. See document heading and cited passage; do not apply outside the issuing part or proceeding. [Official rules document](https://www.nysd.uscourts.gov/sites/default/files/practice_documents/AS%20Subramanian%20Civil%20Individual%20Practices.pdf) · Source page 1 · Collected 2026-10-27 #### Motion practice B. Amended or Corrected Filings. Any amended or corrected filing (including but not limited to amended pleadings) shall be filed with a redline showing all differences between the original and revised filing. Any motion to amend a pleading shall similarly be filed with a redline showing all differences between the operative pleading and the proposed amended pleading. See document heading and cited passage; do not apply outside the issuing part or proceeding. [Official rules document](https://www.nysd.uscourts.gov/sites/default/files/practice_documents/AS%20Subramanian%20Civil%20Individual%20Practices.pdf) · Source page 1 · Collected 2026-10-27 #### Filing and working copies C. No Courtesy Copies. Unless the Court orders otherwise, parties should not submit courtesy copies of any submissions. See document heading and cited passage; do not apply outside the issuing part or proceeding. [Official rules document](https://www.nysd.uscourts.gov/sites/default/files/practice_documents/AS%20Subramanian%20Civil%20Individual%20Practices.pdf) · Source page 1 · Collected 2026-10-27 #### Communications with chambers A. Letters. Except as otherwise provided below, communications with the Court should be by letter, filed electronically on ECF. Letters seeking relief should be filed on ECF as letter-motions in accordance with Paragraph 8(A) below, not as ordinary letters. Unless otherwise ordered by the Court, letters may not exceed three pages in length. See document heading and cited passage; do not apply outside the issuing part or proceeding. [Official rules document](https://www.nysd.uscourts.gov/sites/default/files/practice_documents/AS%20Subramanian%20Civil%20Individual%20Practices.pdf) · Source page 2 · Collected 2026-10-27 #### Communications with chambers B. Telephone Calls. Telephone calls to Chambers are permitted solely in emergency situations where a letter or letter-motion is not feasible, or as specifically authorized in Paragraph 6(B) (Conduct in Depositions). In such situations, counsel for all parties must join the call. Technical questions pertaining to ECF filings should be directed to the ECF Help Desk at helpdesk@nysd.uscourts.gov or (212) 805-0800. See document heading and cited passage; do not apply outside the issuing part or proceeding. [Official rules document](https://www.nysd.uscourts.gov/sites/default/files/practice_documents/AS%20Subramanian%20Civil%20Individual%20Practices.pdf) · Source page 2 · Collected 2026-10-27 #### Communications with chambers C. Faxes. Faxes are not permitted except with prior approval of Chambers. See document heading and cited passage; do not apply outside the issuing part or proceeding. [Official rules document](https://www.nysd.uscourts.gov/sites/default/files/practice_documents/AS%20Subramanian%20Civil%20Individual%20Practices.pdf) · Source page 2 · Collected 2026-10-27 #### Communications with chambers D. Hand Deliveries. Hand-delivered mail should be left with the Court Security Officers at the Worth Street entrance of the Daniel Patrick Moynihan United States District Courthouse at 500 Pearl Street, New York, NY 10007, and may not be brought directly to Chambers. If the hand-delivered letter is urgent and requires the Court’s immediate attention, ask the Court Security Officers to notify Chambers that an urgent package has arrived that needs to be retrieved by Chambers staff immediately. See document heading and cited passage; do not apply outside the issuing part or proceeding. [Official rules document](https://www.nysd.uscourts.gov/sites/default/files/practice_documents/AS%20Subramanian%20Civil%20Individual%20Practices.pdf) · Source page 2 · Collected 2026-10-27 #### Adjournments E. Requests for Adjournments or Extensions of Time. All requests for adjournments or extensions of time must be made in writing and filed on ECF as letter-motions, not as ordinary letters, proposed stipulations, or proposed orders. See document heading and cited passage; do not apply outside the issuing part or proceeding. [Official rules document](https://www.nysd.uscourts.gov/sites/default/files/practice_documents/AS%20Subramanian%20Civil%20Individual%20Practices.pdf) · Source page 2 · Collected 2026-10-27 #### Adjournments The letter-motion must state: (1) the original date(s); (2) the number of previous requests for adjournment or extension; (3) whether these previous requests were granted or denied; (4) the reasons for the requested extension; (5) whether the adversary consents and, if not, the reasons given by the adversary for refusing to consent; and (6) the date of the parties’ next scheduled appearance before the Court as well as any other existing deadlines. If the extension will affect any other deadlines in the case, the party seeking the extension should propose amendments to those deadlines as well. Requests for extensions of deadlines regarding a matter that has been referred to a Magistrate Judge shall be addressed to that assigned Magistrate Judge. See document heading and cited passage; do not apply outside the issuing part or proceeding. [Official rules document](https://www.nysd.uscourts.gov/sites/default/files/practice_documents/AS%20Subramanian%20Civil%20Individual%20Practices.pdf) · Source page 2 · Collected 2026-10-27 #### Adjournments Any request for extension or adjournment shall be made at least two business days prior to the deadline or scheduled appearance. Requests for extensions will ordinarily be denied if made after this deadline. See document heading and cited passage; do not apply outside the issuing part or proceeding. [Official rules document](https://www.nysd.uscourts.gov/sites/default/files/practice_documents/AS%20Subramanian%20Civil%20Individual%20Practices.pdf) · Source page 2 · Collected 2026-10-27 #### Communications with chambers F. Related and Consolidated Cases. After an action has been accepted as related to a prior filing, all future court papers and correspondence must contain the docket number of the new filing as well as the docket number of the case to which it is related (e.g., 12-CV-1234 [rel. 11-CV-4321]). After two or more actions have been consolidated for all purposes under a single docket number pursuant to Rule See document heading and cited passage; do not apply outside the issuing part or proceeding. [Official rules document](https://www.nysd.uscourts.gov/sites/default/files/practice_documents/AS%20Subramanian%20Civil%20Individual%20Practices.pdf) · Source page 2 · Collected 2026-10-27 #### Communications with chambers 42(a)(2) of the Federal Rules of Civil Procedure, all future court papers and correspondence should be filed only in the docket under which the cases have been consolidated and should reference only that docket number. See document heading and cited passage; do not apply outside the issuing part or proceeding. [Official rules document](https://www.nysd.uscourts.gov/sites/default/files/practice_documents/AS%20Subramanian%20Civil%20Individual%20Practices.pdf) · Source page 3 · Collected 2026-10-27 #### Motion practice G. ECF. In accordance with the Electronic Case Filing Rules and Instructions, counsel are required to register promptly as ECF filers and to enter an appearance in the case. Counsel are responsible for updating their contact information on ECF, should it change, and they are responsible for checking the docket sheet regularly, regardless of whether they receive an ECF notification of case activity. For assistance with updating contact information, please contact the ECF Help Desk at helpdesk@nysd.uscourts.gov or (212) 805-0800; do not file a letter-motion advising the Court of the change. See document heading and cited passage; do not apply outside the issuing part or proceeding. [Official rules document](https://www.nysd.uscourts.gov/sites/default/files/practice_documents/AS%20Subramanian%20Civil%20Individual%20Practices.pdf) · Source page 3 · Collected 2026-10-27 #### Conferences and appearances A. In-Person Conferences. Unless otherwise ordered by the Court, all in-person conferences will be held in Courtroom 15A, 500 Pearl Street, New York, NY 10007. See document heading and cited passage; do not apply outside the issuing part or proceeding. [Official rules document](https://www.nysd.uscourts.gov/sites/default/files/practice_documents/AS%20Subramanian%20Civil%20Individual%20Practices.pdf) · Source page 3 · Collected 2026-10-27 #### Conferences and appearances B. Teleconferences. The following procedures shall apply to all teleconferences with See document heading and cited passage; do not apply outside the issuing part or proceeding. [Official rules document](https://www.nysd.uscourts.gov/sites/default/files/practice_documents/AS%20Subramanian%20Civil%20Individual%20Practices.pdf) · Source page 3 · Collected 2026-10-27 #### Communications with chambers i. At least 24 hours before a scheduled teleconference, the parties must jointly email to the Court a list of counsel who may speak during the teleconference. No more than one individual should be designated to speak on behalf of each party. The email should also provide the telephone numbers from which counsel expect to join the call. See document heading and cited passage; do not apply outside the issuing part or proceeding. [Official rules document](https://www.nysd.uscourts.gov/sites/default/files/practice_documents/AS%20Subramanian%20Civil%20Individual%20Practices.pdf) · Source page 3 · Collected 2026-10-27 #### Conferences and appearances iii. To facilitate orderly teleconferences and the creation of an accurate transcript where a teleconference is held on the record, counsel are required to identify themselves every time they speak. Counsel should spell any proper names for the court reporter and take special care not to interrupt or speak over one another. See document heading and cited passage; do not apply outside the issuing part or proceeding. [Official rules document](https://www.nysd.uscourts.gov/sites/default/files/practice_documents/AS%20Subramanian%20Civil%20Individual%20Practices.pdf) · Source page 3 · Collected 2026-10-27 #### Conferences and appearances iv. Broadcasting or recording of any court conference is prohibited by law. See document heading and cited passage; do not apply outside the issuing part or proceeding. [Official rules document](https://www.nysd.uscourts.gov/sites/default/files/practice_documents/AS%20Subramanian%20Civil%20Individual%20Practices.pdf) · Source page 3 · Collected 2026-10-27 #### Discovery C. Attendance by Lead Trial Counsel and Principal Decision-Makers. Lead Trial Counsel must appear at all conferences with the Court, must have authority to bind the party they represent consistent with the proceeding (for example, by agreeing to a discovery or briefing schedule), and should be prepared to address any matters likely to arise at the proceeding. Any attorney appearing before the Court must enter a notice of appearance on ECF. Principal decision-makers must attend the final pretrial conference and the trial. See document heading and cited passage; do not apply outside the issuing part or proceeding. [Official rules document](https://www.nysd.uscourts.gov/sites/default/files/practice_documents/AS%20Subramanian%20Civil%20Individual%20Practices.pdf) · Source page 3 · Collected 2026-10-27 #### Motion practice D. Initial Case Management Conference. In most cases, the Court will schedule a Federal Rule of Civil Procedure 16(c) conference to occur no more than three months after the filing of the complaint or notice of removal. Plaintiff’s counsel (or, in a matter removed from state court, defense counsel) is directed to promptly notify all counsel of the Notice of Initial Pretrial Conference. In most cases, the Notice will direct the parties to submit on ECF a joint letter as well as a proposed Civil Case Management Plan and Scheduling Order attached as an exhibit to the joint letter, no later than Thursday of the week prior to the conference date. This must be filed on ECF as a letter motion- not a standard letter. The parties shall use the form Proposed Case Management Plan and Scheduling Order available at the Court’s website. See document heading and cited passage; do not apply outside the issuing part or proceeding. [Official rules document](https://www.nysd.uscourts.gov/sites/default/files/practice_documents/AS%20Subramanian%20Civil%20Individual%20Practices.pdf) · Source page 4 · Collected 2026-10-27 #### Discovery A. Parties must follow Local Civil Rule 37.2 with the following modifications. Special rules regarding disputes raised during depositions are addressed in Paragraph 6. See document heading and cited passage; do not apply outside the issuing part or proceeding. [Official rules document](https://www.nysd.uscourts.gov/sites/default/files/practice_documents/AS%20Subramanian%20Civil%20Individual%20Practices.pdf) · Source page 4 · Collected 2026-10-27 #### Communications with chambers B. Any party wishing to raise a discovery dispute with the Court must first confer in good faith with the opposing party—in person, by videoconference, or by telephone—to resolve the dispute. This process must include at least one conference among Lead Trial Counsel for the parties involved in the dispute. See document heading and cited passage; do not apply outside the issuing part or proceeding. [Official rules document](https://www.nysd.uscourts.gov/sites/default/files/practice_documents/AS%20Subramanian%20Civil%20Individual%20Practices.pdf) · Source page 4 · Collected 2026-10-27 #### Discovery C. Where a party raises a discovery dispute with the opposing party, the opposing party must make itself available to confer in good faith to resolve the dispute within two business days of a request for a conference. If a party requests a Lead Trial Counsel conference, Lead Trial Counsel for the opposing party must make themselves available within two business days. See document heading and cited passage; do not apply outside the issuing part or proceeding. [Official rules document](https://www.nysd.uscourts.gov/sites/default/files/practice_documents/AS%20Subramanian%20Civil%20Individual%20Practices.pdf) · Source page 4 · Collected 2026-10-27 #### Motion practice D. If the meet-and-confer process does not resolve the dispute within 10 business days of the dispute first being raised (or sooner, if an impasse has been reached), the party seeking discovery may file on ECF a letter-motion, no longer than three pages, explaining the nature of the dispute and, if applicable, why the party is entitled to relief and requesting an informal conference. Any letter-motion seeking relief must state: (1) the dates and times of each conference conducted pursuant to Paragraph 5(B)–(C); (2) the duration of these conferences; (3) the names of the attorneys who participated; and (4) that the moving party informed the adversary See document heading and cited passage; do not apply outside the issuing part or proceeding. [Official rules document](https://www.nysd.uscourts.gov/sites/default/files/practice_documents/AS%20Subramanian%20Civil%20Individual%20Practices.pdf) · Source page 4 · Collected 2026-10-27 #### Motion practice during the last conference that the moving party believed the parties to be at an impasse and that the moving party would be requesting a conference with the Court. The letter-motion must specifically state that the required Lead Trial Counsel conference occurred. See document heading and cited passage; do not apply outside the issuing part or proceeding. [Official rules document](https://www.nysd.uscourts.gov/sites/default/files/practice_documents/AS%20Subramanian%20Civil%20Individual%20Practices.pdf) · Source page 5 · Collected 2026-10-27 #### Motion practice E. Any opposition to a letter-motion seeking relief shall be filed as a letter, not to exceed three pages, within two business days. Counsel should be prepared to discuss with the Court the matters raised by such letters, as the Court will seek to resolve discovery disputes quickly, by order (based on the letters alone) or in a conference. See document heading and cited passage; do not apply outside the issuing part or proceeding. [Official rules document](https://www.nysd.uscourts.gov/sites/default/files/practice_documents/AS%20Subramanian%20Civil%20Individual%20Practices.pdf) · Source page 5 · Collected 2026-10-27 #### Discovery F. Counsel should seek relief in accordance with these procedures in a timely fashion. If a party waits until near the close of discovery to raise an issue that could have been raised earlier, the party is unlikely to be granted the relief that it seeks or more time for discovery. See document heading and cited passage; do not apply outside the issuing part or proceeding. [Official rules document](https://www.nysd.uscourts.gov/sites/default/files/practice_documents/AS%20Subramanian%20Civil%20Individual%20Practices.pdf) · Source page 5 · Collected 2026-10-27 #### Communications with chambers G. Privilege Logs and Privilege Log Disputes. Privilege logs should be sufficiently detailed to enable the receiving party to evaluate a claim of privilege, including identification of attorneys involved in the relevant documents or communications. See document heading and cited passage; do not apply outside the issuing part or proceeding. [Official rules document](https://www.nysd.uscourts.gov/sites/default/files/practice_documents/AS%20Subramanian%20Civil%20Individual%20Practices.pdf) · Source page 5 · Collected 2026-10-27 #### Discovery Privilege logs must be promptly produced and updated on a rolling basis as documents are produced. Each log and update must include a certification from counsel that counsel has reviewed the withheld or redacted documents, and that there is a good-faith basis to assert privilege over those documents. Disputes related to privilege logs are subject to the rules governing discovery disputes specified in Paragraph 5. The Court may on its own initiative order in camera production to the Court of unredacted documents from the producing party’s log where a dispute is raised. See document heading and cited passage; do not apply outside the issuing part or proceeding. [Official rules document](https://www.nysd.uscourts.gov/sites/default/files/practice_documents/AS%20Subramanian%20Civil%20Individual%20Practices.pdf) · Source page 5 · Collected 2026-10-27 #### Discovery A. All objections during a deposition must be “stated concisely in a nonargumentative and nonsuggestive manner.” Fed. R. Civ. P. 30(c)(2). Witness coaching or disruptive commentary of any kind during questioning is prohibited. Objections to the form of a question (e.g., argumentative, asked and answered, calls for a narrative response, calls for a legal conclusion, compound, vague, ambiguous, calls for speculation) should be limited to “objection form.” If the examining attorney is unclear as to the nature of the form objection, they may seek further clarification from the objecting attorney. See document heading and cited passage; do not apply outside the issuing part or proceeding. [Official rules document](https://www.nysd.uscourts.gov/sites/default/files/practice_documents/AS%20Subramanian%20Civil%20Individual%20Practices.pdf) · Source page 5 · Collected 2026-10-27 #### Communications with chambers B. If a dispute arises during a deposition, and the letter-motion procedures in Paragraph 5 are not feasible to address it, the parties may email Chambers to raise the dispute with the Court during the deposition. If a party wishes to engage the Court in this manner, all parties in attendance at the deposition must make themselves available and email the Court jointly. See document heading and cited passage; do not apply outside the issuing part or proceeding. [Official rules document](https://www.nysd.uscourts.gov/sites/default/files/practice_documents/AS%20Subramanian%20Civil%20Individual%20Practices.pdf) · Source page 5 · Collected 2026-10-27 #### Motion practice A. The Court encourages the participation of less-experienced attorneys in all proceedings—including pretrial conferences, hearings on discovery disputes, oral arguments, and examinations of witnesses at trial—particularly where that attorney played a substantial role in drafting the underlying filing or in preparing the relevant witness. The Court may be inclined to grant a request for oral argument, or a request for more than one attorney to speak on behalf of a party in a conference, where doing so would afford the opportunity for a junior attorney to gain experience. See document heading and cited passage; do not apply outside the issuing part or proceeding. [Official rules document](https://www.nysd.uscourts.gov/sites/default/files/practice_documents/AS%20Subramanian%20Civil%20Individual%20Practices.pdf) · Source page 6 · Collected 2026-10-27 #### Motion practice A. Letter-Motions. When permitted by the S.D.N.Y. Local Rules and the S.D.N.Y. Electronic Case Filing Rules and Instructions, letters seeking relief should be filed on ECF as letter-motions, not as ordinary letters. See document heading and cited passage; do not apply outside the issuing part or proceeding. [Official rules document](https://www.nysd.uscourts.gov/sites/default/files/practice_documents/AS%20Subramanian%20Civil%20Individual%20Practices.pdf) · Source page 6 · Collected 2026-10-27 #### Motion practice B. Pre-Motion Conferences in Civil Cases. Pre-motion conferences are not required, except for disputes concerning discovery, which are governed by Paragraph 5 above. See document heading and cited passage; do not apply outside the issuing part or proceeding. [Official rules document](https://www.nysd.uscourts.gov/sites/default/files/practice_documents/AS%20Subramanian%20Civil%20Individual%20Practices.pdf) · Source page 6 · Collected 2026-10-27 #### Filing and working copies C. Memoranda of Law. Please reference Local Civil Rule 7.1(c) for all requirements. Sur-reply memoranda will not be accepted without prior permission of the Court. All appendices to memoranda of law must be indexed. The Court will rarely grant requests, even on consent of all parties, to expand these page limits. See document heading and cited passage; do not apply outside the issuing part or proceeding. [Official rules document](https://www.nysd.uscourts.gov/sites/default/files/practice_documents/AS%20Subramanian%20Civil%20Individual%20Practices.pdf) · Source page 6 · Collected 2026-10-27 #### Communications with chambers D. Unpublished Cases. If a party cites to a case not available in an official reporter, it need not provide copies of the case to Chambers if the case is available on Westlaw or Lexis. For cases only available on Westlaw or Lexis, the Westlaw citation should be used whenever possible. See document heading and cited passage; do not apply outside the issuing part or proceeding. [Official rules document](https://www.nysd.uscourts.gov/sites/default/files/practice_documents/AS%20Subramanian%20Civil%20Individual%20Practices.pdf) · Source page 6 · Collected 2026-10-27 #### Motion practice E. Oral Argument on Motions. A party may request oral argument by indicating “ORAL ARGUMENT REQUESTED” on the cover page of its memorandum of law. A party should advise the Court by letter if oral argument would be handled by a less-experienced attorney because, as discussed in Paragraph 7 above, that may make the Court more inclined to hold oral argument. If oral argument is requested, the Court will determine whether argument will be heard and, if so, advise counsel of the argument date. See document heading and cited passage; do not apply outside the issuing part or proceeding. [Official rules document](https://www.nysd.uscourts.gov/sites/default/files/practice_documents/AS%20Subramanian%20Civil%20Individual%20Practices.pdf) · Source page 6 · Collected 2026-10-27 #### Filing and working copies F. Use of ChatGPT and Other Tools. Counsel is responsible for providing the Court with complete and accurate representations of the record, the procedural history of the case, and any cited legal authorities. Use of ChatGPT or other such tools is not prohibited, but counsel must at all times personally confirm for themselves the accuracy of any research conducted by these means. At all times, counsel—and specifically designated Lead Trial Counsel—bears responsibility for any filings made by the party that counsel represents. See document heading and cited passage; do not apply outside the issuing part or proceeding. [Official rules document](https://www.nysd.uscourts.gov/sites/default/files/practice_documents/AS%20Subramanian%20Civil%20Individual%20Practices.pdf) · Source page 6 · Collected 2026-10-27 #### Motion practice i. In any motion to dismiss arguing that a pleading fails to plausibly allege a claim, the supporting papers must clearly indicate the specific claim elements that the moving party believes have not been plausibly pleaded. See document heading and cited passage; do not apply outside the issuing part or proceeding. [Official rules document](https://www.nysd.uscourts.gov/sites/default/files/practice_documents/AS%20Subramanian%20Civil%20Individual%20Practices.pdf) · Source page 7 · Collected 2026-10-27 #### Trial exhibits and witnesses In response, the non-moving party must identify the specific paragraphs in the pleading that the non-moving party believes plausibly allege those specific elements. The moving party must attach a non-argumentative chart as an exhibit to its moving papers identifying the elements not plausibly alleged, and the non-moving party must attach a responsive, non- argumentative exhibit to its responsive papers identifying the paragraphs of the complaint that plausibly allege those elements. See document heading and cited passage; do not apply outside the issuing part or proceeding. [Official rules document](https://www.nysd.uscourts.gov/sites/default/files/practice_documents/AS%20Subramanian%20Civil%20Individual%20Practices.pdf) · Source page 7 · Collected 2026-10-27 #### Motion practice ii. When a motion to dismiss is filed and the non-moving party elects to amend its pleading pursuant to Federal Rule of Civil Procedure 15(a)(1), the non- moving party must, within 10 days of receipt of the motion, notify the Court and its adversary if it intends to file an amended pleading pursuant to Rule 15(a)(1), and the date by which it will do so. This provision does not alter the time for a non-moving party to file a response to the motion to dismiss as specified in the Federal Rules of Civil Procedure or Local Rules. Non- moving parties are on notice that declining to amend their pleadings to timely respond to an argument in the motion to dismiss may constitute a waiver of their right to later use the amendment process to cure defects that have been made apparent by the briefing. See document heading and cited passage; do not apply outside the issuing part or proceeding. [Official rules document](https://www.nysd.uscourts.gov/sites/default/files/practice_documents/AS%20Subramanian%20Civil%20Individual%20Practices.pdf) · Source page 7 · Collected 2026-10-27 #### Motion practice H. Motions for Leave to Amend a Pleading. When moving to amend any pleading, the moving party shall—in accordance with Paragraph 2(B) above—file with the motion a redline showing all differences between the operative pleading and the proposed amended pleading. See document heading and cited passage; do not apply outside the issuing part or proceeding. [Official rules document](https://www.nysd.uscourts.gov/sites/default/files/practice_documents/AS%20Subramanian%20Civil%20Individual%20Practices.pdf) · Source page 7 · Collected 2026-10-27 #### Trial exhibits and witnesses i. Absent good cause, the Court will not ordinarily have summary judgment practice in a non-jury case. See document heading and cited passage; do not apply outside the issuing part or proceeding. [Official rules document](https://www.nysd.uscourts.gov/sites/default/files/practice_documents/AS%20Subramanian%20Civil%20Individual%20Practices.pdf) · Source page 7 · Collected 2026-10-27 #### Motion practice ii. Parties may not file more than one motion for summary judgment absent prior Court approval. See document heading and cited passage; do not apply outside the issuing part or proceeding. [Official rules document](https://www.nysd.uscourts.gov/sites/default/files/practice_documents/AS%20Subramanian%20Civil%20Individual%20Practices.pdf) · Source page 7 · Collected 2026-10-27 #### Courtroom conduct and technology iii. Any party moving for summary judgment shall provide all other parties with an electronic copy, in Microsoft Word format, 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. See document heading and cited passage; do not apply outside the issuing part or proceeding. [Official rules document](https://www.nysd.uscourts.gov/sites/default/files/practice_documents/AS%20Subramanian%20Civil%20Individual%20Practices.pdf) · Source page 8 · Collected 2026-10-27 #### Discovery iv. With respect to any deposition that is supplied, the index to the deposition should be included if it is available. See document heading and cited passage; do not apply outside the issuing part or proceeding. [Official rules document](https://www.nysd.uscourts.gov/sites/default/files/practice_documents/AS%20Subramanian%20Civil%20Individual%20Practices.pdf) · Source page 8 · Collected 2026-10-27 #### Discovery v. The parties should provide the Court with a complete electronic, text- searchable copy of any hearing or deposition transcript on which the parties rely, if such a copy is available, unless doing so would be unduly burdensome. See document heading and cited passage; do not apply outside the issuing part or proceeding. [Official rules document](https://www.nysd.uscourts.gov/sites/default/files/practice_documents/AS%20Subramanian%20Civil%20Individual%20Practices.pdf) · Source page 8 · Collected 2026-10-27 #### Motion practice J. Motions to Exclude Testimony of Experts. Unless the Court orders otherwise, motions to exclude testimony of experts, pursuant to Rules 702–705 of the Federal Rules of Evidence and the Daubert v. Merrell Dow Pharmaceuticals, Inc., 509 U.S. See document heading and cited passage; do not apply outside the issuing part or proceeding. [Official rules document](https://www.nysd.uscourts.gov/sites/default/files/practice_documents/AS%20Subramanian%20Civil%20Individual%20Practices.pdf) · Source page 8 · Collected 2026-10-27 #### Motion practice 579 (1993), line of cases, must be made by the deadline for dispositive motions and should not be treated as motions in limine. See document heading and cited passage; do not apply outside the issuing part or proceeding. [Official rules document](https://www.nysd.uscourts.gov/sites/default/files/practice_documents/AS%20Subramanian%20Civil%20Individual%20Practices.pdf) · Source page 8 · Collected 2026-10-27 #### Motion practice L. Default Judgment Motions. If a party fails to respond to a claim, the party asserting the claim should promptly move for entry of default judgment if appropriate. A party seeking a default judgment must proceed by filing a motion for default judgment on ECF pursuant to Federal Rule of Civil Procedure 55(b)(2) and Local Civil Rule 55.2(b). A party seeking a default judgment should not proceed by order to show cause. The motion must be supported by the following See document heading and cited passage; do not apply outside the issuing part or proceeding. [Official rules document](https://www.nysd.uscourts.gov/sites/default/files/practice_documents/AS%20Subramanian%20Civil%20Individual%20Practices.pdf) · Source page 8 · Collected 2026-10-27 #### Communications with chambers iii. if the proposed damages are supported by calculations, native versions of the files with calculations (i.e., versions of the files in their original format, such as in “.xlsx”), which shall be emailed to Chambers; See document heading and cited passage; do not apply outside the issuing part or proceeding. [Official rules document](https://www.nysd.uscourts.gov/sites/default/files/practice_documents/AS%20Subramanian%20Civil%20Individual%20Practices.pdf) · Source page 9 · Collected 2026-10-27 #### Adjournments M. Proposed Stipulations and Orders. In accordance with the S.D.N.Y. Local Rules and the S.D.N.Y. Electronic Case Filing Rules and Instructions, parties should file on ECF all proposed stipulations and orders that they wish the Court to sign, using the appropriate ECF filing event. See SDNY ECF Rules & Instructions §§ 13.17– 19 & App’x A. As noted above, requests for extensions and adjournments must be made by letter-motion, not by proposed stipulation or proposed order. See document heading and cited passage; do not apply outside the issuing part or proceeding. [Official rules document](https://www.nysd.uscourts.gov/sites/default/files/practice_documents/AS%20Subramanian%20Civil%20Individual%20Practices.pdf) · Source page 9 · Collected 2026-10-27 #### Communications with chambers A. Applications for Temporary Restraining Orders. A party should confer with its adversary before making an application for a temporary restraining order unless the party seeking relief is able to satisfy the requirements for obtaining temporary relief without notice to the adverse party set forth in Federal Rule of Civil Procedure 65(b)(1). If the party seeking relief believes that Rule 65(b)(1)’s requirements can be met and a temporary restraining order should issue without notice to the adverse party, the party should file its papers on ECF under seal (or, if ECF is not a viable option, by email to Chambers) and then email Chambers providing notice. If the party is prepared to seek relief on notice to the adverse party, the party seeking relief should simultaneously file its papers on ECF, serve them on all other parties, and then email Chambers. See document heading and cited passage; do not apply outside the issuing part or proceeding. [Official rules document](https://www.nysd.uscourts.gov/sites/default/files/practice_documents/AS%20Subramanian%20Civil%20Individual%20Practices.pdf) · Source page 9 · Collected 2026-10-27 #### Conferences and appearances B. Settlement Agreements. Unless the Court orders otherwise, the Court will not retain jurisdiction to enforce confidential settlement agreements. If the parties wish that the Court retain jurisdiction to enforce a settlement agreement, the parties must place the terms of their agreement on the public record. The parties may either See document heading and cited passage; do not apply outside the issuing part or proceeding. [Official rules document](https://www.nysd.uscourts.gov/sites/default/files/practice_documents/AS%20Subramanian%20Civil%20Individual%20Practices.pdf) · Source page 9 · Collected 2026-10-27 #### Conferences and appearances A. Joint Pretrial Order. Unless otherwise ordered by the Court, at least 14 days prior to the scheduled final pretrial conference, the parties shall both file on ECF, as a “Joint Pretrial Statement,” and submit by email to the Court a proposed joint pretrial See document heading and cited passage; do not apply outside the issuing part or proceeding. [Official rules document](https://www.nysd.uscourts.gov/sites/default/files/practice_documents/AS%20Subramanian%20Civil%20Individual%20Practices.pdf) · Source page 10 · Collected 2026-10-27 #### Trial exhibits and witnesses viii. a statement as to whether all parties have consented to trial by a Magistrate Judge, without identifying which parties do or do not consent; See document heading and cited passage; do not apply outside the issuing part or proceeding. [Official rules document](https://www.nysd.uscourts.gov/sites/default/files/practice_documents/AS%20Subramanian%20Civil%20Individual%20Practices.pdf) · Source page 10 · Collected 2026-10-27 #### Trial exhibits and witnesses ix. any stipulations or agreed statements of fact or law to which all parties consent. In a jury case, the parties should memorialize any such stipulations or agreed statements of fact or law in a standalone document that can be marked and admitted at trial; See document heading and cited passage; do not apply outside the issuing part or proceeding. [Official rules document](https://www.nysd.uscourts.gov/sites/default/files/practice_documents/AS%20Subramanian%20Civil%20Individual%20Practices.pdf) · Source page 10 · Collected 2026-10-27 #### Discovery x. a list of all trial witnesses, indicating whether such witnesses will testify in person or by deposition, whether such witnesses will require an interpreter (and, if so, which party will pay the costs for the interpreter), and a brief summary of the substance of each witness’s testimony. Absent leave of Court, a witness listed by both sides shall testify only once (with the defendant permitted to go beyond the scope of the direct on cross- examination), and counsel should confer with respect to scheduling; See document heading and cited passage; do not apply outside the issuing part or proceeding. [Official rules document](https://www.nysd.uscourts.gov/sites/default/files/practice_documents/AS%20Subramanian%20Civil%20Individual%20Practices.pdf) · Source page 11 · Collected 2026-10-27 #### Discovery xi. a designation by each party of deposition testimony to be offered in its case-in-chief and any counter-designations and objections by any other party. The parties need not designate deposition testimony to be used for impeachment purposes only; See document heading and cited passage; do not apply outside the issuing part or proceeding. [Official rules document](https://www.nysd.uscourts.gov/sites/default/files/practice_documents/AS%20Subramanian%20Civil%20Individual%20Practices.pdf) · Source page 11 · Collected 2026-10-27 #### Trial exhibits and witnesses xii. a list by each party of all exhibits to be offered in its case-in-chief, with a single asterisk indicating exhibits to which no party objects on any ground. If a party objects to an exhibit, the objection should be noted by indicating the Federal Rule of Evidence that is the basis for the objection. If any party believes that the Court should rule on such an objection in advance of trial, that party should include a notation to that effect (e.g., “Advance Ruling Requested”) as well. In general, the Court will rule on relevance and authenticity objections at the time of trial; See document heading and cited passage; do not apply outside the issuing part or proceeding. [Official rules document](https://www.nysd.uscourts.gov/sites/default/files/practice_documents/AS%20Subramanian%20Civil%20Individual%20Practices.pdf) · Source page 11 · Collected 2026-10-27 #### Filing and working copies B. Required Pretrial Filings. Unless otherwise ordered by the Court, each party shall See document heading and cited passage; do not apply outside the issuing part or proceeding. [Official rules document](https://www.nysd.uscourts.gov/sites/default/files/practice_documents/AS%20Subramanian%20Civil%20Individual%20Practices.pdf) · Source page 11 · Collected 2026-10-27 #### Motion practice i. in all cases, motions addressing any evidentiary issues or other matters that should be resolved in limine. Absent leave of the Court, each party must file a single memorandum of law, consistent with Paragraph 8(C) above, in support of all motions in limine filed by that party; See document heading and cited passage; do not apply outside the issuing part or proceeding. [Official rules document](https://www.nysd.uscourts.gov/sites/default/files/practice_documents/AS%20Subramanian%20Civil%20Individual%20Practices.pdf) · Source page 11 · Collected 2026-10-27 #### Filing and working copies iii. in all non-jury cases, proposed findings of fact and conclusions of law. The proposed findings of fact should be detailed and should include citations to the proffered trial testimony and exhibits, as there may be no opportunity for post-trial submissions. At the time of filing, parties should also submit copies of these documents to the Court by email, both in PDF format and as a Microsoft Word document. See document heading and cited passage; do not apply outside the issuing part or proceeding. [Official rules document](https://www.nysd.uscourts.gov/sites/default/files/practice_documents/AS%20Subramanian%20Civil%20Individual%20Practices.pdf) · Source page 11 · Collected 2026-10-27 #### Trial exhibits and witnesses C. Electronic Copies of Exhibits and Exhibit Lists. Unless otherwise ordered by the See document heading and cited passage; do not apply outside the issuing part or proceeding. [Official rules document](https://www.nysd.uscourts.gov/sites/default/files/practice_documents/AS%20Subramanian%20Civil%20Individual%20Practices.pdf) · Source page 12 · Collected 2026-10-27 #### Communications with chambers i. an electronic copy of each exhibit sought to be admitted (with each filename corresponding to the relevant exhibit number—e.g., “PX-1,” “DX-1,” etc.). If submission of electronic copies would be an undue burden on a party, the party may seek leave of Court (by letter-motion filed on ECF) to submit prospective documentary exhibits in hard copy. Each hard copy shall be pre-marked (that is, with an exhibit sticker) and assembled sequentially in a loose-leaf binder (not to exceed 2-1/2 inches in thickness) or in separate manila folders labeled with the exhibit numbers and placed in redweld folders labeled with the case name and docket number; and See document heading and cited passage; do not apply outside the issuing part or proceeding. [Official rules document](https://www.nysd.uscourts.gov/sites/default/files/practice_documents/AS%20Subramanian%20Civil%20Individual%20Practices.pdf) · Source page 12 · Collected 2026-10-27 #### Trial exhibits and witnesses (1) “Exhibit Number”; (2) “Description” (of the exhibit); (3) “Date Identified”; and (4) “Date Admitted.” The parties shall complete the first two columns, but leave the third and fourth columns blank, to be filled in by the Court during trial. See document heading and cited passage; do not apply outside the issuing part or proceeding. [Official rules document](https://www.nysd.uscourts.gov/sites/default/files/practice_documents/AS%20Subramanian%20Civil%20Individual%20Practices.pdf) · Source page 12 · Collected 2026-10-27 #### Filing and working copies D. Requests to Charge and Proposed Voir Dire. Unless otherwise ordered by the Court, in all jury trials, joint requests to charge, joint proposed verdict forms, and joint proposed voir dire questions shall be submitted as attachments to the proposed joint pretrial order, with any differing proposals displayed in track-change format and supported by authority or other justification. At the time of filing, parties should also submit copies of these documents to the Court by email, as Microsoft Word documents. For any request to charge or proposed voir dire question on which the parties cannot agree, each party should clearly set forth its proposed charge or question, and briefly state why the Court should use its proposed charge or question, with citations to supporting authority. See document heading and cited passage; do not apply outside the issuing part or proceeding. [Official rules document](https://www.nysd.uscourts.gov/sites/default/files/practice_documents/AS%20Subramanian%20Civil%20Individual%20Practices.pdf) · Source page 12 · Collected 2026-10-27 #### Filing and working copies E. Additional Submissions in Non-Jury Cases. Unless otherwise ordered by the Court, at the time the joint pretrial order is filed, each party in a non-jury trial shall submit to the Court by email and serve on opposing counsel, but not file on ECF, the See document heading and cited passage; do not apply outside the issuing part or proceeding. [Official rules document](https://www.nysd.uscourts.gov/sites/default/files/practice_documents/AS%20Subramanian%20Civil%20Individual%20Practices.pdf) · Source page 12 · Collected 2026-10-27 #### Filing and working copies i. copies of affidavits constituting the direct testimony of each trial witness, except for the direct testimony of an adverse party, a person whose attendance is compelled by subpoena, or a person for whom the Court has agreed to hear direct testimony live at the trial. The affidavit should be treated as a direct substitute for the witness’s live testimony; that is, counsel should be attentive to the Rules of Evidence (e.g., hearsay and the like) and authenticate any exhibits that will be offered through that witness’s testimony. Three business days after submission of such affidavits, counsel for each party shall submit a list of all affiants whom they intend to cross- examine at the trial. Only those witnesses who will be cross-examined need to appear at trial. The original signed affidavits should be brought to trial See document heading and cited passage; do not apply outside the issuing part or proceeding. [Official rules document](https://www.nysd.uscourts.gov/sites/default/files/practice_documents/AS%20Subramanian%20Civil%20Individual%20Practices.pdf) · Source page 12 · Collected 2026-10-27 #### Discovery ii. all deposition excerpts that will be offered as substantive evidence, as well as a one-page synopsis of those excerpts for each deposition. Each synopsis shall include page citations to the pertinent pages of the deposition transcripts. See document heading and cited passage; do not apply outside the issuing part or proceeding. [Official rules document](https://www.nysd.uscourts.gov/sites/default/files/practice_documents/AS%20Subramanian%20Civil%20Individual%20Practices.pdf) · Source page 13 · Collected 2026-10-27 #### Filing and working copies F. Filings in Opposition. Unless otherwise ordered by the Court, any party may file See document heading and cited passage; do not apply outside the issuing part or proceeding. [Official rules document](https://www.nysd.uscourts.gov/sites/default/files/practice_documents/AS%20Subramanian%20Civil%20Individual%20Practices.pdf) · Source page 13 · Collected 2026-10-27 #### Filing and working copies A. Redactions Not Requiring Court Approval. The parties are referred to Rule 5.2 of the Federal Rules of Civil Procedure and the S.D.N.Y. ECF Privacy Policy (“Privacy Policy”). There are two categories of information that may be redacted from public court filings without prior permission from the Court: “sensitive information” and information requiring “caution.” Parties should not include in their public filings, unless necessary, the five categories of “sensitive information” (i.e., social security numbers [use the last four digits only], names of minor children [use the initials only], dates of birth [use the year only], financial account numbers [use the last four digits only], and home addresses [use only the City and State]). See document heading and cited passage; do not apply outside the issuing part or proceeding. [Official rules document](https://www.nysd.uscourts.gov/sites/default/files/practice_documents/AS%20Subramanian%20Civil%20Individual%20Practices.pdf) · Source page 13 · Collected 2026-10-27 #### Filing and working copies B. Redactions and Sealed Filings Requiring Court Approval. Except for redactions permitted by Paragraph 11(A) or as provided by the protective order approved in the case, all redactions or sealing of public court filings require Court approval. To be approved, any redaction or sealing of a court filing must be narrowly tailored to serve whatever purpose justifies the redaction or sealing and must be otherwise consistent with the presumption in favor of public access to judicial documents. In general, the parties’ consent or the fact that information is subject to a confidentiality agreement between litigants is not, by itself, a valid basis to overcome the presumption in favor of public access to judicial documents. See document heading and cited passage; do not apply outside the issuing part or proceeding. [Official rules document](https://www.nysd.uscourts.gov/sites/default/files/practice_documents/AS%20Subramanian%20Civil%20Individual%20Practices.pdf) · Source page 13 · Collected 2026-10-27 #### Filing and working copies in advance to narrow the scope of the request. When a party seeks leave to file a document under seal or in redacted form on the ground that an opposing party or third party has requested it, the filing party shall notify the opposing party or third party that it must file, within three business days, a letter explaining the need to seal or redact the document. See document heading and cited passage; do not apply outside the issuing part or proceeding. [Official rules document](https://www.nysd.uscourts.gov/sites/default/files/practice_documents/AS%20Subramanian%20Civil%20Individual%20Practices.pdf) · Source page 14 · Collected 2026-10-27 #### Motion practice ii. Sealed Document(s). The party shall file a letter-motion seeking leave to file a document under seal on ECF in accordance with Standing Order 19- MC-583 and Section 6 of the S.D.N.Y. Electronic Case Filing Rules and Instructions. The letter-motion itself shall be filed in public view, should explain the reasons for seeking to file the document under seal, and should not include confidential information. The proposed sealed document shall be contemporaneously filed under seal on ECF (with the appropriate level of restriction) and electronically related to the motion (or to the relevant Court order if the Court previously granted leave to file the document under seal). Note that the summary docket text, but not the document itself, will be open to public inspection and should not include confidential information sought to be filed under seal. See document heading and cited passage; do not apply outside the issuing part or proceeding. [Official rules document](https://www.nysd.uscourts.gov/sites/default/files/practice_documents/AS%20Subramanian%20Civil%20Individual%20Practices.pdf) · Source page 14 · Collected 2026-10-27 #### Motion practice iii. Redacted Document(s). Where a party seeks leave to file a document in redacted form, the party shall file a letter-motion seeking leave to file a document in redacted form on ECF in accordance with Standing Order 19- MC-583 and Section 6 of the S.D.N.Y. Electronic Case Filing Rules and Instructions. The letter-motion itself shall be filed in public view, should explain the reasons for seeking to file the document in redacted form, and should not include confidential information. At the same time, the party shall: (1) publicly file on ECF and electronically relate to the letter-motion a copy of the document with the proposed redactions; and (2) file under seal on ECF (with the appropriate level of restriction) and electronically relate to the motion an unredacted copy of the document with the proposed redactions highlighted. See document heading and cited passage; do not apply outside the issuing part or proceeding. [Official rules document](https://www.nysd.uscourts.gov/sites/default/files/practice_documents/AS%20Subramanian%20Civil%20Individual%20Practices.pdf) · Source page 14 · Collected 2026-10-27 #### Communications with chambers iv. Submission by Email. Any party unable to comply with the requirements for electronic filing under seal through the ECF system, or who believes that a particular document should not be electronically filed at all, shall file a letter-motion seeking leave of the Court to file in a different manner. If the party is unable to file such a letter-motion on ECF or believes there is good cause not to file such a letter-motion on ECF, the party may submit it by email as a text-searchable PDF attachment with a copy simultaneously delivered to all counsel. Any such email shall state clearly in the subject line: (1) the caption of the case, including the lead party names and docket number; and (2) a brief description of the contents of the letter. Parties may not include substantive communications in the body of the email; such communications may be included only in the body of the letter. See document heading and cited passage; do not apply outside the issuing part or proceeding. [Official rules document](https://www.nysd.uscourts.gov/sites/default/files/practice_documents/AS%20Subramanian%20Civil%20Individual%20Practices.pdf) · Source page 14 · Collected 2026-10-27 #### Communications with chambers Judge Subramanian’s webpage. 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. The Court disfavors modifications to the Court’s Model Protective Order. See document heading and cited passage; do not apply outside the issuing part or proceeding. [Official rules document](https://www.nysd.uscourts.gov/sites/default/files/practice_documents/AS%20Subramanian%20Civil%20Individual%20Practices.pdf) · Source page 15 · Collected 2026-10-27 #### Communications with chambers A. Use of Electronic Devices. Electronic devices (including mobile telephones, personal electronic devices, and computers) may not be used in Judge Subramanian’s Courtroom without his permission. More broadly, the use of any such devices within the Courthouse and its environs is governed by the Court’s Standing Order M10-468. If required by the Standing Order, counsel seeking to bring a device into the Courthouse shall submit an Electronic Device and Wi-Fi Access Request Form, available on the Court’s website, to the Court by e-mail as early as possible—and certainly no later than three business days before the start of the trial or hearing. Requests submitted later than three business days prior to the relevant trial or hearing may be denied on that basis alone. If permitted by the Standing Order, mobile telephones are permitted inside the Courtroom, but they MUST be kept turned off at all times. Non-compliance with this rule may result in forfeiture of the device for the remainder of the proceedings. See document heading and cited passage; do not apply outside the issuing part or proceeding. [Official rules document](https://www.nysd.uscourts.gov/sites/default/files/practice_documents/AS%20Subramanian%20Civil%20Individual%20Practices.pdf) · Source page 15 · Collected 2026-10-27 #### Trial exhibits and witnesses Unless otherwise ordered, these Individual Practices apply to hearings and trials in both civil and criminal cases before Judge Subramanian. See document heading and cited passage; do not apply outside the issuing part or proceeding. [Official rules document](https://www.nysd.uscourts.gov/sites/default/files/practice_documents/AS%20Subramanian%20Individual%20Practices%20for%20Hearings%20and%20Trials.pdf) · Source page 1 · Collected 2026-10-27 #### Communications with chambers 2. Wi-Fi Access. Attorneys may obtain authorization to use the Court’s Wi-Fi system in Judge Subramanian’s Courtroom during a hearing or trial by submitting an Electronic Device and Wi-Fi Access Request Form, available on the Court’s website. The completed form should be submitted as early as possible—and certainly no later than three business days before the start of the trial or hearing. If approved and signed by Judge Subramanian, a copy of the Order will be sent to the requesting attorney, who will receive a network name, username, password, and instructions from the District Executive’s Office on or before the first day of the scheduled proceeding. Wi-Fi access is limited to the approved attorney (who may not share his or her username or password with others) for the duration of the proceeding and for Courtroom 15A (unless Judge Subramanian or another judicial officer grants permission for it to be used in another courtroom). If an attorney wishes to test the Wi-Fi prior to the proceeding, that request must also be made to Chambers at least three business days prior to the proceeding. See document heading and cited passage; do not apply outside the issuing part or proceeding. [Official rules document](https://www.nysd.uscourts.gov/sites/default/files/practice_documents/AS%20Subramanian%20Individual%20Practices%20for%20Hearings%20and%20Trials.pdf) · Source page 1 · Collected 2026-10-27 #### Trial exhibits and witnesses 3. Audio-Visual Needs. If a party wishes to use audio-visual equipment at a hearing or trial, it is that party’s responsibility to ensure that any required approvals are obtained and that the necessary equipment is set up and working properly in advance of trial. See document heading and cited passage; do not apply outside the issuing part or proceeding. [Official rules document](https://www.nysd.uscourts.gov/sites/default/files/practice_documents/AS%20Subramanian%20Individual%20Practices%20for%20Hearings%20and%20Trials.pdf) · Source page 1 · Collected 2026-10-27 #### Trial exhibits and witnesses A list of the technology already set up in Judge Subramanian’s courtroom can be found in Attachment B. The party should contact the Courtroom Deputy, at (212) 805- 0238, sufficiently in advance of trial to make the necessary arrangements for a See document heading and cited passage; do not apply outside the issuing part or proceeding. [Official rules document](https://www.nysd.uscourts.gov/sites/default/files/practice_documents/AS%20Subramanian%20Individual%20Practices%20for%20Hearings%20and%20Trials.pdf) · Source page 1 · Collected 2026-10-27 #### Trial exhibits and witnesses technology walk-through and to test the equipment. To the extent that authorization is required to use electronic devices, a party must submit an Electronic Device and Wi-Fi Access Request Form, which is available on the Court’s website. The completed Form should be submitted as early as possible — and certainly no later than three business days before the start of the trial or hearing. See document heading and cited passage; do not apply outside the issuing part or proceeding. [Official rules document](https://www.nysd.uscourts.gov/sites/default/files/practice_documents/AS%20Subramanian%20Individual%20Practices%20for%20Hearings%20and%20Trials.pdf) · Source page 2 · Collected 2026-10-27 #### Conferences and appearances 5. Time Limits. In most civil cases, the Court will impose time limits on both sides at the final prehearing or pretrial conference. The parties’ opening statements (in civil jury trials) and examinations of witnesses will count against their time; lengthy colloquies before the jury will be split down the middle. The time limits do not apply to jury selection or to summations; the Court may impose separate time limits for summations. The parties should be prepared to address the issue of time limits at the final prehearing or pretrial conference. See document heading and cited passage; do not apply outside the issuing part or proceeding. [Official rules document](https://www.nysd.uscourts.gov/sites/default/files/practice_documents/AS%20Subramanian%20Individual%20Practices%20for%20Hearings%20and%20Trials.pdf) · Source page 2 · Collected 2026-10-27 #### Trial exhibits and witnesses 6. Hearing and Trial Practices. Counsel shall abide by the following rules and See document heading and cited passage; do not apply outside the issuing part or proceeding. [Official rules document](https://www.nysd.uscourts.gov/sites/default/files/practice_documents/AS%20Subramanian%20Individual%20Practices%20for%20Hearings%20and%20Trials.pdf) · Source page 2 · Collected 2026-10-27 #### Conferences and appearances A. Sidebars during jury trials are strongly disfavored. Counsel are expected to anticipate any issues that might require argument and to raise those issues with the Court in advance of the time that the jury will be hearing the evidence, ideally in advance of the final pretrial conference. See document heading and cited passage; do not apply outside the issuing part or proceeding. [Official rules document](https://www.nysd.uscourts.gov/sites/default/files/practice_documents/AS%20Subramanian%20Individual%20Practices%20for%20Hearings%20and%20Trials.pdf) · Source page 2 · Collected 2026-10-27 #### Trial exhibits and witnesses B. If counsel intends to use demonstrative aids (e.g., PowerPoint presentations) during their opening statement or during the examination of any witness, the aids should be furnished to opposing counsel in advance of their use and the parties should raise any disputes with the Court in advance. See document heading and cited passage; do not apply outside the issuing part or proceeding. [Official rules document](https://www.nysd.uscourts.gov/sites/default/files/practice_documents/AS%20Subramanian%20Individual%20Practices%20for%20Hearings%20and%20Trials.pdf) · Source page 2 · Collected 2026-10-27 #### Trial exhibits and witnesses C. Counsel shall ensure that each witness is present and ready to take the stand when that witness’s turn to testify arrives. If a witness finishes his or her testimony, and the side calling that witness does not have another witness present and ready to testify, that side will be deemed to have rested, and the Court will proceed to the next phase of the hearing or trial. See document heading and cited passage; do not apply outside the issuing part or proceeding. [Official rules document](https://www.nysd.uscourts.gov/sites/default/files/practice_documents/AS%20Subramanian%20Individual%20Practices%20for%20Hearings%20and%20Trials.pdf) · Source page 2 · Collected 2026-10-27 #### Trial exhibits and witnesses D. If both sides intend to call a particular witness, the parties shall ensure that the witness does not need to be called twice. Where a defense witness is called by the plaintiff (or a rebuttal witness is called by a defendant), the Court will allow counsel to go beyond the scope of the direct examination on cross-examination to avoid the need for the witness to be recalled. See document heading and cited passage; do not apply outside the issuing part or proceeding. [Official rules document](https://www.nysd.uscourts.gov/sites/default/files/practice_documents/AS%20Subramanian%20Individual%20Practices%20for%20Hearings%20and%20Trials.pdf) · Source page 2 · Collected 2026-10-27 #### Discovery E. If counsel plan to use a deposition at a hearing or trial, for impeachment or any other purpose, a copy of the deposition should be provided to the Court in advance of the hearing or trial session during which the deposition is to be used. See document heading and cited passage; do not apply outside the issuing part or proceeding. [Official rules document](https://www.nysd.uscourts.gov/sites/default/files/practice_documents/AS%20Subramanian%20Individual%20Practices%20for%20Hearings%20and%20Trials.pdf) · Source page 2 · Collected 2026-10-27 #### Trial exhibits and witnesses F. In advance of each hearing or trial session, counsel for the party going forward at that session should show opposing counsel the exhibits they intend to introduce at the session. The parties should raise any objections to an exhibit, other than authenticity or foundation, before the opening of the session. If possible, the Court will rule on the objection then, thereby eliminating the necessity for a colloquy or sidebar when the exhibit is offered. See document heading and cited passage; do not apply outside the issuing part or proceeding. [Official rules document](https://www.nysd.uscourts.gov/sites/default/files/practice_documents/AS%20Subramanian%20Individual%20Practices%20for%20Hearings%20and%20Trials.pdf) · Source page 3 · Collected 2026-10-27 #### Communications with chambers G. Exhibits must be pre-marked (that is, with exhibit stickers or the like) and should generally be labeled by party and exhibit number (e.g., “GX-1,” “PX-1,” “DX-1,” etc.) rather than letter (e.g., “DX-AA”). Parties are encouraged to use electronic copies of exhibits as much as possible. Regardless, electronic copies of any document sought to be admitted (with each filename corresponding to the relevant exhibit number—e.g., “PX-1,” “DX-1,” etc.) should be provided to the Court in advance of the proceeding. If submission of electronic copies would be an undue burden on a party, the party may seek leave of Court (by letter-motion filed on ECF) to submit prospective documentary exhibits in hard copy. See document heading and cited passage; do not apply outside the issuing part or proceeding. [Official rules document](https://www.nysd.uscourts.gov/sites/default/files/practice_documents/AS%20Subramanian%20Individual%20Practices%20for%20Hearings%20and%20Trials.pdf) · Source page 3 · Collected 2026-10-27 #### Trial exhibits and witnesses H. Where a hard copy exhibit is used, sufficient copies should be made, as appropriate, for witnesses, opposing counsel, jurors, the court reporter, any interpreters, and the Court. If counsel intends to publish hard copies of documentary exhibits to the jury rather than using the Court’s audio-visual system, a separate copy should be provided for each juror to avoid unnecessary delay. See document heading and cited passage; do not apply outside the issuing part or proceeding. [Official rules document](https://www.nysd.uscourts.gov/sites/default/files/practice_documents/AS%20Subramanian%20Individual%20Practices%20for%20Hearings%20and%20Trials.pdf) · Source page 3 · Collected 2026-10-27 #### Trial exhibits and witnesses I. Any exhibit offered in evidence should, at the time it is offered, be shown to opposing counsel unless it was provided, pre-marked, to counsel before the proceeding. At the end of the hearing or trial, counsel should make sure they have their exhibits. The Court is not responsible for them. See document heading and cited passage; do not apply outside the issuing part or proceeding. [Official rules document](https://www.nysd.uscourts.gov/sites/default/files/practice_documents/AS%20Subramanian%20Individual%20Practices%20for%20Hearings%20and%20Trials.pdf) · Source page 3 · Collected 2026-10-27 #### Trial exhibits and witnesses K. If counsel intends to question a witness about a group of documents, he or she should avoid delay by having all the documents with him or her when commencing the examination. Where practicable, counsel should provide all the documents in the group to the witness (ideally in a binder) and conduct the examination from the podium to avoid the need to approach the witness separately for each document. See document heading and cited passage; do not apply outside the issuing part or proceeding. [Official rules document](https://www.nysd.uscourts.gov/sites/default/files/practice_documents/AS%20Subramanian%20Individual%20Practices%20for%20Hearings%20and%20Trials.pdf) · Source page 3 · Collected 2026-10-27 #### Trial exhibits and witnesses L. Counsel should not make speaking objections before the jury. In making objections before the jury, counsel should state “objection” only and provide the legal ground (e.g., “relevance” or “hearsay”) only if elaboration is requested by the Court. See document heading and cited passage; do not apply outside the issuing part or proceeding. [Official rules document](https://www.nysd.uscourts.gov/sites/default/files/practice_documents/AS%20Subramanian%20Individual%20Practices%20for%20Hearings%20and%20Trials.pdf) · Source page 3 · Collected 2026-10-27 #### Motion practice M. Counsel should not make motions (e.g., a motion for a mistrial) in the presence of the jury. Such matters may be raised at the next recess. See document heading and cited passage; do not apply outside the issuing part or proceeding. [Official rules document](https://www.nysd.uscourts.gov/sites/default/files/practice_documents/AS%20Subramanian%20Individual%20Practices%20for%20Hearings%20and%20Trials.pdf) · Source page 3 · Collected 2026-10-27 #### Trial exhibits and witnesses N. Offers of, or requests for, a stipulation should be made privately, not within the hearing of the jury. In most instances, stipulations should be reduced to writing in a form that can be marked and admitted at trial. See document heading and cited passage; do not apply outside the issuing part or proceeding. [Official rules document](https://www.nysd.uscourts.gov/sites/default/files/practice_documents/AS%20Subramanian%20Individual%20Practices%20for%20Hearings%20and%20Trials.pdf) · Source page 4 · Collected 2026-10-27 #### Trial exhibits and witnesses 7. Conduct During a Hearing or Trial. Unless excused by the Court or incapable on account of disability, anyone at counsel table, including, as appropriate, any counsel See document heading and cited passage; do not apply outside the issuing part or proceeding. [Official rules document](https://www.nysd.uscourts.gov/sites/default/files/practice_documents/AS%20Subramanian%20Individual%20Practices%20for%20Hearings%20and%20Trials.pdf) · Source page 4 · Collected 2026-10-27 #### Trial exhibits and witnesses F. Only one attorney for each party shall examine, or cross-examine, each witness. The attorney stating objections, if any, during direct examination, shall be the attorney recognized for cross-examination. The attorney who conducts direct examination shall be the attorney who states any objections during cross- examination. See document heading and cited passage; do not apply outside the issuing part or proceeding. [Official rules document](https://www.nysd.uscourts.gov/sites/default/files/practice_documents/AS%20Subramanian%20Individual%20Practices%20for%20Hearings%20and%20Trials.pdf) · Source page 4 · Collected 2026-10-27 #### Trial exhibits and witnesses H. In examining a witness, counsel shall not repeat or echo the answer given by the witness. See document heading and cited passage; do not apply outside the issuing part or proceeding. [Official rules document](https://www.nysd.uscourts.gov/sites/default/files/practice_documents/AS%20Subramanian%20Individual%20Practices%20for%20Hearings%20and%20Trials.pdf) · Source page 4 · Collected 2026-10-27 #### Trial exhibits and witnesses I. Counsel should not face or otherwise appear to address him or herself to jurors when questioning a witness. See document heading and cited passage; do not apply outside the issuing part or proceeding. [Official rules document](https://www.nysd.uscourts.gov/sites/default/files/practice_documents/AS%20Subramanian%20Individual%20Practices%20for%20Hearings%20and%20Trials.pdf) · Source page 4 · Collected 2026-10-27 #### Trial exhibits and witnesses J. In opening statements and in arguments to the jury, counsel shall not express personal knowledge or opinion concerning any matter in issue. See document heading and cited passage; do not apply outside the issuing part or proceeding. [Official rules document](https://www.nysd.uscourts.gov/sites/default/files/practice_documents/AS%20Subramanian%20Individual%20Practices%20for%20Hearings%20and%20Trials.pdf) · Source page 4 · Collected 2026-10-27 #### Motion practice 8. Post-Hearing and Post-Trial Procedures. Counsel are responsible for raising promptly any issue concerning the accuracy of transcripts certified by the Court Reporter to be used for purposes of appeal. Counsel perceiving an error that is material shall stipulate to the appropriate correction or, if agreement cannot be reached, shall proceed by motion on notice. Non-material defects in syntax, grammar, spelling, or punctuation should be ignored. See document heading and cited passage; do not apply outside the issuing part or proceeding. [Official rules document](https://www.nysd.uscourts.gov/sites/default/files/practice_documents/AS%20Subramanian%20Individual%20Practices%20for%20Hearings%20and%20Trials.pdf) · Source page 4 · Collected 2026-10-27 #### Trial exhibits and witnesses Once all challenges for cause have been heard and decided, the parties will then exercise their peremptory challenges (in the Courtroom) against the panelists who compose the potential members of the regular jury (in the ordinary criminal case, against the first 28 panelists) and, in criminal cases, the potential alternates (in a case where 2 alternates are to be selected, panelists 29 through 32). Peremptory challenges will be exercised simultaneously, with each party submitting a written list of the panelists it wishes to excuse. Any overlap among the lists of challenges will not result in parties receiving additional challenges. The jurors will be selected starting with the unchallenged juror with lowest number from the relevant pool (e.g., 1 through 28 for the regular jury and 29 through 32 for the alternates). For example, in an ordinary criminal case, if there was an overlap of 1 peremptory challenge with respect to the potential regular jurors (i.e., the first 28 panelists), the 15 challenged panelists would be excused and the first 12 of the remaining 13 would be seated as the jury. The 13th panelist, that is, the unchallenged panelist with the highest number, would also be excused. See document heading and cited passage; do not apply outside the issuing part or proceeding. [Official rules document](https://www.nysd.uscourts.gov/sites/default/files/practice_documents/AS%20Subramanian%20Individual%20Practices%20for%20Hearings%20and%20Trials.pdf) · Source page 6 · Collected 2026-10-27 #### Communications with chambers The public is invited to propose changes to the Court’s practices by emailing letters to SubramanianNYSDChambers@nysd.uscourts.gov, no later than June 3, 2024. Judge Subramanian specifically welcomes suggestions related to when and how trial material should be disclosed to criminal defendants in advance of trial. See document heading and cited passage; do not apply outside the issuing part or proceeding. [Official rules document](https://www.nysd.uscourts.gov/sites/default/files/practice_documents/AS%20Subramanian%20Notice%20Regarding%20Individual%20Practices%20in%20Criminal%20Cases.pdf) · Source page 1 · Collected 2026-10-27 #### Filing and working copies Pro se parties are advised that there is a Pro Se Law Clinic available to assist self- represented parties in civil cases. The Clinic may be able to provide a pro se party with advice in connection with their case. The Pro Se Law Clinic is run by a private organization called the City Bar Justice Center; it is not part of, or run by, the Court (and, among other things, therefore cannot accept filings on behalf of the Court, which must still be made by any self-represented party through the Pro Se Intake Unit). Litigants in need of legal assistance should complete the City Bar Justice Center’s intake form to make an appointment. If a litigant has questions about the intake form or needs to highlight an urgent deadline already disclosed in the form, the clinic can be contacted by phone (212- 382-4794) or email (fedprosdny@nycbar.org). In-person appointments in the Thurgood Marshall Courthouse in Manhattan and the Charles L. Brieant Jr. Federal Building and Courthouse in White Plains are available Monday through Thursday, 10am to 4pm. See document heading and cited passage; do not apply outside the issuing part or proceeding. [Official rules document](https://www.nysd.uscourts.gov/sites/default/files/practice_documents/AS%20Subramanian%20Pro%20Se%20Individual%20Practices.pdf) · Source page 1 · Collected 2026-10-27 #### Communications with chambers A. No Communications by a Pro Se Party to Chambers. All communications with the Court by a pro se party should be in writing and delivered in person, mailed, or emailed as a PDF to ProSe@nysd.uscourts.gov. No documents or court filings may be sent directly to Chambers. Unless the Court orders otherwise, all communications with the Court will be docketed upon receipt; such docketing See document heading and cited passage; do not apply outside the issuing part or proceeding. [Official rules document](https://www.nysd.uscourts.gov/sites/default/files/practice_documents/AS%20Subramanian%20Pro%20Se%20Individual%20Practices.pdf) · Source page 1 · Collected 2026-10-27 #### Communications with chambers shall constitute service on any user of the ECF system. If any other party is not a user of the ECF system (e.g., if there is another pro se party in the case), a pro se party must send copies of any filing to that party and include an Affidavit of Service or other statement affirming that it has done so. Copies of correspondence between a pro se party and opposing parties shall not be sent to the Court. See document heading and cited passage; do not apply outside the issuing part or proceeding. [Official rules document](https://www.nysd.uscourts.gov/sites/default/files/practice_documents/AS%20Subramanian%20Pro%20Se%20Individual%20Practices.pdf) · Source page 2 · Collected 2026-10-27 #### Communications with chambers B. Communications by Parties Represented by Counsel. Except as otherwise provided below, communications with the Court by a represented party shall be governed by Judge Subramanian’s Individual Practices in Civil Cases, available at https://nysd.uscourts.gov/hon-arun-subramanian. See document heading and cited passage; do not apply outside the issuing part or proceeding. [Official rules document](https://www.nysd.uscourts.gov/sites/default/files/practice_documents/AS%20Subramanian%20Pro%20Se%20Individual%20Practices.pdf) · Source page 2 · Collected 2026-10-27 #### Adjournments C. Requests for Adjournments or Extensions of Time. All requests for adjournments or extensions of time must be made in writing and must state: (1) the original date(s); (2) the number of previous requests for adjournment or extension; See document heading and cited passage; do not apply outside the issuing part or proceeding. [Official rules document](https://www.nysd.uscourts.gov/sites/default/files/practice_documents/AS%20Subramanian%20Pro%20Se%20Individual%20Practices.pdf) · Source page 2 · Collected 2026-10-27 #### Courtroom conduct and technology Requests for extensions of deadlines regarding a matter that has been referred to a Magistrate Judge shall be addressed to that assigned Magistrate Judge. See document heading and cited passage; do not apply outside the issuing part or proceeding. [Official rules document](https://www.nysd.uscourts.gov/sites/default/files/practice_documents/AS%20Subramanian%20Pro%20Se%20Individual%20Practices.pdf) · Source page 2 · Collected 2026-10-27 #### Adjournments Absent an emergency, any request for extension or adjournment shall be made at least 48 hours prior to the deadline or scheduled appearance. Requests for extensions will ordinarily be denied if made after the expiration of the original deadline. See document heading and cited passage; do not apply outside the issuing part or proceeding. [Official rules document](https://www.nysd.uscourts.gov/sites/default/files/practice_documents/AS%20Subramanian%20Pro%20Se%20Individual%20Practices.pdf) · Source page 2 · Collected 2026-10-27 #### Courtroom conduct and technology A. Consent to Receive Electronic Service. To ensure timely service of documents, including Court Orders, non-incarcerated pro se parties are encouraged to consent to receive electronic service through the ECF System. To do so, a pro se party should review the instructions available at https://www.nysd.uscourts.gov/sites/ default/files/2021-03/Consent_Pro-Se_Eservice-Instructions.pdf, and then submit a Consent to Electronic Service (available at https://www.nysd.uscourts.gov/sites/ default/files/2021-03/Consent Pro-Se Eservice-form.pdf). See document heading and cited passage; do not apply outside the issuing part or proceeding. [Official rules document](https://www.nysd.uscourts.gov/sites/default/files/practice_documents/AS%20Subramanian%20Pro%20Se%20Individual%20Practices.pdf) · Source page 2 · Collected 2026-10-27 #### Filing and working copies iii. emailing them as an attachment in PDF format to Temporary_Pro_Se_ Filing@nysd.uscourts.gov, in which case the pro se party should follow the instructions contained in the April 1, 2020, Addendum to the Court’s ECF Rules & Instructions, available in Appendix C at https://www.nysd. See document heading and cited passage; do not apply outside the issuing part or proceeding. [Official rules document](https://www.nysd.uscourts.gov/sites/default/files/practice_documents/AS%20Subramanian%20Pro%20Se%20Individual%20Practices.pdf) · Source page 3 · Collected 2026-10-27 #### Filing and working copies C. Service on a Pro Se Party. Absent a pro se party consenting to receipt of electronic service, counsel in pro se cases must serve a pro se party with a paper copy of any document that is filed electronically and must file with the Court a separate Affidavit of Service. Submissions filed without proof of service that the pro se party was served will not be considered. See document heading and cited passage; do not apply outside the issuing part or proceeding. [Official rules document](https://www.nysd.uscourts.gov/sites/default/files/practice_documents/AS%20Subramanian%20Pro%20Se%20Individual%20Practices.pdf) · Source page 3 · Collected 2026-10-27 #### Discovery A. All requests for discovery by a pro se party should be sent to counsel for the party from whom discovery is sought. Discovery requests should not be sent to the Court. See document heading and cited passage; do not apply outside the issuing part or proceeding. [Official rules document](https://www.nysd.uscourts.gov/sites/default/files/practice_documents/AS%20Subramanian%20Pro%20Se%20Individual%20Practices.pdf) · Source page 3 · Collected 2026-10-27 #### Motion practice B. If there are any discovery disputes, the parties are required to confer with one another to try to resolve the dispute without the need for Court intervention. If the parties are unable to resolve their dispute, either party may file a letter-motion, no longer than three pages and in accordance with Paragraph 1 above, explaining the nature of the dispute and requesting an informal conference. If the opposing party wishes to respond to the letter, it must promptly file a responsive letter, not to exceed three pages. See document heading and cited passage; do not apply outside the issuing part or proceeding. [Official rules document](https://www.nysd.uscourts.gov/sites/default/files/practice_documents/AS%20Subramanian%20Pro%20Se%20Individual%20Practices.pdf) · Source page 3 · Collected 2026-10-27 #### Motion practice A. Filing and Service. Unless otherwise ordered by the Court, papers filed in opposition to a motion must be served and filed within 30 days of service of the motion papers, and reply papers, if any, must be served and filed within two weeks of receipt of opposition papers. See document heading and cited passage; do not apply outside the issuing part or proceeding. [Official rules document](https://www.nysd.uscourts.gov/sites/default/files/practice_documents/AS%20Subramanian%20Pro%20Se%20Individual%20Practices.pdf) · Source page 3 · Collected 2026-10-27 #### Motion practice B. Pro Se Notices. Parties who file a motion to dismiss, a motion for judgment on the pleadings, or a motion for summary judgment must provide the pro se party with a copy of the notices required under Local Civil Rules 12.1 or 56.2. See document heading and cited passage; do not apply outside the issuing part or proceeding. [Official rules document](https://www.nysd.uscourts.gov/sites/default/files/practice_documents/AS%20Subramanian%20Pro%20Se%20Individual%20Practices.pdf) · Source page 3 · Collected 2026-10-27 #### Motion practice that is supplied in connection with a summary judgment motion, the index to the deposition should be included if it is available. See document heading and cited passage; do not apply outside the issuing part or proceeding. [Official rules document](https://www.nysd.uscourts.gov/sites/default/files/practice_documents/AS%20Subramanian%20Pro%20Se%20Individual%20Practices.pdf) · Source page 4 · Collected 2026-10-27 #### Filing and working copies D. No Courtesy Copies. Unless the Court orders otherwise, parties should not submit courtesy hard copies of any submissions in pro se cases. See document heading and cited passage; do not apply outside the issuing part or proceeding. [Official rules document](https://www.nysd.uscourts.gov/sites/default/files/practice_documents/AS%20Subramanian%20Pro%20Se%20Individual%20Practices.pdf) · Source page 4 · Collected 2026-10-27 #### Motion practice E. Oral Argument. Unless otherwise ordered by the Court, oral argument will not be heard in pro se matters. See document heading and cited passage; do not apply outside the issuing part or proceeding. [Official rules document](https://www.nysd.uscourts.gov/sites/default/files/practice_documents/AS%20Subramanian%20Pro%20Se%20Individual%20Practices.pdf) · Source page 4 · Collected 2026-10-27 #### Communications with chambers Absent a motion to dismiss, the Court will generally schedule an initial case-management conference within four months of the filing of the complaint. The Notice of Initial Pretrial Conference will be docketed on ECF and mailed to the pro se party or parties. Unless and until the Court orders otherwise, the conference will be held in person in Courtroom 15A, 500 Pearl Street, New York, NY 10007. An incarcerated party may not be able to attend this or other conferences but may participate by telephone. If an incarcerated party does not have counsel and is unable to participate by telephone, a family member or a representative may attend the conference. See document heading and cited passage; do not apply outside the issuing part or proceeding. [Official rules document](https://www.nysd.uscourts.gov/sites/default/files/practice_documents/AS%20Subramanian%20Pro%20Se%20Individual%20Practices.pdf) · Source page 4 · Collected 2026-10-27 #### Motion practice The Court will set a schedule for the case at the initial case management conference. In most cases, the Court will give the parties four months (from the date of the conference) to complete all discovery and set a deadline for the filing of any motions for summary judgment 30 days after the close of discovery. In advance of the initial case management conference, the parties should, if practicable, confer with one another to determine if such a schedule would be appropriate or if there is anything unusual about the case that would require more time, and be prepared to discuss those issues at the conference. The Court will issue a written order memorializing all dates and deadlines following the conference. See document heading and cited passage; do not apply outside the issuing part or proceeding. [Official rules document](https://www.nysd.uscourts.gov/sites/default/files/practice_documents/AS%20Subramanian%20Pro%20Se%20Individual%20Practices.pdf) · Source page 4 · Collected 2026-10-27 #### Motion practice A. Pretrial Statement. Unless otherwise ordered by the Court, within 30 days of the completion of all discovery or, if a summary judgment motion is filed, within 30 days of the Court’s ruling on summary judgment, the plaintiff in a pro se case shall file a concise, written Pretrial Statement. This Statement must contain the following: (1) a statement of the facts the plaintiff hopes to prove at trial; (2) a list of all documents or other physical objects that the plaintiff plans to put into evidence at trial; and (3) a list of the names and addresses of all witnesses the plaintiff intends to have testify at trial. The Statement must be sworn by the plaintiff to be true and accurate based on the facts known by the plaintiff. If pro se, the plaintiff shall file an original of this Statement with the Pro Se Office. Two weeks after service of the plaintiff’s Statement, the defendant must file and serve a similar Statement of its case containing the same information. See document heading and cited passage; do not apply outside the issuing part or proceeding. [Official rules document](https://www.nysd.uscourts.gov/sites/default/files/practice_documents/AS%20Subramanian%20Pro%20Se%20Individual%20Practices.pdf) · Source page 4 · Collected 2026-10-27 #### Filing and working copies B. Other Pretrial Filings. If the case is to be tried before only a judge without a jury, any parties represented by counsel must also file proposed findings of fact and See document heading and cited passage; do not apply outside the issuing part or proceeding. [Official rules document](https://www.nysd.uscourts.gov/sites/default/files/practice_documents/AS%20Subramanian%20Pro%20Se%20Individual%20Practices.pdf) · Source page 4 · Collected 2026-10-27 #### Filing and working copies conclusions of law at the time of filing the Pretrial Statement. If the case is to be tried before a jury, any parties represented by counsel must also file proposed voir dire questions, a proposed jury charge, and a proposed verdict form at the time of filing the Pretrial Statement. At the time of filing, a represented party should email these documents to the Court in both PDF and Microsoft Word formats. The pro se party may file such documents but is not required to do so and should not submit them by email. See document heading and cited passage; do not apply outside the issuing part or proceeding. [Official rules document](https://www.nysd.uscourts.gov/sites/default/files/practice_documents/AS%20Subramanian%20Pro%20Se%20Individual%20Practices.pdf) · Source page 5 · Collected 2026-10-27 ### Shared court rules - [SDNY and EDNY — Joint Local Civil and Criminal Rules](https://knowjudges.com/courtroom-rules/ny-shared-set-201c11a4597834a9a953) — Federal district-court proceedings only. Civil and criminal sections have distinct scope and district-specific exceptions. Not Bankruptcy Court rules. [Official source](https://www.nysd.uscourts.gov/sites/default/files/local_rules/2026-01-02%20-%20EDNY%20and%20SDNY%20Joint%20Local%20Rules%20As%20Amended.pdf). Collected 2026-10-27. - [Federal Rules of Civil Procedure, December 1, 2025](https://knowjudges.com/courtroom-rules/national-shared-set-651872d6e45e0d82319ecccc) — Civil actions in United States District Courts; Rule 81 exceptions apply. Section-specific exceptions, waivers, later amendments and case orders remain applicable. This is a source excerpt, not an exhaustive statement of the rule. [Official source](https://www.uscourts.gov/sites/default/files/document/federal-rules-of-civil-procedure.pdf). Collected 2026-10-27. - [Federal Rules of Criminal Procedure, December 1, 2025](https://knowjudges.com/courtroom-rules/national-shared-set-8721a344fececced2257fe1d) — Criminal proceedings in United States District Courts; this conservative mapping does not distribute appellate-specific provisions to appellate judges. Section-specific exceptions, waivers, later amendments and case orders remain applicable. This is a source excerpt, not an exhaustive statement of the rule. [Official source](https://www.uscourts.gov/sites/default/files/document/federal-rules-of-criminal-procedure.pdf). Collected 2026-10-27.