--- title: "Jeannette Anne Vargas | KnowJudges" canonical: "https://knowjudges.com/kyj/judge/jeannette-anne-vargas" page_type: "judge_profile" updated: "2026-10-08" --- # Jeannette Anne Vargas 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 - American judge serving on the United States District Court for the Southern District of New York since November 6, 2024 - Assistant U.S. attorney, Southern District of New York, 2002-2024; deputy chief, Tax and Bankruptcy Unit, 2009-2010; chief, Tax and Bankruptcy Unit, 2010-2014; senior trial counsel, 2014-2016; deputy chief, Civil Division, 2016-2024 - Law clerk, Hon. Sonia Sotomayor, U.S. Court of Appeals for the Second Circuit, 2001-2002 ### Education - B.A. magna cum laude from Harvard College in 1995, followed by a J.D. from Yale Law School in 2000 - Harvard University — B.A. (1995) ### Additional information - Private practice, New York City, 2000-2001 - Born 1973. - Vargas was born in Flushing, Queens, New York ## 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 ### remote conferences Scope: judge specific Judge Vargas's remote conferences are held by Microsoft Teams unless otherwise ordered, with published participant requirements. Evidence excerpt: Unless otherwise ordered by the Court, any Remote Conference will be held via a Microsoft Teams meeting organized by the Court. [Judge Vargas's Individual Rules and Practices in Civil Cases](https://www.nysd.uscourts.gov/sites/default/files/practice_documents/JAV%20Vargas%20%20Individual%20Rules%20and%20Practicies%20in%20Civil%20Cases%20February%202025.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/13761858) - [Official roster](https://www.fjc.gov/node/13761858) - [Federal Judicial Center biography](https://www.fjc.gov/node/13761858) - [Judge Vargas's Individual Rules and Practices in Civil Cases](https://www.nysd.uscourts.gov/sites/default/files/practice_documents/JAV%20Vargas%20%20Individual%20Rules%20and%20Practicies%20in%20Civil%20Cases%20February%202025.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 Jeannette Anne Vargas](https://www.fjc.gov/node/13761858) ## JSON-LD ```json { "@context": "https://schema.org", "@graph": [ { "@type": "WebPage", "@id": "https://knowjudges.com/kyj/judge/jeannette-anne-vargas", "url": "https://knowjudges.com/kyj/judge/jeannette-anne-vargas", "name": "Jeannette Anne Vargas | KnowJudges", "description": "Jeannette Anne Vargas, U.S. District Court for the Southern District of New York. 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Civility in All Proceedings 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/JAV%20Vargas%20Individual%20Rules%20and%20Practicies%20in%20Civil%20Cases%20MAY%202025_0.pdf) · Source page 1 · Collected 2026-10-27 #### Filing and working copies A. Electronic Case Filing (“ECF”). In accordance with the S.D.N.Y. Electronic Case Filing Rules and Instructions, except as otherwise expressly provided, all documents filed with the Court must be filed electronically. 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/JAV%20Vargas%20Individual%20Rules%20and%20Practicies%20in%20Civil%20Cases%20MAY%202025_0.pdf) · Source page 1 · Collected 2026-10-27 #### Filing and working copies B. Text Searchable Submissions. If feasible, every submission should be in text-searchable format created by converting the document electronically to PDF by computer (that is, not by scanning a printed document). If a PDF is created by scanning a printed document (for instance, in the case of a pre-existing documentary exhibit), the party should use software to make the document text searchable 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/JAV%20Vargas%20Individual%20Rules%20and%20Practicies%20in%20Civil%20Cases%20MAY%202025_0.pdf) · Source page 1 · Collected 2026-10-27 #### Filing and working copies C. Amended or Corrected Filings. Any amended or corrected filing shall be filed with a redline showing all differences between the original and revised 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/JAV%20Vargas%20Individual%20Rules%20and%20Practicies%20in%20Civil%20Cases%20MAY%202025_0.pdf) · Source page 1 · Collected 2026-10-27 #### Communications with chambers D. Submission of Large Electronic Files. If a party needs to submit large files that cannot be uploaded to ECF due to size, the party should email the Court at VargasNYSDChambers@nysd.uscourts.gov. The email should copy all other counsel in the case and include the name and docket number of the case and the nature and size of the materials to be submitted electronically. 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/JAV%20Vargas%20Individual%20Rules%20and%20Practicies%20in%20Civil%20Cases%20MAY%202025_0.pdf) · Source page 2 · Collected 2026-10-27 #### Filing and working copies E. 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/JAV%20Vargas%20Individual%20Rules%20and%20Practicies%20in%20Civil%20Cases%20MAY%202025_0.pdf) · Source page 2 · Collected 2026-10-27 #### Communications with chambers i. 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., 22-CV-1234 [rel. 21-CV-4321]). 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/JAV%20Vargas%20Individual%20Rules%20and%20Practicies%20in%20Civil%20Cases%20MAY%202025_0.pdf) · Source page 2 · Collected 2026-10-27 #### Communications with chambers ii. After two or more actions have been consolidated for all purposes under a single docket number pursuant to Rule 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. 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/JAV%20Vargas%20Individual%20Rules%20and%20Practicies%20in%20Civil%20Cases%20MAY%202025_0.pdf) · Source page 2 · Collected 2026-10-27 #### Communications with chambers A. Letters and Letter Motions. Except as provided herein or as otherwise ordered by the Court, communications with Chambers shall be by letter filed on ECF. Letters may not exceed four pages in length (single-spaced, with standard font and margins, inclusive of signature blocks, but exclusive of exhibits or attachments) without prior permission from the Court. Copies of correspondence between counsel shall not be sent to the Court or filed on ECF except as exhibits to an otherwise properly filed document. Letters seeking relief (consistent with S.D.N.Y. Local Rules and the S.D.N.Y. Electronic Case Filing Rules and Instructions) should be filed as letter-motions on ECF, not ordinary letters. Any opposition to letters must be filed within three (3) business days of the filing party’s letter motion. 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/JAV%20Vargas%20Individual%20Rules%20and%20Practicies%20in%20Civil%20Cases%20MAY%202025_0.pdf) · Source page 2 · Collected 2026-10-27 #### Communications with chambers B. Telephone Calls. Except as provided in Section 5(L) and 7(B), calls to Chambers are permitted only in urgent situations requiring immediate attention, where submission of a letter or letter motion is not feasible. In such situations, call Chambers. Parties should review these Individual Rules and Practices before calling with questions about the Court’s rules and practices. 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/JAV%20Vargas%20Individual%20Rules%20and%20Practicies%20in%20Civil%20Cases%20MAY%202025_0.pdf) · Source page 2 · Collected 2026-10-27 #### Communications with chambers C. 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, 200 Worth Street, New York, NY 10007. 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/JAV%20Vargas%20Individual%20Rules%20and%20Practicies%20in%20Civil%20Cases%20MAY%202025_0.pdf) · Source page 3 · Collected 2026-10-27 #### Communications with chambers D. Faxes. Faxes to Chambers are not permitted without express prior permission, and only in cases of unforeseeable emergencies. 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/JAV%20Vargas%20Individual%20Rules%20and%20Practicies%20in%20Civil%20Cases%20MAY%202025_0.pdf) · Source page 3 · Collected 2026-10-27 #### Adjournments E. Requests for Adjournment or Extension 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. Parties should not submit proposed stipulations or proposed orders purporting to extend deadlines. 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/JAV%20Vargas%20Individual%20Rules%20and%20Practicies%20in%20Civil%20Cases%20MAY%202025_0.pdf) · Source page 3 · Collected 2026-10-27 #### Adjournments The letter-motion must state: (1) the original date and the new date requested; (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 refusal to consent; and (6) the date of the parties’ next scheduled appearance before the Court. If the requested extension affects any dates set forth in the Civil Case Management Plan, a proposed Amended Civil Case Management Plan must be attached. Absent an emergency, any request for extension or adjournment shall be made as early as possible, and 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/JAV%20Vargas%20Individual%20Rules%20and%20Practicies%20in%20Civil%20Cases%20MAY%202025_0.pdf) · Source page 3 · Collected 2026-10-27 #### Discovery A request to extend the deadline to complete all discovery is unlikely to be granted. But any such request shall include a statement as to what discovery requests have been propounded, who propounded each request, and on what date; what responses were made, who made each response, and on what date; and the volume of documents produced, who produced the documents, and on what 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/JAV%20Vargas%20Individual%20Rules%20and%20Practicies%20in%20Civil%20Cases%20MAY%202025_0.pdf) · Source page 3 · Collected 2026-10-27 #### Communications with chambers A. Telephone and Video Conference (“Remote Conferences”). Unless otherwise ordered by the Court, any Remote Conference will be held via a Microsoft Teams meeting organized by the Court. 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/JAV%20Vargas%20Individual%20Rules%20and%20Practicies%20in%20Civil%20Cases%20MAY%202025_0.pdf) · Source page 3 · Collected 2026-10-27 #### Conferences and appearances i. Prior to the Remote Conference, the Court will issue an Order with instructions regarding how to join the Microsoft Teams meeting. ii. Counsel in attendance who will not be speaking must have their videos off and be muted for the duration of 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/JAV%20Vargas%20Individual%20Rules%20and%20Practicies%20in%20Civil%20Cases%20MAY%202025_0.pdf) · Source page 4 · Collected 2026-10-27 #### Conferences and appearances iii. If counsel joins the Remote Conference by audio-only, counsel should dial-in using a landline whenever possible, should use a headset or handset instead of speakerphone, and must mute themselves whenever they are not speaking to eliminate background noise. To facilitate the creation of an accurate transcript if the conference is held on the record, counsel who are joining the conference audio-only are required to identify themselves every time they speak. Counsel should spell any proper names for the court reporter. Counsel should also 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/JAV%20Vargas%20Individual%20Rules%20and%20Practicies%20in%20Civil%20Cases%20MAY%202025_0.pdf) · Source page 4 · Collected 2026-10-27 #### Conferences and appearances iv. The 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/JAV%20Vargas%20Individual%20Rules%20and%20Practicies%20in%20Civil%20Cases%20MAY%202025_0.pdf) · Source page 4 · Collected 2026-10-27 #### Motion practice B. Participation by Junior Attorneys. The Court encourages the participation of less experienced attorneys in all proceedings— including pretrial conferences, hearings on discovery disputes, and witness examinations 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 where doing so would afford the opportunity for a junior attorney to gain courtroom experience. To facilitate this provision, the Court is amenable to permitting more than one attorney to speak at a conference or argument. 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/JAV%20Vargas%20Individual%20Rules%20and%20Practicies%20in%20Civil%20Cases%20MAY%202025_0.pdf) · Source page 4 · Collected 2026-10-27 #### Motion practice A. 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. The format of all memoranda of law shall comply with Local Rule 7.1, except that all font, including any footnotes, must be in 12- point font or larger. Memoranda of 10 pages or more shall contain a table of contents and a table of authorities, neither of which shall count against the word limit. Surreply memoranda are not allowed (unless specifically permitted in extraordinary situations for good cause). 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/JAV%20Vargas%20Individual%20Rules%20and%20Practicies%20in%20Civil%20Cases%20MAY%202025_0.pdf) · Source page 5 · Collected 2026-10-27 #### Adjournments B. 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. In particular, all requests for adjournments, extensions, and pre-motion conferences (including pre-motion conferences with respect to discovery disputes) should be filed as letter-motions. 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/JAV%20Vargas%20Individual%20Rules%20and%20Practicies%20in%20Civil%20Cases%20MAY%202025_0.pdf) · Source page 5 · Collected 2026-10-27 #### Motion practice C. Pre-Motion Conferences in Civil Cases. Pre-motion conferences are not required, except for disputes concerning discovery, which are governed by Section 6 below. 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/JAV%20Vargas%20Individual%20Rules%20and%20Practicies%20in%20Civil%20Cases%20MAY%202025_0.pdf) · Source page 5 · Collected 2026-10-27 #### Motion practice D. Filing of Motion Papers. Motion papers must be filed promptly after service. 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/JAV%20Vargas%20Individual%20Rules%20and%20Practicies%20in%20Civil%20Cases%20MAY%202025_0.pdf) · Source page 5 · Collected 2026-10-27 #### Motion practice F. Failure of the Court to Schedule Argument or Decide a Motion. If a motion is not decided within 60 days of the date that it was fully briefed, counsel for the movant shall send a letter to alert 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/JAV%20Vargas%20Individual%20Rules%20and%20Practicies%20in%20Civil%20Cases%20MAY%202025_0.pdf) · Source page 6 · Collected 2026-10-27 #### Communications with chambers G. Proposed Orders and Stipulations. Proposed orders to show cause, temporary restraining orders, stipulations, consent orders and proposed judgments are to be filed electronically on ECF as explained in the SDNY Electronic Case Filing Rules and Instructions. Counsel should also email an electronic copy of any proposed order to Chambers, in both Microsoft Word and PDF formats. 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/JAV%20Vargas%20Individual%20Rules%20and%20Practicies%20in%20Civil%20Cases%20MAY%202025_0.pdf) · Source page 6 · Collected 2026-10-27 #### Motion practice H. Oral Argument on Motions. A party may request oral argument by indicating “ORAL ARGUMENT REQUESTED” on the cover page of its memorandum of law. If a party believes that the Court would benefit from oral argument for a particular reason not obvious from the parties’ briefing, the party may file a short letter—not a letter- motion—explaining the reason(s). In this letter, the party should advise the Court if oral argument would be handled by a less- experienced attorney because, as discussed in Section 4(B) 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/JAV%20Vargas%20Individual%20Rules%20and%20Practicies%20in%20Civil%20Cases%20MAY%202025_0.pdf) · Source page 6 · Collected 2026-10-27 #### Motion practice i. Upon the filing of a motion to dismiss, the non-moving party is required, within 10 days, to notify the Court whether it intends to file an amended pleading or rely on the pleading being attacked. If the non-moving party elects not to file an amended pleading, the motion will proceed in the regular course, and the Court is unlikely to grant the non-moving party a further opportunity to amend to address the purported deficiencies made apparent by the fully briefed arguments in the moving party’s motion. See Loreley Fin. (Jersey) No. 3 Ltd. v. Wells Fargo Sec., LLC, 797 F.3d 160, 190 (2d Cir. 2015) (leaving “unaltered the grounds on which denial of leave to amend has long been held proper, such as undue delay, bad faith, dilatory motive, and futility”). This provision does not alter the time to file a response to the motion to dismiss. 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/JAV%20Vargas%20Individual%20Rules%20and%20Practicies%20in%20Civil%20Cases%20MAY%202025_0.pdf) · Source page 6 · Collected 2026-10-27 #### Motion practice J. Motion for Leave to Amend a Pleading. When moving to amend any pleading, the moving party shall 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/JAV%20Vargas%20Individual%20Rules%20and%20Practicies%20in%20Civil%20Cases%20MAY%202025_0.pdf) · Source page 7 · Collected 2026-10-27 #### Motion practice i. Discouraged in Non-Jury Cases. Summary judgment motions are discouraged in non-jury cases. ii. Rule 56.1 Statements. Any party represented by counsel that moves for summary judgment shall provide all other parties with an electronic copy, in a standard word processing format, of the moving party’s Statement of Material Facts Pursuant to Local Civil Rule 56.1 (“Rule 56.1 Statement”). 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. Each factual assertion in Rule 56.1 Statements must be followed by a citation to the portion(s) of the evidentiary record relied upon. 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/JAV%20Vargas%20Individual%20Rules%20and%20Practicies%20in%20Civil%20Cases%20MAY%202025_0.pdf) · Source page 7 · Collected 2026-10-27 #### Trial exhibits and witnesses iii. Record Evidence Citations. Each memorandum of law must include a statement of facts and may not simply incorporate by reference the entirety of a party’s Rule 56.1 Statement. Moreover, all factual assertions in memoranda of law should be supported by citations to the underlying record evidence, not to the Rule 56.1 Statement. 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/JAV%20Vargas%20Individual%20Rules%20and%20Practicies%20in%20Civil%20Cases%20MAY%202025_0.pdf) · Source page 7 · Collected 2026-10-27 #### Motion practice iv. Deposition Transcripts. Deposition transcripts that are supplied in connection with a summary judgment motion, whether in whole or in part, should be text-searchable and include an index where 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/JAV%20Vargas%20Individual%20Rules%20and%20Practicies%20in%20Civil%20Cases%20MAY%202025_0.pdf) · Source page 7 · Collected 2026-10-27 #### Communications with chambers L. Applications for a Temporary Restraining Order. A party must confer with their adversary before making an application for a temporary restraining order unless the requirements of Federal Rule of Civil Procedure 65(b) are met. As soon as a party decides to seek a temporary restraining order, that party must file a letter on ECF (under seal if proceeding ex parte) and state clearly whether: (1) it has notified its adversary and whether the adversary consents to temporary injunctive relief; or (2) the requirements of Federal Rule of Civil Procedure 65(b) are satisfied and no notice is necessary. 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/JAV%20Vargas%20Individual%20Rules%20and%20Practicies%20in%20Civil%20Cases%20MAY%202025_0.pdf) · Source page 7 · Collected 2026-10-27 #### Communications with chambers The moving party must email VargasNYSDChambers@nysd.uscourts.gov giving notice of the filing and the time frame requested for Court action. The moving party should then file a Motion for a Temporary Restraining Order, supporting documents and a proposed order on ECF in accordance with ECF procedures. Where the motion is made on notice to the other parties, the moving party should simultaneously serve the documents on any party that will not receive electronic service via ECF. If the matter is time sensitive and Chambers does not respond within two hours, the movant may call Chambers before the end of the business day. 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/JAV%20Vargas%20Individual%20Rules%20and%20Practicies%20in%20Civil%20Cases%20MAY%202025_0.pdf) · Source page 8 · Collected 2026-10-27 #### Motion practice M. Default Judgment Motions. A plaintiff seeking a default judgment must proceed by way of motion pursuant to the procedure set forth in Attachment A to these rules. 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/JAV%20Vargas%20Individual%20Rules%20and%20Practicies%20in%20Civil%20Cases%20MAY%202025_0.pdf) · Source page 8 · Collected 2026-10-27 #### Filing and working copies N. Protective Order. Any party seeking a protective order must submit a proposed protective order that conforms as closely as possible to the Court’s Model Protective Order, which is available on the Court’s public webpage at https://www.nysd.uscourts.gov/hon-jeannette- vargas. The proposed protective order must be filed on ECF in accordance with Rule 13.18 of the SDNY ECF Rules and Instructions. 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/JAV%20Vargas%20Individual%20Rules%20and%20Practicies%20in%20Civil%20Cases%20MAY%202025_0.pdf) · Source page 8 · Collected 2026-10-27 #### Motion practice O. Exclude Testimony of Experts. Unless the Court orders otherwise, motions to exclude the testimony of experts, pursuant to F.R.E. 702– 705 and the Daubert v. Merrell Dow Pharmaceuticals, Inc., 509 U.S. 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/JAV%20Vargas%20Individual%20Rules%20and%20Practicies%20in%20Civil%20Cases%20MAY%202025_0.pdf) · Source page 8 · Collected 2026-10-27 #### Motion practice A. Stay of Discovery. It is not the Court’s practice to stay discovery while a dispositive motion is pending. If a party nonetheless seeks a stay of discovery, such request must be made in writing and filed on ECF as a letter-motion, not an ordinary letter. Moreover, if the grounds for the requested stay of discovery is the filing of a dispositive motion that is either contemplated or pending at the time the Court holds the initial pretrial conference, the motion for a stay of discovery should be filed no later than two weeks prior to the date of the conference. The opposition to such a motion should be filed one week after the letter-motion is filed. No reply will be permitted. 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/JAV%20Vargas%20Individual%20Rules%20and%20Practicies%20in%20Civil%20Cases%20MAY%202025_0.pdf) · Source page 9 · Collected 2026-10-27 #### Motion practice B. Discovery Disputes. Prior to bringing a motion pursuant to Rules 26 through 37 or Rule 45 of the Federal Rules of Civil Procedure, a party must follow the procedures set forth below. 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/JAV%20Vargas%20Individual%20Rules%20and%20Practicies%20in%20Civil%20Cases%20MAY%202025_0.pdf) · Source page 9 · Collected 2026-10-27 #### Communications with chambers i. Meet and Confer. Any party wishing to raise a discovery dispute with the Court must first confer in good faith at least once with the opposing party—in person, by videoconference, or by telephone—to resolve the dispute. E-mail communication alone will not satisfy the meet-and-confer requirement. 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 three business days of a request for 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/JAV%20Vargas%20Individual%20Rules%20and%20Practicies%20in%20Civil%20Cases%20MAY%202025_0.pdf) · Source page 9 · Collected 2026-10-27 #### Motion practice ii. Letter-Motions. If the meet-and-confer process does not resolve the dispute, the party seeking discovery must promptly submit a letter-motion to the Court via ECF, no longer than four pages (single spaced, with standard font and margins, inclusive of the signature block), explaining the nature of the dispute and why the party is entitled to relief. The initial letter-motion must state: (1) the date(s), time(s), and duration of each meet-and- confer conference; (2) the names of the attorneys who participated; and (3) that the moving party informed the adversary during the last conference that the moving party believed the parties to be at an impasse and that the moving party would be requesting relief from 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/JAV%20Vargas%20Individual%20Rules%20and%20Practicies%20in%20Civil%20Cases%20MAY%202025_0.pdf) · Source page 9 · Collected 2026-10-27 #### Discovery iii. Timeliness. 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/JAV%20Vargas%20Individual%20Rules%20and%20Practicies%20in%20Civil%20Cases%20MAY%202025_0.pdf) · Source page 10 · 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, the examining attorney 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/JAV%20Vargas%20Individual%20Rules%20and%20Practicies%20in%20Civil%20Cases%20MAY%202025_0.pdf) · Source page 10 · 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 call 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 call 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/JAV%20Vargas%20Individual%20Rules%20and%20Practicies%20in%20Civil%20Cases%20MAY%202025_0.pdf) · Source page 10 · Collected 2026-10-27 #### Adjournments A. Initial Case Management Conference. Plaintiff’s counsel (or, in a matter removed from state court, defendant’s counsel) is responsible for distributing copies of the Notice of Initial Pretrial Conference to all parties. The Notice will direct the parties to submit to the Court, approximately one week prior to the conference date, a joint proposed Case Management Plan and Scheduling Order (a model of which can be found on the Court’s public webpage at https://www.nysd.uscourts.gov/hon-jeannette-vargas). Requests for adjournments of the initial pretrial conference must be made in accordance with Section 3(E), supra. 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/JAV%20Vargas%20Individual%20Rules%20and%20Practicies%20in%20Civil%20Cases%20MAY%202025_0.pdf) · Source page 10 · Collected 2026-10-27 #### Conferences and appearances B. Cases Removed from State Court. Counsel for the party or parties that removed the case must follow 28 U.S.C. § 1446(a) and file a copy of the state court docket sheet within three calendar days of filing the notice of removal. Plaintiffs shall ensure that a copy of the operative complaint is posted electronically to the docket on the ECF system. 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/JAV%20Vargas%20Individual%20Rules%20and%20Practicies%20in%20Civil%20Cases%20MAY%202025_0.pdf) · Source page 10 · Collected 2026-10-27 #### Conferences and appearances Counsel for all parties must file on ECF a notice of appearance in this Court promptly upon removal. 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/JAV%20Vargas%20Individual%20Rules%20and%20Practicies%20in%20Civil%20Cases%20MAY%202025_0.pdf) · Source page 11 · Collected 2026-10-27 #### Discovery C. Post-Fact Discovery Settlement Discussions. No later than one week after the close of fact discovery, counsel for all parties must meet for at least one hour to discuss settlement. If no settlement is reached during this meeting, the parties should discuss whether a mediation or referral to the magistrate judge for a settlement conference would be productive. 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/JAV%20Vargas%20Individual%20Rules%20and%20Practicies%20in%20Civil%20Cases%20MAY%202025_0.pdf) · Source page 11 · Collected 2026-10-27 #### Motion practice D. Post-Fact Discovery Joint Status Letter. Two weeks following the close of fact discovery, or at a time otherwise ordered by the Court, the parties shall file a joint letter updating the Court on the status of the case, including but not limited to confirming that the one-hour settlement discussion occurred and stating whether all parties consent to mediation or a settlement conference to be held before the designated Magistrate Judge. The letter should not identify any party that has declined to consent. The parties should indicate in the letter whether the parties intend to conduct expert discovery. In a case without expert discovery, the letter shall notify the Court if any party anticipates filing a dispositive motion, and if so, set forth a proposed briefing schedule for any such motion(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/JAV%20Vargas%20Individual%20Rules%20and%20Practicies%20in%20Civil%20Cases%20MAY%202025_0.pdf) · Source page 11 · Collected 2026-10-27 #### Motion practice E. Post-Expert Discovery Joint Status Letter. In cases in which the parties conduct expert discovery, no later than one week after the close of expert discovery, or at a time otherwise ordered by the Court, counsel for all parties must file a joint status letter. This letter shall notify the Court if any party anticipates filing a dispositive motion or a motion to exclude testimony of experts pursuant to Federal Rules of Evidence 702–705 and the Daubert v. Merrell Dow Pharmaceuticals, Inc., 509 U.S. 579 (1993) line of cases. If so, the parties should set forth a proposed briefing schedule for any such motion(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/JAV%20Vargas%20Individual%20Rules%20and%20Practicies%20in%20Civil%20Cases%20MAY%202025_0.pdf) · Source page 11 · Collected 2026-10-27 #### Motion practice F. Joint Pretrial Order. Unless otherwise specified by the Court, within thirty (30) days after the close of discovery or if any dispositive motion is filed, within thirty (30) days from the Court’s decision on such motion, the parties shall file on ECF a joint pretrial order. The joint pretrial order shall include the information required by Fed. R. 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/JAV%20Vargas%20Individual%20Rules%20and%20Practicies%20in%20Civil%20Cases%20MAY%202025_0.pdf) · Source page 11 · Collected 2026-10-27 #### Trial exhibits and witnesses iii. a statement as to whether or not all parties have consented to trial by a magistrate judge, without identifying which parties do or do not consent; iv. a statement as to the number of trial days needed and as to whether the case is to be tried with or without a jury; 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/JAV%20Vargas%20Individual%20Rules%20and%20Practicies%20in%20Civil%20Cases%20MAY%202025_0.pdf) · Source page 12 · Collected 2026-10-27 #### Discovery x. a list of all trial witnesses, indicating whether such witnesses will testify in person or by deposition, and a brief summary of the substance of each witness’s testimony; 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 should not designate deposition testimony to be used for impeachment purposes only. Any objections not made are waived; 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/JAV%20Vargas%20Individual%20Rules%20and%20Practicies%20in%20Civil%20Cases%20MAY%202025_0.pdf) · Source page 12 · Collected 2026-10-27 #### Motion practice G. Motions in Limine. At the time the joint pretrial order is filed, the parties shall file and serve motions addressing any evidentiary issues or other matters which should be resolved in limine. Any party wishing to file a motion in limine must first confer in good faith with the opposing party in an effort to resolve the dispute. Any motion in limine must include a representation that the meet and-confer process occurred and was unsuccessful. Each party must file a single memorandum of law, consistent with Rule 5(A) above, in support of all motions in limine filed by that party. Any opposition papers will be due in two weeks. 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/JAV%20Vargas%20Individual%20Rules%20and%20Practicies%20in%20Civil%20Cases%20MAY%202025_0.pdf) · Source page 13 · Collected 2026-10-27 #### Filing and working copies H. Pretrial Memoranda of Law. At the time the joint pretrial order is filed, a party may file a pretrial memorandum of law if it believes it would be useful to the Court. Any response or opposition to a pretrial memorandum of law shall be due two weeks after the filing of the opening memorandum. The pretrial memorandum and response each shall not exceed 25 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/JAV%20Vargas%20Individual%20Rules%20and%20Practicies%20in%20Civil%20Cases%20MAY%202025_0.pdf) · Source page 13 · Collected 2026-10-27 #### Communications with chambers I. Deposition Designations. In any civil case in which the parties have designated deposition testimony in the joint pretrial order, by no later than a week prior to the final pretrial conference, the parties shall jointly submit by email to VargasNYSDChambers@nysd.uscourts.gov the complete deposition transcripts with color-coded highlighting indicating the portions designated by each party (including any counter-designations) and the objections listed in the margins. The highlighted deposition transcripts should not be filed 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/JAV%20Vargas%20Individual%20Rules%20and%20Practicies%20in%20Civil%20Cases%20MAY%202025_0.pdf) · Source page 13 · Collected 2026-10-27 #### Communications with chambers J. Additional Required Pretrial Filings in Jury Cases. No later than two weeks before trial, the parties shall jointly file on ECF and submit by email to VargasNYSDChambers@nysd.uscourts.gov 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/JAV%20Vargas%20Individual%20Rules%20and%20Practicies%20in%20Civil%20Cases%20MAY%202025_0.pdf) · Source page 13 · Collected 2026-10-27 #### Trial exhibits and witnesses i. Voir Dire Questions. The parties shall submit in a single document a set of joint case-specific proposed voir dire questions. For any disputes, each party should clearly set forth its proposed question and briefly state why the Court should use it. Absent 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/JAV%20Vargas%20Individual%20Rules%20and%20Practicies%20in%20Civil%20Cases%20MAY%202025_0.pdf) · Source page 13 · Collected 2026-10-27 #### Trial exhibits and witnesses good cause, proposed voir dire questions should include only those questions unique to the facts of the case being tried. ii. Requests to Charge. The parties shall submit in a single document a joint request to charge. The parties shall endeavor to use plain English that can be readily understandable by a layman, and to define terms that may be unfamiliar to the jury. 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/JAV%20Vargas%20Individual%20Rules%20and%20Practicies%20in%20Civil%20Cases%20MAY%202025_0.pdf) · Source page 14 · Collected 2026-10-27 #### Trial exhibits and witnesses Any counterproposal(s) should be presented together with the disputed section, along with a brief explanation of the grounds for each party’s position, with citations to supporting authority. Absent good cause, the parties should not include proposed language for standard instructions (about, for example, the role of the Court and the jury, the standard of proof, what is evidence, etc.), as the Court is likely to use its own standard instructions. The parties should, however, include a list of standard instructions that they believe are appropriate for the Court to give in the 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/JAV%20Vargas%20Individual%20Rules%20and%20Practicies%20in%20Civil%20Cases%20MAY%202025_0.pdf) · Source page 14 · Collected 2026-10-27 #### Communications with chambers K. Additional Required Pretrial Filings in Non-Jury Cases. At the time the joint pretrial order is filed in a non-jury case, each party shall file and serve proposed findings of fact and conclusions of law. The proposed findings of fact must be detailed and include citations to the anticipated trial testimony and exhibits. This document should also be submitted by email to VargasNYSDChambers@nysd.uscourts.gov in Microsoft Word format. 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/JAV%20Vargas%20Individual%20Rules%20and%20Practicies%20in%20Civil%20Cases%20MAY%202025_0.pdf) · Source page 14 · Collected 2026-10-27 #### Conferences and appearances B. 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 provide a copy of the settlement agreement for the Court to endorse or include 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/JAV%20Vargas%20Individual%20Rules%20and%20Practicies%20in%20Civil%20Cases%20MAY%202025_0.pdf) · Source page 14 · Collected 2026-10-27 #### Conferences and appearances C. Parties that seek to settle FLSA claims through a stipulated dismissal with prejudice pursuant to Federal Rule of Civil Procedure 41(a)(1)(A)(ii) must submit the settlement agreement and all other necessary information for Court approval in accordance with Cheeks v. 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/JAV%20Vargas%20Individual%20Rules%20and%20Practicies%20in%20Civil%20Cases%20MAY%202025_0.pdf) · Source page 15 · Collected 2026-10-27 #### Conferences and appearances Freeport Pancake House, Inc., 796 F.3d 199 (2d Cir. 2015). The Court will not approve a settlement agreement that contains an overly broad release clause or for which the parties fail to submit all necessary information, including, inter alia, the parties’ estimations for the plaintiff’s number of hours worked, applicable wages, and a detailed breakdown of the justification for any requested attorneys’ fees. 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/JAV%20Vargas%20Individual%20Rules%20and%20Practicies%20in%20Civil%20Cases%20MAY%202025_0.pdf) · Source page 15 · Collected 2026-10-27 #### Filing and working copies A. Privacy Policy. The parties are referred to Federal Rule of Civil Procedure 5.2 and the S.D.N.Y. ECF Privacy Policy (“Privacy Policy”). The parties should not include, unless necessary, the five categories of “sensitive information” in their submissions (i.e., social security numbers, names of minor children [use the initials only], dates of birth [use the year only], financial account numbers 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/JAV%20Vargas%20Individual%20Rules%20and%20Practicies%20in%20Civil%20Cases%20MAY%202025_0.pdf) · Source page 15 · Collected 2026-10-27 #### Filing and working copies C. Redactions and Sealed Filings Requiring Court Approval. All redactions other than those under Federal Rule of Civil Procedure 5.2 require Court approval. The Court will review each proposed redaction individually. To be approved, redactions must be narrowly tailored to serve whatever purpose justifies them and otherwise consistent with the presumption in favor of public access to judicial documents. See, e.g., Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110, 119–20 (2d Cir. 2006). In general, the parties’ consent or the fact that information is subject to a confidentiality agreement (or protective order) 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/JAV%20Vargas%20Individual%20Rules%20and%20Practicies%20in%20Civil%20Cases%20MAY%202025_0.pdf) · Source page 15 · Collected 2026-10-27 #### Filing and working copies 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/JAV%20Vargas%20Individual%20Rules%20and%20Practicies%20in%20Civil%20Cases%20MAY%202025_0.pdf) · Source page 16 · Collected 2026-10-27 #### Motion practice ii. Sealed Document(s). The party shall electronically 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 separately and 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, thus, the summary docket text 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/JAV%20Vargas%20Individual%20Rules%20and%20Practicies%20in%20Civil%20Cases%20MAY%202025_0.pdf) · Source page 16 · 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/JAV%20Vargas%20Individual%20Rules%20and%20Practicies%20in%20Civil%20Cases%20MAY%202025_0.pdf) · Source page 16 · Collected 2026-10-27 #### Communications with chambers iv. Submission by Email. Any party unable to comply with the requirement for electronic filing under seal on ECF, or who believes that a particular document should not be electronically filed at all, shall file a letter-motion by email, seeking leave of the Court to file in a different manner. Such letter-motions may be emailed to VargasNYSDChambers@nysd.uscourts.gov as text-searchable PDF attachments, with copies simultaneously delivered to all counsel. In the subject line, the cover email should state clearly: (1) the caption of the case, including the lead party names and docket number; and (2) a brief description of the nature of the request. Parties shall not include substantive communications in the body of the email. The letter-motion must explain why sealing or redaction is justified in light of the standards discussed in Section 10(C) above. 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. Unless otherwise ordered by the Court, letter-motions seeking leave to file in a different manner shall comply with Section 3(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/JAV%20Vargas%20Individual%20Rules%20and%20Practicies%20in%20Civil%20Cases%20MAY%202025_0.pdf) · Source page 17 · Collected 2026-10-27 #### Communications with chambers A. Electronic Devices in the Courtroom. Attorneys’ use of personal electronic devices (including mobile phones) and general purpose computing devices (such as laptops and tablets) within the Courthouse and its environs is governed by Standing Order M10-468. When Court permission is required under the Standing Order, attorneys seeking to bring electronic devices to the Court should email a completed Model Court Order to VargasNYSDChambers@nysd.uscourts.gov. Chambers will coordinate with the District Executive’s Office to issue the Order and forward a copy to counsel. The Order must be shown upon bringing the equipment into the Courthouse. 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/JAV%20Vargas%20Individual%20Rules%20and%20Practicies%20in%20Civil%20Cases%20MAY%202025_0.pdf) · Source page 17 · Collected 2026-10-27 #### Courtroom conduct and technology B. Mobile Phones. Attorneys in compliance with the Standing Order may bring mobile phones into the Courtroom, but the phones MUST be kept turned off at all times. Non-compliance with this rule will 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/JAV%20Vargas%20Individual%20Rules%20and%20Practicies%20in%20Civil%20Cases%20MAY%202025_0.pdf) · Source page 17 · Collected 2026-10-27 #### Motion practice If a party fails to respond to a claim, the party asserting the claim should promptly move for entry of default judgment if appropriate. If a failure to answer is the basis for the default, the party seeking a default judgment must begin by seeking a Clerk’s Certificate of Default pursuant to Local Civil Rule 55.1. Only after obtaining a Clerk’s Certificate of Default should the party proceed to file a motion for default judgment on ECF pursuant to Federal Rule of Civil Procedure 55(b)(2) and Local Civil Rule 55.2. (Counsel should therefore seek and obtain a Clerk’s Certificate of Default well in advance of any Court-imposed deadline to move for default judgment.) A party seeking a default judgment should not proceed by order to show cause. Any 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/JAV%20Vargas%20Individual%20Rules%20and%20Practicies%20in%20Civil%20Cases%20MAY%202025_0.pdf) · Source page 18 · Collected 2026-10-27 #### Communications with chambers D. 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 at VargasNYSDChambers@nysd.uscourts.gov; 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/JAV%20Vargas%20Individual%20Rules%20and%20Practicies%20in%20Civil%20Cases%20MAY%202025_0.pdf) · Source page 19 · 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.