Individual Practices; Proposed Case Management Plan For Pro Se Cases; Report of Rule 26(f) Conference and Proposed Case Management Plan

=== Individual Practices ===

Revised: September 8, 2025 INDIVIDUAL PRACTICES OF MAGISTRATE JUDGE STEWART D. AARON Chambers Daniel Patrick Moynihan Courthouse 500 Pearl Street, Room 1970 New York, NY 10007 Email: [email protected] Courtroom Daniel Patrick Moynihan Courthouse 500 Pearl Street, Courtroom 11C New York, NY 10007 Unless otherwise ordered by Judge Aaron or provided in the Local Rules of the United States District Courts for the Southern and Eastern Districts of New York (the “Local Civil Rules”), civil matters before him shall be conducted in accordance with the following individual practices.1 These practices are applicable to cases before Judge Aaron if the matter is within the scope of the District Judge’s Order of Reference or if the parties consent to have the case before Judge Aaron for all purposes pursuant to 28 U.S.C. § 636(c). Should the parties wish to have Judge Aaron preside over is available at: https://nysd.uscourts.gov/sites/default/files/2018-06/AO-3.pdf. for all purposes, the necessary their case form I. Communications With Chambers A. B. Letters. In general, communications with the Court should be by letter, via electronic case filing (“ECF”), without email or other copy to Chambers. Letters may not exceed 3 pages in length, exclusive of attachments, which should be kept to a minimum. Pro Se Parties. By Standing Order, a pro se party must mail all communications with the Court to the Pro Se Intake Unit located at 500 Pearl Street, Room 250, New York, NY 10007. A pro se party may not call Chambers or send any document or filing directly to Chambers. Submissions requiring immediate attention should be hand-delivered to the Pro Se Intake unit. Any non-incarcerated pro se party who wishes to participate in ECF must file a Motion for Permission for Electronic Case Filing, available in the Pro Se Intake Unit.2 Any non-incarcerated pro se party who wishes to receive documents by email instead of by regular mail may consent to electronic service by filing a Pro Se (Non-Prisoner) Consent & Registration Form to Receive Documents Electronically, available in the Pro Se Intake Unit.3 C. Requests For Adjournments Or Extensions Of Time. Requests to adjourn a court 1 Requests for reasonable accommodations on account of disability with respect to these rules may be sent by email to [email protected]. 2 A Motion also be https://nysd.uscourts.gov/sites/default/files/2019-04/2012-prosemotionecffiling-final.pdf. Electronic Case for Permission Filing may for found at: 3 A Pro Se (Non-Prisoner) Consent & Registration Form to Receive Documents Electronically may also be found at: https://nysd.uscourts.gov/sites/default/files/2018-06/proseconsentecfnotice-final.pdf. conference or court proceeding (including a telephonic court conference) or to extend a deadline must be made by Letter-Motion, after consultation with all affected parties, and must state: (1) the original date of the conference, proceeding or deadline; (2) the number of previous requests for adjournment or extension; (3) whether these previous requests were granted or denied; (4) the reason for the present request; (5) whether all affected parties consent; and (6) if not, the reasons given for refusing. If the requested adjournment or extension affects any other scheduled dates, a proposed Revised Scheduling Order must be attached. All requests for extension of a deadline must be made in advance of the deadline to be extended. Absent unforeseeable emergencies, all requests for an adjournment of a court conference or other court proceeding (including a telephonic court conference) must be made at least 72 hours in advance of the proceeding to be adjourned, and must include at least two proposed dates, on which all counsel are available, for the adjourned proceeding. Hand Deliveries. Where permitted by these Rules, hand-deliveries should be left with the Court Security Officers at the Worth Street entrance of 500 Pearl Street and may not be brought directly to Chambers. If the hand-delivery 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 immediately by Chambers staff. Request For Device Orders. Attorneys’ use of electronic devices (including mobile telephones, personal electronic devices, computers, and printers) within the Courthouse and its environs is governed by the Court’s Standing Order M10-468.4 Counsel seeking to bring a device into the Courthouse shall submit a filled-in copy of the Electronic Devices General Purpose Form 5 to the Court by e-mail ([email protected]) at least 24 hours prior to the relevant trial or hearing. A request for a So-Ordered Device Order shall not be filed on ECF. D. E. 4 Standing Order M10-468 is available at: https://nysd.uscourts.gov/sites/default/files/2018-06/standing- order-electronic-devices.pdf. 5 An Electronic Devices General Purpose Form may be found at: https://nysd.uscourts.gov/sites/default/files/2018- 06/Fillable%20Form%20for%20Electronic%20Devices%20General%20Purpose%20.pdf. 2 II. Discovery Disputes A. B. Requirement To Meet And Confer. No discovery dispute shall be heard unless the moving party (including a non-party seeking relief) has first conferred in good faith with the adverse party or parties by telephone or in person in an effort to resolve the dispute. An exchange of letters or emails alone does not satisfy this requirement. Counsel must respond promptly and in good faith to any request from another party to confer in accordance with this paragraph. Letter-Motion For Discovery Conference. If the parties have met and conferred but cannot resolve their dispute, the moving party must request a discovery conference with the Court, by Letter-Motion, as required by Local Civil Rule 37.2. Letter-Motions may not exceed 3 pages in length, exclusive of attachments, which should be kept to a minimum, and must clearly set forth the issues in dispute and the relief sought. As part of the Letter-Motion, the moving party must certify that the required in-person or telephonic conference took place between counsel for the relevant parties and, in particular, must state: (1) the date and time of such conference; (2) the approximate duration of the conference; (3) the names of the attorneys who participated in the conference; (4) the adversary’s position as to each issue being raised (as stated by the adversary during the in-person or telephone conference); and (5) that the moving party informed the adversary during the 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. None of these requirements may be satisfied by submitting copies of correspondence between counsel. 1. Briefing Schedule. Unless the Court has ordered otherwise or the parties have agreed to a different briefing schedule, any opposition to a Letter- Motion shall be filed within three business days of the moving letter, and any reply shall be filed within one business day of the opposition. Letters in opposition and replies may not exceed three pages in length exclusive of attachments, which should be kept to a minimum. If the parties have agreed to a different briefing schedule, they must so inform the Court, either in the moving letter or as soon as agreement is reached. If the Letter-Motion requests emergent or expedited relief, opposing counsel are advised to file any opposition as promptly as possible. 3 2. 3. 4. Courtesy Copies. Courtesy copies of Letter-Motions are not required unless the attached exhibits exceed ten pages, in which case one courtesy copy, marked as such, should submitted to Chambers promptly after filing. Courtesy copies should be printed on double-sided paper, and should bear the ECF header generated at the time of electronic filing and include protruding tabs for any exhibits. Bulky materials should be neatly bound, or placed in 3-ring binders, with appropriate dividers. Redactions And Filing Under Seal Pursuant to Rule 5.2 Of The Federal Rule of Civil Procedure. Rule 5.2 of the Federal Rules of Civil Procedure describes sensitive information that must be redacted from public court filings without seeking prior permission from the Court. These redactions and/or sealing may be performed without Court approval. Redactions And Filing Under Seal Through ECF. A party wishing to file a Letter-Motion (or opposition or reply) that contains material claimed by either party to require confidential treatment may file a redacted copy of the document on ECF, removing or concealing such information only to the extent necessary to safeguard information sought to be filed under seal. At the time of filing, the party also shall contemporaneously file the unredacted sealed document in the ECF system under seal, with the redactions highlighted. The summary docket text, but not the sealed document, will be open to public inspection and should not include confidential information sought to be filed under seal. Both documents must be electronically filed through the ECF system and related to the motion. Within three business days of the date the redacted document is filed, the party filing the redacted document must file a letter on ECF in conformity with the court’s standing order, No. 19-MC-00583, and ECF Rules & Instructions, Section 6. 6 seeking permission to file the document, or a portion thereof, under seal. However, the parties are cautioned that the designation of documents as “confidential” for discovery purposes does not, without more, justify a sealing order. Thus, the letter must explain the need to withhold the material at issue from the public record notwithstanding the strong presumption of public access to “judicial documents” under the First Amendment and the common law. See Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110, 119-21 (2d Cir. 2006). If a sealing request is based on another party’s designation of documents or information as “confidential,” the parties shall confer and jointly submit the request for sealing. 6 See Electronic Case Filing Rules & Instructions, U.S. Dist. Court S.D.N.Y. (July 24, 2023), https://www.nysd.uscourts.gov/sites/default/files/pdf/ecf_rules/ECF%20Rules%2020230724%20TH%20 FINAL.pdf. 4 If the Court does not approve the request for filing under seal, Chambers will cause the unredacted sealed document to be unrestricted and available on the public docket. Any party unable to comply with the requirement for electronic filing under seal through the ECF system, or who has reason to believe that a particular document should not be electronically filed, must move for leave of the Court to file in the traditional manner, on paper. C. Discovery Conferences/Oral Argument On Letter-Motions. It is the Court’s practice to hold a conference with the parties, where appropriate, to address any discovery disputes raised by Letter-Motion. The Court will decide the discovery dispute after the conference, based on the parties’ letters and matters discussed during the conference, unless a party shows – by separate application – good cause why more formal briefing is required. Junior members of legal teams representing clients are invited to argue Letter- Motions they have helped prepare. Firms are encouraged to provide this opportunity to junior attorneys for training purposes. The Court is amenable to permitting a number of lawyers to argue for one party if this creates an opportunity for a junior lawyer to participate. The ultimate decision of who speaks on behalf of the client is for the lawyer in charge of the case, not for the Court. III. Motions (Other Than Discovery Motions) For motions other than discovery motions, a pre-motion conference is not required. A pre-motion conference may be requested by Letter-Motion where counsel believes that an informal conference with the Court may obviate the need for the motion or reduce the issues in dispute. A. B. Briefing Schedule. Unless the Court has ordered otherwise or the parties have agreed to a different briefing schedule, opposition and reply papers with respect to formal motions will be due in accordance with Local Civil Rule 6.1. The parties are strongly encouraged to agree on a reasonable briefing schedule before the moving papers are filed. If the parties have agreed to such a schedule, they must so inform the Court, either in the moving party’s notice of motion or by letter as soon as agreement is reached. Should the parties thereafter agree to modify their briefing schedule, they must promptly inform the Court of the new schedule by letter. Memoranda of Law. The typeface, margins and spacing of motion papers must conform to Local Civil Rule 7.1, which requires all text to be in 12-point type or larger, except for text in footnotes which may be 10-point type; all documents must have at least one-inch margins on all sides; and all text must be double- spaced except for headings, text in footnotes, or block quotations, which may be single-spaced. 5 Unless prior permission has been granted, memoranda of law in support of and in opposition to motions may not exceed 8,750 words, and reply memoranda may not exceed 3,500 words.7 These limits do not include the caption, any index, table of contents, table of authorities, signature blocks, or any required certificates, but do include material contained in footnotes or endnotes. If a brief is filed by an attorney or prepared with a computer, it must include a certificate by the attorney, or party who is not represented by an attorney, that the document complies with the word-count limitations. The person preparing the certificate may rely on the word count of the word-processing program used to prepare the document. The certificate must state the number of words in the document. To the extent the court permits a party to submit briefs longer than these limits, and expresses those limits in pages, each additional page must not contain more than 350 additional words if the brief is filed by an attorney or prepared with a computer. Courtesy Copies. At the time the reply is filed, one courtesy copy of all formal motion papers, marked as such, shall be submitted to Chambers promptly after filing by the moving party.8 Courtesy copies should be printed on double-sided paper, three-hole punched and should bear the ECF header generated at the time of electronic filing. Materials should be neatly bound in one three-ring binders (if possible), with appropriate dividers and protruding tabs for any exhibits. The spines of the binders should be labeled to include the name of the case, the case number and the nature of the materials included in the binder. The non-moving party must provide the movant with a set of its motion papers in time for the movant to deliver all motion papers to the Court. In the event that the courtesy copy would prove especially voluminous, counsel shall jointly email Chambers for further guidance. C. D. Oral Argument On Motions. Parties may request oral argument by letter. The Court will determine whether argument will be heard and, if so, will advise counsel of the argument date and time. As with Letter-Motions, junior members of legal teams representing clients are invited to argue motions they have helped prepare. Firms are encouraged to provide this opportunity to junior attorneys for training purposes. The Court is amenable to permitting a number of lawyers to argue for one party if this creates an opportunity for a junior lawyer to participate. The ultimate decision of who 7 If the memoranda of law is filed by a party who is not represented by an attorney and is handwritten or prepared with a typewriter, briefs in support of and in response to a motion may not exceed 25 pages, and reply briefs may not exceed 10 pages. 8 If a party is proceeding pro se, one courtesy copy of all formal motion papers, marked as such, should be submitted to Chambers by the non-pro se party at the time the reply is due. 6 E. speaks on behalf of the client is for the lawyer in charge of the case, not for the Court. Redactions And Filing Under Seal. Filing under seal and redacting information not covered by Rule 5.2 of the Federal Rules of Civil Procedure requires permission of the Court. Unless otherwise ordered, any party wishing to file a document or portion thereof under seal must do the following on or before the date on which the relevant brief, declaration or other document is due: (1) file a redacted copy of the document via ECF, from which the material claimed to require confidential treatment has been removed or concealed; (2) file the unredacted sealed document in the ECF system under seal. The summary docket text, but not the sealed document, will be open to public inspection and should not include confidential information sought to be filed under seal. Both documents must be electronically filed through the ECF system and related to the motion; and (3) file a letter on ECF seeking permission to file the document under seal and explaining the need to withhold the material at issue from the public record notwithstanding the strong presumption of public access to “judicial documents” under the First Amendment and the common law. See Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110, 119-21 (2d Cir. 2006). If a sealing request is based on another party’s designation of documents or information as “confidential,” the parties shall confer and jointly submit the request for sealing. However, the parties are cautioned that the designation of documents as “confidential” for discovery purposes does not, without more, justify a sealing order. If the Court does not approve the request for filing under seal, Chambers will cause the unredacted sealed document to be unrestricted and available on the public docket. Any party unable to comply with the requirement for electronic filing under seal through the ECF system, or who has reason to believe that a particular document should not be electronically filed, must move for leave of the Court to file in the traditional manner, on paper. IV. Pretrial Procedures For Consent Cases A. B. Applicability. The procedures set out below apply only to cases in which the parties have consented pursuant to 28 U.S.C. § 636(c) to have all proceedings before Judge Aaron, including trial. Joint Pretrial Order. Unless otherwise ordered by the Court, the parties shall submit to the Court for its approval a Joint Pretrial Order within 30 days after the date for the completion of discovery, or, if a summary judgment motion has been filed, within 30 days after the decision on the motion. The proposed Joint Pretrial Order shall be signed by all parties and include the following: 1. 2. The full caption of the action. The names, addresses, telephone numbers (both office and cellular) and 7 3. 4. 5. 6. 7. 8. 9. 10. email addresses of each principal member of the trial team. A brief statement by plaintiff (or, in a removed case, by defendant) as to the basis of subject matter jurisdiction, and a brief statement by each other party as to the presence or absence of subject matter jurisdiction, including citations to all statutes relied on and relevant facts, such as citizenship and jurisdictional amount. A brief summary by each party of the claims and defenses that party has asserted that remain to be tried, including citations to all statutes relied on, but without recital of evidentiary matter. With respect to each claim remaining to be tried, a brief statement listing each element or category of damages sought with respect to such claim and a calculation of the amount of damages sought with respect to such element or category. A statement by each party as to whether the case is to be tried with or without a jury, and the anticipated number of trial days needed. Any stipulations or agreed to statements of fact or law. A statement by each party as to the witnesses whose testimony is to be offered in its case in chief, indicating whether such witnesses will testify in person or by deposition. Absent extraordinary circumstances, a party may not call as a witness in its case in chief any person not listed in the Joint Pretrial Order. A designation by each party of deposition testimony to be offered in that party’s case in chief, referencing page and line numbers, with any cross- designations and objections by any other party. If there is no objection or cross-designation, the Court will deem the opposing party to have waived any such objection or cross-designation. Absent extraordinary circumstances, a party may not offer in its case in chief deposition testimony that is not listed in the Joint Pretrial Order. A list by each party of exhibits to be offered in its case in chief. Each exhibit shall be pre-marked (plaintiff to use numbers, defendant to use letters). For each exhibit as to which there is an objection, the party objecting must briefly specify, next to the listing for that exhibit, the nature of the party’s objection (e.g., “authenticity,” “hearsay,” “Rule 403”). Any objection not listed shall be deemed waived. Absent extraordinary circumstances, a party may not offer in its case in chief any exhibit not listed in the Joint Pretrial Order. 11. A proposed schedule by which the parties will exchange demonstrative exhibits that the parties intend to use at trial, notify each other of any objections thereto, consult with each other regarding those objections and notify the Court of any remaining disputes. 8 12. All other matters that the Court may have ordered or that the parties believe are important to the efficient conduct of the trial. C. Filings Prior to Trial. Unless otherwise ordered by the Court, each party shall file 15 days before the date of commencement of trial if such a date has been fixed (or 30 days after the filing of the final pretrial order if no trial date has been fixed): 1. 2. 3. In jury cases, requests to charge and proposed voir dire questions, and where applicable, a proposed special verdict form. In nonjury cases, proposed findings of fact and statements of law. If the parties believe it would be useful, they also may file in nonjury cases pretrial memoranda, limited to 25 pages. In all cases, motions addressing any evidentiary or other issues which should be resolved in limine. D. Marking Exhibits for Trial. At the commencement of trial, each party must provide each other party, and the Court, with a tabbed binder or binders containing double-sided courtesy copies of its trial exhibits and deposition designations. 9

=== Proposed Case Management Plan For Pro Se Cases ===

Revised November 27, 2023 No. __ -cv-_____ ( ) (SDA) UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK Plaintiff(s), -against- Defendant(s). PROPOSED CASE MANAGEMENT PLAN FOR PRO SE CASE 1. Summary of Claims, Defenses and Relevant Issues: __________________________________________________________________ __________________________________________________________________ __________________________________________________________________ __________________________________________________________________ __________________________________________________________________ __________________________________________________________________ 2. I understand my obligation to and am preserving relevant information. Plaintiff(s): Yes or No (circle one) Defendant(s): Yes or No (circle one) 3. Proposed Schedule: All discovery should be completed by __________________________________. a. Depositions shall be completed by ______________________________. b. Neither party may take more than ______ depositions. Absent an agreement between the parties or an Order from the Court, non-party depositions shall follow initial party depositions. c. Initial Requests for Documents must be made by ___________________. d. Responses to Requests for Documents must be made by _____________. e. Documents from third parties (such as doctors) will/will not (circle one) be required. If required, the following are the third parties from whom Documents will be requested: ____________________________________________________________ ____________________________________________________________ ____________________________________________________________ ____________________________________________________________ f. Subpoenas requesting Documents from third parties must be served by __________________. Documents obtained from third parties must be provided to all parties in this matter. g. There will/will not (circle one) be expert testimony in this case. If expert testimony will be needed, please describe the topic on which the expert(s) is expected to testify. ____________________________________________________________ ____________________________________________________________ ____________________________________________________________ 4. Anticipated Motions: ________________________________________________ 5. Amendment to Pleadings: No amended pleadings may be filed after ____________. Any motion to amend after this date will need to meet the good cause requirements of Federal Rule of Civil Procedure 16(b). No additional parties may be joined after ____________. Any motion to join after this date will need to meet the good cause requirements of Federal Rule of Civil Procedure 16(b). 6. Early Settlement or Resolution: The parties have/have not (circle one) discussed the possibility of settlement. The parties request a settlement conference by no later than ____________. The following information is needed before settlement can be discussed: __________________________________________________________________ __________________________________________________________________ __________________________________________________________________ 2 7. Status Letter: The parties shall file a joint letter regarding the status of discovery on ___________ (date to be determined by the Court). 8. Other Matters: The parties wish to discuss the following additional matters at the Initial Case Management Conference: _____________________________________________________________________ Respectfully submitted this ____ day of _____________ ________________________________ Name ________________________________ Address ________________________________ Phone number ________________________________ Email ________________________________ Party representing (if applicable) 3 Respectfully submitted this ____ day of _____________ ________________________________ Name ________________________________ Address ________________________________ Phone number ________________________________ Email ________________________________ Party representing (if applicable) 4

=== Report of Rule 26(f) Conference and Proposed Case Management Plan ===

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK _______________________________, Plain�ff(s), -against- No: ___-cv-_____ (____) (SDA) _______________________________, Defendant(s). REPORT OF RULE 26(f) MEETING AND [PROPOSED] CASE MANAGEMENT PLAN In accordance with Rule 26(f) of the Federal Rules of Civil Procedure, counsel for the par�es spoke on ______________ and exchanged communica�ons therea�er, and submit the following report of their mee�ng for the court’s considera�on: 1. Summary of Claims, Defenses And Relevant Issues: Plain�ff [Atach Addi�onal Pages As Needed]: _________________________________ ______________________________________________________________________________ ______________________________________________________________________________ ______________________________________________________________________________ ______________________________________________________________________________ ______________________________________________________________________________ ______________________________________________________________________________ ______________________________________________________________________________ Defendant [Atach Addi�onal Pages As Needed]: _______________________________ ______________________________________________________________________________ ______________________________________________________________________________ ______________________________________________________________________________ ______________________________________________________________________________ ______________________________________________________________________________ ______________________________________________________________________________ ______________________________________________________________________________ 2. Basis of Subject Mater Jurisdic�on: The Court’s subject mater jurisdic�on is based on ______________________________. Last Revised on April 18, 2024 3. Subjects On Which Discovery May Be Needed: Plain�ff: ____________________________________________________________ ______________________________________________________________________________ ______________________________________________________________________________ ______________________________________________________________________________ ______________________________________________________________________________ ______________________________________________________________________________ Defendant: ____________________________________________________________ ______________________________________________________________________________ ______________________________________________________________________________ ______________________________________________________________________________ ______________________________________________________________________________ ______________________________________________________________________________ 4. Ini�al Disclosures: The informa�on required by Rule 26(a)(1) was disclosed by Plain�ff(s) on ______________. In addi�on, on ______________, Plain�ff(s) produced/will produce an ini�al set of relevant documents iden�fied in its Ini�al Disclosures and will con�nue to supplement its produc�on. The informa�on required by Rule 26(a)(1) was disclosed by Defendant(s) on ______________. In addi�on, on ______________, Defendant(s) produced/will produce an ini�al set of relevant documents iden�fied in its Ini�al Disclosures and will con�nue to supplement its produc�on. 5. Formal Discovery: The par�es jointly propose to the Court the following discovery plan: a. All fact discovery must be completed by ______________. b. The par�es are to conduct discovery in accordance with the Federal Rules of Civil Procedure and the Local Rules of the Southern District of New York. The following interim deadlines may be extended by the par�es on consent and without applica�on to the Court, provided that the par�es meet the deadline for comple�ng fact discovery set forth in 5(a) above. i. Deposi�ons: Deposi�ons shall be completed by ______________ and limited to no more than ___ deposi�ons per party. Absent an agreement between the par�es or an Order from the Court, non- party deposi�ons shall follow ini�al party deposi�ons. ii. Interrogatories: Ini�al sets of interrogatories shall be served on or before ______________. All subsequent interrogatories must be served no later than 30 days from the discovery deadline. 2 iii. Requests for Admission: Requests for admission must be served on or before______________. iv. Requests for Produc�on: Ini�al requests for produc�on were/will be exchanged on ______________, and responses shall be due on ______________. All subsequent requests for produc�on must be served no later than 30 days before the discovery deadline. v. Supplementa�on: Supplementa�ons under Rule 26(e) must be made within a reasonable period of �me a�er discovery of such informa�on. 6. An�cipated Discovery Disputes: Does either party an�cipate discovery disputes or seek limita�ons on discovery? Describe. ________________________________________________________________________ ______________________________________________________________________________ ______________________________________________________________________________ ______________________________________________________________________________ ______________________________________________________________________________ 7. Amendments To Pleadings: a. No amended pleadings may be filed a�er ______________. Any mo�on to amend a�er this date will need to meet the good cause requirements of Rule 16(b). b. No addi�onal par�es may be joined a�er ______________. Any mo�on to join a�er this date will need to meet the good cause requirements of Rule 16(b). 8. Expert Witness Disclosures: At this �me, the par�es [☐ do / ☐ do not] an�cipate u�lizing experts. Expert discovery shall be completed by ______________. 9. Electronic Discovery And Preserva�on Of Documents And Informa�on: a. b. Have the par�es discussed electronic discovery? [☐ Yes / ☐ No] Is there an electronic discovery protocol in place? [☐ Yes / ☐ No] If not, when do the par�es expect to have one in place? ______________ c. Do the par�es want the Court to enter a Rule 502(d) Order? (See Rule 502(d) Order) [☐ Yes / ☐ No] d. Will the par�es enter into a Protec�ve Order? (See Model Protec�ve Order)? [☐ Yes / ☐ No] If yes, the Protec�ve Order shall be submited no later ______________. 3 e. Are there issues the par�es would like to address concerning preserva�on of evidence and/or electronic discovery at the Ini�al Case Management Conference? Describe. _______________________________________________________________________ _____________________________________________________________________________ _____________________________________________________________________________ _____________________________________________________________________________ 10. An�cipated Mo�ons: ________________________________________________________________________ ______________________________________________________________________________ ______________________________________________________________________________ ______________________________________________________________________________ 11. Early Setlement Or Resolu�on: The par�es [☐ have / ☐ have not] discussed the possibility of setlement. The par�es shall request a setlement conference no later than ______________. The following informa�on is needed before setlement can be discussed: ________________________________________________________________________ ______________________________________________________________________________ ______________________________________________________________________________ 12. Trial: a. b. c. d. The par�es an�cipate that this case will be ready for trial by ______________. The par�es an�cipate that the trial of this case will require ____________ days. The par�es [☐ do / ☐ do not] consent to a trial before a Magistrate Judge. The par�es request a [☐ jury / ☐ bench] trial. 13. Status Leter (To Be Completed By The Court): The par�es shall file a joint leter regarding the status of discovery on ______________. 14. Consent To Proceed Before A United States Magistrate Judge: The par�es are advised that they may consent to Judge Aaron’s jurisdic�on at any �me during the case pursuant to 28 U.S.C. § 636(c). To consent to Judge Aaron’s jurisdic�on, please u�lize the form to Consent for All Purposes or Consent For Specific Disposi�ve Mo�ons, which are hyperlinked herein and also available on Judge Aaron’s Individual Prac�ces Webpage. 4 15. Other Maters: ________________________________________________________________________ ______________________________________________________________________________ ______________________________________________________________________________ ______________________________________________________________________________ ______________________________________________________________________________ Respec�ully submited this ____ day of ______________, ______. Atorney(s) for Plain�ff(s): Atorney(s) for Defendant(s): ___________________________ ___________________________ SO ORDERED. Dated: New York, New York ________________ ______________________________ STEWART D. AARON United States Magistrate Judge 5