Discovery Disputes

Unless the individual practices of the judge presiding over discovery require a different procedure, no motion under Fed. R. Civ. P. 26 through 37 inclusive and Fed. R. Civ. P. 45 will be heard unless counsel for the moving party has first requested an informal 32 Joint Local Rules, S.D.N.Y. and E.D.N.Y. Effective January 2, 2026 conference with the court by letter-motion for a premotion discovery conference and that request has either been denied or the discovery dispute has not been resolved as a consequence of the conference. For relevant historical context for this local rule, consult the Appendix of Committee Notes.