SDNY and EDNY Word Limits: 8,750 and 3,500 Under Joint Local Civil Rule 7.1(c)

Short answer: 8,750 words for a brief in support of or in response to a motion, and 3,500 words for a reply, under Joint Local Civil Rule 7.1(c) in the Southern and Eastern Districts of New York.

Those two numbers are the easy part. The parts that cost motions are the mandatory word-count certificate, the fact that footnotes count while tables and signature blocks do not, the separate and much shorter cap on reconsideration, and the individual-practice layer on top of the joint rule. Some Southern District judges still write their limits in pages, so the operative ceiling in your case may be well below 8,750 words.

What is the word limit for a brief in SDNY and EDNY?

Local Civil Rule 7.1(c), in the edition effective January 2, 2026, provides that “briefs in support of and in response to a motion (except for motions for reconsideration) may not exceed 8,750 words, and reply briefs may not exceed 3,500 words.” The rule is joint, so the same text governs in both districts.

The limit is expressed in words, not pages, so drafting to a 25-page ceiling and checking nothing else no longer maps onto the rule. The word-based text was already in place in the January 2, 2025 edition and carries forward unchanged into the January 2, 2026 edition, while a July 2024 practitioner report still described the reconsideration limits in pages. If your internal checklist says pages, it predates the current rule.

The cap is also per brief, and the parenthetical carve-out for reconsideration sends you to a different rule with different numbers.

What counts toward the 8,750 words?

The rule answers this directly: “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.”

Footnotes count. That matters because Local Civil Rule 7.1(b) permits smaller type in footnotes while requiring that “all text must be 12-point type or larger, except for text in footnotes,” with footnote text capped at 10-point. Shrinking a substantive argument into 10-point footnotes buys visual space and zero word-count relief. Move the material into a declaration or cut it.

Is a word-count certificate required?

Yes. Rule 7.1(c) requires that “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 certificate itself is excluded from the count, so there is no drafting penalty for including it and a compliance problem if you leave it out.

Motions for reconsideration: 3,500 and 1,750

Local Civil Rule 6.3 governs reconsideration and sets its own limits: briefs in support of and in response to the motion may not exceed 3,500 words, and reply briefs may not exceed 1,750 words, with the same exclusions and the same certificate requirement. A reconsideration brief drafted to the 8,750-word ceiling is two and a half times over the operative limit.

The individual-practice layer, which is where the real limit usually lives

The joint rule is a ceiling, not a floor, and Southern District judges set their own. Two verified examples, both read today from the court’s own practice documents.

Judge Andrew L. Carter, Jr., in individual practices dated March 18, 2025: “A memorandum of law, in support of or in opposition to any motion, is limited to 25 pages and reply briefs should be no longer than 10 pages.” Pre-motion conference letters are capped at three pages, “exclusive of letterhead and signature block(s),” for both the moving and the opposing party.

Judge Arun Subramanian, in individual practices revised May 11, 2026, takes the opposite drafting approach: the practices point to “Local Civil Rule 7.1(c) for all requirements” on memoranda and add that the Court “will rarely grant requests” to expand the limits. Letters to chambers “may not exceed three pages in length,” and both a discovery letter-motion and an opposition letter are capped at three pages.

The practical rule: read the joint local rule for the ceiling, then read the assigned judge’s current individual practices for the number you are actually drafting to. The two are amended on independent schedules.

Rule table

Requirement	Operative language	Source
Brief in support or response	“briefs in support of and in response to a motion (except for motions for reconsideration) may not exceed 8,750 words”	Joint Local Civil Rule 7.1(c) (SDNY and EDNY), ed. eff. Jan. 2, 2026
Reply brief	“reply briefs may not exceed 3,500 words”	Joint Local Civil Rule 7.1(c)
Pro se briefs	“briefs in support of and in response to a motion may not exceed 25 pages, and reply briefs may not exceed 10 pages”	Joint Local Civil Rule 7.1(c)
Word-count certificate	“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”	Joint Local Civil Rule 7.1(c)
Exclusions and inclusions	“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.”	Joint Local Civil Rule 7.1(c)
Type size	“all text must be 12-point type or larger, except for text in footnotes”	Joint Local Civil Rule 7.1(b)
Reconsideration	3,500 words in support or response; 1,750 words on reply; same exclusions and certificate	Joint Local Civil Rule 6.3
Bankruptcy appeals	“appellate briefs on bankruptcy appeals must comply with the briefing format and length specifications set forth in Federal Rules of Bankruptcy Procedure 8015 to 8017”	Joint Local Civil Rule 7.1(d)
Letter-motions	“Applications for extensions or adjournments, applications for a premotion conference, and similar nondispositive matters may be brought by letter-motion.”	Joint Local Civil Rule 7.1(e)
Judge-specific override (example)	“A memorandum of law, in support of or in opposition to any motion, is limited to 25 pages and reply briefs should be no longer than 10 pages.”	Individual Practices of Judge Andrew L. Carter, Jr. (SDNY), Mar. 18, 2025

Drafting-ready text: certificate of compliance under Local Civil Rule 7.1(c)

Attach this as the last page of the brief. Adapt the bracketed material.

CERTIFICATE OF COMPLIANCE WITH LOCAL CIVIL RULE 7.1(c)

I, [COUNSEL], an attorney admitted to practice before this Court and counsel of record for [PARTY], certify as follows:

1. This [Memorandum of Law in Support of / Memorandum of Law in Opposition to / Reply Memorandum of Law in Further Support of] [MOTION] was prepared using [WORD PROCESSING PROGRAM AND VERSION] in [FONT], 12-point type, with footnotes in no smaller than 10-point type, double-spaced, with margins of not less than one inch on all four sides.

2. Excluding the caption, any index, the table of contents, the table of authorities, the signature block, and this certificate, and including all material contained in footnotes and endnotes, this memorandum contains [NUMBER] words as counted by the word-count function of that program.

3. That total does not exceed the [8,750-word limit for briefs in support of and in response to a motion / 3,500-word limit for reply briefs] set by Local Civil Rule 7.1(c). [For reconsideration: the 3,500-word limit for briefs in support of and in response to a motion for reconsideration / the 1,750-word limit for reply briefs set by Local Civil Rule 6.3.]

4. This memorandum also complies with the length limitation set by the Individual Practices of [JUDGE], dated [DATE]. [Omit if the assigned judge sets no separate limit.]

Dated: [CITY], New York
[DATE]

_______________________________
[COUNSEL]
[FIRM, ADDRESS, TELEPHONE, EMAIL]

Worked example: what 8,750 words actually buys you

Take a summary judgment brief in the Southern District. A double-spaced page in 12-point type with one-inch margins typically holds roughly 250 to 300 words. So 8,750 words is about 29 to 35 pages, and 3,500 words on reply is about 12 to 14 pages.

Now apply Judge Carter’s 25-page limit to the same brief. At 250 to 300 words per page, 25 pages is roughly 6,250 to 7,500 words, which is 1,250 to 2,500 words below the joint rule’s ceiling. His 10-page reply limit is roughly 2,500 to 3,000 words against the rule’s 3,500. Drafting to the local rule and then discovering the individual practice means cutting between one and three full pages of argument at the end, which is where the cuts are worst.

Budget the other direction. Assume the operative ceiling is 8,750 words. Reserve 600 words for the preliminary statement, 1,800 for the statement of undisputed facts keyed to the Rule 56.1 statement, 300 for the standard of review, and 350 for the conclusion. That leaves about 5,700 words of argument. Across four causes of action, that is roughly 1,425 words per count, or about five double-spaced pages each. If one count will not compress below 2,500 words, that is the signal to seek leave before drafting, not to shave the strongest argument at midnight.

Cross-jurisdiction contrast

New York state court. Section 202.8-b of the Uniform Civil Rules limits computer-prepared “attorney affidavits, or affirmations, and memoranda of law in chief” to 7,000 words each, and “reply attorney affidavits, or affirmations, and memoranda of law” to 4,200 words each. The count “shall exclude the caption, table of contents, table of authorities, and signature block,” and a certification of the word count must be attached at the end of the document. So a motion that would fit in federal court in Manhattan at 8,750 words is 1,750 words over the state limit across the street, and the state rule caps affidavits as well as briefs.

California state court. California still limits by pages. Rule of Court 3.1113(d) provides that “no opening or responding memorandum may exceed 15 pages. In a summary judgment or summary adjudication motion, no opening or responding memorandum may exceed 20 pages. No reply or closing memorandum may exceed 10 pages.” Subdivision (g) supplies the consequence: an over-length memorandum “must be filed and considered in the same manner as a late-filed paper.” There is no word-count certificate to file, because there is no word count.

Bankruptcy appeals. Local Civil Rule 7.1(d) routes these away from the 8,750-word limit entirely. Federal Rule of Bankruptcy Procedure 8015 allows a principal brief that “contains no more than 13,000 words,” a reply brief of “no more than half the type volume specified” for a principal brief, and a certificate stating “the number of words, or the number of lines of monospaced type, in the document.” A district judge may order otherwise, so check the appeal’s docket before relying on 13,000.

Pre-filing checklist

• Confirm which rule applies: Local Civil Rule 7.1(c) for ordinary motions, Local Civil Rule 6.3 for reconsideration, Local Civil Rule 7.1(d) and FRBP 8015 for bankruptcy appeals.
• Confirm the number: 8,750 words in support or response, 3,500 on reply. Reconsideration: 3,500 and 1,750.
• Pull the assigned judge’s current individual practices and note any page or word limit that is lower than the joint rule. Draft to the lower number.
• Check the individual practices for a pre-motion conference requirement and its own letter page limit before you draft the brief at all.
• Run the word count with footnotes and endnotes included, and with the caption, index, tables, signature block, and certificates excluded.
• Verify 12-point type in the body, no smaller than 10-point in footnotes, margins of at least one inch, double-spaced text.
• Attach the Rule 7.1(c) certificate of compliance stating the actual word count.
• Confirm the certificate names the correct limit, including the individual practice limit if one applies.
• Confirm the notice of motion identifies the rules relied on and the relief sought.
• If the brief will exceed the operative limit, seek leave before the filing date rather than filing long.

SDNY and EDNY motion drafting

The hardest version of this problem is a summary judgment brief that has to reach four counts, carry a Rule 56.1 statement, and land inside a judge’s 25-page individual practice limit rather than the joint rule’s 8,750 words. Compressing that without losing the argument is a drafting job, not an editing job. LegalBriefsUSA drafts Southern District and Eastern District of New York memoranda, Rule 56.1 statements, reply briefs, and the Rule 7.1(c) certificate of compliance, drafted to the assigned judge’s current individual practices rather than to the joint rule alone. If you have a brief that runs 11,000 words with a filing date that will not move, that is the document to send us.

Related reading: New York state motion word limits under 202.8-b, appellate brief word limits compared, summary judgment timing in three systems, and motion drafting services for attorneys.

Authorities cited

Joint Local Civil Rules of the United States District Courts for the Southern and Eastern Districts of New York, Rules 6.3, 7.1(a), 7.1(b), 7.1(c), 7.1(d), and 7.1(e), edition effective January 2, 2026, read in the court’s own PDF at nysd.uscourts.gov, with the January 2, 2025 edition read at nysd.uscourts.gov to confirm the word-based limits were already in force in that edition and are unchanged. Individual Practices of Judge Andrew L. Carter, Jr., dated March 18, 2025, and Individual Practices in Civil Cases of Judge Arun Subramanian, revised May 11, 2026, read in the practice documents posted at nysd.uscourts.gov. Federal Rule of Bankruptcy Procedure 8015, read at law.cornell.edu. 22 NYCRR 202.8-b, read at law.cornell.edu. California Rules of Court, rule 3.1113(d) and (g), read at courts.ca.gov. Left out for lack of verification: the Central District of California word limit under Local Rule 11-6.1, because the court’s current local rules PDF would not render its text today; the specific page-limit numbers in the July 1, 2024 edition of Local Civil Rule 7.1; and any case law applying these limits, because no opinion was opened and read in the course of preparing this article.

LegalBriefsUSA.com provides drafting and research support to licensed attorneys and law firms. This article is written for attorneys, is not legal advice, and does not create an attorney-client relationship.