Sanket J. Bulsara

United States District Court for the Eastern District of New York Appointed by Joe Biden (Democratic) 8 signed orders read

How Judge Bulsara decides

Patterns drawn from this judge's own signed orders. Every observation links to the order it came from.

What persuades

Reconsideration is an 'extraordinary' remedy. He will not entertain new arguments or new case authority that could have been raised in the original briefing, and disagreement with the result ('mere carping after having lost') is not a ground. Bring controlling decisions or overlooked data the first time.

“Reconsideration is 'an extraordinary request that is granted only in rare circumstances ...' It 'is not a vehicle for relitigating old issues, presenting the case under new theories, securing a rehearing on the merits, or otherwise taking [another] bite at the apple.'”

He distinguishes substance from form on the party-presentation rule: a court may cite governing authorities the parties never briefed, because the rule limits the issues/arguments a court decides, not the cases it may rely on to construe the law on an issue properly before it.

“The party presentation principle applies to arguments or issues, not cases. ... 'When an issue or claim is properly before the court, the court ... retains the independent power to identify and apply the proper construction of governing law.'”

Procedural preferences

Before the 'drastic' sanction of striking an answer or entering default, he demands the full procedural predicate: a finding of willfulness/bad faith/fault, consideration of lesser sanctions, and clear prior notice/warning TO THE DISOBEDIENT PARTY. An order merely directing the moving party to file a motion to strike is NOT notice to the defendant.

“An order directing the party entitled to discovery to file a motion to strike ... is not a warning to the disobedient party. ... Parties must be given notice and an opportunity to respond before a cause of action, or potential remedy, is dismissed as a sanction for failure to comply with court orders.”

He enforces service rules to the letter: a Rule 45 subpoena on a corporation must be served by a Rule 4 method on an authorized agent, and a Rule 4(m) failure to serve within 90 days (absent good cause) draws a mandatory dismissal after notice. Get service and proof-of-service right.

“In the absence of good cause, dismissal of the Complaint is mandatory. ... Accordingly, the Complaint is dismissed without prejudice against Defendants”

Cautions

Do not move to strike a corporate defendant's answer as a back-door to default: he notes striking is not the right vehicle because it does not produce the entry of default that is the prerequisite to a default judgment -- seek an entry of default for failure to defend (Rule 55(a)) instead.

“seeking to strike the answer is not the appropriate means of achieving the ultimate goal of obtaining a default judgment, since it would not result in an entry of default, the prerequisite to a default judgment.”

Motion outcomes

Counted from classified signed orders only. Percentages are shown only where the sample is large enough to be meaningful; smaller samples are reported as raw counts.

Motions to strike
N = 2
Denied: 2 counts only
Motion to enforce settlement
N = 1
Granted: 1 counts only
Motion to seal
N = 1
Granted: 1 counts only
Motions to compel
N = 1
Denied: 1 counts only
Motion for reconsideration
N = 1
Denied: 1 counts only
Motion to lift stay
N = 1
Granted: 1 counts only
Motion to reinstate
N = 1
Denied: 1 counts only
Motions to dismiss
N = 1
Granted: 1 counts only

A "1 of 1" is one ruling, not a tendency. Treat small samples as illustrative, not predictive.

Signed rulings

A grounded sample of orders signed by this judge, with the verbatim dispositive language.

Ferenczi v. City of New York
1:18-cv-03352 · 2019-08-14
Motions to compel (defendant) Denied

“The motion to compel is denied without prejudice to renewal.”

Patel v. Long Island University
1:17-cv-02170 · 2023-07-31
Motion to enforce settlement (defendant) Granted

“it is respectfully recommended that LIU's motion for settlement enforcement be granted and the parties be directed to perform the settlement”

Motion to seal (defendant) Granted

“Separately, the motion to seal is granted.”

Orrego v. Knipfing
2:20-cv-03361 · 2025-03-03
Motion to lift stay (plaintiff) Granted

“The motion to life the stay is granted.”

Motion to reinstate (plaintiff) Denied

“The motion to reinstate Plaintiff's prior motions is denied.”

Luce v. Aon Service Corporation
2:24-cv-08195 · 2025-09-11
Motions to dismiss (defendant) Granted

“the Court grants Nationwide's motion to dismiss with prejudice as to the claims against Nationwide only.”

Keith v. Austin Coins, Inc.
2:24-cv-00206 · 2025-09-18
Motions to strike (plaintiff) Denied

“The motion to strike White's answers is denied.”

Motions to strike (plaintiff) Denied

“For the reasons below, both motions are denied. ... Without proper notice and warning, a motion to strike cannot be granted.”

Gagliano v. United States
2:24-cv-07930 · 2026-01-20
Motion for reconsideration (defendant) Denied

“The motion for reconsideration is denied.”

Murcia Guardado v. El Mango Deli Grocery Corp.
2:23-cv-03643 · 2025-12-09

FLSA collective action. After plaintiffs' counsel withdrew pre-trial and plaintiffs went silent for >4 months, Magistrate Judge Shields issued a SUA SPONTE R&R recommending dismissal with prejudice for failure to prosecute (Rule 41(b)). District Judge Bulsara, finding no clear error and no objections, ADOPTED the R&R and dismissed with prejudice. Non-motion disposition: counted as an order read, excluded from motion stats. Grounding quote: 'the R&R is adopted in its entirety and the case is dismissed with prejudice for failure to prosecute.'

Lawrence v. Larry Flowers Group, P.C.
2:25-cv-00221 · 2025-06-16

Pro se case. As DISTRICT JUDGE, Bulsara dismissed the complaint SUA SPONTE under Fed. R. Civ. P. 4(m) for failure to serve within 90 days, after twice ordering service and warning of dismissal. No party motion -- court acted on its own. Counted as an order read, excluded from motion stats. Grounding quote: 'the Complaint is dismissed without prejudice against Defendants Larry Flowers Group, P.C. and Larry E. Flowers.'

Caseload & timing

From public federal docket records for this judge.

Case-level snapshot from a 20-docket search_dockets sample of his DISTRICT-JUDGE assignments (all filed 2026, sitting in Central Islip / 2:26-cv dockets, all still PENDING). Nature-of-suit mix: a 2026 surge of 463 Habeas Corpus - Alien Detainee petitions (Martinez Canales, Nazarenko, Inestroza Carbajal, Yeleshev v. LaRocco), plus FLSA labor (Aguilar Gonzalez, Campbell, Bueso Lopez), civil-rights/jobs (Godec, Salembier), consumer/financial (Calderon v. Experian, Dash v. Goldman Sachs), Social Security, contract, USCIS/immigration mandamus, and two miscellaneous (mc) matters.