In rules amended last week (redline here), Judge Carter became the latest judge in a growing trend, especially among more recent appointees, to require that the basic grounds for a motion to dismiss be presented either by letter or at a pre-motion conference, after which the opposing party can either amend immediately or risk losing a chance to amend after a ruling.   By our count, the nine judges with this type of procedure are Judge Baer, Judge Berman, Judge Briccetti, Judge Carter, Judge Engelmayer, Judge Furman, Judge Marrero, Judge Nathan and Judge Oetken.