Court Rules

New York Supreme Court, Bronx County Pre-Motion Conference Requirements

84 rules from official source documents

47 of 84 checked against the court's document. Each rule says how far it was checked. A value with a question mark is not in the court's wording on its card.

Pre-motion conference and letter requirements before filing motions, including sequential steps. This page is scoped to New York Supreme Court, Bronx County; use the court rules overview to switch categories without leaving this court.

Checked against the court's document on Oct 5, 2026CRITICAL

Civil cases

Before filing any discovery-related motion, parties must request both a Discovery Conference and a Motion Scheduling Order from the Court.

Parties shall request a Discovery Conference with the Court AND a Motion Scheduling Order BEFORE the filing of any discovery-related motion (BxSupCiv-IA5@nycourts.gov).

Judge Alison Tuitt

Checked against the court's document on Oct 5, 2026CRITICAL

Civil cases

A discovery-related motion filed before the Motion Scheduling Order is issued will be denied.

Discovery-related motions made prior to the Motion Scheduling Order being issued will be denied.

Judge Alison Tuitt

Checked against the court's document on Oct 5, 2026CRITICAL

Civil cases

No motions in this Part may be submitted without oral argument, and every motion must be orally argued without exception.

There are NO SUBMITTED MOTIONS IN THIS PART, AND ALL MOTIONS WITHOUT EXCEPTION MUST BE ORALLY ARGUED.

Judge Alison Tuitt

Checked against the court's document on Oct 5, 2026CRITICAL

Civil cases

A discovery motion must be supported by counsel's affidavit or affirmation and requires the Court's permission to file.

Discovery motions shall be supported by an affidavit or affirmation from counsel, as set forth in 22 NYCRR 202.20-f and require permission from the Court.

Judge Bianka Perez

Checked against the court's document on Oct 5, 2026CRITICAL

Civil cases

Oral argument is mandatory for discovery-dispute motions and must follow full submission of the motion to the Motion Support Office.

Oral argument of motions regarding disclosure disputes are mandatory and, after the motion is fully submitted in the Motion Support Office, Room 217, shall be scheduled and held in person in Part 30 on Thursdays or Fridays at 9:30 a.m. or 2:30 p.m.

Judge Erik L. Gray

Checked against the court's document on Oct 5, 2026CRITICAL

Each party ordinarily receives only one opportunity to move for summary judgment unless sufficient justification is shown or the court previously authorizes another opportunity.

Unless sufficient justification is demonstrated, or unless expressly authorized by the Court in a prior order, each party shall be afforded only one opportunity to make a motion for summary judgment.

Judge Erin Noelle Guven

Checked against the court's document on Oct 5, 2026CRITICAL

The discovery pre-motion letter must identify the specific disputes and describe the parties' good-faith resolution efforts.

The letter shall set forth the specific discovery issue(s) to be addressed at the conference and the details of their good faith efforts to resolve the dispute prior to seeking Court intervention.

Judge Erin Noelle Guven

Checked against the court's document on Oct 5, 2026CRITICAL

A discovery motion may not be combined with a request for other relief.

Discovery motions shall not be combined with requests for any other relief.

Judge Erin Noelle Guven

Checked against the court's document on Oct 5, 2026CRITICAL

Filing a motion does not stay discovery; any discovery stay must be requested in a separate request.

The filing of any motion shall NOT stay discovery. A stay of discovery must be requested separately.

Judge Erin Noelle Guven

Checked against the court's document on Oct 5, 2026CRITICAL

Civil cases

A discovery motion filed without a prior Rule 14 Conference will be held in abeyance until the conference occurs.

Discovery motions made absent a prior Rule 14 Conference will be held in abeyance until such a conference is held.

Judge Fidel Gomez

Checked against the court's document on Oct 5, 2026CRITICAL

Civil cases

If good-faith efforts do not resolve a discovery dispute, the parties must submit a Rule 14 Conference request letter describing the dispute and resolution efforts through NYSCEF.

If a dispute cannot be resolved after such good faith effort, the parties must submit a letter requesting a Rule 14 conference and advising the Court of the nature of the dispute and the efforts made to resolve it. The request must be submitted to the Court via NYSCEF.

Judge Fidel Gomez

Checked against the court's document on Oct 5, 2026CRITICAL

Civil cases

A sur-reply may not be submitted without leave of court.

No sur-replies shall be submitted absent leave of court.

Judge Fidel Gomez

Checked against the court's document on Oct 5, 2026CRITICAL

Civil cases

An order-to-show-cause application must demonstrate a need for exigent or urgent relief or it will not be signed.

22 NYCRR 202.8-d is strictly enforced and an application brought by Order to Show Cause that fails to demonstrate that exigent or urgent relief is required will be not be signed.

Judge Fidel Gomez

Checked against the court's document on Oct 5, 2026CRITICAL

Civil cases

Orders to Show Cause are generally returnable on Wednesdays, other than court holidays or as otherwise indicated, and appearances are required.

All Orders to Show Cause are returnable on Wednesdays, except for court holidays, unless otherwise indicated. Appearances are required.

Judge Fidel Gomez

Checked against the court's document on Oct 5, 2026CRITICAL

Civil cases

Before seeking judicial intervention, the parties must consult in good faith to try to resolve all discovery disputes.

Accordingly, pursuant to 22 NYCRR 202.20-f(b), before seeking judicial intervention, the parties must first consult with one another in a good faith effort to resolve all discovery disputes.

Judge Fidel Gomez

Checked against the court's document on Oct 5, 2026CRITICAL

Before filing a discovery motion, the parties must follow 22 NYCRR 202.20-f; if the dispute persists, they must seek a Tuesday pre-motion conference by email with a letter describing the issues and resolution attempts.

With respect to any discovery-related disputes, the parties will adhere to 22 NYCRR 202.20-f before filing a motion; if the dispute persists, the parties shall make an application for a pre-motion conference, which will be scheduled on the Tuesday calendar for the part. Such applications shall be made via email to fserrano@nycourts.gov. The parties shall attach a letter to said email specifying the issues and attempts made to resolve such disputes.

Judge Marissa Soto

Checked and corrected to match the court's document on Oct 5, 2026CRITICAL

A motion to withdraw as counsel will not be decided unless there is a noticed appearance before the Court.

No motions to withdraw as counsel will be decided without a noticed appearance before the Court.

Judge Marissa Soto

Checked against the court's document on Oct 5, 2026CRITICAL

Discovery motions are highly discouraged and may be filed only with the Court’s permission after the required steps and a conference with the Court.

Discovery motions are highly discouraged and require the Court’s permission to file. The parties may not file a discovery motion prior to following the above steps and conferencing with the Court.

Judge Mary Lynn Nicolas-Brewster

Checked against the court's document on Oct 5, 2026CRITICAL

The parties must appear at a preliminary conference if the Part Clerk does not receive a completed proposed order at least two business days beforehand.

Appearances on all P.C.’s are required if a completed proposed P.C. Order is not received by the part clerk at least two (2) business days prior to the scheduled P.C.

Judge Matthew Parker-Raso

Checked and corrected to match the court's document on Oct 5, 2026CRITICAL

In-person appearances are mandatory at all compliance and status conferences.

In Person appearances at all Compliance Conferences and Status Conferences are mandatory.

Judge Matthew Parker-Raso

Checked against the court's document on Oct 5, 2026CRITICAL

Civil cases

Discovery motions are highly discouraged and require court permission; counsel must make good-faith efforts to resolve disputes and seek a court conference before filing a discovery motion.

Discovery Motions are highly discouraged and require the Court’s permission to file. Pursuant to 22 NYCRR 202.20-f, discovery disputes should be resolved through informal procedures, such as conferences, to the maximum extent possible. Prior to the submission of any motions on discovery-related matters, counsels must first seek a conference with the Court to resolve discovery disputes. Prior to seeking a conference with the Court, parties must make good faith efforts to resolve disputes without Court intervention.

Judge Paul Alpert

Checked against the court's document on Oct 5, 2026CRITICAL

Civil cases

Every discovery motion requires oral argument.

All discovery motions shall require oral argument.

Judge Paul Alpert

Checked against the court's document on Oct 5, 2026CRITICAL

Civil cases

Parties should resolve discovery disputes through informal procedures and must seek a court conference before filing any discovery-related motion.

To the maximum extent possible, discovery disputes should be resolved through informal procedures, such as conferences, as opposed to motion practice (22 NYCRR 202.20-f [a]). Parties shall seek a conference with the Court BEFORE the filing of any discovery-related motion (BxSupCiv-IA35@nycourts.gov).

Judge Raymond P. Fernandez

Checked and corrected to match the court's document on Oct 5, 2026CRITICAL

A party must file an RJI for a motion under CPLR §3211 and may file an RJI after service of process to request a preliminary conference.

A party must file an RJI, for any motion filed pursuant to CPLR §3211 or a party may file an RJI at any time after service of process to request a Preliminary Conference.

Judge Shawn T. Kelly

Checked against the court's document on Oct 5, 2026CRITICAL

Civil cases

All motions must be brought by Order to Show Cause, and parties must request a conference before filing motion papers; good-faith consultation with one another is strongly suggested.

ALL MOTIONS SHALL BE BY ORDER TO SHOW CAUSE Parties must request a conference prior to filing any motion papers to allow the opportunity to resolve the matter. It is strongly suggested that parties consult one another in a good faith effort to resolve any disputes prior to requesting a conference with the Court.

Judge Veronica Romero Guerrero

Checked and corrected to match the court's document on Oct 5, 2026CRITICAL

Civil cases

Oral argument is required for every Order to Show Cause unless the court directs otherwise.

Oral argument is required on all Orders to Show Cause unless otherwise directed by the Court.

Judge Veronica Romero Guerrero

Checked against the court's document on Oct 5, 2026CRITICAL

Civil cases

Parties must request a conference before filing any discovery motion.

As with all other motions, parties must request a conference prior to filing any discovery motions.

Judge Veronica Romero Guerrero

Checked against the court's document on Oct 5, 2026CRITICAL

A discovery motion requires a prior request for a pre-motion conference.

Discovery motions may not be filed without first requesting a pre-motion conference.

Judge Wilma Guzman

Checked against the court's document on Oct 5, 2026WARNING

Civil cases

Before filing a discovery motion, counsel should consult in good faith to try to resolve the discovery dispute.

Prior to making a discovery motion, Counsel should consult one another in a good faith effort to resolve any discovery disputes in compliance with Uniform Rule § 202.7(a)(2).

Judge Alicia Gerez

Checked and corrected to match the court's document on Oct 5, 2026WARNING

Civil cases

An Order to Show Cause is decided on submission unless the Court specifically schedules oral argument or a conference.

Orders to Show Cause are decided “on submission” unless specifically scheduled for oral argument/conference before the Court.

Judge Bianka Perez

Checked and corrected to match the court's document on Oct 5, 2026WARNING

Civil cases

Oral argument is generally not permitted for summary-judgment and other substantive motions, but a party may request it and the court will decide case by case.

Oral argument of motions for summary judgment and other substantive motions will generally not be permitted (see 22 NYCRR 202.8-f), however, parties may request oral argument of a motion pursuant to 22 NYCRR 202.8-f (b). Requests for oral argument shall be decided on a case-by- case basis, pursuant to 22 NYCRR 202.8-f (a).

Judge Erik L. Gray

Checked against the court's document on Oct 5, 2026WARNING

Non-discovery motions are decided on submission unless the court notifies the parties that oral argument or a conference has been scheduled.

All motions (other than discovery motions) will be decided “on submission” unless the Court notifies the parties that the matter has been scheduled for oral argument/conference before the Court.

Judge Erin Noelle Guven

Checked and corrected to match the court's document on Oct 5, 2026WARNING

Civil cases

Anticipated or pending motions in limine must be disclosed to the court; jury-selection motions must be made orally before jury selection, other motions in limine must be made orally before or during trial, and written submission is not required unless the court directs otherwise.

Apprise the Court of any anticipated/pending motions in limine. If a motion in limine concerns jury selection, it is to be made orally prior to jury selection. If a motion in limine does not concern jury selection, it is to be made orally prior to the commencement of or during the trial. The parties are not required to submit any motions in limine in writing, unless otherwise directed by the Court.

Judge Fidel Gomez

Checked and corrected to match the court's document on Oct 5, 2026WARNING

Motions are ordinarily decided on submission unless the Court specifically schedules oral argument or a conference.

All motions will be decided “on submission” unless specifically scheduled for oral argument/conference before the Court.

Judge Mary Ann Brigantti

Checked and corrected to match the court's document on Oct 5, 2026WARNING

Civil cases

Motions are ordinarily decided on submission unless the court schedules oral argument or a conference.

All motions will be decided “on submission” unless the Court notifies the parties that the matter has been scheduled for oral argument/conference before the Court.

Judge Paul Alpert

Checked and corrected to match the court's document on Oct 5, 2026WARNING

Before a preliminary or compliance conference, all counsel must consult and make a good-faith effort to agree about case resolution, discovery and conference issues, possible ADR, and voluntary exchanges that could promote early settlement.

In compliance with 22 NYCRR §202.23, counsel for all parties shall consult prior to a preliminary or compliance conference about: Resolution of the case, in whole or in part. Discovery and other issues to be discussed at the conference. Use of alternative dispute resolutions (ADR) to resolve all or some of the issues Any voluntary exchange that could assist in early settlement of the case. Counsel must make a good faith effort to reach agreement on these matters prior to the conference.

Judge Shawn T. Kelly

Checked against the court's document on Oct 5, 2026WARNING

The Court will schedule a conference after a discovery-related motion, including a motion to dismiss or strike pleadings based on a discovery violation.

Upon the filing of a discovery-related motion (including any motion to dismiss or strike pleadings based on a discovery violation) the Court will schedule a conference to facilitate resolution of the dispute.

Judge Wilma Guzman

Checked against the court's document on Oct 5, 2026WARNING

The return date in a motion is not the oral-argument date; the Part Clerk schedules oral argument after the return date.

The return date set forth in a motion is NOT the date for oral argument. Oral argument is scheduled by the Part Clerk following the return date.

Judge Wilma Guzman

Checked against the court's document on Oct 5, 2026INFO

Civil cases

If good-faith efforts do not resolve a discovery dispute, the Court strongly encourages an application for a pre-motion conference addressing the dispute and other discovery issues.

If the parties are unable to resolve a discovery dispute after good faith efforts, the Court strongly encourages that an application be made for a pre-motion conference to discuss the discovery dispute and all other discovery issues in the case.

Judge Alicia Gerez

Checked and corrected to match the court's document on Oct 5, 2026INFO

Civil cases

Motions are ordinarily decided on submission unless the court specifically schedules oral argument or a conference by Microsoft Teams.

All motions will be decided “on submission” unless specifically scheduled for oral argument/conference before the Court via Microsoft Teams.

Judge Ben Barbato

Checked against the court's document on Oct 5, 2026INFO

A party may request oral argument by filing a letter with the motion papers and emailing the request to the listed chambers address.

Any party may request oral argument of a motion by letter accompanying the motion papers, pursuant to 22 NYCRR §202.8-f [b]. Such request must also be e-mailed to BXSUPCIV-IA17@nycourts.gov).

Judge Erin Noelle Guven

Checked against the court's document on Oct 5, 2026INFO

Parties scheduled for oral argument should keep a copy of their filed papers readily available to the Court.

If scheduled for oral argument, the parties should have a copy of their filed papers readily available for the Court.

Judge Erin Noelle Guven

Checked against the court's document on Oct 5, 2026INFO

Civil cases

Oral argument and a personal appearance are not required for a notice-of-motion matter unless the court directs them.

There shall be no oral argument or personal appearance required on any motion brought by notice of motion unless directed by the Court.

Judge Fidel Gomez

Checked and corrected to match the court's document on Oct 5, 2026INFO

Civil cases

Oral argument and a personal appearance are not required for a notice-of-motion motion unless the Court directs otherwise.

There shall be no oral argument or personal appearance required on any motion brought by notice of motion unless directed by the Court.

Judge Fidel Gomez

Checked against the court's document on Oct 5, 2026INFO

If granted, a discovery pre-motion conference will be scheduled virtually through Microsoft Teams, and the Court conducts discovery conferences as needed.

If the request for a pre-motion conference is granted, a virtual conference will be scheduled to take place via Microsoft Teams. The Court conducts discovery conferences on an AS NEEDED BASIS.

Judge Mary Lynn Nicolas-Brewster

Checked against the court's document on Oct 5, 2026INFO

Civil cases

A party may request oral argument by submitting a letter with the motion papers and emailing the request to the court at the stated address.

Any party may request oral argument of a motion by letter accompanying the motion papers, pursuant to 22 NYCRR § 202.8-f (b) and also email at BxSupCiv-IA26@nycourts.gov.

Judge Paul Alpert

Checked against the court's document on Oct 5, 2026INFO

Civil cases

Pendente lite issues may be resolved at the preliminary conference.

Pendente lite issues may be resolved at the preliminary conference.

Judge Veronica Romero Guerrero

Not confirmed. Read the court's wording below.CRITICAL?

Unless otherwise directed, the moving party shall try to resolve contemplated non-dispositive motion practice informally through a telephone or virtual conference with the Special Referee. The moving party shall involve this informal resolution process by written notice to the Referee and all parties. The moving party must also contact the Referee to schedule a phone or virtual conference on the application.

Summary: Unless otherwise directed, the moving party must attempt informal resolution of contemplated non-dispositive motion practice through notice to the Referee and all parties and by contacting the Referee to schedule a phone or virtual conference.

Court-level rulesOfficial source

Not confirmed. Read the court's wording below.CRITICAL?

Unless the referring Justice directs otherwise, the parties shall schedule a phone or virtual conference with the Referee to set the procedure for filing a formal motion under the circumstances.

Summary: Unless the referring Justice directs otherwise, the parties must schedule a phone or virtual conference with the Referee to establish the procedure for filing a formal motion.

Court-level rulesOfficial source

Not confirmed. Read the court's wording below.CRITICAL?

Civil cases

All discovery-related conferences will be heard in person without exception.

Summary: All discovery-related conferences must be held in person without exception.

Judge Alison Tuitt

Not confirmed. Read the court's wording below.CRITICAL?

Civil cases

Prior to the submission of any motions on discovery-related matters, counsels must first seek a conference with the Court to resolve discovery disputes. Prior to seeking a conference with the Court, parties must make good faith efforts to resolve disputes without Court intervention.

Summary: Before filing a discovery-related motion, counsel must make good-faith efforts to resolve the dispute and then seek a conference with the Court.

Judge Bianka Perez

We could not find this wording in the court's document. Open the source before relying on it.CRITICAL?

Parties shall attempt to resolve all discovery disputes through informal procedures, as opposed to motion practice, pursuant to 22 NYCRR §202.20-f[a].

Machine summary

Parties must first attempt to resolve discovery disputes through informal procedures rather than motion practice.

We could not find this wording in the court's document. Open the source before relying on it.CRITICAL?

Prior to filing a discovery motion, parties shall request a pre-motion conference via letter request filed to NYSCEF and e-mailed to BxSupCiv-IA17@nycourts.gov.

Machine summary

Before filing a discovery motion, a party must request a pre-motion conference by filing a letter request to NYSCEF and emailing it to the listed chambers address.

Not confirmed. Read the court's wording below.CRITICAL?

Failure to adhere to either section will result in denial of the motion, without prejudice to renew on proper papers.

Summary: Failure to comply with the cited discovery-conference requirements results in denial without prejudice and may be renewed with proper papers.

Judge Erin Noelle Guven

Not confirmed. Read the court's wording below.CRITICAL?

The Court will schedule an in-person appearance for oral argument on ALL discovery motions made in compliance with these rules.

Summary: The Court will schedule an in-person oral-argument appearance for every compliant discovery motion.

Judge Erin Noelle Guven

Not confirmed. Read the court's wording below.CRITICAL?

Civil cases

Pursuant to Commercial Division Rule 14, the parties must first consult with one another in a good faith effort to resolve all discovery disputes.

Summary: Before seeking a Rule 14 Conference, the parties must consult in good faith to resolve their discovery disputes.

Judge Fidel Gomez

Not confirmed. Read the court's wording below.CRITICAL?

Civil cases

The procedure prescribed by Commercial Division Rule 24 must be followed before any qualifying motion is made, including those promulgated by Rules 14 and 24. This Rule shall not apply to motions listed in Rule 24(b) and those made pursuant to CPLR § 3215.

Summary: Commercial Division Rule 24 procedure must be followed before a qualifying motion, but it does not apply to Rule 24(b) motions or CPLR § 3215 motions.

Judge Fidel Gomez

Not confirmed. Read the court's wording below.CRITICAL?

Civil cases

In the spirit of 22 NYCRR 202.20-f(a), discovery motions made prior to a conference with the Court will be held in abeyance until such conference is held.

Summary: Discovery motions filed before a conference with the Court are held in abeyance until the conference occurs.

Judge Fidel Gomez

Not confirmed. Read the court's wording below.CRITICAL?

Civil cases

If a dispute cannot be resolved after such good faith effort, the parties must follow the protocol prescribed by Commercial Division Rule 14 (202 NYCRR 202.70), which, inter alia, requires that the party seeking judicial intervention submit a letter requesting a conference and advising the Court of the nature of the dispute and the efforts made to resolve it.

Summary: If good-faith consultation fails, the party seeking judicial intervention must submit a letter requesting a conference and describing the dispute and resolution efforts.

Judge Fidel Gomez

Not confirmed. Read the court's wording below.CRITICAL?

A Discovery Motion shall only be made after the parties have conferred in good faith.

Summary: A party may file a discovery motion only after conferring in good faith with the party from whom discovery is sought.

Judge Mary Ann Brigantti

Not confirmed. Read the court's wording below.CRITICAL?

A party has not fulfilled its obligation to confer pursuant to 22 NYCRR 202.20-f unless they have spoken over the phone or have met virtually or in-person with the party from whom the moving party is requesting discovery.

Summary: A conference ordinarily requires a telephone, virtual, or in-person meeting with the party from whom discovery is requested.

Judge Mary Ann Brigantti

Not confirmed. Read the court's wording below.CRITICAL?

Emails alone do not satisfy the requirements of 22 NYCRR 202.20-f, unless the affirmation includes a history or an indication that the non-complying party has refused to communicate over the phone, virtually, or in-person.

Summary: Email exchange alone is insufficient unless the affirmation documents the communication history or the other party’s refusal to communicate by telephone, virtually, or in person.

Judge Mary Ann Brigantti

Not confirmed. Read the court's wording below.CRITICAL?

Every action shall have one preliminary conference (“P.C.”), one compliance conference (“C.C.”), and as many status conferences as are necessary, and parties shall consult prior to all preliminary, compliance, or status conferences, pursuant to 22 NYCRR 202.11.

Summary: Each discovery action must include a preliminary conference and compliance conference, additional status conferences as needed, and the parties must consult before each such conference.

Judge Matthew Parker-Raso

Not confirmed. Read the court's wording below.CRITICAL?

The parties may not file a discovery motion prior to following the above steps and conferencing with the Court.

Summary: A discovery motion may not be filed until the parties follow the stated informal dispute-resolution steps and conference with the court.

Judge Matthew Parker-Raso

Not confirmed. Read the court's wording below.CRITICAL?

The Court will schedule an in-person appearance on ALL discovery motions made in compliance with these rules. Discovery motions that do not strictly comply with the foregoing will result in the denial of the motion without prejudice, pursuant to 22 NYCRR 202.20-f (c).

Summary: The court will schedule an in-person appearance for every compliant discovery motion, while a noncompliant discovery motion will be denied without prejudice.

Judge Matthew Parker-Raso

Not confirmed. Read the court's wording below.CRITICAL?

Civil cases

If the parties are unable to resolve a discovery dispute after good faith efforts, an application shall be made for a pre-motion conference to discuss the discovery dispute and all other discovery issues in the case. The application shall be made via e-mail to BXMEDMAL-IA34@nycourts.gov and shall state the nature of the discovery dispute and the applicable law relative thereto.

Summary: After unsuccessful good-faith efforts, the parties must apply by email for a pre-motion conference that states the nature of the discovery dispute and the applicable law.

Judge Michael Frishman

Not confirmed. Read the court's wording below.CRITICAL?

discovery motion shall be supported by an affidavit or affirmation from counsel attesting to counsel having conducted an in-person or telephone conference, setting forth the date and time of such conference, persons participating and the length of time of the conference

Summary: A discovery motion must be supported by counsel’s affidavit or affirmation documenting an in-person or telephone conference, including its date, time, participants, and duration.

Judge Myrna Socorro

Not confirmed. Read the court's wording below.CRITICAL?

Civil cases

If the parties are unable to resolve a discovery dispute after good faith efforts, an application shall be made for a pre-motion conference to discuss the discovery dispute and all other discovery issues in the case.

Summary: When good-faith efforts fail to resolve a discovery dispute, the parties must apply for a pre-motion conference addressing the dispute and related discovery issues.

Judge Naita Semaj

Not confirmed. Read the court's wording below.CRITICAL?

Pursuant to 22 NYCRR 202.20-f(b), before seeking judicial intervention, the parties must first consult with one another in a good faith effort to resolve all discovery disputes. Note that letters and emails DO NOT constitute good faith efforts and parties must confer in person or telephonically. If a dispute cannot be resolved after such good faith effort, the party seeking judicial intervention must submit a letter requesting a conference and advising the Court of the nature of the dispute and the efforts made to resolve it. The request must be submitted to chambers by email.

Summary: Before seeking judicial intervention over discovery, the parties must confer in person or by telephone in good faith; letters and emails alone do not suffice, and an unresolved dispute must be described in a conference-request letter emailed to Chambers.

Judge Shawn T. Kelly

Not confirmed. Read the court's wording below.CRITICAL?

Discovery motions may not be filed until the parties have (i) conferred to attempt to resolve the dispute pursuant to 22 NYCRR § 202.7(a)(2), and (ii) participated in a pre-motion conference with the Court.

Summary: A discovery motion may not be filed until the parties have attempted to resolve the dispute and participated in a court pre-motion conference.

Judge Wilma Guzman

Not confirmed. Read the court's wording below.CRITICAL?

If, after making a good faith effort to resolve any discovery dispute, intervention of the Court is necessary, the parties shall file a letter to NYSCEF requesting a discovery conference containing a brief description of the issue. Discovery conferences are held in-person.

Summary: When court intervention is necessary after a good-faith discovery effort, the parties must file an NYSCEF letter requesting an in-person discovery conference and briefly describe the issue.

Judge Wilma Guzman

Not confirmed. Read the court's wording below.WARNING?

Civil cases

The application should be made via email to BxSupCiv-IA19A-30@nycourts.gov, state the nature of the discovery dispute and the applicable law relative thereto.

Summary: A discovery-dispute pre-motion conference application should be emailed to the Court and state the dispute's nature and applicable law.

Judge Alicia Gerez

Not confirmed. Read the court's wording below.WARNING?

Civil cases

Where possible, a conference will be scheduled by the Court if the issue cannot be otherwise resolved. If the discovery dispute is not resolved at the conference, a briefing schedule will be issued for the motion to be made.

Summary: If a discovery issue cannot otherwise be resolved, the Court may schedule a conference; if unresolved at that conference, the Court will issue a briefing schedule for the motion.

Judge Alicia Gerez

Not confirmed. Read the court's wording below.WARNING?

Civil cases

Prior to the submission of any motions on discovery-related matters, counsels are encouraged to first seek a conference with the Court to resolve discovery disputes.

Summary: Counsel is encouraged, but not required, to seek a court conference before submitting discovery-related motions.

Judge John A. Howard-Algarin

Not confirmed. Read the court's wording below.WARNING?

If the parties submit a completed proposed P.C. order at least two (2) business days prior to the scheduled P.C. to the Part Clerk email address, copying all parties, then the parties need not appear for the scheduled P.C. unless the court otherwise directs.

Summary: A timely completed proposed preliminary-conference order emailed to the Part Clerk with all parties copied relieves the parties from appearing unless the court directs otherwise.

Judge Matthew Parker-Raso

Not confirmed. Read the court's wording below.WARNING?

While highly discouraged, pursuant to 22 NYCRR 202.20-f (a), parties do not need leave of court to make a discovery motion.

Summary: Parties may file a discovery motion without leave of court, although the practice is highly discouraged.

Judge Matthew Parker-Raso

Not confirmed. Read the court's wording below.WARNING?

Oral arguments on any motion may be scheduled by the Court at the discretion of the Court (22 NYCRR §202.8-f). If the Court grants oral arguments, the Court will schedule the date for oral argument by a VIRTUAL CONFERENCE VIA MS-TEAMS. RECORDING OF ANY VIRTUAL COURT PROCEEDINGS, IS STRICTLY PROHIBITED.

Summary: The court may schedule oral argument on any motion at its discretion, and if granted, the argument will occur virtually by MS Teams; recording any virtual court proceeding is strictly prohibited.

Judge Myrna Socorro

Not confirmed. Read the court's wording below.WARNING?

Discovery motions are highly discouraged (22 NYCRR §202.20-f), as discovery disputes should be resolved through good faith efforts to resolve without Court intervention.

Summary: Discovery motions are highly discouraged because discovery disputes should first be resolved through good-faith efforts without court intervention.

Judge Myrna Socorro

Not confirmed. Read the court's wording below.WARNING?

If the parties, prior to filing such a motion prefer to seek an immediate status conference if the next in person conference is more than 90 days away, the parties should file a letter addressed to the Court and their adversary as to the discovery dispute, and also email the letter to BxSupCiv- IA33@nycourts.gov and copies to lbeato@nycourts.gov and mvaughan@nycourts.gov.

Summary: If the next in-person conference is more than 90 days away, the parties may file a discovery-dispute letter addressed to the court and adversary and email copies to the part and chambers.

Judge Myrna Socorro

Not confirmed. Read the court's wording below.WARNING?

Civil cases

Counsel shall be prepared to discuss, in detail, any discovery disputes, which will be resolved at the conference.

Summary: Counsel must be prepared to discuss discovery disputes in detail at the compliance conference, where those disputes will be resolved.

Judge Veronica Romero Guerrero

Not confirmed. Read the court's wording below.INFO?

Civil cases

For all motions other than summary judgment, parties are strongly encouraged to request a conference to discuss the dispute prior to filing the motion.

Summary: For motions other than summary judgment, parties are strongly encouraged to request a conference before filing.

Judge Alicia Gerez

Not confirmed. Read the court's wording below.INFO?

Counsel is encouraged to request a conference via email to BxSupCiv-IA28@nycourts.gov, cc'ing all counsel (and/or pro se litigants), prior to filing a motion. Such request shall include at least three proposed adjourn dates/times that work for all attorneys (and/or pro se litigants) on the case.

Summary: Counsel is encouraged, but not required, to request a pre-filing conference by email to the stated address, copy all counsel and pro se litigants, and provide at least three mutually available proposed dates and times.

Judge Sarah P. Cooper

Not confirmed. Read the court's wording below.INFO?

Upon receipt of an RJI made pursuant to 22 NYCRR §202.12(a), a Case Scheduling Order (“CSO”) will be automatically generated within 45 days and uploaded to NYSCEF in lieu of holding a conference.

Summary: After an RJI, the Court will generate and upload a Case Scheduling Order within 45 days instead of holding a preliminary conference.

Judge Shawn T. Kelly

Not confirmed. Read the court's wording below.INFO?

In lieu of filing a motion, a party may request a pre-motion conference by filing a letter with the Court through NYSCEF.

Summary: Instead of filing a discovery motion, a party may request a pre-motion conference by filing a letter through NYSCEF.

Judge Wilma Guzman
Common questions about New York Supreme Court, Bronx County pre-motion conference requirements

Does New York Supreme Court, Bronx County require a pre-motion conference or letter before filing a motion?

New York Supreme Court, Bronx County rules set a pre-motion procedure for covered motions. Unless otherwise directed, the moving party must attempt informal resolution of contemplated non-dispositive motion practice through notice to the Referee and all parties and by contacting the Referee to schedule a phone or virtual conference. Machine summary, not yet verified; check the linked order.

View ruleOfficial source Source: page 3, section Informal Non-Dispositive Motion Practice

Judge Paul Alpert's rules set a pre-motion procedure for discovery. Discovery motions are highly discouraged and require court permission; counsel must make good-faith efforts to resolve disputes and seek a court conference before filing a discovery motion.

View ruleOfficial source Source: page 4, section Discovery Motions

Judge Shawn T. Kelly's rules set a pre-motion procedure for covered motions. A party must file an RJI for a motion under CPLR §3211 and may file an RJI after service of process to request a preliminary conference.

View ruleOfficial source Source: page 2, section REQUEST FOR JUDICIAL INTERVENTION (RJI)

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