Judge Carolyn E. Wade
Individual Rules, Standing Orders & Policies
- Rules last changed:
Limits & Logistics
Document Limits
Courtesy Copies
All filings
Court-wide- When Fully Briefed
Courtesy copies
Court-wideTerms Of Sale
Court-wide- Upon request
Adjournments
- Adjournment requests must be submitted in writing by email to the Part Clerk at least 48 hours before the return date.
- A stipulation to adjourn must be electronically filed and emailed to the Part Clerk at least 48 hours before the return date.
- A subsequent adjournment request generally requires an application to the court showing good cause unless the parties consent.
- A consent-based subsequent adjournment must be submitted by email as a stipulation stating a proposed return date.
Request must include
Communication
Chambers8 contacts
- 347-296-1486
- 347-401-9260
- 347-296-1527
- 347-404-9954
- 347-296-1555
- 347-296-1664
Show 2 moreShow fewer
- (347) 296-1666
- 347-296-1521
Clerk5 contacts
- jgoldste@nycourts.gov
- (347) 296-1694
- 347-296-1578
- 360asupremecivilforeclosure@nycourts.gov
- 360asupremecivilmatrimonial@nycourts.gov
Other Contacts1 contacts
- 347-296-1740
Page & Word Limits2 rules
A written motion in limine may not exceed three pages, must be double-spaced, and must include Official Reporter citations.
Written motions in limine shall not exceed three pages, double spaced, and citations to the Official Reporter is required.
Motion In Limine
Parties must provide a one-page trial summary sheet containing at least a brief summary of the plaintiff’s cause of action and demand.
Parties are to provide a one-page trial summary sheet which must include:A brief summary of Plaintiff’s cause of action and Plaintiff’s demand.
Trial Summary
1 pages
Document Format Requirements10 rules
Each exhibit tab must immediately precede the actual exhibit rather than a blank exhibit-placeholder page.
Exhibit tabs shall immediately precede an actual exhibit (i.e., not a blank page denoted “Exhibit __”).
Proposed jury charges and verdict sheets must also be emailed to the court in Word format.
Additionally, they must be submitted in Word format to the court by e-mail to agrossma@nycourts.gov.
DOCX
A compromise submission must not place the court’s signature line on a blank page.
The Court’s signature line must not appear on a page with no writing.
The proposed infant compromise order must be submitted in Word format.
The proposed order must be e-mailed in Word format, and must include the infant’s full name and date of birth.
DOCX
All papers filed with the court must include exhibit tabs.
Exhibit tabs are required on all papers filed with the Court.
All compromise submissions must be separated with exhibit tabs.
All submissions must be separated by exhibit tabs.
Written motions in limine must be double-spaced.
Written motions in limine shall not exceed three pages, double spaced, and citations to the Official Reporter is required.
Affirmations, affidavits, and legal memoranda must use double spacing.
Affirmations, affidavits, and legal memoranda must be double-spaced.
After oral argument, parties must email Word-format proposed orders to both law clerks as instructed when the motion is fully submitted.
After oral argument, if a motion is marked “fully submitted,” the parties shall e-mail their proposed orders as the Court instructs, in Word format to both law clerks.
DOCX
Plaintiffs must number their trial exhibits, while defendants must letter their trial exhibits.
Plaintiffs will number their exhibits and defendants will letter their exhibits.
Document Filing Requirements15 rules
A wrongful-death compromise order must direct payment of asserted liens.
The Order must include a directive for payment of liens.
Document Type
Wrongful Death Compromise Order
Before trial, counsel must furnish the court with the bill of particulars and marked pleadings under CPLR § 4012.
Prior to trial, counsel shall furnish to the Court the bill of particulars, and the marked pleadings pursuant to CPLR § 4012.
Document Type
Bill Of Particulars And Marked Pleadings
A list of trial exhibits must be provided to the court before trial.
A list of the exhibits shall also be provided to the Court prior to trial.
Document Type
Exhibit List
An amendment to a compromise order must include the original order and an attorney’s affirmation explaining the proposed amendment and its reason.
Amendments to compromise orders must include a copy of the original compromise order and an attorney’s affirmation detailing the proposed amendment and the reason for it, in addition to any other necessary papers.
Document Type
Compromise Order Amendment
A wrongful-death compromise petition must include either an affidavit of no liens or documentation of any liens asserted.
Wrongful Death Compromise petitions must comply with the provisions of EPTL § 5-4.6 and include an affirmation of no liens or, where liens are asserted, documentation of such liens.
Document Type
Wrongful Death Compromise Petition
A proposed order to show cause must be reviewed by the Ex Parte Motion Support Office before submission to the part.
Proposed orders to show cause must be brought to the Ex Parte Motion Support Office for review prior to submission to the part.
Document Type
Proposed Order
The proposed infant compromise order must be emailed in Word format and state the infant’s full name and date of birth.
The proposed order must be e-mailed in Word format, and must include the infant’s full name and date of birth.
Document Type
Proposed Infant Compromise Order
Infant compromise submissions must include a current medical report, a physician’s affirmation, and an affidavit of no liens.
A current medical report, physician’s affirmation, and affirmation of no liens are required with the submissions.
Document Type
Infant Compromise Submission
Proposed jury charges and verdict sheets must be submitted in typed form to the court and opposing counsel by the close of the plaintiff’s case or as the court directs.
All proposed jury charges and proposed verdict sheets shall be submitted to the Court and the opposing counsel in typed form no later than the close of plaintiff’s case, or as instructed by the Court.
Document Type
Proposed Jury Charges And Verdict Sheets
When an infant compromise settlement is structured, the order must state the annuity’s cost.
If any portion of the settlement is structured, the cost of the annuity must be stated in the order.
Document Type
Infant Compromise Order
An infant or wrongful-death stipulation of discontinuance must include a brief attorney’s affirmation supporting entry of the requested order.
Stipulations of Discontinuance involving an infant or a wrongful death case shall be submitted as noted above; and shall include a brief attorney’s affirmation in support of the request for the stipulation to be so ordered.
Document Type
Stipulation Of Discontinuance
A written motion in limine must include citations to the Official Reporter.
Written motions in limine shall not exceed three pages, double spaced, and citations to the Official Reporter is required.
Document Type
Motion In Limine
When a prior defendant settled, the earlier compromise order must be attached as an exhibit and the partial settlement stated in the attorney’s affirmation.
If a Compromise Order was signed as to a previously settling defendant, such order must be attached as an exhibit and the partial settlement so stated in the attorney’s affirmation in support of the final Compromise Order.
Document Type
Final Compromise Order Submission
A copy of each deposition intended for use at trial should be furnished to the court when trial begins.
A copy of depositions intended to be used at trial should be furnished to the Court at the commencement of the trial.
Document Type
Deposition Copy
Proposed orders should identify controlling case law and the legal basis for the court’s ruling.
The proposed orders should include controlling case law, and a basis for the Court’s ruling.
Document Type
Proposed Order
Filing & Service rules
Electronic Filing Rules
Every infant or wrongful-death compromise application must be emailed to the principal court attorney after filing.
Upon filing, all applications must be e-mailed to agrossma@nycourts.gov.
Page 1 | INFANT COMPROMISE & WRONGFUL DEATH COMPROMISE ORDERS
Stipulations to adjourn are required to be filed electronically and emailed to the Part Clerk.
All stipulations to adjourn must be e-filed and e-mailed to the Part Clerk (jgoldste@nycourts.gov) at least 48 hours prior to the return date.
Page 1 | MOTIONS
Electronic filing of motions with proposed orders is permitted for each party.
All motions may be e-filed with proposed orders by each party.
Page 1 | MOTIONS
Filing Timing and Cure Windows
A summary judgment motion must be made within 60 days after the note of issue is filed.
Summary judgment motions must be made within sixty (60) days of the filing of the note of issue.
Page 1 | MOTIONS
Proposed jury charges and verdict sheets are due no later than the close of the plaintiff’s case, unless the court instructs otherwise.
All proposed jury charges and proposed verdict sheets shall be submitted to the Court and the opposing counsel in typed form no later than the close of plaintiff’s case, or as instructed by the Court.
Page 1 | TRIALS
Service and Proof of Service Rules
Unless a motion has a briefing schedule, motion, opposition, and reply papers must be served on adversaries under CPLR § 2214.
Except for those motions with briefing schedules, all motion papers, opposition papers, and reply papers shall be served on adversaries per CPLR § 2214.
Page 1 | MOTIONS
Filing Fees and Waivers
Every stipulation of discontinuance requires payment through the County Clerk’s office and filing in Motion Support.
All Stipulations of Discontinuance shall be paid for in the County Clerk’s office and filed in Motion Support.
Page 1 | STIPULATIONS OF DISCONTINUANCE
Any legally required fee must be paid to the County Clerk before submitting an order to show cause to the part.
Fees as required by law must be paid to the County Clerk prior to submission.
Page 1 | MOTIONS
Adjournment & Extension Requirements
A consent-based subsequent adjournment must be submitted by email as a stipulation stating a proposed return date.
If on consent, parties must submit a stipulation with a proposed return date by e-mail to the Part Clerk, Jay Goldstein at jgoldste@nycourts.gov.
Page 1 | ADJOURNMENTS
A subsequent adjournment request generally requires an application to the court showing good cause unless the parties consent.
Any subsequent adjournment requests must be made upon application to the Court for good cause, unless on consent.
Page 1 | ADJOURNMENTS
A stipulation to adjourn must be electronically filed and emailed to the Part Clerk at least 48 hours before the return date.
All stipulations to adjourn must be e-filed and e-mailed to the Part Clerk (jgoldste@nycourts.gov) at least 48 hours prior to the return date.
Page 1 | MOTIONS
Adjournment requests must be submitted in writing by email to the Part Clerk at least 48 hours before the return date.
All requests for adjournments must be made in writing, at least 48 hours before the return date, and e-mailed to the Part Clerk, Jay Goldstein at jgoldste@nycourts.gov.
Page 1 | ADJOURNMENTS
Chambers Communication Rules
The court will not entertain ex parte communications.
NO EX-PARTE COMMUNICATIONS WILL BE ENTERTAINED.
Page 1 | INQUIRIES
Attorneys may not send correspondence to chambers except stipulations signed by all parties.
No correspondence between attorneys shall be sent to chambers, other than stipulations signed by all parties.
Page 1 | INQUIRIES
Chambers staff may not provide legal advice or guidance to attorneys or litigants.
Chambers staff is not permitted to provide legal advice or guidance to attorneys or litigants.
Page 1 | INQUIRIES
The Part Clerk may be contacted at 347-296-1578 or jgoldste@nycourts.gov when necessary.
If necessary, the Part Clerk, Mr. Jay Goldstein, can be contacted at 347-296-1578 (jgoldste@nycourts.gov).
Page 1 | INQUIRIES
When the parties agree to seek a conference instead of further motion practice, they may email the judge’s law clerks to request a virtual conference.
If the parties agree to a conference with the Court in lieu of further motion practice, the parties may e-mail the Judge’s Law Clerks to request a virtual conference.
Page 1 | INQUIRIES
Case or calendar status inquiries should initially be directed to the Motion Support Office at (347) 296-1694.
All inquiries as to case or calendar status should, in the first instance, be made to the MOTION SUPPORT OFFICE, Room 227, Telephone (347) 296-1694.
Page 1 | INQUIRIES