Judge Joanne D. Quinones
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
- An affirmation of actual engagement must be electronically filed and emailed to chambers at least one day before the court appearance.
- A telephonic adjournment request must be made by conference call to chambers with all parties present no later than one day before the appearance.
- Alternatively, an adjournment request must be emailed to both law clerks at least two days before the appearance as a stipulation signed by every party that states proposed dates and the reason for the request.
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Document Format Requirements3 rules
The first page of every motion paper must display the applicable motion sequence number in the upper-right corner.
Often, several motions are submitted at the same time. To keep papers organized, the first page of every motion paper (notice of motion, opposition, reply, etc.) must include the respective motion sequence number in the upper right corner.
Every exhibit page must be numbered, and references to an exhibit must include pinpoint citations identifying the exact location.
Each page in any exhibit must be numbered. Reference to any exhibit must include pinpoint citations so the exact location within the exhibit can be found easily.
A judge's signature line may not be placed on a blank page when preparing documents for signature.
When preparing documents for the judge’s signature, do not put the judge’s signature line on a blank page.
Document Filing Requirements9 rules
A pretrial memorandum and copies of relied-upon cases and authorities must be submitted as trial documents.
Any pretrial memorandum, copies of cases and authorities upon which you will be relying, especially opinions not contained in the official reporters;
Document Type
Pretrial Memorandum And Relied Upon Authorities
Copies of EBTs intended for trial must be submitted with the specific portions to be used identified.
Copies of all EBTs intended for use at trial and identifying any specific portion of those portions of EBTs to be referenced at trial;
Document Type
Trial Ebt Copies
Judicial subpoenas must be made returnable to the Kings County Subpoenaed Records Room at 360 Adams Street, 6th Floor, Brooklyn, New York 11201.
Judicial subpoenas must be made returnable to the NYS Supreme Court, Kings County Subpoenaed Records Room, 360 Adams Street, 6th Floor, Brooklyn, New York 11201.
Document Type
Judicial Subpoenas
Any requests for audio or visual equipment must be submitted as trial documents.
Any requests for audio/visual equipment;
Document Type
Audio Visual Equipment Request
The parties must submit a list of proposed witnesses and identify interpreter needs, including the requested language and dialect.
A list of proposed witnesses, including the need for any interpreters. If an interpreter is requested, please indicate the language and dialect;
Document Type
Proposed Witness List
The parties must submit a list of proposed exhibits, pre-mark the exhibits, show them to opposing counsel, and use numeric symbols for plaintiff's exhibits and alphabetic symbols for defendant's exhibits.
A list of all proposed exhibits. Proposed exhibits should be pre-marked for identification and are to be shown to opposing counsel. Plaintiff’s exhibits are to be assigned a numeric symbol (i.e., 1, 2, 3, etc.) and Defendant’s an alphabetical one (i.e., A, B, C, etc.);
Document Type
Proposed Exhibit List
All marked pleadings and bills of particulars must be submitted as trial documents.
All marked pleadings and bills of particulars;
Document Type
Marked Pleadings And Bills Of Particulars
Motions in limine must be submitted as trial documents.
Motions in limine.
Document Type
Motion In Limine
The parties must submit written copies of stipulated issues or facts and are strongly encouraged to stipulate to undisputed matters and pre-mark agreed exhibits outside the jury's presence.
A written copy of any issues or facts to which the parties have stipulated in advance of trial. Parties are strongly encouraged to stipulate to all facts and documents not in dispute prior to trial, and to have agreed-upon documents, photographs and other exhibits pre-marked into evidence outside the presence of the jury; and
Document Type
Pretrial Stipulations
Filing & Service rules
Electronic Filing Rules
Litigation may not be conducted by email without express permission from the court.
Litigation by email is strictly prohibited absent express court permission.
Page 1 | Communications with the Court
A complete EBT transcript must be electronically filed with motion papers, and any citation to it must identify the exact page and line numbers relied upon.
A complete EBT (examination before trial/deposition) transcript must be e-filed with motion papers and any reference thereto must cite to the exact page and line numbers relied upon.
Page 1 | Motions
To withdraw a fully submitted pending motion, the movant must electronically file a withdrawal stipulation or letter and immediately notify the court by email.
To withdraw a fully submitted motion that is pending in Part CVAP3, the movant shall e-file a stipulation or letter withdrawing the motion and immediately advise the court via email.
Page 1 | Motions
Filing Timing and Cure Windows
The parties must submit the listed trial documents to chambers no later than seven days before the first scheduled trial date.
No later than seven (7) days prior to the first scheduled trial date, the parties shall submit the following trial documents to chambers:
Page 1 | Requirements for Trial
Summary-judgment motions generally must be filed within 90 days after the Note of Issue is filed, unless a court order directs otherwise or the court grants leave for an exception.
All summary judgment motions must be made no later than 90 days after filing the Note of Issue, or as otherwise directed by order of the court. There are no exceptions without leave of court.
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A late summary-judgment motion may be denied absent good cause even when the opponent does not object.
Absent good cause for late filing, a late motion may be denied, even if your adversary does not object.
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Pre-Motion Conference Requirements
If counsel cannot resolve a disclosure dispute, requesting counsel must email the law clerks with all parties copied, briefly describe the dispute, request a virtual conference, and obtain a conference with the court before filing a discovery motion.
If counsel are unable to resolve any disclosure dispute in this fashion, counsel requesting the conference shall email the law clerks, with all parties copied, briefly outlining the nature of the dispute and requesting a virtual conference. No party shall file a discovery motion without first conferencing the matter with the court.
Page 1 | Motions
Discovery disputes should be resolved through court conference when practicable, and counsel must first attempt resolution in good faith.
Discovery disputes are preferred to be resolved through court conference as opposed to motion practice, if practicable. Counsel must consult with one another in a good faith effort to resolve all disclosure disputes.
Page 1 | Motions
Adjournment & Extension Requirements
An adjournment of a pending motion requires prior Part CVAP3 approval and must follow the standing adjournment procedure.
Adjournments of pending motions require prior approval of Part CVAP3. Adjournment requests shall be made in accordance with Paragraph 4 herein.
Page 1 | Motions
After sending the affirmation of actual engagement, the parties must request the adjournment by conference call or email under the Part rules.
Upon sending the affirmation of actual engagement, the parties must contact the court by conference call or email to request the adjournment in accordance with these Part Rules.
Page 1 | Communications with the Court
A trial date will not be adjourned without express permission from the court.
There will be no adjournment of the trial date without express court permission.
Page 1 | Requirements for Trial
Alternatively, an adjournment request must be emailed to both law clerks at least two days before the appearance as a stipulation signed by every party that states proposed dates and the reason for the request.
Alternatively, an adjournment request may be made by submitting a stipulation signed by all parties at least two (2) days prior to the scheduled appearance, and shall include proposed future dates and the reason for the adjournment. Stipulations of adjournment shall be emailed to both law clerks.
Page 1 | Communications with the Court
Every requested adjournment requires the court's prior approval.
All adjournments require prior approval of the court.
Page 1 | Communications with the Court
A case is presumed ready once assigned a trial date, and consent adjournments are not accepted.
Once a case has been assigned a trial date, it is presumed ready for trial. Trials will be day-to-day or as scheduled by the court. No consent adjournments will be accepted.
Page 1 | Requirements for Trial
A telephonic adjournment request must be made by conference call to chambers with all parties present no later than one day before the appearance.
Adjournment requests shall be made by conference call to chambers only when all parties are present on the line. The telephonic request must be made no later than one (1) day prior to the appearance.
Page 1 | Communications with the Court
A party seeking an extension to file a summary-judgment motion must request it before the deadline expires and follow the standing Part CVAP3 adjournment procedure.
Extensions of time to file summary judgment motions must be made prior to the expiration of the deadline and submitted in accordance with the procedure enumerated in Paragraph 4 of these Part Rules.
Page 1 | Motions
An affirmation of actual engagement must be electronically filed and emailed to chambers at least one day before the court appearance.
Affirmations must be e-filed and emailed to chambers at least one (1) day prior to the court appearance.
Page 1 | Communications with the Court
An adjournment request is not granted unless and until a so-ordered stipulation of adjournment is received.
An adjournment request has not been granted until you receive a so ordered stipulation of adjournment.
Page 1 | Communications with the Court
Requests to adjourn because counsel is actually engaged are governed by Part 125 of the Rules of the Chief Administrator of the Courts.
Adjournments on the ground of engagement of counsel will be granted in accordance with Part 125 of the Rules of the Chief Administrator of the Courts.
Page 1 | Communications with the Court
Chambers Communication Rules
The court will not engage in ex parte communications, and all communications with the court must be provided on notice to all parties and counsel.
The court will not engage in ex parte (one-sided) communications. All communications with the court, including email and telephonic communications, must be on notice to all parties/counsel.
Page 1 | Communications with the Court
When an interpreter is needed, chambers must be notified by email at least three business days before the proceeding, with the requested language and dialect.
Chambers staff must be notified via e-mail at least three (3) business days in advance of each court proceeding (including conference, oral argument, hearing, and trial) if a court interpreter is needed. You must provide the language and dialect for the requested interpreter services.
Page 1 | Court Interpreter Services
Emails to the court must include the case name, index number, and a brief explanation of the communication's purpose.
All email communications to the court shall include the case name, index number, and a brief explanation regarding the reason for the communication.
Page 1 | Communications with the Court
The parties must immediately notify chambers by email or conference call when a case, claim, or pending motion is settled or resolved.
The parties shall immediately notify chambers by email or conference call of the settlement or resolution of any case, claim, or pending motion.
Page 1 | Communications with the Court
All attorneys and self-represented litigants must be copied on emails to the court.
All emails shall include all attorneys and self-represented litigants copied on said correspondence.
Page 1 | Communications with the Court
Chambers must be notified immediately by email if the action is resolved before the scheduled trial date.
Chambers shall be notified immediately via email if the action is resolved prior to any scheduled trial date.
Page 1 | Requirements for Trial
A telephone call to chambers concerning a pending matter may occur only with all parties present on the line.
Any telephone call to chambers regarding a pending matter shall be made only when all parties are present on the line.
Page 1 | Communications with the Court
Litigants represented by counsel may not communicate directly with chambers or the court.
Litigants represented by an attorney are prohibited from communicating with chambers or the court directly
Page 1 | Communications with the Court
Emails to the court should be sent only during courthouse business hours, although emergency emails are excepted from the discouragement of after-hours, weekend, and holiday transmission.
Emails to the court shall only be sent during courthouse business hours. Emails transmitted after courthouse business hours, on weekends, or on court holidays are strongly discouraged, except in the case of an emergency.
Page 1 | Communications with the Court
Counsel should not copy chambers on correspondence with one another.
Chambers should not be copied on correspondence between counsel.
Page 1 | Communications with the Court
Litigants must check NYSCEF for decisions and orders and may not call or email the court merely to ask whether a decision has issued.
To determine whether a decision has been rendered, please check NYSCEF. All decisions and orders are scanned and available on NYSCEF. Please do not call or email the court to ask whether a decision has been issued.
Page 1 | Motions
All written and oral communications with the court must be civil and respectful of the court and its proceedings.
All written and oral communications shall be conducted with civility and in a manner that reflects due respect for the dignity and integrity of the court and its proceedings.
Page 1 | Communications with the Court