New York Supreme Court, Nassau County Document Filing Requirements

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

Applies to

Adjournment request

An adjournment request based on newly engaging counsel must be accompanied by an Affirmation of Actual Engagement.

All adjournments requested on the basis of engagement of counsel require an Affirmation of Actual Engagement to accompany the request.

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

Applies to

Motion

The first page of every motion, opposition, or reply paper must state its sequence number.

All motion papers (including opposition and reply) must state the sequence number on the first page.

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

Applies to

Note of issue

A Note of Issue must be filed before an inquest is held.

A Note of Issue must be filed prior to an inquest being held.

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

Applies to

Trial conference submission

Must include

exhibit list

At the trial conference, counsel must provide the court with all trial pleadings, bills of particulars, witness and exhibit lists, and deposition transcripts intended for use at trial.

At the trial conference, counsel shall supply the Court with all pleadings, bills of particulars, witness lists, exhibit lists and any deposition transcripts that will be used at trial.

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

Applies to

Trial expert disclosure

If an expert witness will be called, counsel must provide the information required by CPLR 3101(d)(1)(I).

If any expert witnesses are to be called, counsel shall provide the information required by CPLR 3101(d)(1)(I).

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

Applies to

Trial exhibits

Trial exhibits must be pre-marked, and counsel should stipulate to the admissibility of documents and records where possible.

All trial exhibits shall be pre-marked for identification and, where possible, counsel shall stipulate to the admissibility of documents and records.

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

Applies to

Motion in limine notice

Counsel must notify the court promptly when a trial assignment is made of any motion in limine and its supporting authority or case law.

Motions in Limine: Counsel shall notify the Court as soon as the trial assignment ===== PAGE 8 ===== is made, of any motions in limine and any supporting authority or case law.

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

Applies to

Subpoenaed records

Unless the CPLR permits otherwise, subpoenaed trial records must be sent to the Subpoenaed Records Room, and counsel must ensure their arrival before trial.

Except as otherwise permitted by the CPLR, subpoenaed records for trial must be sent to the Subpoenaed Records Room. Trial authorizations should be filled out accordingly. It is the responsibility of counsel to ensure that the subpoenaed records have arrived in the records room before trial.

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

Applies to

Requested jury charges

Counsel must submit a complete list of requested jury charges drawn from the current PJI by the date selected at the trial conference, when a charge conference will be scheduled.

Counsel must submit a complete list of requested jury charges, drawn from the current Pattern Jury Instructions (PJI) by the date selected at the Trial Conference . A charge conference will be scheduled at that time.

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

Applies to

Proposed verdict sheet

All counsel and self-represented parties must jointly prepare and submit a typewritten, final Proposed Verdict Sheet by the date selected at the trial conference.

A Proposed Verdict Sheet, jointly prepared by all counsel and self-represented parties, typewritten and in final form for presentation to the jury, shall be submitted by the date selected at the Trial Conference.

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

Civil cases

Applies to

Order to show cause

Every order to show cause and notice of motion must include the email addresses of all counsel and/or parties.

5) Orders to Show Cause • All orders to show cause and notices of motion shall include the email addresses of all counsel and/or parties.

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

Civil cases

Applies to

Trial preparation submissions

Counsel must provide binders containing copies of the EBTs, interrogatories, and bills of particulars to be used at trial.

At dates determined at the pre-trial conference, Counsel shall provide the Court with: o Copies of EBTs, Interrogatories, and Bills of Particulars to be used at trial in binders;

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

Civil cases

Applies to

Trial preparation submissions

Counsel must provide a pre-marked list of all exhibits in the order in which they will be introduced at trial.

o A list of all exhibits pre-marked in the order in which they shall be introduced at trial;

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

Civil cases

Applies to

Trial preparation submissions

Counsel must provide a list of intended trial witnesses, including experts, the date each witness will be called, and the estimated testimony length.

o A list of potential witnesses they intend to call at trial, including expert witnesses, the date they intend to call each witness, and the estimated length of their testimony; and

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

Civil cases

Applies to

Trial preparation submissions

Counsel must provide proposed jury charges and proposed verdict sheets.

o Proposed jury charges and proposed verdict sheets.

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

Civil cases

Applies to

Motion in limine

Any potential evidentiary question or unadjudicated procedural or substantive law matter must be raised with the court by motion in limine.

Any potential evidentiary questions, procedural or substantive law matter not previously adjudicated shall be brought to the Court’s attention by motion in limine.

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

Applies to

Joint evidence log

Counsel must provide a Joint Evidence Log by email on or before 9:30 AM on the assigned pre-marking date, identifying each exhibit and its purpose; the log itself is not evidence.

Counsel shall provide a Joint Evidence Log to the court at JudgeRizzoRemote@nycourts.gov on or before 9:30 AM the date this Court assigns the day for pre-marking exhibits. The evidence log shall identify each exhibit as either marked in evidence, or marked for identification purposes; the purpose of each exhibit (for example plaintiff’s claim, defendant’s claim, defendant’s counter claim) and identify what each exhibit is or intends to demonstrate. The Joint Evidence Log itself will not be considered evidence.

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

Applies to

Letter

The stay or TRO notice letter must state when the phone call or email was sent and whether it received a response, attach the email, and, when applicable, identify consent and the consenting counsel or self-represented party.

The letter shall state the time and date the phone call and/or email was placed, and whether or not the call and/or email was responded to, and shall attach a copy of the email. If applicable, the letter shall notify the court if the application for the stay or TRO is on consent, providing the name of counsel or self-represented party.

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

Applies to

Motion

Must include

proposed order, certificate of service

All motions must include the applicable proof of service and a proposed order addressing the requested relief, but dispositive motions do not require a proposed order.

All motions shall have the appropriate proof of service on all parties where required annexed to the motion as well as a proposed order with respect to the requested relief, except on dispositive motions which will not need a proposed order.

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

Applies to

Expert disclosure

On the first day of trial, counsel must provide the previously exchanged CPLR § 3101-d disclosures and identify each expert and the expected length of direct, cross, and redirect examination.

On the first day of trial, counsel shall provide their previously exchanged CPLR §3101-d [expert disclosure] and identify each expert witness, and the length of their expected testimony, including direct examination, cross-examination and redirect, if any.

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

Applies to

Submission

Must include

word count

Counsel must include a certification of the relevant word count with the submission.

Counsel shall include a certification of the relevant word count with their submission.

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

Applies to

Sur reply

The court does not permit the submission of a sur-reply.

This Court does not allow the submission of a sur-reply.

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

Applies to

Trial letter

In medical malpractice and personal injury damages trials, counsel must provide a letter on the first day after jury selection stating the plaintiff’s date of birth and each expert’s full name and expertise.

MEDICAL MALPRACTICE AND PERSONAL INJURY DAMAGES TRIALS. On the first day of trial after a jury has been selected, counsel shall provide, by way of letter, the plaintiff’s date of birth and the full name and expertise of each expert witness.

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

Applies to

Proposed infant compromise order

A proposed Infant’s Compromise Order must include the infant-plaintiff’s full name and the specified finding concerning confidential personal information.

A proposed Infant’s Compromise Order must include the full name of the infant-plaintiff and reference the following: “Confidential personal information is included in this Order upon the Court’s finding that good cause exists pursuant to 22 NYCRR §202.5[e][2], in that the inclusion of the full name and date of birth of the minor, as well as related information, is material and necessary to effectuate the terms of this Order.”

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

Applies to

Infant compromise paperwork

Infant compromise paperwork must include a medical report or affidavit addressing recovery, injuries, anticipated treatment, and applicable medical records.

The infant’s compromise paperwork submitted to the ICC must include, inter alia, (i) a medical report/affidavit indicating whether the inured infant plaintiff has fully recovered, and if not, the nature and extent of the injuries and anticipated future treatment, if any, and related medical records where applicable;

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

Applies to

Infant compromise paperwork

Infant compromise paperwork must include written proof from defense counsel settling the infant’s claim.

The infant’s compromise paperwork submitted to the ICC must include, inter alia, (i) a medical report/affidavit indicating whether the inured infant plaintiff has fully recovered, and if not, the nature and extent of the injuries and anticipated future treatment, if any, and related medical records where applicable; (ii) proof of settlement of the infant’s claim from defense counsel, in writing; and (iii) defense counsel’s waiver of appearance at the Infant’s Compromise Hearing, in writing.

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

Applies to

Petition

An affidavit of consent from an infant aged fourteen or older must accompany the petition.

If the infant is fourteen years or older, an affidavit of consent from the infant must be included with the petition.

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

Applies to

So order request letter

A request that the court so-order a stipulation, subpoena, or other agreement must be made by letter uploaded to NYSCEF and emailed to the judge with copies to all counsel or self-represented parties, and the letter must state the grounds for the request.

Should counsel or self-represented parties seek this court to “so order” a stipulation or subpoena, or other agreement, they shall request so by way of letter uploaded to NYSCEF and emailed to JudgeRizzoRemote@nycourts.gov, copied to all counsel and/or self-represented parties. The letter shall provide the grounds upon which the party seeks to have the document “so-ordered.”

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

Applies to

Malpractice departures list

In professional-negligence cases, the party bearing the burden must furnish the court and opposing counsel with a list of expert-tested departures from good and accepted practice, with page references when the testimony is transcribed.

Malpractice Departures. In cases involving claims of professional negligence, on the next trial session after party rests, or such other time as the Court may direct, counsel for the party who has the burden of proof shall furnish the Court, and counsel for the opposing party, with a list of the departures from the standards of good and accepted practice which that counsel who has the burden asserts were testified to by its expert witness or witnesses. Where the testimony has been transcribed, page references will be required.

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

Applies to

Proposed requests to charge

The proposed requests to charge must be prepared jointly, identify whether charges are joint, on consent, plaintiff-only, or defendant-only, and reference only the current PJI number and title.

On the first day of trial after the jury has been selected, a Proposed Requests to Charge prepared jointly, with headings requested “Jointly” or “On Consent” and which charges are only requested by “Plaintiff” or “Defendant.” A reference ONLY to the then current PJI number and title will suffice.

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

Applies to

Proposed verdict sheet

The proposed verdict sheet must be prepared jointly on the first day of trial after jury selection.

On the first day of trial after a jury has been selected, a Proposed Verdict Sheet shall be prepared jointly.

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

Applies to

Proposed verdict sheet

If counsel cannot submit a jointly prepared proposed verdict sheet, each party must submit its own proposed verdict sheet.

Should counsel be unable to submit a jointly prepared Proposed Verdict Sheet, each party shall submit one.

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

Applies to

Exhibits

Counsel must pre-mark exhibits with the court reporter before openings.

Counsel shall pre-mark exhibits prior to openings with the court reporter.

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

Applies to

Subpoenaed records

Unless otherwise permitted by CPLR, subpoenaed trial records must be sent to the Subpoenaed Record Room with completed trial authorizations and must arrive at the courthouse before trial.

Except otherwise permitted pursuant to CPLR, subpoenaed records for trial must be sent to the Subpoenaed Record Room. Trial authorizations should be filled out accordingly, counsel shall ensure that the subpoenaed records arrive at the courthouse prior to trial.

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

Applies to

Supporting affidavit

Each branch of relief in a notice of motion or order to show cause must be numbered or lettered to match the supporting affirmation or affidavit paragraphs addressing that relief.

In addition, the various branches of the motions as delineated in the Notice of Motion or Order to Show Cause are to be preceded by a number or letter which corresponds to a number or letter in the supporting affirmations and affidavits containing the numbered paragraphs dealing with the particular relief sought.

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

Applies to

Proposed verdict sheet

All counsel and self-represented litigants must jointly prepare and submit a Proposed Verdict Sheet by email in Microsoft Word format no later than the first pretrial conference.

A Proposed Verdict Sheet, jointly prepared by all counsel/pro se (self-represented) litigant(s) must be submitted by email in Microsoft Word format to the Court’s remote email (JudgeMcGrathRemote@nycourts.gov), as directed but the Court and no later than the first Pre-Trial Conference before this Part.

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

Applies to

Adjournment request

An adjournment request based on counsel's engagement must include an Affirmation of Engagement conforming to 22 NYCRR 125.1.

Adjournments requested because of engagement of counsel must be accompanied by an Affirmation of Engagement in conformity with 22 NYCRR 125.1.

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

Applies to

Emergency order to show cause

An emergency Order to Show Cause requires both a special affidavit based on personal knowledge and an affirmation explaining the emergency in detail.

An “Emergency” Order to Show Cause requires a special affidavit based upon personal knowledge and an affirmation explaining in detail the nature of the emergency.

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

Applies to

Discovery motion

A discovery motion must state that the required pre-filing procedure was complied with, after the Court has conferred and granted leave to file.

After the Court conferences the matter and if the Court grants leave of court to file a discovery motion, any discovery motion must state that this procedure has been complied with.

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

Applies to

Note of issue

Counsel and self-represented litigants may not file a Note of Issue unless the Court grants permission.

Counsel and pro se (self-represented) litigant(s) are not permitted to file a Note of Issue in any action unless permission to do so is granted by the Court.

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

Applies to

Pretrial conference materials

Must include

exhibit list

By the Pre-Trial Conference, counsel or self-represented parties must electronically file and provide the Court with a working copy of marked pleadings and incorporated exhibits, bills of particulars, applicable expert disclosures, a probable trial witness list, and applicable prior decisions or orders.

On or before the Pre-Trial Conference, Plaintiff’s counsel, Defendant’s counsel (or pro se (self-represented) parties) must file via NYSCEF and provide the Court with a working copy of the following: 1. Marked pleadings in accordance with CPLR Section 4012, including copies of any exhibits incorporated by reference in the pleadings; 2. A copy of all bill(s) of particulars; 3. A copy of all expert disclosures served pursuant to CPLR Section 3101(d) (if applicable); 4. A list of probable trial witnesses; 5. A copy of all prior Decisions or Orders on motions issued in the case (if applicable);

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

Applies to

Motion

Must include

ai disclosure

If AI was used to prepare motion papers, counsel must submit an affirming that all AI-provided legal references were thoroughly checked for accuracy and validity.

If counsel did use AI in preparation of the motion papers, counsel must then submit an affirmation that all case law and other references provided by AI were thoroughly checked for accuracy and validity.

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

Applies to

Infant compromise petition

Infant compromise petitions must comply with CPLR 1207, CPLR 1208, and 22 NYCRR 202.67.

Infant Compromise petitions must comply with CPLR 1207, 1208, and 22 NYCRR 202.67.

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

Applies to

Infant compromise approval application

An application for approval of a proposed infant compromise must be submitted through the Infant’s Compromise Clerk.

All applications for Court approval of a proposed compromise of an infant’s claim must be submitted through the Infant’s Compromise Clerk (“ICC”).

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

Applies to

Infant compromise paperwork

Infant compromise paperwork must include a medical report or affidavit addressing recovery, injuries, and anticipated treatment, together with related medical records when applicable.

(i) a medical report/affidavit indicating whether the injured infant plaintiff has fully recovered, and if not, the nature and extent of the injuries and anticipated future treatment, if any, and related medical records where applicable;

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

Applies to

Infant compromise paperwork

Infant compromise paperwork must include written proof of settlement from defense counsel.

(ii) proof of settlement of the infant’s claim from defense counsel, in writing;

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

Applies to

Infant compromise paperwork

Infant compromise paperwork must include defense counsel’s written waiver of appearance at the infant compromise hearing.

(iii) defense counsel’s waiver of appearance at the Infant’s Compromise Hearing, in writing.

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

Applies to

Infant compromise paperwork

An affidavit of consent from an infant aged fourteen or older must accompany the submitted infant compromise papers.

If the infant is fourteen years or older, an affidavit of consent from the infant must be included in the submitted papers.

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

Applies to

Subpoena

A subpoena seeking HIPAA-protected medical or other records must include a duly executed authorization permitting their release.

All subpoenas seeking the production of medical (or other) records subject to the HIPAA Rules shall attach a duly executed authorization permitting the release of such records.

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

Applies to

Trial exhibits

All trial exhibits must be pre-marked with the court reporter, whether or not the parties stipulate to their admission.

All trial exhibits, whether the parties stipulate to admit them into evidence or not, shall be pre-marked with the Court reporter.

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

Applies to

Proposed verdict sheet

If the parties cannot agree on jury questions before the pretrial conference, each side must submit its own Proposed Verdict Sheet by email in Microsoft Word format.

If counsel/pro se (self-represented) litigant(s) cannot agree to the questions to be posed to the jury prior to the Pre-Trial Conference, each side shall submit a Proposed Verdict Sheet by email in Microsoft Word format to the Court’s remote email (JudgeMcGrathRemote@nycourts.gov).

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

Applies to

Motion in limine

Motions in limine must be in writing unless the court approves otherwise.

Absent court approval, all motions in limine shall be in writing.

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

Applies to

Application

All applications must be calendared for their return date, and every party must appear unless the court directs otherwise.

All applications shall be calendared on the date returnable. Appearance by all parties is mandatory unless advised otherwise by the Court.

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

Applies to

Discovery motion

Every discovery motion must include a compliant good-faith affirmation, and failure to comply results in denial.

All discovery motions must contain an affirmation of good faith that strictly complies with 22 NYCRR 202.7(c). Failure to comply will result in denial of the motion.

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

Applies to

Adjournment request

A requested adjournment based on an attorney's actual trial engagement must include a conforming Affirmation of Engagement.

Adjournments requested due to an attorney's actual engagement on trial must be accompanied by an Affirmation of Engagement in conformity with 22 NYCRR Part 125.

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

Applies to

Medical report

Medical reports and affidavits must be executed within the six months preceding submission.

The Court will not accept medical reports/affidavits executed more than six months prior to the submission date.

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

Applies to

Trial transcript

The parties must promptly provide a transcript of the entire trial.

THE PARTIES SHALL BE REQUIRED TO FORTHWITH PROVIDE A TRANSCRIPT OF THE ENTIRE TRIAL.

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

Applies to

Sur reply

The Court will not accept or consider sur-reply affidavits, affirmations, or letters.

5. No sur-reply affidavit, affirmation or letter will be accepted or considered by the Court.

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

Applies to

Order to show cause

An Order to Show Cause may be brought only for genuine urgency, a required stay, or a statutory mandate.

6. Orders to Show Cause: Motions may be brought by Order to Show Cause only when there is genuine urgency, a stay is required, or a statute mandates so proceeding.

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

Applies to

Temporary injunctive relief application

An application for temporary injunctive relief must include an affirmation demonstrating significant prejudice from giving notice.

Accordingly, any application for temporary injunctive relief shall contain an affirmation demonstrating that there will be significant prejudice to the party seeking the restraining order by giving notice.

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

Applies to

Reply on order to show cause

Reply papers are not permitted on Orders to Show Cause.

7. No Reply papers will be permitted on Orders to Show Cause.

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

Applies to

Settlement notice

A letter or stipulation notifying the court of a partial or full settlement must be sent on notice to all parties or counsel and uploaded to NYSCEF.

10. Interim Partial or Full Settlement: If all or part of a submitted motion is settled, a letter or stipulation shall be sent to the court, on notice to all parties/counsel, and same shall be uploaded to NYSCEF.

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

Applies to

Settlement notice

The settlement notice must state the motion submission date, the aspects settled, and any issues remaining for decision.

Such notice shall set forth the date that the motion was submitted, what aspects of the motion have been settled, and what issues, if any, remain to be decided.

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

Applies to

Motion withdrawal notice

A motion withdrawal letter from the movant may be sent to chambers by email or fax and must be uploaded to NYSCEF.

11. Withdrawn Motions: If a motion is being withdrawn, a letter from the movant requesting withdrawal may be sent to chambers by email or fax and must be uploaded to NYSCEF.

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

Applies to

Settlement notice

An out-of-court settlement will not be recognized or accepted unless counsel submits the executed agreement or stipulation, or certifies its execution, with notice to opposing counsel or parties.

D. No out of court settlement will be recognized or accepted unless counsel submits a letter, on notice to opposing counsel/parties, submitting the executed settlement agreement/stipulation or certifying that such agreement/stipulation has, in fact, been executed.

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

Applies to

Motion

All motions other than annual and final accounts must be filed through an order to show cause.

All motions, except for annual and final accounts, shall be filed via order to show cause.

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

Applies to

Motion in limine

Must include

legal argument

Each motion in limine requires a separate brief written affirmation describing the application and supporting law, with an original and copy for the Court and copies for all counsel.

Any party intending to make a motion in limine shall submit a brief written affirmation setting forth the nature of the application and any supporting statutory or case law. The party shall furnish the Court with an original and a copy and provide counsel for all parties with a copy. There shall be a separate affirmation for each motion in limine.

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

Applies to

Order to show cause

Every order to show cause must comply with 22 NYCRR § 202.7(d).

All orders to show cause must comply with Uniform Rules for the Supreme and the County Court (22 NYCRR) § 202.7(d).

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

Applies to

Infant compromise application

Applications for court approval of an infant’s compromise must be submitted through the Infant’s Compromise Clerk.

A. All applications for Court approval of a proposed compromise of an infant’s claim must be submitted through the Infant’s Compromise Clerk (“ICC”) (telephone no. 516-493-3049).

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

Applies to

Proposed order

Must include

proposed order

A proposed Infant’s Compromise Order must include the infant plaintiff’s full name and the quoted good-cause language concerning confidential personal information.

B. A proposed Infant’s Compromise Order must include the full name of the infant plaintiff and reference therein the following: “Confidential personal information is included in this Order upon the Court’s finding that good cause exists pursuant to 22 NYCRR § 202.5 [e][2], in that the inclusion of the full name and date of birth of the minor, as well as related information, is material and necessary to effectuate the terms of this Order”.

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

Applies to

Infant compromise application

Infant compromise submissions must include a medical report or affidavit, related medical records when applicable, written proof of settlement from defense counsel, and defense counsel’s written waiver of appearance at the hearing.

C. The infant’s compromise paperwork submitted to the ICC must include, inter alia, (i) a medical report/affidavit indicating whether the injured infant plaintiff has fully recovered, and if not, the nature and extent of the injuries and anticipated future treatment, if any, and related medical records where applicable; (ii) proof of settlement of the infant’s claim from defense counsel, in writing; and (iii) defense counsel’s waiver of appearance at the Infant’s Compromise Hearing, in writing. Such paperwork must also otherwise comply with all applicable rules concerning the compromise of an infant’s claim.

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

Applies to

Medical report affidavit

Medical reports or affidavits must be executed within six months of submission and state whether the plaintiff fully recovered and, if not, the injuries and future-treatment costs.

The Court will not accept medical reports/affidavits executed more than six months prior to the submission date. The report must indicate whether the injured plaintiff has fully recovered, and if not, the nature and extent of the injuries and the costs of future treatment.

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

Applies to

Sanctions motion

Before filing a sanctions application, the movant must seek withdrawal or discontinuation of the offending conduct, or demand necessary action that is refused, and include proof of that request.

The Court will not consider a sanctions application unless the moving party first seeks withdrawal or discontinuation of the offending act or action or demands required or necessary action which is refused. Proof of such request must be made a part of the sanctions application.

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

Applies to

Discovery motion

Every discovery motion must state compliance with Rule III A, and noncompliance may result in denial.

Any discovery motion must state that Rule III A. above has been complied with. Failure to comply with Rule III above may result in denial of the motion.

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

Applies to

Motion in limine

A party intending to file a motion in limine must submit a brief written affirmation describing the application.

Any party intending to make a motion in limine shall submit a brief written affirmation setting forth the nature of the application and any

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

Applies to

Motion in limine affirmation

A separate affirmation is required for each motion in limine.

There shall be a separate affirmation for each motion in limine;

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

Applies to

Proposed witness list

Counsel must provide a list of proposed witnesses for the Court's information.

A list of proposed witnesses for the Court=s information;

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

Applies to

Expert witness list

Counsel must provide a list of all expert witnesses together with copies of their reports.

A list of all expert witnesses with copies of their reports;

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

Applies to

Pleadings

Marked pleadings must be submitted before opening statements.

Marked pleadings, to be submitted before opening statements;

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

Applies to

Audiovisual equipment

Counsel must provide any required audiovisual equipment.

Any audiovisual equipment required is to be provided by counsel;

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

Applies to

Inquest exhibits

Exhibits must be pre-marked before an inquest, and counsel should be prepared with admissible proof.

Inquests – all exhibits shall be pre-marked for identification prior to any scheduled Inquest. Counsel should be prepared with admissible proof to present at the Inquest.

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

Applies to

Stipulation

In non-e-filed cases, a stipulation submitted for a court “So-Ordered” must bear original signatures from all parties or counsel and may be submitted in counterparts.

On non e-filed cases, any stipulation to be “So-Ordered” by the Court must contain original signatures by all parties and/or counsel, which may be submitted in counterparts.

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

Applies to

Default judgment motion

A movant seeking entry of a default judgment must submit the Part's annexed default-judgment checklist on the submission date.

The movant on a motion for entry of a default judgment shall submit the Part’s annexed checklist for default judgment on the submission date.

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

Applies to

Infant compromise application

Applications for court approval of an infant's compromise must be submitted through the Infant's Compromise Clerk.

All applications for Court approval of a proposed compromise of an infant’s claim must be submitted through the Infant’s Compromise Clerk (“ICC”).

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

Applies to

Proposed order

A proposed infant compromise order must include the infant plaintiff's full name and the specified good-cause language concerning confidential personal information.

A proposed Infant’s Compromise Order must include the full name of the infant plaintiff and reference therein the following: “Confidential personal information is included in this Order upon the Court’s finding that good cause exists pursuant to 22 NYCRR 202.5[e][2], in that the inclusion of the full name and date of birth of the minor, as well as related information, is material and necessary to effectuate the terms of this Order.”

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

Applies to

Infant compromise papers

Infant compromise paperwork submitted to the ICC must include a medical report or affidavit, written proof of settlement from defense counsel, and defense counsel's written waiver of appearance at the hearing.

The infant’s compromise paperwork submitted to the ICC must include, inter alia, (i) a medical report/affidavit indicating whether the injured infant plaintiff has fully recovered, and if not, the nature and extent of the injuries and anticipated future treatment, if any, and related medical records where applicable; (ii) proof of settlement of the infant’s claim from defense counsel, in writing; and (iii) defense counsel’s waiver of appearance at the Infant’s Compromise Hearing, in writing.

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

Applies to

Infant compromise papers

When the infant is fourteen or older, the submitted papers must include an affidavit of consent from the infant.

If the infant is fourteen years or older, an affidavit of consent from the infant must be included in the submitted papers.

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

Applies to

Jury charge requests

A complete list of requested jury charges must be emailed in Microsoft Word format to the court's remote email by the Pre-Trial Conference.

A complete list of requested jury charges, drawn from the Pattern Jury Instructions (PJI) of the then-current year must be submitted by email in Microsoft Word format to the remote email JudgeClavinRemote@nycourts.gov, as directed by the Court and not later than the Pre-Trial Conference.

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

Applies to

Orders judgments counter orders counter judgments

Orders, judgments, counter-orders, and counter-judgments submitted for signature on notice will be returned unsigned unless they include an affidavit of service and a notice of settlement for a date designated under 22 NYCRR 202.48.

Orders, judgments, counter-orders and/or counter-judgments submitted for signature on notice will be returned unsigned unless an Affidavit of Service and Notice of Settlement for a date designated in accordance with 22 NYCRR 202.48 has been included.

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

Applies to

Jury charge requests

Direct PJI requests require the title, section number, and page number; deviations or additions require the full request text and supporting legal authority.

Where the requested charge comes directly from the PJI, only the PJI title, section number and page number need to be provided. Where deviations from, or additions to, the PJI are requested, the full text of such requests must be submitted, together with any supporting legal authority.

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

Applies to

Proposed verdict sheet

A jointly prepared Proposed Verdict Sheet must be emailed in Microsoft Word format to the court's remote email.

A Proposed Verdict Sheet, jointly prepared by all counsel/pro se (self-represented) litigant(s) must be submitted by email in Microsoft World format to the Court’s remote email.

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

Applies to

Proposed verdict sheet

If the parties cannot agree on jury questions before the Pre-Trial Conference, each side must submit its own Proposed Verdict Sheet by email in Microsoft Word format.

If counsel/pro se litigant(s) cannot agree to the questions to be posed to the jury prior to the Pre-Trial Conference, each side shall submit a Proposed Verdict Sheet by email in Microsoft World format to the Court’s remote email.

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

Applies to

Video recording submission

A party intending to use a videotape or other video recording must submit a copy and any applicable transcript to the court at least two weeks before trial.

that party shall submit a copy of the videotape (or other video recording) and transcript of same, if applicable, to the Court at least two (2) weeks prior to the scheduled trial date in order to allow the Court to rule on the admissibility of the videotape (or other video recording), and any Objections made during the video recording.

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

Applies to

Court filing

Must include

ai disclosure

A party or counsel using generative AI to prepare a court filing must disclose the use and specific tool and certify that all AI-assisted content, including citations, legal authority, and facts, was checked for accuracy, with sanctions potentially imposed for noncompliance.

Any party, whether appearing pro se or through counsel, which utilizes any generative artificial intelligence (“AI”) tool (for example, Chat GPT, Westlaw CoCounsel, or Lexis +AI) in preparation of any documents to be filed with the Court must disclose in the document that AI was used and the specific AI tool that was used. The unrepresented party or attorney must further certify in the document that the person has checked the accuracy of any portion of the document drafted by generative AI, including all citations, legal authority, and the recitation of the facts. If generative AI is utilized in the preparation of any documents filed with the Court, the unrepresented party or attorney will be held responsible for the contents thereof. The failure to make the disclosure and certification described herein may result in the denial of any application and the imposition of sanctions.

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

Applies to

Orders judgments counter orders and counter judgments

Must include

certificate of service

An order, judgment, counter-order, or counter-judgment submitted for signature will be returned unsigned unless it includes both the required Affidavit of Service and a Notice of Settlement for a date designated under 22 NYCRR 202.48.

Orders, judgments, counter-orders and/or counter-judgments submitted for signature on notice will be returned unsigned unless an Affidavit of Service and Notice of Settlement for a date designated in accordance with 22 NYCRR Section 202.48 has been included.

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

Applies to

Papers submitted for signature

Papers submitted for the Court's signature must be identified on the signature page, with the example format showing the case name, index number and year, and document type.

All papers which are submitted for signature by the Court shall be identified on the signature page so that the document being signed by the Court can be identified. Example: Jones v. Jones, Index #/year, Type of Document.

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

Applies to

Video recording

A party intending to use a videotape or other video recording must submit a copy and, if applicable, its transcript to the Court at least two weeks before trial so the Court can rule on admissibility and objections.

If a party intends to use a videotape at trial, that party shall submit a copy of the videotape (or other video recording) and transcript of same, if applicable, to the Court at least two (2) weeks prior to the scheduled trial date in order to allow the Court to rule on the admissibility of the videotape (or other video recording), and any Objections made during the video recording.

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

Applies to

Correspondence

All correspondence must include the action title and index number.

All correspondence must include the title of the action and the index number.

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

Applies to

Note of issue

Counsel and self-represented litigants may file a Note of Issue only with the court’s permission.

Counsel and pro se (self-represented) litigant(s) are not permitted to file a Note of Issue in any action unless permission to do so is granted by the Court.

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

Applies to

Marked pleadings

Parties must provide marked pleadings complying with CPLR § 4012, including incorporated exhibits.

1. Marked pleadings in accordance with CPLR Section 4012, including copies of any exhibits incorporated by reference in the pleadings;

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

Applies to

Motion

Must include

caption, case number

All motion papers must include the current caption, Index Number, Motion Sequence Number, and pertinent case information to the right of the caption.

All motion papers shall include the current caption. All motion papers shall include the Index Number and Motion Sequence Number in the case together with other pertinent information to the right of the caption.

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

Applies to

Submission containing legal authority citations

Must include

ai disclosure

A submission containing legal authority citations must include an attorney or self-represented filer certification either stating that no generative AI was used or confirming review and approval of all generated content and identifying any AI program used.

All submissions to the court containing legal authority citations must include a certification by the attorney or the self-represented party, indicating either 1) that no generative artificial intelligence program or tool was used in the drafting of any pleading, affidavit, affirmation, memorandum of law, brief, or other submission, or 2) that a generative artificial intelligence program or tool was used in the drafting of any pleading, affidavit, affirmation, memorandum of law, brief, or other submission, and affirm that all generated text, including citations, quotation, and legal analysis, was reviewed for accuracy and approved by an attorney or the self-represented party. Counsel must also identify the AI program utilized.

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

Applies to

Infant compromise petition

Infant Compromise petitions must comply with CPLR 1207, CPLR 1208, and 22 NYCRR 202.67.

Infant Compromise petitions must comply with CPLR 1207, 1208, and 22 NYCRR 202.67.

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

Applies to

Proposed infant compromise order

A proposed Infant’s Compromise Order must identify the infant-plaintiff by full name and include the specified confidentiality finding and explanatory language.

A proposed Infant’s Compromise Order must include the full name of the infant- plaintiff and reference therein the following: “Confidential personal information is included in this Order upon the Court’s finding that good cause exists pursuant to 22 NYCRR Section 202.5[e][2], in that the inclusion of the full name and date of birth of the minor, as well as related information, is material and necessary to effectuate the terms of this Order.”

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

Applies to

Infant compromise paperwork

Infant Compromise paperwork must include the specified medical information and records where applicable, written settlement proof from defense counsel, and defense counsel’s written waiver of appearance at the hearing; the list is nonexclusive.

The infant’s compromise paperwork submitted to the ICC must include, inter alia, (i) a medical report/affidavit indicating whether the injured infant plaintiff has fully recovered, and if not, the nature and extent of the injuries and anticipated future treatment, if any, and related medical records where applicable; (ii) proof of settlement of the infant’s claim from defense counsel, in writing; and (iii) defense counsel’s waiver of appearance at the Infant’s Compromise Hearing, in writing.

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

Applies to

Jury charge requests

Direct PJI requests require only the title, section number, and page number, while deviations or additions require the full request text and supporting legal authority.

Where the requested charge comes directly from the PJI, only the PJI title, section number and page number need to be provided. Where deviations from, or additions to, the PJI are requested, the full text of such requests must be submitted, together with any supporting legal authority.

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

Applies to

Proposed verdict sheet

All counsel or self-represented litigants must jointly prepare and email a typewritten, final-form Proposed Verdict Sheet by the date selected at the Pre-Trial Conference, and no later than forty-eight (48) hours before the charge conference.

A Proposed Verdict Sheet, jointly prepared by all counsel/pro se (self-represented) litigant(s), typewritten and in final form for presentation to the jury, shall be submitted via email by the date selected at the Pre-Trial Conference and in no event later than forty-eight (48) hours prior to the charge conference.

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

Applies to

Deposition testimony list

Each party must prepare separate lists of unobjected-to and objected-to deposition testimony offered at trial.

Each party shall prepare a list of deposition testimony to be offered by it as to which objection has not been made and, identified separately, a list of deposition testimony as to which objection has been made to the introduction of the testimony or corresponding video recording of the deposition testimony.

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

Applies to

Working copy

Working copies must include the index number, motion sequence number, and return date in the caption section.

Working copies must include the index number, motion sequence number and return date in the caption section.

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

Applies to

Affidavit of service

An Affidavit of Service uploaded to NYSCEF must identify the individual or entity served.

4. Affidavits of Service. Affidavits of Service that are uploaded to NYSCEF must identify the individual/entity on whom/which service was made.

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

Applies to

Exhibits

Each exhibit must be uploaded individually to NYSCEF and clearly identified and described.

5. Exhibits. Exhibits must be uploaded to NYSCEF individually, with each exhibit clearly identified and described (e.g. Affidavit of Defendant, Statement of Net Worth, Lease Agreement, etc.).

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

Applies to

Proposed confidentiality order

Any proposed order regarding the exchange of confidential information must be based on the court’s Model Order.

1. Model Confidentiality Order. Any proposed order regarding the exchange of confidential information shall be based on the model Stipulation and Order for the Production and Exchange of Confidential Information (the “Model Order”):

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

Applies to

Confidentiality order deviation submission

Parties proposing deviations from the Model Order must file the proposed confidentiality order, a redline showing the deviations, and a letter explaining the reasons.

2. Deviations from the Model Order. If the parties propose deviating from the Model Order, they shall file (a) a copy of the parties’ proposed confidentiality order; (b) a redline of the document showing the proposed deviations against the Model Order; and (c) a letter to the Court explaining the reasons for the proposed deviations.

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

Applies to

Affirmation of actual engagement

An application based on counsel’s actual engagement in another matter must include an Affirmation of Actual Engagement conforming to 22 NYCRR Section 125.

If the application is based on counsel’s actual engagement on another matter, an Affirmation of Actual Engagement, in conformity with 22 NYCRR Section 125, must accompany the Request for Adjournment Form.

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

Applies to

Adjournment confirmation letter

A letter confirming an adjournment must identify the adjourned matter and specified date, include both parties’ full names and the index number, state the matter’s current calendar date, and confirm that all parties were simultaneously copied.

Letters confirming adjournments shall state that the Court has adjourned the ===== PAGE 2 ===== conference or motion on consent of the parties to the specified date, and shall contain the full names of both parties, the index number, a notation indicating the current date the matter is on the Court’s calendar, and that all parties have been simultaneously copied.

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

Applies to

Motion

Each motion branch must have a number or letter that is repeated consistently in the supporting papers and corresponds to the notice of motion or order to show cause.

All motions must be organized in such a manner so that each branch of the motion stated in the notice of motion or order to show cause is preceded by a number or a letter. Said number or letter designation shall be used in the supporting affirmation and affidavits and shall correspond to the number/letter used for each branch as set forth in the notice of motion or order to show cause.

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

Applies to

Motion

Any EBT transcript referenced in a motion must identify the exact page and line numbers relied upon, and a full transcript must be supplied; nonconforming motions may be rejected.

Any references to EBT testimony shall cite to the exact page and line numbers relied upon rather than merely attaching the entire transcript or “relevant portions”; full transcripts shall be supplied. Motions not consistent with these rules will be rejected.

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

Applies to

Settlement letter

An out-of-court settlement is not recognized or accepted unless counsel submits a letter, with notice to opposing counsel, containing the executed settlement agreement or stipulation or certifying its execution.

No out of Court settlement will be recognized or accepted unless counsel submits a letter, on notice to opposing counsel, submitting the executed settlement agreement/stipulation or certifying that such agreement/stipulation has, in fact, been executed.

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

Applies to

Sanctions application

A sanctions application will not be considered unless the moving party first seeks withdrawal, discontinuation, or required action, and includes proof of that request.

The Court will not consider a sanctions application unless the moving party first seeks withdrawal or discontinuation of the offending act or action, or demands required or necessary action which is refused. Proof of such request must be made a part of the sanctions application.

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

Applies to

Sur reply

A sur-reply affidavit, affirmation, or letter will not be accepted or considered without leave of the Court.

No sur-reply affidavit, affirmation, or letter will be accepted or considered without leave of Court.

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

Applies to

Letter

Counsel must notify the Court by letter when any part of a submitted motion is settled, identify the motion details and remaining issues, and attach the original stipulation, whose copy must be uploaded to NYSCEF in an e-filed case.

If all or part of a submitted motion is settled, counsel shall notify the Court by letter setting forth the motion sequence number, the date the motion was submitted, what aspects of the motion have been settled and what issues remain to be decided. If the motion is resolved in its entirety, the movant shall indicate same. The letter shall be accompanied by the original stipulation of settlement, a copy of which must be uploaded to NYSCEF in an e-filed case.

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

Applies to

Medical proof

Physician affidavits, reports, and other medical proof submitted in threshold motions must bear the physician or medical provider's original signature.

Any physician affirmations, reports or other medical proof submitted in threshold motions shall contain the original signatures of the physician or medical provider.

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

Applies to

Motion

Motions under CPLR §§ 3211, 3212, or 3213 do not automatically stay discovery.

Motions brought pursuant to CPLR §§3211, 3212, or 3213 shall not automatically stay disclosure.

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

Applies to

Emergency order to show cause

An emergency Order to Show Cause requires a personal-knowledge affidavit and a detailed affirmation explaining the emergency, and the movant should be prepared to appear and make a record if the Court requires it.

An “Emergency” Order to Show Cause requires a special affidavit based upon personal knowledge and an affirmation explaining in detail the nature of the emergency. In addition to the foregoing, the movant should be prepared to appear in Court and to make a record before the Court, if the Court requires same.

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

Applies to

Motion in limine affirmation

Each motion in limine requires a separate brief written affirmation stating its nature and supporting law, with copies furnished to the Court and all counsel and relevant prior decisions and orders provided to the Court.

Any party intending to make a motion in limine shall submit a brief written affirmation setting forth the nature of the application and any supporting statutory or case law. The party shall furnish the Court and provide counsel for all parties, with a copy. There shall be a separate affirmation for each motion in limine. The Court shall be provided with all prior decisions and orders which may be relevant to said in limine applications.

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

Applies to

Pretrial memorandum

Pre-trial memoranda must provide the Court with cited case law, statutory law, and common law to be considered.

Pre-trial memoranda providing the Court with cited case law, statutory law and common law to be considered by the Court.

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

Applies to

Trial exhibit list

A copy of the exhibit list must be provided to the Court before trial begins.

A copy of the list of exhibits must be given to the Court before the trial begins.

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

Applies to

Sur reply

The Court will not accept or consider sur-reply affidavits, affirmations, or letters.

No sur-reply affidavit, affirmation or letter will be accepted or considered by the Court.

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

Applies to

Temporary injunction application

An application for temporary injunctive relief must include an affirmation showing that giving notice would significantly prejudice the party seeking the restraining order.

Accordingly, any application for temporary injunctive relief shall contain an affirmation demonstrating that there will be significant prejudice to the party seeking the restraining order by giving notice.

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

Applies to

Temporary injunction application

When significant prejudice is not shown, the application affidavit or affirmation must demonstrate a good-faith effort to notify the opposing party.

In the absence of a showing of significant prejudice, the affirmation must demonstrate that a good faith effort has been made to notify the party against whom the restraining order is sought.

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

Applies to

Reply brief

Reply papers are not permitted on an Order to Show Cause.

No Reply papers will be permitted on Orders to Show Cause.

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

Applies to

Cross motion reply affirmation

Reply affirmations are not permitted on cross-motions.

No reply affirmations will be permitted on cross-motions.

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

Applies to

Settlement letter or stipulation

Notice of a settlement of all or part of a motion must be sent to the court with notice to all parties or counsel and uploaded to NYSCEF.

If all or part of a submitted motion is settled, a letter or stipulation shall be sent to the court, on notice to all parties/counsel, and same shall be uploaded to NYSCEF.

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

Applies to

Transcript

Unless the Court directs otherwise, counsel must obtain the transcript when a motion is resolved on the record so the resolution can be incorporated into an order.

If any motion is resolved, in whole or part, on the record, counsel shall obtain such transcript so that same can be “so ordered,” unless the Court otherwise directs.

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

Applies to

Motion brief or pleading seeking relief

Must include

local rule certificate

Every motion, brief, and pleading seeking relief must include the certification prescribed by Appendix A.

All motions, briefs, and pleadings seeking relief must include a certification as set forth in Appendix A.

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

Applies to

Sanction application

A sanctions application must include proof that the movant first sought withdrawal, discontinuance, or a required action that was refused.

A. The Court will not consider an application for sanctions unless the moving party first seeks withdrawal or discontinuance of the offending act or action or demands a required or necessary action which is refused. Proof of such request must be made a part of the sanction application.

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

Applies to

Proposed jury instructions

Counsel must provide proposed jury charges and proposed jury verdict sheets at the trial conference.

Counsel shall further provide the Court with proposed jury charges and proposed jury verdict sheets at the trial conference.

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

Applies to

Medical report

A medical report must state whether the plaintiff fully recovered and, if not, describe the injuries and future treatment costs.

The report must indicate whether the injured plaintiff has fully recovered, and if not, the nature and the extent of the injuries and the costs of future treatment.

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

Applies to

Note of issue

A Note of Issue must be filed before any trial may commence.

The filing of a Note of Issue is a condition precedent to the commencement of any trial.

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

Applies to

Motion in limine

Counsel must promptly notify the Court of motions in limine and submit a brief written affirmation or memorandum describing the application and supporting authority.

B. Motions in Limine: Counsel shall notify the Court as soon as the trial assignment is made, or at the trial conference if unable to do so sooner, of any motions in limine and any supporting authority or case law. Counsel shall submit a brief written affirmation and/or memorandum of law setting forth the nature of the application and any supporting authority or case law.

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

Applies to

State agency subpoena

A state-agency document subpoena must comply with CPLR 2307 and include counsel’s affidavit explaining the information’s potential relevance.

Subpoenas seeking documents from a state agency must comply with CPLR 2307 and be accompanied by an affirmation of counsel setting forth the potential relevance of the information sought.

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

Applies to

Expert departures list

In professional-negligence cases, each party must furnish the Court and opposing counsel with a list of asserted departures testified to by experts, including page references when the testimony is transcribed.

G. Malpractice “Departures”: In cases involving claims of professional negligence, on the next trial session after a party rests, or such other time as the Court may direct, each party [plaintiff] shall furnish the Court and counsel for all parties with a list of departures from the standards of good and accepted practice which that party asserts were testified to by its expert witness or witnesses. Where the testimony has been transcribed, page references will be required.

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

Civil cases

Applies to

Secondary appointment request

Requests for secondary appointments must use the Guardianship Clerk’s Office form.

All requests for secondary appointments must use the appropriate form provided by the Guardianship Clerk’s Office.

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

Applies to

Application for temporary injunctive relief

An application for temporary injunctive relief must include an affirmation showing significant prejudice from lack of notice or, absent that showing, a good-faith effort to notify the opposing party.

Accordingly, any application for temporary injunctive relief shall contain an affirmation demonstrating that there will be significant prejudice to the party seeking the restraining order by giving notice. In absence of a showing of significant prejudice, the affirmation must demonstrate that a good fait effort has been made to notify the pary against whom the restraining order is sought.

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

Applies to

Settlement notice

A letter or stipulation reporting a partial or full settlement must be sent to the Court with notice to all parties, uploaded to NYSCEF, and state the submission date, settled issues, and remaining issues.

If all or part of a submitted motion is settled, a letter or stipulation shall be sent to the Court, on notice to all parties, and same shall be uploaded to NYSCEF. Such notice shall set forth: (1) the date that the motion was submitted; (2) what aspects of the motion have been settled; and (3) what issues, if any, remain to be decided.

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

Applies to

Transcript

Unless the Court directs otherwise, counsel must obtain an orderable transcript whenever a motion is resolved wholly or partly on the record.

If any motion is resolved, in whole or part, on the record, counsel shall obtain a transcript that can be “so ordered” unless otherwise directed by the Court.

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

Applies to

Motion withdrawal letter

A withdrawn motion must be accompanied by a movant's withdrawal letter emailed to chambers and uploaded to NYSCEF.

If motions are withdrawn, a letter from the movant requesting withdrawal must be sent to chambers by email and uploaded to NYSCEF.

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

Applies to

Settlement submission letter

The Court will not recognize an out-of-court settlement unless counsel submits a letter, with notice to the opposing parties, containing the executed settlement agreement or stipulation or certifying its execution.

No out of court settlement will be recognized or accepted unless counsel submits a letter, on notice to the opposing parties submitting the executed settlement agreement/stipulation or certifying that such agreement/stipulation has, in fact, been executed.

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

Applies to

Notice of settlement discontinuance mootness death or bankruptcy

All counsel and self-represented litigants must promptly notify the Court in writing of settlement, discontinuance, complete or partial mootness, death, or bankruptcy.

All counsel, including self-represented litigants, have a continuing obligation to promptly notify the Court in writing if an action is settled or discontinued, if a case or motion becomes wholly or partially moot, or if a party dies or files for bankruptcy. Such notification must be made in writing to the Court (see 22 NYCRR 202.28 [b]).

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

Applies to

Motion papers

In non-e-filed or partially participating cases, moving, opposition, and reply papers must include active email addresses for the author and adversary or adversaries.

On non-e-filed cases, or cases where there is only “partial participation” in e-filing, each set of moving papers, opposition papers and reply papers must contain an active email address for the author of the papers and the adversary/adversaries.

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

Applies to

Sur reply

Sur-reply papers require prior court authorization and will be disregarded if submitted without it.

The court will not accept sur-reply papers unless prior authorization has been given by the court. Sur-reply papers submitted in violation of this rule will be disregarded.

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

Applies to

Discovery motion

Every discovery motion must include a good-faith affirmation complying with 22 NYCRR 202.7(c), or the motion will be denied.

All discovery motions must contain an affirmation of good faith that strictly complies with 22 NYCRR 202.7(c). Failure to comply will result in denial of the motion.

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

Applies to

Confidentiality agreement

If requested, a proposed Confidentiality Agreement must be submitted for the court to order.

If sought, a proposed Confidentiality Agreement, is to be submitted to be So Ordered.

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

Applies to

Confidentiality agreement

When changes to the model confidentiality agreement are required, the parties must submit a signed agreement showing the changes and a redline copy for the court to review.

If changes to a Model Form are required, the parties are to submit a signed Confidentiality Agreement with changes and a red line copy for the court’s review and consideration.

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

Applies to

Motion

For summary-judgment motions other than under CPLR §3213, the moving party must attach a concise numbered statement of undisputed material facts with supporting evidence citations.

Upon motion for summary judgment other than pursuant to CPLR §3213, movant shall annex to the motion a short and concise statement, in numbered paragraphs with a citation to the evidence submitted in support of that paragraph, of the material facts as to which the moving party contends there is no genuine issue of fact.

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

Applies to

Admission pro hac vice request

An admission pro hac vice request, including one made by stipulation, must include an attorney affirmation, an applicant affirmation, and a recent certificate of good standing from the applicant's licensing jurisdiction.

including requests made by stipulation, shall be accompanied by an affirmation in support by a member of the Bar of the State of New York, an affirmation from the applicant, and a recent certificate of good standing of the applicant from the jurisdiction in which he or she is admitted to practice.

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

Applies to

Trial binder

The pretrial binders must include the applicable jury questions or issues, jury charges or governing law, marked pleadings and expert reports, trial-use EBTs, interrogatories, and bills of particulars, and anticipated exhibits pre-marked for identification.

Any jury questions (or for a non-jury case, the issues to be decided); Any jury charges (or for a non-jury case, the law to be considered by the Court); All marked pleadings and expert reports; Copies of EBTs, Interrogatories and Bills of Particulars to be used at trial; and Any anticipated exhibits are to be pre-marked for identification;

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

Civil cases

Applies to

Adjournment letter

An approved adjournment must be documented by a letter filed immediately through NYSECF.

If the adjournment is approved, a letter must immediately be filed via NYSECF.

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

Civil cases

Applies to

Letter

The discovery notice must identify the requested relief and its basis and include the parties’ exchanged correspondence.

The written notice must indicate the relief that will be sought and the basis for such relief, together with the exchanged correspondence.

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

Applies to

Correspondence

All correspondence must identify the action by title and index number.

All correspondence must include the title of the action and index number.

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

Applies to

Motion working copy

A required motion working-copy placeholder for an electronically filed voluminous exhibit must state “Exhibit ___ electronically filed.”

The working copy of a motion must include all documents filed in support of the motion, excluding voluminous exhibits exceeding 20 pages in length, which shall be so indicated by use of a placeholder page stating “Exhibit ___ electronically filed.”

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

Applies to

Working copy

Must include

notice of electronic filing

Every working copy must include a firmly fastened NYSCEF Confirmation Notice and comply with applicable e-filing rules; a working copy lacking the notice will be rejected.

All working copies must include a copy of the NYSCEF Confirmation Notice, firmly fastened, and must comply with all requirements of the Nassau County and Supreme Courts E- Filing Rules. The Confirmation Notice is generated when the case is e-filed and is available in the specific case file at www.nycourts.gov/efile. Working copies that do not include a NYSCEF Confirmation Notice will be rejected.

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

Applies to

Note of issue

A party may not file a Note of Issue without the court's permission.

Counsel and pro se (self-represented) litigant(s) are not permitted to file a Note of Issue in any action unless permission to do so is granted by the Court.

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

Applies to

Ai prepared document

Must include

ai disclosure

An attorney or pro se party using AI to prepare a court document must submit a certification identifying the AI programs used and confirming the accuracy of the AI-created portion.

An attorney or pro-se party who has used Artificial Intelligence (“AI”) to prepare any document submitted to the court must also submit a certification setting forth (i) the specific AI program(s) used in preparation of the document; and (ii) that the accuracy of the portion of the document created using AI has been confirmed.

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

Applies to

Voluminous exhibits

The working copy must contain a placeholder page stating “Exhibit ___ electronically filed” for voluminous exhibits provided electronically.

Voluminous Exhibits exceeding twenty (20) pages in length may be provided electronically and shall be indicated in the Court’s working copy by use of a placeholder page stating “Exhibit ___ electronically filed.”

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

Applies to

Emergency order to show cause

An emergency Order to Show Cause must include a special affidavit based on personal knowledge and an affirmation explaining the emergency in detail.

An “Emergency” Order to Show Cause requires a special affidavit based upon personal knowledge and an affirmation explaining in detail the nature of the emergency.

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

Applies to

Motion for default judgment

A movant seeking entry of default judgment must submit the Part's annexed default-judgment checklist on the motion's submission date.

The movant on a motion for entry of a default judgment shall submit the Part’s annexed checklist for default judgment on the submission date.

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

Applies to

Infant compromise petition

All applications for court approval of an infant compromise must be submitted through the Infant's Compromise Clerk.

All applications for Court approval of a proposed compromise of an infant’s claim must be submitted through the Infant’s Compromise Clerk (“ICC”).

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

Applies to

Infant compromise paperwork

Infant compromise paperwork must include the specified medical report or affidavit and applicable records, written settlement proof from defense counsel, and defense counsel's written waiver of appearance at the hearing.

The infant’s compromise paperwork submitted to the ICC must include, inter alia, (i) a medical report/affidavit indicating whether the injured infant plaintiff has fully recovered, and if not, the nature and extent of the injuries and anticipated future treatment, if any, and related medical records where applicable; (ii) proof of settlement of the infant’s claim from defense counsel, in writing; and (iii) defense counsel’s waiver of appearance at the Infant’s Compromise Hearing, in writing.

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

Applies to

Infant compromise papers

An affidavit consenting to the compromise must be included when the infant is fourteen years old or older.

If the infant is fourteen years or older, an affidavit of consent from the infant must be included in the submitted papers.

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

Applies to

Papers submitted for signature

Papers submitted for the judge's signature must identify the case and document type on the signature page.

All papers which are submitted for signature by the Court shall be identified on the signature page so that the document being signed by the Court can be identified. Example: Jones v. Jones, Index #/year, Type of Document.

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

Applies to

Video recording

A party intending to use a videotape or other video recording must submit a copy and, if applicable, its transcript to the Court at least two weeks before trial.

If a party intends to use a videotape at trial, that party shall submit a copy of the videotape (or other video recording) and transcript of same, if applicable, to the Court at least two (2) weeks prior to the scheduled trial date in order to allow the Court to rule on the admissibility of the videotape (or other video recording), and any Objections made during the video recording.

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

Applies to

Departure list

In jury trials alleging professional negligence, each party-plaintiff must furnish the court and all counsel, no later than the next trial session after the party rests or as the court directs, with a list of proposed departures from applicable-care standards asserted to have been testified to, including trial-transcript page references.

In jury trials involving claims of professional negligence, no later than the next trial session after the party “rests,” or such other time as the Court may direct, each party-plaintiff shall furnish the Court and all counsel with a list of proposed departures from the standards of applicable care which that party asserts were testified to by its expert(s) or other witnesses. Page references to the trial transcript are required.

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

Applies to

Affidavit or affirmation of urgency

A matter is not deemed urgent unless an affidavit or affirmation of urgency is filed, which may be filed at any time during the proceeding.

A matter will not be deemed Urgent unless an Affidavit/Affirmation of Urgency is filed. The filing may occur at any point during the pendency of the proceeding.

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

Applies to

Proposed order

All proposed orders must be submitted with a notice of settlement on at least 10 days' notice.

5. Proposed Orders: All proposed Orders are to be submitted with Notice of Settlement on at least 10 Days Notice.

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

Applies to

Request for adjournment

An adjournment request based on counsel's actual engagement in another matter must include a conforming Affirmation of Actual Engagement.

If the application is based on counsel’s actual engagement on another matter, an Affirmation of Actual Engagement, in conformity with 22 NYCRR Section 125, must accompany the Request for Adjournment form.

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

Applies to

Reply

Replies are prohibited on Orders to Show Cause, and sur-replies are prohibited on every motion.

Replies are not permitted on OSC applications and sur-replies are not permitted on any and all motions.

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

Applies to

Settlement notice letter

Counsel must notify the Court by letter when a submitted motion is wholly or partly settled, identifying the motion, submission date, settled portions, and remaining issues.

If all or part of a submitted motion is settled, counsel shall notify the Court by letter setting forth the motion sequence number, the date the motion was submitted, what aspects of the motion have been settled and what issues remain to be decided.

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

All exhibits must be pre-marked for identification before trial begins.

All exhibits shall be pre-marked for identification prior to the commencement of trial.

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

Applies to

Correspondence

All correspondence to the court must identify the action by title and index number.

All correspondence must include the title of the action and index number.

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

Applies to

Adjournment request

An adjournment request based on the engagement of new counsel must include an Affirmation of Engagement complying with 22 NYCRR 125.1.

Adjournments requested because of engagement of counsel must be accompanied by an Affirmation of Engagement in conformity with 22 NYCRR 125.1.

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

Applies to

Motion

Appearances and oral argument on motions and orders to show cause are not permitted unless the Court directs them.

There shall be no appearances or oral arguments on motions or orders to show cause unless directed by the Court.

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

Applies to

Motion

If AI was used to prepare motion papers, counsel must submit an affirming the thorough accuracy and validity review of all AI-provided legal references.

If counsel did use AI in preparation of the motion papers, counsel must then submit an affirmation that all case law and other references provided by AI were thoroughly checked for accuracy and validity.

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

Applies to

Order to show cause

An emergency order to show cause requires both a special affidavit based on personal knowledge and an affirmation detailing the emergency.

An “Emergency” Order to Show Cause requires a special affidavit based upon personal knowledge and an affirmation explaining in detail the nature of the emergency.

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

Applies to

Proposed order

A proposed Infant’s Compromise Order must identify the infant-plaintiff by full name and include the quoted finding concerning confidential personal information.

A proposed Infant’s Compromise Order must include the full name of the infant- plaintiff and reference therein the following: “Confidential personal information is included in this Order upon the Court’s finding that good cause exists pursuant to 22 NYCRR 202.5[e][2], in that the inclusion of the full name and date of birth of the minor, as well as related information, is material and necessary to effectuate the terms of this Order.”

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

Applies to

Proposed verdict sheet

All counsel or self-represented litigants must jointly prepare a Proposed Verdict Sheet and email it in Microsoft Word format to the specified court address as directed and no later than the first pretrial conference.

A Proposed Verdict Sheet, jointly prepared by all counsel/pro se (self-represented) litigant(s) must be submitted by email in Microsoft Word format to the Court’s remote email (JudgeKennyRemote@nycourts.gov), as directed but the Court and no later than the first Pre-Trial Conference before this Part.

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

Applies to

Trial video

A party intending to use a trial video must submit a copy and, if applicable, its transcript to the court at least two weeks before trial so the court can address admissibility and objections.

If a party intends to use a video at trial, that party shall submit a copy of the video and transcript of same, if applicable, to the Court at least two (2) weeks prior to the scheduled trial date to allow the Court to rule on the admissibility of video, conduct a hearing if applicable, and any objections made to the video.

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

Applies to

Proposed departures

In professional-negligence jury trials, each plaintiff must furnish the court and all counsel with a final list of proposed departures, including transcript page references, by the next trial session after resting or at another time directed by the court.

In jury trials involving claims of professional negligence, no later than the next trial session after the party “rests,” or such other time as the Court may direct, each party-plaintiff shall furnish the Court and all counsel with the final list of proposed departures from the standards of applicable care which that party asserts were testified to by its expert(s) or other witnesses. Page references to the trial transcript are required.

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

Civil cases

Applies to

Discovery motion

Every discovery motion must include a good-faith affirmation complying with 22 NYCRR § 202.7.

All discovery motions shall contain an affirmation of good faith in accordance with 22 NYCRR § 202.7.

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

Applies to

Adjournment request

A trial-engagement-based adjournment request must include an Affirmation of Engagement conforming to 22 NYCRR Part 125.

Adjournments requested due to an attorney=s actual engagement on trial must be accompanied by an Affirmation of Engagement in conformity with 22 NYCRR Part 125.

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

Applies to

In limine motion

A party intending to move in limine must submit a brief written affirmation describing the application.

In Limine applications: Any party intending to make a motion in limine shall submit a brief written affirmation setting forth the nature of the application and any

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

Applies to

Infant compromise paperwork

Infant compromise paperwork must include a medical report or affidavit and related records when applicable, written proof of settlement from defense counsel, and either defense counsel’s written waiver of appearance or its appearance at the hearing.

The infant’s compromise paperwork submitted to the ICC must include, inter alia, (i) a medical report/affidavit indicating whether the injured infant plaintiff has fully recovered, and if not, the nature and extent of the injuries and anticipated future treatment, if any, and related medical records where applicable; (ii) proof of settlement of the infant’s claim from defense counsel, in writing; and (iii) defense counsel’s waiver of appearance at the Infant’s Compromise Hearing, in writing (or must appear).

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

Applies to

Motion

Must include

proposed order, certificate of service

A motion must include an appropriate proof of service when required and a proposed order, although dispositive motions do not require a proposed order.

All motions shall have the appropriate proof of service on all parties where required annexed to the motion as well as a proposed Order with respect to the requested relief, except on dispositive motions which will not need a proposed Order.

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

Applies to

Discovery motion

A discovery motion that cannot be resolved another way must be supported by counsel's affidavit or affirmation describing the required conference, including its date, time, participants, and duration.

In the event that a discovery dispute cannot be resolved other than by motion practice, each such discovery motion shall be supported by an affidavit or affirmation from counsel attesting to counsel having conducted an in-person or telephonic conference, stating forth the date and time of such conference, persons participating, and the length of time of the conference.

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

Applies to

Tro application

A TRO application must include an affirmation explaining that notice was given, could not be given despite a good-faith effort, or would cause significant prejudice.

The application for a TRO must include an affirmation attesting as to notice demonstrating that notice has been given, or notice could not be given despite a good faith effort to provide it, or there will be significant prejudice to the party seeking the restraining order by giving notice.

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

Applies to

Motion in limine

On the first Part appearance, a party intending to file a motion in limine must submit a brief written affirmation describing the application and supporting law, with a separate affirmation for each motion.

On the first appearance in the Part for trial, any party intending to make a motion in limine shall submit a brief written affirmation setting forth the nature of the application and any supporting statutory or case law. There shall be a separate affirmation for each motion in limine.

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

Applies to

Proposed verdict sheet

At the first trial appearance, each party must provide a proposed verdict sheet and jury interrogatories.

On the first appearance in the Part for trial, each party shall supply the Court, counsel, and self-represented parties with a proposed verdict sheet and jury interrogatories.

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

Applies to

Malpractice departures list

In professional-negligence cases, defense counsel must provide the court and plaintiff counsel with a list of asserted departures from good and accepted practice after the plaintiff rests or at the court's direction, including transcript page references when available.

In cases involving claims of professional negligence, on the next trial session after a party rests, or such other time as the Court may direct, counsel for the defendant(s) shall furnish the Court, and counsel for the plaintiff, with a list of the departures from the standards of good and accepted practice which that counsel for the defendant asserts were testified to by its expert witness or witnesses. Where the testimony has been transcribed, page references will be required.

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

Applies to

Expert witness material list

Unless pre-marked, each party must submit a specific list of materials each intended expert witness is expected to rely on at the first trial appearance.

On the first appearance in the Part for trial, and if not otherwise pre-marked, each party shall, with respect to each expert witness that party intends to call, submit a list identifying with specificity any record, report, photograph, film, computer animation, x-ray, CT scan, MRI, EMG study or similar item or items to which an expert witness is expected to make reference as supporting in whole or in part the opinion he or she will offer.

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

Applies to

Witness list

At the start of trial or when directed by the court, each party must provide a written witness list specifying witnesses, testimony order, and estimated testimony length, and counsel must separately identify witnesses limited to rebuttal or credibility purposes.

At the commencement of the trial, or at such time as the Court dictates, each party shall identify in writing the witness it intends to call, the order in which they shall testify and the estimated length of their testimony, and shall provide a copy of such witness list to opposing counsel, and self-represented parties. Counsel shall separately identify for the court only a list of the witnesses who may be called solely for rebuttal or with regard to credibility.

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

Applies to

Motion in limine

Every intended motion in limine must be accompanied by a written affirmation describing the application and any supporting statute or case law.

All counsel and pro se (self-represented) litigant(s) intending to make a motion in limine shall submit a written affirmation setting forth the nature of the application and any supporting statutory or case law.

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

Applies to

Preliminary requests to charge

All counsel and pro se litigants must submit preliminary Requests to Charge to the Court and every other party or counsel.

All counsel and pro se (self-represented) litigant(s) shall submit to the Court and every other party and/or counsel a copy of its preliminary Requests to Charge.

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

Applies to

Requests to charge

Any requested deviations from or additions to the Pattern Jury Instructions must be submitted with their full text and supporting legal authority.

Where deviations from, or additions to, the PJI are requested, the full text of such requests must be submitted, together with any supporting legal authority.

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

Applies to

Proposed verdict sheet

A jointly prepared Proposed Verdict Sheet must be emailed in Microsoft Word format to the Court's remote email no later than the first Pre-Trial Conference.

A Proposed Verdict Sheet, jointly prepared by all counsel/pro se (self-represented) litigant(s) must be submitted by email in Microsoft Word format to the Court’s remote email (JudgeKapoorRemote@nycourts.gov), as directed by the Court and no later than the first Pre-Trial Conference before this Part.

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

Applies to

Proposed verdict sheet

If the parties cannot agree on jury questions before the Pre-Trial Conference, each side must separately submit a Microsoft Word Proposed Verdict Sheet by email to the Court.

If counsel/pro se (self- represented) litigant(s) cannot agree to the questions to be posed to the jury prior to the Pre-Trial Conference, each side shall submit a Proposed Verdict Sheet by email in Microsoft Word format to the Court’s remote email (JudgeKapoorRemote@nycourts.gov).

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

Applies to

Pleadings and bills of particular

Counsel and pro se litigants must submit copies of marked pleadings, their amendments, and all served bills of particular to the Court.

Counsel and pro se (self-represented) litigant(s) shall submit to the Court a copy of the marked pleadings, amendments thereto, and all bills of particular served.

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

Applies to

Party contentions

Counsel and pro se litigants must provide the Court with each party's contentions and a list of causes of action to be tried.

Counsel and pro se (self-represented) litigant(s) shall further provide the Court with the contentions of each party, as well as a list of the causes of actions to be tried.

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

Applies to

Trial exhibit binder

An indexed binder or notebook of trial exhibits must be submitted for the Court's use; electronic equivalents are insufficient.

An indexed binder or notebook of trial exhibits shall also be submitted for the Court’s use. Electronic Equivalents will not suffice for the Court.

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

Applies to

Trial witness list

At the start of trial or when directed by the Court, each party must provide a written witness list identifying the witnesses, testimony order, and estimated duration to the Court and, if applicable, opposing parties or counsel.

At the commencement of the trial, or at such time as the Court dictates, each party shall identify in writing the witness(es) it intends to call, the order in which they shall testify and the estimated length of their testimony and shall provide a copy of such witness list to opposing parties and/or counsel if applicable, and the Court.

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

Applies to

Reputation or rebuttal witness list

Counsel and pro se litigants must separately provide the Court with a list identifying witnesses who may be called solely for rebuttal or on credibility.

All counsel and pro se (self-represented) litigant(s) shall separately identify for the Court only a list of the witnesses who may be called solely for rebuttal or with regard to credibility.

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

Applies to

Trial transcript

At the conclusion of trial, parties or counsel must provide the court with a full and complete trial transcript.

Upon conclusion, the parties and/or counsel shall be required to provide the Court with a full and complete transcript of the trial.

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

Applies to

Proposed infant compromise order

A proposed infant compromise order must identify the infant plaintiff by full name and include the quoted good-cause and confidentiality language.

A proposed Infant’s Compromise Order must include the full name of the infant- plaintiff and reference therein the following: “Confidential personal information is included in this Order upon the Court’s finding that good cause exists pursuant to 22 NYCRR § 202.5 [e][2], in that the inclusion of the full name and date of birth of the minor, as well as related information, is material and necessary to effectuate the terms of this Order.”

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

Applies to

Infant compromise paperwork

Infant compromise paperwork must include the specified medical report or affidavit and records, written settlement proof from defense counsel, and defense counsel’s written hearing-appearance waiver.

The infant’s compromise paperwork submitted to the ICC must include, inter alia, (i) Paperwork: a medical report/affidavit indicating whether the injured infant plaintiff has fully recovered, and if not, the nature and extent of the injuries and anticipated future treatment, if any, and related medical records where applicable; (ii) proof of settlement of the infant’s claim from defense counsel, in writing; and (iii) defense counsel’s waiver of appearance at the Infant’s Compromise Hearing, in writing.

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

Applies to

Motion

The motion sequence number must appear on the front page of every paper related to the motion or cross-motion.

All motion papers shall have the motion sequence number on the front page of all papers related to the motion or any cross-motion.

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

Applies to

Memorandum of law

Every moving and responsive motion paper submitted by notice of motion or order to show cause must include a memorandum of law subject to Commercial Division Rule 17 word limits.

All motion papers, moving as well as responsive, whether by notice of motion or order to show cause, must include a memorandum of law, subject to word limits set forth in Commercial Division Rule 17.

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

Applies to

Motion

A citation to deposition or other testimony must identify the exhibit, page, and line number where the testimony appears.

Where reference is made in a motion, or order to show cause, to testimony from a deposition or elsewhere, the party making such reference shall identify the exhibit, page and line number where the testimony is found.

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

Applies to

Exhibits

Each motion exhibit must be clearly labeled with its identifying information.

Exhibits to motions shall be uploaded to NYSCEF individually, with each Exhibit clearly labeled with its respective identifying information.

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

Applies to

Memorandum of law

Electronically submitted memoranda of law must hyperlink cited legal authorities to an accessible legal-research database or a state or federal government website.

That electronically submitted memoranda of law include hyperlinks to cited court decisions, statutes, rules, regulations, treatises, and other legal authorities in either legal research databases to which the Court has access, or in state or federal government websites;

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

Electronically submitted documents citing prior NYSCEF filings must link to the cited docket entries unless the documents are accessible through bookmarks, and links may not provide access to sealed or nonpublic documents.

In addition to each electronically submitted memorandum of law, for other documents that cite to additional documents previously filed with NYSCEF, they shall include a hyperlink to the NYSCEF docket entry for the cited documents, enabling access to the cited documents through the hyperlink. Hyperlinks may not provide access to documents filed under seal or otherwise not in the public record. Cited documents filed with NYSCEF that are accessible through bookmarks in the electronically submitted document need not also be hyperlinked.

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

Applies to

Adjournment confirmation

A letter or stipulation confirming the adjourned date must be filed or emailed, served on all parties, and submitted by the motion's return date.

The Court requires the filing or e-mailing of a letter or stipulation confirming the adjourned date, served upon all parties, on or before the return date of the motion.

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

Applies to

Motion

Each branch of relief in a motion must be numbered or lettered to correspond to the supporting affirmation or affidavit paragraphs addressing that relief.

Various branches of the motion as delineated in the Notice of Motion or Order To Show Cause are to be preceded by a number or letter which corresponds to a number or letter in the supporting affirmations and affidavits containing the numbered paragraphs dealing with the particular relief sought.

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

Applies to

Proposed order

Must include

proposed order

When all or part of a motion is settled, the submission must include a proposed order giving at least 10 days' notice of settlement, or a signed waiver of settlement, for the court's conforming copy.

If all or part of a submitted motion is settled, a proposed order with notice of settlement (on at least 10 days notice), or a signed waiver of settlement, shall be submitted with a copy to be conformed.

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

Applies to

Letter

The settlement order must be accompanied by a letter identifying the submission date, the settled aspects of the motion, and any remaining issues.

Such order shall be accompanied by a letter setting forth the date the motion was submitted, what aspects of the Motion have been settled and what issues remain to be decided.

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

Applies to

Stipulation

A copy of the stipulation settling the identified issues must be sent to the court.

A copy of the stipulation settling such issues shall be forwarded to the Court.

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

Applies to

Transcript

When a motion is resolved wholly or partly on the record, counsel must obtain the transcript so it can be incorporated into the order unless the court directs otherwise.

If the motion is resolved, in whole or part, on the record, counsel shall obtain such transcript so that same can be "so ordered", unless the Court otherwise directs.

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

Applies to

Sanctions application

A sanctions application must include proof that the moving party first sought withdrawal or discontinuation of the conduct for which sanctions are sought.

The Court will not consider a sanctions application unless the moving party first seeks withdrawal or discontinuation of the purported sanctionable conduct. Proof of such request must be made a part of the sanctions application.

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

Applies to

Trial supporting submissions

Before trial, plaintiff's counsel must furnish the court with marked pleadings, applicable statutory provisions, bills of particulars, relevant expert reports, and specified reports, depositions, and written statements.

A. Mark Pleadings: Plaintiff's counsel shall furnish the court with copies of: 1. Marked pleadings as required by CPLR 4012: 2. A copy of any statutory provisions in effect at the time the cause of action arose upon which either the plaintiff or defendant relies: 3. The bill(s) of particulars; 4. All expert reports relevant to the issues; 5. All reports, depositions and written statements which may be used to either refresh a witness' recollection and/or cross-examine the witness.

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

Applies to

Deposition testimony page line identification

If deposition testimony will be read into evidence rather than merely used on cross-examination, counsel must provide the court and adversary with page and line numbers well in advance so objections can be addressed before the jury hears the testimony.

6. If any part of a deposition is to be read into evidence (as distinguished from mere use on cross-examination) you must, well in advance, provide the court and your adversary with the page and ===== PAGE 6 ===== line number of all such testimony so that all objections can be addressed prior to use before the jury.

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

Applies to

Trial exhibit notice

Before trial, counsel must confer in good faith to resolve exhibit objections and must notify the court if they cannot stipulate to an exhibit's admission.

Prior to trial (a) counsel shall confer in good faith in an effort to agree on the exhibits to be offered into evidence without objection and shall notify the Court of their inability to stipulate to the admission of any exhibits to be offered at trial. The Court will rule on the objections to the contested exhibits at the earliest possible time.

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

Applies to

Papers submitted for signature

Papers submitted for the court’s signature must identify the document on the signature page using information such as the case name, index number and year, and document type.

All papers which are submitted for signature by the Court shall be identified on the signature page so that the document being signed by the Court can be identified. Example: Jones v. Jones, Index #/year, Type of Document.

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

Applies to

Motion in limine

Applications in limine may address only evidentiary admissibility issues.

Applications shall be limited to issues regarding the admissibility of evidence.

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

Counsel should provide a proposed-witness list with addresses and phone numbers, along with counsel’s cell numbers, two days before the hearing and email the information to the judge and Sr. Court Clerk.

A list of proposed witnesses with addresses and phone numbers for the Clerk’s information should be provided two days before the hearing along with cell phone numbers of counsel. This information should also be emailed to the judgegugertyremote@nycourts.gov mailbox and Jamie Corsitto, Sr. Court Clerk, jcorsitt@nycourts.gov.

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

A list of expert witnesses and copies of their reports is required.

A list of expert witnesses with copies of their reports.

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

Objections should identify only their grounds, while further argument will be permitted only when invited by the Court.

Objections should be stated without argument except to state the grounds, e.g., hearsay, relevance, etc. If further argument is appropriate, it will be invited by the Court.

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

An urgent conference request should be submitted as a completed conference request form by email to chambers.

For urgent matters requiring immediate attention, parties should email chambers a completed conference request form that can be found on the Supreme Court’s website.https://ww2.nycourts.gov/sites/default/files/document/files/2020- 04/Email%20Request%20For%20Conference%20Form.pdfhttps://ww2.nycourts.gov/sites/ default/

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

Applies to

Motion

All motions, cross-motions, and ex parte applications must comply with 22 NYCRR §§ 202.5 and 202.7, and noncompliant papers may be rejected.

J. All motions, cross motions, and ex parte applications submitted shall be in compliance with Uniform Rules for the Supreme and the County Court (22 NYCRR) §§ 202.5 and 202.7. Any failure to comply with the requirements of this section may result in the rejection of the non-complying papers.

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

Applies to

Affirmation of engagement

An adjournment requested because of an attorney's actual trial engagement must include an Affirmation of Engagement complying with 22 NYCRR Part 125.

Adjournments requested due to an attorney=s actual engagement on trial must be accompanied by an Affirmation of Engagement in conformity with 22 NYCRR Part 125.

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

Applies to

Trial objections

Trial counsel should state objections without argument except for a brief statement of the ground, because the court will invite further argument when appropriate.

Objections should be stated without argument except to simply state the ground therefor, e.g., hearsay, relevance, etc. If further argument is appropriate, it will be invited by the court;

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

Applies to

Bill of particulars

Parties must provide a copy of all bills of particulars.

2. A copy of all bill(s) of particulars;

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

Applies to

Expert disclosure

If applicable, parties must provide copies of all expert disclosures served under CPLR § 3101(d).

3. A copy of all expert disclosures served pursuant to CPLR Section 3101(d) (if applicable);

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

Applies to

Trial witness list

Parties must provide a list of probable trial witnesses.

4. A list of probable trial witnesses;

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

Applies to

Prior decisions and orders

If applicable, parties must provide copies of all prior decisions or orders issued on motions in the case.

5. A copy of all prior Decisions or Orders on motions issued in the case (if applicable);

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

Applies to

Statutory provisions

Parties must provide any statutory provisions from the time the cause of action arose on which they intend to rely.

6. Any statutory provision(s) in effect at the time that the cause of action arose upon which either party intends to rely;

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

Applies to

Apportionment request

Parties must provide any anticipated CPLR Article 16 apportionment request against alleged culpable nonparties.

8. Any anticipated request for apportionment as to alleged culpable non-parties pursuant to CPLR Article 16.

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

Applies to

Proposed verdict sheet

If counsel and pro se litigants cannot agree on the jury questions before the charge conference, each side must present its own proposed verdict sheet.

If counsel/pro se (self-represented) litigant(s) cannot agree to the questions to be posed to the jury prior to the Charge Conference, each side will present a Proposed Verdict Sheet.

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

Applies to

Motion

The Court generally does not hear oral argument on motions, but a pro se party or counsel may request it by a letter accompanying the motion papers.

The Court generally will not entertain oral argument of motions, however, a pro se party or counsel may request oral argument by letter accompanying the motion papers in accordance with 22 NYCRR 202.8-f.

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

Applies to

Trial authorization

Subpoenaed trial records must generally be sent to the Subpoenaed Records Room, with the trial authorizations completed accordingly.

Except as otherwise permitted by the CPLR, subpoenaed records for trial must be sent to the Subpoenaed Records Room. Trial authorizations should be filled out accordingly.

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

Civil cases

Applies to

Statement of material facts

The moving party should provide a short, concise statement in numbered paragraphs of material facts it contends are undisputed, omit facts irrelevant to the motion’s disposition, and cite supporting or opposing evidence after each fact.

The statement should be short and concise, in numbered paragraphs, of the material facts which the moving party contends there is no genuine issue to be tried. The statement should not contain facts that are not pertinent to the disposition of the motion. Each statement of material fact must be followed by citation to evidence submitted in support or opposition to the motion.

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

Applies to

Affirmation or affidavit of actual engagement

An attorney or litigant engaged in another court proceeding must electronically file and email an affirmation or affidavit of actual engagement before the scheduled proceeding or conference.

If an Attorney or Litigant who is scheduled to appear is actively engaged in another Court proceeding, they must file in NYSCEF and E-mail an Affirmation/Affidavit of Actual Engagement prior to the Court Proceeding or Conference.

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

Applies to

Conference request

Every conference request must explain why the conference is needed and be served on all parties.

All requests shall explain the need for the Conference and be served on ALL parties.

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

Applies to

Court filed papers

Court-filed papers, other pleadings, and notices of appearance must include a valid email address for the attorney of record or self-represented litigant.

B. Email Address: All Court filed papers, other Pleadings and Notices of Appearance must contain a valid E-mail address for the Attorney of Record or Self-Represented Litigant.

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

Applies to

Judicial subpoena

Every proposed judicial subpoena must include an affirmation in support and any applicable law.

C. Judicial Subpoenas: Any proposed Judicial Subpoenas must include an Affirmation in Support of same and include any Applicable Law.

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

Civil cases

Applies to

Stipulation

A stipulation concerning a motion must state whether it resolves and withdraws the entire motion or identify which branches of the motion it resolves.

Any stipulation submitted to the court regarding a motion shall state if the stipulation resolves the entire motion and is withdrawn, or state which branches are resolved.

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

Applies to

Adjournment confirmation letter

Must include

case number

A confirming letter should be filed through NYSCEF and state the consent adjournment date, include the full caption and index number, note the current calendar date, and confirm simultaneous copying of all parties.

Letters should be filed via NYSCEF confirming adjournments and shall state that the Court has adjourned the conference on consent of the parties to the specified date, and shall contain the full caption, including the Index Number, a notation indicating the current date the matter is on the Court’s calendar, and that all parties have been simultaneously copied.

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

Applies to

Motion

A party may request oral argument by placing the specified notation above the Index Number on the first page of the motion papers.

Parties seeking oral argument of a motion may request that oral argument be heard by stating “Oral Argument Requested” above the Index Number on the first page of the papers submitted.

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

Applies to

Exhibits

References to exhibits longer than 10 pages must identify the cited page, and an exhibit without page numbers must be Bates-stamped.

Reference to exhibits longer than ten (10) pages shall indicate the page number on which the information cited is contained. Should the exhibit not contain page numbers, the exhibit shall be bates-stamped.

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

Applies to

Papers submitted for signature

Papers submitted for the Court’s signature must identify the document on the signature page, using the case name, index number and year, and document type.

All papers which are submitted for signature by the Court shall be identified on the signature page so that the document being signed by the Court can be identified. Example: Jones v. Jones, Index #/year, Type of Document.

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

Applies to

Affidavit

An affidavit, affirmation, or memorandum of law exceeding 4,500 words must include a bookmark listing its contents.

Each affidavit, affirmation, or memorandum of law more than 4,500 words shall include a bookmark providing a listing of the document's contents.

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

Applies to

Foreign language document

Documents in a foreign language must be translated as required by CPLR 2101(b).

Documents in a foreign language shall be translated as required by CPLR 2101(b).

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

Applies to

Requests to charge

Pattern Jury Instruction charges may be cited by number without reproduction, but requested modifications must be highlighted.

Charges from the most recent and current Pattern Jury Instructions may be identified by number without necessity of reproduction unless a modification of the standard charge is requested, in which case the modification is to be highlighted.

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

Applies to

Deposition transcript

A complete deposition transcript should be available to the Court at the pretrial conference, and each counsel or pro se litigant must separately provide the portions of testimony they will offer on their case-in-chief.

If deposition transcripts are to be utilized, a complete copy of that deposition transcript should be made available to the Court at the pretrial conference. All counsel and pro se (self-represented) litigant(s) must separately provide to the Court those portions of the testimony to be offered into evidence on a their case-in-chief.

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

Applies to

Affidavit

Counsel affidavits and affirmations should not contain legal arguments.

Therefore, affidavits or affirmations of counsel should not contain legal arguments.

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

Applies to

Trial exhibits

Previously unidentified exhibits used solely for credibility or rebuttal need not be pre-marked.

Exhibits not previously identified, which are to be used solely for credibility or rebuttal, need not be pre-marked.

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

Applies to

Motion

A party may request oral argument by placing the specified notation above the Index Number on the motion papers' first page.

Parties seeking oral argument of a motion may request that oral argument be heard by stating “Oral Argument Requested” above the Index Number on the first page of the papers submitted.

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

Applies to

Oral argument request

Oral argument of motions is generally not entertained, but a pro se party or counsel may request it by accompanying letter.

3. Oral Argument: The Court generally will not entertain oral argument of motions, however, a pro se party or counsel may request oral argument by letter accompanying the motion papers in accordance with 22 NYCRR 202.8-f.

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

Parties are encouraged to provide stipulated facts and to stipulate to facts and exhibits.

A statement of stipulated facts. Parties are encouraged to stipulate to facts and/or exhibits.

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

Applies to

Motion

Counsel need not appear on a motion's submission date unless the Court directs them to appear.

Counsel are not required to appear on the submission date unless directed by the Court.

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

Applies to

Proposed order

After a bench decision, a party may submit a proposed order together with the transcript of the proceedings for the court to sign.

Where the Court issues a Bench Decision and a party desires a written Decision or Order, the party may submit a proposed Order to the Court, together with the transcript of the proceedings at which the Bench Decision was rendered to be “So Ordered”.

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

Applies to

Motion

A party may request oral argument by stating “Oral Argument Requested” above the Index Number on the first page of the submitted papers.

Parties seeking oral argument of a motion or Order to Show Cause may request that oral argument be heard by stating “Oral Argument Requested” above the Index Number on the first page of the papers submitted.

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

Applies to

Proposed order or judgment

After a bench decision, a party may submit a proposed order together with the transcript of the proceedings for the judge's signature.

Where the Court issues a Bench Decision and a party desires a written Decision or Order, the party may submit a proposed Order to the Court, together with the transcript of the proceedings at which the Bench Decision was rendered to be “So Ordered”.

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

Applies to

Proposed verdict sheet

The proposed verdict sheet may be supplemented, modified, or edited during the trial.

The proposed verdict sheet may be supplemented, modified or edited as the trial progresses.

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

Applies to

Preliminary requests to charge

Preliminary Requests to Charge may be supplemented, modified, or edited as the trial progresses.

The preliminary requests may be supplemented, modified, and/or edited as the trial progresses.

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

Applies to

Stipulation

Counsel and pro se litigants are encouraged to stipulate to facts or exhibits.

Pro se (self-represented) litigant(s) and/or counsel are encouraged to stipulate to facts and/or exhibits.

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

Applies to

Motion

The affirmation requirement does not apply to the identified special-proceeding or order-of-protection motions unless the Court orders otherwise.

Please note that this requirement shall not apply to orders to show cause or motions in special proceedings brought under Article 7 of the Real Property Actions and Proceedings Law, nor to orders to show cause or motions requesting an order of protection under section 240 of the Domestic Relations Law, unless otherwise ordered by the Court.

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

A request for oral argument may be included in either the notice of motion or the opposition papers.

Requests for oral argument may be included in the notice of motion or in the opposition papers.

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

Applies to

Motion

Counsel need not appear on a motion's submission date unless the Court directs an appearance.

Counsel are not required to appear on the submission date unless directed by the Court.

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

Applies to

Sanctions application

Must include

local rule certificate ?

The Court will not consider an application for sanctions unless the moving Party first seeks withdrawal or discontinuance of the offending act or action or demands a required or necessary action which is refused. Proof of such request must be made a part of the sanction application.

Summary: A sanctions application will not be considered unless the moving party first seeks withdrawal, discontinuance, or a required action, and includes proof of that request.

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

Applies to

Motion in limine ?

Must include

legal argument ?

Counsel shall submit a brief written affirmation and/or memorandum of law setting forth the nature of the application and any supporting authority or case law.

Summary: Counsel must submit a brief written affirmation or memorandum of law explaining the motion in limine and providing supporting authority or case law.

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

Civil cases

Applies to

Trial preparation submissions ?

o Marked pleadings;

Summary: Counsel must provide marked pleadings for trial.

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

Applies to

TRO

Failure to comply with the above mandate will result in the striking of the proposed stay or TRO.

Summary: Failure to comply with the stay or TRO notice requirements will result in striking the proposed stay or TRO.

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

Applies to

Joint evidence log

Counsel shall provide a Joint Evidence Log to the court at JudgeRizzoRemote@nycourts.gov at 9:30 AM the day prior to trial. The evidence log shall identify each exhibit as either marked in evidence, or marked for identification purposes; the purpose of each exhibit (for example plaintiff’s claim, defendant’s claim, defendant’s counter claim) and identify what each exhibit is or intends to demonstrate. The Joint Evidence Log itself will not be considered evidence.

Summary: For non-jury trials, counsel must provide a Joint Evidence Log by email at 9:30 AM the day before trial, identifying each exhibit and its purpose; the log itself is not evidence.

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

Applies to

Evidence

Counsel shall pre-mark evidence with the Part Clerk before a Court Reporter 9:30 AM the day prior to trial.

Summary: For non-jury trials, counsel must pre-mark evidence with the Part Clerk before the court reporter arrives at 9:30 AM the day before trial.

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

Applies to

Motion

All voluntary discontinuances not agreed upon by all parties to the action shall not be so-ordered without a motion.

Summary: A voluntary discontinuance not agreed to by every party may not be so ordered unless a motion is filed.

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

Applies to

Motion ?

Must include

ai disclosure ?

Counsel must upload a certification that Artificial Intelligence (AI) has not been used.

Summary: Counsel must upload a certification stating that AI was not used.

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

Applies to

Orders judgments counter orders and counter judgments ?

Must include

certificate of service ?

Orders, judgments, counter-orders and/or counter-judgments submitted for signature on notice will be returned unsigned unless an Affidavit of Service and Notice of Settlement for a date designated in accordance with 22 NYCRR 202.48 has been included.

Summary: An order, judgment, counter-order, or counter-judgment submitted for signature will be returned unsigned unless it includes the required affidavit of service and notice of settlement.

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

Applies to

Jury charge list ?

a complete list of requested jury charges, drawn from the Pattern Jury Instructions (PJI) of the then-current year, including departures if the trial involves claims of professional negligence, must be submitted by email

Summary: The jury-charge list must be complete, use the then-current Pattern Jury Instructions, and include departures for trials involving professional-negligence claims.

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

Applies to

Expert witness departure list ?

Where the testimony has been transcribed, page references will be required.

Summary: An expert-witness departure list must include page references when the expert testimony was transcribed.

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

Applies to

Temporary injunctive relief application ?

In the absence of a showing of significant prejudice, the affirmation must demonstrate that a good faith effort has been made to notify the party against whom the restraining order is sought.

Summary: If significant prejudice is not shown, the affirmation must state that a good-faith effort was made to notify the opposing party.

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

Applies to

Pretrial memorandum ?

Must include

legal argument ?

Pre-trial memoranda providing the Court with cited case law to be considered by the Court shall be submitted via email at least 48 hours in advance.

Summary: Pre-trial memoranda containing cited case law for the Court must be emailed at least 48 hours before the hearing or trial.

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

Applies to

Adjournment confirmation ?

Where a request is granted, counsel will be directed to either fax a confirming letter to Chambers or send an email to Chambers’ remote email address, copied to all counsel, setting forth the new approved EBT schedule with the firm new date(s), time(s) and location, and must indicate that “EBTs may not be adjourned to any later date without prior Court approval.” Requests to adjourn EBTs are not granted until the Court’s receipt of the confirming letter or email referenced herein.

Summary: After an EBT adjournment is granted, counsel must send Chambers a faxed or emailed confirmation copied to all counsel, state the firm new schedule, include the stated approval warning, and do so before the adjournment is deemed granted.

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

Applies to

Pretrial memorandum ?

Pre-trial memoranda providing the Court with cited case law to be considered by the Court;

Summary: Pre-trial memoranda providing cited case law for the Court's consideration must be supplied.

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

Applies to

Statement of stipulated facts

A statement of stipulated facts. [Parties are encouraged to stipulate to facts and/or exhibits]

Summary: A statement of stipulated facts must be provided, and the parties are encouraged to stipulate to facts or exhibits.

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

Applies to

Proposed verdict sheet

Any proposed verdict sheets;

Summary: Proposed verdict sheets must be provided.

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

Applies to

Infants compromise order ?

Must include

caption ?

A proposed Infant’s Compromise Order must include the full name of the infant- plaintiff and reference therein the following: “Confidential personal information is included in this Order upon the Court’s finding that good cause exists pursuant to 22 NYCRR § 202.5 [e][2], in that the inclusion of the full name and date of birth of the minor, as well as related information, is material and necessary to effectuate the terms of this Order”.

Summary: A proposed Infant’s Compromise Order must identify the infant-plaintiff by full name and include the specified statement concerning confidential personal information and good cause.

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

Applies to

Motion

Counsel must advise the Court, in writing, as soon as practicable, if any submitted or unsubmitted motion, or portion thereof, has been resolved, withdrawn, or rendered moot because the case is settled, or an issue is otherwise resolved.

Summary: Counsel must promptly notify the Court in writing when a motion or part of it has been resolved, withdrawn, or rendered moot.

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

Applies to

Emergency order to show cause

An “Emergency” Order to Show Cause requires a special affidavit based upon personal knowledge and an affirmation explaining in detail the nature of the emergency.

Summary: An emergency Order to Show Cause requires a special affidavit based on personal knowledge and an affirmation explaining the emergency in detail.

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

Applies to

Subpoenaed records ?

other) records subject to the HIPAA Rules shall attach a duly executed authorization permitting the release of such records.

Summary: Records subject to the HIPAA Rules must include a duly executed authorization permitting their release.

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

Applies to

Video

Must include

local rule certificate ?

NYSCEF Form EF-21 must also be filed in order for the Court to consider a video.

Summary: NYSCEF Form EF-21 must be filed for the Court to consider a video submission.

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

Applies to

Discovery motion

Must include

local rule certificate ?

After the Court conferences the matter and if the Court grants leave of court to file a discovery motion, any discovery motion must state that this procedure has been complied with. Failure to comply with this Part’s rules as set forth above may result in denial of the motion.

Summary: A permitted discovery motion must state that the required pre-filing procedure was followed, and noncompliance may result in denial.

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

Applies to

Jury charge requests ?

Counsel must submit a complete list of requested jury charges, drawn from the Pattern Jury Instructions (PJI) of the then-current year.

Summary: Counsel must submit a complete list of requested jury charges drawn from the current year's Pattern Jury Instructions.

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

Applies to

Motion

Must include

certificate of conference ?

The movant shall submit to the Court as part of their motion papers proof of compliance with the prior above mentioned notification requirement, which will include copies of both counsel’s letters.

Summary: The movant must include proof of compliance with the pre-motion notice requirement in the motion papers, together with copies of both counsel’s letters.

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

Applies to

Discovery motion ?

If the matter cannot be resolved, the motion papers must state that this Rule has been fully complied with.

Summary: If the discovery issue remains unresolved, the motion papers must state that the conference rule has been fully complied with.

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

Applies to

Notice of motion ?

Any Order to Show Cause seeking any injunctive relief, including a stay or TRO, must be made in accordance with 22 NYCRR 202.7(f). The moving party shall advise the Court as soon as practicable of counsel’s intent to make such application.

Summary: An order to show cause seeking injunctive relief, including a stay or TRO, must comply with 22 NYCRR 202.7(f), and counsel must advise the Court as soon as practicable of the intended application.

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

Applies to

Compromise application ?

The Court will not accept medical reports/affidavits executed more than six months prior to the submission date.

Summary: Medical reports or affidavits for compromise applications must be executed no more than six months before submission.

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

Applies to

Settlement letter or stipulation ?

Such notice shall set forth the date that the motion was submitted, what aspects of the motion have been settled, and what issues, if any, remain to be decided.

Summary: Settlement notice must identify the motion's submission date, the aspects settled, and any issues remaining for decision.

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

Applies to

Trial conference

At the trial conference, counsel shall supply the Court with all pleadings, all bills of particulars, witness lists, exhibit lists and any deposition transcripts that will be used at trial.

Summary: At the jury-trial conference, counsel must supply all trial pleadings, bills of particulars, witness and exhibit lists, and deposition transcripts intended for use at trial.

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

Applies to

Compromise application ?

Compliance with the provisions of CPLR Sections 1207, 1208, and 22 NYCRR 202.67 and a proposed distribution of net amounts to be recovered by the disabled plaintiff that is consistent with the provisions of the CPLR 1206 is required.

Summary: A compromise application must comply with specified statutes and include a proposed distribution consistent with CPLR 1206.

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

Civil cases

Applies to

Cross petition

Interested Parties seeking Guardianship post Initial Filing: If an interested party wishes to be considered as Guardian, they shall filed a cross-petition in accordance with Mental Hygiene Law § 81.

Summary: An interested party seeking guardianship after the initial filing must file a cross-petition under Mental Hygiene Law § 81.

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

Applies to

Summary judgment opposition ?

Opposing parties must submit a responsive statement consistent with former 22 NYCRR 202.8-g(b).

Summary: An opposing party must submit a responsive statement of material facts in opposition to a summary judgment motion.

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

Applies to

Preliminary conference order ?

(a) Name, Law Firm, Address, Firm Telephone Number, Direct Telephone Number, e-mail address, and full names of all parties.

Summary: The Preliminary Conference Order must include the names, firms, addresses, telephone numbers, email addresses, and full names of all parties.

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

Applies to

Opposition ?

Opposing papers shall contain a correspondingly numbered paragraph responding to each number paragraph in the moving party’s statement, and, if necessary, additional paragraphs containing a statement of the material facts upon which the opponent believes that there exists a genuine issue requiring trial also including citations to the evidence.

Summary: Opposing summary-judgment papers must respond in correspondingly numbered paragraphs and, if necessary, state additional material facts creating genuine issues with evidence citations.

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

Applies to

Note of issue

Upon Completion of a Certification Conference, the parties will be directed to file a Note of Issue and Certificate of Readiness.

Summary: After the Certification Conference, the parties must file a Note of Issue.

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

Applies to

Admission pro hac vice request ?

The applicant must set forth his or her willingness to abide by the Disciplinary Rules of the State of New York, and agree to disclose any change in his or her status as a member in good standing of the bar of another jurisdiction.

Summary: The applicant must state a willingness to follow New York disciplinary rules and agree to disclose any change in good-standing status in another jurisdiction.

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

Civil cases

Applies to

Statement of material facts

The court requires the filing of a separate Statement of Material Facts and a response to same.

Summary: Summary-judgment practice requires a separately filed Statement of Material Facts and a response to that statement.

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

Applies to

Pretrial submission ?

On or before the Pre-Trial Conference, Plaintiff’s counsel, Defendant’s counsel (or pro se (self-represented) parties) must file via NYSCEF and provide the Court with a working copy of the following:

Summary: Plaintiff’s counsel, defendant’s counsel, or pro se parties must file through NYSCEF and provide a working copy of the listed pretrial materials by the Pretrial Conference.

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

Applies to

Discovery motion

After the Court conferences the matter and if the Court grants leave of court to file a discovery motion, any discovery motion must state that this procedure has been complied with.

Summary: A discovery motion filed after leave is granted must state that the required pre-filing dispute-resolution procedure was followed.

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

Applies to

Marked pleadings

Marked pleadings in accordance with CPLR Section 4012, including copies of any exhibits incorporated by reference in the pleadings;

Summary: Marked pleadings under CPLR Section 4012, including incorporated exhibits, must be provided by the Pretrial Conference.

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

Applies to

Bill of particulars ?

A copy of all bill(s) of particulars;

Summary: A copy of all bills of particulars must be provided by the Pretrial Conference.

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

Applies to

Expert disclosures

A copy of all expert disclosures served pursuant to CPLR Section 3101(d) (if applicable);

Summary: If applicable, a copy of all CPLR Section 3101(d) expert disclosures must be provided by the Pretrial Conference.

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

Applies to

Trial witness list ?

A list of probable trial witnesses;

Summary: A list of probable trial witnesses must be provided by the Pretrial Conference.

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

Applies to

Prior decisions and orders ?

A copy of all prior Decisions or Orders on motions issued in the case (if applicable);

Summary: If applicable, copies of prior decisions or orders on motions must be provided by the Pretrial Conference.

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

Applies to

Stipulation of agreed facts

A Stipulation of agreed facts and/or admissible documents (if applicable);

Summary: If applicable, a stipulation of agreed facts and admissible documents must be provided by the Pretrial Conference.

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

Applies to

Statutory provisions

Any statutory provision(s) in effect at the time that the cause of action arose upon which either party intends to rely;

Summary: The statutory provisions on which a party intends to rely must be identified and provided by the Pretrial Conference.

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

Applies to

Legal issue memoranda ?

Memoranda of Law concerning any procedural, evidentiary, or other legal issue which the parties anticipate the Court will need to determine;

Summary: Memoranda addressing anticipated procedural, evidentiary, or other legal issues must be provided by the Pretrial Conference.

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

Applies to

Apportionment request ?

Any anticipated request for apportionment as to alleged culpable non-parties pursuant to CPLR Article 16.

Summary: Any anticipated CPLR Article 16 apportionment request regarding alleged culpable non-parties must be provided by the Pretrial Conference.

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

Applies to

Requests to charge

Requests to Charge (if applicable); and

Summary: If applicable, requests to charge must be provided by the Pretrial Conference.

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

Applies to

Proposed verdict sheet

Proposed Verdict Sheet (if applicable).

Summary: If applicable, a proposed verdict sheet must be provided by the Pretrial Conference.

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

Applies to

Order judgment counter order or counter judgment ?

Orders, judgments, counter-orders and/or counter-judgments submitted for signature on notice will be returned unsigned unless an Affidavit of Service and Notice of Settlement for a date designated in accordance with 22 NYCRR 202.48 has been included.

Summary: An order, judgment, counter-order, or counter-judgment submitted for signature on notice will be returned unsigned unless it includes the required affidavit of service and notice of settlement with the designated date.

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

Applies to

Requested jury charges

A complete list of requested jury charges, drawn from the Pattern Jury Instructions (PJI) of the then-current year must be submitted by email in Microsoft Word format to the remote email (JudgeCairoRemote@nycourts.gov), as directed by the Court and not later than the Pre-Trial Conference.

Summary: A complete list of requested jury charges must be submitted by email in Microsoft Word format to JudgeCairoRemote@nycourts.gov no later than the Pretrial Conference.

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

Applies to

Proposed verdict sheet

A Proposed Verdict Sheet, jointly prepared by all counsel/pro se (self-represented) litigant(s) must be submitted by email in Microsoft World format to the Court’s remote email (JudgeCairoRemote@nycourts.gov).

Summary: All counsel or pro se litigants must jointly prepare and submit a proposed verdict sheet by email to the Court’s remote email address.

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

Applies to

Proposed verdict sheet

If counsel/pro se (self-represented) litigant(s) cannot agree to the questions to be posed to the jury prior to the Pre-Trial Conference, each side shall submit a Proposed Verdict Sheet by email in Microsoft World format to the Court’s remote email (JudgeCairoRemote@nycourts.gov).

Summary: If the parties cannot agree on jury questions before the Pretrial Conference, each side must submit its own proposed verdict sheet by email.

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

Applies to

Request for adjournment

Applications must be made by completing the Request for Adjournment Form attached hereto. The Request for Adjournment Form is to be filled out completely.

Summary: A conference adjournment application must be submitted using a completely filled-out Request for Adjournment Form.

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

Applies to

Pretrial submission ?

Must include

caption ?

On or before the Pre-Trial Conference, Plaintiff’s counsel, Defendant’s counsel (or pro se (self-represented) parties) must file via NYSCEF and provide the Court with a working copy of the following: 1. Marked pleadings in accordance with CPLR Section 4012, including copies of any exhibits incorporated by reference in the pleadings; 2. A copy of all bill(s) of particulars; 3. A copy of all expert disclosures served pursuant to CPLR Section 3101(d) (if applicable); 4. A list of probable trial witnesses; 5. A copy of all prior Decisions or Orders on motions issued in the case (if applicable);

Summary: By the Pre-Trial Conference, counsel and pro se parties must file through NYSCEF and provide the court working copies of marked pleadings, bills of particulars, applicable expert disclosures, a probable-witness list, and applicable prior decisions or orders on motions.

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

Applies to

Motion ?

Counsel must upload a certification that Artificial Intelligence (AI) has not been used.

Summary: Counsel must upload a certification stating that AI was not used.

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

Applies to

Exhibits

A PDF for the corresponding exhibit shall be uploaded to NYSCEF and it shall include a notation that said exhibit will be provided on a USB.

Summary: A corresponding PDF of each video or photograph exhibit must be uploaded to NYSCEF with a notation that the exhibit will be provided on a USB drive.

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

Applies to

Order or judgment ?

Must include

certificate of service ?

Orders, judgments, counter-orders and/or counter-judgments submitted for signature on notice will be returned unsigned unless an Affidavit of Service and Notice of Settlement for a date designated in accordance with 22 NYCRR 202.48 has been included.

Summary: Orders, judgments, counter-orders, and counter-judgments will be returned unsigned unless the submission includes both an Affidavit of Service and a compliant Notice of Settlement.

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

Applies to

Proposed verdict sheet

If counsel/pro se (self-represented) litigant(s) cannot agree to the questions to be posed to the jury prior to the Pre-Trial Conference, each side shall submit a Proposed Verdict Sheet by email in Microsoft Word format to the Court’s remote email (JudgeKennyRemote@nycourts.gov).

Summary: If the parties cannot agree on the jury questions before the pretrial conference, each side must submit its own Proposed Verdict Sheet by email in Microsoft Word format.

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

Applies to

Discovery motion

Must include

local rule certificate ?

Any discovery motion must state that Rule III A. above has been complied with. Failure to comply with Rule III above may result in denial of the motion.

Summary: Every discovery motion must state compliance with Rule III.A, and noncompliance may result in denial.

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

Applies to

Motion ?

Must include

word count

Counsel shall include a certification of the relevant word count with their submission.

Summary: Counsel must include a certification of the applicable word count with the submission.

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

Applies to

Discovery motion ?

If the moving party was unable to conduct a conference due to the unreasonable failure or refusal of an adverse party to participate, then such moving party, in an affidavit or affirmation, detail the efforts made by the moving party to obtain such a conference and set forth the responses received.

Summary: When an adverse party unreasonably refuses to participate, the moving party must detail its conference efforts and the responses received in an affidavit or affirmation.

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

Applies to

Reply brief ?

Absent advance written permission by the court, reply papers shall not be submitted on orders to show cause.

Summary: Reply papers on an order to show cause may not be submitted without the court's advance written permission.

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

Applies to

Witness list ?

Counsel and pro se (self-represented) litigant(s) shall advise the Court of the witnesses to be called, and if any are experts, shall further provide the information required by CPLR 3101 (d)(1)(I).

Summary: Counsel and pro se litigants must identify the witnesses to be called and provide the information required by CPLR 3101(d)(1)(I) for expert witnesses.

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

Applies to

Expert witness supporting materials list ?

Where the exhibit is a many page document such as a hospital record, office record or voluminous (more than ten) page business record, counsel and pro se (self- represented) litigant(s) shall identify by way of tabs, Post-Its®, page numbering or similar device, the particular page or pages to which reference will be made.

Summary: For a many-page or voluminous exhibit, counsel and pro se litigants must identify the referenced pages using tabs, Post-Its, page numbering, or a similar device.

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

Applies to

Party contentions ?

All counsel and pro se (self-represented) litigant(s) shall alert the Court to any anticipated requests for apportionment as to alleged culpable non- parties pursuant to CPLR Article 16.

Summary: All counsel and pro se litigants must alert the Court to anticipated CPLR Article 16 apportionment requests against alleged culpable non-parties.

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

Applies to

Infant compromise paperwork ?

If the infant is fourteen years or older, an affidavit of consent from the infant must be

Summary: If the infant is at least 14 years old, an affidavit of the infant's consent is required.

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

Applies to

Motion ?

an affirmation demonstrating either that: (a) notice has been given; or (b) notice could not be given despite a good faith effort to do so; or (c) there will be significant prejudice to the movant by the giving of notice.

Summary: An affirmation must establish notice, a good-faith inability to provide notice, or significant prejudice from giving notice, subject to the stated exceptions.

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

Applies to

Summary judgment motion ?

Other than a motion for summary judgment pursuant to CPLR 3213, Commercial Division Rule 19-a includes a prescription requiring statements on motions for summary judgment. It prescribes that the movant shall annex to the motion a short and concise statement, in numbered paragraphs, of the material facts as to which the moving party contends there is no genuine issue of fact.

Summary: For summary-judgment motions other than those under CPLR 3213, the movant must annex a short, concise, numbered-paragraph statement of undisputed material facts.

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

Applies to

Memorandum of law ?

7. Memoranda of law concerning any procedural, evidentiary, or other legal issue which the parties participate the Court will need to determine; and

Summary: Parties must provide memoranda of law concerning procedural, evidentiary, or other legal issues they expect the court to determine.

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

Applies to

Brief ?

Each affidavit, affirmation or memorandum of law more than 4,500 words shall include a bookmark providing a listing of the document contents.

Summary: An affidavit, affirmation, or memorandum of law exceeding 4,500 words must include a bookmark listing the document contents.

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

Applies to

Stipulation

Should there be a significant reason that same is requested, the stipulation may be sent to chambers by email with a cover letter requesting said relief and the reason for requesting it, with copies to all counsel/ pro se parties.

Summary: A request that a stipulation be so ordered must include a cover letter stating the requested relief and reason and copies for all counsel and pro se parties.

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

Applies to

Oral argument request ?

however, a party may request oral arguments by letter accompanying the motion papers in accordance with 22 NYCRR 202.8-F. Should the Court determine that oral arguments are warranted, the parties will be notified and advised of the date.

Summary: A party must request oral argument by a letter accompanying the motion papers, and the Court will provide notice and a date if it grants the request.

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

Applies to

Notice of appearance form

All Counsel and Parties appearing must fill out a Notice of Appearance Form with the Clerk of the Part.

Summary: Every counsel or party appearing at a conference must submit a Notice of Appearance Form to the part clerk.

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

Applies to

Exhibit list

Prior to the first day of trial, each side shall have marked its exhibits into evidence those Exhibits: to which no objection has been made. A single combined Exhibit List should be presented to the Court in advance of the Trial. The exhibit list must state each pre- marked exhibit number, or letter, and provide a brief description of the Exhibit (Ex. "Exhibit 1 - Summons with Notice", etc.). The Exhibit List must also indicate which exhibits can be admitted into evidence on consent. All other exhibits must be marked for identification.

Summary: Before trial, each side should present one combined exhibit list identifying and describing its exhibits, identifying exhibits admissible by consent, and marking all other exhibits for identification.

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

Applies to

Expert departure list ?

In cases involving claims of professional negligence, on the next trial session after a Departures: party rests, or at such other time as the Court may direct, each plaintiff shall furnish the Court and all parties and/or counsel with a final list of the alleged departures from the standards of good and accepted practice which that party asserts or testifies to by its expert witness or witnesses. Page references to the trial transcript are required.

Summary: A plaintiff asserting professional negligence must furnish the court and other parties with a final expert-witness list of alleged departures, including transcript page references, at the specified time.

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

Applies to

Summary judgment motion ?

The responsive statement submitted by the non-moving party should include the text of the moving party’s statement to which each paragraph-specific response is addressed.

Summary: A non-movant’s responsive statement should reproduce the movant’s statement text for each paragraph-specific response.

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

Applies to

Deposition testimony list ?

This ===== PAGE 12 ===== Rule does not apply to portions of deposition testimony and corresponding video recording to be used solely for impeachment or credibility purposes.

Summary: The deposition-testimony submission rule does not apply to testimony or video used solely for impeachment or credibility.