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

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

Before filing a discovery motion, counsel or a party must email the part, identify the issue, and request a conference call for the Court's assistance.

3. Discovery Motions: Prior to filing any discovery motion, counsel/parties must contact the part via email, setting forth the issue, and request a conference call for the Court’s assistance in resolving the issue.

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

A request for permission to file a discovery motion may be submitted by a letter uploaded to NYSCEF and emailed to the judge, copied to all counsel and self-represented parties, or made in person at a scheduled conference; the letter must describe good-faith efforts and requested documents, address whether a Jackson Affidavit was requested and, if applicable, not provided, and may not exceed three pages.

Permission to make a discovery motion may be made 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 succinctly set forth the good faith efforts made to resolve the issue, identify the document(s) sought with particularity and specific identification, that a “Jackson Affidavit” was requested, and if applicable, not provided. The letter shall not exceed three pages. Permission to make a discovery motion may also be requested in person at a scheduled conference before the Court.

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

A discovery motion may not be submitted without the required conference.

There shall be no submitted discovery motions in the absence of a Conference (see Rule III(E) above).

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

Sur-reply papers addressing a motion's merits are prohibited without advance permission, except for a letter identifying a relevant post-submission court decision without additional argument.

Absent express permission in advance, sur-reply papers including correspondence, addressing the merits of a motion are not permitted, except that counsel may inform the court by letter of the citation of any post-submission court decision that is relevant to the pending issues, but there shall be no additional argument.

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

A cross-motion set beyond the original motion's return date does not adjourn the original motion.

Submission of a cross-motion with a stated return date that is beyond the return date of the original motion will not serve to adjourn the original motion.

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

Before involving the court or filing a discovery motion, parties must meet and confer through a genuine exchange rather than a one-sided letter or threat.

Regarding discovery disputes, parties are required to meet and confer before involving the court or making a motion (Rule 202.20-f). It is the policy of this Part to not accept letters as good faith efforts, unless a series of letters indicates an interaction among counsel, and not just a one-sided statement or threat.

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

Before filing a discovery motion, the moving party must make a genuine good-faith effort to resolve the dispute and, if unsuccessful, arrange a discovery conference among counsel for all parties and the court; one-sided letters alone will not suffice.

Prior to making or filing any discovery motions, counsel for the moving party MUST make a good faith effort to resolve the issues at hand, pursuant to 22 NYCRR 202.7(c) and Section 202.20-f. It is the policy of this Part to not accept letters as good faith efforts, unless a series of letters indicates an interaction among counsel and not just a one-sided request or threat. If after a true good faith effort to resolve the discovery issues has been made without success, counsel for the moving party MUST arrange for a conference to be held among counsel for all parties and the Court to discuss the issues involved and the possible resolution of those issues. Requests for discovery related conferences must be submitted on the Pre-Motion Discovery Conference Request Form attached at the end of this document, and must be sent to chambers by email or fax.

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

Before filing a discovery-related motion, a party must email the judge a completed conference request form summarizing the issues and attaching a good-faith affirmation detailing prior discovery efforts; conclusory or pro forma submissions do not suffice, and a motion without the conference request will not be scheduled.

Prior to filing a discovery related motion, including motions to strike, restore, preclude, and compel, the parties must send an email to judgegugertyremote@nycourts.gov, attaching a completed conference request form that includes a summary of the discovery related issues, and an affirmation of good faith in compliance with the New Uniform Rules for the Supreme and the County Court (22 NYCRR) § 202.20-f, setting forth, in detail, the efforts made by the attorney/party requesting the conference to obtain discovery pri or to requesting judicial intervention. Conclusory statements, or pro forma letters or emails will not satisfy this requirement. Failure to request a conference prior to the filing of a discovery related motion will result in the motion not being scheduled.

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

Before making or filing a discovery motion, counsel must first discuss the issue with opposing counsel and, if unresolved, must arrange a telephone conference with all counsel and the court, with knowledgeable counsel having settlement authority participating.

Prior to the making or filing of any discovery-related motion, counsel for the prospective movant(s) shall first discuss the issue(s) in question with his or her adversary. If the issue(s) in question cannot be resolved, counsel for the prospective moving party MUST arrange for a telephone conference to be held with all counsel and the Court to address the issue(s) and any possible resolution thereof. Counsel fully familiar with the matter and with authority to bind their client MUST be available ===== PAGE 4 ===== to participate in the conference call.

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

Before filing a discovery motion, counsel must make a good-faith effort to resolve the dispute, contact the court by letter describing the dispute and resolution efforts, obtain leave to file, and state that the procedure was followed; noncompliance may result in denial.

If counsel cannot resolve the discovery issue between themselves after a good faith effort, then the counsel who believes that discovery is not being conducted in accordance with the Court’s Order is to contact the Court by letter (See Rule I[A]), supra.), to advise of the nature of the dispute and the efforts that have been made to attempt to resolve it. The court will either resolve the issue by letter or by scheduling a conference. 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 the denial of the motion.

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

The parties must first attempt to resolve a discovery issue before filing a motion concerning it.

The parties are NOT to make any motion concerning discovery without having first attempted to resolve the issue.

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

No discovery motion may be filed without prior leave of court.

NO DISCOVERY MOTIONS MAY BE FILED WITHOUT LEAVE OF COURT

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

If a good-faith effort fails, counsel must notify the court by letter of the dispute and resolution efforts, after which the court will respond by letter or schedule a conference.

If counsel cannot resolve the discovery issue between themselves after a good faith effort, then the counsel who believes that discovery is not being conducted in accordance with the Court’s Order is to contact the Court by letter (see Rule I[B], supra), to advise of the nature of the dispute and the efforts that have been made to attempt to resolve it. The Court will either resolve the issue by letter or by scheduling a conference.

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

A discovery motion requires a prior pre-motion conference request and good-faith efforts to resolve the dispute, unless the Court directs otherwise.

1. Parties wishing to file a motion concerning discovery must first request a pre- motion conference with the Court. No discovery motion may be filed in the absence of good-faith efforts to resolve the dispute and a pre-motion conference (unless the Court directs otherwise).

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

Before raising a discovery dispute with the Court, a party must substantively meet and confer in good faith about the alleged deficiencies or noncompliance; a pro forma letter is insufficient.

2. A party wishing to raise a discovery dispute with the Court must first meet and confer in good faith with the other side(s) about the issue(s) prior to raising it with the Court, in accordance with 22 NYCRR § 202.7. A pro forma letter does not meet the Rule’s requirements. There must be substantive communications between counsel and self-represented litigants regarding the alleged discovery deficiencies or noncompliance, on one hand, and the claimed compliance or reason(s) for noncompliance, on the other.

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

If parties cannot resolve a dispute, the requesting party must e-file a letter of no more than three pages describing the contemplated motion, its grounds, and resolution efforts, and the opposing party may respond within three business days with a letter of no more than three pages; the Court will decide whether to hold a conference.

If the parties are unable to resolve the dispute, then the party wishing to make the motion is to e-file a letter, not to exceed 3 pages, succinctly describing the contemplated motion and the grounds for the same, and the efforts that have been made to resolve the issue. Any opposing party should then file a letter, not to exceed 3 pages, setting forth its position, within 3 business days after the request is filed. The Court will determine whether to hold a pre-motion conference.

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

Before filing a motion, the moving party generally must serve written notice stating the intended motion and requested relief and offering a good-faith attempt to resolve the matter, subject to emergency and significant-prejudice exceptions.

Except in an emergency situation or where an affirmation is presented demonstrating there will be significant prejudice to the moving party by giving prior notice, prior to making any motion, the moving party is required to serve a written notice to the opposing party of the intention to make the motion and the relief that will be sought in the motion, and offer to make a good faith attempt to resolve the matter.

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

Before filing any discovery motion in this part, the requesting party must submit the pre-motion discovery conference form and confer with the court about the matter.

NO DISCOVERY MOTIONS MAY BE FILED IN THIS PART WITHOUT FIRST SUBMITTING THIS FORM AND CONFERENCING THE MATTER WITH THE COURT.

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

Parties must follow the preliminary conference order's schedule, and any change requires prior court permission.

The court expects parties to strictly adhere to the schedule contained within the preliminary conference order. That schedule cannot be changed without prior permission of the court.

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

The compliance conference must be held no later than 60 days before the scheduled completion of discovery.

The compliance conference date will be set down in the preliminary conference order and must be held no later than 60 days before the date scheduled for the completion of discovery (22 NYCRR §202.19[b][3]).

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

The compliance conference may not be held later than the compliance requirement date stated in the DCM.

In no event shall the compliance conference be held later than the compliance requirement date as set forth in the DCM

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

Parties must meet and confer regarding discovery disputes before involving the court or filing a discovery motion.

Regarding discovery disputes, parties are required to meet and confer before involving the court or making a motion (Rule 202.20-f).

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

A reply to an Order to Show Cause is prohibited unless the court gives prior approval.

replies are not allowed on the Order to Show Cause without prior approval of the Court.

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

Civil cases

Absent an emergency, counsel must email Chambers a completed conference request form before making or filing a discovery-related motion, and the request tolls related filing deadlines pending the court's conference determination.

D. Absent emergency, prior to making or filing any discovery-related motions, including a motion to vacate the note of issue, counsel for the moving party shall request a pre-motion conference by emailing to chambers a completed conference request form. The court will then determine whether a pre-motion conference will be held to discuss the issues involved and possible resolution. A request for a pre- motion conference tolls all related filing deadlines.

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

A party may not file a discovery motion without first attempting to resolve the discovery dispute.

The parties are not to make any motion concerning discovery without having first attempted to resolve the issue.

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

After a good-faith effort fails, the attorney must contact the court by letter describing the discovery dispute and the attempted resolution efforts.

If counsel cannot resolve the discovery issue between themselves after a good faith effort, then the counsel who believes that discovery is not being conducted in accordance with the Court’s Order is to contact the Court by letter (see Rule I[A], supra), to advise of the nature of the dispute and the efforts that have been made to attempt to resolve it.

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

Unless extremely unusual circumstances causing detailed significant prejudice apply, the party presenting an Order to Show Cause requesting a Temporary Restraining Order or other emergency relief must notify opposing counsel or parties at least 24 hours before presentation and advise them of their right to be heard; in a true emergency, the Court may dispense with notice.

Unless there are extremely unusual circumstances in which significant prejudice (set forth in detail in a supporting affidavit/affirmation) will result, opposing counsel or parties are to be advised at least 24 hours in advance of the date and time that any Order to Show Cause which includes a request for a Temporary Restraining Order or other emergency relief is being presented to the Court in accordance with 22 NYCRR 202.7(f) and is to be advised that he/she has the right to be heard on the application. In a true emergency, the Court, in its discretion may dispense with the 24-hour notice requirement.

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

Discovery motions, including motions to vacate a Note of Issue, require a good-faith attempt to resolve the dispute, possible notice to the court by letter, and leave of court before filing; the motion must state that the procedure was followed.

The parties are not to make any motion concerning discovery, including motions to vacate the Note of Issue, without having first attempted to resolve the issue. If counsel cannot resolve the discovery issue between themselves after a good faith effort, then the counsel who believes that discovery is not being conducted in accordance with the Court’s Order is to contact the Court by letter (see Rule I[A], supra), to advise of the nature of the dispute and the efforts that have been made to attempt to resolve it. The Court will either resolve the issue by letter or by scheduling a conference. 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.

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

A discovery motion may not be submitted unless the required conference has occurred.

There shall be no submitted discovery motions in the absence of a Conference (see Rule III(E) above).

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

Every motion requires the Court's prior permission.

ALL MOTIONS REQUIRE PRIOR PERMISSION OF THE COURT.

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

Counsel must make every effort to resolve discovery disputes with the opposing party before engaging in discovery motion practice.

Counsel shall make every effort to resolve discovery disputes with their adversary before engaging in motion practice.

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

A proposed discovery movant must send chambers and all counsel and self-represented parties a remote-email request with the required good-faith affidavit or affirmation, after which the court will notify whether permission or a conference is required.

The proposed moving party shall forward to chambers' remote email address, and all counsel and self-represented parties, any request to make a discovery motion with an affidavit or affirmation of good faith that substantially complies with the form described above. The Court will thereafter notify the moving party, all counsel, and self-represented parties, whether permission is granted, or whether a conference with counsel, self-represented parties and chambers concerning the matter is necessary.

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

An order to show cause may be filed only when there is a genuine emergency, a stay is required, or a statute requires the proceeding.

Orders to Show Cause shall only be filed where there is a genuine emergency, a stay is required or a statute mandates so proceeding.

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

Motions and orders to show cause ordinarily are decided on the filed submissions without oral argument unless the court directs otherwise.

Unless otherwise directed, motions, including Orders to Show Cause, will be decided on SUBMISSIONS ONLY.

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

Sur-replies are prohibited unless the Court expressly grants leave.

No Sur-Replies will be accepted or considered without express leave of the Court.

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

An order to show cause may be brought only for genuine urgency, when a stay is required, or when a statute mandates it.

Motions may be brought by Orders to Show Cause (OSC) only when there is a genuine urgency, a stay is required, or a statute so mandates (22 NYCRR 202.8-d).

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

Absent extremely unusual circumstances causing significant prejudice, opponents must receive at least 24 hours' advance notice of an OSC seeking a TRO or other emergency relief and be told of the right to be heard.

Unless there are extremely unusual circumstances in which significant prejudice (set forth in detail in a supporting affidavit/affirmation) will result, opposing counsel or parties are to be advised at least 24 hours in advance of the date and time that any OSC which includes a request for a Temporary Restraining Order (TRO) or other emergency relief is being presented to the Court in accordance with 22 NYCRR 202.7(f) and is to be advised that he/she has the right to be heard on the application.

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

Counsel and self-represented litigants must confer in good faith before involving the Court or filing a discovery motion, and a one-sided letter alone will not establish a good-faith effort.

All counsel and pro se (self-represented) litigant(s) are required to meet and confer, in Disputes: good faith, before involving the Court or making any discovery motion, including a motion to vacate a note of issue (22 NYCRR 202.20-f). It is the policy of this Part to not accept letters as good faith efforts, unless a series of letters indicates an interaction among counsel, and not just a one-sided statement.

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

A certification conference is required before filing a note of issue.

Pursuant to the rules of the Administrative Judge, a certification conference will be held prior to the filing of a note of issue.

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

Sur-reply papers are prohibited without prior court authorization and will be disregarded if filed 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

If the parties cannot agree whether to continue or terminate a temporary restraining order, all counsel and any pro se litigant must appear on the motion's return date.

If the parties or counsel cannot agree to the continuation or termination of a temporary restraining order, all counsel and any pro se litigant must appear on the return date of the motion.

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

Counsel must obtain court leave before filing a motion to compel discovery or strike a pleading.

Counsels must seek leave of the Court prior to filing a motion to compel discovery or strike a pleading.

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

An applicant seeking temporary injunctive relief must comply with 22 NYCRR 202.7(f) and, if practicable, provide the opposing side at least 24 hours' advance notice by telephone, facsimile, and/or email before presenting the Order to Show Cause.

Applications for temporary injunctive relief must be made in conformity with 22 NYCRR 202.7(f). In addition, the Court requires that the party seeking temporary injunctive relief give the opposing side 24 hours notice in advance of presentment of the Order to Show Cause to the court. Notice should be given by telephone, facsimile and/or e-mail, if practicable.

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

Civil cases

After an unsuccessful good-faith effort to resolve discovery issues, the moving party's counsel must arrange a conference among all counsel and the court, with the request sent to chambers by email.

If a true good faith effort has been made without success, counsel for the moving party must arrange for a conference to be held among counsel for all parties and the Court to discuss the issues involved and the possible resolution. Requests for discovery-related conferences must be sent to chambers by email.

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

Even after the parties agree to resolve a discovery dispute, the Court may issue a sua sponte order with their consent or over their objections.

Regardless of an agreed resolution the Court may issue a sua sponte Order on its own motion on consent of the parties or over their objections.

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

Parties must use diligent good-faith efforts to resolve disclosure disputes before engaging in motion practice, and an unresolved dispute may support a request for a pre-submission conference.

C. Disclosure Motions: Parties are reminded that any dispute arising out of disclosure requires the parties to exercise diligent Good Faith efforts to resolve the issue prior to engaging in Motion practice. A failure to set forth such efforts may result in Summary Denial of the Motion. It is the policy of this Court to make itself available to resolve disputes related to Pre-Trial Disclosure. Therefore, if a dispute over Disclosure arises that cannot be resolved by the parties own diligent, Good Faith efforts, the aggrieved party may request that a Conference be scheduled prior to Submission.

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

Only the moving party may request oral argument, a non-movant needs a valid reason to be granted it, and the Court may request argument sua sponte.

Oral arguments may be requested only by the moving party. The non-movant may be granted oral argument provided they offer a valid reason and basis for orally arguing same. The Court may also request oral arguments on a motion.

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

All motions must be made returnable to the Hon. Thomas Rademaker in Part 11.

All motions are made returnable to the Hon. Thomas Rademaker, Part 11.

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

Except for writs and contempt matters, motions are taken on submission unless the court directs otherwise.

With the exception of Writs and Contempts, motions are taken on submission part only unless otherwise directed by the Court.

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

Counsel should endeavor, where feasible or possible, to coordinate a motion's return date with an already scheduled Part conference or the return date of a previously filed motion.

In the event a case is already scheduled for a conference with this Part, counsel should endeavor to coincide the return date of a motion, where feasible, with the previously scheduled conference. Where a motion is previously filed, any subsequent movants shall endeavor to coincide the return date(s) of any such subsequently filed motions, where possible.

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

If the discovery issue remains unresolved after the teleconference, the prospective movant may seek permission to file a discovery-related motion.

Where the matter cannot be resolved during the teleconference, the prospective movant may request permission to file a discovery-related motion.

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

Movants are encouraged to schedule a virtual conference before making or filing a discovery motion to attempt to resolve the dispute.

Prior to making or filing any discovery motions, the movant is encouraged to schedule a virtual conference to permit the parties and the Court to attempt to resolve the issue(s).

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

After reviewing the submitted motion, the Court decides case by case whether to hold oral argument and will notify counsel when to appear.

Oral Argument: After a review of the submitted motion, the court will determine, on a case-by-case basis, whether oral argument will be heard and will advise counsel when they shall appear.

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

Counsel and/or self-represented parties shall NOT FILE OR SERVE ANY DISCOVERY MOTION without obtaining prior written permission from this Court.

Summary: No discovery motion may be filed or served without prior written permission from the court.

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

Orders to Show Cause shall only be filed where there is a genuine urgency, a stay is required or a statute mandates so proceeding. Absent advance written permission by the court, reply papers shall not be submitted on orders to show cause.

Summary: An order to show cause may be filed only for genuine urgency, when a stay is required, or when a statute mandates the proceeding; absent advance written permission, reply papers may not be submitted.

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

The parties are not to make any motion concerning discovery, including motions to vacate the Note of Issue, without having first attempted to resolve the issue.

Summary: Parties must attempt to resolve a discovery dispute before filing any discovery motion, including a motion to vacate the Note of Issue.

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

Such motions may not be filed without approval from the Court.

Summary: Discovery motions may not be filed without prior court approval.

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

NO DISCOVERY MOTIONS MAY BE FILED IN THIS PART WITHOUT FIRST SUBMITTING THIS FORM AND CONFERENCING THE MATTER WITH THE COURT.

Summary: Before filing a discovery motion in this part, the requesting attorney or party must submit the completed conference request form and confer with the court regarding the discovery dispute.

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

There must be actual, substantive communication between counsel and/or pro se (self-represented) litigant(s), either telephonically or in writing (not to be copied to the Court), regarding the claimed failure to engage in discovery, on the one hand, and the claimed compliance or reason for noncompliance, on the other.

Summary: Before raising a discovery dispute, counsel and/or self-represented litigants must have actual, substantive telephonic or written communication about the dispute, without copying the Court unless requested.

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

The non-moving party is required to respond in writing to the moving party, setting forth consents and/or objections to the relief requested, within 48 business hours of receipt of the written notice from the moving party.

Summary: The non-moving party must respond in writing within 48 business hours after receiving the pre-motion notice and identify any consent to or objection to the requested relief.

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

Notwithstanding [1] above, all motions relating to discovery require a conference on the return date of the motion or order to show cause, unless otherwise specifically waived by the Court. The movant shall email the Court to schedule same.

Summary: Every discovery motion requires a conference on its return date unless the Court specifically waives the conference, and the movant must email the Court to schedule it.

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

No discovery motion shall be marked submitted prior to the holding of a conference with the Court in accordance with this rule, and prior to this Court’s determination that the matter cannot be resolved in conference.

Summary: A discovery motion may not be marked submitted until the required conference has occurred and the Court determines that the matter cannot be resolved.

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

Prior to making or filing any discovery motions, counsel for the moving party MUST make a good faith effort to resolve the issues at hand, pursuant to 22 NYCRR 202.7(c) and section 202.20-f.

Summary: Before making or filing a discovery motion, the moving party’s counsel must make a good-faith effort to resolve the dispute.

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

If after a true good faith effort to resolve the discovery issues has been made without success, counsel for the moving party MUST arrange for a conference to be held among counsel for all parties and the Court to discuss the issues involved and the possible resolution of those issues.

Summary: If a good-faith effort does not resolve discovery issues, moving counsel must arrange a conference among all parties’ counsel and the court before filing a discovery motion.

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

Requests for discovery related conferences must be submitted on the Pre-Motion Discovery Conference Request Form (you can find it here) and must be sent to chambers by email.

Summary: A request for a discovery-related conference must use the Pre-Motion Discovery Conference Request Form and be emailed to chambers.

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

Prior to making or filing any discovery motions, counsel for the moving party must make a good faith effort to resolve the present issues, pursuant to 22 NYCRR 202.7(c) and section 202.20-f. This Part will not accept letters as good faith efforts, unless a series of letters indicates an interaction among the parties and not one-sided requests. If after a true good faith effort to resolve the discovery issues there is no resolution, counsel for the moving party must arrange for a conference to be held among all parties and the Court to discuss the issues and possible resolution. Counsel must submit the attached pre- discovery conference form attached and email it to chamber and the Principal Law Clerk.

Summary: Before making or filing a discovery motion, moving counsel must undertake a genuine good-faith effort and, if the dispute remains unresolved, arrange and submit the required pre-discovery conference form for a conference involving all parties and the Court; one-sided letters alone do not suffice.

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

Preliminary conferences will be held according to the rules set forth in 22 NYCRR §202.19 and will be conducted in the Preliminary Conference Part of the Supreme Court Building.

Summary: Preliminary conferences must comply with 22 NYCRR §202.19 and be held in the Supreme Court Building's Preliminary Conference Part.

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

Attorneys appearing at the compliance conference must have telephone access to their respective clients and shall be prepared to enter into good faith settlement discussions.

Summary: Attorneys at a compliance conference must have telephone access to their clients and be prepared for good-faith settlement discussions.

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

There shall be no submitted discovery motions in the absence of a Conference (see Rule III(C) above).

Summary: A discovery motion may not be submitted unless the required conference has occurred.

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

All motions relating to discovery require a conference before the return date of the Motion or Order to Show Cause, unless otherwise specifically waived by the Court.

Summary: Discovery motions and discovery-related Orders to Show Cause generally require a conference before the return date unless the Court specifically waives it.

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

Civil cases

Prior to filing a discovery motion or requesting a conference with the Court, the movant shall confer with counsel for the opposing party “in a good faith effort to resolve all disputes about disclosure” (22 NYCRR § 202.20-f[b]). If, after such effort, the parties are unable to resolve their dispute, they shall e-mail the Court to schedule a conference. There shall be no submitted discovery motions in the absence of a conference and permission from this court.

Summary: Before filing a discovery motion, the movant must make a good-faith disclosure conference with opposing counsel, and the court must hold a conference and grant permission before the motion may be submitted.

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

Prior to the making or filing of any discovery-related motion, counsel for the prospective movant(s) shall first discuss the issue(s) in question with his or her adversary. If the issue(s) in question cannot be resolved, counsel for the prospective moving party MUST arrange for a telephone conference to be held with all counsel and the Court to address the issue(s) and any possible resolution thereof.

Summary: Before making or filing a discovery-related motion, counsel must first discuss the dispute with the adversary and, if unresolved, arrange a telephone conference with all counsel and the court.

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

Absent exigent circumstances, prior to contacting the court regarding a disclosure dispute, counsel must first consult with one another in a good faith effort to resolve all disputes about disclosure. Such consultation must take place by an in-person or telephonic conference.

Summary: Except in exigent circumstances, counsel must first consult in good faith through an in-person or telephonic conference before contacting the court about a disclosure dispute.

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

No discovery related motion may be filed until the issues are first conferred with Conferences: the Court. Prior to making or filing any discovery motions, the purported movant must schedule a conference so as to permit the parties and the Court to attempt to resolve the issue(s). Such request must include a summary of the discovery related issues, and an affirmation of good faith in compliance with 22 NYCRR 202.20-f.

Summary: Before filing a discovery motion, the movant must first confer with the Court, schedule a conference, provide a summary of the discovery issues, and include an affirmative certification of good-faith compliance.

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

The failure to appear will be deemed a waiver of the defaulting party’s position with respect to the continuation or termination of the TRO.

Summary: Failure to appear on the TRO return date is deemed a waiver of the defaulting party's position on continuation or termination.

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

Prior to making or filing any motions, counsel for the moving party MUST arrange for a conference call to be held with his/her adversary and the Court to discuss the issues involved and the possible resolution thereof.

Summary: Before making or filing any motion, moving counsel must arrange a conference call with the opposing party and the Court to discuss the issues and possible resolution.

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

Counsel fully familiar with the matter and with authority to bind their clients MUST be available to participate in the conference.

Summary: The moving attorney must attend the pre-motion conference with sufficient familiarity and settlement authority to bind the client.

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

Counsel are strongly encouraged to follow this practice for all non-discovery motions as well in order to reduce the need for motion practice.

Summary: Counsel are strongly encouraged, but not required, to use the same pre-filing email and conference-call practice for non-discovery motions.

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

A request for oral argument should not be construed as an automatic grant of same. The Court reserves the right to limit oral argument to fifteen (15) minutes to each side.

Summary: An oral-argument request is not automatically granted, and the Court may limit argument to 15 minutes per side.

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

It is the policy of this Part to not accept letters as good faith efforts, unless a series of letters indicates an interaction among counsel and not just a one-sided request or threat.

Summary: Letters alone do not constitute an adequate good-faith effort unless they show an actual exchange among counsel rather than a unilateral request or threat.

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

“Counsel for all parties shall consult prior to a preliminary or compliance conference about (i) resolution of the case, in whole or in part; (ii) discovery, including discovery of electronically stored information, and any other issues to be discussed at the conference, (iii) the use of alternate dispute resolution to resolve all or some issues in the litigation; and (iv) any voluntary and informal exchange of information that the parties agree would help aid early settlement of the case.

Summary: Before a preliminary or compliance conference, counsel must consult about case resolution, discovery, alternate dispute resolution, and any mutually agreed informal information exchange.

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

The other side may submit a specific response of equal length, within 5 days of the date of the original letter.

Summary: The opposing side may submit a specific response of equal length within five days after the original disclosure-dispute letter.

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

The Part will then schedule a conference, if necessary, with the goal of resolving or limiting the issues in dispute consistent with Rule 14.

Summary: After the disclosure-dispute letters are submitted, the Part will schedule a conference if necessary to resolve or limit the disputed issues.

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

The unreasonable failure or refusal of counsel to participate in a conference requested by another party may relieve the requesting party of the obligation to comply with this paragraph and may be addressed by the imposition of sanctions pursuant to Part 130.

Summary: An unreasonable failure or refusal to participate in a requested discovery conference may excuse compliance with the conference requirement and may lead to sanctions under Part 130.

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

If oral argument is requested, the Court will consider the request, after reviewing the papers, and will then inform the parties of the date of the oral argument if the request is granted.

Summary: The court reviews the papers before deciding whether to grant requested oral argument and then advises the parties of the argument date if granted.

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

This rule does not apply to applications for counsel to be relieved, motions to dismiss, and motions for summary judgment.

Summary: The pre-motion conference requirement does not apply to counsel-relief applications, motions to dismiss, or motions for summary judgment.

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

This rule does not apply to applications for counsel to be relieved, motions to vacate the Note of Issue, or dispositive motions.

Summary: The discovery pre-motion teleconference rule does not apply to counsel-relief applications, motions to vacate the Note of Issue, or dispositive motions.

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

Conferences will be held in-person and virtually.

Summary: Compliance conferences may be held in person or virtually.

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

This rule does not apply to applications for counsel to be relieved, motions to vacate the Note of Issue, or dispositive motions.

Summary: The discovery-motion pre-teleconference rule does not apply to applications to relieve counsel, motions to vacate the Note of Issue, or dispositive motions.

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

In the event a case is already scheduled for a conference with this Part, counsel should endeavor to coincide the return date of a motion, where feasible, with the previously scheduled conference. Where a motion is previously filed, any subsequent movants shall endeavor to coincide the return date(s) of any such subsequently filed motions, where possible.

Summary: Counsel and subsequent movants should, where possible, coordinate motion return dates with an existing Part conference or other related motion return dates.

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

If the matter can be resolved during the conference, an order consistent with such resolution may be issued.

Summary: If the matter is resolved during the pre-motion conference, the court may issue an order consistent with the resolution.