Judge Jennifer G. Schecter
Individual Rules, Standing Orders & Policies
- Rules last changed:
Limits & Logistics
Document Limits
Courtesy Copies
Motion
- 1 copy
Courtesy copies
Court-wideProposed Order
Court-wideAdjournments
- Court permission for an adjournment of a scheduled appearance ordinarily must be obtained at least two business days in advance, but emergencies are excepted.
Communication
Phone
Clerk
Clerk
Phone
Chambers
Phone
Court-wideIntake Unit
Page & Word Limits3 rules
Checked and corrected to match the court's document on Oct 5, 2026Mandatory
Unless the court directs otherwise, a letter may not exceed three pages.
Unless otherwise directed, letters shall have a 3-page limit.
Letter
Not confirmed. Read the court's wording below.Mandatory?
Prior to the PC, the parties must e-file and email the assigned law clerk a joint letter, not to exceed two pages, that includes a summary of the relevant factual background, the causes of action, affirmative defenses and counterclaims, the status of discovery, and the status of any motions.
Summary: The joint letter submitted before the PC is limited to two pages.
Joint Letter
2 pages
Not confirmed. Read the court's wording below.Mandatory?
Briefs and memoranda of law must comply with the requirements set forth in Commercial Division Rule 17, including word limits (7,000 for opening and opposition briefs, 4,200 for reply briefs, and 7,000 for affidavits and affirmations) and certifications of compliance by counsel.
Summary: Opening and opposition briefs are limited to 7,000 words, reply briefs to 4,200 words, and affidavits and affirmations to 7,000 words; counsel must certify compliance.
Opening Brief
7,000 words
Opposition Brief
7,000 words
Reply Brief
4,200 words
Affidavit
7,000 words
Affirmation
7,000 words
Document Format Requirements11 rules
Checked and corrected to match the court's document on Oct 5, 2026Mandatory
Every document filed electronically must be submitted as an OCR text-searchable PDF.
All e-filed documents must be OCR Text Searchable PDFs.
Checked against the court's document on Oct 5, 2026Mandatory
An email submitted for a stipulation to be so-ordered must include an executed Microsoft Word version, and electronic signatures are permitted.
For stipulations to be so-ordered, the email must also include an EXECUTED Microsoft Word version (electronic signatures are permitted).
Checked against the court's document on Oct 5, 2026Mandatory
The email submitting a proposed order must include a Microsoft Word version.
For proposed orders, the email must include a Microsoft Word version.
Checked and corrected to match the court's document on Oct 5, 2026Mandatory
All document production must be electronic, searchable, and bates-stamped; hard-copy, non-searchable PDF, or unstamped production may be ordered redone.
Details related to the manner of document production will be discussed at the PC. However, all production must be electronic, searchable and bates-stamped. A party that produces hard copy documents, non-searchable PDFs or documents without bates stamps will be ordered to re-produce its materials.
Checked against the court's document on Oct 5, 2026Mandatory
All electronically filed briefs, exhibits, and other motion papers must be OCR text searchable.
As noted earlier, briefs, exhibits and all other motion papers that are e-filed must be OCR Text Searchable.
Checked against the court's document on Oct 5, 2026Mandatory
Motion sequence numbers must appear in bold on the front page of all papers related to a motion or cross-motion, except exhibits.
Motion sequence numbers shall appear in bold on the front page of ALL papers related to any motion or cross-motion, except exhibits.
Checked against the court's document on Oct 5, 2026Mandatory
Required hard-copy exhibit volumes must use exhibit tabs and include a cover page stating the motion sequence number.
If the court requires hard copies, each hard-copy volume of exhibits MUST be separated by exhibit tabs and include a cover page containing the motion sequence number.
Checked against the court's document on Oct 5, 2026Important
An e-filed exhibit PDF should begin with the first page of the exhibit rather than a blank exhibit-cover page.
The first page of the e-filed PDF should NOT be a blank page that states “Exhibit __.” For instance, if Exhibit A is a contract, the first page of the contract should be the first page of the e-filed PDF.
Checked against the court's document on Oct 5, 2026Note
A Word version need not be attached for documents not requiring the court's signature, and a PDF of a letter is sufficient.
For the avoidance of doubt, there is no need to attach a Word version of documents that do not need to be signed by the court (i.e., PDFs of letters are sufficient).
We could not find this wording in the court's document. Open the source before relying on it.Important?
Unopposed applications accompanied by an executed Word version of an e-filed stipulation consenting to the relief sought (such as consolidation, admission pro hac vice or an open commission) should be emailed to the assigned law clerk along with the e-filing confirmation receipt.
Machine summary and details
Summary: For an unopposed application, parties should email the assigned law clerk both an executed Word version of the e-filed stipulation and its filing confirmation receipt.
DOCX
Not confirmed. Read the court's wording below.Important?
The court will notify the parties if hard copies will be required.
Summary: The court will notify the parties when hard copies of pretrial submissions are required.
Document Filing Requirements22 rules
Checked against the court's document on Oct 5, 2026Mandatory
A pro hac vice request by motion or stipulation must include a proposed order conforming to the supplied order, a supporting affidavit from a New York Bar member, an applicant affidavit, and a recent certificate of good standing.
A request for pro hac vice admission, whether made by motion or stipulation, shall be accompanied by a proposed order and an affidavit in support from a member of the Bar of the State of New York, an affidavit of the applicant and a recent certificate of good standing from the applicant. The proposed order shall conform to the order that appears after these rules.
Document Type
Pro Hac Vice Request
Checked against the court's document on Oct 5, 2026Mandatory
Commercial Division Rule 24 letters are neither required nor permitted unless the court directs otherwise, and prior leave is not required before filing a dispositive motion.
The court DOES NOT require Commercial Division Rule 24 letters, no such letters are permitted unless otherwise directed by the court, and parties DO NOT need leave prior to filing a dispositive motion (such as pre-NOI partial summary judgment motions).
Requirement
Document requirement
Checked against the court's document on Oct 5, 2026Mandatory
The joint letter must summarize the factual background, causes of action, affirmative defenses and counterclaims, discovery status, and motion status.
Prior to the PC, the parties must e-file and email the assigned law clerk a joint letter, not to exceed two pages, that includes a summary of the relevant factual background, the causes of action, affirmative defenses and counterclaims, the status of discovery, and the status of any motions.
Document Type
Joint Letter
Checked against the court's document on Oct 5, 2026Mandatory
Every motion must include a memorandum of law with a table of contents and table of authorities, except relatively minor motions such as pro hac vice motions.
A memorandum of law with a table of contents and table of authorities must accompany every motion (except for relatively minor motions such as pro hac vice motions).
Document Type
Motion
Checked against the court's document on Oct 5, 2026Mandatory
Motion papers must include complete pleadings, applicable contracts, and any referenced deposition or court-proceeding transcript in its entirety.
The moving papers on a motion must contain complete and legible copies of (a) the pleadings, (b) all applicable contracts, and (c) entire transcripts of depositions and court proceedings if reference is made to the deposition or proceedings in the motion.
Document Type
Motion
Checked against the court's document on Oct 5, 2026Mandatory
The OSC email must include a Microsoft Word version of the order to show cause.
The email shall include a Microsoft Word version of the OSC.
Document Type
Order To Show Cause
Checked against the court's document on Oct 5, 2026Mandatory
A TRO will not be issued unless the moving papers contain complete copies of the pleadings and complete, legible applicable contracts.
The court will not issue a TRO if the moving papers do not contain complete copies of the pleadings and complete legible copies of the applicable contracts.
Document Type
TRO
Checked against the court's document on Oct 5, 2026Mandatory
Pretrial submissions must include witness lists identifying fact or expert witnesses and the expected length of direct examination.
(c) witness lists setting forth whether the witness is a fact witness or an expert and the expected length of direct examination
Document Type
Pretrial Submission
Checked against the court's document on Oct 5, 2026Mandatory
Pretrial submissions must include pre-marked, Bates-stamped exhibits and an exhibit spreadsheet containing identifiers, brief descriptions, and spaces for objections, post-conference positions, and court rulings.
(f) pre-marked exhibits containing their bates stamps, together with a spreadsheet containing the exhibit numbers or letters, a very brief description of the exhibit and blank spaces for a) the opposing parties to object or agree to admission, b) a change of position after the parties meet and confer regarding any objections and c) a court ruling at the pre-trial hearing on the exhibits not agreed upon
Document Type
Pretrial Submission
Checked against the court's document on Oct 5, 2026Mandatory
All pleadings, briefs, and other papers filed with the court must be signed by the attorney of record, who is responsible for the papers and the conduct of the action.
ORDERED that all pleadings, briefs, and other papers filed with the court shall be signed by the attorney of record, who shall be responsible for such papers and for the conduct of this action;
Document Type
Pleadings Briefs And Other Papers
Checked against the court's document on Oct 5, 2026Important
The parties must use the confidentiality agreement and order made available at the specified New York Commercial Division URL.
Parties shall use the confidentiality agreement and order available at: https://www.nycourts.gov/LegacyPDFS/courts/comdiv/NY/PDFs/Confidentiality_ Stip_Part_54.pdf
Document Type
Confidentiality Agreement
Checked against the court's document on Oct 5, 2026Important
Joint exhibits may be cited and filed with the joint statement and will be part of the summary-judgment record without separate filing in the motion papers.
The joint statement may cite and be filed with joint exhibits that will be considered part of the summary-judgment record without the need to separately file them with the parties’ motion papers.
Document Type
Joint Statement Of Material Facts
Not confirmed. Read the court's wording below.Mandatory?
Excerpts of contracts and transcripts may not be filed without prior leave of court.
Summary: Contract and transcript excerpts may be filed only after obtaining prior court permission.
Document Type
Motion
Not confirmed. Read the court's wording below.Mandatory?
A party who wishes to be heard on a more expeditious or ex parte basis shall e-file an affidavit justifying the request.
Summary: A request for a more expeditious or ex parte TRO hearing must be accompanied by an electronically filed affidavit justifying the request.
Document Type
Affidavit
Not confirmed. Read the court's wording below.Mandatory?
(a) marked pleadings
Summary: Pretrial submissions must include marked pleadings.
Document Type
Pretrial Submission
Not confirmed. Read the court's wording below.Mandatory?
If all parties consent to the proposed corrections or agree that no corrections are required, a stipulation to that effect shall be e-filed and emailed to the court with the errata sheet or transcript.
Summary: When all parties consent to proposed transcript corrections or agree that no corrections are required, a stipulation to that effect must be e-filed and emailed with the errata sheet or transcript.
Document Type
Transcript Stipulation
Not confirmed. Read the court's wording below.Mandatory?
(e) cross-designations of deposition testimony including the pages and lines
Summary: Pretrial submissions must include cross-designations of deposition testimony identifying the pages and lines.
Document Type
Pretrial Submission
Not confirmed. Read the court's wording below.Mandatory?
(d) expert reports
Summary: Pretrial submissions must include expert reports.
Document Type
Pretrial Submission
Not confirmed. Read the court's wording below.Mandatory?
(b) pretrial memoranda
Summary: Pretrial submissions must include pretrial memoranda.
Document Type
Pretrial Submission
Not confirmed. Read the court's wording below.Mandatory?
(g) requests to charge including the applicable Pattern Jury Instruction (PJI) number and contentions. If any modification of the PJI is requested, the entire charge shall be typed with the proposed modification clearly indicated in BOLD
Summary: Pretrial submissions must include requests to charge with the applicable PJI number and contentions, and any proposed PJI modification must be clearly indicated in bold.
Document Type
Requests To Charge
Not confirmed. Read the court's wording below.Mandatory?
(i) a stipulation as to all agreed-upon facts for non-jury trials
Summary: Pretrial submissions for non-jury trials must include a stipulation of all agreed-upon facts.
Document Type
Pretrial Submission
Not confirmed. Read the court's wording below.Mandatory?
(h) a proposed verdict sheet
Summary: Pretrial submissions must include a proposed verdict sheet.
Document Type
Pretrial Submission
Filing & Service rules
Electronic Filing Rules
Before the pre-case conference, the parties must electronically file and email the assigned law clerk a joint letter of no more than two pages containing specified case, discovery, and motion information.
Prior to the PC, the parties must e-file and email the assigned law clerk a joint letter, not to exceed two pages, that includes a summary of the relevant factual background, the causes of action, affirmative defenses and counterclaims, the status of discovery, and the status of any motions.
Checked against the court's document on Oct 5, 2026
Page 6 | Conferences
Each exhibit to an electronically filed pleading, affidavit, or affirmation must be filed as a separate document and described in reasonable detail in the Description field, in addition to a number.
Each exhibit to an e-filed pleading, affidavit or affirmation must be e-filed as a separate document and must be described in reasonable detail in the “Description” field, in addition to a number
Checked against the court's document on Oct 5, 2026
Page 8 | MOTIONS
All pretrial submissions, including all in limine motions, must be e-filed and fully submitted at least three weeks before the pretrial conference.
All pre-trial submissions, including all in limine motions, must be e-filed and fully submitted at least three weeks before the pre-trial conference.
Checked against the court's document on Oct 5, 2026
Page 11 | TRIALS & PRE-TRIAL CONFERENCES
A party may, without prior court permission, electronically file and email a short letter seeking reassignment or challenging Commercial Division placement.
If a party believes that a case assigned to Part 54 does not belong in the Commercial Division or should be assigned to another Justice (e.g., as a related case), it may, without prior leave of court, e-file and email a short letter explaining its position.
Checked against the court's document on Oct 5, 2026
Page 1 | GENERAL RULES
A responsive assignment letter must be electronically filed and emailed to the court within two days.
Any responsive letter shall be e-filed and emailed to the court within two days.
Not confirmed. Read the court's wording below.
Page 1 | GENERAL RULES
After e-filing a document requiring the court's attention, the filer must email its PDF and the e-filing confirmation to the assigned law clerk.
PDFs of documents requiring the court’s attention must be emailed to the assigned law clerk after they are e-filed along with the e-filing confirmation.
Not confirmed. Read the court's wording below.
Page 2 | ELECTRONIC FILING
All cases must be filed electronically through NYSCEF, except cases involving pro se litigants who are not licensed to practice law in New York.
All cases must be e-filed on NYSCEF except for cases involving pro se litigants who are not licensed to practice law in New York.
Not confirmed. Read the court's wording below.
Page 2 | ELECTRONIC FILING
Hard copies may not be submitted unless the court specifically directs that they be submitted.
Hard copies SHALL NOT be submitted unless specifically directed by the court.
Not confirmed. Read the court's wording below.
Page 2 | ELECTRONIC FILING
If the parties change the form confidentiality agreement and order, they must electronically file the executed version and email the court a redline.
If the parties make any changes to this form order they shall e-file and email the court an executed version and a redline.
Not confirmed. Read the court's wording below.
Page 7 | Confidentiality Agreements
Unless the court orders otherwise, parties may not provide hard copies or appear in court on an OSC return date.
Unless otherwise ordered, the parties SHALL NOT provide hard copies or appear in court on the return date.
Not confirmed. Read the court's wording below.
Page 9 | Orders to Show Cause
A transcript requested to be So Ordered must be e-filed and emailed to the court with an errata sheet correcting all record errors, including agreed-upon transcription errors in the court’s statements.
Transcripts shall be e-filed and emailed to the court with an errata sheet correcting all errors in the record, including any agreed-upon errors in transcription of the court’s statements.
Not confirmed. Read the court's wording below.
Page 11 | TRANSCRIPTS
Unrepresented litigants who are not licensed New York attorneys are highly encouraged to use NYSCEF electronic filing.
Unrepresented litigants who are not licensed New York attorneys are highly encouraged to e-file (it is the best way to obtain easy access to court filings, keep up to date and serve other parties) and can find instructions at:
Not confirmed. Read the court's wording below.
Page 2 | ELECTRONIC FILING
Filing Timing and Cure Windows
A discovery update may be submitted any time by its due date, but the party must provide the update or request an extension by the deadline.
Such updates may be submitted at any time on or before the date they are due, but parties must always timely provide an update or request an extension by the deadline.
Checked and corrected to match the court's document on Oct 5, 2026
Page 7 | MOTIONS
Unless the court orders otherwise, a summary-judgment motion must be filed within 60 days after filing of the note of issue.
Unless otherwise ordered, summary judgment motions must be filed no later than 60 days after the note of issue is filed.
Checked and corrected to match the court's document on Oct 5, 2026
Page 9 | ELECTRONIC FILING
A motion on which the court reserves is not fully submitted, and no written decision will issue, until the transcript is e-filed.
If the court reserves on a motion, it will not be marked fully submitted and the court will not issue a written decision until the transcript is e-filed.
Checked against the court's document on Oct 5, 2026
Page 11 | TRANSCRIPTS
All oral argument transcripts must be e-filed within 45 days after oral argument, including transcripts when the court decides the motion from the bench.
All oral argument transcripts must be e-filed within 45 days of oral argument, even if the court decides a motion from the bench after oral argument.
Checked against the court's document on Oct 5, 2026
Page 11 | TRANSCRIPTS
A responsive assignment letter must be electronically filed and emailed to the court within two days.
Any responsive letter shall be e-filed and emailed to the court within two days.
Not confirmed. Read the court's wording below.
Page 1 | GENERAL RULES
Service and Proof of Service Rules
Absent significant prejudice, a TRO movant must email the motion papers to opposing counsel and Mr. Rand at least 24 hours before the requested hearing time.
In the absence of significant prejudice, a movant seeking a TRO must email their motion papers to opposing counsel and Mr. Rand at least 24 hours in advance of when the movant wants to be heard on its TRO application.
Checked against the court's document on Oct 5, 2026
Page 9 | Orders to Show Cause
Orders on motions and stipulations to consolidate, sever claims, or amend captions must be served with notice of entry on the County Clerk and General Clerk’s Office under Section J of the applicable electronic-filing protocol.
All orders on motions or stipulations to consolidate, to sever claims or to amend captions shall be served with notice of entry on the County Clerk and the General Clerk’s Office in accordance with Section J of the Protocol on Courthouse and County Clerk Procedures for Electronically Filed Cases
Checked and corrected to match the court's document on Oct 5, 2026
Page 11 | CONSOLIDATION OR AMENDMENT OF CAPTIONS
Failure to electronically file proof of TRO notice containing the opposing side’s email address may delay consideration of the application.
The failure to e-file proof of such notice that includes the other’s side’s email address may result in delayed consideration of the TRO.
Not confirmed. Read the court's wording below.
Page 9 | Orders to Show Cause
Filing Fees and Waivers
Unless otherwise directed, the moving party must order and pay for the oral argument transcript.
Unless otherwise directed, the moving party shall order and pay for the transcript.
Not confirmed. Read the court's wording below.
Page 11 | TRANSCRIPTS
Transcript costs must be shared when there is a cross-motion or when both parties file motions.
If there is a cross-motion or motions are filed by both parties, the costs shall be shared.
We could not find this wording in the court's document. Open the source before relying on it.
Page 11 | TRANSCRIPTS
Courtesy Copy Requirements
For non-electronically filed motion papers, two properly submitted copies are required: one for the court file and one for the court's use, with the delivery location depending on notice or order to show cause.
In those limited cases that ARE NOT e-FILED, TWO copies of motion papers must be properly submitted (in Room 130 if the motion is on notice and to the courtroom if the motion was made by order to show cause): one for the court file and an extra copy for the court’s use.
Checked against the court's document on Oct 5, 2026
Page 2 | ELECTRONIC FILING
Sealing & Redaction Procedures
A party seeking to file a redacted or sealed document must move by OSC; if provisional sealing was used, the OSC should request a TRO, and the moving papers must include narrowly tailored proposed redactions with a highlighted version emailed to the court and opposing counsel.
If provisional sealing status was employed the OSC should include a TRO maintaining such status pending a decision on the motion. Since sealing of entire documents is rarely permitted, the moving papers shall include narrowly tailored proposed redactions and the movant shall email the court and opposing counsel a version of the documents with highlighted proposed redactions.
Not confirmed. Read the court's wording below.
Page 7 | Confidentiality Agreements
Filing Bundling Requirements
Filing a dispositive motion does not stay discovery.
The filing of a dispositive motion DOES NOT stay discovery.
Not confirmed. Read the court's wording below.
Page 4 | COMMUNICATIONS WITH THE COURT — Authorized Letters
Pre-Motion Conference Requirements
A party must obtain prior court leave before filing a discovery motion under Part Rule 28.
Discovery motions, however, require prior leave of court pursuant to Part Rule 28.
Checked against the court's document on Oct 5, 2026
Page 4 | COMMUNICATIONS WITH THE COURT — Authorized Letters
A post-conference motion to stay discovery must be made by order to show cause, although the parties may request a law-clerk conference instead; a stay order must issue before the deadline to relieve consequences, and late or repeated requests are not expected to be granted absent compelling cause.
After the PC, motions to stay discovery must be made by order to show cause. However, parties may email the assigned law clerk to request a conference to address a stay request in lieu of a motion. Parties will not be relieved from the consequences of violating discovery orders unless the court issues a stay order prior to the deadline. Parties should not expect that stay or extension requests on the eve of a deadline will necessarily be granted, particularly if such request could have been made more expeditiously. Parties who have made multiple prior extension requests or have previously failed to comply with discovery deadlines should not expect their extension requests to be granted absent compelling cause.
Checked and corrected to match the court's document on Oct 5, 2026
Page 5 | DISCOVERY
A party may not argue for denial of summary judgment solely based on failure to negotiate and file a joint statement of facts.
No party shall argue that a summary-judgment motion should be denied for the failure to negotiate and file a joint statement of facts.
Checked and corrected to match the court's document on Oct 5, 2026
Page 10 | Summary-Judgment Motions
CPLR 3213 motions do not require a joint statement, and competing Rule 19-a statements may not be submitted for them.
CPLR 3213 motions do not require a joint statement and competing Rule 19-a statements are not to be submitted.
Checked and corrected to match the court's document on Oct 5, 2026
Page 10 | Summary-Judgment Motions
If the parties cannot agree on a joint statement, they may not submit competing Rule 19-a statements of facts.
If the parties cannot agree on a joint statement, competing Rule 19-a statements of facts are strictly prohibited.
Checked and corrected to match the court's document on Oct 5, 2026
Page 10 | Summary-Judgment Motions
Before filing summary judgment, the parties must meet and confer and prepare and file one joint statement of material facts.
Before filing a summary-judgment motion, the parties shall meet and confer to discuss the matters at issue on the motion and shall prepare and file one joint statement of material facts.
Checked and corrected to match the court's document on Oct 5, 2026
Page 10 | Summary-Judgment Motions
A party may file a good-faith partial summary-judgment motion before the note of issue when negotiating a joint statement would be futile or would prejudicially delay filing.
Nor is any party precluded from filing a pre-note-of-issue partial summary judgment motion if they in good faith believe that negotiating a joint statement would be futile or that doing so will cause a prejudicial delay in filing their motion.
Checked and corrected to match the court's document on Oct 5, 2026
Page 10 | Summary-Judgment Motions
Before filing a discovery motion, parties must meet and confer and obtain prior authorization, and the motion must identify who authorized it and when; non-parties and post-judgment discovery disputes are excepted.
After the PC, before making any discovery motion, the parties must meet and confer about all disputes and either raise the issue at the next scheduled conference or email the assigned law clerk to request an earlier conference or leave to file a motion. Discovery motions MAY NOT be made without prior authorization and any discovery motion must set forth who authorized the motion and when. Failure to comply with this rule may result in the summary denial of the discovery motion. This rule does not apply to non-parties, though they may email the assigned law clerk to request a conference in lieu of making a motion. This rule also does not apply to post-judgment discovery disputes, for which a motion may be filed without prior leave of court.
Not confirmed. Read the court's wording below.
Page 5 | DISCOVERY
Adjournment & Extension Requirements
An adjournment request for a submissions-part motion or an OSC returnable on the papers must be made by an e-filed letter that is also emailed to the assigned law clerk.
Requests to adjourn a motion returnable in the submissions part (i.e., Room 130) or an OSC returnable “on papers only” shall be made by e-filed letter that shall also be emailed to the assigned law clerk.
Checked against the court's document on Oct 5, 2026
Page 3 | COMMUNICATIONS WITH THE COURT — Scheduling
An adjournment granted by the submissions part without a stipulation or court approval is void and will be addressed by the court upon notice.
Adjournments granted by the submissions part without a stipulation or court approval ARE VOID, and if and when they are brought to the court’s attention the court will issue an order ruling on the adjournment request.
Checked against the court's document on Oct 5, 2026
Page 3 | COMMUNICATIONS WITH THE COURT — Scheduling
The submissions part may not grant an adjournment unless the parties stipulate to it.
Unless the parties stipulate to an adjournment, the submissions part is NOT authorized to grant adjournments.
Checked against the court's document on Oct 5, 2026
Page 3 | COMMUNICATIONS WITH THE COURT — Scheduling
Court permission for an adjournment of a scheduled appearance ordinarily must be obtained at least two business days in advance, but emergencies are excepted.
To adjourn a scheduled appearance (e.g., a conference or oral argument), the court’s permission must be obtained no later than two business days in advance, except in the event of an emergency.
Checked against the court's document on Oct 5, 2026
Page 3 | COMMUNICATIONS WITH THE COURT — Scheduling
An adjournment request for a scheduled appearance must be emailed to the assigned law clerk and state whether all parties consent.
Requests to adjourn scheduled appearances must be addressed to the assigned law clerk by email and must indicate whether the request is on consent of all parties.
Checked against the court's document on Oct 5, 2026
Page 3 | COMMUNICATIONS WITH THE COURT — Scheduling
Discovery extensions must be requested by emailing the assigned law clerk before the deadline, and the court may grant them for good cause but will not indefinitely grant extensions where the parties are not diligently attempting to meet deadlines.
The parties must strictly comply with all court-ordered discovery deadlines. If an extension of time is needed, it must be requested by emailing the assigned law clerk BEFORE expiration of the deadline. The court may grant extensions for good cause but will not indefinitely grant extensions if the parties are not diligently attempting to meet deadlines.
Checked and corrected to match the court's document on Oct 5, 2026
Page 5 | DISCOVERY
A party cannot assume that a late adjournment request will be granted, and any resulting adjournment will likely be shorter than one granted on an expeditious request.
No party should assume the court will necessarily grant an adjournment request made on the eve of or after a briefing deadline has passed, regardless of whether a prior adjournment request has been made, and if the court does grant such an adjournment, it will likely be much shorter than if the request had been made expeditiously.
Checked against the court's document on Oct 5, 2026
Page 3 | COMMUNICATIONS WITH THE COURT — Scheduling
The Part Clerk may not grant adjournments.
The Part Clerk is NOT authorized to grant adjournments.
Checked against the court's document on Oct 5, 2026
Page 3 | COMMUNICATIONS WITH THE COURT — Scheduling
When an adjournment request is opposed, a responsive email should be sent promptly to the assigned law clerk or by the court-specified deadline.
If the request is opposed, a responsive email should be emailed to the assigned law clerk either promptly or by a deadline that will be communicated by the court.
Not confirmed. Read the court's wording below.
Page 3 | COMMUNICATIONS WITH THE COURT — Scheduling
For an opposed submissions-part or papers-only OSC adjournment request, the responsive letter should be e-filed and emailed promptly or by the court-specified deadline.
If the request is opposed, a responsive letter should be e-filed and emailed to the assigned law clerk either promptly or by a deadline that will be communicated by the court.
Not confirmed. Read the court's wording below.
Page 3 | COMMUNICATIONS WITH THE COURT — Scheduling
Parties should use the procedure in Part Rule 18 rather than requesting an opposed adjournment directly from the submissions part.
Instead, the parties should follow the procedure in Part Rule 18.
Not confirmed. Read the court's wording below.
Page 3 | COMMUNICATIONS WITH THE COURT — Scheduling
Chambers Communication Rules
In cases not filed electronically, pro se litigants and counsel must provide their contact information to the Part Clerk.
In cases that are NOT e-filed, pro se litigants and counsel must provide contact information to the Part Clerk.
Checked against the court's document on Oct 5, 2026
Page 2 | GENERAL RULES
Counsel must email the assigned law clerk as soon as practicable when an action or pending motion is resolved.
Counsel must notify the court as soon as practicable by email to the assigned law clerk if an action or a pending motion has been resolved.
Checked against the court's document on Oct 5, 2026
Page 2 | GENERAL RULES
A party should obtain court leave before filing a Commercial Division Rule 14 letter and may request leave by emailing the assigned law clerk.
Parties should not file Commercial Division Rule 14 letters without prior leave of court. Leave may be requested by emailing the assigned law clerk.
Checked against the court's document on Oct 5, 2026
Page 4 | COMMUNICATIONS WITH THE COURT — Authorized Letters
Every e-filed letter must be emailed to the assigned law clerk with its e-filing confirmation.
All e-filed letters must be emailed to the assigned law clerk along with the e-filing confirmation.
Checked against the court's document on Oct 5, 2026
Page 4 | COMMUNICATIONS WITH THE COURT — Authorized Letters
For an emergency or a resolved case or motion, counsel must immediately email the assigned law clerk rather than merely filing the communication electronically.
In an emergency or if a case or motion is resolved, please email the assigned law clerk immediately. Do not merely e-file a letter or stipulation.
Checked against the court's document on Oct 5, 2026
Page 9 | ELECTRONIC FILING
After a competing-statement violation, opposing counsel must not file a responsive statement and instead should notify the court and request that the statement be stricken.
If a party violates this rule, opposing counsel SHALL NOT file a responsive statement of facts, but rather should e-file and email the court a letter noting the rule violation and requesting that the statement be stricken from the record.
Checked and corrected to match the court's document on Oct 5, 2026
Page 10 | Summary-Judgment Motions
If a rule calls for contacting a law clerk but none has been assigned, the party should email Mr. Rand.
If the rules provide that you should contact a law clerk and one has not yet been assigned, please email Mr. Rand.
Checked against the court's document on Oct 5, 2026
Page 1 | GENERAL RULES
Except for emergencies, parties should not call Chambers.
Unless in the case of an emergency, no one should call Chambers.
Checked against the court's document on Oct 5, 2026
Page 4 | COMMUNICATIONS WITH THE COURT — Telephone Calls
After assignment to the part and before the preliminary conference, parties with a discovery dispute must email Mr. Rand to request resolution guidance.
After an action is assigned to this part, but before the preliminary conference (PC), if the parties have a discovery dispute, they shall email Mr. Rand to request guidance on how to resolve the dispute.
Checked against the court's document on Oct 5, 2026
Page 4 | DISCOVERY
A party seeking an urgent court call should send the assigned law clerk a short email requesting the call and briefly explaining the issues; the court will arrange a Microsoft Teams call and send an invitation.
If a party requires an urgent call with the court--such as an unscheduled call to address a discovery dispute, to resolve a dispute during a deposition, or any other urgent matter--a short email should be sent to the assigned law clerk requesting a call along with a brief explanation of the issues, and the court will notify the parties when there will be a call on Microsoft Teams for which the court will send a Teams invite.
Checked against the court's document on Oct 5, 2026
Page 4 | COMMUNICATIONS WITH THE COURT — Telephone Calls
If the assigned law clerk does not respond or is unavailable, counsel may email the other law clerk and the part clerk.
If the assigned law clerk does not respond or if you receive an out-of-office message, you may email the other law clerk and the part clerk.
Checked against the court's document on Oct 5, 2026
Page 9 | ELECTRONIC FILING
General questions about appearances may be sent to the Part Clerk by phone at (646) 386-3362 or by email to Mr. Rand.
General questions about appearances may be addressed to the Part Clerk by email or by phone at (646) 386-3362, or by email to Mr. Rand.
Checked against the court's document on Oct 5, 2026
Page 3 | COMMUNICATIONS WITH THE COURT — Scheduling
Basic questions and updates should be emailed to the assigned law clerk.
Basic questions or updates should be emailed to the assigned law clerk.
Checked against the court's document on Oct 5, 2026
Page 4 | COMMUNICATIONS WITH THE COURT — Telephone Calls
Law clerks will not communicate ex parte with attorneys or litigants.
The law clerks will not communicate with an attorney or litigant ex parte.
Not confirmed. Read the court's wording below.
Page 1 | GENERAL RULES
Every email to the court must include all appearing parties as copy recipients.
All emails to the court must copy all appearing parties.
Not confirmed. Read the court's wording below.
Page 1 | GENERAL RULES
Even when ex parte TRO relief is legally authorized, counsel must email the papers to Mr. Rand as soon as practicable.
If ex parte relief is legally authorized, you must still email the papers to Mr. Rand as soon as practicable.
Not confirmed. Read the court's wording below.
Page 9 | Orders to Show Cause
An OSC movant must immediately email the papers to Mr. Rand after electronic filing and await further instructions.
The movant on an order to show cause (OSC), regardless of whether a temporary restraining order (TRO) is sought, shall email the papers to Mr. Rand IMMEDIATELY after the OSC is e-filed and await instructions on how to proceed.
Not confirmed. Read the court's wording below.
Page 9 | Orders to Show Cause
Unless the court has sent a Teams invitation, the parties must send an invitation or ask the court to do so at least two business days before the conference.
Unless the court has already sent a Teams invite, at least two business days prior to a conference, the parties shall either send an invite or request that the court do so.
Not confirmed. Read the court's wording below.
Page 4 | COMMUNICATIONS WITH THE COURT — Telephone Calls
All parties must join the Teams call at least five minutes before the scheduled conference begins.
All parties must join the Teams call at least five minutes before the conference is scheduled to begin.
Not confirmed. Read the court's wording below.
Page 4 | COMMUNICATIONS WITH THE COURT — Telephone Calls
The movant must notify Mr. Rand by email when a motion is fully briefed.
When a motion is fully briefed, the movant shall notify Mr. Rand by email.
Not confirmed. Read the court's wording below.
Page 7 | MOTIONS
Every Teams invitation will include a dial-in number for someone unable to use Teams.
The Teams invite will always have a dial-in number alternative for anyone who cannot use Teams.
Not confirmed. Read the court's wording below.
Page 4 | COMMUNICATIONS WITH THE COURT — Telephone Calls
Unless otherwise directed, court calls and discovery conferences take place by audio-only Microsoft Teams with cameras off.
Unless otherwise directed, all calls and discovery conferences will be on Microsoft Teams (audio only, cameras off).
Not confirmed. Read the court's wording below.
Page 4 | COMMUNICATIONS WITH THE COURT — Telephone Calls
Junior Lawyer Participation Incentives
A representation that oral argument will be presented by an attorney enhancing diversity in the bar or admitted to practice fewer than five years weighs in favor of holding oral argument.
A representation by letter that argument will be made by an attorney whose participation enhances diversity in the bar or an attorney admitted to practice fewer than five years will weigh in favor of the court deciding to hold oral argument.
Checked against the court's document on Oct 5, 2026
Page 8 | MOTIONS