New York Supreme Court, New York County Document Filing Requirements

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

Civil cases

Applies to

Summary judgment notice or supporting affirmation

The notice of motion or early portion of the supporting affirmation must state the Note of Issue filing date and that the motion is timely.

In the notice of motion or early in the affirmation in support, please state the date the Note of Issue was filed and that the motion is timely.

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

Civil cases

Applies to

Tro application

A request for temporary restraint in an order to show cause must include proof of adversary notice and the time, date, and manner of presentation for signature.

If a party seeks a temporary restraint in an Order to Show Cause, they MUST provide proof that their adversary was notified about the application and the time, date and manner that the application will be presented for signature.

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

Civil cases

Applies to

Transfer notice letter

A party with a previously scheduled inquest, hearing, or trial in another Part must advise chambers of the transfer by letter filed through NYSCEF and e-mail a courtesy copy to the Part.

Parties with a previously scheduled inquest, hearing, or trial appearance in another Part shall advise chambers of the transfer by letter to Judge, filed to NYSCEF with a courtesy copy e-mailed to the Part.

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

Applies to

Confidentiality order submission

A proposed deviation from the form confidentiality stipulation requires a proposed order, a redline against the form, and a letter explaining the reasons for the deviation.

If the parties propose to deviate from the form Stipulation, the parties shall file (1) a copy of the parties’ proposed confidentiality order; (2) a redline of the parties’ proposed order to the form Stipulation; and (3) a letter to the Court articulating the reasons for such deviations.

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

Applies to

Opposition

All opposing papers must include a response to the Statement of Undisputed Facts that complies with Commercial Division Rule 19-a.

All opposing papers shall include a response to the Statement of Undisputed Facts that comply with Commercial Division Rule 19-a.

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

Applies to

Pro hac vice motion

Must include

proposed order

Every pro hac vice admission request, including a stipulated request, must include the specified supporting affidavits, a recent good-standing certificate, and a proposed order.

Requests for admission pro hac vice, including requests 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, a recent certificate of good standing for the applicant, and a proposed order for each motion.

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

Applies to

Preliminary conference submission

Must include

proposed order, local rule certificate

Before the Preliminary Conference, the parties must jointly submit a two-page-or-less statement, a proposed Preliminary Conference Order using the Court's form, and a Commercial Division Rule 10 Certification via NYSCEF at least two days before the conference.

A. Preliminary Conference: Pursuant to Commercial Division Rules 8 and 11, prior to the scheduled Preliminary Conference, the parties shall meet and confer to jointly prepare a brief statement—not to exceed two (2) pages—describing the facts of the case and the contentions of the parties and a proposed Preliminary Conference Order, using this Court’s form Preliminary Conference Order. The parties shall submit the joint statement, proposed Preliminary Conference Order, and Commercial Division Rule 10 Certification at least two (2) days prior to the date of the scheduled preliminary conference via NYSCEF.

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

Applies to

Exhibit chart

Each side must provide an exhibit chart conforming to the court’s Addendum 1 exhibit-chart template.

Exhibits and Exhibit Charts: Each side must provide an exhibit chart that conforms to Addendum 1 attached to these Practices and Procedures (Template for Exhibit Chart).

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

Applies to

Motion

When a case has a related pending federal-court matter, all relevant federal papers and orders must be attached to motions.

If a case has a collateral pending Federal Court matter, all relevant papers and orders from the Federal Court shall be exhibited to motions.

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

Applies to

Motion withdrawal stipulation

To withdraw a fully submitted motion, the movant must file a stipulation and email it to the Principal, Assistant Law Clerk, and Part Clerk for so-ordering.

To withdraw a fully submitted motion, the movant shall file a stipulation and e-mail same to the Principal and Assistant Law Clerk and Part Clerk to be So-Ordered.

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

Applies to

Order to show cause

An Order to Show Cause must be used for emergent or time-sensitive issues requiring court intervention.

Orders to Show Cause shall be used where there are emergent or time sensitive issues that must be raised to the Court

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

Applies to

Ai certification

When the AI certification reports use of a generative AI program, the certification must identify the program and the documents containing AI-generated material.

If the certification states a generative artificial intelligence program was used, the program must be identified and the documents which include matter generated by the program

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

Applies to

Order to show cause

Every stay application must be made by Order to Show Cause.

All applications for stays shall be made by Order to Show Cause

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

Applies to

Order to show cause

Every request for interim relief must be made by Order to Show Cause.

All requests for interim relief shall be made by Order to Show Cause

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

Applies to

Motion submission

Must include

ai disclosure

Every submission concerning a motion must include an attorney or self-represented party's certification stating either that no generative AI program was used or that all generated text was reviewed for accuracy and approved.

All submissions with respect to a motion must include a certification by an attorney (or self-represented party) either that no generative artificial intelligence program was used in the drafting of any affidavit, affirmation, or memorandum of law contained within the submission, or that a generative artificial intelligence program was used but all generated text, including citations, quotations, and legal analysis was reviewed for accuracy and approved by an attorney (or the self-represented party).

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

Civil cases

Applies to

Motion

The first page of every motion paper must display the applicable Motion Sequence Number in the upper-right corner.

the first page of EVERY motion paper must reflect the respective MSQ in the upper right corner.

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

Civil cases

Applies to

Note of issue

A conference order granting permission is required before a party may file a note of issue.

A note of issue may not be filed until there is a conference order granting permission.

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

Civil cases

Applies to

Temporary restraining order

A party seeking a temporary restraining order must provide proof of adversary notice and the time, date, and manner on which the application will be presented for signature.

If a party seeks a temporary restraint in an Order to Show Cause, they MUST provide proof that their adversary was notified about the application and the time, date and manner that the application will be presented for signature.

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

Civil cases

Applies to

Proposed order

Must include

proposed order

Parties must e-mail a proposed Preliminary Conference Order to the Part Clerk by 3:00 p.m. on the day before the conference, in lieu of appearing.

The Part Clerk will circulate a blank Preliminary Conference Order (PCO) form via e-mail in advance of the scheduled conference date. Parties must submit a proposed PCO via email to the Part Clerk, in lieu of an appearance, no later than 3:00 p.m. the day prior to the scheduled appearance date.

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

Civil cases

Applies to

Proposed order

Must include

proposed order

Parties must e-mail a proposed Compliance Conference Order to the Part Clerk by 3:00 p.m. on the day before the conference, in lieu of appearing.

The Part Clerk will circulate a blank Compliance Conference Order (CCO) form via e-mail in advance of the scheduled conference date. Parties must submit a proposed CCO via email to the Part Clerk, in lieu of an appearance, no later than 3:00 p.m. the day prior to the scheduled appearance date.

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

Civil cases

Applies to

Proposed order

Must include

proposed order

The parties must prepare a draft Status Conference Order before the conference and either e-mail it to the Court in advance or provide it at the appearance.

The Part Clerk will circulate a blank Status Conference Order (SCO) form via e-mail in advance of the scheduled conference date. The parties are directed to prepare a draft SCO prior to the scheduled appearance, inclusive of any terms to which the parties agree. Please either provide the Court with the draft SCO via e-mail prior to the scheduled appearance or be prepared to provide same to the Court at the scheduled appearance.

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

Civil cases

Applies to

Discovery motion

When the Court grants leave to file a discovery motion, the good-faith affirmation must state precisely when and by whom leave was granted.

If leave to make a discovery-related motion was granted by the Court, the affirmation of good faith shall state precisely when and by whom it was granted leave to file the motion.

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

Civil cases

Applies to

Reply brief

Reply papers may not be submitted for an Order to Show Cause without the Court's advance permission.

Absent advance permission of the court, reply papers shall not be submitted on orders to show cause.

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

Civil cases

Applies to

Letter motion

Letter motions are prohibited and will not be considered by the Court.

Letter motions are prohibited and will not be considered.

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

Civil cases

Applies to

Proposed findings conclusions

After a nonjury trial, the parties must submit proposed findings of fact and conclusions of law within 10 calendar days after the record closes unless the court directs otherwise.

For nonjury trials, the parties shall submit proposed findings of facts and conclusions of law within 10 calendar days of the close of the record, unless otherwise directed by the Court.

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

Civil cases

Applies to

Preliminary jury charges

The parties must submit proposed preliminary jury charges with PJI citations no later than 24 hours before trial.

The parties shall submit proposed preliminary jury charges, proposed verdict sheets and final jury charges, with Pattern Jury Instruction (PJI) citations, no later than 24 hours before the commencement of trial.

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

Civil cases

Applies to

Non pji jury charges and modified pji

Counsel must cite appropriate legal authority supporting proposed non-PJI charges or modifications to PJIs.

Counsel shall cite appropriate legal authority in support of suggested non-PJI charges or suggested PJI modifications.

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

Applies to

Judicial subpoena

A judicial subpoena must identify the requested materials or witnesses and include an affirmation explaining why the subpoena is necessary.

Parties seeking a judicial subpoena must state in the subpoena what materials/witnesses are being requested and include an affirmation stating the reasons why a judicial subpoena is necessary.

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

Civil cases

Applies to

Compliance order

Compliance Conference orders must identify all appearing counsel by name, email address, physical address, and telephone number; failure to do so may result in a default.

Please put the names, emails, addresses and telephone numbers of all counsel appearing at the conference. If a party fails to note their appearance, a default against that party may be taken.

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

Civil cases

Applies to

Discovery motion

Every filed discovery motion must describe the court authorization and include the order permitting the motion as an exhibit.

Any discovery motion filed must detail the court’s authorization and an order permitting the filing of the motion shall be submitted as an exhibit.

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

Civil cases

Applies to

Exhibits

Each affidavit or affirmation must be filed as a separate exhibit; combining multiple affidavits or affirmations in one exhibit may result in only the first being considered.

Each affidavit or affirmation is to be its own exhibit. If more than one affidavit or affirmation is contained in an exhibit, it is likely that only the first one will be considered.

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

Civil cases

Applies to

Note of issue

A Note of Issue may not be filed without a so-ordered stipulation certifying that discovery is complete, and an improperly filed Note of Issue may be stricken sua sponte.

A Note of Issue may NOT be filed unless a stipulation is so-ordered certifying that discovery is complete. Improperly filed Notes of Issue may be stricken sua sponte.

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

Civil cases

Applies to

Stipulation

The discovery-completion stipulation must certify completion of discovery and provide for filing the Note of Issue.

The stipulation must certify that all discovery is complete and provide for the filing of a Note of Issue.

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

Applies to

Discovery motion

Every discovery motion must be accompanied by a separate good-faith affirmation under 22 NYCRR § 202.7.

Parties filing discovery motions must include a separate affirmation of good faith (22 NYCRR §202.7).

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

Applies to

Order to show cause

Must include

proposed order

An Order to Show Cause is required for specified statutory, stay, or emergency-interim-relief proceedings; the proposed order must provide for service of responsive papers, and reply papers are prohibited without express court permission.

A motion or special proceeding shall only be initiated by Order to Show Cause, where required by statute, a stay is required or where emergency interim relief is sought. Any proposed Order to Show Cause shall include a provision for the service of responsive papers, with a space reserved for the date and method of service, which will be filled in by the Court. Reply papers are not permitted except by express permission of the Court.

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

Applies to

Order to show cause

A request for temporary restraint in an Order to Show Cause must provide proof of advance notice to all parties or a reasonable explanation for why advance notice could not be provided.

If a party seeks a temporary restraint in an Order to Show Cause, they must comply with 22 NYCRR §202.7-f, providing proof that all parties were notified about the application and the time, date and manner that the application will be presented, or provide a reasonable explanation why such advance notice cannot be provided.

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

Applies to

Pretrial submissions

At the pretrial conference, parties must serve and submit a witness list, proposed jury instructions and verdict sheets in Word format, prior dispositive decisions, and all marked pleadings and bills of particulars to the Part 37 email.

The parties shall serve and submit the following to the Part 37 email (sfc-part37@nycourts.gov) as directed at the Pre-Trial Conference. 1. Witness list (to include any interpreters needed) 2. Proposed jury instructions in Word format with PJI numbers 3. Proposed Jury Verdict Sheets in Word format 4. Copies of all prior dispositive decisions on the case, including but not limited to any appellate decisions and any preclusion decisions 5. All marked pleadings and bills of particulars

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

Applies to

Stipulation

All parties must sign or electronically sign proposed stipulations before they are submitted to the court.

Proposed stipulations must be signed or e-signed by all parties before submission to the court.

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

Applies to

Case or motion status notice

Counsel and self-represented litigants must promptly notify Part 58 in writing of specified settlements, dispositions, mootness, death, or bankruptcy events.

Counsel and self-represented litigants are under a continuing obligation to notify Part 58 in writing, and as soon as possible, if an action is settled, discontinued, or otherwise disposed of, if a case or motion has become totally or partially moot, or if a party has died or filed a petition in bankruptcy.

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

Applies to

Summary judgment motion

Every summary judgment motion must contain a short, concise, numbered-paragraph statement of material facts alleged to be undisputed.

Additionally, in accordance with 22 NYCRR 202.8-g(a), this Court, in its discretion, directs that all summary judgment motions must contain a “short and concise statement, in numbered paragraphs, of the material facts as to which the moving party contends there is no genuine issue to be tried.”

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

Applies to

Discovery motion

Failure to comply with the discovery-motion requirements may result in denial, and the court may decide the motion on submission or schedule a discovery conference instead of argument.

Failure to comply with these requirements will result in the denial of the motion. Additionally, the court has the discretion to decide a discovery motion on submission or to schedule a discovery conference in lieu of hearing argument on the same.

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

Applies to

Stipulation

A stipulation resolving a motion or extending a court deadline must be emailed to the Part 58 Clerk, and stipulations requiring clerk action must direct the action and include form EF-22 in e-filed cases.

Where such a stipulation resolves a motion or extends a deadline previously set by the court, it must be e- mailed to the Part 58 Clerk at SFC-Part58-Clerk@nycourts.gov so that the court may so-order the same. A stipulation resolving a motion which requires a Clerk to take action, such as a motion to consolidate, change venue, or amend a caption or pleading, must contain language directing the Clerk to take such specific action in accordance with CPLR 8019(c) and, in e-filed cases, must be accompanied by NYSCEF form EF-22.

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

Applies to

Order

Orders must be legible, identify the case as a Part 58 action, name Justice Cohen, and list the names, addresses, and telephone numbers of counsel appearing at the conference.

All orders must be legible, must indicate that the case is a Part 58 action, and must contain Justice Cohen’s name, as well as the names, addresses and telephone numbers of all counsel appearing at the conference.

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

Applies to

Trial submission

At the first trial appearance, all parties must provide specified trial materials, including pleadings, discovery-related documents, relevant authorities, motions in limine, a revisable proposed verdict sheet, and a trial memorandum.

At the first appearance before Justice Cohen for trial, all parties shall provide: all marked pleadings and bills of particular, all notices to admit and responses thereto, any relevant case law, prior decisions bearing directly on the issues to be raised at trial, all motions in limine, a proposed verdict sheet (subject to revision), and a brief trial memorandum of law setting forth the relevant facts of the case and setting forth the legal arguments to be contested at trial.

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

Applies to

Trial memorandum

The required trial memorandum must state the relevant facts and the legal arguments that will be contested at trial.

a brief trial memorandum of law setting forth the relevant facts of the case and setting forth the legal arguments to be contested at trial

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

Applies to

Jury instructions

The parties must provide the court with proposed jury instructions in preparation for the charge conference.

In preparation for the charge conference, the parties shall provide the court with proposed jury instructions.

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

Civil cases

Applies to

Motion withdrawal or resolution stipulation

After a fully submitted motion is resolved, the movant must immediately file and email the part clerk a stipulation withdrawing or otherwise resolving it.

If a motion is resolved after it is fully submitted, the movant shall immediately inform the court by filing and emailing to the part clerk a stipulation withdrawing or otherwise resolving the motion.

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

Civil cases

Applies to

Applicant affidavit

The applicant affidavit must disclose prior pro hac vice applications and their outcomes, state whether the applicant has had a disciplinary proceeding, and certify compliance with the Part 13 Rules.

The applicant’s affidavit must: (1) advise the court as to the total number of times the applicant has applied to be admitted in New York pro hac vice and how many times the application has been granted and/or denied; (2) state whether the pro hac vice applicant has ever been or is presently the subject of a disciplinary proceeding; and (3) certify that the applicant has read and will abide by the Part 13 Rules.

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

Civil cases

Applies to

Proposed witness list

The parties must provide a list of proposed witnesses, including interpreter needs and the required language and dialect.

A list of proposed witnesses, including the need for any interpreters with the required language and dialect;

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

Civil cases

Applies to

Trial day estimate

The parties must provide an estimate of the number of trial days required.

An estimate of the number of required trial days;

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

Civil cases

Applies to

Proposed jury instructions

For proposed jury instructions quoted verbatim from the Pattern Jury Instructions, citation of the PJI section numbers is sufficient.

If the proposed instructions are taken verbatim from the Pattern Jury Instructions (hereinafter PJI), PJI section numbers will suffice.

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

Civil cases

Applies to

Proposed jury instructions

When a proposed jury instruction is not verbatim, requires factual or contention-based characterization or description, or is not based on the PJI, the exact requested language and supporting authority must be emailed simultaneously as a DOCX file to Justice Schumacher, both law clerks, and opposing counsel.

If a PJI instruction is not verbatim or requires characterization or description of the evidence or the parties’ contentions, or if the language is not based on the PJI, the exact requested language, together with the authority for it, must be emailed in .docx format to Justice Schumacher, both law clerks, and opposing counsel simultaneously.

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

Civil cases

Applies to

Proposed jury instructions

Any PJI section numbers cited in proposed jury instructions must be current on the submission date.

As the PJI is a living, frequently modified document, the PJI section numbers cited must be current as of the date of submission.

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

Civil cases

Applies to

Subpoenaed documents

Counsel, rather than court personnel, is responsible for ensuring that all subpoenaed documents arrive in the subpoenaed records room at 60 Centre Street.

It is the duty of counsel, not court personnel, to ensure all subpoenaed documents have arrived in the subpoenaed records room at 60 Centre Street.

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

Civil cases

Applies to

Conference form

The conference form must be completed in full and identify all remaining discovery; blank, incomplete, or judge-dependent entries are rejected.

You must fill out the entire form, setting forth all remaining discovery. Blank, incomplete, “must see the judge,” etc. fill will be rejected.

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

Civil cases

Applies to

Memorandum of law

Must include

legal argument

Substantive legal arguments and statutory or case-law references must be presented in a separately filed memorandum of law, not in an affirmation or affidavit.

All substantive legal arguments, including references to statutes and case law, shall be made in memoranda of law, only, which shall be filed separately from any affirmations or affidavits. Legal arguments ===== PAGE 4 ===== are not to be included in affirmations. Do not cite cases in affirmations. Instead, file a memorandum of law.

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

Civil cases

Applies to

Deposition testimony citation

References to deposition testimony must cite the exact page and line numbers relied upon and may not merely attach the entire transcript or selected portions.

Any reference to deposition testimony must cite to the exact page and line numbers relied upon rather than merely attaching the entire transcript or “relevant portions.”

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

Civil cases

Applies to

Voluminous exhibit citation

References to other voluminous exhibits must include pinpoint citations identifying the exact location within the exhibit.

Any reference to any other voluminous exhibit annexed to a motion must include pinpoint citations so that the exact location within the exhibit can be easily located.

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

Civil cases

Applies to

Pro hac vice applicant affidavit

The applicant affidavit must disclose the number of New York pro hac vice applications, the number granted or denied, and whether the applicant has ever or currently faces a disciplinary proceeding.

The applicant’s affidavit must advise the court as to the total number of times the applicant has applied to be admitted in New York pro hac vice and how many times the application has been granted and/or denied. The affidavit must also state whether the pro hac vice applicant has ever been or is presently the subject of a disciplinary proceeding.

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

Civil cases

Applies to

Exhibits

Each electronically submitted exhibit must be identified and described in its heading.

All exhibits electronically submitted must be described in the heading of the attached exhibit (e.g. Exhibit A – Bill of Particulars), so that it is known what document is filed in the exhibit.

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

Civil cases

Applies to

Deposition transcript

The entire deposition transcript must be provided rather than excerpts.

Entire transcript must be provided not simply excerpts.

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

Civil cases

Applies to

Outstanding discovery list

Counsel must bring a list of all outstanding discovery to a compliance conference.

At compliance conferences, counsel must bring a list of all outstanding discovery.

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

Civil cases

Applies to

Order

If a decision presents a problem, an order supported by an attorney affirmation must be filed and emailed to the Part's email address.

If there is a problem with a decision, please file an order with attorney affirmation and email the same to the part email address.

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

Civil cases

Applies to

Motion

The first page of every motion-related paper, including notices, oppositions, replies, and exhibits, must show the applicable motion sequence number.

The first page of every motion paper (notice of motion, opposition, reply, exhibits, etc.) must reflect the applicable motion sequence number.

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

Civil cases

Applies to

Exhibit

Every exhibit must be numbered.

Each exhibit must be numbered.

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

Civil cases

Applies to

Exhibit reference

An exhibit reference must state the exhibit’s NYSCEF docket number and the exact cited page within that exhibit.

References to exhibits must identify the exhibit’s NYSCEF docket number and the exact page being cited within the exhibit.

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

Civil cases

Applies to

Order to show cause

A party seeking interim relief in an order to show cause must give advance notice to the adversary or explain why notice was not provided.

Any party seeking interim relief within an OSC must provide advance notice to the adversary or explain why advance notice was not provided, as required by 22 NYCRR 202.7 (f).

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

Civil cases

Applies to

Trial preparation submission

At the first court appearance, each party must furnish the specified trial-preparation materials, including proposed witnesses, trial-day estimates, pleadings, decisions, notices to admit, EBT excerpts, a five-page trial memorandum, and two business cards per attorney.

Upon the first appearance before this court, the parties must furnish a list of proposed witnesses, including the need for any interpreters, with the required language and dialect; an estimate of required trial days; all marked pleadings and bills of particulars; all decisions in the case, including any appellate decisions; any notices to admit; copies of those portions of EBTs intended for use at trial for any purpose; a trial memorandum not to exceed five pages briefly setting forth the party’s position and the relevant factual and legal issues to be tried, citing relevant case law; and two business cards for each attorney.

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

Civil cases

Applies to

Motion in limine

All in-limine and other motions and applications must be furnished before trial begins.

Before the start of trial, the parties must furnish all in-limine or other motions and applications.

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

Civil cases

Applies to

Motion in limine

In-limine motions must be submitted in writing as soon as practicable or as scheduled at a pretrial conference, with a copy to every party.

All motions in limine must be presented in writing to the court as soon as practicable or as specifically scheduled at any pretrial conference, with a copy to all parties.

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

Civil cases

Applies to

Motion

Every motion or application must include citations to relevant authority.

Any motion or application must include citations to relevant authority.

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

Civil cases

Applies to

Subpoenaed documents

Counsel must ensure that all subpoenaed documents arrive in the subpoenaed records room at 60 Centre Street.

It is the duty of counsel, not court personnel, to ensure all subpoenaed documents have arrived in the subpoenaed records room at 60 Centre Street.

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

Civil cases

Applies to

Jury instructions

For non-verbatim, evidence-dependent, party-contention-based, or non-PJI jury instructions, the exact requested language and supporting authority must be submitted.

If a PJI instruction is not verbatim or requires characterizing or describing the evidence or the parties’ contentions, or if the language is not based on the PJI, the exact requested language, together with the authority for it, must be submitted.

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

Applies to

Proposed order

Must include

proposed order

Proposed Preliminary Conference and Compliance Conference Orders must be emailed to the Assistant Law Clerk and Chambers within 48 hours after the conference.

Proposed Preliminary Conference (“PC”) Orders and Compliance Conference Orders shall be submitted to the Assistant Law Clerk by email to dwachtel@nycourts.gov and to Chambers by email to SFC-Part65@nycourts.gov within forty-eight (48) hours of the conference date.

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

Applies to

Proposed order

Must include

proposed order

A proposed preliminary-conference order must state when the Bill of Particulars was served, and the court will defer issuing the order until the Bill of Particulars is provided if it has not been served.

Any proposed PC Order must state the date on which Plaintiff(s) served the Bill of Particulars (“BP”). If a BP has not been served, the court will defer issuance of a PC Order until the BP is provided.

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

Applies to

Proposed order

Must include

proposed order

If a proposed preliminary-conference order is not received before the scheduled conference date, the parties must appear in person for the preliminary conference.

If the court does not receive a proposed PC Order prior to the scheduled conference date, the parties are required to appear in person for the PC.

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

Applies to

Note of issue

A note of issue may be filed only with a stipulation executed by all parties certifying that discovery is complete.

The note of issue shall not be filed absent a stipulation, executed by all parties, certifying that all discovery is complete.

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

Applies to

Compliance conference stipulation or order

A compliance-conference stipulation or order may not require submission of records or materials for in camera review unless the matter has first been conferenced with and approved by the court.

In Camera Review: No compliance conference stipulation or order shall direct any party to submit records or other materials to the court for in camera review unless the matter has first been conferenced with and approved by the court.

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

Applies to

Summary judgment motion

A memorandum of law is required for every motion for summary judgment.

All motions for summary judgment shall be made no more than 60 days after the note of issue is filed. A memorandum of law is required for all motions for summary judgment.

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

Applies to

Paper

An attorney or party using a generative AI tool to prepare a filed, submitted, or served paper must review it carefully, independently verify that it contains no fabricated material, and certify compliance by signing the paper.

Any attorney or party who employs a generative artificial intelligence tool, as defined in 22 NYCRR § 161.2(b), in the preparation of any paper, as defined in 22 NYCRR § 161.2(c), that is filed with or submitted to this court, or served upon another party in an action before this court, shall carefully review the paper and independently verify that it contains no fabricated or fictitious cases, statutes, or other material. By signing such paper, the attorney or party certifies that this review has been conducted and the submission is free of any fabricated or fictitious content.

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

Applies to

Memorandum of law

A memorandum of law is required for every motion for summary judgment.

15. All motions for summary judgment shall be made no more than 120 days after the filing of the note of issue. A memorandum of law is required for all motions for summary judgment.

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

Applies to

Document filed with court

Every document filed with the Court must include the index number and the name of the alleged or incapacitated person.

Be sure to include the index number and the name of the Alleged/Incapacitated Person on all documents filed with the Court.

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

Applies to

Pro hac vice request

Must include

proposed order

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.

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

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).

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

Applies to

Joint letter

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.

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

Applies to

Motion

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).

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

Applies to

Motion

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.

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

Applies to

Order to show cause

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.

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Applies to

TRO

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.

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

Applies to

Pretrial submission

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

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Applies to

Pretrial submission

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

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

Applies to

Pleadings briefs and other papers

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;

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

Civil cases

Applies to

Joint letter

The compliance-conference joint letter must address discovery status, significant disputes for the conference, outstanding motions and appeals, and attempts at Alternative Dispute Resolution or other settlement efforts.

At least seven days prior to the compliance conference, counsel shall submit a joint letter not exceeding three single-spaced pages setting forth the status of discovery, describing any significant disputes to be addressed at the conference, whether there are any outstanding motions and/or appeals, and whether the parties have attempted Alternative Dispute Resolution or other efforts at settlement.

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

Civil cases

Applies to

Preliminary conference order

Parties must use the Part's standard Preliminary Conference Order, meet and confer, complete the order before the conference, and be prepared to address the topics in Commercial Division Rule 8.

Parties are to use this Part’s standard form Preliminary Conference Order. Copies are available on the Commercial Division website (https://www.nycourts.gov/LegacyPDFS/courts/comdiv/NY/PDFs/Part3- Preliminary-Conference-Order.pdf), from the Part Clerk, or in the Courtroom. Parties are to meet and confer and fill out the Preliminary Conference Order in advance of the Conference and must be prepared to address the topics listed in Commercial Division Rule 8.

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

Civil cases

Applies to

Preliminary conference information exchange

Certain information must be exchanged in advance of the Preliminary Conference under Commercial Division Rule 11(a)-(c).

This Part hereby adopts the procedure set forth in Commercial Division Rule 11(a)-(c), which requires certain information to be exchanged in advance of the Preliminary Conference.

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

Civil cases

Applies to

Joint letter

The status-conference joint letter must summarize the case, state the current discovery and Note of Issue schedule, and identify proposed schedule revisions and the reasons for them.

At least seven days prior to the status conference, counsel shall submit a joint letter not exceeding three single-spaced pages setting forth a summary of the case, the current schedule for completion of discovery and filing Note of Issue, any proposed revisions to the schedule and reasons therefor,

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

Civil cases

Applies to

Joint letter

The joint settlement-conference letter must outline the remaining issues and each party's general position on those issues.

In preparation for the conference, the parties must submit a joint letter (no more than 5 pages) at least one week before the conference, which outlines the remaining issues to be resolved and each parties’ general position on those issues.

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

Civil cases

Applies to

Jury claims summary

For jury trials, each party must provide a one- or two-sentence summary of its claims for use in the Court's preliminary jury instructions.

A short summary (one or two sentences) of each party’s claims to be used by the Court as part of the preliminary instructions to the jury; and

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

Civil cases

Applies to

Exhibits

Trial exhibits must be pre-marked in accordance with Commercial Division Rule 28.

Exhibits must be pre-marked in accordance with Commercial Division Rule 28.

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

Civil cases

Applies to

Proposed exhibits

By the first day of trial, counsel must provide the Court with a flash drive containing proposed exhibits and any witness-display binders.

On or before the first day of trial, counsel shall provide the Court with a flash drive containing copies of their proposed exhibits, as well as any binders of documents that will be shown to witnesses.

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

Civil cases

Applies to

Daily trial transcript

For multi-day trials, the parties must order a daily transcript copy during trial.

For multi-day trials, the Court requires that the parties order a daily copy of the transcript during trial.

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

Applies to

Settlement conference fact statement

Before the mediation-style settlement conference, the parties must submit a short written statement of the action's underlying facts to the Part 56 Part Clerk.

Prior to the two-hour mediation-style settlement conference, the parties shall submit, to the Part 56 Part Clerk, a short written statement of the facts underlying the action, and all parties shall inform the court of their estimation of the full value of the action if liability is proven, with citations to appellate precedent determining the fair and reasonable value of the injuries claimed by the plaintiff, without set-offs for comparative fault or collateral sources.

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

Applies to

Motion in limine

Counsel must submit motions in limine and trial memoranda in writing no later than the first day of jury selection.

Counsel shall submit motions in limine and trial memoranda in writing to the court as directed but, in any event, not later than the first day of jury selection.

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

Applies to

Potential witness list

Counsel must provide the court with an ordered list of potential trial witnesses, including experts.

Counsel shall provide to the court a list of potential witnesses in order in which they intend to call them at trial, including expert witnesses.

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

Applies to

Proposed verdict sheet

The parties must submit proposed verdict sheets and requests to charge by the start of the second trial day, preferably before trial begins.

The parties shall submit proposed verdict sheets and requests to charge (subject to amendment), citing the PJI sections, preferably before the commencement of trial, but not later than the start of the second day.

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

Applies to

Proposed jury charges

Any suggested changes to a PJI must be submitted by email to the Justice’s law clerks as the full text with all changes red-lined in Word format.

If any changes to the PJI are suggested, counsel must submit the full text with all changes red-lined in Word format by email to the Justice’s law clerks.

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

Applies to

Preliminary conference order

Parties must confer on all discovery matters and email the part clerk an agreed-upon, signed draft PCO by noon on the day before the preliminary conference.

Preliminary Conference Order (“PCO”): Parties shall meet and confer about all discovery matters and submit an agreed upon, signed draft PCO (22 NYCRR 202.12) for the judge’s review and signature by email to the Part Clerk by 12:00 noon on the day prior to the Preliminary Conference.

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

Applies to

Joint discovery plan

In complex discovery cases, counsel must submit a joint discovery plan with the PCO containing specified issue, discovery, disclosure, disputes, witness, non-party discovery, and ESI information, after which it will be so ordered and uploaded to NYSCEF.

Joint Discovery Plan: If the case is on a complex discovery track, counsel shall submit a joint Discovery Plan with PCO. The Discovery Plan shall contain: a statement of the issues in the cases and the discovery sought for each issue (both substance and temporal scope); proposed deadlines for disclosure; identification of categories of information that are not in dispute and those that are potentially in dispute; identification of non-party discovery and material witnesses, known and potential; and ESI issues. The Discovery Plan will be So-Ordered and uploaded to NYSCEF with the PCO.

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

Applies to

Compliance or status conference order

Parties must confer on outstanding discovery and email the part clerk an agreed, signed draft CCO or SCO by noon on the preceding day.

Compliance Conference Order (“CCO”) or Status Conference Order (“SCO”): Parties shall meet and confer about outstanding discovery matters and submit an agreed upon, signed draft, CCO or SCO as appropriate, for the judge’s review and signature by email to the Part Clerk by 12:00 noon on the day prior to the scheduled for the Conference.

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

Applies to

Proposed conference order

If parties cannot agree on a PCO, CCO, or SCO after good-faith efforts, they must appear in person with a proposed order completed except for the disputed issue.

Parties who are unable to agree on the terms of any Conference Order (PCO, CCO, SCO), despite their good faith efforts to do so, shall appear in-person before the Court on the scheduled conference date with their proposed Conference Order, completed except for the disputed matter, prepared to discuss the issue for the Court’s ruling.

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

Applies to

Esi protocol

When ESI production is disputed, the parties must exchange an ESI protocol.

ESI: If the production of ESI is an issue, the parties shall exchange an ESI protocol (22 NYCRR 202.12[e][3]).

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

Applies to

Papers

All papers must state the motion sequence number whenever one is available.

Motion Sequence Number: All papers shall state the motion sequence number, when available.

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

Applies to

Motion submission

Must include

ai disclosure

Every motion-related submission must include an attorney or self-represented-party certification stating either that no generative AI was used or that the filer reviewed and approved all generated text, with the program, affected documents, and generated portions identified when AI was used; one certification may cover several documents in a party's submission.

Artificial intelligence (AI) programs: All submissions with respect to a motion must include a certification by an attorney (or self-represented party) either that no generative artificial intelligence program was used in the drafting of any affidavit, affirmation, or memorandum of law contained within the submission, or that a generative artificial intelligence program was used but all generated text, including citations, quotations, and legal analysis were reviewed for accuracy and approved by an attorney (or the self-represented party). If the certification states a generative artificial intelligence program was used, the program must be identified and the documents which include matter generated by ===== PAGE 4 ===== the program must be specified along with which parts of the documents were drafted by the program. One certification pertaining to a party’s submission comprised of several such documents shall suffice.

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

Applies to

Pretrial conference materials

The Part Clerk schedules a pretrial conference at which counsel must have settlement authority and be prepared to discuss the listed trial matters.

When a trial is assigned to Justice Waterman-Marshall, the Part Clerk will schedule a Pre-Trial Conference, during which counsel, who must have authority to discuss settlement, SHALL BRING TO THE CONFERENCE AND BE PREPARED TO DISCUSS THE FOLLOWING:

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

Applies to

Joint statement

Counsel must bring a Joint Statement describing the case and identifying the people, places, and institutions likely to be mentioned during trial.

▪ A Joint Statement summarizing the nature of the case, and a list of people, places, and institutions that are likely to be mentioned during the course of the trial, to be read to potential jurors during jury selection;

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

Applies to

Notice of motion

Motions filed by Notice of Motion will not be considered.

Motions made by Notice of Motion will not be considered.

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

Applies to

Stipulation

When an adjournment is granted, counsel must upload a NYSCEF stipulation listing four dates and times when all counsel and parties are available.

If an adjournment request is granted, counsel must upload a stipulation to the New York State Courts Electronic Filing system (“NYSCEF”) listing four (4) dates and times that all counsel and parties are available.

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

Applies to

Motion

Every motion must be filed by Order to Show Cause and must state its motion sequence number on the first page.

All motions must be made by Order to Show Cause and indicate the respective motion sequence number on the first page.

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

Applies to

Preliminary conference order

At least one day before the preliminary conference, counsel or parties must upload a completed and signed matrimonial preliminary conference order and statements of net worth to NYSCEF, along with a child support worksheet and proposed parenting plan when applicable.

At least one (1) day before the preliminary conference, counsel or parties must upload to NYSCEF: (i) a completed and signed matrimonial preliminary conference order; (ii) statements of net worth; and (iii) a child support worksheet and proposed parenting plan (if applicable).

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

Applies to

Proposed preliminary conference order

A hard copy of the proposed preliminary conference order, signed by the parties and counsel, must be provided to the court on the preliminary conference date.

A hard copy of the proposed preliminary conference order signed by the parties and counsel must be provided to the court on the preliminary conference date.

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

Civil cases

Applies to

Proposed jury instructions

Proposed jury instructions must be specifically tailored to the action.

Proposed jury instructions must be specifically tailored to the action.

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

Civil cases

Applies to

Proposed preliminary conference order

After joinder and filing of a preliminary-conference request, the parties must confer about discovery and submit a proposed preliminary conference order through NYSCEF and email.

Within a reasonable time after issue has been joined and a preliminary conference request has been filed, the parties shall meet and confer regarding a preliminary discovery schedule, which shall be memorialized in a Proposed Preliminary Conference Order that shall be presented to the court to be so ordered by filing on NYSCEF and via email to the Part Clerk.

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

Civil cases

Applies to

Summary judgment notice of motion

A summary-judgment movant, except under CPLR 3213, must attach a separate and concise numbered statement of undisputed material facts.

Upon any motion for summary judgment, other than a motion made pursuant to CPLR 3213, the movant shall annex to the notice of motion a separate, short and concise statement, in numbered paragraphs, of the material facts as to which the moving party contends there is no genuine issue to be tried.

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

Civil cases

Applies to

Note of issue

A note of issue should not be filed before discovery is complete.

Note of issue should not be filed unless discovery is complete.

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

Applies to

Motion

Motions must generally be brought by order to show cause unless the court directs otherwise.

All motions shall be made by order to show cause unless otherwise directed by the court.

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

Applies to

Motion

Every motion, opposition, and reply paper must state the motion sequence number and return date on its first page.

All motion papers (including opposition and reply papers) shall state the motion sequence number and return date of the motion on the first page.

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

Applies to

Sur reply

Sur-replies are prohibited unless the court gives prior permission.

Sur-replies are not accepted without prior court permission.

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

Applies to

Ex parte order of protection application

An ex parte order-of-protection application must include the Family Protection Registry Information Sheet, and the litigant must be present.

Ex-parte applications for orders of protection must be accompanied by the Family Protection Registry Information Sheet and the litigant must be present.

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

Applies to

Motion

A motion to consolidate pending Family Court family-offense proceedings must include complete copies of the relevant pleadings and orders with docket numbers.

Motions to consolidate family offense proceedings pending in the Family Court must contain a complete copy of the relevant pleadings and orders (with relevant docket numbers).

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

Applies to

Preliminary conference submission

At the preliminary conference, each party must submit a sworn net-worth statement, recent state and federal tax returns, and the two most recent paycheck stubs.

The following documents shall be submitted at the preliminary conference: (i) each party’s sworn statement of net worth; (ii) the most recently filed state and federal income tax returns; and (iii) each party’s two most recent paycheck stubs.

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

Applies to

Compliance conference schedule

The compliance-conference date must be set during the preliminary conference.

The date of the compliance conference shall be set at the time of the preliminary conference.

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

Applies to

Pretrial submission

Unless there is a pretrial conference, the parties must exchange and file the disposition statement, updated net-worth statement, tax returns, witness list, and exhibit list with pre-marked exhibits at least two weeks before trial.

Parties shall exchange and file with the court the following documents at the pre-trial conference, if any, or at least two weeks prior to the first day of trial if there is no pre-trial conference: (i) statement of proposed disposition; (ii) updated statement of net worth; (iii) most recently filed tax returns; (iv) witness list; and (v) exhibit list (with pre-marked exhibits).

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

Applies to

Proposed parenting plan

For custody-only trials involving no financial issues, the parties must file a proposed parenting plan instead of a statement of proposed disposition and need not file an updated net-worth statement.

If the trial concerns the issue of custody only and involves no financial issues, the parties shall file a proposed parenting plan instead of a statement of proposed disposition, and need not file an updated statement of net worth.

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

Applies to

Trial evidence and witnesses

During direct testimony, counsel may offer only documents previously disclosed on the exhibit list, and only witnesses previously disclosed on the witness list may testify.

As a general rule, no counsel or party will be permitted to offer a document into evidence during a witness’ direct testimony unless the document was disclosed on the previously exchanged exhibit list, and no witness will be permitted to testify unless the witness was disclosed on the previously exchanged witness list.

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

Applies to

Proposed order to show cause

Every proposed Order to Show Cause must provide for service of responsive papers and reserve space for the court to insert the service date.

All proposed orders to show cause shall include a provision for the service of responsive papers, with a space reserved for the date of service, which shall be filled in by the court.

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

Applies to

Reply papers

Reply papers are prohibited in motions or special proceedings initiated by Order to Show Cause unless expressly permitted.

In accordance with Rule 13(b), section IV, of the Rules of the Justices of the New York County Supreme Court, Civil Branch, no reply papers shall be permitted in connection with motions or special proceedings initiated by order to show cause, except by express permission of the

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

Applies to

Notice required by CPLR 8019(c)

Must include

notice of electronic filing

Within 15 days after entry of the so-ordered caption stipulation, a party directed by the court must serve a copy on the Trial Support Office and separately file and upload the CPLR 8019(c) notice on Form EF-22.

After the court “so orders” the stipulation, one of the parties, as will be directed by the court in the so-ordered stipulation, shall, within 15 days of the entry of the so-ordered stipulation, serve a copy of the so-ordered stipulation upon the Trial Support Office (60 Centre Street, Room 148, New York, NY 10007), and shall separately file and upload the notice required by CPLR 8019(c) on a completed Form EF-22, whereupon the Trial Support Office shall thereupon amend the court records accordingly.

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

Applies to

So ordered subpoena request

Every request for a so-ordered subpoena must include a brief statement explaining why the so-order is needed and why the discovery is appropriate.

All requests for a so-ordered subpoena shall be accompanied by a brief statement indicating the need for the subpoena to be so-ordered and why such discovery is appropriate.

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

Applies to

Proposed discovery conference order

The plaintiff must complete the proposed discovery conference order, leave the next-submission and note-of-issue deadline spaces blank, and email the completed order to the part clerk.

The plaintiff shall be responsible for filling out the proposed discovery conference order, leaving blank the spaces provided for the next discovery order submission date and note of issue filing deadline, and emailing the completed proposed discovery order to the Part Clerk.

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

Applies to

Amended model form

A party seeking to depart from the Model Form for good cause must submit the proposed order, a redlined version identifying the departures, and a party affirmation establishing good cause; an amended Model Form without the redlined version and affidavit will not be approved.

if the parties believe there is good cause to depart from the Model Form, they must submit the following: i. The proposed stipulation and order ii. A red-lined version of the proposed stipulation and order, indicating any departures from the Model Form iii. A party affirmation establishing good cause for any proposed departures from the Model Form. Amended Model Forms unaccompanied by the red-lined version and affidavit will not be approved

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

Applies to

Motion to seal or redact

A sealing or redaction motion must identify the proposed categories with specificity in the spreadsheet and legal memorandum; generic categories are inadequate and generally will not establish good cause.

Movant’s proposed categories shall be identified with specificity in the spreadsheet and legal memoranda to facilitate issuance of a workable and efficient order; for instance, vague categories such as “confidential business information” or “proprietary trade information” are not adequate; Page 7 of 8 Revised April 2026 ===== PAGE 8 ===== examples of specifically-identified categories include “third-party borrower personal identifying information,” “pricing terms for international customers,” “investment methodologies,” “capital contribution information of private entities,” and “strategies for structuring, collateralizing, and marketing structured products.” A carefully tailored list of categories incorporated into movant’s spreadsheet that articulate precise categories of information is required. Generic categories generally will not establish the requisite good cause to seal or redact,

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

Civil cases

Applies to

Exhibit

Must include

ai disclosure

An AI-exhibit identification must state, to the extent known, the tool or process, directing person, nature and extent of the AI contribution, and preservation and availability of the original source material.

The identification shall state, to the extent known: the tool or process used; the identity of the person who directed its use; the nature and extent of the AI contribution; and whether the original, unaltered source material has been preserved and is available for inspection.

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

Civil cases

Applies to

Matrimonial preliminary conference order

Must include

proposed order

At least two days before the preliminary conference, counsel must upload a completed and signed Matrimonial Preliminary Conference Order to NYSCEF.

At least two (2) days prior to the preliminary conference, counsel must upload to NYSCEF: (1) a completed and signed Matrimonial Preliminary Conference Order; (2)

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

Civil cases

Applies to

Statement of net worth

The Court will not conduct a substantive preliminary conference unless each party has filed a complete Statement of Net Worth.

A meaningful and productive preliminary conference cannot take place without a complete Statement of Net Worth from each party, and the Court will not conduct a substantive preliminary conference in the absence of same.

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

Civil cases

Applies to

Proposed order

At least one day before the compliance conference, the parties must upload a jointly completed proposed Compliance Conference Order through NYSCEF.

At least one (1) day prior to a compliance conference, the parties shall upload to NYSCEF a jointly completed proposed Compliance Conference Order.

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

Civil cases

Applies to

Settlement conference submission

At least two days before a settlement conference, each party must email the Court an updated Statement of Net Worth, a marital-property and proposed-distribution list, and a two-page-maximum statement of position rationale.

At least two (2) days prior to the conference, each party shall e-mail the Court an updated Statement of Net Worth, a list of all marital property and proposed distribution, and a statement of no more than two pages setting forth the rationale for their position.

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

Civil cases

Applies to

Note of issue

A Note of Issue is mandatory before the pre-trial conference.

A Note of Issue must be filed before the pre-trial conference.

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

Civil cases

Applies to

Pre trial submission

At least one week before the pre-trial conference, the parties must file through NYSCEF and exchange the listed pretrial submissions, including financial documents, witness and exhibit lists, expert reports, marked pleadings, and memoranda.

At least one (1) week prior to the pre-trial conference, the parties shall file via NYSCEF and exchange: a statement of proposed disposition; an updated Statement of Net Worth; the parties' most recently filed tax returns; a child support worksheet (if applicable); a proposed maintenance worksheet, where applicable; a witness list with a meaningful offer of proof for each witness; an exhibit list (with pre-marked exhibits); any expert reports not previously exchanged; marked pleadings; and any pre-trial memoranda.

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

Civil cases

Applies to

Motion

Every specified type of motion paper must state its motion sequence number on the first page.

All motion papers, including the Order to Show Cause, opposition, reply, memoranda of law, exhibits, affirmations, affidavits, and proposed orders of settlement, must state the motion sequence number on the first page.

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

Civil cases

Applies to

Financial relief motion

A financial-relief motion filed after the preliminary conference must include an updated Statement of Net Worth.

Motions seeking financial relief, filed after the preliminary conference, must include an updated Statement of Net Worth.

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

Civil cases

Applies to

Motion

Each motion must include a table of contents identifying every attached exhibit.

Each motion shall include a table of contents listing each exhibit attached to the motion.

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

Civil cases

Applies to

Emergency order to show cause

An emergency Order to Show Cause must include the required affirmation or affidavit of emergency or may be declined.

Any motion entitled an “emergency” Order to Show Cause must be accompanied by an affirmation or affidavit of emergency pursuant to 22 NYCRR § 202.7 and 202.8 and the CPLR, or the motion may be declined.

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

Civil cases

Applies to

Ex parte order of protection application

An ex parte order-of-protection application must include the Family Protection Registry Information Sheet, and the requesting litigant must attend.

Ex parte applications for orders of protection must be accompanied by the Family Protection Registry Information Sheet, and the litigant seeking protection must be present.

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

Civil cases

Applies to

Paper

An attorney or party using AI to prepare a filed, submitted, or served paper must carefully review it, ensure it contains no fabricated material, and certify that review by signing.

Accordingly, any attorney or party who uses an artificial intelligence tool, as defined in 22 NYCRR 161.2(a), in preparing any paper, as defined in 22 NYCRR 161.2(b), filed in or submitted to this Court or served on another party in a case before this Court is required to carefully review the paper and independently ensure that it contains no fabricated or fictitious cases, statutes, or other material. By signing such paper, an attorney or party certifies that such a review has been conducted and that the paper contains no such fabricated or fictitious content.

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

Civil cases

Applies to

Motion submission

Must include

ai disclosure

Every motion submission must include an attorney or self-represented party's certification either that generative AI was not used for the included papers or that all generated text was reviewed for accuracy and approved.

In addition to the foregoing, all submissions with respect to a motion must include a certification by an attorney (or self-represented party) either that no generative artificial intelligence program was used in the drafting of any affidavit, affirmation, or memorandum of law contained within the submission, or that a generative artificial intelligence program was used but that all generated text, including citations, quotations, and legal analysis, was reviewed for accuracy and approved by an attorney (or the self-represented party).

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

Civil cases

Applies to

Exhibit

Must include

ai disclosure

A party must identify any AI-created or materially AI-altered exhibit offered at trial, a hearing, or in support of or opposition to a motion.

Any party intending to offer at trial, at a hearing, or in support of or in opposition to a motion any exhibit that was, in whole or in material part, created, generated, enhanced, restored, upscaled, translated, transcribed, or otherwise materially altered by an AI tool shall so identify the exhibit.

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

Civil cases

Applies to

Expert disclosure or report

Must include

ai disclosure

An expert disclosure or report must identify any AI tool used in forming the opinion and describe its role in the methodology sufficiently to permit an examination of reliability.

Where an expert, forensic evaluator, or appraiser has used an AI tool in forming any opinion disclosed pursuant to CPLR 3101(d) or in preparing any report submitted to this Court, the disclosure or report shall identify the tool and describe its role in the methodology employed with sufficient particularity to permit examination of its reliability.

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

Civil cases

Applies to

Papers

A self-represented party remains responsible for every filing regardless of whether AI tools were used to prepare it.

You are responsible for everything you file, whether or not you used an AI tool to prepare it.

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

Civil cases

Applies to

Response

A response to suspected fabricated authority must address the authority's existence, the paper's preparation and review process, and corrective action taken.

The response shall address whether the cited authority or material exists; the process by which the paper was prepared and reviewed; and any corrective action taken, including notice to the client and to opposing counsel and any amended or withdrawn filing.

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

Civil cases

Applies to

Trial exhibits

A document may be offered during direct examination only if it appeared on the previously exchanged exhibit list, and a witness may testify only if disclosed on the previously exchanged witness list.

No counsel or party will be permitted to offer a document into evidence during a witness's direct testimony unless the document was disclosed on the previously exchanged exhibit list, and no witness will be permitted to testify unless disclosed on the previously exchanged witness list.

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

Civil cases

Applies to

Audio or video evidence

Counsel or a party intending to offer audio or video evidence must give the Court at least one week's notice.

If counsel or a party intends to offer audio or video evidence, the Court must be given at least one week's notice.

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

Civil cases

Applies to

Audio video evidence

Must include

ai disclosure

Audio or video evidence created or altered by an artificial intelligence tool must be identified under the Rules' artificial-intelligence provisions.

Any audio or video evidence that was created or altered by an artificial intelligence tool must additionally be identified in accordance with the ARTIFICIAL INTELLIGENCE (AI) PROGRAMS section of these Rules.

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

Civil cases

Applies to

Proposed findings conclusions

Counsel must submit proposed Findings of Fact and Conclusions of Law at the conclusion of trial.

At the conclusion of trial, counsel shall submit proposed Findings of Fact and Conclusions of Law and an updated spreadsheet listing each item of marital property with its value and proposed distribution as established at trial.

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

Applies to

Motion

Motions must be filed as an Order to Show Cause rather than by Notice of Motion.

All motions shall be filed by Order to Show Cause, not by Notice of Motion.

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

Applies to

Order to show cause

An Order to Show Cause seeking interim relief must clearly identify that relief in its body.

If the moving party is seeking interim relief, that must be clear in the body of the Order to Show Cause.

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

Applies to

Temporary restraining order motion

A movant seeking a temporary restraining order must clearly state the reasons under MHL § 81.23(b).

If a temporary restraining order is sought, the movant must clearly set forth the reasons why pursuant to MHL § 81.23(b) and if no prior notice was given, specify why notice should not be required pursuant to Uniform Rule 202.7(f).

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

Applies to

Conference call request

A matrimonial conference-call request must state the reason for the request and the available times for the call.

Requests for conference calls with the court in matrimonial cases shall be made by email to lantonci@nycourts.gov, with notice to all counsel, and indicate the reason for the request and available times for the call.

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

Applies to

Virtual trial request

A request for a virtual hearing must set forth the basis for the request.

Counsel is to make application to the court for a virtual hearing by emailing a one-page request to lantonci@nycourts, which sets forth the basis for the request.

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

Applies to

Pretrial submission

Pre-marked exhibits, final witness lists, a brief offer of proof, and an estimated length of testimony must be submitted at least 14 days before the Virtual Court pretrial conference unless the court orders otherwise.

All pre-marked exhibits and final witness lists, including a brief offer of proof and estimated length of testimony, must be submitted to the court at least 14 days before the date set for Virtual Court pre-trial conference (see IDV Virtual Court Rules) unless otherwise ordered.

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

Applies to

Written summation

Family and matrimonial cases require a written summation containing a memorandum of law and, when applicable, a proposed parenting plan and other relevant supporting legal materials unless the court directs otherwise.

Unless otherwise directed by the court, a written summation is required in all family/matrimonial cases which will include a memorandum of law and a proposed parenting plan, if applicable, and/or statutes, cases, opinions and other relevant materials to be relied upon to support a party’s claims, defenses and arguments.

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

Applies to

Qualified domestic relations order

A Qualified Domestic Relations Order not submitted with the JOD must be accompanied by a written plan of approval.

All Qualified Domestic Relations Orders not submitted with the JOD must be submitted within 45 days of the signing of the JOD and must be accompanied by written plan of approval.

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

Applies to

Child support worksheet

A child-support worksheet and proposed parenting plan must be uploaded when applicable.

Child support worksheet and proposed parenting plan, where applicable.

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

Applies to

Settlement conference submission

The required Settlement Conference submission includes an updated net-worth statement, marital property and distribution list, applicable proposed custody and parenting plan, and a rationale statement of no more than two pages.

An updated Statement of Net Worth; A list of all marital property and proposed distribution; A proposed custody and parenting time plan, where applicable; and A short statement no more than two pages in length setting forth the rationale for their position.

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

Applies to

Motion

Every motion must be initiated by Order to Show Cause, and motions brought by Notice of Motion will not be considered.

All motions SHALL be brought by Order to Show Cause (OSC). Motions made by Notice of Motion will not be considered.

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

Applies to

Ex parte order of protection application

An ex parte order-of-protection application must include the Family Protection Registry Information Sheet, and the litigant must be present.

Ex-parte applications for orders of protection must be accompanied by the Family Protection Registry Information Sheet and the litigant must be present.

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

Applies to

Consolidation motion

A motion to consolidate pending Family Court family-offense proceedings must include complete copies of the relevant pleadings and orders with their docket numbers.

Motions to consolidate family offense proceedings pending in the Family Court must include a complete copy of the relevant pleadings and orders (with relevant docket numbers).

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

Applies to

Motion submission

Must include

ai disclosure

Every motion-related submission must include an attorney or self-represented party's certification stating either that no generative AI was used or that all generated material was reviewed and approved.

All submissions with respect to a motion must included a certification by an attorney, or self- represented party, either that no generative artificial intelligence program was used in the drafting of any affidavit, affirmation or memorandum of law contained within the submission, or that a generative artificial intelligence program was used but that all generated text, including citations, quotations and legal analysis was reviewed for accuracy and approved by an attorney, or the self- represented party.

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

Applies to

Ai certification

Must include

ai disclosure

An AI-use certification must identify the program, the documents containing generated material, and the portions drafted by the program.

If the certification states that a generative artificial intelligence program was used, the program must be identified and the documents which include matter generated by the program must be specified along with which parts of the documents were drafted by the program.

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

Civil cases

Applies to

Letter

When a good-faith discovery dispute remains unresolved and no other conference has been set, the parties may request a conference by filing a NYSCEF letter outlining the issues and each party's position.

If the parties have a dispute that they are unable to resolve despite good faith efforts to do so – if another conference is not set forth in a prior conference or discovery order or decision on a motion – they may request a conference with the Court via written letter filed on NYSCEF outlining the issue(s) and the parties’ positions.

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

Civil cases

Applies to

Deposition testimony reference

References to deposition testimony must cite the exact page and line numbers relied upon and may not merely attach the entire transcript or relevant portions.

any reference to deposition testimony must cite to the exact page and line numbers relied upon rather than merely attaching the entire transcript or “relevant portions”.

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

Civil cases

Applies to

Exhibits

Exhibits must be uploaded in accordance with the E-Filing Protocol.

Consult the E-Filing Protocol when uploading exhibits.

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

Civil cases

Applies to

Exhibit reference

References to exhibits must include pinpoint citations identifying the exact location within the exhibit.

Reference to any exhibit must include pinpoint citations so the exact location within the exhibit can be found easily.

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

Civil cases

Applies to

Proposed order

A proposed Preliminary Conference Order must leave the Compliance Conference date and Note of Issue filing deadline spaces blank.

The proposed PCO must leave blank the spaces for the Compliance Conference date and Note of Issue filing deadline.

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

Civil cases

Applies to

Proposed order

A proposed Compliance Conference Order must leave the Status Conference date and Note of Issue filing deadline spaces blank.

The proposed CCO must leave blank the spaces for the Status Conference date and Note of Issue filing deadline.

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

Civil cases

Applies to

Motion

A party requesting oral argument should place the words “Oral Argument Requested” next to the caption in its motion or opposition papers.

If oral argument is requested, the requesting party should include “Oral Argument Requested” next to the caption in the moving / opposing papers.

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

Applies to

Motion

Must include

proposed order

A proposed order should accompany each motion submitted for decision as its final attachment.

Each motion submitted for decision should include a proposed order as the final attachment to the motion.

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

Applies to

Summary judgment motion

Discovery ordinarily continues while a summary judgment motion is pending unless good cause supports a stay.

Absent good cause, discovery between the parties shall continue while a motion for summary judgment is pending.

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

Applies to

Letter

A request to stay discovery during a pending summary judgment motion must be made by email letter stating the motion’s filing date and sequence number and briefly explaining the reasons for the stay.

A party wishing a stay of discovery must request a conference with the Court by letter. The letter is to be submitted by email and include when the summary judgment motion was filed, the sequence number of the motion, and briefly state the reasons why discovery should be stayed.

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

Civil cases

Applies to

Letter

An oral-argument request letter should identify the attorney and the portion of the motion that attorney will argue.

The letter should identify the attorney and the portion of the motion that such attorney will argue.

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

Civil cases

Applies to

Trial memorandum

The trial memorandum must state the party’s position, relevant factual and legal issues, cite relevant case law, and include causes of action and any affirmative defenses or counterclaims.

A trial memorandum, not to exceed two (2) pages, setting forth the party’s position and relevant factual and legal issues to be tried citing relevant case law and including causes of action, and any affirmative defenses and/or counterclaims.

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

Civil cases

Applies to

Stipulation of undisputed facts

For non-jury trials, the parties must provide a stipulation listing all undisputed or agreed-upon facts.

For non-jury trials, a stipulation as to all undisputed/agreed upon facts.

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

Applies to

Oral argument request

Oral argument is ordinarily held in person on Tuesdays; a party must submit a letter to the Part 37 Clerk copying all parties to request oral argument when the Court has not scheduled it.

Oral argument on motions will be held on Tuesdays IN PERSON unless otherwise indicated. Not all motions will be scheduled for oral argument. If the Court has not scheduled a motion for oral argument and a party wishes to request oral argument, they must submit a letter to the Part 37 Clerk, copying all parties on the matter. If after reviewing the request, the Court determines that oral argument is warranted, the parties will be notified of an oral argument date. Motions submitted on default or without opposition are generally not scheduled for oral argument.

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

Applies to

Pretrial conference

After trial assignment, the Court will schedule a pretrial conference, and parties must be prepared to discuss liability, damages, dispositive decisions, settlement efforts, anticipated rulings, witnesses, interpreters, and accommodations.

Once a trial is assigned to Part 37, the Court shall schedule a Pre- Trial Conference. Parties must be prepared to discuss the case fully, including: their position on liability and damages; prior dispositive decisions; any and all settlement attempts; anticipated pre-trial rulings; the number of witnesses and whether language interpreters or special accommodations will be needed.

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

Civil cases

Applies to

Deposition transcript

Each deposition transcript must be a separate, labeled exhibit, and all transcripts must be accompanied by a word index.

Each deposition transcript shall be submitted as a separate exhibit. Parties shall include a word index with all transcripts. Deposition transcripts shall be labeled to indicate both their exhibit number/letter and to identify the deposed individual.

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

Civil cases

Applies to

Motion

References to other voluminous exhibits must include pinpoint citations.

Any reference to any other voluminous exhibit annexed to a motion must include pinpoint citations.

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

Civil cases

Applies to

Attorney business cards

The parties must provide two business cards for every attorney.

Two business cards for each attorney;

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

Civil cases

Applies to

Courtroom technology list

The parties must identify and timely arrange for all courtroom technology, demonstratives, and other trial aids to be used by the party or parties using them, as early before trial as feasible and as convenient for the court.

A list of all proposed courtroom technology, demonstratives, etc., e.g., computers, screens, and other demonstrative aids, to be used at trial as furnished by the party or parties that will use the technology, and to be set up timely and as far in advance of the start of trial as is feasible under the circumstances and at the convenience of the court; and

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

Civil cases

Applies to

Stipulation or preliminary conference order

When all parties attend a conference, a stipulation or preliminary conference order should be completed with discovery-completion dates.

When all parties are present, please complete a stipulation or preliminary conference order with dates for completing discovery.

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

Civil cases

Applies to

Conference order

The submitted order should propose the next conference date and, when necessary, an extension of the note-of-issue deadline.

4. The order as submitted to the court should include a proposed date for the next conference and, if necessary, a proposed extension of the note-of-issue deadline.

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

Civil cases

Applies to

Jury instructions

Proposed jury instructions copied verbatim from the Pattern Jury Instructions need only cite the corresponding PJI section numbers.

If the proposed jury instructions are taken verbatim from the Pattern Jury Instructions, PJI section numbers suffice.

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

Applies to

Confidentiality agreement

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

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

Applies to

Joint statement of material facts

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.

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

Civil cases

Applies to

Exhibits

Parties should pre-mark proposed exhibits as JX-#, PX-#, or DX-# and agree to joint exhibits (JX) when possible.

Any proposed exhibits should be pre-marked (JX-#; PX-#, or DX-#) and the parties should agree to joint exhibits (JX) to the extent possible.

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

Civil cases

Applies to

Exhibits

A flashdrive containing the proposed exhibits should be delivered to the Part Clerk in Courtroom 208.

Please have a flashdrive containing the proposed exhibits delivered to the Part Clerk in Courtroom 208.

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

Civil cases

Applies to

Proposed jury instructions

The proposed jury instructions should include the text of the relevant PJI instructions.

Proposed jury instructions, including the text of relevant PJI instructions, should be submitted by email to Chambers (sfc-part3@nycourts.gov) in Word format.

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

Civil cases

Applies to

Proposed jury instructions

Proposed jury instructions should identify the instructions to which the parties have stipulated.

The submissions should note the instructions to which the parties have stipulated.

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

Civil cases

Applies to

Proposed jury instructions

Proposed deviations from PJI instructions should be highlighted and explained, with citations to legal authority where appropriate.

Any proposed deviations from PJI instructions should be highlighted and explained, with citations to legal authority where appropriate.

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

Civil cases

Applies to

Exhibits

Unobjected joint exhibits should be designated with the prefix JX followed by the exhibit number.

Joint exhibits (as to which there is no objection to admissibility) should be designated by JX followed by the number of the exhibit.

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

Civil cases

Applies to

Post trial brief

In a bench trial, the Court generally will not consider evidence first offered in post-trial briefs absent special circumstances.

In bench trial, the Court will only consider evidence that is raised or introduced during the trial itself. Absent special circumstances, evidence offered for the first time in post-trial briefs will not be considered.

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

Civil cases

Applies to

Flash drive

Flash drives should be marked with the case's short caption and index number.

Flash drives should be marked with the short caption and index number of the case.

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

Civil cases

Applies to

Post trial brief

Initial post-trial briefs should provide proposed conclusions of law separately for each claim, counterclaim, crossclaim, and third-party claim.

iii. Proposed Conclusions of Law, separately for each cause of action (claim, counterclaim, crossclaim, and third-party claim)

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

Civil cases

Applies to

Proposed jury instructions

For fact-specific PJI additions, include the full instruction and proposed case-specific language; for unmodified PJI sections, reference the section number and title.

Where a proposed PJI section requires fact-specific additions, please include the full text of the instruction along with the proposed case-specific language. When using PJI sections without any modification, please simply reference the PJI section by number and title.

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

Applies to

Pretrial stipulation

Before the pretrial conference, the parties must attempt to execute a stipulation addressing exhibit authenticity and admissibility and undisputed facts.

Prior to the pre-trial conference, the parties shall attempt to execute a stipulation as to: (i) the authenticity and admissibility of exhibits; and (ii) undisputed facts.

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

Applies to

Motion to be relieved as counsel

A motion to be relieved as counsel should be made by Order to Show Cause.

Motions to be relieved as counsel should be made by Order to Show Cause.

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

Applies to

Preliminary conference order

Failure to serve the bill of particulars does not bar preparation of a court-directed preliminary conference order, but the order must then specify a bill-of-particulars service deadline.

If the court directs the parties to submit a proposed preliminary conference order, it shall not be an objection to the preparation and submission of such order that the plaintiff has yet to serve a bill of particulars. If that is the case, the preliminary conference order shall specify a deadline for the service of the bill of particulars.

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

Applies to

Confidential information order

Any order governing the confidential exchange of information must follow the court’s Model Form.

In the interest of reducing unnecessary litigation costs, any order regarding the confidential exchange of information must adhere to the Proposed Stipulation and Order for the Production and Exchange of Confidential Information (“the Model Form”).

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

Civil cases

Applies to

Proposed parenting plan

For a custody-only trial without financial issues, the parties must file a proposed parenting plan and need not file an updated Statement of Net Worth.

If the trial concerns custody only with no financial issues, the parties shall instead file a proposed parenting plan and need not file an updated Statement of Net Worth.

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

Civil cases

Applies to

Proposed parenting plan

Attorneys for children may file a proposed parenting plan and must exchange witness and exhibit lists.

Attorneys for children may file a proposed parenting plan and shall exchange witness and exhibit lists.

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

Civil cases

Applies to

Pretrial stipulation

Before the pre-trial conference, the parties must attempt to execute a stipulation addressing exhibit authenticity, admissibility, and undisputed facts.

Prior to the pre-trial conference, the parties shall attempt to execute a stipulation as to the authenticity and admissibility of exhibits and as to undisputed facts not in dispute.

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

Civil cases

Applies to

Cited authority

If the Court directs it, an attorney or self-represented party must produce cited authorities and pinpoint references within five business days.

The Court may, on its own motion or on application of any party, direct any attorney or self- represented party to furnish within five (5) business days a copy of any authority cited in a paper, together with a pinpoint reference to the page or paragraph supporting the proposition for which it is cited.

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

Applies to

Preliminary conference order

Wherever possible, the Preliminary Conference Order should use dates certain instead of indefinite deadlines.

In filling out the PC Order, wherever possible, dates certain, such as “by/on December 31, 2025” shall be used.

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

Applies to

Preliminary conference order

Each inapplicable section of the Preliminary Conference Order must state “N/A.”

Any section of the PC Order that is inapplicable to the matter must include “N/A.”

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

Applies to

Compliance conference order

The proposed Compliance Conference Order should address outstanding discovery issues, and failure to do so may constitute waiver of those issues.

The proposed Compliance Conference Order should address any outstanding discovery issues and the failure to do so may be deemed a waiver of same.

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

Applies to

Pretrial stipulation

Before the Pre-Trial Conference, the parties must attempt to execute a stipulation addressing exhibit authenticity and admissibility and undisputed facts.

Prior to the PTC, the parties shall attempt to execute a stipulation as to: The authenticity and admissibility of exhibits; and ===== PAGE 4 ===== Undisputed facts.

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

Applies to

Motion

The motion sequence number and return date should appear on the first page of each motion submission.

Motion papers should include: o the motion sequence number and return date of the motion on the first page of each submission;

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

Applies to

Motion

A motion's table of contents should list each attached exhibit, and in non-NYSCEF cases the exhibits should be tabbed.

table of contents, which should contain a list of each exhibit attached to the motion and, for non-NYSCEF cases, the exhibits should be marked by tabs;

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

Civil cases

Applies to

Oral argument request letter

Motions are ordinarily decided on submission, and any party may request oral argument by e-filing a letter before submitting the motion.

Motions will be decided on submission unless otherwise directed. Any party can request oral argument by e-filing a letter. Such a request should be made prior to the submission of the motion.

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

Civil cases

Applies to

Conference form

Parties are strongly encouraged, but not required, to complete the conference form together before the conference and bring it for review.

You are strongly encouraged to complete the conference form with all parties prior to your scheduled conference time and bring a copy with you to the appearance for review.

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

Civil cases

Applies to

Exhibits

Parties are strongly encouraged to have the court stenographer premark all exhibits when there is no objection.

Parties are strongly encouraged to have the court stenographer premark all exhibits for identification or evidence if without objection.

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

Civil cases

Applies to

Jury instructions

Parties should use the most recent Pattern Jury Instructions edition when proposing jury instructions.

To avoid confusion or miscommunication among the court and counsel, the parties should work from the most recent PJI edition when proposing jury instructions.

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

Civil cases

Applies to

Post trial brief

The initial post-trial briefs may include a preliminary statement.

i. Preliminary Statement (optional)

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

Applies to

Proposed order

Counsel are strongly encouraged, but not required, to submit a proposed default judgment order explaining the basis for granting relief or denying an opposed motion.

Default Judgment Motions: Counsel are strongly encouraged to submit a proposed Order setting forth the basis for the Court to grant a default judgment (noting the type and timing of service, referencing dispositive documents, etc.) and/or the basis to deny such relief where the motion is opposed.

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

Civil cases

The AI-disclosure rules do not apply to listed routine, non-substantive technical processes that do not alter substantive content.

This section does not apply to routine, non-substantive technical processes that do not alter substantive content, including optical character recognition, file format conversion, spell- check and grammar tools, standard litigation-support redaction and Bates labeling, or ordinary technology-assisted review in discovery.

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

Civil cases

Applies to

Motion ?

Must include

certificate of service ?

All movants must make certain that an affidavit of service is filed via NYSCEF.

Summary: Every movant must file an affidavit of service through NYSCEF.

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

Applies to

Pro hac vice affirmation ?

The affirmation must also disclose whether the applicant has ever been, or is presently, subject to disciplinary proceedings.

Summary: The pro hac vice supporting affirmation must disclose whether the applicant has ever been or is presently subject to disciplinary proceedings.

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

Civil cases

Applies to

Modified pji ?

If any changes to the PJI are suggested, counsel must submit the full text with all proposed changes red-lined in Word format by email to Justice Lantry’s law clerks.

Summary: Counsel proposing PJI changes must submit the full text of the proposed changes rather than relying solely on a PJI citation.

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

Applies to

Discovery motion ?

Must include

local rule certificate ?

Parties filing motions relating to discovery must include a separate good faith affirmation (22 NYCRR 202.7). The affirmation must include the times and dates the parties conferred in person, virtually, or by telephone, to resolve the discovery dispute.

Summary: A discovery motion must include a separate good-faith affidavit stating when and how the parties conferred to resolve the dispute.

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

Civil cases

Applies to

Order to show cause

Any motion to vacate such a default must be brought by Order to Show Cause and must fulfill the requirements of CPLR § 5015.

Summary: A motion to vacate a default resulting from failure to appear at a DCM conference must be brought by Order to Show Cause and comply with CPLR § 5015.

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

Civil cases

Applies to

Motion

Motion sequence numbers shall be included on the front page of all notices of motion/cross-motion, affirmations in support or opposition and reply papers, and any ===== PAGE 4 ===== stipulations or letters relating to a motion, otherwise they may not be considered to be a part of the motion.

Summary: Motion sequence numbers must appear on the front page of all motion notices, cross-motion notices, supporting or opposing affidavits, reply papers, stipulations, and motion-related letters, or those documents may not be treated as part of the motion.

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

Civil cases

Applies to

Proposed witness list ?

A list of proposed witnesses (including the need for any interpreters or other accommodation), the dates of availability of each witness, and the expected length of time of direct examination for each witness.

Summary: At the first appearance, each party must provide a proposed-witness list including accommodations, witness availability dates, and expected direct-examination lengths.

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

Applies to

Proposed order

Must include

proposed order

Proposed orders must be signed by all parties, submitted as an attachment to an email and sent to sfc-part37-clerk@nycourts.gov with all parties cc’d on the email. Ex-parte emails are not permitted and will not receive a response.

Summary: A proposed conference order must be signed by every party and emailed as an attachment to the Part Clerk with all parties copied; ex parte emails are prohibited.

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

Applies to

Discovery motion

The discovery motions filed must include a copy of the letter/email/correspondence to the Court.

Summary: A discovery motion must include a copy of the parties' conference letter, email, or other correspondence with the Court.

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

Applies to

Paper

Must include

ai disclosure ?

Any attorney or party who uses a generative AI tool, as defined in 22 NYCRR 161.2(b), in preparing any paper, as defined in 22 NYCRR 161.2(c), filed in or submitted to this court or served on another party in a case before this court is required to carefully review the paper and independently ensure that it contains no fabricated or fictitious cases, statutes, or other material. By signing such paper, an attorney or party certifies that such a review has been conducted and that the paper contains no such fabricated or fictitious content.

Summary: An attorney or party using a generative AI tool must review the resulting paper and certify by signing that it contains no fabricated or fictitious material.

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

Applies to

Summary judgment motion ?

Pursuant to 22 NYCRR 202.8-g(e), a movant’s failure to submit an undisputed statement of facts will result in the denial of the motion with leave to renew upon proper papers, adjournment of the motion to allow the movant time to submit an undisputed statement of facts, or any other action this Court deems just and proper.

Summary: Failure to submit the required undisputed statement of facts may result in denial with leave to renew, an adjournment, or another action the court deems proper.

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

Applies to

Discovery motion ?

If such a motion is filed, the affirmation of good faith submitted in support of the same must “indicate the time, place and nature of the consultation and the issues discussed and any resolutions, or shall indicate good cause why no such conferral with counsel for opposing parties was held” (22 NYCRR 202.7[c]). The affirmation of good faith must also indicate the identity of the individual who conferenced the case with the parties (i.e., Justice Cohen or which of his Law Clerks), as well as the date on which the case was conferenced by the court.

Summary: A discovery motion must be supported by an affirmation describing the consultation and identifying the court conference participant and date, or stating good cause for no conferral.

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

Civil cases

Applies to

Motion papers ?

You may not file omnibus affidavits, affirmations, memoranda of law, etc. Do not submit papers intended to be applicable to multiple motions (e.g., a party submitting the same affirmation in motion seq. nos. 001–003 must file it once in each sequence number, labeling each accordingly). Exhibits are exempt if you hyperlink any citation to such a document. The court strongly prefers that only one copy of any given exhibit be filed to NYSCEF.

Summary: Omnibus papers may not be filed for multiple motions, and any repeated paper must be filed separately in each motion sequence with an appropriate label.

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

Civil cases

Applies to

Affirmation

All substantive legal arguments, including references to statutes and case law, shall be made in memoranda of law, only, which shall be filed separately from any affirmations or affidavits. Legal arguments are not to be included in affirmations. Do not cite cases in affirmations. Instead, file a memorandum of law.

Summary: Substantive legal arguments and case citations must be presented in a separately filed memorandum of law, not in an affirmation or affidavit.

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

Civil cases

Applies to

Pro hac vice application ?

Must include

proposed order

Each application must include, in separate PDFs: (1) an affidavit of support from a member of the Bar of the State of New York; (2) an affidavit from the applicant; (3) a recent certificate of good standing from the applicant; and, (4) a proposed order.

Summary: Each pro hac vice application must include separate PDFs containing a supporting attorney affidavit, an applicant affidavit, a recent certificate of good standing, and a proposed order.

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

Civil cases

Applies to

Discontinuance application ?

Applications to discontinue requiring an order of the court must be made by motion on notice (see CPLR 3217[b][2]).

Summary: An application to discontinue that requires a court order must be made by a motion on notice.

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

Civil cases

Applies to

Marked pleadings

All marked pleadings and bills of particulars;

Summary: The parties must provide all marked pleadings.

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

Civil cases

Applies to

Prior decisions

All prior decisions in the case, including any appellate decisions;

Summary: The parties must provide all prior trial-court decisions and any appellate decisions in the case.

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

Civil cases

Applies to

Notices to admit

Any notices to admit;

Summary: The parties must provide any notices to admit.

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

Civil cases

Applies to

Ebt transcripts

Copies of EBT transcripts intended for use at trial for any purpose;

Summary: The parties must provide copies of EBT transcripts intended for any trial use.

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

Civil cases

Applies to

Proposed jury instructions and verdict sheet

Proposed jury instructions and verdict sheet.

Summary: For jury trials, the parties must provide proposed jury instructions and a proposed verdict sheet.

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

Civil cases

Applies to

In limine or other application ?

Any such motion or application must include citations to relevant authorities.

Summary: Every in limine motion or other pretrial application must include citations to relevant authorities.

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

Civil cases

Applies to

Certificate of readiness and note of issue

Must include

local rule certificate ?

You are not to file the certificate of readiness and note of issue without first filing a stipulation, or receiving an order, as to that all discovery is complete.

Summary: A certificate of readiness and note of issue may not be filed until the party files a stipulation or obtains an order stating that discovery is complete.

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

Civil cases

Applies to

Motion

Must include

proposed order ?

If a motion is resolved after it is fully submitted, the movant shall immediately inform the court by filing and emailing to the part clerk a stipulation withdrawing the motion.

Summary: If a fully submitted motion is resolved, the movant must immediately file and email the part clerk a stipulation withdrawing the motion.

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

Civil cases

Applies to

Deposition transcript

Must include

exhibit list ?

Each deposition transcript shall be submitted as a separate exhibit. Parties shall include a word index with all transcripts. Deposition transcripts shall be labeled to indicate both their exhibit number/letter and to identify the deposed individual.

Summary: Each deposition transcript must be a separate labeled exhibit, accompanied by a word index identifying the deposed individual.

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

Civil cases

Applies to

Notice of motion

Must include

local rule certificate ?

All applications for admission pro hac vice shall be made by notice of motion. The motion shall include an affidavit of support from a member of the Bar of the State of New York, an affidavit from the applicant, and a recent certificate of good standing from the applicant.

Summary: A pro hac vice admission application must be made by motion and include a supporting affidavit from a New York Bar member, an applicant affidavit, and a recent certificate of good standing.

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

Civil cases

Applies to

Motion ?

Citation to deposition testimony must include notation of page and line number in transcript.

Summary: Citations to deposition testimony must identify the transcript page and line numbers.

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

Civil cases

Applies to

Exhibit

All e-filed exhibits must be described in the exhibit’s docket entry (e.g., Exhibit A, Bill of Particulars; Exhibit B, Photographs) to allow the court to ascertain what document is filed in the exhibit.

Summary: The NYSCEF docket entry for every e-filed exhibit must describe the document contained in the exhibit.

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

Civil cases

Applies to

Affirmation in support

Counsel’s affirmation in support must include the note of issue filing date.

Summary: Counsel’s summary-judgment support affirmation must state the note-of-issue filing date.

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

Civil cases

Applies to

Affirmation in support

If the court has set a motion deadline longer than 60 days after the note of issue, or granted an extension of a 60-day deadline, counsel’s affirmation in support must include the governing motion deadline and state when the court set a longer deadline or granted an extension.

Summary: When a later summary-judgment deadline has been ordered or an extension granted, the support affirmation must state the governing deadline and when the court set or extended it.

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

Civil cases

Applies to

Preliminary conference form

Must include

caption, judge name, page count +8 more ?

2. In a Preliminary Conference form, all items must be completed or marked “n/a” if not applicable.

Summary: Every item on a Preliminary Conference form must be completed or marked “n/a” when inapplicable.

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

Applies to

Motion ?

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.

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

Applies to

Affidavit

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.

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

Applies to

Transcript stipulation ?

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.

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

Applies to

Pretrial submission ?

(a) marked pleadings

Summary: Pretrial submissions must include marked pleadings.

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

Applies to

Pretrial submission ?

(b) pretrial memoranda

Summary: Pretrial submissions must include pretrial memoranda.

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

Applies to

Pretrial submission ?

(d) expert reports

Summary: Pretrial submissions must include expert reports.

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

Applies to

Pretrial submission ?

(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.

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

Applies to

Requests to charge

(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.

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

Applies to

Pretrial submission ?

(h) a proposed verdict sheet

Summary: Pretrial submissions must include a proposed verdict sheet.

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

Applies to

Pretrial submission ?

(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.

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

Civil cases

Applies to

Memorandum of law

C. Memoranda of Law. All motion papers (in support, opposition, and reply), whether by notice of motion or order to show case, must include a Memorandum of Law, subject to the word limits set forth in Commercial Division Rule 17. Wholesale incorporation by reference of an affidavit or other evidentiary material is not a substitute for including a Statement of Facts (with citations to the record) in the Memorandum of Law. Affidavits or Affirmations of counsel containing legal argument should not be submitted.

Summary: All supporting, opposition, and reply motion papers must include a Memorandum of Law with a cited Statement of Facts rather than incorporating evidentiary material by reference.

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

Civil cases

Applies to

Witness list ?

Witnesses at the hearing are limited to individuals who submitted an affidavit in connection with the motion and/or individuals who the other side has had an opportunity to depose.

Summary: Hearing witnesses are limited to persons who submitted a motion-related affidavit or whom the opposing side had an opportunity to depose.

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

Civil cases

Applies to

Settlement position statement

Additionally, each party is to submit a settlement position statement (no more than 3 pages) to Justice Cohen ex parte, which will be treated as confidential and in no way disclosed to the other party.

Summary: Each party's settlement position statement must be submitted ex parte to Justice Cohen and treated as confidential without disclosure to the opposing party.

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

Civil cases

Applies to

Admitted exhibits

Counsel shall provide the Court with a flash drive containing copies of the admitted exhibits, identified by exhibit number.

Summary: After trial, counsel must provide the Court with a flash drive containing copies of the admitted exhibits identified by exhibit number.

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

Applies to

Witness list

▪ Witness Lists;

Summary: Counsel must bring witness lists to the pretrial conference.

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

Applies to

Exhibit list

▪ Exhibit Lists, each indicating any exhibits that will be admitted into evidence on consent;

Summary: Counsel must bring exhibit lists to the pretrial conference identifying exhibits expected to be admitted by consent.

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

Applies to

Proposed jury charges and verdict sheet

▪ Proposed Jury Charges and Verdict Sheet; and

Summary: Counsel must bring proposed jury charges and a verdict sheet to the pretrial conference.

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

Civil cases

Applies to

Counterstatement of material facts

Any party opposing the motion shall submit a counterstatement of material facts.

Summary: A party opposing a summary-judgment motion must submit a counterstatement of material facts.

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

Civil cases

Applies to

Marked pleadings

a. marked pleadings;

Summary: Counsel must serve and submit marked pleadings after a trial is assigned to Part 8.

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

Civil cases

Applies to

Bill of particulars

b. the bill of particulars;

Summary: Counsel must serve and submit the bill of particulars after a trial is assigned to Part 8.

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

Civil cases

Applies to

Witness list

c. a witness list;

Summary: Counsel must serve and submit a witness list after a trial is assigned to Part 8.

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

Civil cases

Applies to

Expert disclosures

d. expert disclosures;

Summary: Counsel must serve and submit expert disclosures after a trial is assigned to Part 8.

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

Civil cases

Applies to

Pretrial memoranda

e. pretrial memoranda (if applicable);

Summary: Counsel must serve and submit pretrial memoranda after a trial is assigned to Part 8 when applicable.

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

Civil cases

Applies to

Jury instructions

f. proposed jury instructions (if applicable);

Summary: Counsel must serve and submit proposed jury instructions after a trial is assigned to Part 8 when applicable.

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

Civil cases

Applies to

Jury verdict sheet

g. proposed jury verdict sheet (if applicable);

Summary: Counsel must serve and submit a proposed jury verdict sheet after a trial is assigned to Part 8 when applicable.

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

Civil cases

Applies to

Summary of contentions ?

h. a one paragraph summary of the parties’ contentions.

Summary: Counsel must serve and submit a one-paragraph summary of the parties' contentions after a trial is assigned to Part 8.

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

Applies to

Final status conference

All discovery shall be completed before the final status conference.

Summary: All discovery must be completed before the final status conference.

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

Applies to

Motion or special proceeding

A motion or special proceeding shall only be initiated by order to show cause where required by statute (see, e.g., CPLR 321[b][2], 5015[a]), these rules, or where emergency interim relief is sought.

Summary: A motion or special proceeding may be initiated by Order to Show Cause only when required by statute or the Part Rules or when emergency interim relief is sought.

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

Applies to

Case dispositive motion ?

Each party must comply with Commercial Division Rule 19-a by submitting a separate statement of material facts.

Summary: Each party filing a summary judgment motion must submit a separate statement of material facts under Commercial Division Rule 19-a.

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

Applies to

Brief ?

All memoranda of law must include a Table of Contents and Table of Authorities.

Summary: Every memorandum of law must include a Table of Contents.

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

Applies to

Rule 14 discovery submission ?

No exhibits or attachments shall be included.

Summary: Exhibits and attachments may not be included in the Rule 14 discovery submission.

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

Civil cases

Applies to

Qualified domestic relations order

Must include

proposed order ?

All Qualified Domestic Relations Orders not submitted with the Judgment must be submitted within 45 days of the signing of the Judgment and must be accompanied by written plan approval.

Summary: A Qualified Domestic Relations Order filed after the Judgment must be accompanied by written approval of the settlement plan.

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

Civil cases

Applies to

Statement of net worth

Full, accurate, and sworn Statements of Net Worth are mandatory and must be timely filed in strict compliance with this rule.

Summary: Each party must timely file a full, accurate, and sworn Statement of Net Worth before a substantive preliminary conference.

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

Civil cases

Applies to

Opposition

Any opposition must also include an updated Statement of Net Worth.

Summary: An opposition to financial relief must include an updated Statement of Net Worth.

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

Civil cases

Applies to

Motion to consolidate

Motions to consolidate Family Court proceedings must include a complete copy of the relevant pleadings and orders, with docket numbers, and a statement of the procedural history and status of the Family Court proceeding.

Summary: A motion to consolidate Family Court proceedings must include copies of relevant pleadings and orders bearing docket numbers and a statement of the other proceeding's procedural history and status.

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

Civil cases

Applies to

Motion submission ?

Must include

ai disclosure ?

If the certification states that a generative artificial intelligence program was used, the certification must identify the program, specify the documents that include matter generated by the program, and identify which parts of those documents were drafted by the program. One certification pertaining to a party's submission comprised of several such documents shall suffice.

Summary: An AI-use certification must identify the program, affected documents, and program-drafted portions, with one certification permitted for a submission containing several such documents.

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

Civil cases

Applies to

Exhibit list

Must include

ai disclosure ?

For trials and hearings, such identification shall be made with the exhibit list exchanged and filed prior to the pre-trial conference.

Summary: For trials and hearings, AI-exhibit identification must appear on the exhibit list exchanged and filed before the pre-trial conference.

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

Civil cases

Applies to

Motion

Must include

ai disclosure ?

For motions, such identification shall be made with the moving or opposing papers.

Summary: For motions, AI-exhibit identification must be included in the moving or opposing papers.

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

Civil cases

Applies to

Pretrial motion ?

A party contesting the authenticity of any exhibit on the ground that it is or may be AI- generated or AI-altered shall raise the objection by pre-trial motion filed in accordance with the Pre-Trial Conferences section of these Rules, stating the specific basis for the challenge.

Summary: An AI-authenticity challenge must be raised by a timely pre-trial motion stating the specific basis for the challenge.

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

Civil cases

Applies to

Papers ?

If you do, you must read everything the tool produces and confirm for yourself that every case, statute, rule, quotation, and fact it gives you is real and says what the tool claims it says.

Summary: A self-represented party using an AI tool must read its output and independently verify every cited authority and fact it supplies.

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

Civil cases

Applies to

Response ?

Where the Court has reason to believe that a paper or submission contains fabricated or fictitious authority or material, the Court will so advise the signing attorney or self-represented party in writing and afford an opportunity to respond within ten (10) days.

Summary: A signing attorney or self-represented party notified of suspected fabricated authority or material has ten days to respond.

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

Civil cases

Applies to

Audio or video evidence ?

The party must provide its own technology, viewable on a

Summary: A party offering audio or video evidence must provide its own viewable technology.

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

Applies to

Preliminary conference order ?

Completed and signed Matrimonial PC Order (if the parties cannot agree on the terms in the PC Order, the parties are directed to bring hard copies of proposed PC Orders);

Summary: Counsel must upload a completed and signed Matrimonial Preliminary Conference Order, with proposed hard copies if the parties cannot agree on its terms.

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

Applies to

Pretrial conference submission ?

If the trial concerns the issue of custody ONLY and involves no financial issues, the parties shall upload to NYSCEF and e-mail a courtesy copy of a proposed parenting plan instead of a statement of proposed disposition and an updated Statement of Net Worth is not required.

Summary: For a custody-only trial with no financial issues, the parties must upload a proposed parenting plan to NYSCEF and email a courtesy copy instead of filing a proposed-disposition statement, and no updated Statement of Net Worth is required.

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

Applies to

Sworn statement of net worth

Sworn Statements of Net Worth;

Summary: A sworn Statement of Net Worth must be uploaded to NYSCEF before the preliminary conference.

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

Applies to

Pretrial conference submission ?

At least one (1) week before the PTC, counsel or parties shall exchange and file, via NYSCEF, the following documents: A statement of proposed disposition; Child support worksheet, if applicable; Updated Statements of Net Worth; Any expert reports not previously exchanged; A proposed parenting plan, where custody is at issue; Most recently filed tax returns; A witness list, with a meaningful offer of proof for each witness; Marked pleadings and any pre-trial memoranda; A list of documents which counsel may stipulate into evidence (documents to be pre-marked as exhibits); and Proof of filing of the Note of Issue.

Summary: The Pre-Trial Conference submission must include the proposed disposition, applicable child-support worksheet, updated net-worth statements, previously unexchanged expert reports, applicable proposed parenting plan, latest tax returns, witness list with meaningful offer of proof, marked pleadings and pretrial memoranda, evidentiary-document list with premarked exhibits, and proof of filing the Note of Issue.

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

Civil cases

Applies to

Document or exhibit ?

Failure to comply with this provision may result in rejection of the filing.

Summary: Failure to separately file and describe electronic documents or exhibits may result in rejection of the filing.

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

Civil cases

Applies to

Summary judgment motion ?

In the notice of motion or early in the affirmation in support, please state the date the Note of Issue was filed and that the motion is timely.

Summary: The notice of summary-judgment motion or the opening of its supporting affirmation should state when the Note of Issue was filed and that the motion is timely.

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

Civil cases

Applies to

Trial day estimate ?

An estimate of required trial days.

Summary: At the first appearance, each party must provide an estimate of the number of trial days required.

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

Civil cases

Applies to

Discovery order

Parties are to bring a copy of the last discovery order to the status/compliance conference.

Summary: Parties must bring a copy of the most recent discovery order to each in-person status or compliance conference.

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

Civil cases

Applies to

Compliance order ?

Use complete dates, including the year.

Summary: Compliance Conference orders must use complete dates that include the year.

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

Civil cases

Applies to

Letter

Must include

page count ?

A party may request oral argument on the face of the motion papers or by a single-page letter e-filed and emailed to the Part22 Clerk (with notice to all parties). Not every request for oral argument will be granted.

Summary: A request for oral argument made by letter must be limited to one page, electronically filed, and emailed to the Part 22 Clerk with notice to all parties.

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

Civil cases

In the notice of motion or early in the affirmation in support, please state the date the Note of Issue was filed and how the motion is timely.

Summary: The notice of motion, or the early portion of the supporting affidavit, should state the Note of Issue filing date and explain why the summary-judgment motion is timely.

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

Civil cases

Applies to

Exhibits

Any exhibit to the motion must be e-filed as a separate document and must be given an identifying label (e.g., Notice of Claim, Bill of Particulars, etc,).

Summary: Each summary-judgment motion exhibit must be given a specific identifying label, such as “Notice of Claim” or “Bill of Particulars.”

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

Civil cases

Applies to

Exhibits

All exhibits should be paginated, and any references to voluminous exhibits (including deposition testimony), must include pinpoint citations (i.e. page numbers).

Summary: All summary-judgment exhibits should be paginated, and references to voluminous exhibits or deposition testimony must include pinpoint page citations.

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

Civil cases

Applies to

Marked pleadings and bills of particulars

All marked pleadings and bills of particulars.

Summary: At the first appearance, the parties must furnish all marked pleadings and bills of particulars.

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

Civil cases

Applies to

Statutory provisions

A copy of any statutory provisions in effect at the time the cause of action arose upon which any party relies.

Summary: At the first appearance, the parties must furnish copies of relied-upon statutory provisions that were in effect when the cause of action arose.

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

Civil cases

Applies to

Ebt transcripts

Copies of the EBT transcripts intended for use at trial during direct examination.

Summary: At the first appearance, the parties must furnish copies of the EBT transcripts intended for use during direct examination.

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

Civil cases

Applies to

Prior decisions

All prior decisions in the case, including any appellate decisions.

Summary: At the first appearance, the parties must furnish all prior decisions in the case, including appellate decisions.

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

Civil cases

Applies to

Demand offer and policy limits

Most recent demand, offer and policy limits.

Summary: At the first appearance, the parties must furnish the most recent demand, offer, and policy limits.

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

Civil cases

Applies to

Motion ?

Any reference to deposition testimony must cite to the exact page and line numbers relied upon rather than merely attaching the entire transcript or “relevant portions.”

Summary: References to deposition testimony must include exact page and line pinpoint citations.

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

Civil cases

Applies to

Media exhibit ?

The media must relate to a placeholder exhibit page and be addressed in the appropriate affirmation, etc., so that it is in admissible form.

Summary: Electronically submitted media must be tied to a placeholder exhibit page and addressed in the appropriate affirmation or other filing so that it is in admissible form.

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

Civil cases

Applies to

Conference submission ?

3. Use firm cut-off dates, such as “on or before December 31, 2023.” Do not use “within 45 days.” Counsel will be held to the dates to which they commit.

Summary: Conference submissions must use firm calendar cut-off dates rather than relative periods, and counsel is held to the committed dates.

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

Civil cases

Applies to

Post trial brief ?

ii. Proposed Findings of Fact

Summary: Initial post-trial briefs should contain proposed findings of fact.

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

Civil cases

Applies to

Post trial brief ?

iv. Conclusion – including specific relief sought for each cause of action

Summary: The conclusion of each initial post-trial brief should identify the specific relief sought for each cause of action.