Judge Edward A. Pace
Individual Rules, Standing Orders & Policies
- Rules last changed:
Limits & Logistics
Courtesy Copies
Courtesy copies
- At Least 10 Days Before Return Date
Adjournments
- Adjournment requests for preliminary conferences are considered only when submitted within three days of notice.
Communication
Chambers
Document Format Requirements4 rules
All stipulated exhibits must be made into a PDF, Bates stamped, if voluminous, and marked for identification (e.g., “Exh. 1”), and the notation “EVD”, and submitted to NYSCEF at least one week before the commencement of the trial, unless otherwise directed by the Court.
- File type
- Exhibits
Formatting
- •Bates stamped if voluminous
- •Marked for identification, for example “Exh. 1”
- •Notated “EVD”
- •Submit to NYSCEF
Video exhibits must be cut to pertinent length or, alternatively, cite the pertinent beginning and ending time markers on the video clip.
At the time of the NYSCEF or paper filings of all Notices of Motion, Orders to Show Cause, Affirmations, Affidavits, and Memorandums of Law (but not exhibits) email Microsoft Word formatted copies to pzalocha@nycourts.gov. Do not send additional paper copies to the Court.
- File type
- Word
- Notice of motion
- Orders to show cause
- Affirmations
- Affidavits
- Memorandums of law
Formatting
- •Exhibits are excluded
The proposed Jury Charges and Verdict Sheets are to be emailed in a Word Document Format to the judge, the law clerk, and copied to the secretary as follows: epace@nycourts.gov, pbannist@nycourts.gov, pzalocha@nycourts.gov
- File type
- Word
- Jury instructions
- Proposed verdict sheet
Document Filing Requirements16 rules
An attorney or party using a defined AI tool to prepare a paper must independently review it for fabricated or fictitious authority and certify that review by signing the paper.
Court's wording
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.
Motions to resolve discovery disputes shall be accompanied by an affidavit of good faith attempt at resolution.
Post-trial motions and responding papers must cite each transcript’s NYSCEF document number, page, and line before the court considers the motion.
Court's wording
all post-trial motion(s) and responding papers must refer to the NYSCEF Document Number assigned to each transcript with page(s) and line(s) cited in all papers in support or in opposition to the motion(s) prior to the Court’s consideration of the motion(s).
If counsel does not receive an email, both attorneys and clients must appear.
Counsel must bring the most recent proposed agreement in paper and electronic form.
Motions seeking financial relief - must be accompanied by the movants DRL§236(B) affidavit.
Quantum meruit applications – the following documents MUST be submitted, or the application will be denied:
If expand on rights: Modification to agreement must be signed & notarized by parties.
Any case that is older than one year from entry of judgment: (Q)DRO must be submitted on motion filed in NYSCEF or the ECCO and then taken to the judge who signed the judgment of divorce with the following documents:
Modification to agreement must be signed & notarized by parties.
In all written or verbal submissions, use NYSCEF Document Numbers when referring to a filed document instead of or in addition to, for example, an exhibit letter or just the name of the document.
It is expected that both parties will have reviewed the proposed agreement prior to the settlement conference, and all litigants and attorneys are required to attend Settlement Conferences In Person.
Partial submissions will not excuse the appearance.
Any case that is less than one year away from entry of judgment: (Q)DRO should be submitted to the judge who signed the judgment of divorce (if no longer on the bench or if it originates as an uncontested matter, go directly to the Chief Clerk’s Office) with the following:
The Adjournment Request Form must be used if the clients are not available.
If all of the necessary documents are submitted, you will receive an email dispensing with your appearance.
Filing & Service rules
Electronic Filing Rules
Post-trial motions must include a simultaneous NYSCEF upload of the relevant trial testimony transcripts and exhibits.
All Post-Trial Motions including those made pursuant to the CPLR and/or GOL, etc. require a simultaneous upload of the trial testimony transcript(s) of each relevant witness to the motion(s) and exhibit(s)
Page 3 | MOTIONS
Filing Timing and Cure Windows
The required transcript citations must be included before the court considers the post-trial motion.
all post-trial motion(s) and responding papers must refer to the NYSCEF Document Number assigned to each transcript with page(s) and line(s) cited in all papers in support or in opposition to the motion(s) prior to the Court’s consideration of the motion(s).
Page 3 | MOTIONS
Each party must submit requests for prior and after-trial jury charges and proposed verdict sheets no later than the day before the final pretrial conference.
The Court requires each party to submit Requests for Prior to and After Trial Jury Charges and Proposed Verdict Sheets to the Court no later than the day before the Final Pre-Trial Conference, which will be set by the trial judge.
Page 3 | PRE-TRIAL RULES
Unless the court directs otherwise, the prevailing party must submit orders within 30 days.
Unless otherwise directed by the Court, Orders are to be submitted within 30 days by the prevailing party.
Page 4 | ORDERS
Deadlines may not be extended without a further court order.
Deadlines may not be extended without further order of the Court.
Page 4 | PRE-TRIAL RULES
Stipulated exhibits must be submitted to NYSCEF at least one week before trial unless the court directs otherwise.
All stipulated exhibits must be made into a PDF, Bates stamped, if voluminous, and marked for identification (e.g., “Exh. 1”), and the notation “EVD”, and submitted to NYSCEF at least one week before the commencement of the trial, unless otherwise directed by the Court.
Page 4 | PRE-TRIAL RULES
The final judgment roll submission ordinarily requires an in-person appearance with clients, but the appearance is avoided only if all checklist documents from both sides are provided to chambers 48 hours before the return date.
The submission date is an in-person appearance with clients. In order to avoid the appearance, you must provide all necessary documents listed on the Judgment Roll Checklist, from both sides, to chambers 48 hours prior to the return date.
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Counsel has 30 days after the court receives a fully executed agreement or written ratification to submit the final judgment roll.
Once a fully executed agreement or written ratification has been received by the Court, counsel will have 30 days to submit the final judgment roll.
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Filing Fees and Waivers
All motion and cross-motion papers must be filed and the filing fees paid before the hearing can be scheduled, which requires contacting court clerk Cornelius Hart.
All motions and cross-motion papers must be filed and filing fees paid before scheduling of the hearing. Contact Court Clerk, Cornelius Hart, to schedule the motion hearing.
Page 2 | MOTIONS
No filing fee is required for this motion.
Note: there is no filing fee for this motion.
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Courtesy Copy Requirements
In non-e-filed cases, a working paper copy for the judge must accompany the moving papers and be filed no later than 10 days before the return date.
For non-e-filed cases, all moving papers must be filed with a working paper copy for the Judge no later than 10 days in advance of the return date.
Page 2 | MOTIONS
Pre-Motion Conference Requirements
Temporary injunctive relief requires compliance with the cited rules and prior notice to opposing counsel and pro se parties, absent a significant-prejudice showing; testimony may also be required for an order to show cause.
Temporary injunctive relief requests must comply with 22NYCRR 202.8(e) and will not be granted in the absence of prior notice to the opposing counsel and pro se parties, as required by 22 NYCRR § 202.7(f), unless the moving party can demonstrate significant prejudice. Live MS Teams or in-person testimony of the moving party may be required where an order to show cause requests temporary injunctive relief.
Page 2 | MOTIONS
An order to show cause or TRO in a case assigned to another judge requires prior written approval from the IAS judge or the IAS judge's law clerk before signature.
Orders to Show Cause/TROs on a case assigned to another judge will be signed only upon prior written approval of IAS judge or his/her law clerk.
Page 2 | MOTIONS
Adjournment & Extension Requirements
Every adjournment request must be copied to all parties and the identified court personnel before court approval.
All requests for adjournment must be copied to all parties and to PATRICK BANNISTER, PETER ZALOCHA, and NEIL HART (and for all correspondence with chambers) before approval by the Court.
Page 1 | ADJOURNMENTS
Consent to an adjournment must be acknowledged in writing by email to the court.
The consent must be acknowledged in writing via email to the Court.
Page 1 | ADJOURNMENTS
An adjournment request requires the prior consent of every counsel or pro se party.
Parties requesting an adjournment must first seek consent of each counsel or pro se party.
Page 1 | ADJOURNMENTS
Conference adjournment requests go to the court secretary, while motion adjournment requests go to the court clerk.
Requests for adjournment of conferences must be directed to the court secretary. Requests for adjournment of motions must be directed to the court clerk.
Page 1 | ADJOURNMENTS
Adjournment requests for preliminary conferences are considered only when submitted within three days of notice.
Preliminary conferences adjournments – because of the limited time to hold a Preliminary Conference, adjournment requests will only be considered within 3 days of notice.
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The court will notify each counsel or pro se party of the new adjourned date.
The Court will notify each counsel or pro se party of the adjourned date.
Page 1 | ADJOURNMENTS
Chambers Communication Rules
A case summary must be emailed to the court secretary at least one week before the first conference.
A brief summary of the case shall be emailed to the Court’s secretary at least one week in advance of the first scheduled conference.
Page 2 | CONFERENCES