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Court Rules
Judge

Judge Lynn M. Keane

Individual Rules, Standing Orders & Policies

New York Supreme Court, Erie County

Limits & Logistics

Courtesy Copies

Exhibits

Notice of Motion, Affidavit

Filters:

Document Format Requirements1 rule

FormattingImportantCivil cases

Requests to charge, proposed verdict sheets, witness lists, pre-marked exhibits and pleadings are to be submitted two weeks prior to jury selection (in Word format).

File type
Word
Applies to
  • Jury instructions
  • Exhibits
  • Trial order
JudgeKeane2026 · p. 2
|SectionCIVIL TRIALS

Document Filing Requirements2 rules

Filing RequirementsMandatoryCivil cases

All orders and other papers for signature (except Orders To Show Cause) must first be circulated to opposing counsel or pro se party for comment and approval.

Filing RequirementsMandatoryCivil cases

Motions to resolve discovery disputes shall be accompanied by an affidavit of good faith attempt at resolution. Letters between counsel are insufficient.

Document
Discovery motion

Must include

  • Affidavit of good faith attempt
JudgeKeane2026 · p. 2
|SectionMOTIONS – Special Term Day

Filing & Service rules

Filing Timing and Cure Windows

The party who brought the motion must submit the order within 30 days.

Orders are to be submitted within 30 days by the party who brought the motion.

Civil cases

Page 2 | ORDERS

Expert disclosure must occur at least 30 days before trial begins unless the Court orders otherwise.

Expert disclosure is to be made at least 30 days prior to the commencement of trial, unless ordered otherwise by the court.

Civil cases

Page 2 | CIVIL TRIALS

All motion submissions, including replies, must be received by the Friday before the return date, and late papers may result in a court-imposed adjournment.

All submissions, including replies, must be received by the Court no later than the Friday prior to the return date. Motions may be adjourned by the Court if any papers are filed after the Friday prior to the return date.

Civil cases

Page 2 | MOTIONS – Special Term Day

The listed trial submissions must be submitted two weeks before jury selection in Word format.

Requests to charge, proposed verdict sheets, witness lists, pre-marked exhibits and pleadings are to be submitted two weeks prior to jury selection (in Word format).

Civil cases

Page 2 | CIVIL TRIALS

Courtesy Copy Requirements

Counsel must provide chambers with hard copies of notices of motion, affidavits, and memoranda of law.

Counsel shall provide chambers with hard copies of notices of motion, affidavits, and memoranda of law.

Civil cases

Page 1 | MOTIONS – Special Term Day

When practical, counsel should provide opposing counsel and the court with a courtesy copy of each trial exhibit.

Counsel shall, if practical, supply a courtesy copy of each exhibit to opposing counsel and the court.

Civil cases

Page 2 | CIVIL TRIALS

For lengthy trial exhibits, only the relevant pages need to be copied for the courtesy copies.

For lengthy exhibits, only the relevant pages need be copied.

Civil cases

Page 2 | CIVIL TRIALS

Pre-Motion Conference Requirements

An in-person preliminary conference must be scheduled within 45 days of receipt of the RJI, with pleadings and an emailed case summary submitted before the conference.

Preliminary conferences will be scheduled in person within 45 days of the Court’s receipt of a filed RJI, as required by 22 NYCRR §202.12(b). The first preliminary conference will be scheduled with Judge Keane or Law Clerk. Pleadings and a brief summary of the case in letter form are required in advance of the initial conference. The brief summary must be emailed to hpark@nycourts.gov one week prior to the conference.

Civil cases

Page 1 | PRELIMINARY CONFERENCES

Adjournment & Extension Requirements

An adjournment requires consent from all parties and approval from the Court obtained through the Court’s Secretary.

Adjournments may be granted with the consent of all parties, subject to the Court’s approval by contacting the Court’s Secretary.

Civil cases

Page 1 | PRELIMINARY CONFERENCES

After a status-conference adjournment is granted, the parties must provide the Court with three mutually convenient alternative dates.

If the court grants the adjournment of a scheduled status conference, it is incumbent upon the parties to offer the Court three mutually convenient dates.

Civil cases

Page 1 | PRELIMINARY CONFERENCES

Chambers Communication Rules

When an order is uploaded to NYSCEF for review, email the Court Clerk and copy the Secretary.

Please email the Court Clerk with a cc to the Secretary when an Order is uploaded to NYSCEF for review.

Civil cases

Page 2 | ORDERS

Court-wide rules

Applies court-wide

These 4 rules apply across New York Supreme Court, Erie County. Where this judge's own standing orders above address the same topic, the judge's requirement controls.

Filing Requirements

All 3
  • Applies to
    236B financial affidavit

    Both sides must exchange completed 236B Financial Affidavits before the first court conference.

  • Applies to
    Final judgment roll

    Within a few weeks after the specified stipulation or fully executed agreements, one attorney must submit the final judgment roll, including the final Findings and Judgment.

  • Applies to
    Proposed dispositions

    Parties or their attorneys will exchange "proposed dispositions" after the information has been exchanged to allow the Court to narrow or resolve some or all of the issues.

Service

All 1
  • A certified copy of the final judgment must be served on both parties.

Common questions about Judge Lynn M. Keane's rules

Are courtesy copies required for Judge Lynn M. Keane?

Courtesy-copy rule applies for notice of motions and affidavits. Counsel must provide chambers with hard copies of notices of motion, affidavits, and memoranda of law.

View ruleSource: page 1, section MOTIONS – Special Term Day

Does Judge Lynn M. Keane require a pre-motion conference or letter before filing a motion?

An in-person preliminary conference must be scheduled within 45 days of receipt of the RJI, with pleadings and an emailed case summary submitted before the conference.

View ruleSource: page 1, section PRELIMINARY CONFERENCES

What formatting rules apply to filings before Judge Lynn M. Keane?

Judge Lynn M. Keane's formatting rule includes file format docx. Requests to charge, proposed verdict sheets, witness lists, pre-marked exhibits, and pleadings must be submitted in Word format.

View ruleSource: page 2, section CIVIL TRIALS

What must be included with discovery motion filings before Judge Lynn M. Keane?

The rule requires affidavit of good faith attempt. A motion to resolve a discovery dispute must include an affidavit describing a good-faith attempt to resolve the dispute; counsel letters alone are insufficient.

View ruleSource: page 2, section MOTIONS – Special Term Day

What must be included with order filings before Judge Lynn M. Keane?

Before submission for signature, orders and other papers must be circulated to opposing counsel or the pro se party for comment and approval, except Orders to Show Cause.

View ruleSource: page 2, section ORDERS

How may parties contact Judge Lynn M. Keane's chambers?

When an order is uploaded to NYSCEF for review, email the Court Clerk and copy the Secretary.

View ruleSource: page 2, section ORDERS

How do I request an adjournment or extension before Judge Lynn M. Keane?

An adjournment requires consent from all parties and approval from the Court obtained through the Court’s Secretary.

View ruleSource: page 1, section PRELIMINARY CONFERENCES

What filing deadlines does Judge Lynn M. Keane set?

All motion submissions, including replies, must be received by the Friday before the return date, and late papers may result in a court-imposed adjournment.

View ruleSource: page 2, section MOTIONS – Special Term Day
Complete rules summary for Judge Lynn M. Keane

An in-person preliminary conference must be scheduled within 45 days of receipt of the RJI, with pleadings and an emailed case summary submitted before the conference.

An adjournment requires consent from all parties and approval from the Court obtained through the Court’s Secretary.

After a status-conference adjournment is granted, the parties must provide the Court with three mutually convenient alternative dates.

All motion submissions, including replies, must be received by the Friday before the return date, and late papers may result in a court-imposed adjournment.

A motion to resolve a discovery dispute must include an affidavit describing a good-faith attempt to resolve the dispute; counsel letters alone are insufficient.

The party who brought the motion must submit the order within 30 days.

Before submission for signature, orders and other papers must be circulated to opposing counsel or the pro se party for comment and approval, except Orders to Show Cause.

When an order is uploaded to NYSCEF for review, email the Court Clerk and copy the Secretary.

Expert disclosure must occur at least 30 days before trial begins unless the Court orders otherwise.

For lengthy trial exhibits, only the relevant pages need to be copied for the courtesy copies.

When practical, counsel should provide opposing counsel and the court with a courtesy copy of each trial exhibit.

The listed trial submissions must be submitted two weeks before jury selection in Word format.

Counsel must provide chambers with hard copies of notices of motion, affidavits, and memoranda of law.

Requests to charge, proposed verdict sheets, witness lists, pre-marked exhibits, and pleadings must be submitted in Word format.

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