Judge Lynn M. Keane
Individual Rules, Standing Orders & Policies

Limits & Logistics
Courtesy Copies
Exhibits
Notice of Motion, Affidavit
Document Format Requirements1 rule
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
- Jury instructions
- Exhibits
- Trial order
Document Filing Requirements2 rules
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.
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
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