Judge Michael A. Siragusa
Individual Rules, Standing Orders & Policies
Limits & Logistics
Document Limits
Communication
Chambers
Chambers
Page & Word Limits1 rule
Prior to a preliminary conference, counsel shall provide Chambers with a one (1) page summary of the case.
- Case summary
- Up to 1 page
Document Format Requirements3 rules
Please complete the preliminary matrimonial information sheet contained in Appendix A to these rules and return a PDF copy of the document to Carolyn Conannon in advance of the preliminary conference.
- File type
If there is any stipulation among counsel as to the admissibility into evidence of any exhibit, counsel shall advise the Court Reporter and it will be marked. Otherwise, exhibits shall be marked for identification only.
Submission of a PDF copy of a completed judgment roll checklist will facilitate the review and execution of a proposed judgment.
- File type
Document Filing Requirements8 rules
Shall be submitted to Chambers by the prevailing party’s counsel within seven (7) business days of a decision as to same and uploaded to NYSCEF, together with verification that the order has been served upon all opposing counsel (or pro se litigants), and that no objection has been received within three (3) business days of service.
Prior to a preliminary conference, counsel shall provide Chambers with a one (1) page summary of the case.
Orders will not be signed without said verification.
Please complete and upload to NYSCEF, the judgement roll checklist contained in Appendix B to these rules in conjunction with the tender of a proposed judgment for judicial signature.
Please also upload a retainer agreement, summons, affidavit of service, and Domestic relations Law §236 B affidavit to NYSCEF in advance of that conference.
Unless your case is one of first impression in the State of New York, compliance with rule §202.8-g is waived.
Counsel shall exchange a list of deposition testimony that will be offered into evidence and confer in good faith to agree upon those portions of the deposition testimony that will be admitted into evidence without objection.
Counsel shall confer in good faith to agree upon those exhibits that shall be admitted into evidence without objection, and shall pre-mark them with the Court Reporter.
Filing & Service rules
Filing Timing and Cure Windows
The prevailing party’s counsel must submit the order to Chambers and upload it to NYSCEF within seven business days of the decision.
Shall be submitted to Chambers by the prevailing party’s counsel within seven (7) business days of a decision as to same and uploaded to NYSCEF
Civil cases
Page 1 | ORDERS
Unless good cause is shown, Defendant’s expert disclosure is due 30 days before jury selection.
The deadline for expert disclosure, absent good cause shown, is forty-five (45) days prior to the scheduled commencement date of jury selection (Plaintiff), and thirty (30) days prior to the scheduled commencement date of jury selection (Defendant).
Civil cases
Page 2 | TRIALS
Motions in limine must be filed and served at least 30 days before jury selection begins.
Motions in limine shall be filed and served as to be heard thirty (30) days prior to the scheduled commencement date of jury selection.
Civil cases
Page 2 | TRIALS
Unless good cause is shown, Plaintiff’s expert disclosure is due 45 days before jury selection and Defendant’s is due 30 days before jury selection.
Expert disclosure shall be staggered. The deadline for expert disclosure, absent good cause shown, is forty-five (45) days prior to the scheduled commencement date of jury selection (Plaintiff), and thirty (30) days prior to the scheduled commencement date of jury selection (Defendant).
Civil cases
Page 2 | TRIALS
Requests to charge, marked pleadings, witness lists, and proposed verdict sheets must be submitted to Chambers two weeks before jury selection after consultation with opposing counsel.
Requests to charge, marked pleadings, witness lists, and proposed verdict sheets shall be submitted to Chambers after consultation with opposing counsel, so as to narrow issues and limit redundancy two (2) weeks prior to the scheduled commencement date of jury selection.
Civil cases
Page 2 | TRIALS
Service and Proof of Service Rules
When a default is entered without a prior appearance by the defaulting party, serve the default judgment motion through the same method used for the summons and complaint and include an affidavit of service.
To the extent a default is taken in the absence of any prior appearance by the defaulting party, please serve a copy of the motion for default judgment upon that party through the same means by which service of the summons and complaint was effectuated and include an affidavit of service in your motion papers.
Civil cases
Page 2 | MATRIMONIAL ACTIONS
Pre-Motion Conference Requirements
Discovery motions require prior consultation with the law clerk, including an initial email copying opposing counsel and describing the dispute, before the law clerk determines whether a conference or motion practice is required.
Discovery motions: Shall be subject to a conference with the Law Clerk prior to filing the motion. In such case, counsel shall first email the Law Clerk, copying opposing counsel, and briefly set forth the discovery related dispute. Opposing counsel shall have a reasonable opportunity to email a brief response, after which the Law clerk will determine whether a conference, or motion practice is required.
Civil cases
Page 1 | MOTIONS
Adjournment & Extension Requirements
Adjournments are granted with opposing counsel’s consent, but the court may grant an adjournment despite opposition when the request is made within the CPLR’s minimum time limits.
Adjournments are granted upon consent of opposing counsel but, if counsel refuses, the Court has a liberal adjournment policy of motions made within minimum time limits of the CPLR and may grant an adjournment upon request, even if opposed.
Civil cases
Page 1 | ADJOURNMENTS
Chambers Communication Rules
Adjournment requests should be made by email to cconcann@nycourts.gov and tnavarro@nycourts.gov; please do not file letter requests for adjournments on NYSCEF.
Adjournment requests should be made by email to cconcann@nycourts.gov and tnavarro@nycourts.gov; please do not file letter requests for adjournments on NYSCEF.
Civil cases
Page 1 | ADJOURNMENTS
A conference is automatically scheduled when Chambers receives a filed RJI.
Conferences shall be automatically scheduled upon receipt by chambers of a filed RJI.
Civil cases
Page 1 | CONFERENCES
A party that believes its case qualifies for compliance with §202.8 must consult the judge before submitting the summary judgment papers.
Those who believe their case qualifies as one to comply with §202.8 shall consult with the Judge before such submission.
Civil cases
Page 1 | MOTIONS
An initial charging conference is required after jury selection, and a final charging conference is required before summations.
An initial charging conference shall be held upon the conclusion of jury selection, and a final charging conference shall be held prior to summations.
Civil cases
Page 2 | TRIALS
A conference may be scheduled upon request directed to Carolyn Concannon.
Conferences may also be scheduled upon request (directed to Carolyn Concannon).
Civil cases
Page 1 | CONFERENCES
Oral arguments are in person unless the parties arrange otherwise with Chambers.
All oral arguments will be in person unless previously arranged with Chambers.
Civil cases
Page 1 | MOTIONS