Judge Carolyn E. Wade
Individual Rules, Standing Orders & Policies
- Rules last changed:
Limits & Logistics
Document Limits
Courtesy Copies
Terms of Sale
Court-wide- Upon request
Adjournments
- Adjournment requests must be submitted in writing by email to the Part Clerk at least 48 hours before the return date.
- A stipulation to adjourn must be electronically filed and emailed to the Part Clerk at least 48 hours before the return date.
- A subsequent adjournment request generally requires an application to the court showing good cause unless the parties consent.
- A consent-based subsequent adjournment must be submitted by email as a stipulation stating a proposed return date.
Request must include
Communication
Chambers8 contacts
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Clerk4 contacts
Other Contacts2 contacts
Page & Word Limits2 rules
Written motions in limine shall not exceed three pages, double spaced, and citations to the Official Reporter is required.
- Format
- Double-spaced
- Motion in limine
Parties are to provide a one-page trial summary sheet which must include:A brief summary of Plaintiff’s cause of action and Plaintiff’s demand.
- Trial summary
- Up to 1 page
Document Format Requirements10 rules
Exhibit tabs shall immediately precede an actual exhibit (i.e., not a blank page denoted “Exhibit __”).
Additionally, they must be submitted in Word format to the court by e-mail to agrossma@nycourts.gov.
- File type
- Word
Formatting
- •Submit by email to agrossma@nycourts.gov.
The Court’s signature line must not appear on a page with no writing.
The proposed order must be e-mailed in Word format, and must include the infant’s full name and date of birth.
- File type
- Word
Formatting
- •Email the proposed order
Exhibit tabs are required on all papers filed with the Court.
All submissions must be separated by exhibit tabs.
Formatting
- •Separate all submissions with exhibit tabs
Written motions in limine shall not exceed three pages, double spaced, and citations to the Official Reporter is required.
- Line spacing
- Double
- Motion in limine
Affirmations, affidavits, and legal memoranda must be double-spaced.
- Line spacing
- Double
- Affirmation
- Affidavit
- Legal memorandum
After oral argument, if a motion is marked “fully submitted,” the parties shall e-mail their proposed orders as the Court instructs, in Word format to both law clerks.
- File type
- Word
- Proposed order
Plaintiffs will number their exhibits and defendants will letter their exhibits.
Document Filing Requirements15 rules
The Order must include a directive for payment of liens.
Prior to trial, counsel shall furnish to the Court the bill of particulars, and the marked pleadings pursuant to CPLR § 4012.
A list of the exhibits shall also be provided to the Court prior to trial.
Amendments to compromise orders must include a copy of the original compromise order and an attorney’s affirmation detailing the proposed amendment and the reason for it, in addition to any other necessary papers.
Wrongful Death Compromise petitions must comply with the provisions of EPTL § 5-4.6 and include an affirmation of no liens or, where liens are asserted, documentation of such liens.
Proposed orders to show cause must be brought to the Ex Parte Motion Support Office for review prior to submission to the part.
The proposed order must be e-mailed in Word format, and must include the infant’s full name and date of birth.
A current medical report, physician’s affirmation, and affirmation of no liens are required with the submissions.
All proposed jury charges and proposed verdict sheets shall be submitted to the Court and the opposing counsel in typed form no later than the close of plaintiff’s case, or as instructed by the Court.
If any portion of the settlement is structured, the cost of the annuity must be stated in the order.
Stipulations of Discontinuance involving an infant or a wrongful death case shall be submitted as noted above; and shall include a brief attorney’s affirmation in support of the request for the stipulation to be so ordered.
Written motions in limine shall not exceed three pages, double spaced, and citations to the Official Reporter is required.
If a Compromise Order was signed as to a previously settling defendant, such order must be attached as an exhibit and the partial settlement so stated in the attorney’s affirmation in support of the final Compromise Order.
A copy of depositions intended to be used at trial should be furnished to the Court at the commencement of the trial.
The proposed orders should include controlling case law, and a basis for the Court’s ruling.
Filing & Service rules
Electronic Filing Rules
Upon filing, all applications must be e-mailed to agrossma@nycourts.gov.
Upon filing, all applications must be e-mailed to agrossma@nycourts.gov.
Civil cases
Page 1 | INFANT COMPROMISE & WRONGFUL DEATH COMPROMISE ORDERS
Stipulations to adjourn are required to be filed electronically and emailed to the Part Clerk.
All stipulations to adjourn must be e-filed and e-mailed to the Part Clerk (jgoldste@nycourts.gov) at least 48 hours prior to the return date.
Civil cases
Page 1 | MOTIONS
Electronic filing of motions with proposed orders is permitted for each party.
All motions may be e-filed with proposed orders by each party.
Civil cases
Page 1 | MOTIONS
Filing Timing and Cure Windows
A summary judgment motion must be made within 60 days after the note of issue is filed.
Summary judgment motions must be made within sixty (60) days of the filing of the note of issue.
Civil cases
Page 1 | MOTIONS
Proposed jury charges and verdict sheets are due no later than the close of the plaintiff’s case, unless the court instructs otherwise.
All proposed jury charges and proposed verdict sheets shall be submitted to the Court and the opposing counsel in typed form no later than the close of plaintiff’s case, or as instructed by the Court.
Civil cases
Page 1 | TRIALS
Service and Proof of Service Rules
Unless a motion has a briefing schedule, motion, opposition, and reply papers must be served on adversaries under CPLR § 2214.
Except for those motions with briefing schedules, all motion papers, opposition papers, and reply papers shall be served on adversaries per CPLR § 2214.
Civil cases
Page 1 | MOTIONS
Filing Fees and Waivers
Every stipulation of discontinuance requires payment through the County Clerk’s office and filing in Motion Support.
All Stipulations of Discontinuance shall be paid for in the County Clerk’s office and filed in Motion Support.
Civil cases
Page 1 | STIPULATIONS OF DISCONTINUANCE
Any legally required fee must be paid to the County Clerk before submitting an order to show cause to the part.
Fees as required by law must be paid to the County Clerk prior to submission.
Civil cases
Page 1 | MOTIONS
Adjournment & Extension Requirements
A consent-based subsequent adjournment must be submitted by email as a stipulation stating a proposed return date.
If on consent, parties must submit a stipulation with a proposed return date by e-mail to the Part Clerk, Jay Goldstein at jgoldste@nycourts.gov.
Civil cases
Page 1 | ADJOURNMENTS
A subsequent adjournment request generally requires an application to the court showing good cause unless the parties consent.
Any subsequent adjournment requests must be made upon application to the Court for good cause, unless on consent.
Civil cases
Page 1 | ADJOURNMENTS
A stipulation to adjourn must be electronically filed and emailed to the Part Clerk at least 48 hours before the return date.
All stipulations to adjourn must be e-filed and e-mailed to the Part Clerk (jgoldste@nycourts.gov) at least 48 hours prior to the return date.
Civil cases
Page 1 | MOTIONS
Adjournment requests must be submitted in writing by email to the Part Clerk at least 48 hours before the return date.
All requests for adjournments must be made in writing, at least 48 hours before the return date, and e-mailed to the Part Clerk, Jay Goldstein at jgoldste@nycourts.gov.
Civil cases
Page 1 | ADJOURNMENTS
Chambers Communication Rules
The court will not entertain ex parte communications.
NO EX-PARTE COMMUNICATIONS WILL BE ENTERTAINED.
Civil cases
Page 1 | INQUIRIES
Attorneys may not send correspondence to chambers except stipulations signed by all parties.
No correspondence between attorneys shall be sent to chambers, other than stipulations signed by all parties.
Civil cases
Page 1 | INQUIRIES
Chambers staff may not provide legal advice or guidance to attorneys or litigants.
Chambers staff is not permitted to provide legal advice or guidance to attorneys or litigants.
Civil cases
Page 1 | INQUIRIES
The Part Clerk may be contacted at 347-296-1578 or jgoldste@nycourts.gov when necessary.
If necessary, the Part Clerk, Mr. Jay Goldstein, can be contacted at 347-296-1578 (jgoldste@nycourts.gov).
Civil cases
Page 1 | INQUIRIES
When the parties agree to seek a conference instead of further motion practice, they may email the judge’s law clerks to request a virtual conference.
If the parties agree to a conference with the Court in lieu of further motion practice, the parties may e-mail the Judge’s Law Clerks to request a virtual conference.
Civil cases
Page 1 | INQUIRIES
All inquiries as to case or calendar status should, in the first instance, be made to the MOTION SUPPORT OFFICE, Room 227, Telephone (347) 296-1694.
All inquiries as to case or calendar status should, in the first instance, be made to the MOTION SUPPORT OFFICE, Room 227, Telephone (347) 296-1694.
Civil cases
Page 1 | INQUIRIES