Judge Daniel J. Doyle
Individual Rules, Standing Orders & Policies
Limits & Logistics
Document Limits
Courtesy Copies
Deposition Testimony
Pleadings
Adjournments
- A request to extend or amend the Scheduling Order must be made by letter to the Court, with notice to opposing counsel, at least ten business days before the affected date, and must include a proposed amended scheduling order.
- Extensions of the scheduling-order deadlines require written good cause, at least ten business days’ notice to opposing counsel, and an accompanying proposed amended scheduling order.
Communication
Chambers
Chambers
Chambers
Page & Word Limits1 rule
Submissions shall be no longer than five (5) pages, exclusive of any submitted exhibits, and shall be emailed to the law clerks at tdonaher@nycourts.gov and awallen@nycourts.gov.
- Page limit
- Up to 5 pages
Excluded from page count
- •Exhibits
Document Format Requirements3 rules
in either Word or Wordperfect format
- File type
- Word
Formatting
- •WordPerfect format is also permitted
The Case Information Statement must be prepared using the fillable pdf. file or submitted in Word or WordPerfect file formats.
Formatting
- •Use the fillable PDF file or submit in Word or WordPerfect format
Hyperlinking citations to another document filed in NYSCEF is encouraged, but not required. Citations to caselaw contained in a memorandum of law do not need to be hyperlinked. Official citations are preferred.
Formatting
- •Official citations are preferred
Document Filing Requirements27 rules
The requesting party must prepare and submit a Case Information Statement, with notice to the opposing party, by the applicable submission deadline.
Court's wording
A Case Information Statement shall be prepared by the party requesting the preliminary conference and submitted – on notice to the opposing party – with the request for cases already assigned to Justice Doyle, or within seven (7) days of notification from chambers that the case has been assigned to Justice Doyle and the conference has been scheduled by chambers.
Exhibits uploaded to NYSCEF must be done on an individualized basis [not all in one PDF] with a short description of the actual item [not just a repetition of the Exhibit letter or number].
Items already in NYSCEF are not part of the motion record unless added as motion exhibits, or at the very least expressly incorporated by reference.
All Notices of Motions MUST be submitted with blank return dates to permit the Court to assign a Special Term date.
Condensed or excerpted transcripts are NOT permitted as motion exhibits. Full transcripts must be provided as exhibits when cited to by the parties. Noncompliant submissions will be rejected.
A request to extend or amend the Scheduling Order must be accompanied by a proposed amended scheduling order.
Court's wording
A request for extension or amendment of the Scheduling Order MUST be made by letter request to the Court, on notice to opposing counsel, at least ten (10) business days in advance of the date to be extended, and it also MUST be accompanied by a proposed Amended Scheduling Order.
A proposed order that references an attached decision must include that decision, and all proposed orders must be filed electronically.
Court's wording
(h) Proposed Orders. When submitting proposed orders that specifically reference an attached decision, said decision must be included therewith. ALL PROPOSED ORDERS MUST BE E-FILED. With e-filing you may also send a copy in either Word or WordPerfect format to the Court.
A proposed amended scheduling order must contain the specified language concerning the Note of Issue, dismissal from the calendar, restoration procedures, and the additional affidavit required for restoration after one year.
Court's wording
The proposed Amended Scheduling Order must contain the following language: ORDERED, that a Note of Issue and Statement of Readiness is to be filed on or before __________, 202__. FAILURE OF THE PLAINTIFF TO FILE A NOTE OF ISSUE AND CERTIFICATE OF READINESS BY THE DATE PROVIDED HEREIN WILL RESULT IN THIS MATTER BEING DEEMED STRICKEN "OFF" THE COURT'S CALENDAR WITHOUT FURTHER NOTICE PURSUANT TO 22 NYCRR § 202.27. If so dismissed, the case may be restored without motion within one year of such dismissal by: (1) the filing of a Note of Issue and Certificate of Readiness; and, (2) the forwarding of a copy thereof with a letter requesting restoration to the Court's Assignment Clerk. Also, restoration after one year shall, before the filing of a Note of Issue and Certificate of Readiness, require the additional documentation of a sworn affidavit by a person with knowledge showing a reasonable excuse for the delay, a meritorious cause of action, a lack of prejudice to the defendant, and the absence of intent to abandon the case. 7
The opposing party or parties shall complete the relevant information below not already completed and submit at least two (2) days in advance of the scheduled conference.
This statement shall be prepared by the party requesting the preliminary conference and submitted – on notice to the opposing party or parties - concurrently with the RJI for cases already assigned to Justice Doyle, or within seven (7) days of notification from chambers that the case has been assigned to Justice Doyle and the conference has been scheduled.
The failure to comply with this Order shall waive any trial objections to the proposed testimony, and result in the preclusion of any non-designated testimony.
objections to deposition testimony shall be made in writing and provided to the Court and opposing counsel no later than seven (7) days prior to the Pretrial Conference scheduled herein, or will be deemed waived.
Each party must submit a concise but comprehensive trial memorandum addressing every anticipated question of law, with copies of cited cases attached.
Court's wording
Each party shall submit a trial memorandum of law to the Court and opposing counsel. The memorandum shall be brief, but comprehensive, and must address each question of law that the party expects to arise at trial. Copies of the cases cited in the memorandum shall be attached thereto.
Any objections thereto shall be made in writing and provided to the Court and opposing counsel no later than seven (7) days prior to the Pretrial Conference scheduled herein, or will be deemed waived.
The failure to comply with this Order shall waive any trial objections to the proposed video testimony.
Each party shall provide the Court with a copy of any proposed video-recorded testimony along with a transcript thereof.
Each party must mark its exhibits and submit a list identifying all exhibits and those stipulated into evidence.
Court's wording
Each party shall mark all exhibits (numbers for plaintiff; letters for defendant) and shall submit to the Court and opposing counsel a list of all such exhibits indicating which exhibits are stipulated into evidence.
Copies of the cases cited in the application’s supporting Memorandum of Law must be attached thereto.
Each party shall submit any motions in limine and a memorandum that addresses each question of law or unique evidentiary issue that the party expects to arise at trial.
When requesting a settlement conference, the parties consent to the Court receiving an ex parte position on settlement from each party.
A statement of material facts is optional, but if submitted it must cite the exhibits supporting the alleged facts.
Court's wording
Consistent with long-standing practice, such Statements are not mandated. Should counsel choose to submit a statement of material facts, citations to the exhibits supporting alleged facts are required.
Defendants completing this section should list any counterclaims and, if alleged in the answer, any laws or regulations.
Court's wording
Brief Description of Defendant’s Defenses and any Counterclaims: (to be completed by Defendant(s)- please include a list of any counterclaims. Should any laws or regulations be alleged in the answer, please list those as well.)
All parties are herein ordered to consult with each other and, to the extent possible, enter into a stipulation governing the authenticity and admissibility of all exhibits.
Exhibits not listed in accordance herewith may be excluded at trial
This Rule does not apply to portions of deposition testimony and corresponding video recording to be used solely for impeachment or credibility purposes
Any motions in limine submitted prior to the Pre-Trial Conference shall be decided at the conference.
A Pre-trial Conference will be conducted on January 12, 2027 at 10:00 a.m., at which time counsel shall submit to the Court a list of all exhibits not previously provided.
Filing & Service rules
Electronic Filing Rules
All cases must be filed electronically unless an appropriate exception applies.
All cases must be e-filed unless an appropriate exception applies.
Civil cases
Page 2 | I. Appearance and Communication by Counsel
Counsel appearing in e-filed cases must register their appearance and provide current contact information in NYSCEF.
In e-filed cases, all counsel must register their appearance in the case in the New York State Courts Electronic Filing (NYSCEF) system and provide up-to- date contact information in NYSCEF.
Civil cases
Page 2 | I. Appearance and Communication by Counsel
In e-filed cases, correspondence to the court must be e-filed and paper copies are unnecessary.
In e-filed cases, all correspondence to the Court (e.g., letters to the Court) shall be e-filed. There is no need to send paper copies to the Court.
Civil cases
Page 2 | I. Appearance and Communication by Counsel
Counsel must immediately notify the Court if their contact information changes.
Counsel shall notify the Court immediately should their contact information change.
Civil cases
Page 2 | I. Appearance and Communication by Counsel
The requesting party must not electronically file the Case Information Statement and must email it to clerkins@nycourts.gov.
Please DO NOT e-file the case information statements; they must be emailed to clerkins@nycourts.gov.
Civil cases
Page 3 | II. Pretrial Conferences
Opposing counsel must provide a Case Information Statement to the court and opposing party within seven days after receiving the initial statement, and must email rather than e-file it.
Opposing counsel shall complete a Case Information Statement and provide to the Court and opposing party within seven (7) days of receipt of the initial Case Information Statement. Please DO NOT e-file the case information statements; they must be emailed to clerkins@nycourts.gov.
Civil cases
Page 3 | II. Pretrial Conferences
Ex parte settlement-position submissions must be emailed to tdonaher@nycourts.gov and awallen@nycourts.gov.
Submissions shall be no longer than five (5) pages, exclusive of any submitted exhibits, and shall be emailed to the law clerks at tdonaher@nycourts.gov and awallen@nycourts.gov.
Civil cases
Page 4 | III. Settlement Conferences and Mediation Orders
All proposed orders must be filed electronically.
ALL PROPOSED ORDERS MUST BE E-FILED.
Civil cases
Page 7 | Proposed Orders
The Case Information Statement must not be electronically filed and must instead be emailed to the court clerk.
DO NOT e-file the statement; please email to clerkins@nycourts.gov.
Civil cases
Page 11 | APPENDIX A
Motions in limine and their supporting memoranda of law must be electronically filed.
Motions and any supporting memorandum of law shall be e-filed.
Civil cases
Page 20 | General Rules
Requests to charge and proposed verdict sheets must be submitted by email in Word or WordPerfect format, with a copy provided to opposing counsel.
requests to charge and proposed verdict sheets shall be filed and submitted in electronic mail to tdonaher@nycourts.gov or awallen@nycourts.gov in either Word or Wordperfect format, with a copy provided to opposing counsel.
Civil cases
Page 20 | General Rules
All Orders to Show Cause and supporting memoranda of law must be electronically filed.
All OTSCs and supporting memorandums of law must be e-filed.
Civil cases
Page 20 | General Rules
Filing Timing and Cure Windows
Each party must submit an ex parte settlement position at least 48 hours before the scheduled conference, excluding weekends.
At least forty-eight (48) hours prior to any scheduled conference (exclusive of weekends) each party shall submit, ex parte, their positions on settlement.
Civil cases
Page 4 | III. Settlement Conferences and Mediation Orders
Unless otherwise noted, e-filing in cases subject to e-filing and governed by a court-imposed deadline must be completed by 4:00 p.m. on the deadline date.
For e-filed cases, and when the Court imposes a filing deadline, that e-filing MUST be completed by 4:00 p.m. on the day in question unless otherwise noted.
Civil cases
Page 5 | IV. Local Commercial Rules — RULE #’s 4 & 21 - Electronic Submission of Papers / Courtesy Copies
Unless the court directs otherwise or a briefing schedule has been set, reply papers are due 24 hours before the motion return-date time.
Unless otherwise directed by the Court, and to augment CPLR 2214 (b), reply papers are due twenty-four (24) hours before the return date time (unless a briefing schedule has been previously set).
Civil cases
Page 6 | IV. Local Commercial Rules — (c) Reply Papers
If the parties do not comply with the discontinuance-filing requirement, the Court may order them to file the stipulation within 14 days after issuance of that order.
Failure to comply with this provision will lead to the Court issuing an order directing the parties to file a stipulation of discontinuance within fourteen (14) days of the issuance of the order.
Civil cases
Page 10 | V. Case Disposition
A stipulation of discontinuance must be filed with the Clerk or electronically within 60 days after notice to the Court that the case settled or was discontinued.
Should the case end with a stipulation of discontinuance, such stipulation must be filed with the Clerk (or e-filed) within 60 days of the notification to the Court that the case has settled or been discontinued.
Civil cases
Page 10 | V. Case Disposition
Any Order to Show Cause or motion must be submitted to the court no later than fourteen days before trial.
any Order to Show Cause or Motion must be submitted to this Court no later than fourteen (14) days prior to the trial.
Civil cases
Page 20 | General Rules
Responses and objections to motions in limine must be submitted seven days before the Pretrial Conference or they will be deemed waived.
Responses and objections thereto shall be submitted seven (7) days prior to the Pretrial Conference scheduled herein, or will be deemed waived.
Civil cases
Page 20 | General Rules
The opposing parties' completed Case Information Statement is due at least two days before the scheduled conference.
The opposing party or parties shall complete the relevant information below not already completed and submit at least two (2) days in advance of the scheduled conference.
Civil cases
Page 11 | APPENDIX A
For cases already assigned to Justice Doyle, the requesting party's Case Information Statement is due concurrently with the RJI; for newly assigned cases, it is due within seven days after chambers' notification and conference scheduling.
This statement shall be prepared by the party requesting the preliminary conference and submitted – on notice to the opposing party or parties - concurrently with the RJI for cases already assigned to Justice Doyle, or within seven (7) days of notification from chambers that the case has been assigned to Justice Doyle and the conference has been scheduled.
Civil cases
Page 11 | APPENDIX A
Untimely applications will not be considered absent a showing of good cause.
Untimely applications will not be considered by this Court except upon a showing of good cause
Civil cases
Page 20 | General Rules
Service and Proof of Service Rules
The moving party must serve the motion return date on any party not participating in electronic filing.
In cases in which a party is not participating in e-filing, the motion return date must be served upon that party by the party bringing the motion.
Civil cases
Page 6 | IV. Local Commercial Rules — (b) Form of Motion Papers and return dates
Courtesy Copy Requirements
In non-e-filed cases, parties appearing at the first scheduled conference must provide the court copies of their pleadings 48 hours before the conference.
For non-e-filed cases, parties appearing at the first scheduled conference shall provide the Court copies of their pleadings forty-eight (48) hours prior to the scheduled conference.
Civil cases
Page 3 | II. Pretrial Conferences
A courtesy copy of deposition testimony for witnesses intended to be called through deposition must be provided to the court.
The list shall identify witnesses the party expects to call in person and those intended to be called through deposition. A courtesy copy of such deposition testimony for the Court is required.
Civil cases
Page 18 | APPENDIX C — STANDARD TRIAL ORDER
Chambers ordinarily does not want courtesy hard copies, although the Court may individually request one copy.
Chambers does NOT want courtesy hard copies, but the Court retains the discretion, on an individualized basis, to request one (1) courtesy hard copy.
Civil cases
Page 5 | IV. Local Commercial Rules — RULE #’s 4 & 21 - Electronic Submission of Papers / Courtesy Copies
Filing Bundling Requirements
Exhibits must be uploaded individually rather than bundled into one PDF and must include a short description of the actual item.
Exhibits uploaded to NYSCEF must be done on an individualized basis [not all in one PDF] with a short description of the actual item [not just a repetition of the Exhibit letter or number].
Civil cases
Page 5 | IV. Local Commercial Rules — RULE #’s 4 & 21 - Electronic Submission of Papers / Courtesy Copies
Pre-Motion Conference Requirements
If parties cannot resolve discovery disputes, they must attend a court conference, held by Teams upon letter or email request, before motion practice will be entertained.
However, should the parties be unable to resolve discovery disputes, the Court requires a conference to potentially resolve the issue(s) prior to motion practice. Discovery disputes will be held via a Teams conference upon a letter request or email request. If the matter still cannot be resolved, only then will motion practice be entertained.
Civil cases
Page 8 | RULE # 14 - Disclosure Disputes.
The Court prefers in-person motion argument but will schedule a virtual argument when one or more parties submit a written application explaining the need.
The Court prefers to hear oral argument of motions in person but will schedule a virtual argument on written application by one or more parties outlining the need for a virtual appearance.
Civil cases
Page 6 | IV. Local Commercial Rules — (b) Form of Motion Papers and return dates
Motions are decided on submission unless a party requests oral argument by separate letter or email and explains why oral argument is necessary.
All motions will be on submissions unless a party requests oral argument, by separate letter or e-mail, setting forth the request for oral argument and the reasons oral argument is necessary.
Civil cases
Page 6 | IV. Local Commercial Rules — (b) Form of Motion Papers and return dates
With these principles in mind, counsel should endeavor to resolve all discovery disputes without the need for motion practice and must “meet and confer” prior to contacting the Court with discovery disputes.
With these principles in mind, counsel should endeavor to resolve all discovery disputes without the need for motion practice and must “meet and confer” prior to contacting the Court with discovery disputes.
Civil cases
Page 8 | RULE # 14 - Disclosure Disputes.
Adjournment & Extension Requirements
A request to extend or amend the Scheduling Order must be made by letter to the Court, with notice to opposing counsel, at least ten business days before the affected date, and must include a proposed amended scheduling order.
A request for extension or amendment of the Scheduling Order MUST be made by letter request to the Court, on notice to opposing counsel, at least ten (10) business days in advance of the date to be extended, and it also MUST be accompanied by a proposed Amended Scheduling Order.
Civil cases
Page 7 | RULE # 13 - Adherence to Discovery Schedule.
Extensions of the scheduling-order deadlines require written good cause, at least ten business days’ notice to opposing counsel, and an accompanying proposed amended scheduling order.
ORDERED, that any extensions of the above deadlines will be granted only upon the showing of good cause, set forth in writing, and on notice to opposing counsel, at least ten (10) business days in advance of the date to be extended. That writing must be accompanied by a proposed Amended Scheduling Order; and it is further
Civil cases
Page 16 | APPENDIX B — SAMPLE SCHEDULING ORDER
A conference adjournment request must be made in writing or by email with notice to all parties, and the court retains discretion whether to grant it.
Requests for adjournment of the conference must be made in writing (email is acceptable) on notice to all parties. Adjournment of scheduled conferences is in the discretion of the Court.
Civil cases
Page 4 | II. Pretrial Conferences
A motion adjournment request must be written and served on notice, although email may be used for the request.
Adjournment requests must be in writing on notice. Requests by email are acceptable.
Civil cases
Page 6 | IV. Local Commercial Rules — (g) Adjournment of Motions
Chambers Communication Rules
Letter applications are required for pretrial conference requests in cases involving pro se parties or cases not filed electronically.
For cases in which there are parties appearing pro se, or cases that are not e-filed, letter applications are required.
Civil cases
Page 2 | II. Pretrial Conferences
Except for permissible ex parte matters, all parties must be included in email communications with chambers staff.
With the exception of permissible ex parte matters, all parties must be included in email communications with the law clerk or secretary.
Civil cases
Page 2 | I. Appearance and Communication by Counsel
Counsel must notify the Court within seven days after trial scheduling if a trial-date conflict exists, by letter on notice to all parties, and must provide at least four proposed alternative dates.
Counsel must confirm with their clients and witnesses their availability for the scheduled trial date and inform the Court within seven (7) days of the date the trial was scheduled if there is a conflict with the scheduled trial date. Such notification shall be by letter, on notice ===== PAGE 10 ===== to all parties, and shall include proposed dates where their clients and witnesses are available. At least four proposed dates shall be provided.
Civil cases
Page 9 | Pre-Trial Conference
When in-person attendance is required, a request to appear by phone must be made in writing, with email accepted at the listed addresses.
When the Court indicates that in-person attendance is required, any request for a party or representative to appear by phone MUST be made to the Court in writing (e- mail is acceptable to: tdonaher@nycourts.gov, awallen@nycourts.gov, and clerkins@nycourts.gov.)
Civil cases
Page 9 | Pre-Trial Conference
Parties must promptly respond to chambers scheduling communications or the conference may proceed without the non-responding party’s input.
All parties are expected to promptly respond to communications from chambers regarding scheduling. Failure to respond will lead to the conference being scheduled without the non-responding party’s input.
Civil cases
Page 3 | II. Pretrial Conferences
Parties should contact the Court when an exhibit must be submitted confidentially or in a format that cannot be uploaded to NYSCEF.
For exhibits that are to be submitted confidentially or in a format that cannot be uploaded to NYSCEF, please contact the Court.
Civil cases
Page 5 | IV. Local Commercial Rules — footnote 6
A pretrial conference may be requested by contacting the court, preferably by email to chambers staff with all parties copied.
A conference may be scheduled for cases assigned to Justice Doyle by contacting the Court to request a conference, preferably by email to the law clerks and secretary, copying in all parties.
Civil cases
Page 2 | II. Pretrial Conferences
Counsel may communicate with the judge's law clerks and secretary by email.
Counsel is free to communicate by email with the law clerks and secretary.
Civil cases
Page 2 | I. Appearance and Communication by Counsel
A request for a pretrial conference may be made by letter.
Requests made by letter are also acceptable.
Civil cases
Page 2 | II. Pretrial Conferences
Copies of pleadings may be emailed to the two listed chambers addresses and the clerk’s email address.
Copies of pleadings may be sent to tdonaher@nycourts.gov, awallen@nycourts.gov, and clerkins@nycourts.gov.
Civil cases
Page 3 | II. Pretrial Conferences
Should the parties wish to conduct a settlement conference, please contact chambers to request a conference date.
Should the parties wish to conduct a settlement conference, please contact chambers to request a conference date.
Civil cases
Page 4 | III. Settlement Conferences and Mediation Orders