Judge Conrad D. Singer
Individual Rules, Standing Orders & Policies
- Rules last changed:
Limits & Logistics
Document Limits
Courtesy Copies
Motion
Adjournments
- An EBT adjournment request must be uploaded to NYSCEF and emailed to the Court with all counsel copied at least three business days before the deposition date, and must state the basis, proposed firm dates, and whether all parties consent.
- Unless an emergency exists, the conference-adjournment form must reach Chambers at least two business days in advance.
Communication
Chambers
Phone
Clerk
Phone
Clerk
Phone
Chambers
Page & Word Limits3 rules
A trial memorandum not to exceed 5 pages, setting forth your party's position, the relevant factual and legal issues to be tried, and citing all relevant statutes and/or case law with copies attached;
- Trial memorandum
- Up to 5 pages
A trial memorandum not to exceed 5 pages, setting forth your party's position, the relevant factual and legal issues to be tried, and citing all relevant statutes and/or case law with copies attached
- Trial memorandum
- Up to 5 pages
A memorandum not to exceed 5 pages, setting forth your party's position, the relevant factual and legal issues and citing all relevant statutes and/or case law with copies attached;
- Memorandum
- Up to 5 pages
Document Format Requirements6 rules
Motion papers must comply strictly with Uniform Rule 202.8-b's length requirements, and noncompliance may result in sanctions including striking the motion papers.
Court's wording
Parties are directed to review Section 202.8-b of the Uniform Rules for the Supreme Court and County Court, eff February 1, 2021, regarding the length of motion papers. This rule must be adhered to strictly. Lawyers who ignore or disobey this rule may be subject to sanctions including, but not limited to, the striking of all their papers on the motion.
Such shall be emailed to chambers at judgesingerremote@nycourts.gov in Word or Word Perfect, as well as provided to chambers on paper;
Formatting
- •Word or Word Perfect format
- •Paper copy provided to chambers
Proposed jury verdict sheet in Word or Word Perfect **emailed to chambers at judgesingerremote@nycourts.gov, as well as provided to chambers on paper;**
- Proposed jury verdict sheet
Formatting
- •Word or Word Perfect format
- •Emailed to chambers
- •Paper copy provided to chambers
All exhibits over 25 pages must be Bates stamped;
- Exhibits
- More than 25 pages
Formatting
- •Bates stamped
All exhibits over 25 pages must be Bates stamped
- Exhibits
- More than 25 pages
Formatting
- •Bates stamped
Unless otherwise noted, at least three (3) business days before jury selection, counsel shall provide the Court with printed copies (in a binder) of the following papers and documents
- Trial papers
Formatting
- •Printed copies in a binder
Document Filing Requirements9 rules
All discovery motions must contain an affirmation of good faith that strictly complies with 22 NYCRR 202.7(c). Failure to comply will result in denial of the motion.
All applications shall be calendared on the date returnable. Appearance by all parties is mandatory unless advised otherwise by the Court.
Absent court approval, all motions in limine shall be in writing.
Adjournments requested due to an attorney's actual engagement on trial must be accompanied by an Affirmation of Engagement in conformity with 22 NYCRR Part 125.
Proposed deliberation jury charges should contain the exact requested language for each jury charge.
Where the testimony has been transcribed, page references will be required.
THE PARTIES SHALL BE REQUIRED TO FORTHWITH PROVIDE A TRANSCRIPT OF THE ENTIRE TRIAL.
The Court will not accept medical reports/affidavits executed more than six months prior to the submission date.
Applications shall be limited to issues regarding the admissibility of evidence.
Filing & Service rules
Electronic Filing Rules
Written notice of settlement, discontinuance, mootness, death, or bankruptcy must be electronically filed with a courtesy copy emailed to the court.
Such written notice is to be e-filed, with a courtesy copy emailed to judgesingerremote@nycourts.gov.
Page 2 | Appearances
Counsel must promptly notify the court in writing through NYSCEF when a motion or part of it has been resolved, withdrawn, or rendered moot.
Counsel must advise the Court, in writing (upload to NYSCEF), as soon as practicable, if any submitted or unsubmitted motion, or portion thereof, has been resolved, withdrawn, or rendered moot because the case is settled, or an issue is otherwise resolved.
Page 5 | Motions
The conference-adjournment form must be completed in full, list mutually acceptable Monday, Tuesday, or Thursday dates, be uploaded to NYSCEF, and be emailed to the chambers address with all counsel copied.
Potential dates amenable to all parties must be provided on the adjournment request form (requested adjourn dates should be restricted to Monday, Tuesday or Thursday) which is to be completed in its entirety and uploaded to NYSCEF with a copy emailed to judgesingerremote@nycourts.gov with all counsel copied.
Page 6 | Requests to Adjourn Motions and Conferences
Motion in limine papers must be served, filed in NYSCEF, and provided to chambers on paper six business days before trial.
All motions in limine with copies of all case law and statutory law attached. Such shall be served on all adversaries, filed in NYSCEF **and provided to chambers on paper**, 6 business days before the trial begins.
Page 9 | Non Jury Trials
Filing Timing and Cure Windows
A Certification Conference must occur before the note of issue is filed, no later than 90 days before its filing date, and in compliance with the applicable timetable.
A Certification Conference will be held prior to the filing of a note of issue. The Certification Conference will be held no later than 90 days before the date fixed for the filing of the note of issue and in compliance with the standard and goals timetable accompanying the PC Order.
Page 3 | Certification Conference
The Compliance Conference must be held no later than 60 days before the scheduled completion of discovery.
The Compliance Conference date will be set down in the Preliminary Conference Order and must be held no later than 60 days before the date scheduled for the completion of discovery (22 NYCRR §202.19[b][3]).
Page 3 | Compliance Conference
The Compliance Conference may not be held later than the deadline in the Standards & Goals timetable accompanying the Preliminary Conference Order.
In no event shall the Compliance Conference be held later than the deadline set forth in the Standards & Goals timetable accompanying the PC Order (provided by DCM).
Page 3 | Compliance Conference
A summary-judgment motion must be filed within 60 days after the Note of Issue unless the court grants leave for good cause.
a motion for summary judgment shall be **filed** no later than sixty (60) days after the filing of the Note of Issue, except with leave of court on good cause shown.
Page 4 | MOTIONS: Submission of Motions
The Trial Worksheet schedule must be followed strictly, and failure to do so may waive all motions in limine.
The schedule outlined in the "Trial Worksheet" shall be strictly adhered to. Failure to adhere to such may constitute a waiver of any and all motions in limine.
Page 5 | Submission of Motions
A motion for summary judgment must be filed within 60 days after the note of issue is filed.
Motions for summary judgment shall be filed no later than 60 days after the filing of a note of issue.
Page 5 | Summary Judgment
Requests left merely on Chambers voicemail are disregarded, and no adjournment is granted until Chambers receives the form and approves it.
Adjournment requests which are left on the Chamber's Voice Mail shall be disregarded. An adjournment request is not granted until the form is received by chambers and the adjournment is approved by Chambers.
Page 6 | Requests to Adjourn Motions and Conferences
Unless otherwise noted, counsel must provide the Court with binder copies of the listed trial papers and email copies to the adversary at least three business days before jury selection.
Unless otherwise noted, at least three (3) business days before jury selection, counsel shall provide the Court with printed copies (in a binder) of the following papers and documents (counsel shall also email copies to their adversary):
Page 7 | Trials
Opposition papers are due four business days before jury selection, and reply papers are due three business days before jury selection.
All opposition papers are due 4 business days before jury selection and reply papers are due 3 business days before jury selection.
Page 8 | Trials
Reply papers on motion in limine are due three business days before trial.
reply papers are due 3 business days before the trial starts
Page 9 | Non Jury Trials
A Note of Issue must be filed before trial begins.
the filing of a Note of Issue is a condition precedent to the commencement of any trial.
Page 9 | Non Jury Trials
Opposition papers on motion in limine are due four business days before trial.
All opposition papers are due 4 business days before the trial starts
Page 9 | Non Jury Trials
A note of issue must be filed before any hearing or inquest begins.
the filing of a note of issue is a condition precedent to the commencement of any hearing or inquest.
Page 10 | Hearings/Inquests
A complaint is subject to dismissal when the note-of-issue filing deadline passes without a filed note of issue.
If the deadline for filing a note of issue (NOI) has passed and the note of issue has not been filed, the complaint will be subject to dismissal.
Page 11
Service and Proof of Service Rules
Compromise applications must be submitted through Special Term with proof of service on all remaining parties.
All applications for court approval of a proposed compromise of an infant or other disabled party's claim must be submitted through the Special Term, with proof of service on all remaining parties.
Page 10 | Compromise Applications
Trial papers must also be emailed to the opposing party.
counsel shall also email copies to their adversary
Page 9 | Non Jury Trials
Courtesy Copy Requirements
A courtesy hard copy of the listed trial materials must be provided to the court in a binder.
Court with a courtesy hard copy (in a binder) of the following:
Page 11
The Court will notify counsel when courtesy hard copies of motion papers or legal authorities are required.
The Court will notify counsel if a courtesy hard copy of motion papers and/or case law/statutory law is required.
Page 4 | MOTIONS: Submission of Motions
Filing Bundling Requirements
A trial conference must be held immediately before every nonjury trial.
A trial conference with the Court shall be held immediately prior to the commencement of all trials.
Page 9 | Non Jury Trials
Court with a courtesy hard copy (in a binder) of the following:
Court with a courtesy hard copy (in a binder) of the following:
Page 11
Pre-Motion Conference Requirements
Sur-reply papers addressing a motion's merits are prohibited without advance permission, except for a letter identifying a relevant post-submission court decision without additional argument.
Absent express permission in advance, sur-reply papers including correspondence, addressing the merits of a motion are not permitted, except that counsel may inform the court by letter of the citation of any post-submission court decision that is relevant to the pending issues, but there shall be no additional argument.
Page 4 | MOTIONS: Submission of Motions
A cross-motion set beyond the original motion's return date does not adjourn the original motion.
Submission of a cross-motion with a stated return date that is beyond the return date of the original motion will not serve to adjourn the original motion.
Page 5 | Cross-Motions
Discovery motions may not be filed without prior court approval.
Such motions may not be filed without approval from the Court.
Page 5 | Discovery Motions
Before involving the court or filing a discovery motion, parties must meet and confer through a genuine exchange rather than a one-sided letter or threat.
Regarding discovery disputes, parties are required to meet and confer before involving the court or making a motion (Rule 202.20-f). It is the policy of this Part to not accept letters as good faith efforts, unless a series of letters indicates an interaction among counsel, and not just a one-sided statement or threat.
Page 6 | Discovery in General
Counsel should endeavor, where feasible or possible, to coordinate a motion's return date with an already scheduled Part conference or the return date of a previously filed motion.
In the event a case is already scheduled for a conference with this Part, counsel should endeavor to coincide the return date of a motion, where feasible, with the previously scheduled conference. Where a motion is previously filed, any subsequent movants shall endeavor to coincide the return date(s) of any such subsequently filed motions, where possible.
Page 5 | Motions
Adjournment & Extension Requirements
Compliance Conference adjournments are permitted only for compelling reasons and require the Court's prior approval.
Adjournments will only be granted for compelling reasons. No Compliance Conference may be adjourned without prior approval of the Court.
Page 3 | Compliance Conference
A Certification Conference may not be adjourned without court permission.
There shall be no adjournments of Certification Conferences without the permission of the court.
Page 4 | Certification Conference
An application adjournment will not be considered or granted without a consent stipulation signed by all parties and any nonparty alleged contemptor and received by noon on the preceding day.
No adjournments will be considered or granted unless a stipulation consenting to the adjournment, signed by all parties and any alleged contemptor who is not a party, is received in Chambers no later than 12:00 p.m. of the day prior to the return date.
Page 5 | Writs and Contempts
Except for PC, DCM, and Central Jury appearances, conference adjournments may be requested only through Chambers using the court's adjournment-request form.
Adjournment requests of Conferences (excluding PC/DCM/Central Jury appearances) may only be sought through Chambers by completing the adjournment request form located on the Court website with the Part Rules.
Page 6 | Requests to Adjourn Motions and Conferences
Court-ordered deposition dates may not be moved to a later date without prior court approval.
Depositions are court-ordered pursuant to the PC Order. Deposition dates specified in the PC Order or any other Order may not be adjourned to any later date without prior court approval.
Page 6 | Requests to Adjourn Discovery Deadlines
A motion-adjournment request must first seek the adversary's consent; consented requests should be uploaded to NYSCEF, while a nonconsenting party may request a law-clerk conference by phone or in person.
If an adjournment of a motion is being requested, parties must first seek the consent of their adversary. If the adjournment is on consent, a stipulation or letter regarding the adjournment should be uploaded to NYSCEF. If the adversary does not consent, a conference with the law clerk, either by phone or in person, can be requested.
Page 6 | Requests to Adjourn Motions and Conferences
Unless an emergency exists, the conference-adjournment form must reach Chambers at least two business days in advance.
Absent emergency, all forms must be submitted to chambers at least 2 business days in advance.
Page 6 | Requests to Adjourn Motions and Conferences
Discovery deadlines in the Preliminary Conference Order cannot be adjourned without prior court permission.
No adjournments of discovery deadlines set forth in the Preliminary Conference Order shall be permitted without prior Court permission.
Page 6 | Requests to Adjourn Discovery Deadlines
An EBT adjournment request must be uploaded to NYSCEF and emailed to the Court with all counsel copied at least three business days before the deposition date, and must state the basis, proposed firm dates, and whether all parties consent.
uploading the Part's Adjournment Request form to NYSCEF and e-mailing judgesingerremote@nycourts.gov with all counsel copied at least three business days before the scheduled deposition date. Counsel requesting the adjournment must state a reasonable basis for the request, a proposed new deposition schedule with firm dates, and whether the request is on consent of all parties.
Page 7 | Requests to Adjourn Preliminary Conferences
An EBT adjournment request cannot proceed unless the Court grants or approves it.
Requests to adjourn EBTs are not granted until the Court grants or approves the adjournment request.
Page 7 | Requests to Adjourn Preliminary Conferences
Chambers Communication Rules
Email communication with chambers requires pre-approval, inclusion of all other parties, and use of the listed court email address; substantive emails are not permitted without pre-approval.
Email: With the pre-approval of chambers, counsel/ pro-se parties may communicate by email with chambers. An attorney / pro-se party emailing chambers must include all the other parties to the case on the email. Emails sent to the Court that contain substantive issues regarding the case are not permitted absent prior approval from chambers. Email communication should only be to the email address listed above.
Page 1 | Communication with Chambers
Substantive letters to the court require prior approval and must copy opposing counsel or pro se parties.
Letters: Except as provided herein, letters to the Court that contain substantive issues regarding the case are not permitted absent prior approval from the Court. Letters sent without prior approval shall be disregarded. No correspondence shall be sent to the Court without copying opposing counsel / pro-se parties with that correspondence.
Page 1 | Communication with Chambers
Counsel and self-represented litigants may not make ex parte communications to the court by telephone or letter.
The Court will not accept any ex parte communications by telephone or letter from counsel or a self-represented litigant.
Page 10 | Miscellaneous Rules
Telephone calls to chambers are permitted only for emergency situations requiring immediate attention.
**Telephone Calls:** Telephone calls to chambers are permitted only in emergency situations requiring immediate attention. In such situations only, call chambers at the above listed number.
Page 2 | Communication with Chambers
Preliminary Conference adjournment requests must be directed to the DCM Clerk's office or Preliminary Conference Part at 516-493-3100 rather than Chambers.
PC adjournment requests are to be addressed to the DCM Clerk's office or Preliminary Conference Part (telephone no. 516-493-3100), not to Chambers.
Page 7 | Requests to Adjourn Preliminary Conferences
Pretrial conference adjournment requests must be directed to the CCP/DCM Part at 516-493-3113 rather than Chambers.
Requests to adjourn pretrial conferences are to be directed to the CCP/DCM Part (telephone no. 516-493-3113), not to Chambers.
Page 7 | Requests to Adjourn Pre-Trial (DCM/CCP) Conferences
Parties should direct questions about motion return dates and adjournments to the courtroom clerk.
Parties should contact the courtroom clerk with all questions regarding return dates and adjournments on Motions.
Page 6 | Requests to Adjourn Motions and Conferences
Individual parties may contact the court to request a conference or ask about Part procedures not covered by the rules.
Individual parties may contact the Court to request a conference or to inquire about Part procedures that are not otherwise contained in these rules.
Page 10 | Miscellaneous Rules