Judge Lisa A. Cairo
Individual Rules, Standing Orders & Policies
- Rules last changed:
Limits & Logistics
Document Limits
Courtesy Copies
All filings
Motion
Adjournments
- Adjournment requests left on chambers voicemail will be disregarded and must comply with the Part Rules.
- An adjournment request based on counsel's engagement must include an Affirmation of Engagement complying with 22 NYCRR 125.1.
- A motion-adjournment request must be written, uploaded to NYSCEF for Chambers before the motion's return date, copied to all counsel and pro se litigants, and granted only by the Court.
- +3 more
Request must include
- A conference adjournment request must be submitted in writing through NYSCEF and copied to JudgeCairoRemote@nycourts.gov at least 24 hours before the conference.
Communication
Phone
Phone
Clerk
Phone
Page & Word Limits1 rule
Except for good cause shown, no affirmation or affidavit shall exceed 20 pages.
- Affirmation or affidavit
- Up to 20 pages
- Affirmation
- Affidavit
Document Format Requirements9 rules
Should the exhibit not contain page numbers, the exhibit shall be bates-stamped.
All motion papers and Orders to Show Cause must be typewritten (minimum 12-point type), double-spaced, securely bound and entirely legible.
- Font size
- At least 12 points
- Line spacing
- Double
- Binding
- Securely bound
- Motion
Formatting
- •Typewritten
- •Entirely legible
Any submission over 1/2-inch thick must be acco-fastened, not stapled.
Formatting
- •Submissions over one-half inch thick must be acco-fastened and not stapled
Reference to exhibits longer than ten (10) pages shall indicate the page number on which the information cited is contained.
- More than 10 pages
All exhibits must be legible and labeled with external tab markings. Plaintiffs shall designate exhibits by number; Defendants shall designate exhibits by letter.
- Exhibits
Formatting
- •Legible
- •External tab markings
- •Plaintiff exhibits designated by number
- •Defendant exhibits designated by letter
Proposed Orders or Judgments shall be submitted to the appropriate clerk, uploaded to NYSCEF, and copied via email to JudgeCairoRemote@nycourts.gov in Microsoft Word format.
- File type
- Word
- Proposed order
- Judgment
The proposed verdict sheet must be submitted in the document’s stated “Microsoft World” format.
- Proposed verdict sheet
Formatting
- •Microsoft World format
Court's wording
A Proposed Verdict Sheet, jointly prepared by all counsel/pro se (self-represented) litigant(s) must be submitted by email in Microsoft World format to the Court’s remote email (JudgeCairoRemote@nycourts.gov).
Requested jury charges must be submitted in Microsoft Word format.
- File type
- Word
- Requested jury charges
Court's wording
A complete list of requested jury charges, drawn from the Pattern Jury Instructions (PJI) of the then-current year must be submitted by email in Microsoft Word format to the remote email (JudgeCairoRemote@nycourts.gov), as directed by the Court and not later than the Pre-Trial Conference.
When the parties cannot agree on jury questions, each side’s proposed verdict sheet must use the stated “Microsoft World” format.
- Proposed verdict sheet
Formatting
- •Microsoft World format
Court's wording
If counsel/pro se (self-represented) litigant(s) cannot agree to the questions to be posed to the jury prior to the Pre-Trial Conference, each side shall submit a Proposed Verdict Sheet by email in Microsoft World format to the Court’s remote email (JudgeCairoRemote@nycourts.gov).
Document Filing Requirements33 rules
All correspondence must include the title of the action and index number.
Every working copy must include a firmly fastened NYSCEF Confirmation Notice and comply with applicable e-filing rules; a working copy lacking the notice will be rejected.
Court's wording
All working copies must include a copy of the NYSCEF Confirmation Notice, firmly fastened, and must comply with all requirements of the Nassau County and Supreme Courts E- Filing Rules. The Confirmation Notice is generated when the case is e-filed and is available in the specific case file at www.nycourts.gov/efile. Working copies that do not include a NYSCEF Confirmation Notice will be rejected.
A required motion working-copy placeholder for an electronically filed voluminous exhibit must state “Exhibit ___ electronically filed.”
- Document
- Motion working copy
Must include
- •Exhibit electronically filed
Court's wording
The working copy of a motion must include all documents filed in support of the motion, excluding voluminous exhibits exceeding 20 pages in length, which shall be so indicated by use of a placeholder page stating “Exhibit ___ electronically filed.”
Counsel and pro se (self-represented) litigant(s) are not permitted to file a Note of Issue in any action unless permission to do so is granted by the Court.
After the Court conferences the matter and if the Court grants leave of court to file a discovery motion, any discovery motion must state that this procedure has been complied with.
Memoranda of Law concerning any procedural, evidentiary, or other legal issue which the parties anticipate the Court will need to determine;
A copy of all expert disclosures served pursuant to CPLR Section 3101(d) (if applicable);
On or before the Pre-Trial Conference, Plaintiff’s counsel, Defendant’s counsel (or pro se (self-represented) parties) must file via NYSCEF and provide the Court with a working copy of the following:
A Stipulation of agreed facts and/or admissible documents (if applicable);
Proposed Verdict Sheet (if applicable).
Marked pleadings in accordance with CPLR Section 4012, including copies of any exhibits incorporated by reference in the pleadings;
Any statutory provision(s) in effect at the time that the cause of action arose upon which either party intends to rely;
A copy of all prior Decisions or Orders on motions issued in the case (if applicable);
A copy of all bill(s) of particulars;
A list of probable trial witnesses;
Any anticipated request for apportionment as to alleged culpable non-parties pursuant to CPLR Article 16.
Requests to Charge (if applicable); and
An attorney or pro se party using AI to prepare a court document must submit a certification identifying the AI programs used and confirming the accuracy of the AI-created portion.
- Document
- AI prepared document
Must include
- •AI disclosure
Court's wording
An attorney or pro-se party who has used Artificial Intelligence (“AI”) to prepare any document submitted to the court must also submit a certification setting forth (i) the specific AI program(s) used in preparation of the document; and (ii) that the accuracy of the portion of the document created using AI has been confirmed.
Voluminous Exhibits exceeding twenty (20) pages in length may be provided electronically and shall be indicated in the Court’s working copy by use of a placeholder page stating “Exhibit ___ electronically filed.”
- Document
- Voluminous exhibits
Must include
- •Exhibit electronically filed
An “Emergency” Order to Show Cause requires a special affidavit based upon personal knowledge and an affirmation explaining in detail the nature of the emergency.
The movant on a motion for entry of a default judgment shall submit the Part’s annexed checklist for default judgment on the submission date.
Papers submitted for the judge's signature must identify the case and document type on the signature page.
- Document
- Papers submitted for signature
- Placement
- Signature block
Court's wording
All papers which are submitted for signature by the Court shall be identified on the signature page so that the document being signed by the Court can be identified. Example: Jones v. Jones, Index #/year, Type of Document.
Infant compromise paperwork must include the specified medical report or affidavit and applicable records, written settlement proof from defense counsel, and defense counsel's written waiver of appearance at the hearing.
Court's wording
The infant’s compromise paperwork submitted to the ICC must include, inter alia, (i) a medical report/affidavit indicating whether the injured infant plaintiff has fully recovered, and if not, the nature and extent of the injuries and anticipated future treatment, if any, and related medical records where applicable; (ii) proof of settlement of the infant’s claim from defense counsel, in writing; and (iii) defense counsel’s waiver of appearance at the Infant’s Compromise Hearing, in writing.
If the infant is fourteen years or older, an affidavit of consent from the infant must be included in the submitted papers.
Orders, judgments, counter-orders and/or counter-judgments submitted for signature on notice will be returned unsigned unless an Affidavit of Service and Notice of Settlement for a date designated in accordance with 22 NYCRR 202.48 has been included.
A proposed Infant’s Compromise Order must include the full name of the infant-plaintiff and reference therein the following:
All applications for Court approval of a proposed compromise of an infant’s claim must be submitted through the Infant’s Compromise Clerk (“ICC”).
If the parties cannot agree on jury questions before the Pretrial Conference, each side must submit its own proposed verdict sheet by email.
Court's wording
If counsel/pro se (self-represented) litigant(s) cannot agree to the questions to be posed to the jury prior to the Pre-Trial Conference, each side shall submit a Proposed Verdict Sheet by email in Microsoft World format to the Court’s remote email (JudgeCairoRemote@nycourts.gov).
A Proposed Verdict Sheet, jointly prepared by all counsel/pro se (self-represented) litigant(s) must be submitted by email in Microsoft World format to the Court’s remote email (JudgeCairoRemote@nycourts.gov).
A complete list of requested jury charges must be submitted by email in Microsoft Word format to JudgeCairoRemote@nycourts.gov no later than the Pretrial Conference.
Court's wording
A complete list of requested jury charges, drawn from the Pattern Jury Instructions (PJI) of the then-current year must be submitted by email in Microsoft Word format to the remote email (JudgeCairoRemote@nycourts.gov), as directed by the Court and not later than the Pre-Trial Conference.
A party intending to use a videotape or other video recording must submit a copy and, if applicable, its transcript to the Court at least two weeks before trial.
Court's wording
If a party intends to use a videotape at trial, that party shall submit a copy of the videotape (or other video recording) and transcript of same, if applicable, to the Court at least two (2) weeks prior to the scheduled trial date in order to allow the Court to rule on the admissibility of the videotape (or other video recording), and any Objections made during the video recording.
In jury trials involving claims of professional negligence, no later than the next trial session after the party “rests,” or such other time as the Court may direct, each party-plaintiff shall furnish the Court and all counsel with a list of proposed departures from the standards of applicable care which that party asserts were testified to by its expert(s) or other witnesses. Page references to the trial transcript are required.
After a bench decision, a party may submit a proposed order together with the transcript of the proceedings for the judge's signature.
Court's wording
Where the Court issues a Bench Decision and a party desires a written Decision or Order, the party may submit a proposed Order to the Court, together with the transcript of the proceedings at which the Bench Decision was rendered to be “So Ordered”.
Filing & Service rules
Electronic Filing Rules
Documents in mandatory e-filed cases must be filed through NYSCEF, subject to the stated opt-out and consent-withholding exceptions, and all court submissions must be electronically filed.
All documents in mandatory e-filed cases, except documents subject to the opt-out provision of Section 202.5-bb of the Uniform Rules for the New York State Trial Courts, or documents subject to e-filing in which consent is being withheld, are to be filed through the New York State Courts E-Filing System (NYSCEF). All submissions to the Court must be electronically filed.
Page 2 | II. E-Filing Rules — A. E-Filing Rules
The motion’s affidavit of service must be separately uploaded to NYSCEF before the motion is submitted.
In addition to being part of the motion papers, the affidavit of service of the motion must be separately uploaded to NYSCEF prior to submission of the motion.
Page 6 | IV.A.6
An opposing party requesting oral argument on a Temporary Restraining Order or other emergency relief must immediately, upon receiving notice required by 22 NYCRR 202.7(f), file a letter through NYSCEF and email a copy to JudgeCairoRemote@nycourts.gov, notifying all counsel and self-represented litigants.
If the opposing party requests oral argument concerning the request for a Temporary Restraining Order or other emergency relief, said request shall be made immediately upon receipt of notice required by 22 NYCRR 202.7(f) via letter uploaded to NYSCEF and email copy to JudgeCairoRemote@nycourts.gov on notice to all counsel/pro se (self- represented) litigant(s).
Page 7 | IV. Motions
Proposed orders and judgments must be submitted to the appropriate clerk, uploaded to NYSCEF, emailed to JudgeCairoRemote@nycourts.gov, and provided in Microsoft Word format.
Proposed Orders or Judgments shall be submitted to the appropriate clerk, uploaded to NYSCEF, and copied via email to JudgeCairoRemote@nycourts.gov in Microsoft Word format.
Page 8 | V. Judgments, Decisions and Orders
All correspondence to this part should be filed via NYSCEF and copied via email to JudgeCairoRemote@nycourts.gov.
All correspondence to this part should be filed via NYSCEF and copied via email to JudgeCairoRemote@nycourts.gov.
Page 1 | I. Communications with the Court — A. Correspondence
Exhibits longer than 20 pages may be filed electronically, with a placeholder in the working copy stating “Exhibit ___ electronically filed.”
Voluminous Exhibits exceeding twenty (20) pages in length may be provided electronically and shall be indicated in the Court’s working copy by use of a placeholder page stating “Exhibit ___ electronically filed.”
Page 6 | IV.A.4
Filing Timing and Cure Windows
Required working copies must be mailed or hand-delivered to chambers and received no later than the return date.
Working copies shall be mailed or hand-delivered to Chambers, to be received by Chambers no later than the return date.
Page 2 | II. E-Filing Rules — C. Working Copies
The affidavit of service must be uploaded before the motion is submitted.
In addition to being part of the motion papers, the affidavit of service of the motion must be separately uploaded to NYSCEF prior to submission of the motion.
Page 6 | IV.A.6
The requested-jury-charge list is due no later than the Pretrial Conference.
A complete list of requested jury charges, drawn from the Pattern Jury Instructions (PJI) of the then-current year must be submitted by email in Microsoft Word format to the remote email (JudgeCairoRemote@nycourts.gov), as directed by the Court and not later than the Pre-Trial Conference.
Page 9 | D. Requests to Charge
Copies of trial video recordings and applicable transcripts must be submitted to the Court at least two weeks before the scheduled trial date.
If a party intends to use a videotape at trial, that party shall submit a copy of the videotape (or other video recording) and transcript of same, if applicable, to the Court at least two (2) weeks prior to the scheduled trial date in order to allow the Court to rule on the admissibility of the videotape (or other video recording), and any Objections made during the video recording.
Page 10 | M. Use of Videotapes
Counsel must promptly notify the court in writing when a submitted or unsubmitted motion or part of it is resolved, withdrawn, or rendered moot because of settlement or another resolution.
Counsel must advise the Court, in writing, and 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 6 | IV.A.7
Service and Proof of Service Rules
Correspondence to the court must always be copied to all adversary counsel and self-represented litigants.
Correspondence to the Court shall, without exception, be copied to all adversary counsel and pro se (self-represented) litigant(s).
Page 1 | I. Communications with the Court — A. Correspondence
Courtesy Copy Requirements
A motion's chambers working copy must include all supporting filings, but voluminous exhibits exceeding 20 pages may be replaced by a specified placeholder page.
The working copy of a motion must include all documents filed in support of the motion, excluding voluminous exhibits exceeding 20 pages in length, which shall be so indicated by use of a placeholder page stating “Exhibit ___ electronically filed.”
Page 2 | II. E-Filing Rules — C. Working Copies
Counsel and self-represented litigants must provide chambers with working copies of legal papers requiring judicial action.
Counsel and pro se (self-represented) litigant(s) must provide working copies of all legal papers which require judicial action (e.g., motions, notices of settlement, ex parte applications and proposed orders).
Page 2 | II. E-Filing Rules — C. Working Copies
Sealing & Redaction Procedures
A case or any portion of a case may not be sealed without a showing of good cause.
No case or portion thereof shall be sealed unless good cause has been adequately shown (22 NYCRR 216.1).
Page 2 | II. E-Filing Rules — E. Sealing Orders
Pre-Motion Conference Requirements
After a good-faith effort fails, the attorney must contact the court by letter describing the discovery dispute and the attempted resolution efforts.
If counsel cannot resolve the discovery issue between themselves after a good faith effort, then the counsel who believes that discovery is not being conducted in accordance with the Court’s Order is to contact the Court by letter (see Rule I[A], supra), to advise of the nature of the dispute and the efforts that have been made to attempt to resolve it.
Page 4 | D. Compliance with Preliminary Conference Orders
A party may not file a discovery motion without first attempting to resolve the discovery dispute.
The parties are not to make any motion concerning discovery without having first attempted to resolve the issue.
Page 4 | D. Compliance with Preliminary Conference Orders
A discovery motion may not be submitted unless the required conference has occurred.
There shall be no submitted discovery motions in the absence of a Conference (see Rule III(C) above).
Page 7 | IV.C. Discovery Motions
Unless extremely unusual circumstances causing detailed significant prejudice apply, the party presenting an Order to Show Cause requesting a Temporary Restraining Order or other emergency relief must notify opposing counsel or parties at least 24 hours before presentation and advise them of their right to be heard; in a true emergency, the Court may dispense with notice.
Unless there are extremely unusual circumstances in which significant prejudice (set forth in detail in a supporting affidavit/affirmation) will result, opposing counsel or parties are to be advised at least 24 hours in advance of the date and time that any Order to Show Cause which includes a request for a Temporary Restraining Order or other emergency relief is being presented to the Court in accordance with 22 NYCRR 202.7(f) and is to be advised that he/she has the right to be heard on the application. In a true emergency, the Court, in its discretion may dispense with the 24-hour notice requirement.
Page 7 | IV. Motions
Adjournment & Extension Requirements
A conference adjournment request must be submitted in writing through NYSCEF and copied to JudgeCairoRemote@nycourts.gov at least 24 hours before the conference.
A request to adjourn a conference must be made in writing, by uploading to NYSCEF and copy to JudgeCairoRemote@nycourts.gov at least twenty- four (24) hours in advance of the scheduled conference.
Page 3 | B. Adjournment of Conferences
An adjournment request based on counsel's engagement must include an Affirmation of Engagement complying with 22 NYCRR 125.1.
Adjournments requested because of engagement of counsel must be accompanied by an Affirmation of Engagement in conformity with 22 NYCRR 125.1.
Page 3 | B. Adjournment of Conferences
Every adjournment application must state the reason, whether opposing parties consent or object, and the requested duration or a mutually available consent date.
All applications for adjournments must set forth: (1) the reason why an adjournment is necessary; (2) whether the opposing party(ies) consent(s) or object(s) to the application; and (3) the length of the adjournment sought or, if on consent, a date all parties are available.
Page 3 | B. Adjournment of Conferences
A motion-adjournment request must be written, uploaded to NYSCEF for Chambers before the motion's return date, copied to all counsel and pro se litigants, and granted only by the Court.
A request to adjourn a motion must be made in writing and transmitted to Chambers by letter uploaded to NYSCEF, prior to the return date of the motion, and copied to all counsel and pro se (self-represented) litigant(s). Adjournment requests may only be granted by the Court, not by stipulation of counsel.
Page 7 | IV.A. Adjournments of Motions
Every motion-adjournment request must state the current return date, necessity, opposing parties' consent or objection, requested length, and prior requests with their previously set dates.
All applications for adjournments must set forth: (1) the current return date; (2) the reason why an adjournment is necessary; (3) whether the opposing party(ies) consent(s) or object(s) to the application; (4) the length of the adjournment sought; and (5) the number of prior requests for adjournment and the dates previously set.
Page 7 | IV.A. Adjournments of Motions
Adjournment requests left on chambers voicemail will be disregarded and must comply with the Part Rules.
Adjournment requests that are left on Chamber’s voicemail shall be disregarded. All requests for adjournments shall be made in accordance with these rules.
Page 1 | I. Communications with the Court — C. Adjournment requests
An adjournment letter and any response may not advocate a substantive position and must address only why consent to the requested adjournment was declined.
The letter request and the response, if any, are not to be used to advocate a position on the substantive dispute and shall address only the reason that consent for the requested adjournment is being declined.
Page 7 | IV.A. Adjournments of Motions
Chambers Communication Rules
Preliminary Conference adjournment requests must be directed to the DCM Clerk’s office or Preliminary Conference Part at the stated telephone number.
Accordingly, PC adjournment requests are to be addressed to the DCM Clerk’s office or Preliminary Conference Part at (516) 493-3120.
Page 3 | C. Preliminary Conferences
Requested jury charges must be submitted by email to JudgeCairoRemote@nycourts.gov.
A complete list of requested jury charges, drawn from the Pattern Jury Instructions (PJI) of the then-current year must be submitted by email in Microsoft Word format to the remote email (JudgeCairoRemote@nycourts.gov), as directed by the Court and not later than the Pre-Trial Conference.
Page 9 | D. Requests to Charge
When the parties cannot agree on jury questions, each side must submit its proposed verdict sheet by email to JudgeCairoRemote@nycourts.gov.
If counsel/pro se (self-represented) litigant(s) cannot agree to the questions to be posed to the jury prior to the Pre-Trial Conference, each side shall submit a Proposed Verdict Sheet by email in Microsoft World format to the Court’s remote email (JudgeCairoRemote@nycourts.gov).
Page 9 | E. Proposed Verdict Sheet
The proposed verdict sheet must be submitted by email to JudgeCairoRemote@nycourts.gov.
A Proposed Verdict Sheet, jointly prepared by all counsel/pro se (self-represented) litigant(s) must be submitted by email in Microsoft World format to the Court’s remote email (JudgeCairoRemote@nycourts.gov).
Page 9 | E. Proposed Verdict Sheet
Court staff may be called by telephone only for urgent situations requiring immediate attention.
Telephone calls to Court staff are permitted only in urgent situations requiring immediate attention.
Page 1 | I. Communications with the Court — B. Telephone Calls
Parties ordinarily may not copy correspondence between themselves to the court, except in circumstances expressly provided by the Part Rules.
Correspondence between counsel and/or pro se (self-represented) litigant(s) shall not be copied to the Court except in the limited circumstances provided within these Part Rules.
Page 1 | I. Communications with the Court — A. Correspondence
The party must contact opposing counsel and advise the Part Clerk or Court staff by telephone as soon as possible.
contact opposing counsel, and advise the Part Clerk or Court staff, by telephone, as soon as possible.
Page 3 | Court Conferences
Communications concerning the adjournment request must be copied to all counsel and all pro se litigants.
All such communications must be copied to all counsel and pro se (self-represented) litigants.
Page 3 | B. Adjournment of Conferences
General e-filing questions may be directed to the E-Filing Resource Center by telephone or email.
General questions about e-filing should be addressed to the E-Filing Resource Center at (646) 386-3033 or nyscef@nycourts.gov.
Page 1 | II. E-Filing Rules — A. E-Filing Rules
Orders are posted on NYSCEF and ordinarily are not sent to attorneys unless urgently needed.
Copies of orders are posted on NYSCEF and will not be sent to attorneys unless there is an urgent need for an order to be provided.
Page 2 | II. E-Filing Rules — D. Court Orders
A party may provide a concise reason for objecting to an adjournment request by email to JudgeCairoRemote@nycourts.gov.
A party objecting to an adjournment request may succinctly provide the reason for objecting via email to JudgeCairoRemote@nycourts.gov
Page 3 | B. Adjournment of Conferences