Judge Anar Rathod Patel
Individual Rules, Standing Orders & Policies
- Rules last changed:
Limits & Logistics
Document Limits
Courtesy Copies
Proposed Order
Court-wide
Adjournments
- A dispositive-motion adjournment request must be written, noticed to the other parties, filed on NYSCEF at least 48 hours before the return date, and include the required scheduling and consent information.
- An appearance adjournment request must be written, noticed to the other parties, filed on NYSCEF at least 48 hours before the appearance, and include specified information while attempting to obtain all parties' consent.
Communication
Other Contacts3 contacts
Chambers1 contacts
Page & Word Limits3 rules
Thirty (30) days after receiving the transcript, the parties shall submit post-trial briefs of up to 7,000 words (excluding caption, table of contents, table of authorities, and signature blocks). Thirty days (30) thereafter, the parties may file reply briefs of up to 4,200 words (subject to the same exclusions).
- Post-trial brief
- Up to 7,000 words
- Reply brief
- Up to 4,200 words
Excluded from word count
- •Caption
- •Table of contents
- •Table of authorities
- •Signature block
All parties so served may serve and file a letter response, not to exceed two (2) pages, via NYSCEF, within two (2) business days from service of the notification letter.
- Letter
- Up to 2 pages
the parties shall meet and confer to jointly prepare a brief statement—not to exceed two (2) pages—describing the facts of the case and the contentions of the parties
- Brief
- Up to 2 pages
Document Format Requirements2 rules
The Virtual Evidence Courtroom accepts PDF documents only; non-PDF materials must be identified by a slipsheet and delivered to the court on a labeled USB flash drive.
- File type
- Proposed exhibits
Formatting
- •Non-PDF documents may not be uploaded to the Virtual Evidence Courtroom
Court's wording
The Virtual Evidence Courtroom does not accept non-PDF documents. Should any party seek to file non-PDF documents (e.g., Excel, videos), the party is directed to file a slipsheet identifying the exhibit notation and provide the underlying file(s) to the Court on a USB flash drive with the case caption / index number denoted.
Proposed Jury Instructions and Verdict Sheets, including the text of relevant PJI instructions, should be submitted by e-mail to Chambers (sfc-Part45@nycourts.gov) in Word format.
- File type
- Word
- Proposed jury instructions
- Verdict sheets
Formatting
- •The submissions should be sent by email to Chambers
Document Filing Requirements8 rules
The affirmation must also disclose whether the applicant has ever been, or is presently, subject to disciplinary proceedings.
A proposed deviation from the form confidentiality stipulation requires a proposed order, a redline against the form, and a letter explaining the reasons for the deviation.
Court's wording
If the parties propose to deviate from the form Stipulation, the parties shall file (1) a copy of the parties’ proposed confidentiality order; (2) a redline of the parties’ proposed order to the form Stipulation; and (3) a letter to the Court articulating the reasons for such deviations.
Every pro hac vice admission request, including a stipulated request, must include the specified supporting affidavits, a recent good-standing certificate, and a proposed order.
- Document
- Pro hac vice motion
Must include
- •Proposed order
Court's wording
Requests for admission pro hac vice, including requests by stipulation, shall be accompanied by an affirmation in support by a member of the Bar of the State of New York, an affirmation from the applicant, a recent certificate of good standing for the applicant, and a proposed order for each motion.
A motion to seal or redact must include a good-cause memorandum, a personal-knowledge affidavit, a proposed order identifying each NYSCEF document, and a detailed sealing/redacting spreadsheet.
- Document
- Order to show cause
Must include
- •Proposed order
Court's wording
A movant must submit the following materials in conjunction with the proposed Order to Show Cause: 1. Memorandum of law stating the basis of the purported good cause to seal or redact each document or piece of information, citing applicable law, supporting authority, and referring to each document by the corresponding NYSCEF Docket Number. 2. Affidavit based on personal knowledge (i.e., not an attorney affidavit based on information and belief) attesting to the factual bases for sealing or redaction and referring to each document by the corresponding NYSCEF Docket Number; 3. Proposed order identifying each document by NYSCEF Docket Number to be sealed/redacted; 4. Sealing/redacting spreadsheet that clearly identifies: (a) each document sought to be sealed or redacted with the corresponding NYSCEF Docket Number; (b) the categorization of each document; (c) whether movant seeks to seal or redact the document; (d) the proposed good faith basis to seal or redact; and (e) citations to applicable authority supporting good cause to seal/redact.
All opposing papers shall include a response to the Statement of Undisputed Facts that comply with Commercial Division Rule 19-a.
- Document
- Opposition
Must include
- •Statement of facts
Before the Preliminary Conference, the parties must jointly submit a two-page-or-less statement, a proposed Preliminary Conference Order using the Court's form, and a Commercial Division Rule 10 Certification via NYSCEF at least two days before the conference.
Court's wording
A. Preliminary Conference: Pursuant to Commercial Division Rules 8 and 11, prior to the scheduled Preliminary Conference, the parties shall meet and confer to jointly prepare a brief statement—not to exceed two (2) pages—describing the facts of the case and the contentions of the parties and a proposed Preliminary Conference Order, using this Court’s form Preliminary Conference Order. The parties shall submit the joint statement, proposed Preliminary Conference Order, and Commercial Division Rule 10 Certification at least two (2) days prior to the date of the scheduled preliminary conference via NYSCEF.
Exhibits and Exhibit Charts: Each side must provide an exhibit chart that conforms to Addendum 1 attached to these Practices and Procedures (Template for Exhibit Chart).
Absent a specific request, the Court does not require working copies of documents.
Filing & Service rules
Electronic Filing Rules
Communications with the Court must be written, filed on NYSCEF, and simultaneously delivered to all counsel or self-represented parties.
All communications with the Court shall be in writing and filed on NYSCEF, with copies simultaneously delivered to all counsel or self-represented parties.
Page 2 | III.A. Letters
In e-filing cases, all documents and submissions—including motion papers, letters, proposed orders, and proposed judgments—must be electronically filed on NYSCEF.
All documents in e-filing cases must be filed on NYSCEF. All submissions to the Court, including motion papers, letters, proposed orders, and proposed judgments must be electronically filed on NYSCEF.
Page 2 | IV.A. E-Filing and Working Copies
All motions must comply with Commercial Division Rules 16–18; sur-replies and post-submission papers are not permitted without Court permission, and all motion papers, exhibits, and unpublished opinions must be uploaded to NYSCEF.
A. General: All motions shall be made in accordance with Commercial Division Rules 16, 17, and 18. Absent permission from the Court, sur-reply and post-submission papers are not permitted. All motion papers and accompanying documents, including exhibits and unpublished opinions, must be uploaded to NYSCEF.
Page 4 | VIII. Motions, A. General
The parties must submit and upload to NYSCEF the consolidated transcript, applicable post-trial memoranda, and any other documents required to complete the appellate record.
F. Post-Trial: In accordance with the schedule set by the Court, the parties must submit and upload to NYSCEF: (1) a consolidated transcript of the proceeding; (2) for non- jury trials, post-trial memoranda as set forth below; and (3) and any other document required to complete the record for purposes of any appeal.
Page 8 | XI.F. Post-Trial
Proposed exhibits, exhibit charts, witness lists, and other trial-preparation documents should be uploaded to the Virtual Evidence Courtroom, except proposed jury instructions and verdict sheets.
A Virtual Evidence Courtroom will be set up in NYSCEF for each trial/hearing. All proposed exhibits, exhibit charts, and proposed witness lists should be uploaded to the Virtual Evidence Courtroom. With the exception of proposed jury instructions and verdict sheets, all documents in preparation for any trial/evidentiary hearing, including documents named in Section XI.C, infra, should be uploaded to the Virtual Evidence Courtroom.
Page 7 | XI.B. Virtual Evidence Courtroom
Filing Timing and Cure Windows
Summary-judgment motions must be served or filed within forty-five days of service or filing of the Note of Issue.
Motions for summary judgment must be served/filed within forty-five (45) days of the service/filing of the Note of Issue.
Page 5 | VIII. Motions
The listed pretrial submissions must be e-filed at least three business days before the Pre-Trial Conference, with jury charges and verdict sheets included for jury trials.
Three (3) business days prior to the Pre-Trial Conference: The parties must e-file the following: (1) pre-trial memoranda of law (including, but not limited to, claims to be resolved at trial); (2) a copy of all expert reports; (3) marked pleadings; (4) a joint statement of stipulated facts and procedural history; (5) exhibit charts and proposed exhibits as described below; (6) proposed witness lists; (7) deposition designations (jointly submitted with each side’s designations to follow the other side’s designations in page order), and (8) for jury trials, proposed jury charges and verdict sheets.
Page 7 | XI.C.2.
After a recorded appearance, the parties must obtain the transcript and file it on NYSCEF within thirty days of the appearance date.
Following all appearances conducted on the record, the parties are directed to obtain a copy of the transcript and file it on NYSCEF within thirty (30) day of the appearance date.
Page 6 | X. Conferences
Service and Proof of Service Rules
Copies of Court communications must be simultaneously delivered to all counsel or self-represented parties.
With copies simultaneously delivered to all counsel or self-represented parties.
Page 2 | III.A. Letters
A party intending to use a direct affidavit must provide a copy to the court and all parties at least three days before the witness testifies.
If the parties intend to use direct affidavits, the party must provide the Court and all parties with a copy of the affidavit at least three (3) days before the witness is scheduled to testify.
Page 8 | XI.E. Direct Affidavits
Sealing & Redaction Procedures
The movant bears the burden of demonstrating compelling circumstances to justify restricting public access.
Under applicable law, “the party seeking to seal court records has the burden to demonstrate compelling circumstances to justify restricting public access.”
Page 3 | VII. Document Sealing and Redacting Procedures, D.1
A confidentiality agreement or stipulation does not itself justify sealing or redaction; the Court independently determines whether sealing is appropriate.
The fact that the parties have a confidentiality agreement or otherwise stipulate to sealing is not sufficient to warrant sealing or redaction of specific documents. The Court has an independent obligation to determine whether sealing is appropriate.
Page 3 | VII. Document Sealing and Redacting Procedures, D.1
The Court will not entertain successive sealing or redaction motions concerning material previously permitted to be sealed or redacted by final order; the parties must submit a proposed sealing order citing the prior order.
B. Successive motions: The Court will not entertain successive motions to seal documents/information that the Court previously permitted (by final order) to be redacted or sealed; instead, the parties shall submit a proposed sealing order to the Court pursuant to Section VII generally and Section VII.D.4 (proposed order), citing to the relevant order permitting the documents/information in question to be redacted or sealed.
Page 3 | VII. Document Sealing and Redacting Procedures, B. Successive motions
Unredacted versions of putatively confidential documents must be filed on NYSCEF under the “Request to Seal” option for consideration of the Order to Show Cause.
Unredacted versions of putatively confidential documents must be filed on NYSCEF for the Court’s consideration in reviewing the Order to Show Cause. When filing the unredacted document on NYSCEF, choose the “Request to Seal” option when selecting the “Document Type.”
Page 3 | VII. Document Sealing and Redacting Procedures, C. Temporary sealing of documents pending the hearing on the Order to Show Cause
The parties may not stipulate to sealing or redaction, and sealing or redaction must be requested by an Order to Show Cause.
A. General: The parties may not stipulate to seal or redact documents or information. Motions to seal and/or redact must be made by Order to Show Cause.
Page 3 | VII. Document Sealing and Redacting Procedures, A. General
An Order to Show Cause seeking an extension of temporary sealing should request interim relief directing the Clerk to keep the identified NYSCEF document temporarily sealed and accessible only to the parties, counsel, and court personnel.
To extend the period of temporary sealing beyond fourteen days, the Order to Show Cause should include a request for interim relief as follows: “ORDERED that pending the determination on this Order to Show Cause, the Clerk of the Court is directed to maintain NYSCEF Doc. No. [Insert] temporarily under seal, accessible only to the parties, their counsel, and court personnel.”
Page 3 | VII. Document Sealing and Redacting Procedures, C. Temporary sealing of documents pending the hearing on the Order to Show Cause
Before filing a motion to seal, the movant must confer with opposing counsel and state in the memorandum of law whether the motion is opposed or unopposed.
Prior to filing a motion to seal, the movant must meet and confer with opposing counsel and indicate in its memorandum of law whether the motion is opposed or unopposed.
Page 3 | VII. Document Sealing and Redacting Procedures, A. General
Temporary sealing expires after fourteen days unless the Court orders otherwise.
The temporary sealing expires, absent court order, after fourteen days.
Page 3 | VII. Document Sealing and Redacting Procedures, C. Temporary sealing of documents pending the hearing on the Order to Show Cause
Chambers will not accept sealed or redacted documents by hard copy or email.
Chambers will not accept documents by hard copy or e-mail.
Page 4 | VII. Document Sealing and Redacting Procedures, E. Proposed Sealed or Redacted Documents
Counsel must also e-file a public copy on NYSCEF with proposed redactions in place, or a slip sheet when seeking to seal an entire document.
counsel must also e-file a public copy of each document on NYSCEF with the proposed redactions in place, or a slip sheet if seeking to seal an entire document
Page 4 | VII. Document Sealing and Redacting Procedures, E. Proposed Sealed or Redacted Documents
Every document sought to be sealed or redacted must be filed on NYSCEF under temporary seal in completely unredacted form, with proposed redactions highlighted in yellow and corresponding to the spreadsheet.
counsel must file every document sought to be sealed or redacted on NYSCEF under temporary seal in completely unredacted form with all proposed redactions highlighted in yellow, and corresponding to the sealing/redacting spreadsheet
Page 4 | VII. Document Sealing and Redacting Procedures, E. Proposed Sealed or Redacted Documents
The Court strongly encourages narrowly tailored redactions rather than sealing an entire document.
The Court strongly encourages the parties to consider narrowly tailored redactions instead of the sealing of an entire document.
Page 3 | VII. Document Sealing and Redacting Procedures, A. General
Pre-Motion Conference Requirements
Except as allowed by Commercial Division Rule 24, a party seeking a motion must file a NYSCEF pre-motion conference request on notice to all other parties, stating the motion’s basis and limited to two pages; served parties may file a response within two business days, also limited to two pages.
B. Pre-Motion Conference Required: Pursuant to Commercial Division Rule 24, any party seeking to make a motion, except as allowed by Rule 24, must file a written letter request for a pre-motion conference, on notice to all other parties, on NYSCEF. The letter request should state the basis of the anticipated motion and may not exceed two (2) pages. All parties so served may serve and file a letter response, not to exceed two (2) pages, via NYSCEF, within two (2) business days from service of the notification letter.
Page 4 | VIII. Motions, B. Pre-Motion Conference Required
Sur-replies and post-submission papers are not permitted unless the Court grants permission.
Absent permission from the Court, sur-reply and post-submission papers are not permitted.
Page 4 | VIII. Motions, A. General
A discovery motion requires a prior court conference, a written request of no more than two pages stating the meet-and-confer history and basis for the motion, and any response must be filed within two business days and may not exceed two pages.
B. Discovery Motions: For cases already assigned to this Court at the time that a discovery dispute arises, no motion with respect to the dispute shall be made without a prior conference with the Court. Any party seeking to make a discovery motion must file a written letter request, not to exceed two (2) pages, for a conference, on notice to all other parties, on NYSCEF. The letter request should state: (a) that the parties have met and conferred pursuant to Commercial Division Rule 14 and the dates of the meet and confer sessions; (b) the basis of the anticipated motion and attendant discovery-related disputes. All parties so served may serve and file a letter response, not to exceed two (2) pages, via NYSCEF, within two (2) business days from service of the notification letter.
Page 5 | IX. Discovery
Motions are submitted only unless the Court advises otherwise, and a party may request oral argument by making the stated designation.
D. Oral Argument: All motions are by submission only unless otherwise advised by the Court. Parties may request oral argument by stating “Oral Argument Requested” on
Page 4 | VIII. Motions, D. Oral Argument
Personal appearances on the return date are not required unless the Court directs an appearance.
C. Return Date: Personal appearances are not required on the return date unless directed by the Court.
Page 4 | VIII. Motions, C. Return Date
Discovery motions are discouraged, and the parties must meet and confer in good faith to resolve discovery disputes before seeking judicial intervention.
A. Rule 14 Conference: Pursuant to Commercial Division Rules 14 and 14-a, discovery motions are discouraged, and the parties shall meet and confer in good faith to resolve discovery disputes prior to seeking judicial intervention.
Page 5 | IX. Discovery
Adjournment & Extension Requirements
A dispositive-motion adjournment request must be written, noticed to the other parties, filed on NYSCEF at least 48 hours before the return date, and include the required scheduling and consent information.
Requests for an adjournment of a dispositive motion shall be made in writing at least forty-eight (48) hours prior to the return date on notice to the other parties and filed on NYSCEF. Any party seeking an adjournment must attempt to obtain consent from all other parties. Applications for adjournments must state: (1) the return date, (2) the proposed amended briefing schedule, (3) the reason for the As of April 17, 2026 request, (4) the number of prior adjournments, and (5) whether the opposing party(ies) consent(s) or object(s).
Page 1 | II.C. Requests to Adjourn a Motion
An appearance adjournment, including one agreed to by the parties, is not granted without explicit Court approval.
Absent explicit approval from the Court, the adjournment is not deemed granted, including an adjournment on consent.
Page 1 | II.B.1.
An appearance adjournment request must be written, noticed to the other parties, filed on NYSCEF at least 48 hours before the appearance, and include specified information while attempting to obtain all parties' consent.
A request for an adjournment of an appearance shall be made in writing at least forty-eight (48) hours prior to the appearance on notice to the other parties and filed on NYSCEF. Any party seeking an adjournment must attempt to obtain consent from all other parties. Applications for adjournments must state: (1) the appearance date, (2) three (3) proposed adjourned dates/times on consent, (3) the reason for the request, (4) the number of prior adjournments, and (5) whether the opposing party(ies) consent(s) or object(s).
Page 1 | II.B. Requests to Adjourn an Appearance
A dispositive-motion return date is not adjourned without explicit Court approval, even if a stipulation is filed in Submissions Part – Rm 130.
Absent explicit approval from the Court, the adjournment of the return date of a dispositive motion is not deemed granted, including a stipulation for an adjournment of motion filed in Submissions Part – Rm 130.
Page 2 | II.C.1.
Chambers Communication Rules
Self-represented parties must route all communications through the Part Clerk.
Self-represented parties must direct all communications through the Part Clerk.
Page 2 | III.B. Telephone Calls and E-mails
Ex parte communications are strictly prohibited.
Any ex parte communication is strictly prohibited.
Page 2 | III.B. Telephone Calls and E-mails
Telephone calls and emails to Chambers are permitted only when immediate attention is required.
Telephone calls and e-mails to Chambers are permitted only in situations requiring immediate attention.
Page 2 | III.B. Telephone Calls and E-mails
Proposed jury instructions and verdict sheets should be emailed to chambers in Word format, identify stipulated instructions, and include a full proposed charge and case-law memorandum if a PJI deviation is sought.
Proposed Jury Instructions and Verdict Sheets, including the text of relevant PJI instructions, should be submitted by e-mail to Chambers (sfc- Part45@nycourts.gov) in Word format. The submissions should designate the instructions to which the parties have stipulated. If a deviation from PJI instructions is sought, the parties must submit the full text of the proposed charge, together with a legal memorandum supported by case law.
Page 7 | XI.C.2.a.
Scheduling and calendar inquiries should be directed to the Part Clerk.
Inquiries regarding scheduling and calendar matters should be directed to the Part Clerk.
Page 1 | II. Scheduling
For procedural e-filing assistance, including provisional-seal filing procedures, contact the County Clerk’s Office E-File Department or Commercial Division Support Office at the listed phone numbers or email address.
For assistance with procedural e-filing issues, including the procedure for filing documents under provisional seal, please contact the County Clerk’s Office E- File Department, Room 141 B, 646-386-3737, or the Commercial Division Support Office, Room 119, 646-386-3020, SFC-CDSupport@nycourts.gov.
Page 4 | VII. Document Sealing and Redacting Procedures, F. Assistance