Judge Christopher Chin
Individual Rules, Standing Orders & Policies
- Rules last changed:
Limits & Logistics
Document Limits
Courtesy Copies
Proposed Order
Court-wide
Adjournments
- An in-person conference adjournment application must include an all-parties stipulation and the reason for the request and must be sent at least 48 hours, identified as two business days, before the conference.
- A stipulated oral-argument adjournment must be uploaded and emailed to the Part 22 Clerk at least 48 hours before argument, requires court approval, and does not excuse appearance unless a judge-signed approval is uploaded.
Communication
Clerk
Phone
Clerk
Phone
Clerk
Phone
Court-widePhone
Court-widePage & Word Limits1 rule
A trial memorandum, not to exceed two (2) pages, setting forth the party’s position and relevant factual and legal issues to be tried citing relevant case law and including causes of action, and any affirmative defenses and/or counterclaims.
- Trial memorandum
- Up to 2 pages
Document Format Requirements6 rules
Hard copies shall not be submitted unless specifically directed by the court.
Formatting
- •Do not submit hard copies unless specifically directed by the court
Please write legibly in black ink. Illegible orders will not be signed.
- Compliance order
Formatting
- •Write legibly in black ink
- •Illegible orders will not be signed
If an exhibit to a motion or opposition papers include a video, be prepared to be able to show the judge the video, during argument (on your electronic device).
Please note that the court cannot access links to a video via Google Drive or OneDrive.
If any modification of the PJI is requested, the entire charge shall be typed with the proposed modification in Bold type.
For jury trials, all counsel shall email proposed jury charges and verdict sheets in Word format to Part 22’s court attorney and opposing counsel.
- Proposed jury charges
- Verdict sheet
Formatting
- •Word format
Document Filing Requirements25 rules
Any motion to vacate such a default must be brought by Order to Show Cause and must fulfill the requirements of CPLR § 5015.
Please put the names, emails, addresses and telephone numbers of all counsel appearing at the conference. If a party fails to note their appearance, a default against that party may be taken.
Motion sequence numbers shall be included on the front page of all notices of motion/cross-motion, affirmations in support or opposition and reply papers, and any stipulations or letters relating to a motion, otherwise they may not be considered to be a part of the motion.
- Document
- Motion
- Placement
- First page
Any discovery motion filed must detail the court’s authorization and an order permitting the filing of the motion shall be submitted as an exhibit.
Each affidavit or affirmation is to be its own exhibit. If more than one affidavit or affirmation is contained in an exhibit, it is likely that only the first one will be considered.
A Note of Issue may NOT be filed unless a stipulation is so-ordered certifying that discovery is complete. Improperly filed Notes of Issue may be stricken sua sponte.
The stipulation must certify that all discovery is complete and provide for the filing of a Note of Issue.
A list of proposed witnesses (including the need for any interpreters or other accommodation), the dates of availability of each witness, and the expected length of time of direct examination for each witness.
Parties are to bring a copy of the last discovery order to the status/compliance conference.
Use complete dates, including the year.
- Document
- Compliance order
Include
- •Use complete dates, including the year
A party may request oral argument on the face of the motion papers or by a single-page letter e-filed and emailed to the Part22 Clerk (with notice to all parties). Not every request for oral argument will be granted.
The letter should identify the attorney and the portion of the motion that such attorney will argue.
Any exhibit to the motion must be e-filed as a separate document and must be given an identifying label (e.g., Notice of Claim, Bill of Particulars, etc,).
In the notice of motion or early in the affirmation in support, please state the date the Note of Issue was filed and how the motion is timely.
All exhibits should be paginated, and any references to voluminous exhibits (including deposition testimony), must include pinpoint citations (i.e. page numbers).
An estimate of required trial days.
Copies of the EBT transcripts intended for use at trial during direct examination.
All marked pleadings and bills of particulars.
A copy of any statutory provisions in effect at the time the cause of action arose upon which any party relies.
For non-jury trials, a stipulation as to all undisputed/agreed upon facts.
All prior decisions in the case, including any appellate decisions.
A trial memorandum, not to exceed two (2) pages, setting forth the party’s position and relevant factual and legal issues to be tried citing relevant case law and including causes of action, and any affirmative defenses and/or counterclaims.
Most recent demand, offer and policy limits.
Such a letter may also be submitted with the opposition papers.
Two (2) business cards for each attorney.
Filing & Service rules
Electronic Filing Rules
A filed letter or stipulation must also be communicated by email because e-filing alone does not alert the judge or court staff.
Please be aware that e-filing a letter or stipulation does not automatically come to the attention of the judge or court staff. You must communicate it by email.
Civil cases
Page 1 | I. Communications with Part Clerk, DCM Coordinators, and Chambers – Including Adjournments, E
For Labor Law afternoon Preliminary Conferences, the parties may substitute an emailed proposed stipulated PC Order for an in-person appearance, but it must reach the Part Clerk by the preceding Friday and must not be uploaded to NYSCEF.
In lieu of an in-person appearance at a scheduled afternoon Preliminary Conference, the parties may submit a proposed stipulated PC Order. The proposed stipulated PC Order must be emailed to the Part Clerk at SFC-Part22- Clerk@nycourts.gov, on or before the Friday prior to the scheduled PC date and shall NOT be uploaded to NYSCEF.
Civil cases
Page 3 | I.C. LABOR LAW CASES: For afternoon Preliminary Conferences ONLY
Each summary-judgment motion exhibit must be electronically filed as a separate document and assigned an identifying label.
Any exhibit to the motion must be e-filed as a separate document and must be given an identifying label (e.g., Notice of Claim, Bill of Particulars, etc,).
Civil cases
Page 4 | III.D. Summary Judgment Motions
Motions in limine must be written, e-filed promptly or as scheduled at a pretrial conference, and copied to all parties.
Motions in limine shall be presented in writing to the court and e-filed as soon as practicable or as specifically scheduled at any pre-trial conference, with a copy to all parties.
Civil cases
Page 6 | VII. Trial Rules
Filing Timing and Cure Windows
A proposed stipulated Preliminary Conference Order must be emailed to the Part Clerk no later than the Friday before the scheduled conference.
The proposed stipulated PC Order must be emailed to the Part Clerk at SFC-Part22- Clerk@nycourts.gov, on or before the Friday prior to the scheduled PC date and shall NOT be uploaded to NYSCEF.
Civil cases
Page 3 | I.C. LABOR LAW CASES: For afternoon Preliminary Conferences ONLY
A summary-judgment motion must be filed no later than 60 days after the Note of Issue unless the court grants leave; the notice or supporting affidavit should explain timeliness, and a late motion will ordinarily be denied absent good cause.
All summary judgment motions must be made no later than 60 days after filing the Note of Issue – without leave of Court. In the notice of motion or early in the affirmation in support, please state the date the Note of Issue was filed and how the motion is timely. Absent good cause for late filing, a late motion will be denied, even if there is no objection.
Civil cases
Page 4 | III.D. Summary Judgment Motions
A cross-motion, particularly one seeking relief unrelated to the main motion, does not relate back to the filing date of the original motion.
Cross-motions, especially cross-motions seeking relief unrelated to the main motion, DO NOT relate back to the date the original motion was made.
Civil cases
Page 4 | III.D. Summary Judgment Motions
Service and Proof of Service Rules
Failure to serve a Bill of Particulars before the first DCM conference may result in the plaintiff being precluded from offering trial evidence.
If a Bill of Particulars has not been served, the first DCM order may preclude plaintiff from offering any evidence at trial.
Civil cases
Page 2 | II. Discovery Conferences
Plaintiffs must serve a Bill of Particulars before the first DCM conference.
Additionally, plaintiffs must serve a Bill of Particulars prior to the first DCM conference.
Civil cases
Page 2 | II. Discovery Conferences
Orders concerning consolidation, severance, or caption amendment must be served with notice of entry on the County Clerk and General Clerk’s Office.
All orders on motions or stipulations to consolidate, to sever claims or to amend captions shall be served with notice of entry on the County Clerk and the General Clerk’s Office in accordance with Section J of the Protocol on Courthouse and County Clerk Procedures for Electronically Filed Cases
Civil cases
Page 5 | V. Consolidation or Amendment of Captions
A copy of each motion in limine must be provided to all parties.
Motions in limine shall be presented in writing to the court and e-filed as soon as practicable or as specifically scheduled at any pre-trial conference, with a copy to all parties.
Civil cases
Page 6 | VII. Trial Rules
Pre-Motion Conference Requirements
A discovery motion requires prior court authorization, must describe that authorization, and must include the authorizing order as an exhibit.
Discovery motions may not be made without prior authorization from the court. Any discovery motion filed must detail the court’s authorization and an order permitting the filing of the motion shall be submitted as an exhibit.
Civil cases
Page 4 | III.C. Discovery Motions
Before a discovery motion, all parties must meet and confer; if unresolved, they must request a DCM discovery conference, after which the DCM order may narrow issues, authorize a motion, and set a briefing schedule.
Prior to making any discovery motion, all parties are required to first meet and confer about any issues, in accordance with 22 NYCRR § 202.7. If the parties are unable to resolve the issues, they shall request a discovery conference with the DCM Courtroom Part. If the dispute cannot be resolved at the DCM conference, the issue(s) will be narrowed, and the DCM Order will specifically allow a motion to be filed and set forth a briefing schedule.
Civil cases
Page 4 | III.C. Discovery Motions
Adjournment & Extension Requirements
An in-person conference adjournment application must include an all-parties stipulation and the reason for the request and must be sent at least 48 hours, identified as two business days, before the conference.
Applications to adjourn in-person conferences must include a stipulation executed by all parties and the reason for the adjournment and may be sent to James Metzger at jtmetzger@nycourts.gov at least 48 (2 business days) hours prior to the scheduled conference.
Civil cases
Page 2 | II. Discovery Conferences
A stipulated oral-argument adjournment must be uploaded and emailed to the Part 22 Clerk at least 48 hours before argument, requires court approval, and does not excuse appearance unless a judge-signed approval is uploaded.
If the parties have stipulated to an adjournment of the oral argument, the signed stipulation must be uploaded and emailed to the Part 22 clerk at least 48 hours prior to the oral argument date. The adjournment must be approved by the Court. If no approval is received (uploaded stipulation signed by the judge), the parties are to appear at the oral argument date.
Civil cases
Page 4 | III.B. Motion Practice
A motion may not be adjourned for more than 60 days without obtaining the court’s prior approval.
Motions cannot be adjourned for more than 60 days without prior court approval.
Civil cases
Page 4 | III.D. Summary Judgment Motions
Chambers Communication Rules
Counsel must not copy the court on letters or emails exchanged between counsel.
Do not copy the court on letters or emails exchanged between counsel.
Civil cases
Page 1 | I. Communications with Part Clerk, DCM Coordinators, and Chambers – Including Adjournments, B
Ex parte communications with the judge or law clerks are prohibited, and parties should not call or email Chambers unless specifically instructed.
No ex parte communications with the judge or law clerks. Unless specifically instructed, please do not unilaterally call or e-mail chambers.
Civil cases
Page 1 | I. Communications with Part Clerk, DCM Coordinators, and Chambers – Including Adjournments, B
Parties must not call Chambers unless specifically instructed.
Unless specifically instructed, please do not unilaterally call or e-mail chambers.
Civil cases
Page 1 | I. Communications with Part Clerk, DCM Coordinators, and Chambers – Including Adjournments, B
Please notify the Part Clerk as soon as a case settles or if all parties want a settlement conference, at any point in the litigation.
Please notify the Part Clerk as soon as a case settles or if all parties want a settlement conference, at any point in the litigation.
Civil cases
Page 1 | I. Communications with Part Clerk, DCM Coordinators, and Chambers – Including Adjournments, A
A request for a court reporter at oral argument must be emailed to the Part Clerk at least 48 hours, or two business days, before argument.
Parties requesting a court reporter for oral argument must make the request in an email to the Part Clerk at least 48 hours (2 business days) prior to the scheduled oral argument.
Civil cases
Page 3 | III.A. Motion Practice
If good-faith efforts to resolve a compliance dispute fail, the parties must immediately contact the Part Clerk by email or telephone, without filing a motion, for an in-person conference before the next compliance conference.
If the parties’ good faith efforts to resolve the dispute fail, then immediately - without making a motion - contact the Part Clerk at SFC-Part22-Clerk@nycourts.gov or (646) 386-3271, who will schedule an in-person conference in the DCM Courtroom Part to resolve the dispute before the next scheduled compliance conference.
Civil cases
Page 3 | I. Communications with Part Clerk, DCM Coordinators, and Chambers – Including Adjournments
If a motion is resolved before decision, the parties must email the law clerk a signed stipulation rather than merely electronically filing a letter or stipulation.
If a motion is resolved prior to the issuance of a decision by the court, the parties shall email the court’s law clerk, with a copy of a signed stipulation. Do not merely e-file a letter or stipulation.
Civil cases
Page 4 | III.B. Motion Practice
Early-settlement-conference issues should be directed to DCM Part Clerk James Metzger rather than the Part 22 Clerk.
Any issues concerning early settlement conferences should be addressed to James Metzger, the DCM Part clerk and not to the Part 22 clerk.
Civil cases
Page 1 | I. Communications with Part Clerk, DCM Coordinators, and Chambers – Including Adjournments, F
A DCM conference adjournment or other DCM appearance calendar issue should be raised by calling James Metzger at (646) 386-3682 or (646) 386-3683.
To request an adjournment of a conference in the DCM Part or address any other calendar issues related to a DCM appearance, please call the DCM Clerk, James Metzger, at (646) 386-3682 or (646) 386-3683.
Civil cases
Page 2 | II. Discovery Conferences
A party may request oral argument on the motion papers' face or by a single-page letter electronically filed and emailed to the Part 22 Clerk with notice to all parties, but the request is discretionary and may be denied.
A party may request oral argument on the face of the motion papers or by a single-page letter e-filed and emailed to the Part22 Clerk (with notice to all parties). Not every request for oral argument will be granted.
Civil cases
Page 3 | III.A. Motion Practice
For jury trials, counsel must email proposed jury charges and verdict sheets in Word format to Part 22’s court attorney and opposing counsel.
For jury trials, all counsel shall email proposed jury charges and verdict sheets in Word format to Part 22’s court attorney and opposing counsel.
Civil cases
Page 6 | VII. Trial Rules
The Part Clerk may be contacted by phone at (646) 386-3271 or by email at SFC-PART22-CLERK@nycourts.gov for general appearance questions.
General questions about appearances may be addressed to the Part Clerk by phone at (646) 386-3271, or email to SFC-PART22-CLERK@nycourts.gov.
Civil cases
Page 1 | I. Communications with Part Clerk, DCM Coordinators, and Chambers – Including Adjournments, D
An earlier conference may be requested by emailing SFC-Part22-Clerk@nycourts.gov.
To request a conference sooner than one that is already scheduled, please contact the Part Clerk at SFC-Part22-Clerk@nycourts.gov or (646) 386-3271.
Civil cases
Page 2 | II. Discovery Conferences
Parties may email the Part’s Law Clerk to request a conference about a stay request instead of filing a motion.
Parties may email the Part’s Law Clerk to request a conference to address a stay request in lieu of a motion.
Civil cases
Page 5 | III. Note of Issue
Junior Lawyer Participation Incentives
The court is more inclined to hold oral argument when an attorney admitted for fewer than five years, or an attorney whose participation enhances bar diversity, will argue.
A representation that the argument will be made by an attorney whose participation enhances diversity in the bar or an attorney admitted to practice fewer than five years will weigh in favor of the court deciding to hold oral argument.
Civil cases
Page 3 | III.A. Motion Practice