Judge Dana M. Catanzaro
Individual Rules, Standing Orders & Policies
Limits & Logistics
Document Limits
Courtesy Copies
Proposed Order
Court-wide
Adjournments
- A Note of Issue extension may be requested by letter emailed to the Part 37 address, explaining the need for additional time, identifying prior extensions, and stating whether all parties consent.
Request must include
- An adjournment request must be emailed to the Part 37 Clerk with all parties copied at least two business days before the scheduled appearance, and an unconsented request must state good cause.
Communication
Clerk
Phone
Clerk
Phone
Chambers
Phone
Court-widePhone
Court-wideDocument Filing Requirements9 rules
Proposed orders must be signed by all parties, submitted as an attachment to an email and sent to sfc-part37-clerk@nycourts.gov with all parties cc’d on the email. Ex-parte emails are not permitted and will not receive a response.
Parties filing discovery motions must include a separate affirmation of good faith (22 NYCRR §202.7).
The discovery motions filed must include a copy of the letter/email/correspondence to the Court.
An attorney or party using a generative AI tool must review the resulting paper and certify by signing that it contains no fabricated or fictitious material.
- Document
- Paper
Must include
- •AI disclosure
Court's wording
Any attorney or party who uses a generative AI tool, as defined in 22 NYCRR 161.2(b), in preparing any paper, as defined in 22 NYCRR 161.2(c), filed in or submitted to this court or served on another party in a case before this court is required to carefully review the paper and independently ensure that it contains no fabricated or fictitious cases, statutes, or other material. By signing such paper, an attorney or party certifies that such a review has been conducted and that the paper contains no such fabricated or fictitious content.
A request for temporary restraint in an Order to Show Cause must provide proof of advance notice to all parties or a reasonable explanation for why advance notice could not be provided.
Court's wording
If a party seeks a temporary restraint in an Order to Show Cause, they must comply with 22 NYCRR §202.7-f, providing proof that all parties were notified about the application and the time, date and manner that the application will be presented, or provide a reasonable explanation why such advance notice cannot be provided.
At the pretrial conference, parties must serve and submit a witness list, proposed jury instructions and verdict sheets in Word format, prior dispositive decisions, and all marked pleadings and bills of particulars to the Part 37 email.
Court's wording
The parties shall serve and submit the following to the Part 37 email (sfc-part37@nycourts.gov) as directed at the Pre-Trial Conference. 1. Witness list (to include any interpreters needed) 2. Proposed jury instructions in Word format with PJI numbers 3. Proposed Jury Verdict Sheets in Word format 4. Copies of all prior dispositive decisions on the case, including but not limited to any appellate decisions and any preclusion decisions 5. All marked pleadings and bills of particulars
An Order to Show Cause is required for specified statutory, stay, or emergency-interim-relief proceedings; the proposed order must provide for service of responsive papers, and reply papers are prohibited without express court permission.
- Document
- Order to show cause
Must include
- •Proposed order
Court's wording
A motion or special proceeding shall only be initiated by Order to Show Cause, where required by statute, a stay is required or where emergency interim relief is sought. Any proposed Order to Show Cause shall include a provision for the service of responsive papers, with a space reserved for the date and method of service, which will be filled in by the Court. Reply papers are not permitted except by express permission of the Court.
Oral argument is ordinarily held in person on Tuesdays; a party must submit a letter to the Part 37 Clerk copying all parties to request oral argument when the Court has not scheduled it.
Court's wording
Oral argument on motions will be held on Tuesdays IN PERSON unless otherwise indicated. Not all motions will be scheduled for oral argument. If the Court has not scheduled a motion for oral argument and a party wishes to request oral argument, they must submit a letter to the Part 37 Clerk, copying all parties on the matter. If after reviewing the request, the Court determines that oral argument is warranted, the parties will be notified of an oral argument date. Motions submitted on default or without opposition are generally not scheduled for oral argument.
Once a trial is assigned to Part 37, the Court shall schedule a Pre- Trial Conference. Parties must be prepared to discuss the case fully, including: their position on liability and damages; prior dispositive decisions; any and all settlement attempts; anticipated pre-trial rulings; the number of witnesses and whether language interpreters or special accommodations will be needed.
Filing & Service rules
Electronic Filing Rules
Parties must not e-file proposed conference orders; the Part Clerk will upload the signed orders to NYSCEF.
Do not e-file proposed orders on NYSCEF. The Part Clerk will upload the signed orders to NYSCEF.
Page 1 | II. CONFERENCES
Part 37 generally requires mandatory electronic motion filing, except for a pro se litigant or a showing of undue hardship.
Part 37 is a mandatory e-filing part. Absent a pro se litigant or a showing of undue hardship, all motions must be electronically filed with the General’s Clerk Office.
Page 2 | III. MOTION PRACTICE
Correspondence must not be uploaded to NYSCEF.
Additionally, no correspondence should be uploaded to NYSCEF.
Page 1 | I. GENERAL/COMMUNICATION WITH THE COURT
Filing Timing and Cure Windows
Parties may avoid a conference appearance by submitting a proposed conference order at least one day before the conference.
The parties may submit a proposed conference order at least one day prior to the conference date in lieu of appearing.
Page 1 | II. CONFERENCES
A summary judgment motion must be filed no later than 120 days after filing the Note of Issue.
Motions for summary judgment must be filed no later than one hundred and twenty (120) days after the Note of Issue is filed.
Page 2 | III. MOTION PRACTICE
Failure to timely file the Note of Issue or request additional time may result in disposition of the action.
The failure to file the Note of Issue by a given date or to timely request an extension and/or move for additional time may result in the action being disposed.
Page 3 | V. NOTE OF ISSUE
Motions in limine must be served and filed by 5 p.m. on the next business day after the pre-trial conference.
C. Motions in Limine: Motions in Limine shall be served and filed no later than 5 pm on the next business day following the pre-trial conference with opposition papers served and filed no later than 5pm on the next business day.
Page 5 | C. Motions in Limine
Service and Proof of Service Rules
Parties seeking a judicial subpoena must email the documents for review and an attorney affirmation explaining why the subpoena is necessary to sfc-part37-clerk@nycourts.gov, copying only the parties to the action.
Parties seeking a judicial subpoena must include the documents for review and an attorney affirmation giving the reasons why a judicial subpoena is necessary. The documents must be emailed as attachments to sfc-part37-clerk@nycourts.gov with only the parties to the action copied.
Page 4 | VI. JUDICIAL SUBPOENAS
Motion and opposition papers, if any, must also be emailed to the Part 37 email address with all parties copied.
In addition to filing the Motions in Limine, motion papers and opposition papers (if any) must also be emailed to the Part 37 email with all parties copied.
Page 5 | C. Motions in Limine
Pre-Motion Conference Requirements
After the required conference, a party may file a discovery motion concerning the issues identified in its conference letter.
Following a conference with the Court, as outlined above, parties may file discovery motions regarding the issues outlined in the aforementioned letter to the Court.
Page 2 | III. MOTION PRACTICE
Before filing a discovery motion other than a motion to vacate the Note of Issue, a party must first request a conference by submitting an email letter copied to all parties, explaining the anticipated motion in no more than two pages and detailing prior good-faith efforts to resolve the dispute.
A party seeking to make a discovery motion (other than motions to vacate the Note of Issue) must first request a conference with the Court by submitting a letter to sfc-part37-clerk@nycourts.gov, with all parties copied, stating the reason for the anticipated motion (not to exceed two [2] pages in length). In addition, parties intending to make a discovery motion are to detail the good faith efforts made in advance to resolve the discovery dispute.
Page 2 | III. MOTION PRACTICE
Discovery motions must include a good-faith showing of efforts made or attempted to resolve the dispute through in-person, virtual, or telephone conferences; email exchanges alone are insufficient.
and dates the parties met and conferred in person, virtually, or had telephone conversations to resolve the motion issue. Email attempts or communications between the parties are insufficient to satisfy an affirmation of good faith. Discovery motions filed without a showing of good faiths efforts made or attempted to resolve the matter will be denied.
Page 3 | III. MOTION PRACTICE
Every Order to Show Cause must first be processed by the Ex Parte Motion Office, and the movant should confirm processing and submission to Chambers before asking the Part Clerk about its status.
All Orders to Show Cause must first be processed by the Ex Parte Motion Office. A movant should first contact the Ex Parte Motion Office to ensure that the Order to Show Cause has been processed and submitted to Chambers before inquiring with the Part Clerk about the status of the Order to Show Cause.
Page 4 | VII. ORDERS TO SHOW CAUSE AND SPECIAL PROCEEDINGS
The Court encourages parties to resolve discovery disputes without filing motions.
The Court encourages parties to resolve discovery disputes without motion practice.
Page 2 | III. MOTION PRACTICE
Adjournment & Extension Requirements
An adjournment request must be emailed to the Part 37 Clerk with all parties copied at least two business days before the scheduled appearance, and an unconsented request must state good cause.
Parties requesting an adjournment must e-mail the Part 37 Clerk sfc-part37-clerk@nycourts.gov no later than 5 p.m. two (2) business days prior to the scheduled appearance date, with all parties cc’d. If the adjournment request tin on consent of all parties, the e-mail should indicate as such. If all parties do not consent to the adjournment, the party seeking the adjournment must set forth good cause for the adjournment request.
Page 3 | IV. ADJOURNMENT REQUESTS
A Note of Issue extension may be requested by letter emailed to the Part 37 address, explaining the need for additional time, identifying prior extensions, and stating whether all parties consent.
The Note of Issue date given on the Preliminary Conference Order will govern, unless an extension for good cause is requested and granted. An extension of time to file the Note of Issue may be requested via letter, to be So Ordered by the Court. The letter shall be emailed to the Part 37 email (sfc-part37@nycourts.gov) and shall explain why additional time is needed, indicate whether any prior extensions were granted and advise as to whether the request is on consent of all parties.
Page 3 | V. NOTE OF ISSUE
Chambers Communication Rules
A party seeking a good-cause discovery stay during summary judgment practice must request a conference by emailed letter stating the filing date and sequence number of the summary judgment motion and briefly explaining why discovery should be stayed.
A party seeking to stay discovery for good cause must request a conference with the Court by letter. The letter is to be submitted by email and include when the summary judgment motion was filed, the sequence number of the motion and briefly state the reasons why discovery should be stayed.
Page 2 | III. MOTION PRACTICE
Do not contact chambers about adjournment requests or appearance questions.
Please DO NOT contact chambers regarding adjournment requests or questions concerning appearances.
Page 1 | I. GENERAL/COMMUNICATION WITH THE COURT
Chambers may be telephoned only for an emergency and only after the Part Clerk cannot be reached.
Telephone calls to Chambers are only permitted in emergency situations and after being unable to reach the Part Clerk.
Page 1 | I. GENERAL/COMMUNICATION WITH THE COURT
Unless instructed otherwise, emails to the Court or Part Clerk must copy every party, include the purpose, index number, and case name in the subject line, and identify the sender and represented party.
Unless otherwise instructed, all emails sent to the Court or to the Part Clerk must carbon copy (cc) all parties in the action, and the subject line must include the purpose of the email, the index number, and case name. E-mails should also identify the sender and the party the sender represents.
Page 1 | I. GENERAL/COMMUNICATION WITH THE COURT
Noncompliant and ex parte emails to the Court are prohibited and will receive no response.
E-mails sent to the Court not following these instructions, including ex-parte e-mails, are not permitted and will not receive a response.
Page 1 | I. GENERAL/COMMUNICATION WITH THE COURT
Telephone the Part Clerk only during the stated business hours and only for matters not addressed elsewhere in the standing order.
Telephone calls should be made only to the Part Clerk during the business hours of 9:30 a.m. to 12:50 p.m. and 2:15 p.m. to 4:30 p.m. and limited to matters otherwise not explained below.
Page 1 | I. GENERAL/COMMUNICATION WITH THE COURT
If the parties wish to conference with the Court, at any time, they mail email the Part Clerk to schedule an appearance.
If the parties wish to conference with the Court, at any time, they mail email the Part Clerk to schedule an appearance.
Page 2 | II. CONFERENCES