Judge Lynn R. Kotler
Individual Rules, Standing Orders & Policies
- Rules last changed:
Limits & Logistics
Document Limits
Courtesy Copies
Proposed Order
Court-wide
Adjournments
- A consented appearance adjournment requires a stipulation signed by all appearing parties, submitted by fax, email, or NYSCEF by 2:00 p.m. the preceding day, and remains subject to court approval.
- Parties seeking an extension of the note-of-issue deadline should confer, set deadlines for all outstanding discovery in a written stipulation submitted for court approval, and request the extension.
Request must include
- An unconsented adjournment request must be filed at least 48 hours before the hearing, describe the efforts to obtain consent and their results, and will not be considered if submitted later than that deadline.
Communication
Phone
Court-widePhone
Court-wideClerk
Phone
Court-wideClerk
Document Format Requirements1 rule
All parties are encouraged to have their exhibits pre-marked by the court reporter.
Document Filing Requirements12 rules
After joinder and filing of a preliminary-conference request, the parties must confer about discovery and submit a proposed preliminary conference order through NYSCEF and email.
Court's wording
Within a reasonable time after issue has been joined and a preliminary conference request has been filed, the parties shall meet and confer regarding a preliminary discovery schedule, which shall be memorialized in a Proposed Preliminary Conference Order that shall be presented to the court to be so ordered by filing on NYSCEF and via email to the Part Clerk.
Any party opposing the motion shall submit a counterstatement of material facts.
- Document
- Counterstatement of material facts
Must include
- •Statement of facts
A summary-judgment movant, except under CPLR 3213, must attach a separate and concise numbered statement of undisputed material facts.
Court's wording
Upon any motion for summary judgment, other than a motion made pursuant to CPLR 3213, the movant shall annex to the notice of motion a separate, short and concise statement, in numbered paragraphs, of the material facts as to which the moving party contends there is no genuine issue to be tried.
c. a witness list;
a. marked pleadings;
g. proposed jury verdict sheet (if applicable);
e. pretrial memoranda (if applicable);
b. the bill of particulars;
d. expert disclosures;
f. proposed jury instructions (if applicable);
h. a one paragraph summary of the parties’ contentions.
Note of issue should not be filed unless discovery is complete.
Filing & Service rules
Electronic Filing Rules
The proposed preliminary conference order must be filed on NYSCEF and emailed to the Part Clerk for entry as an order.
Within a reasonable time after issue has been joined and a preliminary conference request has been filed, the parties shall meet and confer regarding a preliminary discovery schedule, which shall be memorialized in a Proposed Preliminary Conference Order that shall be presented to the court to be so ordered by filing on NYSCEF and via email to the Part Clerk.
Civil cases
Page 1 | II. Conferences
The parties must promptly and continuously notify the court in writing through NYSCEF and email when specified case-changing events occur.
If an action is discontinued, or wholly or partially settled by stipulation, a motion has become wholly or partially moot, or a party has died or become a debtor in bankruptcy, the parties promptly shall notify the court in writing of such an event. This is a continuing obligation, and such notification shall be made in writing to the court via filing on NYSCEF and email to the Part Clerk or Chambers staff (Uniform Civil Rules for the Supreme Court and the County Court § 202.28[a]).
Civil cases
Page 1 | I. General
A consented adjournment stipulation may be delivered to the court by fax, email, or NYSCEF filing.
A court appearance may be adjourned on consent, provided all parties who have appeared in the action sign a stipulation to that effect and deliver it to court via fax, email or filing on NYSCEF by 2:00 p.m. the day before the appearance is scheduled.
Civil cases
Page 2 | V. Adjournments
Audio or video exhibits should be delivered by USB to the Part 8 courtroom or by cloud link emailed to the principal court attorney by the motion submission date.
Electronic copies of exhibits such as audio or video should be submitted to the court on a USB drive delivered to the Part 8 Courtroom at 80 Centre Street, Room 278, or via cloud service with a link to the exhibit emailed to Aryeh Roskies, Esq., at aroskies@nycourts.gov, on or before the motion submission date.
Civil cases
Page 2 | IV. Motions
Filing Timing and Cure Windows
A consented adjournment stipulation must be delivered by 2:00 p.m. on the day before the scheduled appearance.
A court appearance may be adjourned on consent, provided all parties who have appeared in the action sign a stipulation to that effect and deliver it to court via fax, email or filing on NYSCEF by 2:00 p.m. the day before the appearance is scheduled.
Civil cases
Page 2 | V. Adjournments
A written discovery-completion stipulation may be filed without a future compliance conference only if it reaches the court by email or NYSCEF by 2:00 p.m. on the day before the scheduled appearance.
This stipulation must be sent to the court via email or filing on NYSCEF by 2:00 p.m. the day before the appearance is scheduled.
Civil cases
Page 3 | VII. Note of Issue
Service and Proof of Service Rules
An attorney notified of an appearance must notify all other parties by email of the assigned hearing date and time.
Pursuant to Uniform Civil Rules for the Supreme Court and the County Court § 202.23(c), “each attorney who receives notification of an appearance on a specific date and time is responsible for notifying all other parties by email that the matter is scheduled to be heard on that assigned date and time.”
Civil cases
Page 1 | I. General
A temporary-restraint application must include proof of advance adversary notice identifying when, where, and how the application will be presented, or a reasonable explanation for omitting notice.
If a party seeks a temporary restraint in an Order to Show Cause, they MUST provide proof that their adversary was notified about the application and the time, date and manner that the application will be presented for signature or provide a reasonable explanation why such advance notice cannot be provided.
Civil cases
Page 2 | III. Orders to Show Cause
Courtesy Copy Requirements
Working copies of e-filed motions are not required and should not be delivered to the part.
“Courtesy” or working copies of e-filed motions are not required and should not be delivered to the part.
Civil cases
Page 2 | IV. Motions
Pre-Motion Conference Requirements
Reply papers may not be submitted on an order to show cause without the court’s advance permission.
Pursuant to Uniform Civil Rules for the Supreme Court and the County Court § 202.8-d: “[m]otions shall be brought on by order to show cause only when there is genuine urgency (e.g., applications for provisional relief), a stay is required or a statute mandates so proceeding (see Section 202.8-e). Absent advance permission of the court, reply papers shall not be submitted on orders to show cause.”
Civil cases
Page 2 | III. Orders to Show Cause
To the maximum extent possible, discovery disputes should be addressed through informal conferences rather than motion practice.
Pursuant to the Uniform Civil Rules for the Supreme Court and the County Court § 202.20-f: “[t]o the maximum extent possible, discovery disputes should be resolved through informal procedures, such as conferences, as opposed to motion practice.”
Civil cases
Page 1 | II. Conferences
Motions ordinarily are submitted without oral argument unless rescheduled case by case, and oral argument is typically held Tuesday.
Motions will be submitted without argument or rescheduled for oral argument on a case-by-case basis. Oral argument is typically held on a Tuesday.
Civil cases
Page 2 | IV. Motions
Advance court permission is not required before filing a motion.
Advance permission to bring any motion is not required.
Civil cases
Page 2 | IV. Motions
Adjournment & Extension Requirements
An unconsented adjournment request must be filed at least 48 hours before the hearing, describe the efforts to obtain consent and their results, and will not be considered if submitted later than that deadline.
If there is no consent to a request for an adjournment of a court appearance, requests for adjournments shall be transmitted in writing to the court and to all parties via filing on NYSCEF, so as to be received no later than 48 hours before the hearing and shall set forth the efforts made to obtain the consent of all parties and the results thereof (see Uniform Civil Rules for the Supreme Court and the County Court § 202.23). Requests for adjournments not on consent made less than 48 hours before the scheduled date will not be considered, and counsel must appear on the scheduled date to make an oral application for the adjournment.
Civil cases
Page 2 | V. Adjournments
A consented appearance adjournment requires a stipulation signed by all appearing parties, submitted by fax, email, or NYSCEF by 2:00 p.m. the preceding day, and remains subject to court approval.
A court appearance may be adjourned on consent, provided all parties who have appeared in the action sign a stipulation to that effect and deliver it to court via fax, email or filing on NYSCEF by 2:00 p.m. the day before the appearance is scheduled. The stipulation is still subject to court approval, and it must include: 1) the reason for the adjournment, 2) the date the case was last on, and 3) the date by which the Note of Issue must be filed.
Civil cases
Page 2 | V. Adjournments
Parties seeking an extension of the note-of-issue deadline should confer, set deadlines for all outstanding discovery in a written stipulation submitted for court approval, and request the extension.
If the parties need an extension of the note of issue deadline, they should meet and confer and set deadlines for all outstanding discovery in a written stipulation to be so ordered by the court and request an extension of the deadline to file note of issue.
Civil cases
Page 3 | VII. Note of Issue
Chambers Communication Rules
Ex parte communications are prohibited unless they concern scheduling, administration, or emergencies, and all sides must be copied on written communications to the court.
Ex parte communications that are not for scheduling, administrative or emergency purposes are not permitted. All sides must be carbon copied on written communications to the court.
Civil cases
Page 1 | I. General
The court will not consider letters or emails requesting affirmative relief unless exigent circumstances exist.
Letters or emails seeking affirmative relief may not be considered absent exigent circumstances.
Civil cases
Page 1 | I. General
The court ordinarily does not issue rulings by telephone.
The court does not routinely make rulings via telephone.
Civil cases
Page 1 | I. General
If good-faith efforts do not resolve a discovery dispute, the parties may request a virtual conference by filing and emailing a letter outlining the issues and each party's position.
If the parties are unable to agree on a preliminary discovery schedule, or a dispute arises during discovery that they are unable to resolve despite good faith efforts to do so (see Uniform Civil Rules for the Supreme Court and the County Court § 202.20-f [b]), they may request a virtual conference Last updated 12/18/25 ===== PAGE 2 ===== with the court via written letter filed on NYSCEF and emailed to the Park Clerk outlining the issue(s) and the parties’ positions.
Civil cases
Page 2 | II. Conferences