Judge Robert R. Reed
Individual Rules, Standing Orders & Policies
Limits & Logistics
Document Limits
Courtesy Copies
Proposed Order
Court-wide
Adjournments
- Ex parte adjournment applications will not be considered.
- Every request to adjourn an oral-argument motion, conference, or trial requires the court's prior approval.
- A stipulation requires prior approval for acceptance; failure to appear may result in default or an appropriate sanction.
- +6 more
Request must include
- A conference-adjournment application must be submitted at least 48 hours before the scheduled conference.
- Adjournment applications must be submitted at least 48 hours before the scheduled hearing or trial.
- An application to adjourn a motion scheduled for oral argument should be made at least 72 hours beforehand.
- Except in emergencies, an oral-argument motion will not be adjourned when the application is submitted fewer than 72 hours before the appearance.
Communication
Chambers
Clerk
Phone
Clerk
Phone
Court-widePhone
Court-widePage & Word Limits4 rules
At least seven days before a status conference, counsel must submit a joint case-status letter of no more than three single-spaced pages.
- Status conference joint letter
- Up to 3 pages
- Format
- Single-spaced
Court's wording
At least seven (7) days prior to the status conference, counsel shall submit a joint letter not exceeding three single-spaced pages, setting forth a summary of the case, the current schedule for completion of discovery and filing of the Note of Issue, and proposed revisions to the schedule and reasons therefor, whether there are any outstanding motions and/or appeals, and whether the parties have attempted Alternative Dispute Resolution or other efforts at settlement.
When no discovery schedule can be agreed upon, the required Rule 11(a) statement may not exceed three single-spaced pages.
- Discovery dispute statement
- Up to 3 pages
- Format
- Single-spaced
Court's wording
If the parties cannot agree on a discovery schedule, the plaintiff and any party asserting a counterclaim must submit a Commercial Division Rule 11(a) statement not exceeding three single spaced pages, setting forth the discovery dispute.
At least seven days before a compliance conference, counsel must submit a joint status letter of no more than three single-spaced pages.
- Compliance conference joint letter
- Up to 3 pages
- Format
- Single-spaced
Court's wording
At least seven (7) days prior to the compliance conference, counsel shall submit a joint letter not exceeding three single-spaced pages, setting forth the status of discovery, describing any significant disputes to be addressed at the conference, whether there are any outstanding motions and/or appeals, and whether the parties have attempted Alternative Dispute Resolution or other efforts at settlement.
The court will consider requests to enlarge applicable word limitations to facilitate the filing of combined briefs.
Document Format Requirements3 rules
All electronically submitted memoranda of law must contain bookmarks and hyperlinks pursuant to Commercial Division Rule 6.
All e-filed documents must be text-searchable.
Formatting
- •Documents must be text-searchable
Proposed jury instructions, including the text of relevant PJI Instructions, should be submitted by e-mail to Chambers (SFC-part43@nycourts.gov) in Word format.
- Proposed jury instructions
Formatting
- •Word format
Document Filing Requirements7 rules
All memoranda of law must include a Table of Contents and Table of Authorities.
Must include
- •Table of contents
Each party must comply with Commercial Division Rule 19-a by submitting a separate statement of material facts.
Must include
- •Statement of facts
No exhibits or attachments shall be included.
A sealing or redaction motion must identify the proposed categories with specificity in the spreadsheet and legal memorandum; generic categories are inadequate and generally will not establish good cause.
Court's wording
Movant’s proposed categories shall be identified with specificity in the spreadsheet and legal memoranda to facilitate issuance of a workable and efficient order; for instance, vague categories such as “confidential business information” or “proprietary trade information” are not adequate; Page 7 of 8 Revised April 2026 ===== PAGE 8 ===== examples of specifically-identified categories include “third-party borrower personal identifying information,” “pricing terms for international customers,” “investment methodologies,” “capital contribution information of private entities,” and “strategies for structuring, collateralizing, and marketing structured products.” A carefully tailored list of categories incorporated into movant’s spreadsheet that articulate precise categories of information is required. Generic categories generally will not establish the requisite good cause to seal or redact,
if the parties believe there is good cause to depart from the Model Form, they must submit the following: i. The proposed stipulation and order ii. A red-lined version of the proposed stipulation and order, indicating any departures from the Model Form iii. A party affirmation establishing good cause for any proposed departures from the Model Form. Amended Model Forms unaccompanied by the red-lined version and affidavit will not be approved
The parties must use specific cut-off dates (e.g., “on or before December 31, 2022”). Do not use open-ended dates or general timeframes, such as “within 45 days,” etc.
Any order governing the confidential exchange of information must follow the court’s Model Form.
Court's wording
In the interest of reducing unnecessary litigation costs, any order regarding the confidential exchange of information must adhere to the Proposed Stipulation and Order for the Production and Exchange of Confidential Information (“the Model Form”).
Filing & Service rules
Electronic Filing Rules
Documents in Part 43 must be filed electronically.
Part 43 is an e-filing Part.
Page 1 | 2. ELECTRONIC FILING & SUBMISSION OF DOCUMENTS
Justice Reed does not accept letters, documents, or papers by email or mail unless the Part Rules or specified Commercial Division Rules permit them or the court gives prior approval.
Justice Reed does not accept any letters, documents, or papers by email or mail unless expressly permitted by these Part Rules, Commercial Division Rules 2 and 18, or by prior approval of the court.
Page 2 | 3. COMMUNICATION WITH THE PART CLERK AND CHAMBERS
Documents requiring Justice Reed's signature for so-ordering must be emailed to Chambers at SFC-part43@nycourts.gov.
Documents requiring Justice Reed’s signature for so-ordering must be emailed to Chambers at SFC-part43@nycourts.gov.
Page 2 | 2. ELECTRONIC FILING & SUBMISSION OF DOCUMENTS
The agreed adjournment stipulation must be electronically filed and submitted to the Submissions Part on the motion's return date.
The stipulation must be electronically filed and filed in the Submissions Part on the return date of the motion.
Page 2 | 4. ADJOURNMENTS
The parties must electronically file all court-approved stipulations to adjourn.
All court-approved stipulations to adjourn must be electronically filed by the parties.
Page 3 | 4. ADJOURNMENTS
The disclosing party must electronically file an affirmation certifying completion of the initial disclosures.
The disclosing party shall e-file an affirmation certifying completion of the initial disclosure.
Page 3 | 5. INITIAL DISCLOSURES
Each exhibit must be electronically filed under its own document number and bear a short label identifying its nature.
Each exhibit must be e-filed under its own document number and include a short label identifying the nature of the exhibit (e.g., Complaint, Contract dated 10/23/22, etc.).
Page 4 | 6. MOTION PRACTICE
The compliance-conference joint letter must be filed in NYSCEF and emailed to the stated chambers address.
The joint letter must be filed to NYSCEF and sent by email to SFC-part43@nycourts.gov.
Page 5 | 7. CONFERENCES AND DISCOVERY DISPUTES
After approval, the So-Ordered version of the stipulation is electronically filed for retrieval and presentation on the return date.
If approved, the So-Ordered version of the stipulation will be electronically filed, so that the parties may retrieve the signed order from the electronic filing system and present it to the Submissions Part on the return date.
Page 3 | 4. ADJOURNMENTS
When a decision and order has issued on the record, the Part Clerk will electronically file the So-Ordered transcript after Justice Reed so orders it.
If a decision and order has been issued on the record, Justice Reed will “so order” the transcript, and the Part Clerk will e-file the “so ordered” transcript.
Page 4 | 6. MOTION PRACTICE
Filing Timing and Cure Windows
The stipulation must be electronically filed and filed in the Submissions Part on the motion’s return date.
The stipulation must be electronically filed and filed in the Submissions Part on the return date of the motion.
Page 2 | 4. ADJOURNMENTS
Initial disclosures must be exchanged within 30 days after the defendant files an answer or appears on a motion.
Within 30 days of filing an answer or appearance by defendant on motion, initial disclosures shall be exchanged as follows:
Page 3 | 5. INITIAL DISCLOSURES
A party first served or joined after the Rule 8 consultation must make initial disclosures within 30 days after appearing, unless a stipulation or court order sets a different time.
A party that is first served or otherwise joined after the Commercial Division Rule 8 consultation must make the initial disclosures within 30 days after making an appearance, unless a different time is set by stipulation or court order.
Page 3 | 5. INITIAL DISCLOSURES
Opposition papers on an order to show cause must be electronically filed no later than 72 hours before the hearing.
OSC opposition papers shall be e-filed no later than 72 hours before the motion is to be heard.
Page 4 | 6. MOTION PRACTICE
A summary judgment motion must be filed no later than 60 days after the Note of Issue is filed.
Summary judgment motions must be filed not later than 60 days after the filing of the Note of Issue.
Page 4 | 6. MOTION PRACTICE
The parties must submit a consent preliminary conference order to the part at least seven days before the preliminary conference.
At least seven (7) days prior to the preliminary conference date, the parties must comply with Commercial Division Rule 8 and submit a consent preliminary conference order to the part.
Page 5 | 7. CONFERENCES AND DISCOVERY DISPUTES
An application for an in-person discovery conference must be submitted to chambers no later than two weeks before the scheduled conference.
If an in-person conference is requested, the parties must submit their application to chambers no later than two weeks prior to the scheduled conference date.
Page 5 | 7. CONFERENCES AND DISCOVERY DISPUTES
A completed draft order must be submitted to chambers at least seven days before every conference.
At least seven (7) days prior to every conference, a draft order must be completed and submitted to chambers.
Page 5 | 7. CONFERENCES AND DISCOVERY DISPUTES
The specified trial submissions, marked pleadings, and joint stipulated-facts statement must be submitted at least 10 days before the final pretrial conference.
The submissions required under Commercial Division Rules 26, 27, 28, 29, 31(a), 31(b), and 32, plus marked pleadings and a Joint Statement of Stipulated Facts and Procedural History, shall be made at least 10 days prior to the final Pre-Trial Conference.
Page 6 | 8. TRIALS/ EVIDENTIARY HEARINGS
For non-jury trials, proposed findings of fact and conclusions of law are due within 10 calendar days after the record closes unless the court directs otherwise.
For non-jury trials, the parties shall submit proposed findings of facts and conclusions of law within ten (10) calendar days of the close of the record, unless otherwise directed by the court.
Page 6 | 8. TRIALS/ EVIDENTIARY HEARINGS
A post-trial motion must be made within the time prescribed by CPLR 4405.
Any post-trial motion shall be made within the time allotted pursuant to CPLR 4405.
Page 6 | 8. TRIALS/ EVIDENTIARY HEARINGS
The Part Clerk will file trial extracts within 30 days after entry of the verdict or decision.
Trial extracts will be filed by the Part Clerk within 30 days of entry of the verdict or decision.
Page 6 | 8. TRIALS/ EVIDENTIARY HEARINGS
Service and Proof of Service Rules
Initial disclosures must be written, signed, and served.
The disclosures must be in writing, signed, and served.
Page 4 | 5. INITIAL DISCLOSURES
Sealing & Redaction Procedures
A generic assertion that information is confidential is insufficient; the party seeking sealing must demonstrate compelling circumstances justifying restricted public access.
General assertions that information contained in documents is “confidential” are not sufficient. Under applicable law, “the party seeking to seal court records has the burden to demonstrate compelling circumstances to justify restricting public access”
Page 7 | 11. SEALING DOCUMENTS
A motion to seal or redact must be made by order to show cause, include a NYSCEF-number spreadsheet, a memorandum explaining the good cause and supporting law, and a knowledgeable affiant; an attorney affirmation alone is inadequate.
Motions to seal and/or redact shall be made by order to show cause and shall include a spreadsheet identifying each document by New York State Court Electronic Filing (NYSCEF) document number. Movant’s memorandum of law shall set forth the basis of the purported good cause to seal or redact each document or piece of information and any applicable law or authority supporting movant’s good cause to seal/redact the document/information. The movant’s papers must also include an affidavit from a person with knowledge setting forth the grounds to seal or redact the document/information. An attorney affirmation, standing alone, is not adequate.
Page 7 | 11. SEALING DOCUMENTS
A confidentiality agreement or stipulation to sealing does not itself justify sealing or redaction, and 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 7 | 11. SEALING DOCUMENTS
When additional redactions or sealing are permitted, counsel must electronically file a public redacted copy and an unredacted copy under seal.
If the court permits additional redactions or sealing of a document in whole or in part, counsel shall e-file both the redacted copy publicly and the unredacted copy of the document under seal.
Page 8 | 11. SEALING DOCUMENTS
Additional sealing or redactions beyond those permitted by the Redaction Rules are discouraged and must be requested under 22 NYCRR 216.1.
Sealing (including redactions beyond those permitted by the Redaction Rules) is discouraged. Any request for additional redactions or sealing shall be made according to the Uniform Rules for Trial Courts 22 NYCRR 216.1.
Page 7 | 11. SEALING DOCUMENTS
Filing Bundling Requirements
The parties must coordinate a single Rule 14 submission containing the initial letter and all responsive letters.
The parties shall coordinate to make a single Rule 14 submission to chambers at SFC-part43@nycourts.gov, containing both the initial letter and any responsive letter(s).
Page 6 | 7. CONFERENCES AND DISCOVERY DISPUTES
Similarly situated parties should make reasonable efforts to consolidate briefing papers and avoid duplication in combined briefs.
Combined briefs – similarly situated parties (e.g., multiple defendants moving to dismiss on overlapping grounds) should make reasonable efforts to consolidate their briefing papers to avoid duplication.
Page 4 | 6. MOTION PRACTICE
Adjournment & Extension Requirements
A conference-adjournment application must be submitted at least 48 hours before the scheduled conference.
Applications to adjourn a conference shall be made at least 48 hours in advance of the scheduled conference.
Page 2 | 4. ADJOURNMENTS
A stipulation requires prior approval for acceptance; failure to appear may result in default or an appropriate sanction.
Without prior approval, a stipulation will not be accepted and failure to appear may result in a default, or appropriate sanction.
Page 2 | 4. ADJOURNMENTS
Every adjournment request must state the reason for the requested adjournment.
All adjournment requests must provide a reason for the request.
Page 2 | 4. ADJOURNMENTS
Before selecting a replacement oral-argument date, the parties must consult the Part Clerk.
The parties must first consult with the Part Clerk before selecting a new date for the oral argument.
Page 2 | 4. ADJOURNMENTS
The parties may obtain no more than two conference adjournments, totaling no more than two months.
Parties may adjourn a conference no more than two times, and for no more than a total of two (2) months.
Page 2 | 4. ADJOURNMENTS
Every request to adjourn an oral-argument motion, conference, or trial requires the court's prior approval.
All requests for adjournments (motions scheduled for oral argument, conferences, trials) require prior court approval.
Page 2 | 4. ADJOURNMENTS
A motion scheduled for oral argument will generally be adjourned only by stipulation.
In general, motions scheduled for oral argument will only be adjourned by stipulation.
Page 2 | 4. ADJOURNMENTS
Except in emergencies, an oral-argument motion will not be adjourned when the application is submitted fewer than 72 hours before the appearance.
Except for emergency situations, adjournments for motions scheduled for oral argument will not be given if the application is made less than 72 hours before the scheduled appearance.
Page 2 | 4. ADJOURNMENTS
Ex parte adjournment applications will not be considered.
Ex parte applications will not be considered.
Page 2 | 4. ADJOURNMENTS
An adjournment more than 60 days after the original return date requires a stipulation of adjournment submitted to the court for approval.
If the parties wish to adjourn the motion to a date more than sixty (60) days from the original return date, the parties must submit a stipulation of adjournment to the court for approval.
Page 3 | 4. ADJOURNMENTS
Adjournment applications must be submitted at least 48 hours before the scheduled hearing or trial.
Applications for adjournments shall be made at least 48 hours in advance of the scheduled hearing or trial.
Page 3 | 4. ADJOURNMENTS
An application to adjourn a motion scheduled for oral argument should be made at least 72 hours beforehand.
Applications to adjourn a motion scheduled for oral argument should be made at least 72 hours in advance of the oral argument.
Page 2 | 4. ADJOURNMENTS
A motion in the Submissions Part may be adjourned by stipulation without a court order when the new date is fewer than 60 days after the original return date.
If the parties wish to adjourn the motion to a date less than sixty (60) days from the original return date, the parties may adjourn by stipulation without an order from the Court.
Page 2 | 4. ADJOURNMENTS
Chambers Communication Rules
Counsel must notify the court as soon as practicable of any settlement or resolution of an active case or pending motion.
Counsel must notify the court as soon as practicable, of any settlement or resolution of active cases or pending motions.
Page 1 | 1. GENERAL
Counsel for every party, including pro se litigants, must be copied on all correspondence with the court.
Counsel for all parties, including pro se litigants, must be carbon-copied on all correspondence with the court.
Page 1 | 1. GENERAL
Justice Reed, the law clerks, and the Part Clerk will not engage in ex parte communications.
Justice Reed, his Law Clerks, and Part Clerk will not engage in any ex parte communications.
Page 1 | 1. GENERAL
A request to adjourn a conference must be directed to the Part Clerk by telephone at 646-386-3238 or by email at SFC-Part43-Clerk@nycourts.gov.
All requests to adjourn a conference shall be directed to the Part Clerk at 646-386-3238 or by emailing the Part Clerk at SFC-Part43-Clerk@nycourts.gov.
Page 2 | 4. ADJOURNMENTS
All Part 43 communications must be sent by email to both chambers and the Part Clerk, with a copy to all counsel.
All communication with Part 43 shall be sent my email, copying all counsel, to both chambers and the part clerk.
Page 2 | 3. COMMUNICATION WITH THE PART CLERK AND CHAMBERS
The court must not be copied on letters exchanged privately between the parties.
Do not copy the court on letters exchanged between the parties.
Page 2 | 3. COMMUNICATION WITH THE PART CLERK AND CHAMBERS
A hearing or trial adjournment request requires a conference call with the Part Clerk and all parties.
To adjourn a hearing or trial, the parties must contact the Part Clerk at 646-386-3238 on a conference call with all parties on the line.
Page 3 | 4. ADJOURNMENTS
The proposed adjournment stipulation must be delivered to Chambers by email at the stated address.
Parties must deliver the proposed stipulation to the court by emailing chambers at SFC-part43@nycourts.gov.
Page 3 | 4. ADJOURNMENTS
Counsel may report a settlement by conference call to the Part Clerk or by email to chambers with a carbon copy to all assigned counsel.
Counsel may contact the court by conference call to the Part Clerk, or by email to chambers with a carbon copy to all counsel assigned to the matter.
Page 1 | 1. GENERAL
The Part Clerk cannot accept deliveries from 1:00 p.m. to 2:15 p.m. or after 4:30 p.m.
The Part Clerk is unable to accept deliveries between 1:00 p.m. and 2:15 p.m., or after 4:30 p.m.
Page 1 | 1. GENERAL
Chambers must not be called regarding scheduling matters or adjournment requests.
Do not call Chambers regarding scheduling matters or requests for adjournments.
Page 2 | 4. ADJOURNMENTS
Parties should refrain from telephoning chambers.
Please refrain from calling chambers.
Page 2 | 3. COMMUNICATION WITH THE PART CLERK AND CHAMBERS
Should the parties desire a conference, a request should be sent to chambers at SFC-part43@nycourts.gov, stating the reason for the conference request.
Should the parties desire a conference, a request should be sent to chambers at SFC-part43@nycourts.gov, stating the reason for the conference request.
Page 2 | 3. COMMUNICATION WITH THE PART CLERK AND CHAMBERS
All parties should be copied on the email.
All parties should be copied on the email.
Page 3 | 4. ADJOURNMENTS
The Part Clerk may also be emailed about a hearing or trial adjournment request.
The parties may also email the Part Clerk at SFC-Part43-Clerk@nycourts.gov.
Page 3 | 4. ADJOURNMENTS
The parties may request a preliminary conference by emailing the stated chambers address.
The parties may request a preliminary conference by email to SFC-part43@nycourts.gov.
Page 5 | 7. CONFERENCES AND DISCOVERY DISPUTES
The parties may request a settlement conference, by consent, through the stated chambers email address.
The parties may, on consent, request a settlement conference by emailing chambers at SFC-part43@nycourts.gov.
Page 6 | 7. CONFERENCES AND DISCOVERY DISPUTES
Junior Lawyer Participation Incentives
The court strongly encourages courtroom participation by underrepresented attorneys and permits a less experienced attorney who prepared the brief to argue the motion.
To create opportunities for attorneys knowledgeable with the subject matter of the action, but who historically have been underrepresented in the Commercial Division, the court strongly encourages courtroom participation by such attorneys. Participation may be achieved by having a less experienced attorney who prepared the brief on the motion, argue the motion before Justice Reed.
Page 1 | 1. GENERAL