Counsel must jointly prepare a proposed verdict sheet at the close of plaintiff's case.
Counsel must provide marked pleadings and an exhibit list as soon as possible after trial begins.
All documents in E-Filing Cases must be filed through NYSCEF unless an exception or exemption applies.
Every submission to the Court, including proposed orders, proposed judgments, and letters, must be electronically filed.
General e-filing questions may be directed to the E-Filing Resource Center by phone at 646-386-3033 or by email at efile@courts.state.ny.us.
Questions about local procedures should be directed by phone to the Civil Department at 914-824-5300.
Unless otherwise inapplicable, an application for temporary injunctive relief must include either an affirmation detailing a good-faith notice effort or an affirmation stating that notice would significantly prejudice the applicant.
Communications with Chambers must generally be submitted as letters on NYSCEF, subject to judicial direction and any exception or exemption.
A letter requiring immediate attention should be emailed to Eva Nilsson-Smith in Chambers and also filed on NYSCEF.
Scheduling and calendar matters should be handled by calling Part Clerk Joseph Tuohy at 914-824-5623 between 9 a.m. and 4:30 p.m.
Unaddressed matters and emergencies requiring immediate attention should be raised by calling Chambers at 914-824-5392, leaving a message with the action name, index number, and call details if necessary.
An application to adjourn an appearance must be submitted on NYSCEF as a letter or stipulation unless an exception or exemption applies.
The adjournment letter or stipulation should state the appearance date, proposed adjourned date, number of prior adjournments, whether the adversary consents, and any reasons given for refusing consent.
An adjournment request must be submitted at least 48 hours before the appearance unless good cause is shown.
Material intended for use on cross-examination does not have to be included on the exhibit list.
Counsel must provide all previous judicial decisions entered in the case, including appellate decisions, as soon as possible after trial begins.
All requests-to-charge submissions must be served on opposing counsel.
The parties' contentions must be submitted on one typed, single-spaced page as soon as possible after trial begins.
Counsel must provide pretrial memoranda addressing known disputed legal issues that the Court must determine.
Submit a complete list of requested charges by e-mail to llubell@nycourts.gov, even if the Court has provided standard charges.
For standard pattern charges, only the PJI numbers and section titles must be submitted unless a deviation or addition is requested.
Requested charge deviations, additions, or charges requiring trial-related information must include the full request, included material, and supporting legal authority.
The proposed verdict sheet must be typed and submitted in final form for presentation to the jury.
If the parties cannot agree on a proposed verdict sheet, each side must present a separate proposed verdict sheet.
When feasible, parties must also submit the proposals by e-mail in a format compatible with Microsoft Word or WordPerfect.
The final verdict sheet will be formalized at a charge conference during the trial after the conclusion of plaintiff's case.
In e-filed cases, hard-copy submissions will be rejected unless accompanied by the completed Notice of Hard Copy Submission - E-Filed Case form.
The reporter will mark only the items received in evidence.
Counsel must provide a list of witnesses for each party as soon as possible after trial begins.
