Hon. Joanne D. Quinones — Part CVA3 Rules

Hon. Joanne D. Qui ñones: Part CVAP3 Rules

Chambers Telephone

(347) 296-1366

Courtroom

320 Jay Street, Room 19.36 (19th Floor)

Courtroom Telephone

(347) 296-1353

Principal Law Clerk

Ronald Cosme, Jr., Esq., rcosme@nycourts.gov

Assistant Law Clerk

Olivia R. Nacionales, Esq., onacionales@nycourts.gov

Updated

August 5, 2026

Part CVAP3 has been established in accordance with 22 NYCRR 202.72 and CPLR 214-g. All parties shall familiarize themselves with these Part CVAP3 Rules, the Uniform Civil Rules for the Supreme Court and the County Court , and the New York Civil Practice Law and Rules (CPLR).

Communications with the Court

Ex Parte Communications: The court will not engage in ex parte (one-sided) communications. All communications with the court, including email and telephonic communications, must be on notice to all parties/counsel.

Email Communications: All email communications to the court must adhere to the following guidelines: All email communications to the court shall include the case name, index number, and a brief explanation regarding the reason for the communication.

All emails shall include all attorneys and self-represented litigants copied on said correspondence.

Emails to the court shall only be sent during courthouse business hours. Emails transmitted after courthouse business hours, on weekends, or on court holidays are strongly discouraged, except in the case of an emergency.

Litigants represented by an attorney are prohibited from communicating with chambers or the court directly

All written and oral communications shall be conducted with civility and in a manner that reflects due respect for the dignity and integrity of the court and its proceedings.

Litigation by email is strictly prohibited absent express court permission.

Chambers should not be copied on correspondence between counsel.

Telephonic Communications: Any telephone call to chambers regarding a pending matter shall be made only when all parties are present on the line.

Requests for Adjournments: All adjournments require prior approval of the court. Request by Conference Call : Adjournment requests shall be made by conference call to chambers only when all parties are present on the line. The telephonic request must be made no later than one (1) day prior to the appearance.

Request by Email: Alternatively, an adjournment request may be made by submitting a stipulation signed by all parties at least two (2) days prior to the scheduled appearance, and shall include proposed future dates and the reason for the adjournment. Stipulations of adjournment shall be emailed to both law clerks. An adjournment request has not been granted until you receive a so ordered stipulation of adjournment.

Actual Engagement: Adjournments on the ground of engagement of counsel will be granted in accordance with Part 125 of the Rules of the Chief Administrator of the Courts. Affirmations must be e-filed and emailed to chambers at least one (1) day prior to the court appearance. Upon sending the affirmation of actual engagement, the parties must contact the court by conference call or email to request the adjournment in accordance with these Part Rules.

Notification of Settlement: The parties shall immediately notify chambers by email or conference call of the settlement or resolution of any case, claim, or pending motion.

Motions

Oral Argument: If oral argument is desired, the request must appear in the notice of motion; however, motions will only be scheduled for oral argument at the judge’s discretion. If oral argument is scheduled, you will be notified electronically of the date. Oral argument in Part CVAP3 is heard on Thursdays .

Return Date

All motions filed in Part CVAP3 shall be made returnable on Thursdays at 10:00 a.m.

Adjournment of Motion(s) : All adjournments of pending motions require prior approval of Part CVAP3. Adjournment requests shall be made in accordance with Paragraph 4 herein.

Motion Sequence Number: Often, several motions are submitted at the same time. To keep papers organized, the first page of every motion paper (notice of motion, opposition, reply, etc.) must include the respective motion sequence number in the upper right corner.

Exhibits: Each page in any exhibit must be numbered. Reference to any exhibit must include pinpoint citations so the exact location within the exhibit can be found easily.

EBT Transcripts: A complete EBT (examination before trial/deposition) transcript must be e-filed with motion papers and any reference thereto must cite to the exact page and line numbers relied upon.

Discovery Disputes: Discovery disputes are preferred to be resolved through court conference as opposed to motion practice, if practicable. Counsel must consult with one another in a good faith effort to resolve all disclosure disputes. If counsel are unable to resolve any disclosure dispute in this fashion, counsel requesting the conference shall email the law clerks, with all parties copied, briefly outlining the nature of the dispute and requesting a virtual conference. No party shall file a discovery motion without first conferencing the matter with the court.

Summary Judgment Motions: All summary judgment motions must be made no later than 90 days after filing the Note of Issue, or as otherwise directed by order of the court. There are no exceptions without leave of court. Absent good cause for late filing, a late motion may be denied, even if your adversary does not object. Extensions of time to file summary judgment motions must be made prior to the expiration of the deadline and submitted in accordance with the procedure enumerated in Paragraph 4 of these Part Rules.

Withdrawal of Motion: To withdraw a fully submitted motion that is pending in Part CVAP3, the movant shall e-file a stipulation or letter withdrawing the motion and immediately advise the court via email.

Decisions: To determine whether a decision has been rendered, please check NYSCEF. All decisions and orders are scanned and available on NYSCEF. Please do not call or email the court to ask whether a decision has been issued.

Court Interpreter Services

Chambers staff must be notified via e-mail at least three (3) business days in advance of each court proceeding (including conference, oral argument, hearing, and trial) if a court interpreter is needed. You must provide the language and dialect for the requested interpreter services.

Requirements for Trial

Trial Scheduling: Once a case has been assigned a trial date, it is presumed ready for trial. Trials will be day-to-day or as scheduled by the court. No consent adjournments will be accepted. Failure to proceed without good cause will result in a finding of default, striking of the pleadings, and/or dismissal of the action. Chambers shall be notified immediately via email if the action is resolved prior to any scheduled trial date.

Trial Documents: No later than seven (7) days prior to the first scheduled trial date, the parties shall submit the following trial documents to chambers: Any pretrial memorandum, copies of cases and authorities upon which you will be relying, especially opinions not contained in the official reporters;

A list of proposed witnesses, including the need for any interpreters. If an interpreter is requested, please indicate the language and dialect;

A list of all proposed exhibits. Proposed exhibits should be pre-marked for identification and are to be shown to opposing counsel. Plaintiff’s exhibits are to be assigned a numeric symbol ( i.e. , 1, 2, 3, etc. ) and Defendant’s an alphabetical one ( i.e. , A, B, C, etc. );

All marked pleadings and bills of particulars;

Copies of all EBTs intended for use at trial and identifying any specific portion of those portions of EBTs to be referenced at trial;

Any requests for audio/visual equipment;

A written copy of any issues or facts to which the parties have stipulated in advance of trial . Parties are strongly encouraged to stipulate to all facts and documents not in dispute prior to trial, and to have agreed-upon documents, photographs and other exhibits pre-marked into evidence outside the presence of the jury; and

Motions in limine.

Adjournment of Trial: There will be no adjournment of the trial date without express court permission. Failure to proceed may result in a judgment of default or dismissal of the action.

Trial Scheduling

All trials proceed day-to-day until completed, unless otherwise scheduled by the court.

Exhibits: Exhibits left in the courtroom after settlement or the end of the trial will be discarded after five (5) business days have elapsed or at the discretion of the court.

Additional Notes

Documents for Signature: When preparing documents for the judge’s signature, do not put the judge’s signature line on a blank page.

Judicial Subpoenas: Judicial subpoenas must be made returnable to the NYS Supreme Court, Kings County Subpoenaed Records Room, 360 Adams Street, 6th Floor, Brooklyn, New York 11201.

Sanctions and/or costs may be imposed for failure to comply with any rule set forth herein.