Hon. Christopher Chin — Part 22 Rules

HON. CHRISTOPHER CHIN, J.S.C.

Part Rules (Part 22) [effective September 17, 2026]

Courtroom:

80 Centre Street, Room 136, New York, NY 10013

Part 22 Clerk:

Aramis Torry, 646-386-3271

SFC-PART22-CLERK@nycourts.gov

Principal Law Clerk

Donna Albano, Esq., dalbano@nycourts.gov

Assistant Law Clerk

Samaha Hossain, Esq., shossain@nycourts.gov

DCM Conferences (in-person only) - DCM Courtroom Part, 80 Centre Street, Room 103,

Mondays (2:00pm-4:30pm) and Fridays (9:30am-1:00pm)

DCM Part Clerk

James Metzger

Phone

646-386-3683

E-mail

jtmetzger@nycourts.gov

I. Communications with Part Clerk, DCM Coordinators, and Chambers – Including

Adjournments

A. Please notify the Part Clerk as soon as a case settles or if all parties want a settlement

conference, at any point in the litigation.

B. No ex parte communications with the judge or law clerks. Unless specifically

instructed, please do not unilaterally call or e-mail chambers. Do not copy the court on

letters or emails exchanged between counsel.

C. All decisions and orders (including DCM orders) are scanned and available on-line

through NYSCEF.

D. General questions about appearances may be addressed to the Part Clerk by phone at

(646) 386-3271, or email to SFC-PART22-CLERK@nycourts.gov.

E. Please be aware that e-filing a letter or stipulation does not automatically come to the

attention of the judge or court staff. You must communicate it by email.

F. Any issues concerning early settlement conferences should be addressed to James

Metzger, the DCM Part clerk and not to the Part 22 clerk.

II. Discovery Conferences

Most motor vehicle cases will be part of the Differentiated Case Management (DCM) Program. A

case scheduling order (“CSO”) will be issued as part of the DCM Program after a request for a

preliminary conference or on the court’s own initiative. This is a court order, and the parties are

required to comply with the directives in the CSO. Parties must be prepared to explain to the

judge why a directive in the CSO has not been complied when appearing for a status or

compliance conference. Failure to adequately provide an explanation by the attorney in court may

result in the adjournment of the conference with a mandate that a partner of the offending law

office come into court in person to explain. Additionally, plaintiffs must serve a Bill of

Particulars prior to the first DCM conference. If a Bill of Particulars has not been served, the

first DCM order may preclude plaintiff from offering any evidence at trial.

Status conferences and compliance conferences on DCM cases for Part 22 are conducted in-

person in the DCM Courtroom Part (80 Centre Street, Room 103) on Mondays (2:00pm-4:30pm)

and Fridays (9:30am-1:00pm). Stipulations may not be submitted in lieu of appearing in-person

for conferences, except for stipulations indicating that all discovery has been completed. Case-

specific stipulation forms will not be provided in advance of the in-person conference date.

Stipulations will be provided to parties upon check-in on the in-person conference date. Counsel

shall be aware of and comply with all directives provided in the case scheduling order. Parties are

to bring a copy of the last discovery order to the status/compliance conference.

To request a conference sooner than one that is already scheduled, please contact the Part Clerk at

SFC-Part22-Clerk@nycourts.gov or (646) 386-3271.

To request an adjournment of a conference in the DCM Part or address any other calendar

issues related to a DCM appearance, please call the DCM Clerk, James Metzger, at (646)

386-3682 or (646) 386-3683. Applications to adjourn in-person conferences must include

a stipulation executed by all parties and the reason for the adjournment and may be sent to

James Metzger at jtmetzger@nycourts.gov at least 48 (2 business days) hours prior to the

scheduled conference.

A. Conferences are important; please be prepared.

1. The Court invests significant resources into the DCM system in order to

efficiently and fairly resolve discovery disputes. The rules of this Part require

compliance with court-ordered deadlines. Remember, these are court orders.

Failure to adhere to deadlines and comply with orders may result in penalties.

Counsel attending the conference are to be familiar with the case and have the

authority to discuss and to stipulate to resolve all discovery issues, as well as

settlement.

2. It is assumed counsel have consulted clients, examining doctors, etc. as to their

availability for EBTs, IMEs, and the like. EBTs are expected to be conducted

within 60 days of the conference date unless good cause is shown. Stipulations

containing EBT dates more than 60 days away may be amended by the judge to a

sooner “on or before” date and/or preclusion language may be added and the

stipulation converted into an order.

3. Upon a party’s failure to appear for a DCM conference, the case may

be dismissed, or the party’s pleading may be stricken, in accordance with 22

NYCRR § 202.27. Any motion to vacate such a default must be brought by

Order to Show Cause and must fulfill the requirements of CPLR § 5015.

4. Parties shall adhere to a discovery schedule pursuant to 22 NYCRR § 202.20-e

(a). If a dispute arises about compliance with any discovery order, or if

deadlines are passing without discovery being provided, DO NOT WAIT until

the next conference to report that nothing has been done. Counsel must

comply with court orders and/or report non-compliance. If the parties’ good

faith efforts to resolve the dispute fail, then immediately - without making a

motion - contact the Part Clerk at SFC-Part22-Clerk@nycourts.gov or (646)

386-3271, who will schedule an in-person conference in the DCM Courtroom

Part to resolve the dispute before the next scheduled compliance conference.

B. Instructions Applicable to Compliance Conference Orders

1. Please write legibly in black ink. Illegible orders will not be signed.

Please put the names, emails, addresses and telephone numbers of all counsel

appearing at the conference. If a party fails to note their appearance, a default

against that party may be taken.

2. All orders will be scanned and will appear on NYSCEF. Use complete dates,

including the year. Please remember that some of the dates you are selecting

may be in the next calendar year.

C. LABOR LAW CASES

For afternoon Preliminary Conferences ONLY

In lieu of an in-person appearance at a scheduled afternoon Preliminary

Conference, the parties may submit a proposed stipulated PC Order. The

proposed stipulated PC Order must be emailed to the Part Clerk at SFC-Part22-

Clerk@nycourts.gov, on or before the Friday prior to the scheduled PC date and

shall NOT be uploaded to NYSCEF. Once the PC Order is signed by the court,

the Order will be uploaded to NYSCEF, and a conference date will be provided

therein. A blank PC form can be found

at: https://www.nycourts.gov/LegacyPDFS/courts/1jd/supctmanh/PC-Genl.pdf

III. Motion Practice

A. All motions are on submission unless the court or the parties request otherwise. A

party may request oral argument on the face of the motion papers or by a single-page

letter e-filed and emailed to the Part22 Clerk (with notice to all parties). Not every

request for oral argument will be granted. A representation that the argument will be

made by an attorney whose participation enhances diversity in the bar or an

attorney admitted to practice fewer than five years will weigh in favor of the court

deciding to hold oral argument. The letter should identify the attorney and the portion

of the motion that such attorney will argue. Such a letter may also be submitted with the

opposition papers. Hard copies shall not be submitted unless specifically directed by the

court. If an exhibit to a motion or opposition papers include a video, be prepared to be

able to show the judge the video, during argument (on your electronic device). Please

note that the court cannot access links to a video via Google Drive or OneDrive.

Parties requesting a court reporter for oral argument must make the request in an email to

the Part Clerk at least 48 hours (2 business days) prior to the scheduled oral argument.

Motion sequence numbers shall be included on the front page of all notices of

motion/cross-motion, affirmations in support or opposition and reply papers, and any

stipulations or letters relating to a motion, otherwise they may not be considered to be a

part of the motion.

B. If a motion is resolved prior to the issuance of a decision by the court, the parties shall

email the court’s law clerk, with a copy of a signed stipulation. Do not merely e-file a

letter or stipulation.

If the parties have stipulated to an adjournment of the oral argument, the signed

stipulation must be uploaded and emailed to the Part 22 clerk at least 48 hours prior to the

oral argument date. The adjournment must be approved by the Court. If no approval is

received (uploaded stipulation signed by the judge), the parties are to appear at the oral

argument date. Failure to appear on an argument date, may result in the granting/denying

of the motion on default, in accordance with 22 NYCRR 202.27.

C. Discovery Motions – Discovery motions may not be made without prior authorization

from the court. Any discovery motion filed must detail the court’s authorization and

an order permitting the filing of the motion shall be submitted as an exhibit. Failure to

comply with this rule may result in the summary denial of the discovery motion.

Prior to making any discovery motion, all parties are required to first meet and confer

about any issues, in accordance with 22 NYCRR § 202.7. If the parties are unable to

resolve the issues, they shall request a discovery conference with the DCM Courtroom

Part. If the dispute cannot be resolved at the DCM conference, the issue(s) will be

narrowed, and the DCM Order will specifically allow a motion to be filed and set forth a

briefing schedule.

D. Summary Judgment Motions

1. All summary judgment motions must be made no later than 60 days after filing

the Note of Issue – without leave of Court. In the notice of motion or early in

the affirmation in support, please state the date the Note of Issue was filed and

how the motion is timely. Absent good cause for late filing, a late motion will

be denied, even if there is no objection. Any exhibit to the motion

must be e-filed as a separate document and must be given an identifying label

(e.g., Notice of Claim, Bill of Particulars, etc,). Each affidavit or affirmation is to

be its own exhibit. If more than one affidavit or affirmation is contained in an

exhibit, it is likely that only the first one will be considered. All exhibits should

be paginated, and any references to voluminous exhibits (including deposition

testimony), must include pinpoint citations (i.e. page numbers).

2. Cross-motions, especially cross-motions seeking relief unrelated to the main

motion, DO NOT relate back to the date the original motion was made.

3. Motions cannot be adjourned for more than 60 days without prior court

approval.

4. Discovery is not stayed and must continue during the pendency of a CPLR §

3212 motion (or other dispositive motions), unless good cause is shown for a

stay. Consult the DCM Courtroom Part at the conference regarding the “good

cause”; the DCM Courtroom Part will consult with Justice Chin, if necessary.

A stipulation will not suffice; any stay must be by court order. Parties may

email the Part’s Law Clerk to request a conference to address a stay request in

lieu of a motion.

IV. Note of Issue

A. A Note of Issue may NOT be filed unless a stipulation is so-ordered certifying that

discovery is complete. Improperly filed Notes of Issue may be stricken sua sponte.

B. Generally, the certification of completed discovery will be made at the final

compliance conference. However, if all parties agree that discovery is complete

before the next court date, the in-person conference may be avoided by emailing a

stipulation to the Part 22 Clerk at SFC-Part22-Clerk@nycourts.gov and to the DCM Part

Clerk James Metzger at jtmetzger@nycourts.gov at least two days before the scheduled

conference. The stipulation must certify that all discovery is complete and provide

for the filing of a Note of Issue. The DCM Courtroom Part will provide a date by

which the Note of Issue must be filed, and the so-ordered stipulation will be scanned

and uploaded to NYSCEF.

V. Consolidation or Amendment of Captions

All orders on motions or stipulations to consolidate, to sever claims or to amend

captions shall be served with notice of entry on the County Clerk and the General Clerk’s

Office in accordance with Section J of the Protocol on Courthouse and County Clerk

Procedures for Electronically Filed Cases (available at

https://www.nycourts.gov/courts/1jd/supctmanh/Efil-protocol.pdf).

VI. Subpoenas

Subpoenas which a party seeks to have “so ordered” by the court must be hand delivered to the

Part 22 Clerk; the submitting party will be notified by the Part Clerk once the subpoena has been

signed.

VII. Trial Rules

A. Upon the first appearance before this Court, the parties must furnish the following:

1. A list of proposed witnesses (including the need for any interpreters or other

accommodation), the dates of availability of each witness, and the expected

length of time of direct examination for each witness.

2. An estimate of required trial days.

3. All marked pleadings and bills of particulars.

4. A copy of any statutory provisions in effect at the time the cause of action arose

upon which any party relies.

5. Copies of the EBT transcripts intended for use at trial during direct

examination.

6. A trial memorandum, not to exceed two (2) pages, setting forth the party’s

position and relevant factual and legal issues to be tried citing relevant case

law and including causes of action, and any affirmative defenses and/or

counterclaims.

7. All prior decisions in the case, including any appellate decisions.

8. Two (2) business cards for each attorney.

9. Most recent demand, offer and policy limits.

B. Prior to the start of trial, the parties must furnish the following:

1. Motions in limine shall be presented in writing to the court and e-filed as soon

as practicable or as specifically scheduled at any pre-trial conference, with a

copy to all parties.

2. For jury trials, all counsel shall email proposed jury charges and verdict sheets

in Word format to Part 22’s court attorney and opposing counsel. If any

modification of the PJI is requested, the entire charge shall be typed with the

proposed modification in Bold type.

3. For non-jury trials, a stipulation as to all undisputed/agreed upon facts.

C. Parties are to have the court reporter pre-mark exhibits for identification and/or

evidence if there is no objection.

D. It is the duty of counsel to ensure that the subpoenaed documents counsel intends to

use at trial have arrived in the subpoenaed records room at 60 Centre Street, Room

145M.