Hon. Dakota D. Ramseur — Part 34 Rules

HON. DAKOTA D. RAMSEUR

Part 34 Practices and Procedures

(revised June 30, 2026)

Supreme Court of the State of New York

New York County

Civil Term – IAS Part 34

60 Centre Street, Courtroom 341

New York, New York 10007

Part 34 Clerk: Brian Thompson Principal Law Clerk: Aqua Etuk

Part Clerk Email: SFC-Part34-clerk@nycourts.gov Assistant Law Clerk: Sajani Patel

Part Clerk Phone: (646) 386-4370 Part 34 Email: SFC-Part34@nycourts.gov

Chambers Phone: (646) 386-3191

1. General

a. The use of audio/video/image recording or photography in any manner in the

courtroom is prohibited. Only counsel seated at the counsel table, with permission of

the Court, may use electronic equipment. All use by others, in the absence of explicit

permission by the Court, is prohibited.

b. Failure to abide by the Court’s rules may result in expulsion from the Courtroom,

sanctions, or other consequences, as provided by law and in the Court’s sole

discretion.

2. Communication with the Court

a. No party may contact the Court via e-mail, telephone, or any other means of

communication without all parties involved copied thereto or directly participating in

the communication. No communication shall discuss the merits of the underlying case

via e-mail or telephone with the Part Clerk or chambers unless directed otherwise.

b. Court Calendar. All scheduling/party appearance requests, inquiries, and disputes

are to be directed to the Part Clerk unless otherwise directed by the Court.

Adjournment requests must be made no later than 3:00 p.m. 48 hours before the

scheduled appearance date. If a matter requires urgent attention, the parties should

contact chambers.

c. Case Status. Counsel must promptly notify the Court of any settlement or resolution

of any active case or motion, or bankruptcy or death of any party. Notices shall be

sent directly to the Part Clerk.

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3. Conferences

a. All conferences shall take place in-person on Tuesdays at 9:30 a.m. Unless otherwise

directed, the parties are to prepare a proposed conference order for the Court staff to

review at the time of the conference. The parties should also be prepared to address

all discovery-related issues.

b. If the parties are directed to appear virtually, invitations to a Microsoft Teams

meeting will be sent to counsel of record on NYSCEF.

c. Meet and confer. Parties must meet and confer to address all outstanding discovery

matters before their conference with the Court.

d. Pending Discovery Motions. If a discovery motion is pending in a case scheduled

for a conference, the parties are to notify the Court and be prepared to discuss the

motion at the conference.

e. Failure to Appear. Multiple failures to appear for a conference may result in the

dismissal of the matter, the non-appearing party’s pleadings stricken, or the entry of

default against the non-appearing party pursuant to 22 NYCRR 202.27.

f. At any time during litigation, or if compliance with section 3 (c) does not resolve a

dispute, the parties may contact the Part Clerk to request a conference with the Court.

4. Motion Practice

a. Part 34 is an e-file part. “Courtesy” or working copies of e-filed motions are not

required and should not be delivered to the part.

b. Oral Argument. Oral argument on motions is scheduled at the Court’s discretion.

Any party may request oral argument in their notice of motion or by letter on

NYSCEF at least 21 days before the scheduled return date. (22 NYSCRR 202.8-f.) If

scheduled, oral argument will take place on Tuesdays, or at a date scheduled by the

Court.

c. Discovery. Discovery motions are discouraged. Instead, the parties must first meet

and confer per section 3(c) above. If compliance with same is unsuccessful the parties

may submit a request for a discovery conference to the Part Clerk.

d. Appearances. Counsel appearing on dispositive motions should have settlement

authority. A failure to appear with settlement authority may be deemed a default.

e. Papers. All documents—including those already filed on NYSCEF—intended to be

referenced in support of or opposition to a motion must be filed as an exhibit under

the respective motion sequence. (CPLR 2214 [c].) The first page of all motion papers

must contain the motion sequence number in the upper right-hand corner.

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f. Memorandums. All memorandums of law must contain a table of contents and a

table of authorities.

g. Affirmations. Affirmations submitted in support of or in response to dispositive

motions must be separate from the memoranda of law. Affirmations should not

include arguments of law.

h. Exhibits. Each exhibit must be e-filed under its own document number and must

include a short label identifying the nature of the exhibit (e.g., Complaint, Contract

dated 1/1/15, etc.). All exhibits should be paginated, and reference to any voluminous

exhibit, including deposition testimony, must include pinpoint citations. The

movant’s exhibits shall be numbered (e.g. Exhibit 1, Complaint.) The non-movant’s

exhibits shall be lettered (e.g., Exhibit A, Answer to Complaint)

i. Summary Judgment. Motions for summary judgment shall attach copies of the

pleadings and include a separate statement of material facts.

j. Artificial intelligence (AI) programs. All submissions with respect to a motion must

include a certification by an attorney (or self-represented party) either that no

generative artificial intelligence program was used in the drafting of any affidavit,

affirmation, or memorandum of law contained within the submission, or that a

generative artificial intelligence program was used but all generated text, including

citations, quotations. and legal analysis was reviewed for accuracy and approved by

an attorney (or the self-represented party). If the certification states a generative

artificial intelligence program was used, the program must be identified and the

documents which include matter generated by the program must be specified along

with which parts of the documents were drafted by the program. One certification

pertaining to a party's submission comprised of several such documents shall suffice.

k. Motion Adjournments.

i. Adjournments on Consent. Motions scheduled for oral argument may be

adjourned upon consent of all sides no more than 60 days from the original

argument date. Requests are to be addressed to the Motion Support Office.

ii. Adjournment requests/stipulations to extend the argument date beyond 60

days of the date must be “so-ordered” by the Court, and must also contain a

specific reason for the adjournment. Such requests must be filed on

NYSCEF and e-mailed to the Part Clerk.

iii. Disputes. Disputed requests to adjourn a motion return date shall be filed on

NYSCEF and emailed to Part 34, with all involved parties copied.

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5. Electronic filing (NYSCEF) and eTrack

a. eTrack enables parties to track active Civil Supreme Court cases and to receive e-mail

notifications of appearances. All parties (and counsel if represented) should register

for the eTrack service for all Part 34 cases at (https://iapps.courts.state.ny.us/webcivil/)

6. Trials:

a. Upon the first appearance before this court, the parties shall provide (or shall provide

a list of NYSCEF docket entries corresponding to):

i. A list of proposed witnesses, including the need for any interpreters with the

required language and dialect;

ii. An estimate of required trial days;

iii. All marked pleadings and bills of particulars;

iv. All prior decisions in the case, including any appellate decisions;

v. Any notices to admit;

vi. Copies of those portions of EBTs intended for use at trial for any purpose;

vii. A trial memorandum, not to exceed five (5) pages, briefly setting forth the

party’s position and the relevant factual and legal issues to be tried, citing

relevant case law;

viii. Any requests for the use of technology and/or audiovisual equipment; and

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

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

i. All in limine or other applications. All motions in limine must be presented

in writing to the Court as soon as practicable or as specifically scheduled at

any pre-trial conference, with a copy to all parties. Any such motion or

application must include citations to relevant authority. The parties send

motions in limine to the chambers at SFC-Part34@nycourts.gov

ii. For jury trials:

1. Proposed jury instructions in the form of requested PJI numbers. If a

PJI instruction requires modification (including a characterization of

the evidence), or if the language is not based on the PJI, the party

making the request must submit the exact requested language, together

with the authority for it, in Word or PDF format to the part clerk and

opposing counsel simultaneously;

2. Proposed jury verdict sheet must be submitted in Word format to the

part clerk and opposing counsel simultaneously.

c. Parties are strongly encouraged to have the court stenographer pre-mark all exhibits

for identification and/or evidence if without objection. Plaintiff’s exhibits shall be

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numbered (e.g. Exhibit 1, Complaint.) Defendant’s exhibits shall be lettered (e.g.,

Exhibit A, Answer to Complaint.)

d. Counsel, not court personnel, shall ensure all subpoenaed documents have arrived in

the subpoenaed records room at 60 Centre Street.

e. Trial dates scheduled by the Court are firm and may only be adjourned upon

application to the Administrative Judge if said trial is located at 60 Centre Street,

and/or the trial date is selected by the Administrative Judge. Trials are held every day

of the week except Tuesday mornings.

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