Hon. Michele Titus — Part 50 Rules

PART50–RULES,PRACTICESANDPROCEDURES

SupremeCourtoftheStateofNewYork,CivilTerm

88-11 Sutphin Blvd., Jamaica, NY 11435

PRESIDING JUSTICE: HON.MICHELE TITUS

Principal Law Clerk: LindaV.Rampertab,Esq.

Asst. Law Clerk: Jessica Orellana, Esq.

Chambers: (718)298-1459

PrincipalLawClerk: (718)298-1465

Asst.LawClerk: (718)298-1503

Courtroom #27: (718)298-1052

Part 50 Email: QSCPART50@nycourts.gov

GENERAL

1. Calendar call is at 9:30 AM unless otherwise instructed by the Court. Please be

prompt for all appearances.

2. All questions regarding motions, adjournments, calendar calls, and scheduling should

be made via email to QSCPART50@nycourts.gov.

3. Please notify the Court, especially while a motion is pending before Justice Titus, if

the action has been settled, discontinued, or the motion has been resolved, via email

at QSCPART50@nycourts.gov and copied to ALL parties to the action.

4. Please notify the Court at least 5 business days prior to your scheduled court

appearance by email to QSCPART50@NYCOURTS.GOV if an interpreter is needed

for your case.

5. The parties are required to familiarize themselves with the new Uniform Civil Rules

for the Supreme Court and the County Court. Please refer to this link Uniform Civil

Rules(https://ww2.nycourts.gov/rules/trialcourts/202.shtml)

6. Part 50 is entirely an electronic part and does not accept working copies of motions.

DO NOT MAIL IN COURTESY COPIES OF MOTION PAPERS as they will be

discarded.

7. For the most up-to-date information concerning the handling of matters before the

11th Judicial District Civil Term (Queens Supreme Court), please refer to:

Queens County Supreme Court, Civil Term | New York Courts

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8. Matrimonial Mediation and Neutral Evaluation Program: Part 50 is a

presumptive matrimonial mediation part, which means that eligible cases may, at

the Court’s discretion, be referred to mediation or the neutral evaluation program.

Parties and Counsel are encouraged to avail themselves of the Court’s ADR

program: Alternative Dispute Resolution (ADR) NYCOURTS.GOV

Queens Alternative Dispute Resolution (ADR) | New York Courts

9. Automatic Orders: Pursuant to Domestic Relations Law §236 (B)(2)(b), when

servinga summons, a copy of the automatic orders must also be served and noted in

the affidavit of service separately.

COMMUNICATIONSWITHPART50AND

CHAMBERS

1. Counsel and litigants (represented or self-represented) are advised that Justice Titus,

her Principal Law Clerk, Assistant Law Clerk, and Part Clerk will not engage in any

ex parte communications.

2. Do not send any letters, documents, papers, mail, or facsimile to the part or

chambers, unless expressly permitted by these Practice Rules or by prior approval of

the Court.

3. AllcommunicationswithChambersmustincludeallpartiesandCounsel.

ADJOURNMENTS

M All adjournments are subject to the final approval of Justice Titus. Applications for

adjournments made less than three (3) business days prior to the scheduled date will

be denied, except for a reason pursuant to Rules of Chief Administrative Judge Rule

125.1, medical emergency, other exigent circumstance, or unavailability of the Court.

ORDERSOFPROTECTION

M Any request for issuance of a temporary order of protection must contain the Family

Protection Registry Information Sheet, and the party must be present.

M Counsel/Parties shall notify the Court of any orders of protections issued by another

court including the date of issuance and expiration and provide the Court with a copy

of such order.

https://www.nycourts.gov/LegacyPDFS/FORMS/familycourt/pdfs/info_she.pdf.

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MOTIONS

M Motions shall be heard virtually on Wednesdays, unless otherwise directed by the

Court.

M All Orders to Show Cause, Cross-Motions, and related filings must indicate the

respective motion sequence number on the first page.

M Affidavits, affirmations, and memoranda of law (exclusive of table of contents and

table of authorities) shall not exceed 25 pages each, double-spaced.

M The Court does not accept sur-replypapers without prior permission.

M Discovery motions are strongly discouraged. Prior to making any discovery related

motion, counsel must consult one another in a good faith effort to resolve any

discovery disputes and, in the absence of resolution, request a conference call with the

Court prior to filing any discovery related motion.

M Any questions regarding the procedure for e-filing proposed orders to show cause

should be directed to the Ex Parte Office.

CONFERENCES

M Compliance, status and settlement conferences will be held on Tuesdays (Virtual or

in person as directed by the Court).

M The Court will schedule a settlement conference in the appropriate case where the

parties are ready and willing to resolve their issues.

M Two days prior to the settlement conference, counsel shall e-mail directly to Part 50

email (qscpart50@nycourts.gov) a spreadsheet listing each item of marital property,

with their values and proposed distribution, and a statement, no more than two pages

long, setting forth the rationale for their position.

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TRIALSandHEARINGS

M All cases scheduled for trial in Part 50 will be scheduled for a Pre-Trial conference.

M Two weeks prior to the Pre-Trial Conference, counsel or the parties shall file and

exchange the following documents:

(1) A statement of proposed disposition, a child support worksheet (if applicable),

updated Statements of Net Worth, and most recent filed tax returns.

(2) A spreadsheet listing each item of marital property, with their values and proposed

distribution.

(3) Awitnesslist, with meaningful offerofproof foreach witness.

(4) A list of documents which counsel may stipulate into evidence. The documents to

be pre-marked as exhibits. (Plaintiff’s exhibits marked numerically and Defendant’s

exhibits marked alphabetically)

(5) Pursuant to 22 NYCRR 2-216(9), all experts reports are to be exchanged and filed

with the court sixty (60) days before the date set for trial. Reply reports, if any, shall

be exchanged no later than thirty (30) days before the date set for trial.

(6) Markedpleadingsandanypre-trialmemoranda.

(7) Proofoffilingofthenote ofissue.

M Counsel shall, if necessary, make motions in limine and shall be prepared to discuss

any evidentiary issues at the Pre-Trial Conference.

M Forensic Reports and Testimony: The report(s) of any neutral forensic expert(s)

appointed by the Court will be admitted into evidence subject to all hearsay and other

proper objections. Such report(s) may be considered the direct testimony of the

forensic expert(s), who shall be subject to cross-examination by the parties.

Additionally, an attorney affirmation will be required from counsel if counsel

requests a copy of a forensic report submitted to the Court. Please contact Part 50 if

counsel need further guidance in connection with the submission of this affirmation.

M Post-Trial Submissions: At the completion of the trial, counsel or the parties shall

submit via email to Part 50 the proposed Findings of Fact and Conclusions of Law in

Word format; an updated (if necessary) spreadsheet listing each item of marital

property, with their values and proposed distribution as established at trial; and post-

trial memorandum of no more than 25 pages (doubled-spaced and 12 point font).

INQUESTS:

M AllinquestswillbeheldINPERSONwithacourt reporter.

M ANoteof Issuemust befiledpriortotheInquest with proofemailedtothePart.

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M The Stipulation of Settlement, if any, must be filed with the judgment papers within 60

days of the inquest.

PRELIMINARYCONFERENCES

M A preliminary conference will be held IN PERSON on a date selected by the Court.

The Conference must be held within 45 days of the filing of the RJI. The party

seeking judicial intervention is required to notify the opposing party of the

preliminary conference date. Orders directing Preliminary Conferences will only be

e-filed via the NYSCEF system.

M Counsel for all parties shall consult prior to the preliminary conference about the

substantive issues and discovery schedule and shall make a good faith effort to reach

an agreement on these matters, whether in whole or in part.

M Beforethe preliminaryconference, counsel or parties must upload to NYSCEF:

(i) acompleted andsignedmatrimonial PreliminaryConferenceOrder form;

(ii) Statements ofNetWorth completewith copiesofretainerandmost recentfiled

tax returns; and

(iii) where applicable, a child support worksheet and proposed parentingplan.

M Counsel and/or parties must bring to the Preliminary Conference hard-copies of the

proposed Preliminary Conference Order, Statements of Net Worth and attachments,

child support worksheet and proposed parenting plan.

M Parties and counsel should be prepared to discuss all substantive issues in the case,

including settlement, to the extent possible.

M Please be advised that 22 NYCRR 202.16 was amended as of July1, 2022. You must

complete and submit the most recent preliminary order, which you will find at end of

the statute or on the Courts’ website in Matrimonial -Divorce Forms and instructions:

https://www.nycourts.gov/media/12391

M Therewill benoadjournmentsof thepreliminary conferencebeyondthe45days

from the filing of the RJI without express permission from the Court.

SUBMISSIONOFJUDGMENT

M All proposed judgmentsand final papersmust be e-filed.

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M AlljudgmentsshallincludeacompletedcopyoftheMatrimonialClerk’sOffice’s

contested judgment checklist, indicating all necessary attachments.

M Pursuant to 22 NYCRR 202.48, proposed judgments with proof of service on all

parties must be submitted for signature, within sixty (60) days, unless otherwise

directed by the court.

Updatedasof April29,2024

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