provision_id,doc_id,judge_id,rule_number,title,text,source_page,topics,cross_references,judicial_district,county,court_type,doc_type ARP45-PCO-1,176,NY-COMDIV-RATHOD-PATEL,¶1,Confidentiality Agreement and Order,The parties are directed to Commercial Division Rule 11-g and Appendix B thereto for the form Stipulation and Order for the Production and Exchange of Confidential Information. Deviations from the form require filing of: (1) a copy of the parties' proposed confidentiality order; (2) a redline; and (3) a letter articulating reasons for deviations.,,"[""discovery-scheduling"", ""e-discovery""]","[""Commercial Division Rule 11-g"", ""Appendix B""]",1,New York,supreme,preliminary_conference_order ARP45-PCO-10,176,NY-COMDIV-RATHOD-PATEL,¶10,Motions – Pre-Motion Conference and Summary Judgment Deadline,"Pre-motion conferences are required before making any application to the Court. Any dispositive motions shall be served within forty-five (45) days of the filing of the Note of Issue, unless otherwise directed by the Court.",,"[""summary-judgment"", ""note-of-issue""]",[],1,New York,supreme,preliminary_conference_order ARP45-PCO-3,176,NY-COMDIV-RATHOD-PATEL,¶3,Exchange of ESI,"The parties shall execute a stipulation reflecting their agreement as to exchanging ESI by the date set in the order, or if there is no agreement or only partial agreement, notify the Court.",,"[""e-discovery"", ""discovery-scheduling""]","[""Commercial Division Rule 11-c""]",1,New York,supreme,preliminary_conference_order ARP45-PCO-5,176,NY-COMDIV-RATHOD-PATEL,¶5,Expert Discovery Schedule,Parties shall serve expert disclosure on or before the date set in the order. Expert Discovery shall be completed on or before the date set in the order.,,"[""expert-disclosure"", ""discovery-scheduling""]","[""Commercial Division Rule 13""]",1,New York,supreme,preliminary_conference_order ARP45-PCO-9,176,NY-COMDIV-RATHOD-PATEL,¶9,Discovery Disputes,"Counsel shall comply with this Court's Practices and Procedures and Commercial Division Rule 14. If counsel cannot resolve a discovery dispute after good faith consultation, counsel shall promptly notify the Court via letter filed on NYSCEF to schedule a virtual conference, otherwise the issue(s) will be waived. No motion relating to discovery shall be made without the permission of the Court.",,"[""discovery-disputes"", ""conference-procedures""]","[""Commercial Division Rule 14""]",1,New York,supreme,preliminary_conference_order