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provisions: NY-SC-1JD-GOETZ-002

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NY-SC-1JD-GOETZ-002 83 NY-SC-1JD-GOETZ II Motion Practice Attorneys appearing before Justice Goetz must be thoroughly familiar with the case. All Counsel must be prepared for settlement discussions and to have their client or adjuster available by telephone. Oral argument on motions will generally only be directed when requested by a party. The movant shall specify in the notice of motion, order to show cause, and in a concluding section of a memorandum of law the exact relief sought; if there is a discrepancy between the notice of motion and the supporting papers, the notice of motion is controlling. Orders to Show Cause: Motions shall be brought on by order to show cause only when there is genuine urgency. Reply papers shall not be submitted on orders to show cause unless authorized by the Court. Temporary Injunctive Relief: As per Rule 202.7(f), any application for temporary injunctive relief, including a TRO, shall be made on at least 24-hours notice to the adversary, absent a showing of significant prejudice. Discovery motions are strongly discouraged. Discovery motions are not to be brought unless prior approval by the court is obtained. If a discovery dispute arises, the parties must meet and confer in a good faith effort to resolve the issues prior to contacting or seeking relief from the Court. If dispute is not resolved, parties are to request a conference with the Court by contacting the Part Clerk. Any discovery motions must be accompanied by a good faith affidavit or affirmation as pursuant to Rule 202.20-f. Summary Judgment Motions: All summary judgment motions must be made no later than 60 days after filing the Note of Issue. There are no exceptions without leave of Court. The motion papers must state the date the Note of Issue was filed and that the motion is timely. Discovery must continue during the pendency of a summary judgment motion unless good cause is shown for a stay; a stipulation will not suffice, any stay must be so-ordered. All summary judgment motions should include a Statement of Material Facts pursuant to Rule 202.8-g. Motion Papers: Must comply with Rule 202.8-b. The motion sequence number must appear on the notice of motion. To request oral argument, include the phrase 'Oral Argument Requested' in bold and all caps. Referring to exhibits and EBT transcripts: each page in any exhibit must be numbered with pinpoint citations.   ["hearing-procedures", "discovery-disputes", "summary-judgment", "note-of-issue", "briefing-schedule"] ["22 NYCRR 202.7(f)", "22 NYCRR 202.20-f", "22 NYCRR 202.8-b", "22 NYCRR 202.8-g"] 1 New York supreme part_rules
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