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New York StateUnified Court System

Hon. Carolyn E. Wade

Part 84 Rules

Courtroom: 423
Court Room Tel.: 347-296-1612

Chambers Room: 381
Chambers Tel.: 347-401-9372
Chambers Fax.: 212-618-5097

Principal Court Attorney: Turquoise Haskin, Esq.
Assistant Law Clerk: Kwok Kei Ng, Esq.
Part Clerk: Danielle Becket
Court Officer: Officer Thorance Scott



Non-disclosure related motions may be adjourned once, upon consent of the parties, with a schedule for briefing. Any further adjournments must be made upon application to the Court for good cause. The stipulation, with an adjournment date pre-approved by the Court, shall be faxed to chambers at (212) 618-5097 or emailed to the Principal Court Attorney at and the Assistant Law Clerk at


Appearances must be made by attorneys with knowledge of the case and the pending motion.


All court conferences will be held in Courtroom 423, at 360 Adams Street, Brooklyn, New York. There will be two calls of the calendar for conferences, which will commence promptly at 9:45 A.M. and 10:30 A.M. All parties must appear by counsel unless the Court was notified in advance that the matter was settled, discontinued, dismissed, or otherwise disposed of. 


Pursuant to Uniform Rule 202.27, the Court has discretion in addressing a calendar default. Thus, an action may be dismissed, or judgment entered for the failure of a party to appear for a conference or hearing, or a motion marked off if the movant fails to appear on the return date.

Similarly, a motion, if appropriately supported, will likely be granted upon the failure of the non-moving party to appear. The Part Clerk will mark the motion “RESERVED” and the movant will submit a proposed order to the Part Clerk. 
counsel is advised that if a motion has been marked ready and no one appears to argue the motion when it is called to be heard, a default may be taken against the party who answered ready and then failed to appear.


Courtesy copies of all motion papers, opposition papers, reply papers, and proposed orders shall be submitted to chambers or the courtroom at least ONE WEEK prior to the return date of the motion.

Courtesy copies for E-filed matters shall be submitted to Chambers or to the Part Clerk in the Courtroom.

All courtesy copies shall have the NYSCEF Confirmation Notice attached.

Courtesy copies shall have exhibits tabbed.


Motions will be heard every other Friday (except legal holidays) in Courtroom 423, at 360 Adams Street, Brooklyn, New York.

All motions require appearances and oral arguments.

The first call of the calendar is at 9:45 A.M. The second call of the calendar is at 10:30 A.M. promptly. Judge Wade is on the bench for both calendar calls.

Applications will be taken after the calendar call. Parties must be ready to proceed in the event the application is denied.

Parties are encouraged to resolve discovery motions and to present consent orders for signature, listing the specific items outstanding and the dates for production. On all other motions, all parties must be present and ready for argument.

If you must leave to go to another part, inform the Part Clerk of your whereabouts and cell phone number prior to leaving the courtroom.

Except those motions with briefing schedules, all motion papers, opposition papers, and reply papers shall be served on adversaries as per CPLR ' 2214.

All motions are to be submitted with proposed orders. The Court’s signature line must not appear on a page with no writing.

Exhibit tabs are required on all papers filed with the Court. Exhibit tabs shall immediately precede an actual exhibit (i.e., not a blank page denoted “Exhibit __”). Affirmations, affidavits, and legal memoranda must be double-spaced.

Summary judgment motions must be made within sixty (60) days of the filing of the note of issue.

Proposed orders to show cause must be brought to the Ex Parte Motion Support Office for review prior to submission to the part. Fees as required by law must be paid to the County Clerk prior to submission.


All parties must be present in court by 9:30 A.M. unless otherwise scheduled with the Court.

Bill of Particulars/Marked Pleadings. Prior to trial, counsel shall furnish to the Court the bill of particulars, and the marked pleadings pursuant to CPLR ' 4012. 

Exhibits. Counsel shall pre-mark all exhibits in the order which they intend to introduce them at trial. A list of the exhibits shall also be provided to the Court prior to trial. Plaintiffs will number their exhibits and defendants will letter their exhibits. On the day of trial the exhibits and the list will be given to the Part Clerk who will officially mark them before trial. It is the responsibility of the attorneys to ensure that subpoenaed records have arrived in the Subpoenaed Record Room.

Witnesses. Prior to trial, Counsel shall provide to the court a list of potential witnesses in the order in which they intend to call them at trial, including expert witnesses, their expertise, and summary of expected trial testimony, and any interpreters needed.

Motions in Limine. Any potential evidentiary question or procedural or substantive law matter not previously adjudicated shall be brought to the Court's attention and addressed prior to trial by way of a written or oral motion in limine. A written memorandum of law with citations to the Official Reports is required. Citations and copies of relevant court decisions and statutes should be furnished to the Court prior to commencement of plaintiff's case and when otherwise requested by the Court.

Depositions. A copy of depositions intended to be used at trial should be furnished to the Court at the commencement of the trial. If any part of a deposition is to be read into evidence (as distinguished from mere use on cross-examination) you must, well in advance, provide the Court and your adversary with the page and line number of all such testimony so that all objections can be addressed prior to use before the jury.

Proposed Jury Charges and Verdict Sheets. All proposed jury charges and proposed verdict sheets shall be submitted to the Court in typed form no later than the close of plaintiff's case. Additionally, proposed jury charges and the proposed verdict sheet shall be emailed to the Court (, in editable text format such as WordPerfect or MS Word (.doc) format.


Petitions for compromise orders must be filed through Motion Support or through Special Term Part 72.

Hearings will be scheduled by the Court. Any adjournments must be obtained through chambers.

Infant Compromise petitions must comply with CPLR § 1208. If any portion of the settlement is structured, the cost of the annuity must be stated in the order. The attorney’s affirmation must account for all defendants named in the caption and indicate dismissals, discontinuances or defaults in appearances. A current medical report, physician affirmation, and affirmation of no liens are required with the submissions.

Death Compromise petitions must comply with the provisions of EPTL § 5-4.6 and include an affirmation of no liens or, where liens are asserted, documentation of such liens. The Order must include a directive for payment of liens.

If a Compromise Order was signed as to a previously settling defendant, such order must be attached as an exhibit and the partial settlement so stated in the attorney affirmation in support of the final Compromise Order.

Amendments to compromise orders must include a copy of the original compromise order and an attorney affirmation detailing the proposed amendment and the reason for it, in addition to any other necessary papers.

All submissions must be separated by exhibit tabs.

The Court’s signature line must not appear on a page with no writing.


All Stipulations of Discontinuance shall be paid for in the County Clerk’s office and filed in Motion Support.

Stipulations of Discontinuance involving an infant or a death case shall be submitted as noted above and shall include a brief attorney affirmation in support of the request for the stipulation to be so ordered.


The Kings County Supreme Court Uniform Civil Term Rules can be located at:


All inquiries as to case or calendar status should, in the first instance, be made to the E-FILE/MOTION SUPPORT OFFICE, Room 227, Telephone (347) 401-9249. Chambers staff is not permitted to provide guidance or advice to attorneys or litigants.
No correspondence between attorneys shall be sent to chambers, other than stipulations signed by all parties.
If the parties agree to a conference with the Court in lieu of further motion practice, the parties may contact chambers by conference call to schedule a meeting.



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