Hon. Carolyn E. Wade: Part 84 Rules

Courtroom Room Number: 969
Courtroom Telephone Number: (347) 296-1578

Chambers Room Number: 1035
Chambers Telephone Number: (347) 401-9372
Chambers Fax Number: (212) 618-5097

Principal Court Attorney: Turquoise Haskin, Esq., [email protected]
Assistant Law Clerk: Jameson Xu, [email protected]
Part Clerk: Jay Goldstein, [email protected]


Civil Term - Part 84


Updated: April 2, 2024






All requests for adjournments must be made in writing, at least 48 hours before the return date, and e-mailed to the Part Clerk, Jay Goldstein at [email protected].  Reasonable requests for motions that are first time on are generally granted.

Any subsequent adjournment requests must be made upon application to the Court for good cause, unless on consent.  If on consent, parties must submit a stipulation with a proposed return date by e-mail to the Part Clerk, Jay Goldstein at [email protected].


All appearances are IN PERSON. Appearances must be made by attorneys with knowledge of the case and the pending motion.


Oral argument on motions will be held, in person, in Courtroom 969, at 360 Adams Street, Brooklyn, New York.  There will be two calls of the calendar, 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 “FULLY SUBMITTED” 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. 


  1. Motions will be heard every Wednesday (except Court holidays) in Courtroom 969, at 360 Adams Street, Brooklyn, New York. REQUESTS FOR VIRTUAL APPEARANCES WILL NOT BE ENTERTAINED.
  2. All motions require appearances and oral arguments.  Attorneys that appear must be fully familiar with the case and motion(s) at hand.
  3. 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.
  4. Applications will be addressed after the calendar call.  Parties must be ready to proceed in the event the application is denied.
  5. Parties are encouraged to resolve motions and to present consent orders for signature.  Otherwise, all parties must be present and ready for oral argument. 
  6. If you must leave to go to another part, inform the Part Clerk of your whereabouts and provide your cell phone number prior to leaving the courtroom.
  7. Except for those motions with briefing schedules, all motion papers, opposition papers, and reply papers shall be served on adversaries per CPLR § 2214.
  8. All motions may be e-filed with proposed orders by each party.  After oral argument, if a motion is marked “fully submitted,” the parties shall e-mail their proposed orders as the Court instructs, in Word format to both law clerks.  The proposed orders should include controlling case law, and a basis for the Court’s ruling.
  9. 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.
  10. Summary judgment motions must be made within sixty (60) days of the filing of the note of issue.
  11. 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.
  12. All stipulations to adjourn must be e-filed and e-mailed to the Part Clerk ([email protected]) at least 48 hours prior to the return date.


  1. Pre-Trial Conference: Once a trial is assigned to the Court, Chambers will notify the parties of the time and place for a brief conference to schedule trial dates.
  2. Parties are to provide a one-page trial summary sheet which must include:
    • A brief summary of Plaintiff’s cause of action and Plaintiff’s demand.
    • Anticipated length of trial.
    • Attorney contact information (include cell phone number, e-mail, office address and phone number).
    • A schedule of potential witnesses (expert witnesses must provide business addresses, their expertise, and qualifications) and a summary of expected trial testimony.
  3. Interpreters: Parties must notify the Part Clerk of their request for an interpreter at least 48 hours prior to scheduled testimony of the witness. 
  4. Motions in Limine
    1. Any potential evidentiary question 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.  
    2. Written motions in limine shall not exceed three pages, double spaced, and citations to the Official Reporter is required.  Citations and copies of relevant court decisions and statutes should be furnished to the Court prior to the commencement of plaintiff’s case, and when otherwise requested by the Court.
    3. After commencement of trial, all written motions in limine require Court approval prior to their submission.  ANY MOTIONS IN LIMINE SUBMITTED WITHOUT COURT APPROVAL WILL NOT BE CONSIDERED.  
    4. Trial counsel are encouraged to resolve evidentiary issues prior to making motions in limine
  5. Proposed Jury Charges and Verdict Sheets: All proposed jury charges and proposed verdict sheets shall be submitted to the Court and the opposing counsel in typed form no later than the close of plaintiff’s case, or as instructed by the Court.  Additionally, they must be submitted in Word format to the court by e-mail to [email protected]. It is the responsibility of the parties to ensure that all requests to charge are up to date.
  6. 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.
  7. 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 Records Room. 
  8. 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 such testimony so that all objections can be addressed prior to use before the jury.
  9. Trial Objections and Arguments: If a lawyer wishes to make an objection, it can be accomplished by standing and saying the word “objection” and by adding thereto up to three more words so as to state the generic grounds for the objection, such as “hearsay,” “bolstering,” “leading,” or “asked and answered.”  If you believe further argument is required, request permission to approach the bench.  This request will almost always be granted.  Keep in mind that you will always be given the opportunity to make a full record.
  10. All parties must be present in court by 9:30 A.M. unless otherwise scheduled with the Court.


  1. Petitions for compromise orders must be filed through Motion Support or through Special Term Part 72.  Upon filing, all applications must be e-mailed to [email protected].
  2. Virtual hearings will be scheduled by the Court.  Any adjournments must be obtained through chambers. 
  3. 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 of the defendants named in the caption and indicate dismissals, discontinuances or defaults in appearances. A current medical report, physician’s affirmation, and affirmation of no liens are required with the submissions. The proposed order must be e-mailed in Word format, and must include the infant’s full name and date of birth.
  4. Wrongful 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.
  5. 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’s affirmation in support of the final Compromise Order.
  6. Amendments to compromise orders must include a copy of the original compromise order and an attorney’s affirmation detailing the proposed amendment and the reason for it, in addition to any other necessary papers. 
  7. All submissions must be separated by exhibit tabs.
  8. The Court’s signature line must not appear on a page with no writing.


  1. All Stipulations of Discontinuance shall be paid for in the County Clerk’s office and filed in Motion Support. 
  2. Stipulations of Discontinuance involving an infant or a wrongful death case shall be submitted as noted above; and shall include a brief attorney’s 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: http://www.nycourts.gov/kingscivil/KingsCivilSupremeRules.shtml.

All inquiries as to case or calendar status should, in the first instance, be made to the MOTION SUPPORT OFFICE, Room 227, Telephone (347) 296-1694. Chambers staff is not permitted to provide legal advice or guidance to attorneys or litigants.

If necessary, the Part Clerk, Mr. Jay Goldstein, can be contacted at 347-296-1578 ([email protected]). 

Any inquiries pertaining to discovery matters should be directed to the Centralized Compliance Part (CCP) at 347-296-1626.

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 e-mail the Judge’s Law Clerks to request a virtual conference.

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