Judge Sharon M.J Gianelli
Individual Rules, Standing Orders & Policies
Limits & Logistics
Courtesy Copies
Courtesy copies
Adjournments
- A written conference-adjournment request must be emailed to the court, copied to all parties, and state whether it is consensual; absent extraordinary circumstances, it should be submitted at least 48 hours before the conference and explain the reason, while a participating attorney may request for a self-represented party.
Communication
Chambers
Document Format Requirements3 rules
Checked against the court's document on Oct 5, 2026Mandatory
Parties must submit an indexed binder of trial exhibits for the court, a copy for each attorney, and a binder of original exhibits for witnesses, preferably at the pre-trial conference and no later than 14 days before trial unless otherwise instructed.
Exhibits. Again, the parties shall submit to the Court for its use at trial, an indexed binder of trial exhibits, along with a copy for each attorney and a binder of the originals for witnesses, preferably at the pre-trial conference, but no later than at least 14 days prior to the start of trial, unless otherwise instructed.
Checked against the court's document on Oct 5, 2026Mandatory
Counsel must provide the court a marked flash drive containing copies of the exhibits corresponding to the indexed trial-exhibit binder on the first day of trial or by another date selected by the court.
On or before the first day of trial, or by a date otherwise selected by the Court, counsel shall provide the Court with a flash drive containing copies of their exhibits corresponding to the indexed binder of trial exhibits. Flash drives are to be marked with the short caption and index number of the case.
Checked against the court's document on Oct 5, 2026Important
Proposed jury instructions must be submitted in Word format, identify stipulated instructions, and highlight and explain proposed deviations with legal citations where appropriate.
Proposed jury instructions, including the text of relevant PJI instructions are to be submitted by e-mail to Chambers at judgegianelliremote@nycourts.gov, in Word format. The submissions should note the instructions to which the parties have stipulated. Any proposed deviations from PJI instructions should be highlighted and explained, with citations to legal authority where appropriate.
Document Filing Requirements14 rules
Checked against the court's document on Oct 5, 2026Mandatory
The motion sequence number must appear on the front page of every paper related to the motion or cross-motion.
All motion papers shall have the motion sequence number on the front page of all papers related to the motion or any cross-motion.
Document Type
Motion
Checked against the court's document on Oct 5, 2026Mandatory
A citation to deposition or other testimony must identify the exhibit, page, and line number where the testimony appears.
Where reference is made in a motion, or order to show cause, to testimony from a deposition or elsewhere, the party making such reference shall identify the exhibit, page and line number where the testimony is found.
Document Type
Motion
Checked against the court's document on Oct 5, 2026Mandatory
Electronically submitted memoranda of law must hyperlink cited legal authorities to an accessible legal-research database or a state or federal government website.
That electronically submitted memoranda of law include hyperlinks to cited court decisions, statutes, rules, regulations, treatises, and other legal authorities in either legal research databases to which the Court has access, or in state or federal government websites;
Document Type
Memorandum Of Law
Checked against the court's document on Oct 5, 2026Mandatory
Each motion exhibit must be clearly labeled with its identifying information.
Exhibits to motions shall be uploaded to NYSCEF individually, with each Exhibit clearly labeled with its respective identifying information.
Document Type
Exhibits
Checked against the court's document on Oct 5, 2026Mandatory
Electronically submitted documents citing prior NYSCEF filings must link to the cited docket entries unless the documents are accessible through bookmarks, and links may not provide access to sealed or nonpublic documents.
In addition to each electronically submitted memorandum of law, for other documents that cite to additional documents previously filed with NYSCEF, they shall include a hyperlink to the NYSCEF docket entry for the cited documents, enabling access to the cited documents through the hyperlink. Hyperlinks may not provide access to documents filed under seal or otherwise not in the public record. Cited documents filed with NYSCEF that are accessible through bookmarks in the electronically submitted document need not also be hyperlinked.
Requirement
Document requirement
Checked against the court's document on Oct 5, 2026Mandatory
Every moving and responsive motion paper submitted by notice of motion or order to show cause must include a memorandum of law subject to Commercial Division Rule 17 word limits.
All motion papers, moving as well as responsive, whether by notice of motion or order to show cause, must include a memorandum of law, subject to word limits set forth in Commercial Division Rule 17.
Document Type
Memorandum Of Law
Checked against the court's document on Oct 5, 2026Mandatory
A letter or stipulation confirming the adjourned date must be filed or emailed, served on all parties, and submitted by the motion's return date.
The Court requires the filing or e-mailing of a letter or stipulation confirming the adjourned date, served upon all parties, on or before the return date of the motion.
Document Type
Adjournment Confirmation
Checked against the court's document on Oct 5, 2026Important
Counsel affidavits and affirmations should not contain legal arguments.
Therefore, affidavits or affirmations of counsel should not contain legal arguments.
Document Type
Affidavit
Checked against the court's document on Oct 5, 2026Note
The affirmation requirement does not apply to the identified special-proceeding or order-of-protection motions unless the Court orders otherwise.
Please note that this requirement shall not apply to orders to show cause or motions in special proceedings brought under Article 7 of the Real Property Actions and Proceedings Law, nor to orders to show cause or motions requesting an order of protection under section 240 of the Domestic Relations Law, unless otherwise ordered by the Court.
Document Type
Motion
Checked against the court's document on Oct 5, 2026Note
A request for oral argument may be included in either the notice of motion or the opposition papers.
Requests for oral argument may be included in the notice of motion or in the opposition papers.
Requirement
Document requirement
Not confirmed. Read the court's wording below.Mandatory?
an affirmation demonstrating either that: (a) notice has been given; or (b) notice could not be given despite a good faith effort to do so; or (c) there will be significant prejudice to the movant by the giving of notice.
Summary: An affirmation must establish notice, a good-faith inability to provide notice, or significant prejudice from giving notice, subject to the stated exceptions.
Document Type
Motion
Not confirmed. Read the court's wording below.Mandatory?
Other than a motion for summary judgment pursuant to CPLR 3213, Commercial Division Rule 19-a includes a prescription requiring statements on motions for summary judgment. It prescribes that the movant shall annex to the motion a short and concise statement, in numbered paragraphs, of the material facts as to which the moving party contends there is no genuine issue of fact.
Summary: For summary-judgment motions other than those under CPLR 3213, the movant must annex a short, concise, numbered-paragraph statement of undisputed material facts.
Document Type
Summary Judgment Motion
We could not find this wording in the court's document. Open the source before relying on it.Mandatory?
Opposing papers shall contain a correspondingly numbered paragraph responding to each numbered paragraph in the movant’s statement, and, if necessary, additional paragraphs containing a statement of the material facts upon which the opponent believes that there exists a genuine issue requiring trial.
Machine summary and details
Summary: Opposing papers must respond to each numbered movant paragraph and, when necessary, state additional material facts allegedly requiring trial.
Document Type
Opposition
Not confirmed. Read the court's wording below.Important?
The responsive statement submitted by the non-moving party should include the text of the moving party’s statement to which each paragraph-specific response is addressed.
Summary: A non-movant’s responsive statement should reproduce the movant’s statement text for each paragraph-specific response.
Document Type
Summary Judgment Motion
Filing & Service rules
Electronic Filing Rules
Motion exhibits must be uploaded to NYSCEF individually.
Exhibits to motions shall be uploaded to NYSCEF individually, with each Exhibit clearly labeled with its respective identifying information.
Checked and corrected to match the court's document on Oct 5, 2026
Page 5 | MOTION PRACTICE
Filing Timing and Cure Windows
The parties must provide the identified pre-trial submissions and joint statement of undisputed facts to the court before the pre-trial conference.
Pre-trial submissions required under Commercial Division Rules 26, 27, 28, 29, 31(a), 31(b), and 32, in addition to a joint statement of undisputed facts, shall be provided to the Court in advance of the pre-trial conference.
Checked against the court's document on Oct 5, 2026
Page 3 | Pre-Trial Conference
The parties should submit the indexed trial-exhibit binder at the pre-trial conference and, unless otherwise instructed, must submit it no later than 14 days before trial.
The parties thereafter shall submit to the Court for its use at trial an indexed binder of trial exhibits, along with a copy for each attorney and a binder of the originals for witnesses, preferably at the pre-trial conference, but no later than at least 14 days prior to the start of trial, unless otherwise instructed.
Checked against the court's document on Oct 5, 2026
Page 3 | Pre-Trial Conference
Unless the court directs otherwise, motions in limine must be submitted at least 10 business days before the pre-trial conference and be returnable by that conference date.
Motions in limine are to be submitted no later than 10 business days before the pre-trial conference, unless otherwise directed by the Court, and shall be returnable by the date of the pre-trial conference.
Checked against the court's document on Oct 5, 2026
Page 4 | Pre-Trial Conference
The pre-trial conference must occur within 45 days before the trial start date.
The pre-trial conference is essential to trial preparation. It is to take place within 45 days prior to the trial start date.
Not confirmed. Read the court's wording below.
Page 3 | Pre-Trial Conference
Service and Proof of Service Rules
A party seeking an order to show cause must provide at least 24 hours' notice to all other parties and annex an affidavit or affirmation of notice, unless notice would cause significant prejudice or could not be given despite a good-faith effort.
Consistent with Rules 19 and 20 (in concert with the amendment of The Uniform Civil Rules for the Supreme Court and the County Court, adding new section 202.8-e), a party seeking relief via an order to show cause shall provide a 24-hour minimum notice to all other parties and annex an affidavit or affirmation of notice to the documents, unless the moving party can demonstrate significant prejudice by reason of giving notice, or that notice could not be given despite a good faith effort to do so.
Checked and corrected to match the court's document on Oct 5, 2026
Page 4 | Motion Practice
Unless the court directs otherwise, the movant must give notice of the application's time, date, and place and provide supporting papers to opposing parties sufficiently in advance for them to contest it.
Unless otherwise directed by the Court, the movant must give notice of the time, date and place that the application will be made, and provide copies of all supporting papers to the opposing parties sufficiently in advance to permit them an opportunity to appear and contest the application.
Checked and corrected to match the court's document on Oct 5, 2026
Page 4 | Motion Practice
Specific responses to a document request must be served, or proper objections must be timely made under CPLR 3122(a).
Pursuant to Rule 11-e, specific responses to a document request shall be served, or proper objections timely made pursuant to CPLR 3122(a).
Checked against the court's document on Oct 5, 2026
Page 6 | DISCOVERY
Courtesy Copy Requirements
Courtesy copies of motion papers ordinarily should not be submitted and are appropriate only when requested or otherwise directed.
As we are essentially a paperless part, courtesy copies of motion papers should not be submitted unless requested or otherwise directed.
Checked and corrected to match the court's document on Oct 5, 2026
Page 6 | Courtesy Copies
Sealing & Redaction Procedures
If the parties do not agree to sealing or redaction, the requesting party may proceed by order to show cause with proper reasons and good cause under 22 NYCRR 216.1.
If the parties do not agree, the party seeking to have the document sealed or redacted may proceed by order to show cause giving proper reasons and demonstrating good cause for sealing or redacting pursuant to 22 NYCRR 216.1.
Checked against the court's document on Oct 5, 2026
Page 8 | CONFIDENTIALITY ORDERS AND SEALING
A request for additional redactions or sealing must be made by order to show cause establishing good cause under 22 NYCRR 216.1.
Any request for additional redactions or sealing shall be made by order to show cause and must establish “good cause” pursuant to the Uniform Rules for Trial Courts, 22 NYCRR 216.1.
Checked and corrected to match the court's document on Oct 5, 2026
Page 8 | CONFIDENTIALITY ORDERS AND SEALING
A sealing motion must include an unredacted version of the relevant documents, sent to the court by email for comparison with the motion's redacted versions.
A sealing motion must be accompanied by an unredacted version of the relevant documents, which shall be sent to the Court, via e-mail, for comparison with the redacted form of the documents contained in the motion.
Checked against the court's document on Oct 5, 2026
Page 8 | CONFIDENTIALITY ORDERS AND SEALING
Before filing documents deemed confidential, a party must notify the confidentiality-designating party at least five business days in advance, and the parties must meet and confer within three days after that notice.
Parties wishing to submit documents to the Court which have been deemed confidential shall provide notice to the party who designated them as confidential, at least 5 business days before filing the documents at issue. The parties shall meet and confer within 3 days of such notification.
Checked and corrected to match the court's document on Oct 5, 2026
Page 8 | CONFIDENTIALITY ORDERS AND SEALING
The court may require a sealing motion at any time concerning a request for sealing.
At any time, the Court may require a motion concerning any request for sealing.
Checked against the court's document on Oct 5, 2026
Page 8 | CONFIDENTIALITY ORDERS AND SEALING
If the parties agree that confidential documents present compelling circumstances for sealing, they may proceed through a stipulation setting forth good-cause reasons for the court to so-order.
If the parties agree that the documents demonstrate compelling circumstances for sealing, they may proceed by means of a stipulation setting forth the good cause reasons for sealing, to be considered by the Court, and for the stipulation to be so-ordered.
Checked against the court's document on Oct 5, 2026
Page 8 | CONFIDENTIALITY ORDERS AND SEALING
Sealing and additional redactions are disfavored, and a confidentiality agreement alone does not justify sealing.
Sealing, including redactions beyond those generally permitted (i.e. date of birth, social security number, account numbers…), is not encouraged. The mere fact that a document is subject to a confidentiality agreement is not sufficient in and of itself to warrant sealing (Mancheski v. Gabelli Group Capital Partners, 39 AD3d 499, 502 [2nd Dept. 2007]).
Checked against the court's document on Oct 5, 2026
Page 8 | CONFIDENTIALITY ORDERS AND SEALING
The parties may exchange documents proposed for sealing, but no unsealed version may be filed unless the sealing motion is denied.
While the parties are free to exchange documents sought to be sealed, no unsealed version of the documents shall be filed unless found to be not subject to sealing in an Order on the sealing motion.
Not confirmed. Read the court's wording below.
Page 8 | CONFIDENTIALITY ORDERS AND SEALING
Adjournment & Extension Requirements
A preliminary conference may not be adjourned absent good cause.
A preliminary conference may not be adjourned, except for good cause.
Checked against the court's document on Oct 5, 2026
Page 2 | CONFERENCES — Preliminary Conference
A request to adjourn a motion must be consented to by the other parties, although Chambers will accept counsel's representation of that consent.
Requests for adjournments of motions must be on consent of the other parties, and Chambers staff will accept the representation of counsel that he/she has the consent of the other parties.
Checked against the court's document on Oct 5, 2026
Page 8 | ADJOURNMENTS
A self-represented party may request an adjournment through a participating attorney or by submitting a stipulation signed by all parties.
Self-represented parties seeking an adjournment may have a participating attorney make the request, or submit a stipulation signed by all parties.
Checked against the court's document on Oct 5, 2026
Page 8 | ADJOURNMENTS
A written conference-adjournment request must be emailed to the court, copied to all parties, and state whether it is consensual; absent extraordinary circumstances, it should be submitted at least 48 hours before the conference and explain the reason, while a participating attorney may request for a self-represented party.
Additionally, an adjournment of a scheduled conference may be obtained upon a written request to the Part and the requesting party shall e-mail the request to the Court (judgegianelliremote@nycourts.gov), copied to all parties, and shall include a statement as to whether the adjournment request is on consent. Self-represented parties may have a participating attorney make the request on their behalf. Absent extraordinary circumstances, requests to adjourn should be made no later than 48 hours prior to the scheduled conference date and should articulate a reason for the adjournment request.
Checked against the court's document on Oct 5, 2026
Page 9 | Conferences
Every motion, conference, hearing, or trial adjournment requires prior court approval and notice to all parties.
All adjournments (motions, conferences, hearings, trials) require prior Court approval, on notice to all parties.
Not confirmed. Read the court's wording below.
Page 8 | ADJOURNMENTS
Chambers Communication Rules
Proposed jury instructions, including relevant PJI text, must be emailed to Chambers at the stated address in Word format.
Proposed jury instructions, including the text of relevant PJI instructions are to be submitted by e-mail to Chambers at judgegianelliremote@nycourts.gov, in Word format.
Checked against the court's document on Oct 5, 2026
Page 4 | Pre-Trial Conference