Court Rules
Judge

Judge Dana M. Catanzaro

Individual Rules, Standing Orders & Policies

New York Supreme Court, New York County

Limits & Logistics

Document Limits

Memorandum Of LawCourt-wide
30 pgs

Courtesy Copies

Courtesy copies

Court-wide

Proposed Order

Court-wide

Adjournments

  • A Note of Issue extension may be requested by letter emailed to the Part 37 address, explaining the need for additional time, identifying prior extensions, and stating whether all parties consent.

Request must include

Reason For RequestPrevious Requests Granted Or Denied
2Business Daysnotice
  • An adjournment request must be emailed to the Part 37 Clerk with all parties copied at least two business days before the scheduled appearance, and an unconsented request must state good cause.
Reason For Request

Communication

Email

Clerk

sfc-part37-clerk@nycourts.gov
Scheduling
Phone

Clerk

Hours: 9:30 a.m. to 12:50 p.m. and 2:15 p.m. to 4:30 p.m.
Phone

Chambers

Emergencies
Email

Duty Judge

Scheduling
Phone
Court-wide

Intake Unit

646-386-3033
SchedulingTechnical Issues
Phone
Court-wide

Clerk

646-386-3687
Phone
Court-wide

Clerk

646-386-3682
Scheduling
Filters:AllMandatoryImportantConferencesDiscoveryProposed OrdersLettersJuryEvidence/WitnessesOral ArgumentSettlement

Document Filing Requirements9 rules

Filing Requirements

Checked against the court's document on Oct 5, 2026Mandatory

Every discovery motion must be accompanied by a separate good-faith affirmation under 22 NYCRR § 202.7.

Parties filing discovery motions must include a separate affirmation of good faith (22 NYCRR §202.7).

Document Type

Discovery Motion

Specific requirements detailed in rule text.
Filing Requirements

Checked against the court's document on Oct 5, 2026Mandatory

A request for temporary restraint in an Order to Show Cause must provide proof of advance notice to all parties or a reasonable explanation for why advance notice could not be provided.

If a party seeks a temporary restraint in an Order to Show Cause, they must comply with 22 NYCRR §202.7-f, providing proof that all parties were notified about the application and the time, date and manner that the application will be presented, or provide a reasonable explanation why such advance notice cannot be provided.

Document Type

Order To Show Cause

Specific requirements detailed in rule text.
sfc dmc-part-37-rules-9 10 26 · p. 4
|SecVII. ORDERS TO SHOW CAUSE AND SPECIAL PROCEEDINGS
Filing Requirements

Checked and corrected to match the court's document on Oct 5, 2026Mandatory

At the pretrial conference, parties must serve and submit a witness list, proposed jury instructions and verdict sheets in Word format, prior dispositive decisions, and all marked pleadings and bills of particulars to the Part 37 email.

The parties shall serve and submit the following to the Part 37 email (sfc-part37@nycourts.gov) as directed at the Pre-Trial Conference. 1. Witness list (to include any interpreters needed) 2. Proposed jury instructions in Word format with PJI numbers 3. Proposed Jury Verdict Sheets in Word format 4. Copies of all prior dispositive decisions on the case, including but not limited to any appellate decisions and any preclusion decisions 5. All marked pleadings and bills of particulars

Document Type

Pretrial Submissions

Specific requirements detailed in rule text.
Filing Requirements

Checked against the court's document on Oct 5, 2026Mandatory

An Order to Show Cause is required for specified statutory, stay, or emergency-interim-relief proceedings; the proposed order must provide for service of responsive papers, and reply papers are prohibited without express court permission.

A motion or special proceeding shall only be initiated by Order to Show Cause, where required by statute, a stay is required or where emergency interim relief is sought. Any proposed Order to Show Cause shall include a provision for the service of responsive papers, with a space reserved for the date and method of service, which will be filled in by the Court. Reply papers are not permitted except by express permission of the Court.

Document Type

Order To Show Cause

Content & Formatting
Proposed Order
sfc dmc-part-37-rules-9 10 26 · p. 4
|SecVII. ORDERS TO SHOW CAUSE AND SPECIAL PROCEEDINGS
Filing Requirements

Checked against the court's document on Oct 5, 2026Important

Oral argument is ordinarily held in person on Tuesdays; a party must submit a letter to the Part 37 Clerk copying all parties to request oral argument when the Court has not scheduled it.

Oral argument on motions will be held on Tuesdays IN PERSON unless otherwise indicated. Not all motions will be scheduled for oral argument. If the Court has not scheduled a motion for oral argument and a party wishes to request oral argument, they must submit a letter to the Part 37 Clerk, copying all parties on the matter. If after reviewing the request, the Court determines that oral argument is warranted, the parties will be notified of an oral argument date. Motions submitted on default or without opposition are generally not scheduled for oral argument.

Document Type

Oral Argument Request

Specific requirements detailed in rule text.
Filing Requirements

Checked and corrected to match the court's document on Oct 5, 2026Important

After trial assignment, the Court will schedule a pretrial conference, and parties must be prepared to discuss liability, damages, dispositive decisions, settlement efforts, anticipated rulings, witnesses, interpreters, and accommodations.

Once a trial is assigned to Part 37, the Court shall schedule a Pre- Trial Conference. Parties must be prepared to discuss the case fully, including: their position on liability and damages; prior dispositive decisions; any and all settlement attempts; anticipated pre-trial rulings; the number of witnesses and whether language interpreters or special accommodations will be needed.

Document Type

Pretrial Conference

Specific requirements detailed in rule text.
Filing Requirements

Not confirmed. Read the court's wording below.Mandatory?

Proposed orders must be signed by all parties, submitted as an attachment to an email and sent to sfc-part37-clerk@nycourts.gov with all parties cc’d on the email. Ex-parte emails are not permitted and will not receive a response.

Summary: A proposed conference order must be signed by every party and emailed as an attachment to the Part Clerk with all parties copied; ex parte emails are prohibited.

Document Type

Proposed Order

Content & Formatting
Proposed Order
Filing Requirements

Not confirmed. Read the court's wording below.Mandatory?

The discovery motions filed must include a copy of the letter/email/correspondence to the Court.

Summary: A discovery motion must include a copy of the parties' conference letter, email, or other correspondence with the Court.

Document Type

Discovery Motion

Specific requirements detailed in rule text.
Filing Requirements

Not confirmed. Read the court's wording below.Mandatory?

Any attorney or party who uses a generative AI tool, as defined in 22 NYCRR 161.2(b), in preparing any paper, as defined in 22 NYCRR 161.2(c), filed in or submitted to this court or served on another party in a case before this court is required to carefully review the paper and independently ensure that it contains no fabricated or fictitious cases, statutes, or other material. By signing such paper, an attorney or party certifies that such a review has been conducted and that the paper contains no such fabricated or fictitious content.

Summary: An attorney or party using a generative AI tool must review the resulting paper and certify by signing that it contains no fabricated or fictitious material.

Document Type

Paper

Content & Formatting
Ai Disclosure

Filing & Service rules

Electronic Filing Rules

Parties must not e-file proposed conference orders; the Part Clerk will upload the signed orders to NYSCEF.

Do not e-file proposed orders on NYSCEF. The Part Clerk will upload the signed orders to NYSCEF.

Checked and corrected to match the court's document on Oct 5, 2026

Page 1 | II. CONFERENCES

Part 37 generally requires mandatory electronic motion filing, except for a pro se litigant or a showing of undue hardship.

Part 37 is a mandatory e-filing part. Absent a pro se litigant or a showing of undue hardship, all motions must be electronically filed with the General’s Clerk Office.

Checked and corrected to match the court's document on Oct 5, 2026

Page 2 | III. MOTION PRACTICE

Correspondence must not be uploaded to NYSCEF.

Additionally, no correspondence should be uploaded to NYSCEF.

Not confirmed. Read the court's wording below.

Page 1 | I. GENERAL/COMMUNICATION WITH THE COURT

Filing Timing and Cure Windows

Parties may avoid a conference appearance by submitting a proposed conference order at least one day before the conference.

The parties may submit a proposed conference order at least one day prior to the conference date in lieu of appearing.

Checked against the court's document on Oct 5, 2026

Page 1 | II. CONFERENCES

A summary judgment motion must be filed no later than 120 days after filing the Note of Issue.

Motions for summary judgment must be filed no later than one hundred and twenty (120) days after the Note of Issue is filed.

Checked and corrected to match the court's document on Oct 5, 2026

Page 2 | III. MOTION PRACTICE

Failure to timely file the Note of Issue or request additional time may result in disposition of the action.

The failure to file the Note of Issue by a given date or to timely request an extension and/or move for additional time may result in the action being disposed.

Checked and corrected to match the court's document on Oct 5, 2026

Page 3 | V. NOTE OF ISSUE

Motions in limine must be served and filed by 5 p.m. on the next business day after the pre-trial conference.

C. Motions in Limine: Motions in Limine shall be served and filed no later than 5 pm on the next business day following the pre-trial conference with opposition papers served and filed no later than 5pm on the next business day.

Checked against the court's document on Oct 5, 2026

Page 5 | C. Motions in Limine

Service and Proof of Service Rules

Parties seeking a judicial subpoena must email the documents for review and an attorney affirmation explaining why the subpoena is necessary to sfc-part37-clerk@nycourts.gov, copying only the parties to the action.

Parties seeking a judicial subpoena must include the documents for review and an attorney affirmation giving the reasons why a judicial subpoena is necessary. The documents must be emailed as attachments to sfc-part37-clerk@nycourts.gov with only the parties to the action copied.

Checked and corrected to match the court's document on Oct 5, 2026

Page 4 | VI. JUDICIAL SUBPOENAS

Motion and opposition papers, if any, must also be emailed to the Part 37 email address with all parties copied.

In addition to filing the Motions in Limine, motion papers and opposition papers (if any) must also be emailed to the Part 37 email with all parties copied.

Checked against the court's document on Oct 5, 2026

Page 5 | C. Motions in Limine

Pre-Motion Conference Requirements

Before filing a discovery motion other than a motion to vacate the Note of Issue, a party must first request a conference by submitting an email letter copied to all parties, explaining the anticipated motion in no more than two pages and detailing prior good-faith efforts to resolve the dispute.

A party seeking to make a discovery motion (other than motions to vacate the Note of Issue) must first request a conference with the Court by submitting a letter to sfc-part37-clerk@nycourts.gov, with all parties copied, stating the reason for the anticipated motion (not to exceed two [2] pages in length). In addition, parties intending to make a discovery motion are to detail the good faith efforts made in advance to resolve the discovery dispute.

Checked against the court's document on Oct 5, 2026

Page 2 | III. MOTION PRACTICE

Discovery motions must include a good-faith showing of efforts made or attempted to resolve the dispute through in-person, virtual, or telephone conferences; email exchanges alone are insufficient.

and dates the parties met and conferred in person, virtually, or had telephone conversations to resolve the motion issue. Email attempts or communications between the parties are insufficient to satisfy an affirmation of good faith. Discovery motions filed without a showing of good faiths efforts made or attempted to resolve the matter will be denied.

Checked against the court's document on Oct 5, 2026

Page 3 | III. MOTION PRACTICE

The Court encourages parties to resolve discovery disputes without filing motions.

The Court encourages parties to resolve discovery disputes without motion practice.

Checked against the court's document on Oct 5, 2026

Page 2 | III. MOTION PRACTICE

After the required conference, a party may file a discovery motion concerning the issues identified in its conference letter.

Following a conference with the Court, as outlined above, parties may file discovery motions regarding the issues outlined in the aforementioned letter to the Court.

Not confirmed. Read the court's wording below.

Page 2 | III. MOTION PRACTICE

Every Order to Show Cause must first be processed by the Ex Parte Motion Office, and the movant should confirm processing and submission to Chambers before asking the Part Clerk about its status.

All Orders to Show Cause must first be processed by the Ex Parte Motion Office. A movant should first contact the Ex Parte Motion Office to ensure that the Order to Show Cause has been processed and submitted to Chambers before inquiring with the Part Clerk about the status of the Order to Show Cause.

Not confirmed. Read the court's wording below.

Page 4 | VII. ORDERS TO SHOW CAUSE AND SPECIAL PROCEEDINGS

Adjournment & Extension Requirements

An adjournment request must be emailed to the Part 37 Clerk with all parties copied at least two business days before the scheduled appearance, and an unconsented request must state good cause.

Parties requesting an adjournment must e-mail the Part 37 Clerk sfc-part37-clerk@nycourts.gov no later than 5 p.m. two (2) business days prior to the scheduled appearance date, with all parties cc’d. If the adjournment request tin on consent of all parties, the e-mail should indicate as such. If all parties do not consent to the adjournment, the party seeking the adjournment must set forth good cause for the adjournment request.

Checked against the court's document on Oct 5, 2026

Page 3 | IV. ADJOURNMENT REQUESTS

A Note of Issue extension may be requested by letter emailed to the Part 37 address, explaining the need for additional time, identifying prior extensions, and stating whether all parties consent.

The Note of Issue date given on the Preliminary Conference Order will govern, unless an extension for good cause is requested and granted. An extension of time to file the Note of Issue may be requested via letter, to be So Ordered by the Court. The letter shall be emailed to the Part 37 email (sfc-part37@nycourts.gov) and shall explain why additional time is needed, indicate whether any prior extensions were granted and advise as to whether the request is on consent of all parties.

Checked against the court's document on Oct 5, 2026

Page 3 | V. NOTE OF ISSUE

Chambers Communication Rules

Do not contact chambers about adjournment requests or appearance questions.

Please DO NOT contact chambers regarding adjournment requests or questions concerning appearances.

Checked and corrected to match the court's document on Oct 5, 2026

Page 1 | I. GENERAL/COMMUNICATION WITH THE COURT

Chambers may be telephoned only for an emergency and only after the Part Clerk cannot be reached.

Telephone calls to Chambers are only permitted in emergency situations and after being unable to reach the Part Clerk.

Checked against the court's document on Oct 5, 2026

Page 1 | I. GENERAL/COMMUNICATION WITH THE COURT

Unless instructed otherwise, emails to the Court or Part Clerk must copy every party, include the purpose, index number, and case name in the subject line, and identify the sender and represented party.

Unless otherwise instructed, all emails sent to the Court or to the Part Clerk must carbon copy (cc) all parties in the action, and the subject line must include the purpose of the email, the index number, and case name. E-mails should also identify the sender and the party the sender represents.

Checked against the court's document on Oct 5, 2026

Page 1 | I. GENERAL/COMMUNICATION WITH THE COURT

Noncompliant and ex parte emails to the Court are prohibited and will receive no response.

E-mails sent to the Court not following these instructions, including ex-parte e-mails, are not permitted and will not receive a response.

Checked against the court's document on Oct 5, 2026

Page 1 | I. GENERAL/COMMUNICATION WITH THE COURT

Telephone the Part Clerk only during the stated business hours and only for matters not addressed elsewhere in the standing order.

Telephone calls should be made only to the Part Clerk during the business hours of 9:30 a.m. to 12:50 p.m. and 2:15 p.m. to 4:30 p.m. and limited to matters otherwise not explained below.

Checked against the court's document on Oct 5, 2026

Page 1 | I. GENERAL/COMMUNICATION WITH THE COURT

A party seeking a good-cause discovery stay during summary judgment practice must request a conference by emailed letter stating the filing date and sequence number of the summary judgment motion and briefly explaining why discovery should be stayed.

A party seeking to stay discovery for good cause must request a conference with the Court by letter. The letter is to be submitted by email and include when the summary judgment motion was filed, the sequence number of the motion and briefly state the reasons why discovery should be stayed.

Not confirmed. Read the court's wording below.

Page 2 | III. MOTION PRACTICE

The parties may email the Part Clerk at any time to schedule a settlement conference appearance.

If the parties wish to conference with the Court, at any time, they mail email the Part Clerk to schedule an appearance.

Not confirmed. Read the court's wording below.

Page 2 | II. CONFERENCES

Court-wide rules

Applies court-wide

These 265 rules apply across New York Supreme Court, New York County. Where this judge's own standing orders above address the same topic, the judge's requirement controls.

Filing Requirements

All 60
  • Applies to
    Filing agent authorization

    A filing agent must submit an authorization form before or with the attorney’s first NYSCEF filing in the action.

  • Applies to
    Hard copy documents
    Must include
    notice of electronic filing

    Nonparticipating counsel must submit the original hard-copy documents, an additional unbound copy, and a Notice of Hard-Copy Submission simultaneously.

  • Applies to
    Attorney filing account
    Must include
    notice of electronic filing

    An attorney using a filing agent must have a User ID and password so the agent’s filings are associated with the attorney of record.

E-Filing

All 59
  • For cases commenced on or after February 19, 2013, e-filing through NYSCEF is mandatory except for the listed case types, and all subsequent documents must be e-filed.

  • An attorney lacking the equipment or knowledge to e-file, and lacking qualifying staff support, may opt out of mandatory e-filing by filing Form EFM 2 with the Clerk.

  • Unrepresented litigants are automatically exempt from mandatory e-filing but may voluntarily participate.

Filing Timing

All 38
  • Deadline
    3 business days

    Failure to electronically refile hard-copy documents within three business days will cause the originals to be discarded and may result in an incomplete court record.

  • A motion on notice or notice of petition must be e-filed no later than eight days before the return date.

  • Deadline
    24 hours

    The Clerk normally takes 24 hours to review and process a proposed order to show cause.

Sealing

All 25
  • To correct an electronically filed document containing confidential data or filed in error, notify the parties and non-party filers, request restricted status through NYSCEF, and file an order to show cause within five business days seeking temporary relief and correction; restricted status expires after five days unless extended by the required notification and order.

  • An order granting relief to correct a filing must be submitted to the County Clerk using the applicable notice form, with the sealing-order procedure using the NYSCEF sealing notification and a copy of the order.

  • An infant's compromise application must be filed through NYSCEF in redacted form, with an unredacted copy submitted for the Justice's action.

About Judge Dana M. Catanzaro

- **Appointed:** Appointed an Acting Justice of the Supreme Court, New York County by Chief Administrative Judge Joseph A. Zayas, effective January 2026 - **Elected:** Elected to the New York City Civil Court in November of 2023 - **Prior position:** Served as a Judge of the Civil Court in New York County in 2024 and 2025 - **Education:** Bachelor's degree in Psychology, Fairfield University - **Education:** J.D., New York Law School - **Prior position:** Partner at a national law firm, where she litigated high exposure personal injury lawsuits arising out of construction accidents from inception through trial

- **Address:** 111 Centre Street, New York, NY 10013 - **Part:** Part 37 General IAS Part - **Chambers:** Room 541 - **Chambers Phone:** (646) 386-3181 - **Courtroom:** Room 684 - **Courtroom Phone:** (646) 386-3222 - **Law Clerk:** Morgan E. Mueller, Esq.

Common questions about Judge Dana M. Catanzaro's rules

Does Judge Dana M. Catanzaro require a pre-motion conference or letter before filing a motion?

Yes. A pre-motion letter is required for discovery. Details: 2 pages. Before filing a discovery motion other than a motion to vacate the Note of Issue, a party must first request a conference by submitting an email letter copied to all parties, explaining the anticipated motion in no more than two pages and detailing prior good-faith efforts to resolve the dispute.

View ruleSource: page 2, section III. MOTION PRACTICE

What must be included with proposed order filings before Judge Dana M. Catanzaro?

The rule requires proposed order. A proposed conference order must be signed by every party and emailed as an attachment to the Part Clerk with all parties copied; ex parte emails are prohibited.

View ruleSource: page 1, section II. CONFERENCES

What must be included with discovery motion filings before Judge Dana M. Catanzaro?

The rule identifies required filing content or certificates. A discovery motion must include a copy of the parties' conference letter, email, or other correspondence with the Court.

View ruleSource: page 2, section III. MOTION PRACTICE

How may parties contact Judge Dana M. Catanzaro's chambers?

The rule addresses email communications with Judge Dana M. Catanzaro's duty judge. A party seeking a good-cause discovery stay during summary judgment practice must request a conference by emailed letter stating the filing date and sequence number of the summary judgment motion and briefly explaining why discovery should be stayed.

View ruleSource: page 2, section III. MOTION PRACTICE

How do I request an adjournment or extension before Judge Dana M. Catanzaro?

Requests should be made at least 2 business days in advance when this rule applies before Judge Dana M. Catanzaro. The request must include reason for request. An adjournment request must be emailed to the Part 37 Clerk with all parties copied at least two business days before the scheduled appearance, and an unconsented request must state good cause.

View ruleSource: page 3, section IV. ADJOURNMENT REQUESTS

Is electronic filing required before Judge Dana M. Catanzaro?

No. Electronic filing is prohibited for the covered filings. Parties must not e-file proposed conference orders; the Part Clerk will upload the signed orders to NYSCEF.

View ruleSource: page 1, section II. CONFERENCES

What filing deadlines apply to proposed order filings before Judge Dana M. Catanzaro?

Parties may avoid a conference appearance by submitting a proposed conference order at least one day before the conference.

View ruleSource: page 1, section II. CONFERENCES

What rule applies to service for judicial subpoena before Judge Dana M. Catanzaro?

The rule addresses service method, recipient, or timing requirements. Details: method: service by email, recipient: the clerk. Parties seeking a judicial subpoena must email the documents for review and an attorney affirmation explaining why the subpoena is necessary to sfc-part37-clerk@nycourts.gov, copying only the parties to the action.

View ruleSource: page 4, section VI. JUDICIAL SUBPOENAS
Complete rules summary for Judge Dana M. Catanzaro

Do not contact chambers about adjournment requests or appearance questions.

Telephone the Part Clerk only during the stated business hours and only for matters not addressed elsewhere in the standing order.

Chambers may be telephoned only for an emergency and only after the Part Clerk cannot be reached.

Unless instructed otherwise, emails to the Court or Part Clerk must copy every party, include the purpose, index number, and case name in the subject line, and identify the sender and represented party.

A Note of Issue extension may be requested by letter emailed to the Part 37 address, explaining the need for additional time, identifying prior extensions, and stating whether all parties consent.

Noncompliant and ex parte emails to the Court are prohibited and will receive no response.

Correspondence must not be uploaded to NYSCEF.

Parties may avoid a conference appearance by submitting a proposed conference order at least one day before the conference.

A proposed conference order must be signed by every party and emailed as an attachment to the Part Clerk with all parties copied; ex parte emails are prohibited.

Parties must not e-file proposed conference orders; the Part Clerk will upload the signed orders to NYSCEF.

The parties may email the Part Clerk at any time to schedule a settlement conference appearance.

Part 37 generally requires mandatory electronic motion filing, except for a pro se litigant or a showing of undue hardship.

A summary judgment motion must be filed no later than 120 days after filing the Note of Issue.

A party seeking a good-cause discovery stay during summary judgment practice must request a conference by emailed letter stating the filing date and sequence number of the summary judgment motion and briefly explaining why discovery should be stayed.

The Court encourages parties to resolve discovery disputes without filing motions.

Before filing a discovery motion other than a motion to vacate the Note of Issue, a party must first request a conference by submitting an email letter copied to all parties, explaining the anticipated motion in no more than two pages and detailing prior good-faith efforts to resolve the dispute.

After the required conference, a party may file a discovery motion concerning the issues identified in its conference letter.

A discovery motion must include a copy of the parties' conference letter, email, or other correspondence with the Court.

Every discovery motion must be accompanied by a separate good-faith affirmation under 22 NYCRR § 202.7.

Discovery motions must include a good-faith showing of efforts made or attempted to resolve the dispute through in-person, virtual, or telephone conferences; email exchanges alone are insufficient.

Oral argument is ordinarily held in person on Tuesdays; a party must submit a letter to the Part 37 Clerk copying all parties to request oral argument when the Court has not scheduled it.

An attorney or party using a generative AI tool must review the resulting paper and certify by signing that it contains no fabricated or fictitious material.

An adjournment request must be emailed to the Part 37 Clerk with all parties copied at least two business days before the scheduled appearance, and an unconsented request must state good cause.

Failure to timely file the Note of Issue or request additional time may result in disposition of the action.

Parties seeking a judicial subpoena must email the documents for review and an attorney affirmation explaining why the subpoena is necessary to sfc-part37-clerk@nycourts.gov, copying only the parties to the action.

An Order to Show Cause is required for specified statutory, stay, or emergency-interim-relief proceedings; the proposed order must provide for service of responsive papers, and reply papers are prohibited without express court permission.

A request for temporary restraint in an Order to Show Cause must provide proof of advance notice to all parties or a reasonable explanation for why advance notice could not be provided.

Every Order to Show Cause must first be processed by the Ex Parte Motion Office, and the movant should confirm processing and submission to Chambers before asking the Part Clerk about its status.

After trial assignment, the Court will schedule a pretrial conference, and parties must be prepared to discuss liability, damages, dispositive decisions, settlement efforts, anticipated rulings, witnesses, interpreters, and accommodations.

At the pretrial conference, parties must serve and submit a witness list, proposed jury instructions and verdict sheets in Word format, prior dispositive decisions, and all marked pleadings and bills of particulars to the Part 37 email.

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