New York Codes, Rules and Regulations
Title 22 - JUDICIARY
Subtitle A - JUDICIAL ADMINISTRATION
Chapter II - UNIFORM RULES FOR THE NEW YORK STATE TRIAL COURTS
Part 202 - Uniform Civil Rules for the Supreme Court and the County Court
Section 202.70 - Rules of the Commercial Division of the Supreme Court
Rule 202.70.31 - Pre-Trial Memoranda, Trial Exhibits and Requests for Jury Instructions

(a) If requested by the Court, counsel shall submit pre-trial memoranda at such time as the court may set. Counsel shall comply with CPLR 2103(e). A single memorandum of no more than 7,000 words shall be submitted by each side. No memoranda in response shall be submitted.

(b) At the pre-trial conference or at such other time as the court may set, counsel shall submit a copy of trial exhibits for each attorney's and the court's use. Unless otherwise directed in the Court's individual part rules, plaintiff's exhibits shall be tabbed numerically, and defendant's exhibits shall be tabbed alphabetically.

(c) Where the trial is by jury, counsel shall, on the pre-trial conference date or such other time as the court may set, provide the court with case-specific requests to charge and proposed jury interrogatories. Where the requested charge is from the New York Pattern Jury Instructions--Civil, a reference to the PJI number will suffice.

(d) In cases brought before paperless commercial parts, counsel shall submit the pre-trial memoranda, copy of trial exhibits and requests to charge on a USB flash drive. In all other commercial parts, counsel shall submit the pre-trial memoranda and requests to charge in a Word document, 12-point type, and submit the copy of trial exhibits in an indexed binder or notebook.