Emmanuel Kossaris, Esq. 28-03 43rd Street Astoria, NY 11103 Tel (718) 777-0692 Fax (718) 626 6553 Hours 9:00am - 6:00pm M-F

Preliminary Conference Rules
General Rules:

•  The caption, index number, RJI filing date and attorney appearance(s) must be completed.
•  If there is more than one plaintiff and/or defendant in the action, any section which applies to a particular party must specify to which plaintiff and/or defendant the section applies.
•  All sections which are inapplicable or NOT completed must be stricken. A notation of n/a is acceptable.
•  Failure to appear at a preliminary conference that has been previously scheduled may result in an ex parte or default order.
•  All sections which require a date or time period by which to comply must be filled in, or else the court may fill in what it deems appropriate.
•  The order must be dated and signed by all appearing parties.
•  Please be sure the writing on the preliminary conference order is legible.

Responses to Sections:
Question #1 Insurance Coverage: If this section applies to more than one defendant, specify the applicable defendant(s).

Question #2 Bill of Particulars: Parties must specify which party must serve a B.P. demand and which party must serve a B.P.

Question#3 Medical Records and Authorizations: If employment records or school authorizations are requested, the relevant period must be specified, otherwise the court will insert the period it deems appropriate.

Question #4 Physical Examinations: If an Independent Medical Examination has already been held, indicate same.

Question#5 Depositions: Make sure the date selected is a weekday. If the date selected is a Saturday, Sunday or official holiday, the Court will deem the date changed to the next weekday. If a deposition has already been held for any party, please indicate same.

Question #6 Other Disclosure: The date or time period to comply MUST be specified for questions “a”, “c” and “d”. (Do not write “per CPLR”)

Question #7 Additional Disclosure Issues: If a demand is made for compliance with a previously served discovery demand, the provision must indicate: (a) The date of the demand,(b) the party to which the discovery refers and (3) the specific outstanding items which have not been furnished. (DO NOT write “plaintiff/defendant to comply with any/all outstanding discovery demands”).

Question #9 Completion of Disclosure: Insert a date on or before the date of the compliance conference.

ATTORNEYS MUST CHECK THE COURT FILE TO REVIEW THE “SO ORDERED” PC FOR ANY OF THE AFOREMENTIONED CHANGES MADE THERETO BY THE JUDGE.