New York Litigation Drafting for Attorneys
New York civil drafting for CPLR 3211 motions, CPLR 3212 summary judgment, responsive papers and trial submissions. We identify the court, assigned part and any Commercial Division requirements before shaping the document and its supporting record. Membership from $1,500 a month.
CPLR 3211: identify the selected dismissal ground
A CPLR 3211 motion can raise different grounds, including documentary evidence, jurisdiction and failure to state a cause of action. The draft specifies the subsection and challenged claim rather than assuming a federal Rule 12 analysis. Counsel supplies the pleading, documentary materials and intended relief; we flag how the selected ground affects the record and structure of the argument.
CPLR 3212: build the submission from the evidence
For summary judgment, the intake includes the pleadings, affidavits or affirmations, deposition testimony and other proof counsel intends to rely on, together with the scheduling orders. We organize the statement of facts and argument around counsel’s selected grounds. Whether a separate statement is required is checked against the current part and Commercial Division rules; statewide Uniform Civil Rule 202.8-g is repealed.
Word limits and reply scope are part of the outline
Uniform Civil Rule 202.8-b generally limits computer-prepared memoranda in chief to 7,000 words and reply memoranda to 4,200, unless the court permits otherwise. The rule identifies exclusions and requires counsel’s word-count certification. Reply argument must respond or relate to the opening memoranda. We check the applicable part rules, orders and any Commercial Division provisions before finalizing the drafting checklist.
The part’s practice matters
An assignment identifies required conferences, motion submission procedures, exhibit conventions and the court’s directions concerning proposed orders. The draft and any accompanying papers follow that agreed checklist. Counsel confirms the return date, service method and filing schedule; Litigify does not assume that a delivery target resolves CPLR timing or NYSCEF filing obligations.
Start with the controlling materials.
Scope the jurisdiction-specific work.
Can you draft for the Commercial Division?
Yes. Identify the county, justice, individual part rules and orders. The Commercial Division’s requirements are checked separately from general motion practice, including any required factual statement or pre-motion procedure.
Do you include attorney affirmations and exhibits?
They can be included in the scoped document set. Counsel supplies the facts and source materials, reviews statements made in their name, and signs the final papers.
Is a CPLR 3211 motion the same as summary judgment?
No. CPLR 3211 and 3212 are different procedural vehicles with different grounds and records. Counsel chooses the appropriate procedure, and the draft is prepared for that assignment.