02. How many days' notice must I give when serving a motion and cross motion?

Effective July 3, 2007, CPLR sections 2214(b) and 2215 have been amended to provide new requirements for timely service of notices of motion and cross motions. The amendments apply to Notices of Motion served on or after July 3, 2007.

The following tables summarize the service requirements for motions and cross motions. The shaded areas indicate changes in the law:

Notices of Motion

Method of ServiceMain Motion Demands 7 Days' Answering PapersMinimum Service Time Required*
Personal or FAXMotion DOES DEMAND
7 Days' Answering Papers
16 days
Overnight DeliveryMotion DOES DEMAND
7 Days' Answering Papers
17 days
(16 days + 1 day for overnight delivery pursuant to CPLR 2103b6)
MailMotion DOES DEMAND
7 Days' Answering Papers
21 days
(16 days + 5 days for mailing pursuant to CPLR 2103b2)
Personal or FAXMotion DOES NOT DEMAND
7 Days' Answering Papers
8 days
Overnight DeliveryMotion DOES NOT DEMAND
7 Days' Answering Papers
9 days
(8 days + 1 day for overnight delivery pursuant to CPLR 2103b6)
MailMotion DOES NOT DEMAND
7 Days' Answering Papers
13 days
(8 days + 5 days for mailing pursuant to CPLR 2103b2)

 

Notices of Cross Motion

Method of ServiceMain Motion Demands 7 Days' Answering PapersMinimum Service Time Required*
Personal or FAXMain Motion DOES DEMAND
7 Days' Answering Papers
7 days
Overnight DeliveryMain Motion DOES DEMAND
7 Days' Answering Papers
8 days
(7 days + 1 day for overnight delivery pursuant to CPLR 2215)
MailMain Motion DOES DEMAND
7 Days' Answering Papers
10 days
(7 days + 3 days for mailing pursuant to CPLR 2215)
Personal or FAXMain Motion DOES NOT DEMAND
7 Days' Answering Papers
3 days
Overnight DeliveryMain Motion DOES NOT DEMAND
7 Days' Answering Papers
4 days
(3 days+ 1 day for overnight delivery pursuant to CPLR 2215)
MailMain Motion DOES NOT DEMAND
7 Days' Answering Papers
6 days
(3 days + 3 days for mailing pursuant to CPLR 2215)

*Prior to the return date of the motion (cross motions should be noticed to be heard on the same date as the main motion)