Edward Thomas McLoughlin at a glance
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Judicial Officer · County Court, Dutchess County
New York statewide rules require permission before photographing, filming, videotaping, audiotaping, broadcasting, or telecasting in court facilities, including courtrooms.
Taking photographs, films or videotapes, or audiotaping, broadcasting or telecasting, in a courthouse including any courtroom, office or hallway thereof, at any time or on any occasion, whether or not the court is in session, is forbidden, unless permission of the Chief Administrator of the Courts or a designee of the Chief Administrator is first obtainedPart 29: Electronic Recording and Audio-Visual Coverage in Court Facilities and of Court Proceedings ↗
The official Guide to New York Evidence identifies court control over presentation of evidence as a statewide evidence topic; counsel should expect the assigned judge to control the mode and order of proof.
1.07. COURT CONTROL OVER PRESENTATION OF EVIDENCEGuide to New York Evidence: Article 1, General Provisions and Court's Role ↗
See document heading and cited passage; do not apply outside the issuing part or proceeding.
Official rules document ↗ · Collected 2026-10-27
Every pleading, written motion and other paper served or filed in an action must be signed by an attorney pursuant to §130-1.1a of the Rules of the Chief Administrator of the Courts.
Source page 1(a) Within ten (10) days of written notification of this Part’s assignment to a case, or written notification of a Preliminary Conference, whichever shall first occur, each attorney shall file a record of appearance with chambers. The record of appearance shall include the attorney’s name, firm affiliation, mailing address, telephone and facsimile number as well as the party represented. The record of appearance shall also contain a written acknowledgment that counsel is familiar with these Part Rules.
Source page 1(d) At all scheduled appearances and conferences before the Court, only an attorney thoroughly familiar with the action and authorized to act on behalf of a party shall appear.
Source page 1A party may request a preliminary conference any time after issue has been joined. In any event, the Court will schedule a preliminary conference within forty-five (45) days after an RJI has been filed on a matter. A form stipulation and order shall be provided to the parties which shall establish a timetable for discovery within parameters set forth by the Court after determination as to whether a matter should be designated a “standard” or a “complex” case. If all parties sign the stipulation and return it to chambers prior to the scheduled conference, such form shall be “so ordered” by the Court and, unless the Court orders otherwise, appearances will not be required at the preliminary
Source page 1(i) a Matrimonial Order Directing Preliminary Conference; and (ii) a Matrimonial Preliminary Conference Stipulation and Order. (b) The parties must be present for the preliminary conference. (c) No later than ten (10) days prior to the preliminary conference in any matrimonial
Source page 23. Most recent paystub and income tax return. (d) At the preliminary conference, counsel shall be prepared to discuss all issues identified in the Matrimonial Order Directing Preliminary Conference. No later than ten (10) days prior to the preliminary conference, counsel shall also exchange all documents identified in that Order.
Source page 2(e) At the preliminary conference, the parties and their counsel shall fill out and execute the Matrimonial Preliminary Conference Stipulation and Order, for review and approval by the Court. (f) Any application regarding child support must be accompanied by a completed Child Support Worksheet.
Source page 2The preliminary conference order shall provide a date and time for the parties to appear at compliance conference. (a) At the compliance conference, the Court will ensure that discovery is proceeding as scheduled. (b) Unless a note of issue has been earlier filed, the Court shall direct a date as the deadline for filing a note of issue and certificate of readiness.
Source page 2(a) Counsel must confer with one another in a good faith effort to resolve all discovery disputes. 22 NYCRR 202.7 (b) No discovery motion may be made without the permission of the Court. (c) It is the policy of this Court to make itself available to facilitate resolution of any discovery disputes without formal motion practice. In the event of a discovery dispute, the aggrieved party shall organize a conference call with counsel for all
Source page 2Within 45 days of the filing of a note of issue, the Court shall schedule a Pretrial Conference. (a) At the pretrial conference, the Court shall establish a deadline for the exchange of expert witness information pursuant to CPLR §3101(d)(1) which shall, in no event, be later than ninety (90) days before trial for the party bearing the burden of proof on that issue. The opposing party must serve its disclosure within forty-five (45) days of trial.
Source page 3Any amended or supplemental expert disclosure shall be allowed only with leave of the Court on good cause shown. The statutory stay of disclosure (CPLR3214[d]) upon the service of a dispositive motion under CPLR 3211 shall not apply to the service of these expert responses. Unless the Court directs otherwise, a party who fails to comply with this rule is precluded from offering the testimony and opinions of the expert for whom a timely response has not been given.
Source page 3(b) The Court will explore limitation of issues for trial, including referring certain issues to a referee if appropriate. (c) The Court will schedule a date certain for trial of all outstanding issues. (d) Counsel should be prepared to discuss settlement and should have full authority from their respective clients.
Source page 3(b) Motions are returnable on Tuesdays and Thursdays. There will be no appearances unless specifically stated by the court. (c) Original initiating motion papers should be submitted directly to the County Clerk accompanied by an affidavit/affirmation of service and the required fees. All answering and reply papers should be submitted directly to chambers.
Source page 3(d) With the exception of e-filed motions, courtesy copies of motion papers are not necessary. For e-filed motions, a hard copy of the motion papers with exhibit tabs must be delivered to chambers by the motion return date, along with a copy of the filing confirmation notice received from the NYSCEF site.
Source page 3(e) All affirmations, affidavits and memoranda of law must contain numbered pages and exhibit tabs. (f) All documents required to decide the application must be attached to the motion. It is not sufficient that documents may be on file with the Clerk of the Court.
Source page 3(g) The Court does not accept sur-reply papers, whether submitted as formal motion papers or correspondence. The Court will not consider new issues that have been improperly raised for the first time in reply papers. If there has been a change in the law while the motion is pending that counsel believes will have a material
Source page 3The Court will notify the parties whether a conference will be scheduled. (h) Counsel must provide an additional copy of any proposed order or judgment submitted to conform to the original. Orders and judgments must have at least one line of text on the signature page.
Source page 4(i) Motion papers, orders and judgments must be accompanied by a stamped, self- addressed envelope. (j) Motions in limine are also subject to the requirements of the “Pretrial Conference” section of these Part Rules.
Source page 4(k) Requests for adjournment of motions may be requested on consent of all counsel. Even if a requested adjournment is on consent of all counsel, the request must also be approved by the Court before it will be deemed granted. No adjournments will be granted for motions returnable within thirty (30) days of the trial date.
Source page 4(l) The party requesting an adjournment must fax the adjournment request to the Court, on notice to all counsel. Unless good cause is shown, no more than two adjournments of a motion date shall be permitted on any matter. A written
Source page 4(I) identify the current motion date; (ii) identify the number of adjournments that have previously been requested, if any; (iii) state whether the request is made on consent of all counsel; and (iv) identify the proposed motion schedule.
Source page 4(m) Counsel shall immediately notify the Court whenever it becomes unnecessary to decide a motion.
Source page 4Letters to the court should not address substantive issues in the case. No motion papers or exhibits may be faxed to the court without the court’s prior consent. No fax in excess of 10 pages may be sent without prior permission of the court.
Source page 41. A. Trial Readiness: All trial dates are final. Counsel must notify all witnesses and experts of the trial date as soon as it is issued by the court. Prior to jury selection, counsel is cautioned to ascertain the availability of all witnesses and subpoenaed documents. If you have non-English speaking or deaf witnesses, the court must be notified at the pre-trial conference to allow the clerk time to arrange for the
Source page 4B. BIFURCATED TRIALS: All trials other than Medical Malpractice and Wrongful Death are bifurcated in the Second Department. The damages portion commences with the same jury immediately following a liability verdict. Counsel should have medical testimony and any other professionals for the damages portion ready to proceed at that time.
Source page 5E. If any part of a deposition is to be read into evidence (as distinguished from mere use on cross-examination) you must provide the Court and your adversary with the page and line number of all such testimony so that all objections can be addressed prior to use before the jury.
Source page 5A. At least 30 days before trial, all counsel and pro se parties shall provide the court with the following: (binders or bound notebooks are not required)
Source page 5Requests to charge. A complete list of requested charges drawn from the Pattern Jury Instructions (PJI). A list of the PJI numbers of all charges requested is sufficient. However, if deviations from or additions to the PJI are requested, the full text of such request must be submitted together with any supporting legal precedent;
Source page 55: Alert the Court as to any anticipated problems regarding the attendance at trial of parties, attorneys or essential witnesses, and any other practical problems which the Court should consider in scheduling; 6: Alert the Court to any anticipated request for apportionment as to alleged culpable non-parties pursuant to CPLR Article 16.
Source page 64. Pre-Marked Exhibits: All trial exhibits should be pre-marked by the court reporter when ever possible, for identification, and copies of the resulting Exhibit Sheet provided to the Court.
Source page 6A. JURY SELECTION: Attorneys shall employ “White’s Method” of selecting the jury panel, unless counsel agree otherwise. In each round, questioning shall be conducted first by plaintiff’s counsel. This part uses undesignated alternates.
Source page 6D. To alert the Court to any anticipated requests for a jury instruction relating to missing witnesses and/or documents;
Source page 6No Communication with Jurors: In order to maintain the appearance of total impartiality, once the jury has been selected no one is to communicate in any form at any time with any juror. This includes both verbal and non-verbal communication, including, without limitation, nods, shrugs and shaking the head. Do not even say “hello” or “good morning”.
Source page 67. Trial Objections and Arguments: When making an objection, after saying the word,“objection”, add only those few words necessary to state the generic grounds for the objection, such as “hearsay”, “bolstering”, “leading”, or “asked and answered”. If you believe further argument is required, ask permission to approach the bench.
Source page 6be made to opposing counsel. If you require a significant discussion with your adversary, such as possible stipulation, ask for permission to approach the bench, so you may have a chance to talk to each other outside the presence of the jury.
Source page 79. Use Of Proposed Exhibits: Do not show anything, including an exhibit or proposed exhibit to a witness without first showing it to opposing counsel. If this procedure is claimed to compromise trial strategy, a pre offer ruling outside the presence of the jury should be first obtained.
Source page 710. Examination of Witnesses: Do not approach a witness without permission of the Court. Please allow the witness to complete his/her answer to your question before asking another question. Do not interrupt the witness in the middle of an answer, unless it’s totally unresponsive in which event you should seek a ruling from the Court. Direct examination, cross, redirect and re-cross are permitted.
Source page 711. Jury Charge & Verdict Sheet: At the commencement of the trial, all counsel shall submit suggested jury charges and a suggested verdict questionnaire. Amendments thereto shall be permitted at the final charging conference. If counsel relies on a Pattern Jury Instruction [PJI] without any change thereto, it should be referred to by PJI number and topic only. If any changes to the PJI are suggested, then the entire proposed charge should be set forth and the changes should be highlighted or otherwise called to the Court’s attention. Citations to appropriate statutory or common law authority shall be given in support of suggested non-PJI jury charges or suggested PJI modification.
Source page 7A. Electronic Filing. All parties should familiarize themselves with the statewide E-Filing Rules (see Uniform Rules §§ 202.5-b and 202.5-bb, available at www.nycourts.gov/efile). General questions about e-filing should be addressed to the E-Filing Resource Center at (646) 386-3033 or efile@nycourts.gov.
Source page 7All actions required to be filed electronically shall be filed through the New York State Courts E- Filing system (NYSCEF), including proposed orders, proposed judgments, and letters.
Source page 7B. Working Copies. This Part requires one working copy of each motion submission, including all exhibits and proposed orders (see Uniform Rule §202.5-b[d][4]). The NYSCEF Confirmation Notice generated when the motion is e-filed must be firmly attached to the front page of the motion submission. Working copies that do not include the NYSCEF Confirmation Notice may be rejected. Working copies shall be received by Chambers on or before the return date or notice of settlement date. Failure to timely submit working copies to Chambers will result in denial of the motion.
Source page 7Any applications addressing the preclusion of evidence, testimony or other trial related matters shall be brought to the attention of the court immediately upon counsel becoming aware of such matter to be addressed, it being the intent to avoid applications made on the eve of, or during trial of a matter. Failure to bring the matter before the court in a timely fashion may result in summary denial of such application.
Source page 8While the court strives for adherence to scheduled jury selection and commencement dates, the court’s trial calendar is such that exact days cannot always be guaranteed. Requests for a continuance or rescheduling due to an expert’s unavailability for testimony generally cannot be granted due to the large number of matters pending for trial. Counsel may use videotaping of experts when necessary.
Source page 81. Any motion by a party to preclude or limit expert testimony under the expert disclosure part of this order or pursuant to CPLR 3101(d) must be made as soon as practicable.
Source page 82. Where a party’s summary judgment motion is or will be based in whole or in part upon the granting of a motion directed at precluding or limiting expert testimony made pursuant to this part of this order, the motions’ return date shall be the same.
Source page 8(a) Adjournments of scheduled trials and hearings are not permitted except as provided in 22 NYCRR §125.1 and in accordance with the procedure set forth therein. (b) Adjournments of motions and conferences may be requested on consent of opposing counsel. After obtaining such consent, the requesting party must fax the adjournment request to (845) 431-1924 to obtain a new date. Faxes sent to a different court fax number may not be received in a timely manner. A REQUEST
Source page 8LEAST 24 HOURS IN ADVANCE OF THE SCHEDULED APPEARANCE. All adjournments must be confirmed in writing to the Court, by the requesting party, and a copy of the letter sent to all parties. No more than two adjournments shall be permitted on any matter unless good cause is shown upon written application made to and approved by the Court. WHEN REQUESTING AN
Source page 8(1) Orders to Show Cause to validate or invalidate designating or nominating petitions will be made returnable no later than five (5) days after the last day to statutorily commence such proceedings. A copy of these rules shall be attached to the original and each copy of the Order to Show Cause.
Source page 10(2) The calendar call on the return date must be answered by counsel or the litigant(s), (self-represented) who shall provide the Part Clerk with their addresses and telephone numbers. Non-lawyer “representatives” of the parties are not permitted to answer the calendar call. Proof of service of the Orders to Show Cause, as well as any interposed Counterclaims or Answers, shall be filed with the Part Clerk at or before the initial appearance.
Source page 10(A) a written offer of proof in any matter alleging a question of residency of a candidate shall be filed with the court clerk and served on the opposing party; (B) specifications of objections or bills of particulars not previously served and/or filed with the Board of Elections shall be filed with the court clerk and served on the opposing party;
Source page 10(C) a complete written offer of proof in all matters alleging fraud including identification of witness to be called, their names and addresses, volume, page and line together with status of each (candidate, signatory, notary, expert, subscribing witness, etc.)shall be filed with the court clerk and served on all opposing parties.
Source page 10Article 7 petitions may be called for appearances upon filing of a Request for Judicial Intervention (RJI) and/or at the time a Note of Issue (NOI) is filed.
Source page 11Attorneys are notified of calendar calls in writing or by telephone by the clerk of this part and require appearances unless waived by the court.
Source page 11All preliminary conferences are held at 10 Market Street, Poughkeepsie, New York on the fourth floor. If you are unable to attend a PLC, you may advise your adversary of the adjourned date you prefer, and the clerk will, to the extent possible, accommodate your request at the time the calendar is called. Otherwise, appearances are required on the initial date for the preliminary conference.
Source page 11A party may request a trial schedule at the time of the first appearance on the PLC or any time thereafter. It should be noted to the court whether the request being submitted is for each individual property and for each year in question.
Source page 11Photocopies of trial exhibits and other documents are to be made outside the courthouse. All exhibits must be pre-marked prior to the commencement of trial. A list of all exhibits to be offered by each party shall be provided to the Court at the commencement of the trial. Should the exhibit list be amended during the trial, a copy of the updated or amended list shall be provided to the Court.
Source page 11All witnesses, including but not limited to assessors, appraisers, experts, and fact witnesses, who maintain and/or possess a file and/or documents relevant to their testimony and/or the subject matter of the trial, hearing, or other matter before the Court, shall bring their entire and complete file and/or any and all relevant documents with them to Court on the date of their testimony and on any dates on which their testimony continues. Any party whose witness fails to appear with his or her complete file and/or any and all relevant documents as detailed above, will bear any and all costs associated with the adjournment of the trial, hearing, or other proceeding as may be necessary to secure the witness’ file and/or relevant documents .
Source page 12Trial appraisals, pre and post trial memoranda are to be submitted. An original of the trial appraisal and pre-trial memoranda are to be delivered to this Court (no courtesy copies are required)on or before the pre-trial conference which is scheduled. At the time of the hearing, each pleading is to be labeled on its face so as to distinguish which is the original and the copy.
Source page 12Counsel are directed to mutually exchange trial appraisals, pre and post trial memoranda, and expert reports if any, without the assistance of the Court. Any post trial memoranda and the dates for exchange shall be directed by the court at the conclusion of the trial. In light of the direction that these matters have priority over other civil cases, our court ordered discovery and trial dates are to be strictly complied with and any adjournments must be by permission of the court for good cause shown. Any such adjournments must be requested by fax to the court at (845) 431- 1924. Faxes sent to a different court fax number may not be received in a timely manner.
Source page 12Any motion to be submitted must be by original. All motion fees are payable to the County Clerk. The motions are on submission of papers only unless otherwise directed by the court, no appearances are required. Any adjournment of return dates on motions shall be cleared with opposing counsel and will generally be granted by this court. Confirmation of the adjourn date must be by letter addressed to the court with copy to opposing counsel. Any adjournment that is without consent, may be granted, but must be requested in person on the motion return date with advance notice given to the court and opposing counsel.
Source page 12Settlement orders, stipulations and/or judgments must be accompanied by a copy of the RJI and NOI, if any for each index number listed. A conformed copy of an order or judgment will be sent back to the submitting party only when it is accompanied by a stamped, self-addressed envelope.
Source page 12County Court, Dutchess County
State criminal proceedings only; section-specific court and case exceptions remain applicable.
Official source ↗ · Collected 2026-10-27County Court, Dutchess County
Civil actions and proceedings only; section-specific and specialized-part restrictions remain applicable.
Official source ↗ · Collected 2026-10-27County Court, Dutchess County
Scope is limited to the court class in the source claim. Shared court context only; case-type restrictions, exceptions, later amendments and case orders apply. This is not a personal preference or a complete rules inventory.
Official source ↗ · Collected 2026-07-26County Court, Dutchess County
Scope is limited to the court class in the source claim. Shared court context only; case-type restrictions, exceptions, later amendments and case orders apply. This is not a personal preference or a complete rules inventory.
Official source ↗ · Collected 2026-07-26Identity source checked July 27, 2026.
Biography sources checked August 2, 2026.
Identity source · HTML · Source checked July 27, 2026
View New York State Unified Court System official judicial roster ↗Identity source · HTML · Source checked August 2, 2026
View CourtListener judicial biographical directory ↗Statewide source · HTML · Source checked July 26, 2026
View Part 29: Electronic Recording and Audio-Visual Coverage in Court Facilities and of Court Proceedings ↗Statewide source · HTML · Source checked July 26, 2026
View Guide to New York Evidence: Article 1, General Provisions and Court's Role ↗