When must a New York post-trial motion be made?

Identify the event applicable to the particular requested relief. Preserve the verdict, decision or jury-discharge record.

Do not substitute later judgment entry or its service for the applicable trial event.

Responsible actor. The party seeking post-trial relief under CPLR article 44. The established CPLR article 44 trial event and a motion before the judge who presided, before appellate argument or submission.

1. Identify the event applicable to the particular requested relief. Preserve the verdict, decision or jury-discharge record.
2. Do not substitute later judgment entry or its service for the applicable trial event.
3. Exclude the established event day and count every intermediate calendar day under GCL 20.
4. Make the motion before the trial judge. For a noticed motion, CPLR 2211 uses service of its notice or order to show cause. Complete the separate required filing.

GCL 20 excludes the established event day. These five-, ten-, fifteen-, twenty-, twenty-one-, thirty-, sixty- and ninety-day periods count intermediate calendar days. GCL 30 uses the corresponding calendar-month day, or the final day of a shorter month. GCL 58 defines a year as twelve months. GCL 25-a permits the next succeeding business day when the statutory final day is closed and expressly includes periods before which an act is required. The actual hearing or entry time and any different court direction remain separate checks. The independent calendar follows GCL 24 and Election Law 8-100. It includes Lincoln’s Birthday, the second Sunday in June as Flag Day, Juneteenth and general election day. GCL 24 adds the following day for a listed Sunday holiday except Flag Day. It does not generally move a Saturday holiday to Friday. Dates after 2027 are projections of the reviewed standing statute through 2033, not proof of future court openings. Check amendments, additional appointed holidays and actual closures separately.

The scoped calculators accept independently established events in 2026 and 2027 and projected final dates through 2033. They require the particular disclosed branch, no unsupported service-method addition, no unmodeled toll, no different actual court order and no additional closure. Earlier editions, historical tolls and outside dates require separate review and receive no computed or paid date. This software boundary does not establish that an act is legally late.

Fictitious example

The established CPLR article 44 trial event and a motion before the judge who presided, before appellate argument or submission. Fictitious established facts. The established CPLR article 44 trial event and a motion before the judge who presided, before appellate argument or submission.

Fictitious established facts. The date does not prove classification, valid service, jurisdiction, completed filing, a granted motion or an extension. Any earlier competing boundary, actual hour and future-calendar qualification still applies.

Trial judge

Section 4405 requires the judge who presided at the trial.

Appellate cutoff

The court has no power under this provision to grant relief after argument or submission of an appeal from the final judgment.

Relief grounds

CPLR 4404 distinguishes jury and nonjury trial relief. A timely date does not establish entitlement.

Edition and projected calendar

The scoped calculators accept independently established events in 2026 and 2027 and projected final dates through 2033. They require the particular disclosed branch, no unsupported service-method addition, no unmodeled toll, no different actual court order and no additional closure. Earlier editions, historical tolls and outside dates require separate review and receive no computed or paid date. This software boundary does not establish that an act is legally late.

• The established CPLR article 44 trial event and a motion before the judge who presided, before appellate argument or submission.
• Use only the disclosed statutory component. Establish every omitted branch separately.

• Identify the event applicable to the particular requested relief. Preserve the verdict, decision or jury-discharge record.
• Do not substitute later judgment entry or its service for the applicable trial event.
• Make the motion before the trial judge. For a noticed motion, CPLR 2211 uses service of its notice or order to show cause. Complete the separate required filing.
• Section 4405 requires the judge who presided at the trial.
• The court has no power under this provision to grant relief after argument or submission of an appeal from the final judgment.
• CPLR 4404 distinguishes jury and nonjury trial relief. A timely date does not establish entitlement.
• In the applicable Supreme Court NYSCEF program, preserve recorded transmission and the required fee event under rule 202.5-b(d). Participating-party service has its own notification event under (f). Initiating filing does not itself serve the respondent. The clerk’s entry notification is not party service of notice of entry under (h)(2). Check actual paper receipt, exemptions, emergency procedure and qualifying technical-failure directions separately.