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A motion for sanctions under Rule 11 must be made separately from all other motions and must describe the specific conduct of the lawyer (or the party) against whom the motion is directed. The motion may be made either by the opposing party or sua sponte by the court.

Rule 11-c. Discovery of Electronically Stored Information from Nonparties. Parties and nonparties should adhere to the Commercial Division's Guidelines for Discovezy of Electronically Stored Information ("ESI") from nonparties. which can be found in Appendix A to these Rules of the Commercial Division.

Rule 11-f establishes that a party may serve a notice or subpoena on any legal or commercial entity. [10] While, as noted above, a party is not required to identify which matters the deponent will be asked about, if the party chooses to do so, the party must describe the matters with "reasonable particularity."

11-f - Depositions of Entities; Identification of Matters (a) A notice or subpoena may name as a deponent a corporation, business trust, estate, trust, partnership, limited liability company, association, joint venture, public corporation, government, or govern- mental subdivision, agency or instrumentality, or any ...

- "N.Y.2d" is the abbreviation for the New York Reports, the reporter containing this opinion. - "433" is the page in the reporter where this opinion begins. The parallel citations are to the North Eastern Reporter and West's New York Supplement.

Section 202.8-g - Motions for Summary Judgment; Statements of Material Facts (a) Upon any motion for summary judgment, other than a motion made pursuant to CPLR 3213, the court may direct that there shall be annexed to the notice of motion a separate, short and concise statement, in numbered paragraphs, of the material ...