Changes

In New York state court, a litigant must bring a motion for JNOV within 15 days of the entering of the verdict.  Specifically, NY CLS CPLR R 4405 (Time and judge before whom post-trial motion made) requires that:

In New York state court, a litigant must bring a motion for JNOV within 15 days of the entering of the verdict.  Specifically, NY CLS CPLR R 4405 (Time and judge before whom post-trial motion made) requires that:

:A motion under this article shall be made before the judge who presided at the trial within fifteen days after decision, verdict or discharge of the jury. The court shall have no power to grant relief after argument or submission of an appeal from the final judgment.

:A motion under this article shall be made before the [[judge]] who presided at the trial within fifteen days after decision, verdict or discharge of the jury. The court shall have no power to grant relief after argument or submission of an appeal from the final judgment.

The timing of this deadline has been an issue of some dispute, but all reported decisions have held that the time begins when the decision is filed:

The timing of this deadline has been an issue of some dispute, but all reported decisions have held that the time begins when the decision is filed: