I recently moved to stay a trial at the Appellate Division — a difficult task indeed.  I wanted to share some words of advice before wasting the Court’s and your client’s time. 

1. Make sure that your reasons for moving for the stay are exceptional (deprivations of liberty, extreme family court matters, and issues that will cause definite irreparable harm);

2. Communicate with the Clerk’s office to learn the procedures for that Judicial Department; and

3. Read the Court’s rules carefully and research CPLR 5519 and the accompanying practice commentaries.

Good luck!