I need to file a motion.

You also need a notice of motion, of course. Look at CPLR 2221; there is no statutorily defined motion to "reconsider;" your options are...

Can i ask the court to grant me more time to write a new complaint ?

Yes. Before the time runs out send the court a letter request, copy to your adversary.

You don't "fill up" a motion. You file it. Messrs. Isquith and Feinberg are on the mark.

HOW DO i APPEAL ?

You have lost the opportunity to raise those issues on appeal. Had you not filed notices of appeal, you could have raised all the issues on appeal...

Can I refuse to turn over discovery until after I depose a defendant? Show my proof before she gives her responses???

Yes, they can have it both ways. It's called "pleading in the alternative" and it's standard practice. You cannot withhold duly demanded...

I have moved this to Workers' Compensation. My colleagues are correct--Article 78 is commenced in Supreme Court. Beyond that, all workers'...

On the other hand, if no judgment enforcement is imminent, a notice of motion is less work on the front end.

I am going through a divorce I want to file a motion to preclude or a motion to Limine can I do both? or is it the same thing?

As you have counsel these questions should be addressed to him/her, who should decide when/how to address the issue. In fact, the court will not...

Can the case be filed in SC if the original employment case was filed in NY. Does it matter if it is in State or Federal Court

You may file a disciplinary complaint against the attorney(s) in New York, where they practice and where the alleged wrongs occurred. I see no...

Will I be able to retain an attorney to appeal my NY Bar Exam results despite their "no appeals" policy?

This is not even an appeals question. It's a litigation question involving a potential Article 78 proceeding against a public entity. Perhaps the...