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CPLR 2106: Swear Less, Win More!

Master the transition to unsworn affirmations under the new CPLR 2106 to streamline filings, ensure strict compliance, and eliminate notary bottlenecks in your practice.

Created byNYS Academy of Trial Lawyers
BeginnerUpdated Jan 21, 2026
CPLR 2106: Swear Less, Win More!

What You'll Learn

check_circleIdentify CPLR 2106 statutory requirements.
check_circleApply specific 'magic words' for valid filings.
check_circleReplace notarized affidavits with affirmations.
check_circleReview case law regarding substantial compliance.
check_circleRecognize documents that still require a notary.

About This Course

Did you know that this new rule has replaced affidavits with affirmations? Join us for an in-depth explanation on how to navigate the new rule, ensure compliance, and address outstanding questions surrounding its application across various areas of practice.

The program explores the evolution of the statute, examining the shift from limited exceptions for attorneys and medical professionals to a universal application effectively removing the notary requirement for most litigation documents. Presenters analyze recent case law, highlighting the varying degrees of judicial leniency regarding defective affirmations and the absolute necessity of using the specific statutory "magic words." With insight from the bench, participants will learn how judges view non-compliant submissions and the potential for curing defects under CPLR 2001.

Key topics covered in this course include:

  • The history and specific requirements of the amended CPLR 2106.
  • An analysis of recent trial court decisions regarding strict compliance versus judicial discretion.
  • Practical applications of the statute for verification of pleadings, bills of particulars, and administrative proceedings.
  • Crucial exceptions where notarization remains mandatory, such as matrimonial agreements and real estate conveyances.
  • Best practices for drafting affirmations to ensure admissibility and avoid clerical rejection.

By the end of this session, legal professionals will be equipped with the knowledge to streamline their document verification processes while maintaining strict adherence to the new statutory requirements.

Your Instructors

NYS Academy of Trial Lawyers
NYS Academy of Trial Lawyers
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The NYS Academy of Trial Lawyers is the largest statewide trial bar in the US with 5,700+ lawyer and judge members. We are committed to protecting, preserving and enhancing the civil justice system. Our highly acclaimed CLE programming features extraordinary presenters covering the most timely and important topics.

Michael  Kohan, Esq.
Michael Kohan, Esq.

Principal Attorney at Kohan Law Group, P.C.

Michael Kohan, Esq., is a graduate of Queens College with a degree in political science and dual minors in history and psychology. He was named to the Dean’s List every semester and graduated magna cum laude. Michael went on to receive his Juris Doctor degree from Hofstra University School of Law, where he was a New York State Bar Association Trial Lawyers Section Statewide Trial Team Champion. As part of his studies, Michael was a student of the late U.S. Supreme Court Justice Ruth Bader Ginsburg. In 2018, the Presiding Justice of the Appellate Division, Second Department, appointed Michael to the Court’s Committees on Character and Fitness, to which he was reappointed in 2022 and where he continues to serve proudly. As the founding partner of Kohan Law Group, PC, a boutique civil litigation firm, Michael has significant experience handling complex civil litigation matters from inception through trial or settlement. He has proudly volunteered his time as the inaugural member of the personal injury division at Legally Links, a nonprofit organization serving the needy, including indigent widows and widowers. Michael serves as president of the Network of Bar Leaders and has been an adjunct professor of law at Hofstra Law School, teaching trial and litigation skills courses. He is also the former president of the Queens County Brandeis Bar Association.

Hon. Suzanne  Adams
Hon. Suzanne Adams

Administrative Judge, Manhattan Civil Supreme Court Justice

Justice Adams was appointed as the Administrative Judge for Manhattan Civil Supreme Court in October of 2024 by Chief Administrative Judge Joseph A. Zayas and First Deputy Chief Administrative Judge Norman St. George. She oversees the day-to-day operation of one of the state's busiest courts of civil jurisdiction, including 60 Supreme Court Justices, 285 court staff (non-uniform), 104 court staff (uniform), and 121 chambers staff. Prior to her appointment, Justice Adams was an Acting Supreme Court Justice in New York County from 2020 to 2024 and, before that, practiced for nearly twenty years as a litigator in the New York State Courts. Justice Adams is a frequent lecturer, a member of numerous bar associations, and a proud recipient of countless awards; she also serves as a mentor to attorneys from underrepresented communities, inspiring them to become judges.

Isabel  Kupilik, Esq.
Isabel Kupilik, Esq.

Attorney at Kohan Law Group

Isabel is a graduate of St. John's University with a degree in History, where she advanced to the Dean's List every semester and graduated summa cum laude. Isabel went on to receive her JD from Benjamin N. Cardozo School of Law. While in law school, Isabel held two internships as a Student Prosecutor at the Queens District Attorney's Office and served as a Student Mediator in Cardozo's Divorce Mediation Clinic. She also volunteered for the Uncontested Divorce Project, helping to grant free divorces for victims of domestic violence. Isabel is a member of the Nassau County Bar Association and the Queens County Bar Association. In her role at Kohan Law Group, Isabel is instrumental in handling court conferences, conducting legal research, and drafting complicated pleadings, motion papers, and discovery documents.

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We are a registered provider with 327+ associations and regulatory bodies worldwide. We operate across 29 global markets including Canada, the US, Australia, and the UK. Every course page clearly displays its specific accreditations. Upon completion, you receive a professional certificate that can be validated online. Our certificates include all necessary accreditation details, credit hours, and completion dates, and are formatted specifically to meet the submission requirements of most global regulatory bodies.

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