In a recent decision, Chief Judge Trust described the application of the wildcard exemption. In re Banfi , No. 19-77029-ast, 2021 WL 2407504, at *4 (Bankr. E.D.N.Y. June 9, 2021). On May 13, 2021, defendant filed a letter for a pre-motion conference in this action in anticipation of a motion to dismiss.

A motion for reconsideration is considered timely under Rule 59(e) and Bankruptcy Rule 9023 if it is filed within 14 days of the judgment or order. In re Banfi, 2021 WL 2407504, at *2 (Bankr. E.D.N.Y. 2021).

A motion for reconsideration is considered timely under Rule 59(e) and Bankruptcy Rule 9023 if it is filed within 14 days of the judgment or order. In re Banfi, 2021 WL 2407504, at *2 (Bankr. E.D.N.Y. 2021). However, arguments raised for the first time on a motion for reconsideration are considered untimely; it is improper for a movant to present new material on a motion for reconsideration, because that material has not been previously presented and therefore has not been previously overlooked by the court.