Ex parte motion practice has always played an important part in matrimonial actions where it is frequently necessary to seek emergency relief from the court such as a temporary restraining order or order of protection. Other relief such as a pre-commencement order directing service of process by an alternative method (CPLR 308(5)), or a pre-commencement order of sequestration (Domestic Relations Law §233) require ex parte submissions. Moreover, post-judgment enforcement and modification proceedings must usually be commenced by Order to Show Cause directing the method of service upon the defendant.