The following excerpt is from International Business Machines Corp. v. Edelstein, 526 F.2d 37 (2nd Cir. 1975):
We think that so far as the requirement of writing is concerned, it is sufficient that the motion was made in open court and entered upon the record immediately following the rendition of the verdict. It is not necessary that a motion be made in writing if made 'during a hearing or trial'. Witt v. Merrill, 208 F.2d 285, 286 (4th Cir. 1953).
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