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Bankruptcy Exhibits for New York Courts

New York's bankruptcy courts in Manhattan (SDNY) and Brooklyn (EDNY) handle many of the nation's largest Chapter 11 cases and complex consumer bankruptcies. Both courts have specific local rules governing exhibits in contested matters and adversary proceedings. This guide covers exhibit preparation for Chapter 7, 11, and 13 cases, as well as adversary proceedings in New York bankruptcy courts.

CM/ECF (Bankruptcy Court)Per scheduling order or SDNY/EDNY local rulesSDNY Bankr. L.R. 9013-1, EDNY Bankr. L.R.

New York Quick Reference

E-Filing SystemCM/ECF (Bankruptcy Court)
File Size Limit50 MB per document
Exchange DeadlinePer scheduling order or SDNY/EDNY local rules
Primary RuleSDNY Bankr. L.R. 9013-1, EDNY Bankr. L.R.

Common Bankruptcy Exhibits in New York

Schedules and Statement of Financial Affairs
Proof of claim documentation
Financial statements and bank records
Real property documents (deeds, mortgages)
Business records (Chapter 11)
Employment records and pay stubs
Tax returns (2-4 years)
Vehicle titles and loan documents
Lease agreements
Litigation documentation (pending suits)
Insurance policies
Creditor correspondence

New York Bankruptcy Tips

  • 1SDNY Bankruptcy Court (Manhattan) handles major Chapter 11 cases - follow General Order M-399
  • 2EDNY Bankruptcy Court (Brooklyn) has different local rules - verify requirements
  • 3Proofs of claim must include supporting documentation as exhibits
  • 4Adversary proceedings require separate exhibit numbering per FRBP 7001
  • 5First-day motions in Chapter 11 require extensive exhibit support
  • 6Operating reports in Chapter 11 follow specific SDNY/EDNY formats
  • 7Individual judge preferences vary - check chambers rules

Common Bankruptcy Filing Mistakes in New York

Failing to attach supporting documentation to proofs of claim
Not following CM/ECF naming conventions for exhibits
Missing redaction requirements for personal identifiers (SSN, account numbers)
Exceeding file size limits without proper document splitting
Failing to properly authenticate business records
Not organizing financial records chronologically

Bankruptcy Exhibits in New York: FAQ

What documentation is required for proofs of claim in New York bankruptcy cases?

Proofs of claim must include documentation supporting the claim, such as contracts, invoices, account statements, or promissory notes. Failure to attach documentation can result in claim objections. Organize exhibits chronologically with Bates numbers.

How do SDNY and EDNY bankruptcy local rules differ?

While both follow the Federal Rules of Bankruptcy Procedure, each court has specific local rules. SDNY has General Order M-399 for complex Chapter 11 cases. EDNY has its own procedures for consumer cases. Always check the applicable local rules.

What exhibits are needed for Chapter 11 first-day motions?

First-day motions typically require extensive exhibits: financial statements, cash flow projections, lists of critical vendors, employee information, insurance policies, and declarations explaining the need for emergency relief.

How should I redact personal information in bankruptcy exhibits?

FRBP 9037 requires redacting Social Security numbers (show only last 4 digits), financial account numbers (show only last 4 digits), and birth dates (show only year). CM/ECF has specific redaction requirements.

What are the file size limits for New York bankruptcy court e-filings?

CM/ECF allows up to 50 MB per document. For large exhibit packages, split into multiple parts and clearly label (e.g., "Exhibit A Part 1 of 3"). Contact the clerk for guidance on exceptionally large filings.

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