Commercial Litigation Exhibits for New York Courts
New York commercial litigation, particularly in the Commercial Division, calls for careful exhibit preparation under 22 NYCRR 202.34, 22 NYCRR 202.70 and individual judges' rules. The Commercial Division in Manhattan (and other counties) handles complex business disputes with specific exhibit protocols. This guide covers exhibit preparation for contract disputes, partnership dissolutions, securities matters, and complex commercial cases.
- New York's primary exhibit rule is 22 NYCRR 202.34, CPLR 3101.
- Commercial Litigation cases in New York e-file through NYSCEF.
- NYSCEF caps each uploaded document at 25 MB.
- The exhibit exchange deadline in New York is Per Court scheduling order.
- Common Commercial Litigation exhibits in New York include Contracts and agreements (executed copies) and Email chains and business correspondence.
- ExhibitPrep stamps exhibits in the browser, so case files never leave the computer.
Before you file
ExhibitPrep formats documents. It does not provide legal advice, submit filings, or determine whether evidence is admissible or a filing meets court requirements.
Some guidance has not been verified against current official sources. A citation supports only its stated claim and scope. Compare the finished PDF with current court instructions and orders in your case. Follow the filing review checklist.
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New York Quick Reference
| E-Filing System | NYSCEF ↗ |
| File Size Limit | 25 MB |
| Exchange Deadline | Per Court scheduling order |
| Primary Rule | 22 NYCRR 202.34, CPLR 3101 |
Common Commercial Litigation Exhibits in New York
New York Commercial Litigation Tips
- 1Commercial Division judges have individual rules - ALWAYS check before filing
- 2Check the assigned judge's pretrial order for joint exhibit list requirements
- 3Bates stamp all documents exchanged in discovery - required for large document productions
- 4NYSCEF has specific naming conventions - follow them exactly
- 5Consider using confidentiality designations for sensitive business documents
- 6Email exhibits should include full headers and metadata where relevant
- 7Check the Commercial Division rules on discovery of electronically stored information and coordinate exhibit format early
Common Commercial Litigation Filing Mistakes in New York
Commercial Litigation Exhibits in New York: FAQ
What is the Commercial Division in New York?
The Commercial Division is a specialized court for complex business disputes. It operates in Manhattan (NY County) and several other counties. Cases are assigned to judges with expertise in commercial matters. The division has specific rules under 22 NYCRR 202.70 and individual judge practices.
Are there different exhibit rules for Commercial Division cases?
Yes. Commercial Division judges often have detailed individual rules governing exhibits, including joint exhibit list requirements, electronic exhibit protocols, and pretrial exchange deadlines. Always check the assigned judge's rules on the court website.
How should I handle confidential business documents in NY commercial cases?
Use a confidentiality stipulation or protective order. Mark exhibits as "Confidential" per the stipulation. NYSCEF allows documents to be filed under seal with court permission. Commercial Division Rule 11-g addresses confidential information.
What are NYSCEF requirements for commercial litigation exhibits?
NYSCEF requires PDF format, 25 MB maximum file size, and specific file naming conventions. Exhibits should be clearly labeled and bookmarked for multi-page documents. Follow the county's NYSCEF user guide for formatting requirements.
How do I handle large document productions in NY commercial cases?
For large productions, Bates stamp all documents sequentially before production. Organize by custodian or category. Consider using a document review platform. When exhibits come from produced documents, reference the Bates range in your exhibit list.
Related Resources
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