- New York exhibit marking and exchange rule (22 NYCRR 202.34) (22 NYCRR 202.34)
Governs exhibit marking, exchange deadlines, and disclosure for criminal defense cases in New York courts.
Criminal Defense Exhibits in New York
The discovery is in: arrest and supplemental reports, body-camera stills, witness statements and a forensic report. The suppression motion needs a defense exhibit set, marked as yours and not the prosecution's, and nothing in the file can leave your office.
Complete guide to preparing criminal defense exhibits that comply with New York court requirements. Learn the correct labeling conventions, exchange deadlines, and e-filing procedures.
- New York's primary rule governing exhibit preparation is 22 NYCRR 202.34.
- Plaintiffs in New York label exhibits with Numbers (1, 2, 3...).
- Defendants in New York label exhibits with Letters (A, B, C...).
- New York courts require electronic exhibits to be filed through NYSCEF.
- Exhibits must be exchanged with opposing counsel 10-14 days before trial (varies by county) under 22 NYCRR 202.34.
- Common criminal defense exhibits in New York include police reports, body camera footage, witness statements.
- ExhibitPrep applies New York exhibit stamps entirely in the browser, so criminal defense case files never leave the user's computer.
What goes wrong with criminal defense exhibits, and how it is handled
What goes wrongDefense exhibits need a defense label that does not reuse the prosecution's numbering.
How ExhibitPrep handles itThe Plaintiff's, Defendant's, Petitioner's, Respondent's and Defense Exhibit templates name the side in the stamp header; the label sequence, and any prefix such as D- or PX-, are set once and applied to every exhibit in the set.
What goes wrongDiscovery includes a phone extraction's message export, and the court needs the exchange as a readable, dated exhibit rather than a spreadsheet.
How ExhibitPrep handles itPhone screenshots become PDF pages like any image; an RSMF message export from a collection or review tool renders to a transcript instead — every message with its time, sender and account identifier, deleted and edited messages marked, the export's hash on the first page — and is then stamped in the same sequence as everything else.
What goes wrongThe case file is privileged and cannot be uploaded to be stamped.
How ExhibitPrep handles itDocument bytes are processed locally in your browser and are not uploaded to our servers.
What goes wrongDiscovery produced as one long PDF needs page references that carry across the set.
How ExhibitPrep handles itBates numbering adds page numbers with the prefix, starting number and zero padding you set — ABC-001 onward — and the count continues across the documents in a set or restarts in each file.
Essential tools for criminal defense exhibits
Batch stamping
Sequential labels across the whole set — 1, 2, 3 or A, B, C — from the starting value you choose
How it worksStamp exhibits
29 templates, with labels in the convention your court uses — 50 states and federal
How it worksBates numbering
Page numbers with the prefix, starting number and zero padding you set — ABC-001 onward
How it worksNew York Exhibit Requirements at a Glance
| Plaintiff Exhibits | Numbers (1, 2, 3...) |
| Defendant Exhibits | Letters (A, B, C...) |
| Exchange Deadline | 10-14 days before trial (varies by county) |
| Primary Rule | 22 NYCRR 202.34 |
| E-Filing System | NYSCEF |
Common Criminal Defense Exhibits
Police Reports
Arrest reports, incident reports, supplemental reports. For New York e-filing on NYSCEF, confirm the current file-size cap (100 MB per PDF document) before uploading.
Body Camera Footage
Screenshots and stills from body-worn cameras
Witness Statements
Prosecution and defense witness statements
Expert Reports
Forensic analysis, DNA experts, medical examinations
Character Evidence
Letters, employment records, community ties
Physical Evidence Photos
Photographs of physical evidence items
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New York-Specific Considerations
- Bail reform affects pretrial exhibit deadlines
- Discovery reform (CPL Article 245) expands disclosure
- Rosario material must be preserved
- Speedy trial requirements under CPL 30.30
How to Prepare Your Exhibits
Gather Your Documents
Collect all documents relevant to your criminal defense case. This typically includes police reports, body camera footage, witness statements, and other supporting evidence.
Convert to PDF
Convert all documents to PDF format. New York courts require electronic exhibits to be filed via NYSCEF. Scan paper documents at 300 DPI.
Apply Exhibit Labels
Use ExhibitPrep to add exhibit stamps for New York filing review. Plaintiffs commonly use Numbers (1, 2, 3...), while defendants commonly use Letters (A, B, C...); verify the governing rules.
Exchange with Opposing Counsel
Exchange your exhibit list and copies with opposing counsel 10-14 days before trial (varies by county) per 22 NYCRR 202.34.
Save Hours on Exhibit Preparation
ExhibitPrep stamps all your criminal defense exhibits in minutes, not hours. Upload your documents, select the correct New York template, and download court-ready exhibits.
Frequently Asked Questions
How should I label criminal defense exhibits in New York?
Use Numbers (1, 2, 3...) for plaintiff exhibits and Letters (A, B, C...) for defense exhibits, per 22 NYCRR 202.34. NYSCEF accepts up to 100 MB per PDF document. ExhibitPrep's Criminal Defense templates apply the right prefix automatically, so you're not re-deriving the local convention on every filing.
When do I have to exchange criminal defense exhibits in New York?
New York sets the exhibit exchange window at 10-14 days before trial (varies by county) under 22 NYCRR 202.34, though the exact date can shift with your assigned judge's scheduling order. Confirm the deadline in your case's pretrial order before you start stamping, then batch-process the full criminal defense production in one ExhibitPrep session once it's locked in.
What e-filing system handles criminal defense exhibits in New York?
New York runs electronic filing through NYSCEF. Check the current upload cap before filing (100 MB per PDF document), export each exhibit as a text-searchable PDF, and split any long police reports into separate files so a single scanned record doesn't blow past the limit.
What exhibits come up most in a New York criminal defense case?
Criminal Defense matters in New York typically turn on police reports, body camera footage, witness statements, plus whatever case-specific records the dispute calls for. Bail reform affects pretrial exhibit deadlines. Stamp them all inside ExhibitPrep using the matching plaintiff or defense template, so every exhibit in the production carries a consistent, consistent exhibit mark before it goes to opposing counsel.
Can I stamp a large criminal defense production for New York courts?
Yes. The Day Pass ($14.99) gives you unlimited stamping for 24 hours, which covers hundreds of exhibits in a single criminal defense case. Processing runs entirely in your browser, so your New York case files never leave your computer. That matters here because e-filing upload caps (100 MB per PDF document) often force a large production into multiple separate uploads.
Related Resources
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ExhibitPrep formats documents; it does not provide legal advice or filing approval. Some guidance remains unverified. Citations support only their stated claims and scope. Review the finished files against current court instructions and case orders before filing. Check requirements and the finished PDF before filing.