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Second Circuit

Southern District of New York Exhibit Requirements

The Southern District of New York (SDNY) is one of the busiest and most prestigious federal courts, headquartered at the Daniel Patrick Moynihan U.S. Courthouse in Manhattan. Known for handling major securities, commercial, and white-collar criminal cases, SDNY has specific exhibit practices that vary significantly by judge. The district requires strict compliance with Local Civil Rules and individual judge practices.

SDNYCM/ECF (PACER)Per pretrial order (typically 30 days)

Quick Reference

E-Filing SystemCM/ECF (PACER)
File Size Limit35 MB per document
Plaintiff MarkingPX-1, PX-2, PX-3...
Defendant MarkingDX-A, DX-B, DX-C...
Exchange DeadlinePer pretrial order (typically 30 days)
Primary RuleLocal Civil Rule 26.3

What This Guide Covers

Local Civil Rule 26.3 disclosure requirements
Judge-specific individual practices (critical)
Joint pretrial order exhibit schedules
ECF filing conventions for attachments
Bates numbering requirements
Confidentiality designation protocols
Multi-volume exhibit organization
Trial exhibit binder requirements

Divisions & Courthouses

Manhattan (Foley Square)

  • Main courthouse - most commercial cases
  • Daniel Patrick Moynihan Courthouse
  • Securities and financial litigation hub
  • Judges have strong individual preferences

White Plains

  • Handles Westchester/Rockland cases
  • Same local rules as Manhattan
  • Smaller caseload

Judge-Specific Practices

SDNY judges maintain individual rules and practices that can significantly differ from general local rules. Before any filing, always check the assigned judge's Individual Practices document on the court website. Some judges require specific exhibit formats, courtesy copies, or modified timelines. The Clerk's Office can provide guidance on specific judge requirements.

Pro Tips for SDNY

  • 1ALWAYS check assigned judge's individual practices - they override general rules
  • 2SDNY judges often require joint pretrial orders with specific exhibit formats
  • 3Use PX/DX prefixes consistently (some judges require specific formats)
  • 4Bates stamp all exhibits - many judges require sequential numbering across documents
  • 5File confidential exhibits under seal per Local Rule 6.1
  • 6Review ECF Notice of Electronic Filing for any filing errors immediately

Common Mistakes to Avoid

Not reviewing judge's individual practices before filing
Missing joint pretrial order deadlines for exhibit exchange
Inconsistent Bates numbering across exhibit sets
Filing documents exceeding 35 MB without splitting
Not properly designating confidential exhibits
Failing to provide courtesy copies when required by judge

Related Court Guides

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