Don't Let Your New York Exhibits Get Rejected
Get the complete New York exhibit requirements checklist. Know exactly what 22 NYCRR 202.20-h (Pre-Trial Memoranda, Exhibit Book, and Requests for Jury Instructions) requires before your filing deadline.
- Exhibit exchange deadlines are set by the court or assigned judge; check the part rules and scheduling order.
- Exhibit practice in New York centers on the New York State Courts.
- New York's e-filing file-size limit is 100 MB per PDF document.
- Manhattan (Commercial Division): Check the Commercial Division rules in 22 NYCRR 202.70 and the assigned justice's rules.
- Kings County (Brooklyn): Confirm current exhibit tab requirements with the clerk's office.
- Pre-marking of trial exhibits in New York civil courts is governed by 22 NYCRR 202.34.
- A common New York exhibit-filing mistake: not confirming a county clerk's tab and binding requirements before filing paper exhibits.
Free New York Exhibit Guide
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Use the guide as a preparation checklist
- Check the instructions for your assigned court.
- Confirm labels, deadlines, and delivery method.
- Review the finished files before submitting.
Quick Reference
Source citations apply to the statement beside them, not the whole page. Check current court instructions and your case orders before filing.
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Try It FreeExhibitPrep 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.
Two Ways to Prepare New York Exhibits
Manual Stamping
- •Place each label individually
- •Keep a separate exhibit list
- •Check numbering across files
- •Review instructions and finished files
With ExhibitPrep
- •Apply chosen labels across a batch
- •Create a contents page and bookmarks
- •Review stamps before saving
- •Revise and compare saved copies
About New York Exhibit Requirements
Individual judges' part rules in New York courts may differ, so check them. Individual judges may have part rules or preferences that differ from general state rules. This guide covers CPLR statewide requirements and highlights the importance of checking individual part rules before any court appearance.
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.
What's in the Guide
- Individual judge rules: check the assigned part's rules
- NYSCEF e-filing is mandatory in the classes of actions and counties the Chief Administrator specifies
- Check the requirements of the specific borough courthouse and part
- Commercial Division procedures: check the rules and the assigned justice's requirements
- Westchester County local rule variations - confirm with the court
- Check Nassau and Suffolk local and part rules for differences
- Upstate court practices vary by county and part; check local rules
- Business records foundation under CPLR 4518(a)
County-Specific Rules Covered
Manhattan (Commercial Division)
- • Check the Commercial Division rules in 22 NYCRR 202.70 and the assigned justice's rules
- • Check the Commercial Division rules and the assigned justice's requirements for pre-marking exhibits and stating objections
Kings County (Brooklyn)
- • Confirm exhibit tab requirements with the county clerk before filing paper exhibits
- • Confirm with the Kings County clerk how long trial exhibits are kept after a verdict
Nassau County
- • New York County's NYSCEF protocol asks that each exhibit be a separate attachment Source (opens in a new tab)
- • Confirm paper exhibit tabbing and binding requirements with the assigned part
Pro Tips Included
- •NYSCEF allows up to 100 MB per PDF document.
- •Keep PDFs free of active content, which NYSCEF does not allow
- •For Commercial Division cases, check the rules for bookmark and hyperlink requirements in memoranda
- •Check individual judge's part rules before your court date
Common Mistakes to Avoid
- 1.Embedding active content in a PDF, which NYSCEF does not allow
- 2.Not confirming exhibit tab requirements with the Kings County clerk
- 3.Grouping exhibits into one PDF where the county protocol asks for separate attachments
- 4.Not confirming how the court accepts video exhibits
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New York Exhibit FAQs
What exhibit marking system do New York courts require?
In a court-directed trial exhibit binder, plaintiff's exhibits are numerically tabbed and defendant's exhibits are tabbed alphabetically (22 NYCRR 202.20-h(b)). However, individual judges may have specific preferences, so always check the part rules for your assigned judge.
Is e-filing mandatory in New York courts?
NYSCEF e-filing is mandatory in Supreme Court only in the classes of actions and counties the Chief Administrator specifies by order. The NYSCEF file size limit is 100 megabytes per PDF document. Check nyscef.courts.state.ny.us for current requirements and participating courts.
Why are individual judge rules so important in New York?
Judges' preferences may vary, so check each part's rules. Each judge may have specific requirements for exhibit exchange deadlines, formatting, and presentation. Always check your assigned judge's part rules before appearing.
How do I authenticate business records in New York?
Business records produced under a subpoena duces tecum may be authenticated by a custodian's sworn certification under CPLR 3122-a, which is deemed to satisfy CPLR 4518(a). A custodian's certification under CPLR 3122-a must state that the records were made in the regular course of business, at the time of the event or within a reasonable time thereafter, and that making such records was the regular course of business.
See It in Action
A video walkthrough of ExhibitPrep stamping exhibits for New York courts.
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Nearby Jurisdictions
Practicing in multiple states? Check requirements for neighboring jurisdictions.