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New York Court Guide
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New York Court Exhibit Requirements

A guide to preparing exhibits for New York courts, including pre-marking under 22 NYCRR 202.34, including NYSCEF e-filing requirements, Commercial Division standards, and county-specific practices.

Pre-marking a 40-exhibit set by hand for a 202.34 pretrial conference takes about 2 hours. ExhibitPrep applies NYSCEF-ready numbered and lettered labels to the whole set in minutes.

Opens the tool set up for New York — plaintiff: Numbers starting at 1; defendant: Letters starting at A.

New York exhibit facts at a glance
  • 22 NYCRR 202.34 requires counsel to consult before trial to agree on exhibits offered without objection and, unless the court directs otherwise, to pre-mark exhibits.
  • NYSCEF caps PDFs at 100 MB per document and requires scanned PDF images at 200 dpi minimum resolution.
  • Plaintiff exhibits are numerically tabbed and defendant exhibits alphabetically tabbed in a court-directed trial binder under 22 NYCRR 202.20-h(b).
  • Commercial Division cases have their own rules (22 NYCRR 202.70) on exhibits, so check those rules and the assigned justice's order for deadlines and bookmarking.
  • Check 22 NYCRR 202.5 and the assigned judge's rules for paper size, margins and font before filing.
  • Check the Kings County clerk's and the assigned judge's requirements for exhibit tabs and for retrieving trial exhibits after a verdict.
  • For Nassau County, confirm the court's current protocol for uploading exhibits to NYSCEF.
  • NYSCEF e-filing is mandatory only in the case types and counties specified by order of the Chief Administrator under 22 NYCRR 202.5-bb, and unrepresented litigants are exempt.
62 CountiesNYSCEF System100 MB File LimitCheck the Scheduling Order for Deadlines

Quick Reference

Updated 2026-07
Size Limit

100 MB per PDF document Source (opens in a new tab)

Plaintiff

Numbers (numerically tabbed) Source (opens in a new tab)

Defendant

Letters (alphabetically tabbed) Source (opens in a new tab)

Deadline

Exhibits are pre-marked before trial begins unless the court directs…

Source links open in a new tab.

Source citations apply to the statement beside them, not the whole page. Check current court instructions and your case orders before filing.

Applicable Rules & Citations

Primary Rule

22 NYCRR 202.34

Pre-marking of exhibits before trial is required unless the court directs otherwise. Counsel must consult and attempt in good faith to agree on exhibits to be offered without objection.

Formatting Requirements

22 NYCRR 202.5

Check 22 NYCRR 202.5 and the assigned judge's rules for paper size, margins and font. Check the court's rules on translations of foreign-language exhibits.

E-Filing System

NYSCEF

NYSCEF accepts PDF documents up to 100 megabytes each; scanned PDF images require a resolution of 200 dots per inch; no active content is allowed.

Key Deadlines

Commercial Division Rule 28

Exchange trial exhibits by the deadline in the court's scheduling or pretrial order. Standard courts: exchange deadlines are set by the scheduling order or the assigned judge.

Overview

New York State courts use the NYSCEF (New York State Courts Electronic Filing) system, where e-filing is mandatory only in designated case types and counties. e-filing in the classes of actions and counties the Chief Administrator designates. 22 NYCRR 202.34 establishes pre-marking requirements, while the Commercial Division has its own rules of practice that should be reviewed for complex business litigation.

Key advantage: NYSCEF allows up to 100 MB per PDF document, which can reduce the need to split large exhibits. However, check your court's e-filing protocol for how exhibits should be uploaded, since some courts want each as a separate attachment.

NYSCEF Technical Specifications

100 MB File Limit Per PDF Document

NYSCEF allows up to 100 MB per PDF document. This means fewer split exhibits and simpler filing for document-heavy cases. Confirm the current file-size limit with the e-filing system or county clerk for California and Georgia courts.

File Format Requirements

Document Specifications

  • NYSCEF does not allow active content in PDF documents
  • 100 MB maximum per PDF document
  • 200 dpi minimum for scanned images

Commercial Division Extras

  • Commercial Division Rule 6 requires bookmarks in e-filed memoranda of law
  • Check the applicable Commercial Division rules for hyperlinks to cited exhibits
  • Confirm whether the court or assigned justice requires text-searchable PDFs

Exhibit Numbering Conventions

Standard New York Conventions

Plaintiff/Petitioner Exhibits

  • Numbers (plaintiff's exhibits are numerically tabbed in a court-directed binder)
  • Or: follow the numbering the court's pretrial order directs.
  • Or: follow the numbering the court's pretrial order directs.

Defendant/Respondent Exhibits

  • Letters: A, B, C... (defendant's exhibits are tabbed alphabetically in a court-directed binder)
  • Or: follow the numbering the court's pretrial order directs.
  • Or: follow any different numbering the court directs.

22 NYCRR 202.34: Pre-Marking of Exhibits

Counsel are generally expected to confer before trial about exhibits that can be offered without objection; check the assigned judge's rules. Pre-mark exhibits as 22 NYCRR 202.34 requires, unless the court directs otherwise, and exchange them per the court's scheduling order. Document all stipulations regarding exhibit authenticity and admissibility.

County-Specific Requirements

Kings County (Brooklyn)

Confirm current exhibit tab and exhibit-retrieval practice with the Kings County clerk's office.

Nassau County

Confirm Nassau County's current NYSCEF exhibit-upload and paper-exhibit requirements with the assigned part before exhibit exchange.

Westchester County

In New York County Supreme Court, each exhibit should be a separate attachment to its affidavit or affirmation. In New York County Supreme Court, exhibits should not be grouped together as a single PDF.

Commercial Division

Stricter requirements under 22 NYCRR 202.70 Rule 28. Counsel must consult prior to pre-trial conference. Memoranda must include bookmarks and hyperlinks.

22 NYCRR 202.70 Rule 28

Kings County (Brooklyn) - Confirm Tab Requirements With the Clerk

Confirm Kings County tab requirements for paper exhibits with the clerk before filing. Additionally, ask the clerk how long trial exhibits may be retrieved after verdict. Ensure physical exhibits have proper tabs that extend beyond the page edge.

For e-filed exhibits, clear electronic stamps can serve to identify them, but be prepared with properly tabbed physical copies for trial.

Common NYSCEF Issues

Exhibits Grouped Into a Single Upload

Solution: in New York County, make each exhibit a separate attachment, and confirm your county's e-filing protocol. Export individual files from ExhibitPrep and, where your court's protocol calls for it, upload each as its own attachment.

Missing Pre-Marking Per 22 NYCRR 202.34

Solution: Pre-mark exhibits before trial as 22 NYCRR 202.34 requires, unless the court directs otherwise. ExhibitPrep places consistent stamps on every page meeting NYSCEF requirements.

Commercial Division: Missing Bookmarks

Solution: Commercial Division Rule 6 requires bookmarks in e-filed memoranda of law and, where appropriate, affidavits and affirmations. Add PDF bookmarks and link to specific exhibit pages when citing evidence.

Scanned Images Below 200 DPI

Solution: NYSCEF requires scanned PDF images at 200 dpi minimum. Re-scan documents at 300 dpi for best quality. ExhibitPrep preserves source document resolution.

The pre-marking and formatting rejections above are exactly what ExhibitPrep prevents automatically. Stamp NYSCEF-ready exhibits now →

Take the New York Requirements With You

Get the complete New York exhibit guide as a PDF — 22 NYCRR 202.34 pre-marking, NYSCEF format rules, Commercial Division deadlines, and county-specific notes, ready to share with your paralegal.

Free New York Exhibit Guide

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Court-rule updates and exhibit-prep tips, by state

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.
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How ExhibitPrep Helps with New York Requirements

Time Savings

Stamp 50 exhibits in 5 minutes vs. 2+ hours manually preparing labels.

Cost Effective

$14.99 Day Pass vs. $100+/hr paralegal time. Stamp unlimited exhibits for one low price.

NYSCEF Ready

Export individual files for separate NYSCEF uploads. 22 NYCRR 202.34 compliant formatting.

Opens the tool set up for New York — plaintiff: Numbers starting at 1; defendant: Letters starting at A.

ExhibitPrep Configuration for New York Courts

Recommended Settings

Exhibit Format

Use the exhibit label format the court or assigned judge directs. Add party designation if required (e.g., "Plaintiff's Exhibit 1" for plaintiff; confirm the convention for defendant with the court or pretrial order).

Export Method

In New York County NYSCEF cases, upload each exhibit as a separate attachment to its affidavit or affirmation. New York County Supreme Court asks that each exhibit be submitted as a separate attachment to its affidavit or affirmation.

Stamp Position

Place the stamp where it does not cover existing text, and check the assigned judge's preferences. Ensure stamps are clearly visible and don't obscure document content.

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.

Frequently Asked Questions

What are the NYSCEF mandatory pre-marking requirements under 22 NYCRR 202.34?

22 NYCRR 202.34 requires pre-marking of trial exhibits in Supreme and County Court civil actions unless the court directs otherwise. Counsel must consult before trial and attempt in good faith to agree on exhibits that can be offered without objection. Exhibits are pre-marked before trial under 22 NYCRR 202.34; check the court's scheduling order for exchange deadlines.

What is the NYSCEF file size limit for exhibits?

NYSCEF allows PDF documents of up to 100 megabytes each. NYSCEF requires a resolution of 200 dots per inch for scanned PDF images and does not allow active content in PDFs. Confirm the current NYSCEF size limit before deciding whether large exhibits need to be split.

What are the Commercial Division exhibit requirements under 22 NYCRR 202.70 Rule 28?

Commercial Division cases are subject to additional rules in 22 NYCRR 202.70 and the assigned justice's rules, so check them for exhibit submission deadlines, bookmarking and pre-trial consultation requirements.

Why does Kings County reject papers without protruding tabs?

Confirm current exhibit tab and exhibit-retrieval practice with the Kings County clerk's office.

What are the Nassau County NYSCEF exhibit requirements?

Confirm Nassau County's current exhibit-upload and paper-exhibit requirements with the assigned part; New York County's NYSCEF protocol asks that each exhibit be a separate attachment rather than a single grouped PDF.

How do I format exhibits for New York Supreme Court?

Check the court's rules and the assigned part for paper size, margin and font requirements, and for how plaintiff's and defendant's exhibits are labeled.

Prepare New York Court Exhibits in Minutes

ExhibitPrep makes it easy to prepare professional New York exhibits for review against current NYSCEF and court requirements. Preview your stamped exhibits before paying.

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