- New York Uniform Rules 202.20 (22 NYCRR 202.20) (opens in a new tab)
New York pretrial conference and exhibit marking requirements
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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.
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- 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.
Quick Reference
Updated 2026-07- Primary Rule
- 22 NYCRR 202.20-h… (opens in a new tab)
- E-Filing
- NYSCEF (opens in a new tab)
- 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
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
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 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
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 28Kings 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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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.
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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