New York Court Exhibit Requirements
A comprehensive guide to preparing exhibits for New York courts under 22 NYCRR 202.34, including NYSCEF e-filing requirements, Commercial Division standards, and county-specific practices.
- 22 NYCRR 202.34 requires mandatory pre-marking of exhibits and a pretrial conference where counsel must consult to agree on exhibits offered without objection.
- NYSCEF caps PDFs at 100 MB per document — the largest limit among state e-filing systems — and requires PDF/A format at 200 dpi minimum resolution.
- Plaintiff/petitioner exhibits typically use numbers (1, 2, 3); defendant/respondent exhibits use letters (A, B, C) or D-1, D-2 prefixes.
- Commercial Division Rule 28 (22 NYCRR 202.70) requires trial exhibits submitted at least 14 days before trial with bookmarks and hyperlinks in supporting memoranda.
- 22 NYCRR 202.5 requires 8.5 x 11 paper, 1-inch margins, 12-point minimum font, and certified English translations with translator affidavits for foreign-language exhibits.
- Kings County (Brooklyn) clerks reject papers lacking protruding exhibit tabs, and trial exhibits not retrieved within 30 days of verdict are disposed.
- Nassau County requires each e-filed exhibit to be a separate NYSCEF document — exhibits cannot be grouped under a single exhibit number.
- NYSCEF e-filing is mandatory for attorneys in most New York counties and operates across the 62 counties of the New York State Unified Court System.
Quick Reference
Updated 2026-01-31100 MB
Numbers (1, 2, 3...)
Letters (A, B, C...)
14-21 days before trial
Applicable Rules & Citations
Primary Rule
Mandatory pre-marking of exhibits. Counsel must consult to agree on exhibits to be offered without objection.
Formatting Requirements
8.5x11 paper, 1-inch margins, 12-point minimum font. Foreign language exhibits require English translations with translator affidavits.
E-Filing System
100 MB max (largest among jurisdictions). PDF/A format required, 200 dpi minimum resolution.
Key Deadlines
Trial exhibits submitted at least 14 days before trial. Standard courts: 14-21 days per scheduling order.
Overview
New York State courts use the NYSCEF (New York State Courts Electronic Filing) system with mandatory e-filing in most counties. 22 NYCRR 202.34 establishes mandatory pre-marking requirements, while the Commercial Division under Rule 28 has stricter standards for complex business litigation.
Key advantage: NYSCEF's 100 MB file limit is the largest among state e-filing systems, allowing for larger exhibits without splitting. However, each exhibit must still be uploaded as a separate document in most counties.
NYSCEF Technical Specifications
100 MB File Limit - Largest Among State Courts
NYSCEF allows up to 100 MB per document, significantly larger than California (25 MB), Texas (25 MB), Florida (7 MB), or Georgia (1.5 MB). This means fewer split exhibits and simpler filing for document-heavy cases.
File Format Requirements
Document Specifications
- PDF/A format required
- 100 MB maximum per document
- 200 dpi minimum resolution
Commercial Division Extras
- Bookmarks required in memoranda
- Hyperlinks to cited exhibits
- Text-searchable PDFs required
Exhibit Numbering Conventions
Standard New York Conventions
Plaintiff/Petitioner Exhibits
- Numbers: 1, 2, 3... (most common)
- Or: P-1, P-2, P-3...
- Or: Plaintiff's Exhibit 1, 2, 3...
Defendant/Respondent Exhibits
- Letters: A, B, C... (traditional)
- Or: D-1, D-2, D-3...
- Or: numbers starting at 100+
22 NYCRR 202.34: Mandatory Pre-Marking Conference
Counsel must consult before trial to agree on exhibits that can be offered without objection. Pre-mark all exhibits for identification and exchange per the court's scheduling order. Document all stipulations regarding exhibit authenticity and admissibility.
County-Specific Requirements
Kings County (Brooklyn)
Clerks reject papers without protruding exhibit tabs. Trial exhibits not retrieved within 30 days of verdict are disposed.
Nassau County
Each e-filed exhibit must be separate NYSCEF document. Paper exhibits must be clearly tabbed, single-sided, with litigation back (max 2 inches thick).
Westchester County
Each exhibit must be uploaded as separate PDF. Multiple documents cannot be grouped under single exhibit.
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) - Papers Rejected Without Protruding Tabs
Kings County clerks are known to reject papers that lack protruding exhibit tabs. Additionally, trial exhibits not retrieved within 30 days of verdict are disposed. Ensure physical exhibits have proper tabs that extend beyond the page edge.
For e-filed exhibits, clear electronic stamps serve the identification purpose, but be prepared with properly tabbed physical copies for trial.
Common NYSCEF Issues
Exhibits Not Uploaded as Separate Documents
Solution: Nassau and other counties require each exhibit as a separate NYSCEF document. Export individual files from ExhibitPrep and upload each as its own attachment.
Missing Pre-Marking Per 22 NYCRR 202.34
Solution: Ensure all exhibits are pre-marked for identification before trial. ExhibitPrep places consistent stamps on every page meeting NYSCEF requirements.
Commercial Division: Missing Bookmarks/Hyperlinks
Solution: Rule 28 requires bookmarks and hyperlinks in memoranda. Add PDF bookmarks and link to specific exhibit pages when citing evidence.
Resolution Below 200 DPI
Solution: NYSCEF requires minimum 200 dpi resolution. Re-scan documents at 300 dpi for best quality. ExhibitPrep preserves source document resolution.
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.
ExhibitPrep Configuration for New York Courts
Recommended Settings
Exhibit Format
Use "Exhibit [number]" format. Add party designation if required (e.g., "Plaintiff's Exhibit 1" for plaintiff, "Exhibit A" or "D-1" for defendant).
Export Method
Export as individual files for NYSCEF upload. Most counties require each exhibit as a separate document attachment.
Stamp Position
Bottom-right corner is standard. Ensure stamps are clearly visible and don't obscure document content.
Frequently Asked Questions
What are the NYSCEF mandatory pre-marking requirements under 22 NYCRR 202.34?
22 NYCRR 202.34 requires mandatory pre-marking of exhibits in New York State courts. Counsel must consult before trial to agree on exhibits that can be offered without objection. Exhibits must be pre-marked for identification and exchanged according to court scheduling orders.
What is the NYSCEF file size limit for exhibits?
NYSCEF has the most generous file size limit among state courts at 100 MB per document. PDF/A format is required with 200 dpi minimum resolution. This allows for larger exhibits without splitting compared to other jurisdictions.
What are the Commercial Division exhibit requirements under 22 NYCRR 202.70 Rule 28?
Commercial Division Rule 28 (22 NYCRR 202.70) requires stricter exhibit standards. Trial exhibits must be submitted at least 14 days before trial. Memoranda must include bookmarks and hyperlinks to cited exhibits. Counsel must consult prior to pre-trial conference.
Why does Kings County reject papers without protruding tabs?
Kings County (Brooklyn) clerks are known to reject papers that lack protruding exhibit tabs. Trial exhibits not retrieved within 30 days of verdict are disposed. This is a specific local practice that requires careful attention to physical exhibit formatting.
What are the Nassau County NYSCEF exhibit requirements?
Nassau County requires each e-filed exhibit to be a separate NYSCEF document - documents cannot be grouped under a single exhibit number. Paper exhibits must be clearly tabbed, single-sided, with litigation back (max 2 inches thick).
How do I format exhibits for New York Supreme Court?
New York Supreme Court requires 8.5x11 inch paper with 1-inch margins and 12-point minimum font (22 NYCRR 202.5). Plaintiffs typically use numbers (1, 2, 3) and defendants use letters (A, B, C). Foreign language exhibits require English translations with translator affidavits.
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