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Personal Injury
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Personal Injury Exhibits for New York Courts

New York personal injury litigation follows CPLR Article 31 for discovery and 22 NYCRR for court procedures. NYC Supreme Court (Manhattan, Brooklyn, Bronx, Queens) handles enormous personal injury volume. No-fault insurance and serious injury threshold create unique exhibit needs. This guide covers exhibit preparation for motor vehicle, premises, and construction accident cases in New York.

Personal Injury exhibits in New York: key facts
  • New York's primary exhibit rule is CPLR 3101, 22 NYCRR.
  • Personal Injury cases in New York e-file through NYSCEF.
  • NYSCEF caps each uploaded document at 25 MB.
  • The exhibit exchange deadline in New York is Per CPLR 3101 and court order.
  • Common Personal Injury exhibits in New York include Police accident reports (MV-104) and Medical records and bills.
  • ExhibitPrep stamps exhibits in the browser, so case files never leave the computer.

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.

NYSCEFPer CPLR 3101 and court orderCPLR 3101, 22 NYCRR

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

Free New York Guide

New York Quick Reference

E-Filing SystemNYSCEF ↗
File Size Limit25 MB
Exchange DeadlinePer CPLR 3101 and court order
Primary RuleCPLR 3101, 22 NYCRR

Common Personal Injury Exhibits in New York

Police accident reports (MV-104)
Medical records and bills
Photographs of injuries and scene
Witness statements
IME reports
Expert medical reports
Life care plans
Economic loss calculations
No-fault records
Labor Law 240/241 documentation
Construction site records
Day-in-the-life videos

New York Personal Injury Tips

  • 1CPLR 3101 governs broad discovery rights
  • 2No-fault serious injury threshold must be met (Insurance Law 5102(d))
  • 3NYC has specific note of issue and trial readiness requirements
  • 4Labor Law 240/241 applies to construction accidents
  • 5NYSCEF is mandatory for most cases
  • 6IME (Independent Medical Exam) records important
  • 7Bates stamp all medical records chronologically

Common Personal Injury Filing Mistakes in New York

Failing to prove serious injury threshold
Incomplete no-fault application records
Missing Labor Law documentation in construction cases
Not obtaining all IME reports
Inadequate lost wage documentation
Missing pre-existing condition evidence

Personal Injury Exhibits in New York: FAQ

What is the New York serious injury threshold?

Insurance Law 5102(d) requires proof of "serious injury" to recover non-economic damages in motor vehicle cases. Serious injury categories include permanent consequential limitation of use of a body organ or member and significant limitation of use of a body function or system. Prepare medical exhibits addressing threshold.

What are NYC Supreme Court injury case procedures?

NYC Supreme Court has specific preliminary conference, compliance conference, and note of issue requirements. Check county-specific procedures for Manhattan, Brooklyn, Bronx, or Queens.

What is New York Labor Law 240/241?

Labor Law 240 (Scaffold Law) provides strict liability for gravity-related construction injuries. Labor Law 241(6) requires compliance with Industrial Code. Prepare exhibits documenting violations.

How do I organize medical records for NY injury cases?

Organize chronologically by provider. Include all treatment records, no-fault applications, and IME reports. Address serious injury categories in medical summaries.

What no-fault exhibits are needed in New York?

Include no-fault applications, denial letters, payment records, and correspondence. No-fault benefits are primary before tort recovery.

Related Resources

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