Personal Injury Exhibits in Pennsylvania
Complete guide to preparing personal injury exhibits that comply with Pennsylvania court requirements. Learn the correct labeling conventions, exchange deadlines, and e-filing procedures.
- Pennsylvania's primary rule governing exhibit preparation is Pa. R.C.P. 4003.5.
- Plaintiffs in Pennsylvania label exhibits with Numbers (P-1, P-2, P-3...).
- Defendants in Pennsylvania label exhibits with Numbers with D prefix (D-1, D-2, D-3...).
- Pennsylvania courts require electronic exhibits to be filed through County-specific for the courts of common pleas.
- Exhibits must be exchanged with opposing counsel 20 days before trial (Pa. R.C.P. 4003.5) under Pa. R.C.P. 4003.5.
- Common personal injury exhibits in Pennsylvania include medical records, medical bills, lost wage documentation.
- ExhibitPrep applies Pennsylvania exhibit stamps entirely in the browser, so personal injury case files never leave the user's computer.
Pennsylvania Exhibit Requirements at a Glance
| Plaintiff Exhibits | Numbers (P-1, P-2, P-3...) |
| Defendant Exhibits | Numbers with D prefix (D-1, D-2, D-3...) |
| Exchange Deadline | 20 days before trial (Pa. R.C.P. 4003.5) |
| Primary Rule | Pa. R.C.P. 4003.5 |
| E-Filing System | County-specific for the courts of common pleas |
Common Personal Injury Exhibits
Medical Records
Treatment records, imaging, surgical reports from all providers. For Pennsylvania e-filing on County-specific for the courts of common pleas, confirm the current file-size cap (Varies by county; no statewide limit confirmed) before uploading.
Medical Bills
Itemized statements, insurance EOBs, and lien documentation
Lost Wage Documentation
Pay stubs, tax returns, employer verification letters
Photographs
Injury photos, accident scene, vehicle damage
Police/Incident Reports
Official reports documenting the incident
Expert Reports
Medical experts, accident reconstructionists, economists
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Pennsylvania-Specific Considerations
- A plaintiff who chose limited-tort auto coverage must prove a "serious injury" threshold under 75 Pa.C.S. § 1702 before recovering for pain and suffering, which changes what the medical exhibits need to show
- Pennsylvania bars recovery entirely once a plaintiff is found 51% or more at fault under the modified comparative negligence rule in 42 Pa.C.S. § 7102
- Pennsylvania's collateral source rule generally keeps a plaintiff's own insurance payments out of evidence, so billing exhibits should reflect amounts billed rather than amounts actually paid
- Philadelphia's Complex Litigation Center manages a high volume of personal injury cases on its own case-management track, with exhibit-exchange deadlines set by that program rather than a fixed statewide date
How to Prepare Your Exhibits
Gather Your Documents
Collect all documents relevant to your personal injury case. This typically includes medical records, medical bills, lost wage documentation, and other supporting evidence.
Convert to PDF
Convert all documents to PDF format. Pennsylvania courts require electronic exhibits to be filed via County-specific for the courts of common pleas. Scan paper documents at 300 DPI.
Apply Exhibit Labels
Use ExhibitPrep to add Pennsylvania-compliant exhibit stamps. Plaintiffs use Numbers (P-1, P-2, P-3...), defendants use Numbers with D prefix (D-1, D-2, D-3...).
Exchange with Opposing Counsel
Exchange your exhibit list and copies with opposing counsel 20 days before trial (Pa. R.C.P. 4003.5) per Pa. R.C.P. 4003.5.
Save Hours on Exhibit Preparation
ExhibitPrep stamps all your personal injury exhibits in minutes, not hours. Upload your documents, select the correct Pennsylvania template, and download court-ready exhibits.
Frequently Asked Questions
How does Pennsylvania's limited tort option change what injury exhibits I need?
A plaintiff who chose limited-tort auto insurance coverage must prove a "serious injury" threshold under 75 Pa.C.S. § 1702 before recovering for pain and suffering, which means medical exhibits need to establish permanent disfigurement, serious impairment, or death, not just document treatment. Full-tort plaintiffs face no such threshold, so confirm which coverage applied before building the medical exhibit set.
What happens if a Pennsylvania plaintiff is found partly at fault?
Pennsylvania's modified comparative negligence rule under 42 Pa.C.S. § 7102 bars recovery entirely once a plaintiff is found 51% or more at fault, and reduces the award proportionally below that threshold. Fault-allocation exhibits — accident reconstruction reports, witness statements, dashcam footage — carry outsized weight because of how directly they affect the final number.
Can a defendant introduce a plaintiff's own insurance payments at trial?
Generally no. Pennsylvania's collateral source rule bars evidence of payments the plaintiff received from their own insurance, so medical billing exhibits typically need to reflect the amount billed, not the amount actually paid after insurance adjustments. That distinction matters when preparing damages exhibits for trial.
Does Philadelphia handle personal injury exhibits differently than the rest of the state?
Philadelphia's Complex Litigation Center manages a high volume of personal injury cases through its own case management track, with exhibit-exchange deadlines set by that program rather than a fixed statewide date. Confirm the Center's specific scheduling order rather than assuming Pa. R.C.P. 4003.5's general discovery framework alone controls timing.
How tight is Philadelphia's e-filing size limit for medical record exhibits?
Philadelphia caps individual e-filed documents at 5 MB, far tighter than PACFile's 500 MB statewide total, so a lengthy hospital record with imaging reports often needs to be split into several files. Plan on breaking up any exhibit over a few hundred pages before uploading in a Philadelphia County case.
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ExhibitPrep provides general information about court exhibit practices, not legal advice. Requirements change — verify current rules with your court or clerk before filing.