- Pennsylvania exhibit marking and exchange rule (Pa. R.C.P. 4003.5) (Pa. R.C.P. 4003.5)
Governs exhibit marking, exchange deadlines, and disclosure for personal injury cases in Pennsylvania courts.
Personal Injury Exhibits in Pennsylvania
The pretrial exchange is next week. On your desk are records from four providers, the police report, the billing summary and a folder of scene photographs, each in a different format. Every one needs a plaintiff's exhibit label, in the order your exhibit list will use.
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 Permitted or required by local rule (Pa.R.C.P. 205.4(a)(1)).
- 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.
What goes wrong with personal injury exhibits, and how it is handled
What goes wrongRecords arrive from each provider as a separate PDF, and labeling them one at a time is where a number gets skipped or used twice.
How ExhibitPrep handles itBatch stamping applies sequential labels across the whole set — 1, 2, 3 or A, B, C — from the starting value you choose, in the document order you set.
What goes wrongScene and injury photographs are JPG and PNG files, not PDFs.
How ExhibitPrep handles itPDFs are stamped directly; PNG, JPG, GIF, WebP, BMP, TIFF images become PDF pages first, so photographs and screenshots take a label in the same sequence as everything else.
What goes wrongThe department's trial order requires every page of a multi-page exhibit to be numbered: Exhibit 1, then 1-2, 1-3 through the last page of the records.
How ExhibitPrep handles itTurn on Number every page of each exhibit and the stamp itself carries the page number — Exhibit 1 on the first page, then Exhibit 1-2, Exhibit 1-3 to the last page — with a hyphen or a period, previewed page by page and read back from every page before the file is delivered.
What goes wrongMedical records are confidential, and the file cannot go to a third-party server to be stamped.
How ExhibitPrep handles itDocument bytes are processed locally in your browser and are not uploaded to our servers.
Essential tools for personal injury exhibits
Batch stamping
Sequential labels across the whole set — 1, 2, 3 or A, B, C — from the starting value you choose
How it worksCombine with a table of contents
One PDF in exhibit order, with an optional table of contents and clickable bookmarks
How it worksExhibit list
A captioned Exhibit List PDF built from the labels and titles you assigned
How it worksPennsylvania 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 | Permitted or required by local rule (Pa.R.C.P. 205.4(a)(1)) |
Common Personal Injury Exhibits
Medical Records
Treatment records, imaging, surgical reports from all providers. For Pennsylvania e-filing on Permitted or required by local rule (Pa.R.C.P. 205.4(a)(1)), confirm the current file-size cap (No statewide limit located — confirm with the county prothonotary) 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
- Confirm whether the plaintiff's auto coverage was limited-tort or full-tort, since that may affect 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 Permitted or required by local rule (Pa.R.C.P. 205.4(a)(1)). Scan paper documents at 300 DPI.
Apply Exhibit Labels
Use ExhibitPrep to add exhibit stamps for Pennsylvania filing review. Plaintiffs commonly use Numbers (P-1, P-2, P-3...), while defendants commonly use Numbers with D prefix (D-1, D-2, D-3...); verify the governing rules.
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?
Confirm whether the plaintiff's auto coverage was limited-tort or full-tort, since that may affect what the medical exhibits need to show; confirm the threshold with counsel. 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.
Related Resources
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ExhibitPrep formats documents; it does not provide legal advice or filing approval. Some guidance remains unverified. Citations support only their stated claims and scope. Review the finished files against current court instructions and case orders before filing. Check requirements and the finished PDF before filing.