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Legal authority cited:
  • New York exhibit marking and exchange rule (22 NYCRR 202.34) (22 NYCRR 202.34)

    Governs exhibit marking, exchange deadlines, and disclosure for real estate cases in New York courts.

Real EstateNew York

Real Estate Exhibits in New York

Your boundary dispute is set for trial. The purchase agreement and its addenda, the title report, two surveys, the inspection report and condition photographs need exhibit labels, and the plats have to stay readable at full size.

Complete guide to preparing real estate exhibits that comply with New York court requirements. Learn the correct labeling conventions, exchange deadlines, and e-filing procedures.

New York real estate exhibit facts at a glance
  • New York's primary rule governing exhibit preparation is 22 NYCRR 202.34.
  • Plaintiffs in New York label exhibits with Numbers (1, 2, 3...).
  • Defendants in New York label exhibits with Letters (A, B, C...).
  • New York courts require electronic exhibits to be filed through NYSCEF.
  • Exhibits must be exchanged with opposing counsel 10-14 days before trial (varies by county) under 22 NYCRR 202.34.
  • Common real estate exhibits in New York include purchase agreements, title documents, property surveys.
  • ExhibitPrep applies New York exhibit stamps entirely in the browser, so real estate case files never leave the user's computer.
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What goes wrong with real estate exhibits, and how it is handled

  • What goes wrongA stamp across a plat or a legal description makes the exhibit harder to read.

    How ExhibitPrep handles itDrag the stamp anywhere on the page or choose a preset; the preview shows the page you will download, so the stamp can be kept clear of signatures, figures and existing page numbers.

  • What goes wrongCondition photographs are JPG files from a phone.

    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 closing file is a dozen documents that belong together as one binder.

    How ExhibitPrep handles itCombining produces one PDF in exhibit order, with an optional table of contents and clickable bookmarks; each contents entry lists the exhibit label, its title when you add one, and the page it starts on.

  • What goes wrongSurveys and plats are larger pages than the rest of the set.

    How ExhibitPrep handles itSet the stamp size once for the set, make it readable without covering document content, and check mixed page sizes in the finished preview.

Essential tools for real estate exhibits

New York Exhibit Requirements at a Glance

Plaintiff ExhibitsNumbers (1, 2, 3...)
Defendant ExhibitsLetters (A, B, C...)
Exchange Deadline10-14 days before trial (varies by county)
Primary Rule22 NYCRR 202.34
E-Filing SystemNYSCEF

Common Real Estate Exhibits

Purchase Agreements

Contracts, addenda, counteroffers, and closing documents. For New York e-filing on NYSCEF, confirm the current file-size cap (100 MB per PDF document) before uploading.

Title Documents

Deeds, title reports, title insurance policies

Property Surveys

Boundary surveys, plat maps, site plans

Inspection Reports

Home inspection, pest inspection, environmental reports

Disclosure Documents

Seller disclosures, HOA documents, CC&Rs

Appraisals

Property valuations, comparable sales data

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New York-Specific Considerations

  • NYC transfer taxes add significant costs
  • Co-op vs condo distinction affects documentation
  • Attorney review period standard in contracts
  • Lead paint and asbestos disclosure requirements

How to Prepare Your Exhibits

1

Gather Your Documents

Collect all documents relevant to your real estate case. This typically includes purchase agreements, title documents, property surveys, and other supporting evidence.

2

Convert to PDF

Convert all documents to PDF format. New York courts require electronic exhibits to be filed via NYSCEF. Scan paper documents at 300 DPI.

3

Apply Exhibit Labels

Use ExhibitPrep to add exhibit stamps for New York filing review. Plaintiffs commonly use Numbers (1, 2, 3...), while defendants commonly use Letters (A, B, C...); verify the governing rules.

4

Exchange with Opposing Counsel

Exchange your exhibit list and copies with opposing counsel 10-14 days before trial (varies by county) per 22 NYCRR 202.34.

Save Hours on Exhibit Preparation

ExhibitPrep stamps all your real estate exhibits in minutes, not hours. Upload your documents, select the correct New York template, and download court-ready exhibits.

Frequently Asked Questions

How should I label real estate exhibits in New York?

Use Numbers (1, 2, 3...) for plaintiff exhibits and Letters (A, B, C...) for defense exhibits, per 22 NYCRR 202.34. NYSCEF accepts up to 100 MB per PDF document. ExhibitPrep's Real Estate templates apply the right prefix automatically, so you're not re-deriving the local convention on every filing.

When do I have to exchange real estate exhibits in New York?

New York sets the exhibit exchange window at 10-14 days before trial (varies by county) under 22 NYCRR 202.34, though the exact date can shift with your assigned judge's scheduling order. Confirm the deadline in your case's pretrial order before you start stamping, then batch-process the full real estate production in one ExhibitPrep session once it's locked in.

What e-filing system handles real estate exhibits in New York?

New York runs electronic filing through NYSCEF. Check the current upload cap before filing (100 MB per PDF document), export each exhibit as a text-searchable PDF, and split any long purchase agreements into separate files so a single scanned record doesn't blow past the limit.

What exhibits come up most in a New York real estate case?

Real Estate matters in New York typically turn on purchase agreements, title documents, property surveys, plus whatever case-specific records the dispute calls for. NYC transfer taxes add significant costs. Stamp them all inside ExhibitPrep using the matching plaintiff or defense template, so every exhibit in the production carries a consistent, consistent exhibit mark before it goes to opposing counsel.

Can I stamp a large real estate production for New York courts?

Yes. The Day Pass ($14.99) gives you unlimited stamping for 24 hours, which covers hundreds of exhibits in a single real estate case. Processing runs entirely in your browser, so your New York case files never leave your computer. That matters here because e-filing upload caps (100 MB per PDF document) often force a large production into multiple separate uploads.

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.