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Real Estate Exhibits in New York

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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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, keep each file under 100 MB per document.

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 New York-compliant exhibit stamps. Plaintiffs use Numbers (1, 2, 3...), defendants use Letters (A, B, C...).

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.

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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. New York's 100 MB NYSCEF upload cap is the largest of any state, and pre-marking of exhibits under 22 NYCRR 202.34 is mandatory before trial. 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, which caps individual uploads at 100 MB per document. Export each exhibit as a text-searchable PDF, and split any long purchase agreements into separate files before uploading so a single scanned record doesn't blow past the cap.

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, court-compliant 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 NYSCEF's 100 MB per document cap often forces a large production into dozens of separate uploads.

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