- New York exhibit marking and exchange rule (22 NYCRR 202.34) (22 NYCRR 202.34)
Governs exhibit marking, exchange deadlines, and disclosure for telecommunications cases in New York courts.
Telecommunications Exhibits in New York
Your TCPA case is built on call records. Call-detail reports, consent forms, dialer configuration exports and a damages calculation become exhibits, and some of them are spreadsheets and audio files with no pages to stamp.
Complete guide to preparing telecommunications exhibits that comply with New York court requirements. Learn the correct labeling conventions, exchange deadlines, and e-filing procedures.
- 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 telecommunications exhibits in New York include call records, esi/electronic discovery, contracts & agreements.
- ExhibitPrep applies New York exhibit stamps entirely in the browser, so telecommunications case files never leave the user's computer.
What goes wrong with telecommunications exhibits, and how it is handled
What goes wrongSpreadsheets and call recordings have no pages to stamp, but they still need a place in the exhibit sequence.
How ExhibitPrep handles itA slipsheet holds the place of a Word, Excel, PowerPoint, audio or video file in the sequence: a placeholder page that names the original file, so the separate file can be matched to it.
What goes wrongCall logs run across many files, each needing its own label.
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 wrongCall records, consent evidence and technical documents belong in separate sections of the binder.
How ExhibitPrep handles itCategory slipsheets are divider pages inserted between groups of exhibits in a combined PDF, keeping your document order intact.
What goes wrongThe text-message logs that prove the calls and texts arrive as an RSMF export from the carrier production or a collection tool.
How ExhibitPrep handles itPhone screenshots become PDF pages like any image; an RSMF message export from a collection or review tool renders to a transcript instead — every message with its time, sender and account identifier, deleted and edited messages marked, the export's hash on the first page — and is then stamped in the same sequence as everything else.
Essential tools for telecommunications exhibits
Slipsheets
Word, Excel, PowerPoint and audio or video files get a placeholder page that holds their place in the sequence
How it worksBatch 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 worksNew York Exhibit Requirements at a Glance
| Plaintiff Exhibits | Numbers (1, 2, 3...) |
| Defendant Exhibits | Letters (A, B, C...) |
| Exchange Deadline | 10-14 days before trial (varies by county) |
| Primary Rule | 22 NYCRR 202.34 |
| E-Filing System | NYSCEF |
Common Telecommunications Exhibits
Call Records
Phone logs, text message records, call detail records. For New York e-filing on NYSCEF, confirm the current file-size cap (100 MB per PDF document) before uploading.
ESI/Electronic Discovery
Emails, voicemails, chat logs, social media
Contracts & Agreements
Service agreements, terms of service, consent forms
TCPA Compliance Records
Do-not-call lists, consent documentation, scripts
Technical Evidence
Network logs, auto-dialer records, caller ID info
Damages Evidence
Receipts, call volumes, statutory damages calculations
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New York-Specific Considerations
- General Business Law §399-p telemarketing rules
- NYC consumer protection laws stricter
- Major financial services calling cases
- TCPA mass action venue popular
How to Prepare Your Exhibits
Gather Your Documents
Collect all documents relevant to your telecommunications case. This typically includes call records, esi/electronic discovery, contracts & agreements, and other supporting evidence.
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.
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.
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 telecommunications 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 telecommunications 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 Telecommunications templates apply the right prefix automatically, so you're not re-deriving the local convention on every filing.
When do I have to exchange telecommunications 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 telecommunications production in one ExhibitPrep session once it's locked in.
What e-filing system handles telecommunications 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 call records into separate files so a single scanned record doesn't blow past the limit.
What exhibits come up most in a New York telecommunications case?
Telecommunications matters in New York typically turn on call records, esi/electronic discovery, contracts & agreements, plus whatever case-specific records the dispute calls for. General Business Law §399-p telemarketing rules. 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 telecommunications 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 telecommunications 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.