A trial exhibit list is a table filed before trial that assigns each piece of evidence a number or letter, describes it, identifies the witness who will introduce it, and leaves blank columns for the clerk to complete during proceedings. Below is an exhibit list example for trial, followed by the format rules, deadlines, and consequences that shape how you fill one out in federal court.
A Sample Exhibit List
Federal courts use a standard form, AO 187, published by the Administrative Office of the United States Courts. Under the case caption and a title like “Plaintiff’s Pretrial Exhibit List,” the body of a completed list for a plaintiff in a contract dispute might read:
- Exhibit 1: Signed Services Agreement dated March 12, 2024 (8 pages)
- Exhibit 2: Email from Defendant to Plaintiff dated June 3, 2024, re: “Payment Schedule Change”
- Exhibit 3: Invoice No. 4417 dated July 15, 2024 ($42,500.00)
- Exhibit 4: Photograph of damaged equipment at Plaintiff’s warehouse, taken August 1, 2024
- Exhibit 5: Bank statement for Plaintiff’s business account, August 2024 (redacted)
The defendant’s exhibits follow the same structure but use letters: Exhibit A, Exhibit B, and so on. That split keeps the record clean when both sides are handing documents to the same witness.
The Column Structure
The AO 187 form organizes each row into six columns:
- PLF. NO. — the plaintiff’s exhibit number (1, 2, 3)
- DEF. NO. — the defendant’s exhibit letter or number (A, B, C)
- DATE OFFERED — left blank; the clerk fills this in at trial
- MARKED — left blank; the clerk records when the exhibit is marked for identification
- ADMITTED — left blank; the clerk records when the court formally admits it into evidence
- DESCRIPTION OF EXHIBITS AND WITNESSES — your description of each item, with a note about the location of any exhibit not held with the case file or unavailable because of size
The form also asks you to flag any exhibit that will be stored separately, like an oversized map or a physical object that won’t fit in a folder. Build the body of your list as a table with your information on the left and the three clerk columns on the right. Carry blank column blocks to the bottom of every page, and leave extra blank rows at the end, because exhibits sometimes multiply once testimony starts.
What Each Row Needs
Unique Numbers and Letters
Every exhibit gets one identifier that nobody else in the case is using. Plaintiffs number sequentially; defendants use letters. If a defendant runs past 26 exhibits, some courts use double letters (AA, BB) before switching to numbers.
Descriptions That Identify the Item
The description has to tell the judge and opposing counsel exactly what they are looking at. Include the type of document, any identifying number, the date, and enough detail to separate it from anything similar. “Promissory Note dated May 15, 2024, in the amount of $75,000” works. “Document” does not. For photographs, name the subject and the date the photo was taken: “Six photographs of intersection at Main and Oak Streets, taken September 3, 2025.”
Vague descriptions cause real problems at trial. If your list says “Contract” and three contracts are in evidence, no one can track which one the witness is discussing. Opposing counsel will object, and the court may sustain the objection until you clarify the record.
Will Offer vs. May Offer
Federal rules require you to separate exhibits you expect to offer from exhibits you may offer only if the need arises. The distinction affects your opponent’s duty to object: even for a “may offer” item, they still have to raise objections within the deadline or risk waiving them, but the court understands you might never actually use it.
Sponsoring Witnesses
Many courts require you to identify the witness who will introduce each exhibit. That witness lays the foundation, usually by testifying that they recognize the document, created it, or can otherwise authenticate it. Naming sponsors helps the court schedule testimony and gives opposing counsel a clear map of how you plan to connect each exhibit to your case.
The Caption and Title
Every exhibit list opens with the same case caption that appears on your other filings: court name, case number, and party names. Directly below, add a plain title such as “Plaintiff’s Pretrial Exhibit List” or “Defendant’s Exhibit List.” That title keeps the document tied to the right case file when the clerk’s office is processing hundreds of filings.
Digital and Electronic Evidence
Digital files need more description than paper does, because a judge can’t glance at a video the way they’d glance at a contract. Include the file type, the duration or size where relevant, and the subject matter. For example: “Exhibit 7: Security camera footage from Plaintiff’s loading dock, July 22, 2024, 2:14–2:47 PM (.mp4, 3 min 22 sec).”
When you submit digital exhibits on physical media like a DVD or USB drive, courts typically require each file to be named with its exhibit number and a short description, following a format like “7_loading_dock_footage.mp4.” Include a hard copy index listing every file on the media alongside its electronic filename so the clerk can match each digital file back to your exhibit list without opening it.
Redactions Before You File
Federal Rule of Civil Procedure 5.2 requires you to strip certain personal identifiers from anything filed with the court. Filings may include only:
- the last four digits of a Social Security or taxpayer ID number
- the year of a person’s birth
- a minor’s initials in place of their name
- the last four digits of a financial account number
Trial exhibits are subject to these rules to the extent they are filed. Exhibits that aren’t initially filed but are later included in an appeal must be redacted at that point. If your list references a bank statement or tax return, the underlying document must be redacted before it goes in. The court can also order redaction of additional categories for good cause.
Filing Deadlines
The 30-Day Rule and the 14-Day Objection Window
Under the Federal Rules of Civil Procedure, pretrial disclosures, including your exhibit list, must be filed and served on the opposing party at least 30 days before trial unless the court sets a different deadline. Many judges set their own timeline in the scheduling order, sometimes earlier than the default. Read the scheduling order first, because that deadline controls.
Once you receive the other side’s exhibit list, you have 14 days to file written objections to any exhibit. Miss that window and most objections are waived. Two survive without a timely filing: objections based on relevance under Federal Rule of Evidence 402 and objections based on unfair prejudice under Federal Rule of Evidence 403. Everything else is gone.
The Duty to Supplement
Filing your exhibit list isn’t a one-time event. If you later discover the list is incomplete or incorrect in some material way, you have an ongoing duty to supplement it in a timely manner. This obligation applies whenever the new information hasn’t already reached the other parties through discovery. If you find a key document after filing your list, update the list and notify the other side rather than saving it as a surprise.
What Happens If You Leave an Exhibit Off
The penalty is direct: the court can bar you from using it. Federal Rule of Civil Procedure 37(c)(1) says that if a party fails to identify an exhibit as required under Rule 26(a), “the party is not allowed to use that information or witness to supply evidence on a motion, at a hearing, or at a trial, unless the failure was substantially justified or is harmless.”
That last clause is the only way out. You would need to persuade the judge that you had a good reason for the omission or that admitting the evidence won’t prejudice the other side. Courts weigh how long the evidence was withheld, whether the omission was deliberate, and how important the exhibit is to the case.
Exclusion isn’t the only sanction. On motion, the court can order you to pay the opposing party’s reasonable expenses and attorney’s fees caused by the failure. The court can also inform the jury of your failure to disclose. In extreme cases, the court may strike pleadings, enter default judgment, or dismiss claims.
Pre-Marking Exhibits Before Trial
When a party expects to introduce more than a handful of exhibits, courts generally require pre-marking. That means physically attaching a numbered or lettered label (a sticker or tab) to each item so that when counsel says “I’d like to offer Plaintiff’s Exhibit 12,” everyone can find it. The label numbers must match your exhibit list exactly.
Organize physical binders in sequential order with tabbed dividers between exhibits, and put a descriptive index at the front that mirrors your filed list. Most judges want at least two sets of binders delivered to chambers before trial, usually the week before. You’ll also need a set for your own counsel table and one for opposing counsel as a courtesy, since they need to follow along during testimony.
Joint Exhibit Lists and Stipulations
In many cases, the court’s pretrial order requires both sides to file a single joint exhibit list instead of separate lists. A joint list consolidates all exhibits into one document and forces the parties to confer about which items will be admitted by agreement and which will be contested. Exhibits admitted by stipulation don’t require foundation testimony at trial, which saves hours of courtroom time.
A joint list typically adds a status column for each exhibit: “Admitted by Stipulation,” “Objection,” or “Marked for Identification Only.” Working through this exercise before trial narrows the genuine disputes and gives the judge a realistic count of the evidentiary rulings ahead.