# California Court PDF Requirements for Scanned Exhibits

- Author: Schema Law (https://www.schemalaw.com/)
- Published: 2026-09-23T18:00:58Z
- Updated: 2026-10-11T19:22:20Z
- Category: Litigation support
- Canonical: https://www.schemalaw.com/blog/california-court-pdf-requirements

> California court PDF requirements for e-filed scanned exhibits: what rules 2.256, 3.1110 and 8.74 say about searchable text, bookmarks and file size.

California court PDF requirements come from three statewide rules plus your county's own. Rule 2.256(b) asks for a searchable document in the trial courts where that is feasible, rule 3.1110(f)(4) requires bookmarked electronic exhibits on motions, and rule 8.74 sets stricter PDF terms in the reviewing courts. A scanned exhibit has to satisfy whichever of them applies.

This post reads each rule in its own words and then turns them into a checklist for a scanned exhibit set. It explains how to prepare documents and is not legal advice. The rule text quoted here was read on the Judicial Branch website when this was written. Rules are amended, so open the linked rule before you rely on a quotation.

## Which California rules set PDF requirements for e-filed documents?

Three California Rules of Court carry the PDF requirements for e-filed documents. Rule 2.256(b) governs the format of documents filed electronically in the trial courts. Rule 3.1110(f) governs exhibits to motion papers. Rule 8.74 governs electronic documents in the Courts of Appeal and the Supreme Court. Local rules and court orders add county detail.

| Rule | Where it applies | What it covers for a PDF |
| --- | --- | --- |
| [Rule 2.253](https://courts.ca.gov/cms/rules/index/two/rule2_253) | Trial courts | Lets a court permit or require electronic filing by local rule |
| [Rule 2.256(b)](https://courts.ca.gov/cms/rules/index/two/rule2_256) | Trial courts | Format chosen by the court, printing without loss, text search when feasible |
| [Rule 3.1110(f)](https://courts.ca.gov/cms/rules/index/three/rule3_1110) | Motion papers in civil cases | Exhibit index, one exhibit per deposition, bookmarks on electronic exhibits |
| [Rule 8.74](https://courts.ca.gov/cms/rules/index/eight/rule8_74) | Reviewing courts | Searchable PDF, page numbering, bookmarks, file size, fonts for new documents |
| [Rule 8.124(d)](https://courts.ca.gov/cms/rules/index/eight/rule8_124) and [rule 8.144](https://courts.ca.gov/cms/rules/index/eight/rule8_144) | Appendixes and transcripts on appeal | Indexes, consecutive page numbers, volumes |

One detail in that table is easy to miss. The trial court rule never uses the word PDF. Rule 2.256(b) says a document "must be in a format specified by the court unless it cannot be created in that format." The court you file in names the format, and the statewide rule limits what the court may choose. Rule 8.74 is different. It names the portable document format directly.

The rules also rank themselves. Rule 2.256(b) ends by saying that when an electronically filed document cannot be formatted consistently with a formatting rule elsewhere in the California Rules of Court, "the rules in this chapter prevail." Rule 8.74(d) is shorter: "This rule prevails over other formatting rules." If two instructions seem to pull against each other, those sentences tell you which one wins inside each court level.

## Text-searchable filings under California Rule of Court 2.256

Rule 2.256(b)(3) says an electronically filed document "must be text searchable when technologically feasible without impairment of the document's image." For a scanned exhibit, that means running ordinary OCR and keeping the page image as it was. The requirement is one of three conditions the rule places on whatever format a trial court specifies.

### The three conditions in subdivision (b)

Rule 2.256(b) says the format a court adopts must meet these requirements:

1. "The software for creating and reading documents must be in the public domain or generally available at a reasonable cost."
2. "The printing of documents must not result in the loss of document text, format, or appearance."
3. "The document must be text searchable when technologically feasible without impairment of the document's image."

Each one has a consequence for a scanned exhibit.

- **Condition 1** means the format a court picks cannot depend on software that is costly or hard to obtain. For your part, do not file something that only a specialized viewer can open.
- **Condition 2** is a print test. Print one page of the final file. If a stamp, a margin note or the text itself is missing from the paper, fix the file before you submit it, however it looks on screen.
- **Condition 3** carries two limits inside it. "Technologically feasible" caps the effort, and "without impairment of the document's image" protects the picture of the page.

### How much effort does "technologically feasible" mean?

The Advisory Committee Comment to subdivision (b)(3) answers this directly. The term "does not require more than the application of standard, commercially available optical character recognition (OCR) software." The rule asks you to run OCR. It does not ask you to retype a page that OCR reads badly. What courts mean by the phrase more generally is covered in the section on [what a court means by text-searchable](https://www.schemalaw.com/blog/searchable-pdf-for-court-filing#what-does-a-court-mean-by-text-searchable).

### What "without impairment of the document's image" rules out

The image clause matters for exhibits more than for anything you drafted. An exhibit is evidence of what a document looks like. A conversion that replaces the scanned page with freshly typeset words changes the image. A searchable PDF that leaves the scan untouched and adds text behind it does not.

A short worked example. Okafor Holdings is moving for summary judgment in a superior court, and Exhibit C is a 14-page lease that exists only on paper, with initials in the margin of each page.

1. Scan the lease to PDF.
2. Run OCR so that a text layer sits behind each page image.
3. Open the result and confirm the initials, the signature block and every page look the same as the scan.
4. Search for a word on page 1 and a word on page 14.
5. Print page 14 and compare it with the paper.

If step 3 or step 5 shows a change, use a different OCR setting or tool. The feasibility clause covers a page that will not yield text. It does not excuse a page whose image you altered.

Keep the exhibit image when you file in a California trial court. The state court electronic filing page names the PDF form for the clerk of court. A motion that cites the exhibit should point at the scanned page, so leave that image in place and put the text behind it. After you save, search for a word you can see on the exhibit.

### Duties in subdivision (a) that touch the file

Rule 2.256(a) lists what each electronic filer must do. Two items concern the file itself. Under (a)(1) the filer must "Comply with any court requirements designed to ensure the integrity of electronic filing and to protect sensitive personal information." Under (a)(3) the filer must take "all reasonable steps to ensure that the filing does not contain computer code, including viruses, that might be harmful to the court's electronic filing system and to other users of that system." Read your court's e-filing page for how it applies those duties to PDFs.

## Electronic bookmarks for exhibits under California Rule 3.1110

Rule 3.1110(f)(4) says that, unless a self-represented party submits them, "electronic exhibits must include electronic bookmarks with links to the first page of each exhibit and with bookmark titles that identify the exhibit number or letter and briefly describe the exhibit." The same paragraph says electronic exhibits "must meet the requirements in rule 2.256(b)."

Rule 3.1110 is titled "General format" and opens with what a notice of motion must state. Check whether the paper you are filing falls under it, and whether another rule or a local rule sets exhibit requirements for your kind of filing.

### What the bookmark sentence requires, piece by piece

| Phrase in rule 3.1110(f)(4) | What to check in your file |
| --- | --- |
| "links to the first page of each exhibit" | Click each bookmark. It should land on page one of that exhibit, not on a slip sheet in front of it or on the declaration that introduces it |
| "identify the exhibit number or letter" | The bookmark title starts with the same designation the index and the declaration use |
| "briefly describe the exhibit" | A few words after the designation say what the document is |
| "Unless they are submitted by a self-represented party" | The exception belongs to self-represented parties. Read the rule for whether it reaches your filing |

For the lease in the Okafor example, a bookmark titled "Exhibit C, Lease dated March 3, 2021" meets each phrase. How to word labels across a whole set, and which other courts have bookmark rules, belongs to the guide on [how to bookmark a PDF for court filing](https://www.schemalaw.com/blog/how-to-bookmark-a-pdf-for-court-filing). The steps for creating them are in its section on [adding bookmarks to a compiled exhibit PDF](https://www.schemalaw.com/blog/how-to-bookmark-a-pdf-for-court-filing#adding-bookmarks-to-a-compiled-exhibit-pdf-one-exhibit-at-a-time).

### The rest of subdivision (f)

Bookmarks are the fourth of four exhibit requirements in rule 3.1110(f). The other three shape the same PDF.

- **(f)(1):** "An index of exhibits must be provided. The index must briefly describe the exhibit and identify the exhibit number or letter and page number." Your bookmark titles and your index describe the same things, so write the index first and copy its wording into the bookmarks.
- **(f)(2):** "Pages from a single deposition must be designated as a single exhibit." Excerpts from one deposition go under one designation and one bookmark, even when the pages are not consecutive.
- **(f)(3)** covers tabs on paper exhibits and does not affect the electronic file.

Rule 3.1110(c) adds: "Documents must be consecutively paginated. The page numbering must begin with the first page and use only Arabic numerals (e.g., 1, 2, 3)." Open the rule for the exact scope of that sentence before you number a combined exhibit file.

### Does the rule expect paid software?

The Advisory Committee Comment to subdivision (f)(4) says: "Under current technology, software programs that allow users to apply electronic bookmarks to electronic documents are available for free." The comment does not name a program. Schema Law does not add bookmarks. It reads the scanned pages into text. Bookmarking is a step you do afterwards in your PDF software, on the assembled file.

## How do California appellate PDF requirements differ under Rule 8.74?

Rule 8.74 asks for more than the trial court rules do. It names PDF as the format, requires the PDF page counter to match the printed page number, requires bookmarks on every heading and component of every document, and caps a filing at 100 megabytes. The rule shows an amendment effective July 1, 2026, so read the current text.

| Subject | Trial courts | Reviewing courts under rule 8.74 |
| --- | --- | --- |
| Format | "a format specified by the court" (rule 2.256(b)) | "text-searchable portable document format (PDF) while maintaining the original document formatting" ((a)(1)) |
| Scanned paper | Searchable "when technologically feasible" | May be non-searchable only "In the limited circumstances in which a document cannot practicably be converted to a text-searchable PDF" ((a)(1)) |
| Page numbers | Consecutive Arabic numerals on motion papers (rule 3.1110(c)) | "The electronic page counter for the electronic document must match the page number for each page of the document" ((a)(2)) |
| Bookmarks | First page of each electronic exhibit (rule 3.1110(f)(4)) | "each heading, subheading, and the first page of any component of the document" ((a)(3)) |
| Size | Set by the court or its filing system | "An electronic filing may not be larger than 100 megabytes" ((a)(5)) |
| Typeface | Not set by these rules | 13-point proportionally spaced serif for documents prepared for the reviewing court ((b)(1)) |

### Scans in a reviewing court

The Advisory Committee Comment to subdivision (a)(1) speaks to paper originals. If you hold a document only in paper form, "use of a scanned image is a permitted means of conversion to PDF, but optical character recognition must be used, if possible." The comment then lists what may stay non-searchable: a document that is "entirely or substantially handwritten, a photograph, or a graphic such as a chart or diagram that is not primarily text based."

That is narrower than the trial court wording. Keep a note of why any page in an appellate filing has no text, in case the clerk asks.

### Page counter and bookmarks

Under (a)(2), numbering "must begin with the first page or cover page as page 1" and continue with Arabic numerals only. A filing with a cover, tables in Roman numerals and a body starting at 1 will not match the PDF counter. Renumber it so that the number printed on a page is the number the reader types to reach it.

Under (a)(3), a bookmark to an exhibit or attachment "must include the letter or number of the exhibit or attachment and a brief description." The paragraph adds a setting to check in your software: "All bookmarks must be set to retain the reader's selected zoom setting." The comment gives a model label, "Exhibit A, First Amended Complaint filed 8/12/17."

### Size, multiple files and exhibits

When a document is over 100 megabytes, (a)(5) says the filer "must submit the document in more than one file, with each file 100 megabytes or less." The first file carries a master index, each file gets a cover page stating its file number, volumes and page range, and page numbers run on across the files. Paragraph (a)(6) sends a document of more than 10 files to manual filing on electronic media. Read (a)(5) and (a)(6) in full before you split anything.

Exhibits have their own line in (c)(6): "Electronic exhibits must be submitted in files no larger than 25 megabytes, rather than as individual documents." Ways to bring a scanned file under a cap are in the guide to [reducing PDF size for court filing](https://www.schemalaw.com/blog/reduce-pdf-size-for-court-filing).

### What subdivision (b) leaves alone

The font, spacing and margin terms in subdivision (b) apply to documents prepared for the reviewing court. The comment says subdivision (b) "does not apply to previously created documents (such as exhibits), whose formatting cannot or should not be altered." A scanned trial exhibit keeps its own look.

Under (c)(3), an appendix must comply with rule 8.74 and with rule 8.144. Putting one together is the subject of the guide to building an [appellate appendix PDF](https://www.schemalaw.com/blog/appellate-appendix-pdf).

## What do California superior courts add through local rules?

Superior courts add the practical detail: which case types must be e-filed, which filing service providers to use, size limits, and sometimes bookmark duties wider than the statewide rule. Rule 2.253(b) says a court "may require parties by local rule to electronically file documents in civil actions." Read your county's local rules, orders and e-filing page.

Two courts' own pages show the kind of thing a county adds. They are examples, not a survey, and each can change.

**Ventura.** The Ventura Superior Court's [Amended Administrative Order No. 25.03 on mandatory electronic filing](https://ventura.courts.ca.gov/system/files/general/amended-2503-mandatory-efiling.pdf) has a technical requirements section. It says "Electronic documents must be eFiled in PDF, in text searchable format" and "Any table of contents within any document must be bookmarked." It lists attachments that must be bookmarked, among them points and authorities, declarations, depositions, exhibits, transcripts and proofs of service. It also says each document filed concurrently with another "must be electronically filed as a separate digital PDF document." That list reaches further than the first page of each exhibit.

**San Bernardino.** The San Bernardino Superior Court's [probate eFiling requirements](https://sanbernardino.courts.ca.gov/online-services/efiling/probate-efiling/probate-efiling-requirements) state file sizes: "No single document can be larger than 25 MB and no group of documents can be larger than 50 MB on a single eFile submission." The page says the court cannot accept "forms with fillable fields, a negative image, or an image that is saved as an object on the filed document," and that documents failing the requirements "will be rejected." It restates rule 3.1110(f)(4) for exhibits and encourages bookmarks on headings and components as well.

### Where to look in your own county

| Question | Where a superior court answers it |
| --- | --- |
| Is e-filing mandatory for my case type? | Local rules and any general or administrative order on e-filing |
| What file size will the system take? | The court's e-filing page, or your filing service provider's help pages |
| Are bookmarks required beyond exhibits? | Local rules and the e-filing order's technical section |
| Are fillable forms or color scans restricted? | The e-filing requirements page |
| Does my department want courtesy copies? | The department's or judge's own page |

Search your court's site for the words "electronic filing" together with "bookmark" and "searchable". If the local material and the statewide rule seem to differ, ask the clerk's office which one the court applies.

## A California filing checklist for a scanned exhibit set

Work through a scanned exhibit set in four passes: confirm which rules apply, make every scanned page searchable without changing its image, build the index and bookmarks, then test the final file. The checklist assumes a motion in a superior court, with a note where a reviewing court differs.

**Before you scan**

- Open rule 2.256, rule 3.1110 and your county's e-filing order, and note the date you read them.
- Write down your court's size limit per document and per submission.
- List the exhibits with their letters or numbers and a short description of each. This becomes the index that rule 3.1110(f)(1) requires.
- Group all pages from one deposition under one designation.
- Convert anything you hold as an electronic file directly to PDF. Scan only what exists on paper.

**Making the scans searchable**

- Scan in black and white unless color carries meaning or your court says otherwise.
- Run OCR on each scanned exhibit and keep the page image unchanged. Schema Law does this from an upload in the browser and exports a searchable PDF. Uploads are capped at 20 MB, so a large exhibit may need splitting first. The [pricing page](https://www.schemalaw.com/pricing) lists page limits per plan.
- Compare the first and last page of each result with the scan.
- Note any page that stays unsearchable and why, such as handwriting or a photograph.

**Assembling the file**

- Put the index in front and check its page numbers against the assembled file.
- Add a bookmark to the first page of each exhibit, titled with the designation and a brief description that matches the index.
- Add any further bookmarks your county requires, such as the table of contents or each declaration.
- Number the pages consecutively in Arabic numerals.
- Remove fillable fields if your court refuses them.

**Testing before you submit**

- Click every bookmark and confirm where it lands.
- Search one word from the first and last page of every exhibit.
- Print one page with a stamp or handwriting and compare it with the original.
- Check the size against the limit.
- Search the final file for anything that should have been redacted, and read your court's rules on protecting personal information.

**If the filing is going to a reviewing court instead**

- Make the PDF page counter match the printed page numbers, starting at 1 on the cover.
- Bookmark every heading, subheading and component, and set bookmarks to keep the reader's zoom.
- Keep exhibit files at 25 megabytes or less and the filing at 100 megabytes or less.
- Use OCR on scanned paper wherever possible, and record the reason for any page left without text.

Recognition is strongest on clean print and weaker on handwriting, and no OCR result should be trusted unread. If an exhibit is confidential, look at the [security commitments on the Schema Law homepage](https://www.schemalaw.com/#security) before you upload it, and delete the document from the tool once the filing is accepted.

## Try it on a real document

Upload a scanned PDF and export it as Word, a searchable PDF or plain text on the free plan. Your documents are never used to train an AI model. [Start free](https://www.schemalaw.com/api/auth/google)