Courts reject filings for over-merging and under-merging — sometimes in the same standards table. Illinois' rejection standards, effective September 1, 2024, contain both directions as numbered grounds:
That's the entire judgment call, and Illinois' own guidance supplies the test: a motion and its notice of motion are two documents (each its own PDF, each uploaded as a Lead document); exhibits attach to the document they evidence; a single order with all its pages is one. When in doubt, count documents as the hard copy would be counted — the standards derive from paper filing conventions. Michigan's self-help guidance states the same rule with its own exception (summary-proceedings complaints and attachments combine into one file).
| Court | Rule |
|---|---|
| Illinois (Courts of Review) | #17: never multiple filings in one PDF · #18: never one filing in multiple PDFs (size-limit exception only) · each e-filed document = separate PDF per AOIC guidance |
| NY Appellate Division 1st Dept | Each volume of a multi-volume record/appendix = separate PDF, "shall not be combined into one PDF"; appendix + brief not combined unless combined in the hard copy |
| Ninth Circuit | The opposite pull: brief + required certificates + appendix = one document; each Excerpts of Record volume = one document, ≤ 300 pages; multi-volume sets numbered consecutively |
The pattern: documents are the unit — one PDF per document, volumes are the sanctioned way to split a document that is too big, and nothing bigger than a document gets merged.
Merging is an edit, and edits have casualties. After any combine:
Primary sources only — the statute, form or paper this page is built on.