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Assembly order Australia 4 min read

The filing pack

An application is rarely one document. It may be a notice, an affidavit, exhibits, proposed orders, sometimes submissions, sometimes a fee form, each with its own rules about form and copies. A filing pack is one folder, numbered in the order it will be read, with a checklist on top.

Use this when

You are about to lodge an application, a response, or any set of documents with a court or tribunal.

Leave with

One folder that can be filed, served and found again without anyone having to work out what goes with what.

Verify with

A senior NSW civil litigation solicitor.

The central rule

Number the documents in the order they will be read, and put the checklist at zero

A reader will usually take the notice first, then the evidence it relies on, then the orders it asks for. So will you, at 9am on the day. Build the folder in that order once, and everyone gets the same pack.

The pack

What a lodgement must contain, in what form, and how it is filed and served are set by your court's rules and the kind of application; check them before using any of this. The example below is one NSW motion, named as files in one folder using the naming system:

261001 - Lee application for production/
  0. READ ME - checklist.txt
  1. Notice of motion (FINAL - rule-checked).pdf
  2. Affidavit of Jordan Lee 30 Sep 2026 (SIGNED).pdf
  2a. Annexure A - Request letter 12 Sep.pdf
  2b. Annexure B - Reply 25 Sep.pdf
  3. Short minutes of order (proposed).pdf
  4. Outline of submissions.pdf
  5. Fee form or exemption.pdf
  Sent/ (the exact PDFs as lodged, plus the registry receipt)
  • Numbers follow the order the documents will be read in, which is a suggested working order, not a registry rule. Annexures sit under the affidavit they belong to, lettered, with the certification and pagination your court requires. In NSW an exhibit is different: it is identified by a certificate, kept and produced separately, and must not be filed with the affidavit (UCPR rule 35.6(5)); so a pack that is being filed uses annexures, and exhibits, if any, are listed in the READ ME as held separately.
  • The status is in the name: FINAL only after it has been checked against the rules; SIGNED only once it has been. The name is a promise about the contents.
  • Sent/ holds the exact files that left, untouched, with the receipt. Versions are history; the record is the file that left.
  • Check the court's rules for form, page limits, copies and how filing works in your list. The pack is a way of organising; the rules decide what goes in it.

The READ ME

A plain text file, ten lines, written before you file and read again the morning of any hearing. It is the only document in the pack addressed to you.

Fictional READ ME
Application for production — filed 1 Oct 2026, listed 22 Oct 9:30am, Registrar's list, Court 4B. WHAT I AM ASKING FOR: orders 1–3 in doc 3. Fallback: order 1 alone. RELIES ON: affidavit paras 4–9; annexures A, B. Exhibits: none (any would be held separately, not filed). FILED: 1 Oct via online registry, receipt in Sent/. SERVED: 1 Oct by email to Grant, who has consented in writing to email service (UCPR r 3.7); copy in Sent/. CHECKED AGAINST: UCPR form and page limits — yes. Practice note for the list — yes. STILL TO DO: confirm courtroom on the daily list the morning of. IF ASKED "have you conferred?": yes, letters 12 Sep and 25 Sep. DO NOT: argue the merits of the termination. This is about documents.

Everything in it is short because the pack behind it holds the detail. The hearing-eve checklist assumes a READ ME exists.

From Jordan's case file

Fictional example: The registry that sent it back
Jordan's first application went in as seven attachments to one email, named by whatever he had called them while drafting. The registry returned it: the affidavit referred to an annexure that was missing, and the proposed orders were a Word file with tracked changes still showing. He rebuilt it as a pack. Numbered, checked, annexures under the affidavit, a READ ME on top listing what each document was and what it relied on. The second lodgement was accepted the same afternoon. The next application took a third of the time, because the folder structure already existed and only the contents changed.

Checklist

  • One folder per lodgement, named by date and purpose
  • Documents numbered in a sensible reading order; annexures lettered under their affidavit; any exhibits held separately as the court requires
  • Status in every filename, and FINAL means rule-checked
  • READ ME at zero: what it asks, what it relies on, filed and served how, what is still to do
  • Court's rules on form, copies, filing method and valid service checked before lodging; filing, acceptance by the registry and service are three different things
  • Exact lodged files and the receipt kept untouched in Sent/