You are about to lodge an application, a response, or any set of documents with a court or tribunal.
One folder that can be filed, served and found again without anyone having to work out what goes with what.
A senior NSW civil litigation solicitor.
The central rule
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:
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.
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
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/