Record Designation on Appeal
Drafts a designation identifying all trial court materials to be transmitted to the appellate court, organized for completeness against each appellate issue.
Prerequisites
- Notice of Appeal — filed and served; appellate case number if assigned
- Trial court docket — chronological docket with filing dates and entry numbers
- Case documents — pleadings, motions, orders, jury instructions, verdict forms
- Trial exhibits — exhibit numbers, descriptions, and admission status
- Hearing/trial dates — dates, judges, subject matter, witness lists
- Appellate issues — identified errors or rulings being challenged
- Applicable rules — jurisdiction-specific deadlines and format requirements
- Party role — appellant (initial designation) or appellee (counter-designation)
Output Structure
1. Caption
| Element |
Requirement |
| Court |
Full appellate court name |
| Case numbers |
Appellate case no. + trial court case no. |
| Parties |
Full names with appellate designations (Appellant/Appellee or Petitioner/Respondent) |
| Title |
"Designation of Record on Appeal" or jurisdiction-specific variant |
2. Organization
Choose based on case complexity:
- Chronological — simple cases; all items by filing/occurrence date
- Categorical — complex cases; group by type with chronological sub-ordering
3. Foundational Documents
- Notice of Appeal
- Final judgment or appealable order
- Post-judgment motions (JNOV, new trial, reconsideration)
For each item: exact docket title, filing date, docket entry number.
4. Pleadings
- Complaint/petition (and amendments)
- Answers, responsive pleadings
- Counterclaims, cross-claims (if relevant to appellate issues)
5. Motions & Briefing
For each challenged ruling, designate the complete motion package:
| Component |
Details |
| Motion |
Title, filing date, docket no. |
| Supporting briefs |
All opposition and reply briefs |
| Declarations/affidavits |
Each declarant identified |
| Documentary evidence |
Attached or filed in support |
| Hearing transcript |
Date and subject |
| Written order |
Granting/denying |
6. Transcripts
Format each designation:
Transcript of [Proceeding Type] held on [Date],
before Judge [Name], regarding [Subject Matter].
[If partial]: Limited to: (1) testimony of [Witness];
(2) sidebar conference at p. [X] regarding Exhibit [Y];
(3) [other specific portions].
Identify by: date, proceeding type, judge, subject matter, witnesses, exhibit discussions. Err toward completeness — omitted portions cannot be reviewed on appeal.
7. Exhibits
Format each entry:
[Party]'s Exhibit [No.]: [Description], dated [Date] — [Admitted/Excluded/Limited Purpose]
- Use trial numbering/lettering system
- Designate specific pages/sections for voluminous exhibits if only portions are relevant, but include full exhibit when context matters
8. Orders & Rulings
- Interlocutory orders on dispositive motions
- Discovery rulings affecting available evidence
- Evidentiary rulings (in limine, trial objections)
- Directed verdict / JMOL rulings
- Jury instructions — given AND refused
- Special verdict forms
- Post-trial motion orders
9. Counter-Designation Additions (Appellee Only)
When drafting a counter-designation, also include:
- Direct examination context for appellant's cross-exam excerpts
- Colloquy showing court's reasoning or party concessions
- Evidence supporting affirmance / substantial evidence for findings
- Record showing opponent's failure to preserve issues
- Statement re cost responsibility for additional materials
10. Closing Components
| Component |
Requirement |
| Cost allocation |
Appellant acknowledges preparation/transmission costs; appellee addresses costs for counter-designated additions |
| Certification |
Accuracy and completeness after reasonable inquiry |
| Certificate of service |
All parties, trial court clerk, court reporters per local rules |
| Signature block |
Counsel name, bar number, firm, address, phone, email |
Guidelines
- Deadlines are often jurisdictional — verify filing window (typically 10–30 days post-notice for appellant; shorter for counter-designation) [VERIFY for jurisdiction]
- Cross-reference against appellate issues — every challenged ruling must have its complete supporting record designated
- Incomplete designation risk — materials not designated may be permanently excluded from appellate review
- Partial transcript caution — if appellant designates less than full transcript, appellee may designate additional portions at appellant's cost
- Format compliance — check local rules for required organization, numbering, and filing method
- When in doubt, include it — over-designation costs money; under-designation loses issues
1---2name: record-designation3description: Drafts a Record Designation on Appeal identifying trial court materials for transmission to the appellate court. Covers appellant designations and appellee counter-designations with transcript requests, exhibit lists, cost allocation, and compliance guidance. Use when filing a designation of record, counter-designation, transcript designation, or preparing the appellate record after a notice of appeal.4---5
6# Record Designation on Appeal
7
8Drafts a designation identifying all trial court materials to be transmitted to the appellate court, organized for completeness against each appellate issue.
9
10## Prerequisites
11
121. **Notice of Appeal** — filed and served; appellate case number if assigned
132. **Trial court docket** — chronological docket with filing dates and entry numbers
143. **Case documents** — pleadings, motions, orders, jury instructions, verdict forms
154. **Trial exhibits** — exhibit numbers, descriptions, and admission status
165. **Hearing/trial dates** — dates, judges, subject matter, witness lists
176. **Appellate issues** — identified errors or rulings being challenged
187. **Applicable rules** — jurisdiction-specific deadlines and format requirements
198. **Party role** — appellant (initial designation) or appellee (counter-designation)
20
21## Output Structure
22
23### 1. Caption
24
25| Element | Requirement |
26|---|---|
27| Court | Full appellate court name |
28| Case numbers | Appellate case no. + trial court case no. |
29| Parties | Full names with appellate designations (Appellant/Appellee or Petitioner/Respondent) |
30| Title | "Designation of Record on Appeal" or jurisdiction-specific variant |
31
32### 2. Organization
33
34Choose based on case complexity:
35
36- **Chronological** — simple cases; all items by filing/occurrence date
37- **Categorical** — complex cases; group by type with chronological sub-ordering
38
39### 3. Foundational Documents
40
41- Notice of Appeal
42- Final judgment or appealable order
43- Post-judgment motions (JNOV, new trial, reconsideration)
44
45> For each item: exact docket title, filing date, docket entry number.
46
47### 4. Pleadings
48
49- Complaint/petition (and amendments)
50- Answers, responsive pleadings
51- Counterclaims, cross-claims (if relevant to appellate issues)
52
53### 5. Motions & Briefing
54
55For each challenged ruling, designate the complete motion package:
56
57| Component | Details |
58|---|---|
59| Motion | Title, filing date, docket no. |
60| Supporting briefs | All opposition and reply briefs |
61| Declarations/affidavits | Each declarant identified |
62| Documentary evidence | Attached or filed in support |
63| Hearing transcript | Date and subject |
64| Written order | Granting/denying |
65
66### 6. Transcripts
67
68Format each designation:
69
70```
71Transcript of [Proceeding Type] held on [Date],
72before Judge [Name], regarding [Subject Matter].
73[If partial]: Limited to: (1) testimony of [Witness];
74(2) sidebar conference at p. [X] regarding Exhibit [Y];
75(3) [other specific portions].
76```
77
78Identify by: date, proceeding type, judge, subject matter, witnesses, exhibit discussions. Err toward completeness — omitted portions cannot be reviewed on appeal.
79
80### 7. Exhibits
81
82Format each entry:
83
84```
85[Party]'s Exhibit [No.]: [Description], dated [Date] — [Admitted/Excluded/Limited Purpose]
86```
87
88- Use trial numbering/lettering system
89- Designate specific pages/sections for voluminous exhibits if only portions are relevant, but include full exhibit when context matters
90
91### 8. Orders & Rulings
92
93- Interlocutory orders on dispositive motions
94- Discovery rulings affecting available evidence
95- Evidentiary rulings (in limine, trial objections)
96- Directed verdict / JMOL rulings
97- Jury instructions — given AND refused
98- Special verdict forms
99- Post-trial motion orders
100
101### 9. Counter-Designation Additions (Appellee Only)
102
103When drafting a counter-designation, also include:
104
105- Direct examination context for appellant's cross-exam excerpts
106- Colloquy showing court's reasoning or party concessions
107- Evidence supporting affirmance / substantial evidence for findings
108- Record showing opponent's failure to preserve issues
109- Statement re cost responsibility for additional materials
110
111### 10. Closing Components
112
113| Component | Requirement |
114|---|---|
115| Cost allocation | Appellant acknowledges preparation/transmission costs; appellee addresses costs for counter-designated additions |
116| Certification | Accuracy and completeness after reasonable inquiry |
117| Certificate of service | All parties, trial court clerk, court reporters per local rules |
118| Signature block | Counsel name, bar number, firm, address, phone, email |
119
120## Guidelines
121
122- **Deadlines are often jurisdictional** — verify filing window (typically 10–30 days post-notice for appellant; shorter for counter-designation) [VERIFY for jurisdiction]
123- **Cross-reference against appellate issues** — every challenged ruling must have its complete supporting record designated
124- **Incomplete designation risk** — materials not designated may be permanently excluded from appellate review
125- **Partial transcript caution** — if appellant designates less than full transcript, appellee may designate additional portions at appellant's cost
126- **Format compliance** — check local rules for required organization, numbering, and filing method
127- **When in doubt, include it** — over-designation costs money; under-designation loses issues