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---56# Record Designation on Appeal78Drafts a designation identifying all trial court materials to be transmitted to the appellate court, organized for completeness against each appellate issue.910## Prerequisites11121. **Notice of Appeal** — filed and served; appellate case number if assigned132. **Trial court docket** — chronological docket with filing dates and entry numbers143. **Case documents** — pleadings, motions, orders, jury instructions, verdict forms154. **Trial exhibits** — exhibit numbers, descriptions, and admission status165. **Hearing/trial dates** — dates, judges, subject matter, witness lists176. **Appellate issues** — identified errors or rulings being challenged187. **Applicable rules** — jurisdiction-specific deadlines and format requirements198. **Party role** — appellant (initial designation) or appellee (counter-designation)2021## Output Structure2223### 1. Caption2425| 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 |3132### 2. Organization3334Choose based on case complexity:3536- **Chronological** — simple cases; all items by filing/occurrence date37- **Categorical** — complex cases; group by type with chronological sub-ordering3839### 3. Foundational Documents4041- Notice of Appeal42- Final judgment or appealable order43- Post-judgment motions (JNOV, new trial, reconsideration)4445> For each item: exact docket title, filing date, docket entry number.4647### 4. Pleadings4849- Complaint/petition (and amendments)50- Answers, responsive pleadings51- Counterclaims, cross-claims (if relevant to appellate issues)5253### 5. Motions & Briefing5455For each challenged ruling, designate the complete motion package:5657| 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 |6566### 6. Transcripts6768Format each designation:6970```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```7778Identify by: date, proceeding type, judge, subject matter, witnesses, exhibit discussions. Err toward completeness — omitted portions cannot be reviewed on appeal.7980### 7. Exhibits8182Format each entry:8384```85[Party]'s Exhibit [No.]: [Description], dated [Date] — [Admitted/Excluded/Limited Purpose]86```8788- Use trial numbering/lettering system89- Designate specific pages/sections for voluminous exhibits if only portions are relevant, but include full exhibit when context matters9091### 8. Orders & Rulings9293- Interlocutory orders on dispositive motions94- Discovery rulings affecting available evidence95- Evidentiary rulings (in limine, trial objections)96- Directed verdict / JMOL rulings97- Jury instructions — given AND refused98- Special verdict forms99- Post-trial motion orders100101### 9. Counter-Designation Additions (Appellee Only)102103When drafting a counter-designation, also include:104105- Direct examination context for appellant's cross-exam excerpts106- Colloquy showing court's reasoning or party concessions107- Evidence supporting affirmance / substantial evidence for findings108- Record showing opponent's failure to preserve issues109- Statement re cost responsibility for additional materials110111### 10. Closing Components112113| 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 |119120## Guidelines121122- **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 designated124- **Incomplete designation risk** — materials not designated may be permanently excluded from appellate review125- **Partial transcript caution** — if appellant designates less than full transcript, appellee may designate additional portions at appellant's cost126- **Format compliance** — check local rules for required organization, numbering, and filing method127- **When in doubt, include it** — over-designation costs money; under-designation loses issues