Is an electronic statement admissible?

Yes. Electronic signatures and records are generally admissible under the federal ESIGN Act (15 U.S.C. §7001) and New York’s technology-neutral statute, provided intent, consent, attribution, and reliable retention are demonstrable.

Does the statement require notarization?

Not always. Notarization is required when a court or statute specifically demands a sworn or acknowledged instrument; verify local rules and the document’s intended use before notarizing.

What format should exhibits use?

Submit exhibits as searchable PDFs where possible; mark each exhibit clearly (Ex. 1, Ex. 2) and include those identifiers in the statement to avoid confusion during review.

How precise must evidence references be?

Very precise. Cite page numbers, deposition lines, exhibit IDs, or document metadata to enable quick verification and reduce disputes about what evidence supports each position.

Can parties exchange statements by email?

Yes if permitted by local rules, but ensure delivery receipts and signed copies are preserved; consider authenticated eSignature methods to strengthen attribution.

What if the tribunal requires a different format?

Follow the tribunal’s procedural order. If the court prescribes a template or field set, adapt your statement to that format while preserving the same issue-by-issue clarity.

Electronic Signature
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New York Statement on Specific Issues in Dispute

New York Statement on Specific Issues in Dispute

This template is fully customizable. Edit the text, fill out the fields, and send it for signature. Give it a try!

What the New York Statement on Specific Issues in Dispute Is

The New York Statement on Specific Issues in Dispute is a focused written declaration used to identify and clarify discrete points of disagreement between parties, typically in litigation, arbitration, administrative proceedings, or settlement negotiations. It summarizes contested facts or legal issues, assigns party positions, and may include citations to the controlling contract provisions, statutes, or evidence. The statement is used to narrow the disputed topics for the court, tribunal, or opposing counsel and to streamline issue-focused discovery or motion practice.

Why a Clear Statement Matters for Case Management

A concise, well-structured statement reduces ambiguity, focuses discovery, and helps adjudicators understand the exact disputes. It saves time in hearings and can limit the scope of contested evidence.

Who Typically Prepares and Reviews This Statement

The document is also useful to settlement negotiators and neutral evaluators who require a compact map of the dispute for resolution planning.

Plaintiff / Claimant counsel preparing a list of disputed contract terms and evidence deadlines.
Defense counsel isolating legal defenses and factual disagreements for targeted motions or discovery.
Administrative law judges or hearing officers using the statement to set an issues list for prehearing orders.

Essential Components of an Effective Statement

A professional statement organizes disputes into numbered items, identifies the asserting party, cites the controlling provision or evidence, and states the requested relief or outcome. Clarity and neutrality matter.

Issue Heading

A concise label for each disputed topic, enabling quick reference during conferences or motions.

Party Position

Which party asserts or contests the issue, stated without argumentative language for clarity.

Factual Basis

Short summary of the facts each party relies on, linked to exhibits or discovery references.

Legal Basis

Citation to the relevant contract clause, statute, rule, or authority supporting each position.

Relief Sought

Specify the remedy or desired ruling tied to the particular issue if appropriate and permitted.

Status / Notes

Current procedural posture for the issue, including discovery outstanding or proposed deadlines.

Step-by-Step: Completing the Statement

Follow these sequential steps to prepare a focused, procedurally compliant statement usable in New York tribunals or administrative hearings.

01

1. Gather Documents: Collect contracts, pleadings, and key exhibits before drafting.
02

2. Identify Issues: List discrete factual or legal points in plain terms.
03

3. Assign Positions: Note which party disputes each issue and why.
04

4. Cross-Reference: Include exhibit numbers, deposition citations, or discovery responses.

How the Statement Is Used in Proceedings

The statement guides case management conferences, evidence rulings, and settlement talks by narrowing contested topics and documenting each party’s position.

Pre-Conference Use: Court or tribunal uses it to set an issues agenda.
Discovery Focus: Limits discovery to relevant contested issues, reducing scope disputes.
Motion Preparation: Supports targeted dispositive or evidentiary motions on specific items.
Settlement Talks: Facilitates issue-by-issue negotiation and mediation discussions.

Setting Up a Digital Workflow for This Document

A consistent online workflow reduces version errors and ensures each party receives a timestamped copy with an audit trail.

Template	Create a reusable statement template with fixed fields for issue, party, and evidence.
Field Mapping	Map fields to case management IDs and exhibit numbers for cross-reference.
Signer Authentication	Require authenticated signer email or stronger ID where required by rules.
Notifications	Set automated delivery to opposing counsel and the court, if permitted.
Archive	Store final signed PDF in the case file with a searchable audit trail.

Technical Considerations for eFiling and eSigning

Maintain a secure copy with the audit trail and supporting exhibits to meet court retention or discovery obligations.

File Formats: PDF or DOCX are widely accepted for filings and retain formatting.
Authentication: Email or SMS OTP is common; stronger ID may be required.
Audit Trail: Preserve timestamps, IP addresses, and signer events.

Timelines and Typical Deadlines to Watch

Check local rules and any case management orders for exact dates; common deadlines are listed below to guide scheduling.

Pre-Conference Filing:

Often 7–14 days before a case management conference.

Discovery Cutoff:

Set by scheduling order; usually months before trial.

Motion Deadlines:

Deadlines vary; obey local rules for filing and service.

Settlement Exchange:

Parties may set parallel deadlines for statement exchanges.

Record Retention:

Keep signed statements until final judgment and applicable retention period.

Key Milestones in Preparing and Exchanging the Statement

A standard sequence helps coordinate drafting, review, exchange, and submission to the tribunal.

01

Drafting

Prepare the initial draft and attach key exhibits for review.

02

Internal Review

Counsel review and revise positions, focusing on concise citations.

03

Exchange

Serve the statement on opposing counsel according to procedural rules.

04

Submit to Tribunal

File or present the final version at the scheduled conference.

Common Preparation Pitfalls to Avoid

Overly argumentative language that reads like brief writing rather than a neutral issue statement can antagonize the court and opponents.
Vague references such as 'see file' without exhibit numbers or deposition citations slow verification and invite disputes.
Failing to coordinate versions among co-counsel leads to inconsistent positions and may require corrective filings.
Neglecting to list whether an issue is agreed or contested creates unnecessary procedural disputes about scope and discovery.

Consequences of an Incorrect or Incomplete Statement

Procedural Delay: May result in adjournment or additional briefing

Credibility Harm: Inconsistent facts can harm the asserting party’s credibility

Discovery Overbreadth: Poorly framed issues can trigger costly, broad discovery

Sanctions Risk: Court may impose sanctions for misleading statements

Evidentiary Exclusion: Missing exhibit references can lead to evidence being excluded

Tax / Reporting Exposure: Incorrect party IDs can have downstream reporting effects

Security and Compliance Elements to Preserve Integrity

Encryption in Transit: TLS 1.2/1.3

Encryption at Rest: AES-256

Audit Trail: Timestamp and event history

Regulatory Compliance: ESIGN and UETA alignment

Healthcare: HIPAA (BAA required)

FDA Records: 21 CFR Part 11 support

eSignature Pricing and Feature Snapshot

Comparison of common eSignature vendors and core plan features. Confirm vendor pages for plan details and enterprise pricing before purchase decisions.

	signNow	DocuSign	Adobe Sign	PandaDoc	HelloSign
Starting Price	$8/user/mo	$15/user/mo	$14/user/mo	$19/user/mo	$15/user/mo
Free Trial	7-day trial, no card	Varies by vendor	Varies by vendor	Varies by vendor	Varies by vendor
Bulk Send	Yes	Yes	Yes	Yes	No
Audit Trail	Yes	Yes	Yes	Yes	Yes
HIPAA Compliant	Yes	Yes	Yes	No	No
Envelope Cap	No envelope cap	100 envelopes/user/year	Varies by plan	Varies by plan	Varies by plan

Frequently Asked Questions About Preparing and Using the Statement

Answers to common questions about formality, admissibility, electronic signing, and procedural use in New York disputes.

Need help? Contact support

Is an electronic statement admissible?
Yes. Electronic signatures and records are generally admissible under the federal ESIGN Act (15 U.S.C. §7001) and New York’s technology-neutral statute, provided intent, consent, attribution, and reliable retention are demonstrable.
Does the statement require notarization?
Not always. Notarization is required when a court or statute specifically demands a sworn or acknowledged instrument; verify local rules and the document’s intended use before notarizing.
What format should exhibits use?
Submit exhibits as searchable PDFs where possible; mark each exhibit clearly (Ex. 1, Ex. 2) and include those identifiers in the statement to avoid confusion during review.
How precise must evidence references be?
Very precise. Cite page numbers, deposition lines, exhibit IDs, or document metadata to enable quick verification and reduce disputes about what evidence supports each position.
Can parties exchange statements by email?
Yes if permitted by local rules, but ensure delivery receipts and signed copies are preserved; consider authenticated eSignature methods to strengthen attribution.
What if the tribunal requires a different format?
Follow the tribunal’s procedural order. If the court prescribes a template or field set, adapt your statement to that format while preserving the same issue-by-issue clarity.

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