# How to combine PDFs for a court filing

Checked against three federal court websites, PACER, the San Francisco Superior Court and the California Rules of Court on November 12, 2026. Updated 2026-11-12. Source page: https://fairfillpdf.com/guides/how-to-combine-pdfs-for-court-filing/

Whether to combine PDFs for a court filing depends on the court’s rules. The Northern District of California lets exhibits share a PDF with the main document. The Western District of Kentucky requires each exhibit as its own PDF. Where exhibits share one PDF, the San Francisco Superior Court requires slip sheets whose only printed words are “Exhibit A,” “Exhibit B” and so on.

## Combining court exhibits at a glance

| Your court’s rule | What it means | What to do |
| --- | --- | --- |
| Exhibits may share a PDF with the main document | One file for the document and its exhibits, under the size limit | Combine them in order |
| Each exhibit is its own PDF | The main document and every exhibit are separate attachments | Don’t combine them; file each exhibit as its own attachment |
| The combined PDF is over a federal court’s maximum file size | CM/ECF rejects the PDF | See “What if the combined PDF is too large?” below |

## Can you combine exhibits into one PDF?

Combining exhibits into one PDF is allowed at some courts and not at others, so read your court’s e-filing rules first. Guidance posted by four courts, read on November 12, 2026:

| Court | Exhibits in one PDF? |
| --- | --- |
| U.S. District Court, Northern District of California | May share a PDF with the main document, or be filed separately if the file would exceed 50 MB |
| U.S. District Court, Western District of Louisiana (training module, July 1, 2020) | Exhibits under 25 MB in total can be one PDF; over 25 MB, they must be filed individually or in groups |
| Superior Court of California, County of San Francisco | The filer’s choice for a declaration; one document for a proposed order, stipulation and order, judgment or verdict |
| U.S. District Court, Western District of Kentucky | No. Each exhibit must be its own PDF, at most 75 MB |

In one example from the Northern District of California, a 500 KB complaint has 2 MB of exhibits, and the court recommends combining them into one PDF.

## How to combine PDFs here

FairFill PDF combines PDFs in your browser, in the order you set, with slip sheets you type yourself.

1. Open the main document with the button above. Your PDFs are never uploaded.
2. Place the $1.99 hold. Nothing is charged until you download, and the hold is released if you don’t download within 24 hours.
3. Press Add files and pick the exhibit PDFs. You can pick several at once, and they go after the last page.
4. Put the pages in order. In the page side bar, drag a page, or press its up and down arrows.
5. For a slip sheet, press the ⋯ button on the page just before an exhibit and choose Add a blank page after.
6. Choose Text, click the blank page, and type the exhibit’s name, such as Exhibit A. Do the same before each exhibit.
7. Press Download, then the Download button in the window that opens. We charge the $1.99 then, and your browser saves one combined PDF.

You can also open the [merge PDF files](https://fairfillpdf.com/merge-pdf/) tool directly.

## What goes on a slip sheet?

The San Francisco Superior Court requires slip sheets, used as exhibit tabs, wherever exhibits share one document with a declaration or with each other. It describes them as pages where the only words printed are “Exhibit A,” “Exhibit B” and so on. That court doesn’t allow blank pages as slip sheets.

At that court, when you upload a group of exhibits as one document, you must add a caption page with a specific title. The court’s example is “Exhibits A-E to Declaration of Joe Smith in Support of Motion for Summary Judgment.”

## Do court exhibits need bookmarks?

Some courts require bookmarks in electronic exhibits. The Judicial Council of California sets the format of motion papers in California Rule of Court 3.1110. Under that rule, a party other than a self-represented party must include bookmarks to the first page of each exhibit. The filer must also provide an index of exhibits that briefly describes each exhibit and gives its number or letter and page number.

FairFill PDF can’t add bookmarks, and bookmarks in PDFs added with Add files aren’t kept.

## What if the combined PDF is too large?

Each federal court sets its own maximum PDF size in CM/ECF, the federal e-filing system, and the system rejects a larger PDF. FairFill PDF doesn’t show a file’s size and can’t make a PDF smaller, so check the saved file’s size on your device. To file a larger PDF, split it into parts. See [what is the CM/ECF file size limit](https://fairfillpdf.com/guides/cm-ecf-file-size-limit/) for the limits at five courts and the steps.

## Questions about combining PDFs for court

### Can I combine Word files and photos with my PDFs?

Photos can be combined. FairFill PDF opens JPG, PNG and WebP photos, and each photo becomes a page. Word files can’t be opened here, so save a Word file as a PDF first.

### Is there a limit on how many PDFs I can combine?

FairFill PDF has no limit on the number of files, and each PDF can be up to 100 MB.

### Will the filled forms in my exhibits stay fillable?

No. In PDFs added with Add files, filled answers are kept but the form boxes become part of the page. Form boxes in the first PDF you open stay fillable unless you lock them; see [how to flatten a PDF](https://fairfillpdf.com/guides/how-to-flatten-a-pdf/).

### Can I describe each attachment in CM/ECF as just “Exhibit A”?

Not at every court. The Western District of Kentucky says attachments must be described clearly in CM/ECF, and filers may not simply name them Exhibit A or Exhibit B.

### Are my exhibits uploaded when I combine them here?

No. FairFill PDF opens, shows and rebuilds your PDFs inside your browser tab, and they are never sent to our server.

### Can I combine password-protected PDFs?

No. Password-protected or edit-locked PDFs can’t be opened in FairFill PDF. CM/ECF also rejects encrypted or password-protected PDFs, so ask the sender for a copy without the password.

We write general information, not legal advice. For your own situation, ask the agency or a lawyer.

## Sources

1. [Preparing Your CM/ECF Filing, U.S. District Court, Northern District of California](https://www.cand.uscourts.gov/cases-e-filing/cmecf-information/preparing-your-cmecf-filing), read November 12, 2026
2. [E-Filing Special Instructions, Superior Court of California, County of San Francisco](https://sf.courts.ca.gov/online-services/e-filing/e-filing-special-instructions), read November 12, 2026
3. [Checklist for E-Filings, U.S. District Court, Western District of Kentucky](https://www.kywd.uscourts.gov/sites/kywd/files/court_docs/ECF_Filing_Checklist_2.pdf), read November 12, 2026
4. [Filing Documents with Attachments, U.S. District Court, Western District of Louisiana (July 1, 2020)](https://www.lawd.uscourts.gov/sites/lawd/files/UPLOADS/Filing%20Documents%20with%20Attachments.pdf), read November 12, 2026
5. [Rule 3.1110, General format, California Rules of Court](https://courts.ca.gov/cms/rules/index/three/rule3_1110), read November 12, 2026
6. [PDF-Related Functionality for Public Filers in NextGen CM/ECF Release 1.6, PACER, federal judiciary (June 2021)](https://pacer.uscourts.gov/sites/default/files/files/AC-DC-BC-0160ECF-PDF-Functionality_0.pdf), read November 12, 2026