Let’s settle this: if you are citing to a court filing where the ECF page number does not correspond to the page number in the brief due to a TOC/TOA, how do you cite to that?

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When I clerked I preferred ECF page pincites. Quicker for the clerk to find the page.



The judge (their clerks) will cite to the ECF page numbers, and they will very much appreciate that you do the same. Also, credit to the above commenter who said you should try to make sure the ECF page lines up with the document page.

Moral of the story: always try to make it easier on the clerks. Especially here, where a little effort goes a long way.


I use the ECF page number. But some courts are solving this with local rules that require all pages to be numbered consecutively.


It’s been a long time since I’ve had to do this, but I think I did both if they were different. Br. at 4, ECF No. 12 at 7, etc.

Unless I needed to squeeze every drop of space out for a word/page limit, of course.



ECF. Also, if the local rules don’t specify a citation format, I’ll drop a footnote explaining that citations correspond to ECF pagination.

That is a very good approach, thank you!

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