The Appellate Division, First Department will not, in fact, accept photographs in an Appellate Brief. One may certainly reference a photograph that is included in the Record on Appeal/Appendix that was filed with the brief. However, including a photograph as an embedded image within the brief will result in its categorical rejection by the Court. If one does not wish to picture an angry client blasting his/her attorney as to why a brief was rejected, then keep photos out of your briefs.
Wednesday Wisdom
