Bates numbering and how to label court exhibits

Bates numbers make pages easy to identify

A Bates number is a unique page identifier applied across a document set. A practical format combines a neutral prefix, hyphen, and fixed-width sequence: SMITH-000001, SMITH-000002, and so on. Fixed width keeps filenames and references sorted correctly.

The name comes from nineteenth-century Bates numbering machines used to apply consecutive numbers to documents. The useful modern point is simpler: every reviewer can refer to the same page without relying on a changing PDF page count or vague description.

That origin is widely repeated, but it is not needed to use the system correctly. This guide does not rely on a particular inventor date or patent history. Modern “Bates” numbering usually means sequential production identifiers whether applied by software, a court platform, or a physical stamp.

Bates numbering is an index, not proof. It does not show who wrote a message, whether a document is complete, or whether its contents are true. It can support orderly production and make gaps or duplicates easier to spot.

Numbering is sometimes required and often conventional

There is no single US rule requiring every exhibit in every court to use Bates numbers. Discovery protocols, scheduling orders, local rules, agency instructions, and agreements may require a particular format. Read all applicable directions before choosing one.

A common US trial convention uses numbers for plaintiff exhibits and letters for defendant exhibits. State that only as a convention. Some courts number all exhibits, reserve ranges for each party, assign identifiers through an electronic evidence system, or have the clerk mark exhibits at trial.

Do not invent the final exhibit mark in advance if the court assigns it. You can use a working label such as “Proposed Plaintiff Exhibit 3” and update it as directed.

Exhibit labels and Bates numbers do different jobs

An exhibit label identifies a whole item: Exhibit 4 — Messages between A and B, March 1–12, 2026. Bates numbers identify individual pages inside that item. A 40-page exhibit may therefore be Exhibit 4 and pages MSG-000101 through MSG-000140.

Put the label on a cover sheet or in an unobtrusive stamp area. Avoid covering message text, dates, attachments, existing pagination, signatures, or court stamps. Include the case name or number only if required and safe to disclose.

Use a prefix that is neutral and stable. Initials, matter codes, or content codes work better than argumentative labels. Estimate the maximum set size before choosing padding. Six digits covers up to 999,999 pages without changing width.

Keep four identifiers distinct:

Identifier	Identifies	Example	Usually assigned by
Source filename	Original or collected file	chat-export.zip	Platform or collector
Bates number	One produced page	MSG-000123	Producing party under protocol
Exhibit label	One offered item	Proposed Exhibit 4	Party, clerk, or court procedure
Bundle page	One page in an assembled UK bundle	B/143 or PDF page 143	Bundle preparer under directions

They can coexist. Do not replace the original filename in the inventory merely because a PDF received Bates numbers. Do not call an exhibit “admitted” before the court admits it. Do not assume a UK bundle page is a Bates number.

Design the number before stamping

A number has a prefix, separator, padded counter, and sometimes a controlled suffix. ACME-MSG-000123 uses a matter or party prefix, a document-type segment, a hyphen, and six digits. Keep it short enough to fit every page.

Padding should accommodate expected growth. Moving from MSG-9999 to MSG-10000 changes width and can disrupt sorting. A neutral prefix avoids revealing private party names when files are shared beyond the immediate team. Agree on reserved ranges if several people will produce documents.

Native files require special planning. A spreadsheet, audio file, or video may be produced in native form because a page image would lose function. A protocol may assign the native file a Bates-like identifier and use that identifier in a placeholder slip sheet, filename, or load file. Suffixes can identify inserts or replacements, but only if the court order or agreed protocol permits them. Never improvise suffixes after exchange without recording the rule.

Continue numbering across a production

A production sequence normally continues from the last issued number rather than restarting at 1 for every PDF. If production 1 ends at MSG-000842, production 2 can begin at MSG-000843. Record every range in a production log.

Do not reuse identifiers for replacement pages. Mark a corrected production according to the governing protocol, preserve the withdrawn version, and state what changed. If a page was omitted, ask whether to use a suffix, a new range, or a complete replacement. Silent renumbering breaks citations already used in correspondence, declarations, and hearings.

A useful control log includes production date, recipient, source item, output filename, page count, first and last number, gaps, replacements, confidentiality marking, and hash. Compare the arithmetic: an inclusive range from 101 through 125 should contain 25 pages unless a documented suffix or gap exists.

Place the stamp where it remains readable

The stamp should be visible at normal zoom and survive black-and-white printing. A bottom-right or bottom-center margin is common, but the right location depends on existing page numbers and content. Use one position consistently unless a page needs a documented exception.

Do not cover text, signatures, dates, QR codes, attachment images, or existing identifiers. Rotated landscape pages need visual inspection after stamping; a stamp placed by PDF coordinates can appear sideways or over content. Keep adequate contrast but avoid an opaque box larger than necessary.

If the source has no safe margin, add a border or slip sheet to a derivative rather than stamping over evidence. Adding a border changes pagination and appearance, so preserve the original and document the transformation. Test at the court’s expected print size, not only on a large monitor.

Number a PDF with the in-browser tool

1. Preserve the original PDF unchanged.
2. Open the free Bates numbering tool.
3. Select the PDF. Processing occurs in your browser; the file content is not uploaded.
4. Enter a prefix, starting number, digit count, and stamp position.
5. Keep the stamp clear of existing content and page numbers.
6. Download the numbered derivative with a descriptive filename.
7. Review the first page, last page, rotated pages, attachments, and page transitions.
8. Record the filename, page range, date, operator, and hash of the result.

Stamping changes the PDF. Keep the original hash and calculate a separate hash for the stamped derivative. If pages are added later, avoid inserting numbers into an issued range. Use an agreed suffix convention or create a new controlled version.

Before step 1, settle the page order. Expand or identify attachments, decide whether cover sheets count, normalize rotation, and confirm whether blank pages remain. After step 8, search the output for the prefix, inspect thumbnails for missing pages, and compare the count with the assigned range.

The tool processes the selected PDF in the browser without uploading its contents. That privacy property does not replace local access controls. Download to a protected folder, close shared computers, and remove temporary copies according to your retention plan.

Build a usable exhibit list

An exhibit list should let the clerk, court, and parties identify each item quickly. Adapt this template to the court’s form:

Proposed exhibit	Short description	Date or range	Pages / Bates range	Offered by	Status	Notes
P-1	Complete message export, A and B	Mar. 1–12, 2026	MSG-000001–000084	Plaintiff	Proposed	Unredacted copy retained
P-2	Focused excerpt from P-1	Mar. 6, 2026	MSG-000041–000049	Plaintiff	Proposed	Gap markers shown
D-A	Screenshot set from phone	Mar. 6, 2026	DEF-000001–000012	Defendant	Proposed	Originals preserved

“Status” may track proposed, stipulated, admitted, not admitted, or withdrawn, but use the court’s terminology. Do not imply admission before the court rules.

England and Wales uses indexed, paginated bundles

Practice Direction 32 says the trial bundle should be indexed and paginated and, unless the court otherwise directs, use continuous page numbering. This is bundle pagination rather than a universal Bates requirement.

The judiciary’s electronic bundle guidance says pagination should match the PDF page numbering and recommends searchable text and bookmarks. Follow any newer case-specific order first. A logical bookmark hierarchy might use statements, pleadings, orders, and exhibits, with a descriptive bookmark for the message export.

Do not combine several independently numbered PDFs and assume the viewer’s page number is enough. Assemble the final bundle, paginate continuously, check the index against actual PDF pages, and test all bookmarks.

The Judiciary’s general guidance is guidance, and case-specific directions control. Where possible, it calls for one searchable PDF, sensible bookmarks, and electronic page numbering that corresponds with PDF page numbers. A bundle can still contain an exhibit with its own earlier Bates range. The index should bridge those systems.

Avoid handwritten repagination after electronic circulation. If the bundle must change, follow the direction for supplemental bundles, replacement pages, or revised pagination. Tell recipients which version is current and preserve the former version when it has already been cited.

Quality-control the final set

Check that every page has one identifier, sequence is continuous, no stamp obscures content, and landscape pages remain readable. Compare the exhibit list’s ranges to the actual first and last stamps. Search for duplicate identifiers.

Preserve a version log. Record source filename, output filename, page count, first and last number, software or tool, operator, date, and SHA-256 hash. If the bundle changes, issue a clearly named replacement rather than silently overwriting the previous file.

Avoid the failures that cause rework

Restarting at 000001 for each attachment creates duplicate references. Renumbering after exchange invalidates earlier citations. Stamping the only source copy destroys the clean baseline. Placing a number over text can conceal content. Using too few digits creates inconsistent sorting. Treating PDF viewer pages as permanent citations fails when a cover is inserted.

Other failures are subtler. A confidentiality footer can collide with the Bates stamp. OCR may become less useful if pages are rasterized during stamping. A portfolio PDF can contain nested files that were never assigned identifiers. Password protection may prevent the court from opening the file. Check searchability, accessibility, links, bookmarks, restrictions, and file size after processing.

Use a four-corner sample for a large set: first page, last page, a landscape page, and a dense page with existing footer content. Then automate or manually check the full sequence. The sample catches layout problems; the sequence check catches missing and duplicate numbers.

Finally, reconcile the exhibit list to the actual delivery. Open each file from the delivery folder, not from a working directory. Confirm its description, dates, range, page count, and hash. That last check catches stale copies with convincing filenames.