01
Bates numbering
Every document production
Sequential page identifiers are the backbone of a production. Every page gets a unique number in an unbroken sequence so a motion, a transcript, and an appellate brief can all point at the same page without ambiguity. Prefix, start number, and zero padding should be configurable, and the sequence must carry forward correctly across rolling productions.
Practice tip: Pick your padding width once per case and never change it. ABC000001 and ABC1 in the same production is a sorting problem you will discover at the worst time.
02
Exhibit stamping
Depositions, hearings, and trial
Exhibit labels mark a document as Exhibit A or Plaintiff's Exhibit 12, applied once to the first page. They sit alongside Bates numbers rather than replacing them, and they must be offset so the two marks never collide.
Practice tip: Apply Bates numbers to the whole set first, then exhibit labels document by document. Reversing the order is the most common cause of gaps.
03
True redaction
Privilege, personal data, and sealed material
Redaction must remove the text layer, not cover it. Cosmetic black boxes have repeatedly exposed sealed information in high-profile filings, because anyone can select and copy the text underneath. Pattern-based detection for Social Security numbers and account numbers helps, but verification is still manual.
Practice tip: After redacting, open the file and try to select text inside the black box. If anything copies out, the redaction failed.
04
OCR
Scanned exhibits and legacy records
Optical character recognition adds a searchable text layer to scanned pages. Without it, keyword review silently misses documents and courts that require text-searchable filings will reject the submission.
Practice tip: Run OCR before review, not after. A privilege screen against image-only documents is not a privilege screen.
05
Merge, split, and page assembly
Building exhibit binders and filing packages
Combining a motion, declaration, and exhibits into one filing, or splitting a 900-page production into court-sized volumes, is routine. Page-level control including rotation, deletion, and reordering keeps assembled packages clean.
Practice tip: Assemble first, stamp second. Stamping before assembly produces out-of-order Bates ranges inside a single filed document.
06
Bookmarks and hyperlinked indexes
Long briefs and appellate records
Many courts require bookmarked exhibits and internal links from a table of contents or exhibit index. A judge who cannot navigate a 400-page appendix will not go looking for your best document.
Practice tip: Name bookmarks with both the exhibit label and the Bates range so the sidebar doubles as an index.
07
Text extraction and search across a set
Finding the document you know exists
Cross-document search over an entire production set is what turns a folder of PDFs into something usable. It also confirms whether a keyword actually appears where you believe it does before you assert it in a brief.
Practice tip: If a search returns nothing on a scanned document, the problem is usually missing OCR, not a missing document.
08
Metadata inspection and scrubbing
Before anything leaves the firm
PDFs carry author names, editing history, comments, and sometimes tracked-change residue from the source file. Producing that unintentionally is an avoidable disclosure.
Practice tip: Inspect and sanitize the document before production unless the ESI protocol specifically requires metadata preservation.
09
PDF/A conversion
Archival filings and agency submissions
PDF/A is an ISO archival profile that embeds fonts and forbids external dependencies so files render identically in the future. Several courts and agencies require it, and it is the safest format for long-term record retention.
Practice tip: Convert to PDF/A after stamping, not before, so the Bates and exhibit marks are part of the archived file.
10
Production index and load-file export
Delivering and tracking the production
A production index maps every file to its exhibit label, Bates range, and page count. It is what lets you answer 'what did we produce, when, and where is it' six months later without reopening every PDF.
Practice tip: Export the index at the same moment you export the stamped files. Reconstructing it later is manual work nobody enjoys.