Bates Numbering Explained: A Simple Guide for Legal Documents

Picture a hearing where both sides are working from a stack of 4,000 pages. “If you turn to the email from March, the second attachment, about halfway down the third page…” is how you lose a room. “Please look at SMITH002417” is how you keep it.

That is the whole idea behind Bates numbering: every page in a set of documents gets its own permanent, unique number, so anyone can point to exactly the same page without ambiguity.

Where the name comes from

The name comes from Edwin G. Bates, a New York inventor whose numbering machine was patented in the 1890s. His improvement was a mechanism that advanced the number automatically after each stamp, so a clerk could number page after page in sequence. Law firms adopted the machines, and the name stuck long after the stamps were replaced by software. (More on the history.)

Today almost nobody uses an ink stamp. The number is added electronically to PDFs, but the principle is the same.

What a Bates number looks like

There is no single official format, but most follow the same pattern:

A few real-world-style examples: SMITH000001, ABC-0004512, DEF_PROD_00012345. Ranges are written first to last: SMITH000012–SMITH000015.

Why the zeros? Without them, a computer sorts SMITH10 before SMITH2. With padding, SMITH000002 comes before SMITH000010, exactly as it should. Choose enough digits for the largest production you can imagine; six digits covers up to 999,999 pages.

Where Bates numbers are used

• Litigation and discovery, where each side produces documents to the other and both need to cite pages exactly.
• Court exhibits and appendices.
• Medical records requested for injury, insurance or negligence claims.
• Regulatory investigations and audits, where every page handed over needs to be accounted for.
• Due diligence for acquisitions and large contracts.
• Insurance claims with large supporting files.

The rules that matter

1. One number per page, never reused. If a page is withdrawn, its number is retired, not given to another page.
2. Continuous across files. The second document picks up where the first ended. If file 1 ends at SMITH000245, file 2 starts at SMITH000246.
3. Number after the order is final. Renumbering after documents have been produced causes confusion that can last the whole case.
4. Don’t cover the content. Put the number in the margin, usually bottom right. A small white box behind the number keeps it readable on pages with content near the edge.
5. Every page counts, including blank pages and slip sheets, unless the agreed protocol says otherwise.
6. Keep a log. A simple index of each document’s first and last number is what you will put in the production letter and search when someone cites a page.

Courts, agencies and the other side may have their own requirements for format, position and endorsements, often set out in an ESI protocol or local rules. Check them before you start. This guide is general information, not legal advice.

Confidentiality endorsements

Alongside the Bates number, documents under a protective order often carry a second label, such as CONFIDENTIAL or CONFIDENTIAL – SUBJECT TO PROTECTIVE ORDER. It usually sits in a different corner from the number, for example bottom left, so the two never overlap.

How to Bates number PDFs

1. Add all the files.

   Open Bates Numbering and add every PDF in the production. If any documents are still in Word, convert them first with Word to PDF.

2. Put them in order.

   Use the arrows to arrange the files. The list shows the Bates range each file will receive, so you can see the numbering before anything is stamped.

3. Set the format.

   Enter the prefix, an optional suffix, the starting number and the number of digits. The first number appears as a preview, for example ABC000001.

4. Choose position and style.

   Bottom right is the usual choice. Drag the number on the preview if a page layout needs a different spot. Courier or Helvetica in black, with the white box switched on, is the safe default.

5. Add an endorsement if the production needs one.
6. Number and download.

   With several files you get a ZIP containing the numbered PDFs and a CSV index of each file’s first and last number. You can also have the files named by their Bates range, such as ABC000001-ABC000024.pdf.

Everything runs in the browser, which matters for privileged or sensitive material: the documents are never uploaded to a server in order to be numbered.

Bates numbers vs page numbers

For an ordinary report, Add Page Numbers is all you need. For anything that may be cited, produced or audited, use Bates numbers. Many documents end up carrying both.

A worked example: one production, three files

Say you are producing three PDFs for client ABC: a set of emails (245 pages), signed contracts (112 pages) and invoices (58 pages). With the prefix ABC and six digits, starting at 1, the numbering works out like this:

That table is your index. It goes into the cover letter (“ABC000001–ABC000415, produced on 8 November 2026”), and it is the first thing you will check when the other side cites ABC000301 and you need to know which document that is. Here, it’s the contracts file, page 56.

Supplemental productions and withheld pages

Discovery rarely happens in one go. When a second batch follows a month later, don’t start again at 000001. Continue from the next unused number, ABC000416 in the example above, so every page across every production stays unique. Many teams also label each batch as a volume (VOL001, VOL002) in the production letter, without changing the Bates sequence itself.

Pages that are withheld, for example for privilege, are usually still accounted for. A common approach is to replace the document with a single slip sheet saying “Document withheld – privileged” and give that sheet its own Bates number, so the sequence has no unexplained gaps. The privilege log then refers to that number. Agreed protocols differ, so follow the one in your matter.

Common mistakes

• Numbering before the set is final, then inserting a document in the middle.
• Starting each file at 000001 instead of continuing the sequence.
• Too few digits, so a large production runs out of numbers or sorts wrongly.
• Stamping over text near the page edge.
• Losing the index, so nobody can quickly find which document holds a given page.
• Overwriting the originals. Keep an unstamped copy of every document.

Frequently asked questions