Why Discovery Specifically Demands Discipline Here
In litigation, Bates numbers become the permanent reference point for every page produced — cited in deposition transcripts, referenced in motions, relied on by opposing counsel. A mistake in the numbering (duplicates, gaps, inconsistent formatting) doesn't just look sloppy; it can create genuine confusion about which document is being referenced, and in some cases raise questions about production completeness.
Choosing a Prefix
A common convention identifies the producing party, such as SMITH- or PLAINTIFF-. Keep it short, consistent, and agreed upon before production begins — changing a prefix partway through a case creates unnecessary confusion for everyone tracking references across the matter.
Digit Padding and Starting Number
Most productions use consistent zero-padding (e.g., 6 digits: 000001) so that numbers sort correctly and align visually regardless of magnitude. Confirm with opposing counsel or the court whether there's an expected convention before your first production, and stay consistent with it for every subsequent production in that same case.
Keeping a Production Log
Track which Bates range corresponds to which production, batch, or date — for example, "Production 3, Bates SMITH-004521 through SMITH-005890, produced March 3." This makes it straightforward to answer questions later about when and how a specific document was produced, without having to reconstruct that history from scratch.
Never Renumber a Production That's Already Gone Out
Once a Bates-numbered set has been produced to another party or filed with a court, treat that numbering as permanent. If an error is discovered, it's generally handled through a supplemental production with new numbers and a clear explanation, not by reissuing the same numbers with different content — doing so undermines the entire point of Bates numbering as a stable, unambiguous reference system.
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