Litigation terms
Bates numbering
Bates numbering is the practice of stamping every page of produced documents with a unique sequential identifier, so any page can be cited, tracked, and retrieved unambiguously across a case.
Named for the late-1800s Bates Automatic Numbering Machine, the modern version is digital: a
prefix identifying the producing party plus a zero-padded sequence — SMITH000001,
ACME004312 — applied to every page before production. Once stamped, “the memo” stops being a
description and becomes an address.
Why it matters in practice
Everything downstream of production runs on Bates numbers. Discovery responses reference them, deposition exhibits are identified by them, motions cite them, and privilege disputes turn on ranges of them. A production with gaps in its Bates sequence is itself evidence: missing numbers mean withheld or misnumbered pages, and comparing produced ranges against a privilege log is a standard completeness check.
Two conventions to know. First, the prefix identifies the producing party, not the author —
ACME000123 means Acme produced it. Second, a Bates cite pins a page, not a document: a
ten-page contract spans ten numbers, and precise work product cites the page, not just the
first stamp.
In a verified fact record
Page-level citation is the whole reason Bates numbering survived 130 years. FactMarshal treats the Bates page as the atomic unit of proof: every extracted fact is pinned to the specific stamped page it came from, so a chronology entry or a flagged contradiction is always one click from the exact page you would hand the witness.