What should a paralegal do when a production arrives already stamped with opposing counsel Bates numbers?

The first rule: their numbers stay

When a production lands from the other side, every page already carries the producing party's prefix and number. That number is not decoration. It is the citation key that will appear in deposition transcripts, meet and confer letters, motion exhibits, and the judge's own notes. If you restamp those pages with your own sequence, you have created two competing addresses for the same piece of paper, and every time someone reads a number aloud in a room, half the participants will be looking at a different page.

The instinct to renumber usually comes from a good place. Teams want everything in the case to live in one continuous internal sequence so nothing gets lost. Resist it. Track incoming documents by the producing party's range in your review database or index instead. Your internal control number, if you need one, belongs in a field, not burned onto the page. The only marks that reasonably go on top of a received page later are exhibit labels, and those come with their own rules covered further down. Related: What are the best practices for adding exhibit labels to documents before a hearing?

Keep reading: What exactly is Bates numbering and why do law firms rely on it for documents?, How do you keep Bates numbering consistent across multiple separate document productions?, When should you apply confidential or privileged watermarks to a batch of documents?. See how PdfStampr helps you bulk pdf stamping and bates numbering.

What actually arrives, and the intake check you owe the case

A production is rarely just a folder of PDFs. Depending on the protocol the parties agreed to, you may receive multi-page PDFs named by Bates range, single-page image files with a separate text folder, native spreadsheets accompanied by a slip sheet that carries the Bates number for the placeholder, and a delimited load file listing the begin and end Bates for each document along with metadata fields such as custodian, date, and family relationships. Each of those pieces can disagree with the others, and the disagreement is your problem to catch. Related: What exactly is Bates numbering and why do law firms rely on it for documents?

Run the same intake check every time. Confirm the page count matches the range from the first number to the last. Walk the sequence looking for gaps, then decide whether each gap is legitimate or an error. Withheld privileged documents often leave an intentional hole that should be reflected on the privilege log, while a missing block of forty pages in the middle of a contract usually means something failed during export. Confirm the load file begin and end values match the numbers actually printed on the pages, because a mismatch there will quietly poison every cite you build later. Write down what you find and raise it in a short letter within days, not weeks. Gaps are cheap to fix on arrival and expensive to fix the morning of a deposition. Related: When should you apply confidential or privileged watermarks to a batch of documents?

When their stamps are unusable

Sometimes the numbers you receive are technically present and practically useless. The common failure modes are familiar to anyone who has done this work: a stamp burned directly over a signature block or a table of figures, a number so faint after two rounds of copying and rescanning that it will not survive another pass, a stamp that drifts across pages because the source documents had mixed page sizes, or a set where the number lives only in the load file and never got applied to the image at all. Scanned image sets with no text layer add a second problem, because you cannot search for a number you can only see.

The remedy is a conversation, not a workaround. Ask the producing party for a corrected reproduction of the affected range and say specifically what is wrong, with a handful of example numbers. If time will not allow that and you need something usable for a deposition next week, you can place your own reference mark in a genuinely empty corner that repeats their number rather than replacing it, so the page still answers to the same address. Whatever you do, keep the set exactly as it arrived in a read only location, do all work on copies, and note in your file what was altered and when. If the same range ever gets disputed, that untouched copy is the thing that settles it.

Turning a received set into exhibits and hearing binders

Exhibit labels are the one addition that belongs on top of someone else's production, and they are additive rather than replacing. Place the label where it does not cover the existing Bates number or any content, typically the opposite bottom corner or the upper right, and keep it visually distinct from the underlying stamp so a witness can tell the two apart at a glance. Confidentiality legends are a different matter. Designations under a protective order belong to the producing party, so you neither add nor remove them, and if you believe a designation is wrong the fix is a challenge letter, not an editing pass.

Keep three separate sets and never let them blur. The received set stays pristine. The working set is where redaction for filing, exhibit labeling, and binder assembly happen. The produced or filed set is what actually went out the door, preserved as sent. Name files so the filename and the page agree, usually by the Bates range the document covers, because that one habit removes most of the confusion when three people are pulling documents at the same time under deadline. None of this is glamorous, but a case that stays organized in discovery is a case that does not lose an afternoon reconstructing which version of a page went into which binder. Related: How do you keep Bates numbering consistent across multiple separate document productions?