How to Prepare Exhibits for Trial: Step by Step

Exhibit preparation is the bridge between "we have our documents" and "the judge can cite page 3 of Exhibit 7." This guide walks through each step in the order it actually happens, with the practical details courts expect and paralegals need.

Step 1: Collect and organize everything first

Before touching a stamp or a sticker, get the full universe of documents assembled. Contracts, correspondence, invoices, photos, expert reports, medical records — every document that might be offered. Organize by category or chronologically, whichever your trial team prefers. Remove exact duplicates now; near-duplicates (different versions of the same contract) usually both stay.

Convert non-PDF files (Word documents, Excel spreadsheets, scanned images) to PDF at this stage. Every exhibit needs to be a single, self-contained PDF before numbering begins. Exhibix handles Word and Excel conversion automatically on upload.

Step 2: Assign exhibit numbers

Exhibit numbers identify entire documents — Exhibit 1, Exhibit 2, Exhibit A, Exhibit B. The format depends on your court and which party you represent. Common conventions include sequential numbers (Exhibit 1 through Exhibit 47), letter prefixes by party (PX-1 for plaintiff, DX-1 for defendant), or joint numbering (J-1 through J-30 for stipulated exhibits in a joint pretrial).

Whatever format you choose, lock it before stamping begins — renumbering after Bates stamps are applied means re-stamping the entire set, because the exhibit list references both.

Step 3: Apply Bates numbers

Bates numbers go on every page of every exhibit, running continuously across the entire set (PLF-000001 through PLF-000847, for example). They exist so that any page of any document can be cited precisely — in motions, depositions, and at trial — without ambiguity.

Key decisions at this stage: the prefix (PLF, DEF, a case code, a client abbreviation), the number of digits (six is standard; eight for large productions), position on the page (bottom-right is the convention, but check local rules), and font size (small enough not to obscure content, large enough to read).

Step 4: Place evidence stickers

Evidence stickers are the court's official exhibit labels. Unlike Bates numbers (which you control), evidence stickers follow the format your specific court requires — with fields the clerk fills in when the exhibit is formally identified or admitted during testimony.

Different courts use different formats. Florida's Palm Beach County requires the sticker on the back of the last page. Broward's 17th Circuit uses a different field layout than Miami-Dade's 11th Circuit. Federal district courts use yet another format. Using the wrong format or the wrong placement is the kind of detail that gets noticed at the clerk's desk.

Step 5: Redact what shouldn't reach the jury

Some content in your exhibits needs to come out before trial: privileged attorney notes that ended up on a document, Social Security numbers, financial account numbers, or passages a judge has ruled inadmissible. Redaction is the last substantive step before the exhibit list, because adding or removing content after the exhibit list is generated would put it out of sync.

True redaction permanently destroys the underlying content — the affected page is flattened to an image so nothing recoverable remains underneath the black (or white) box. Drawing a black rectangle in an ordinary PDF editor is not redaction; the text stays in the file and can be copied out. For a law firm, the difference between "covered" and "destroyed" is the difference between a redaction and a malpractice claim.

Step 6: Generate the exhibit list

The exhibit list is the actual deliverable — the document filed with the court, listing every exhibit by number, description, and Bates range, in whatever column format your jurisdiction requires.

Florida circuit courts expect Exhibit No., Description, Date Identified, and Date Admitted (the clerk fills the last two at trial). Federal courts use the AO 187 layout. New York's Commercial Division Rule 28 pre-marking process needs stipulation and objection columns. California superior courts use Marked for Identification and Admitted columns.

The exhibit list must match the exhibits exactly — every document name, every Bates range, every exhibit number. If the list says "Exhibit 5: Contract, PLF-000023 through PLF-000031" but the actual document runs through PLF-000034, someone retyped a number wrong. This is the single most common error in manual exhibit preparation, and the one most likely to cause problems at trial.

Step 7: Assemble and file

With the stamped, stickered, redacted PDFs and a matching exhibit list, you have a court-ready exhibit package. Most courts accept electronic filing of the exhibit list with the pretrial order, and the stamped PDFs are brought to trial (or filed electronically in courts that accept electronic exhibits). Keep an unstamped copy of every original document in case a question arises about what was under a redaction or whether a Bates number was applied correctly.

Frequently asked questions

What is the correct order for preparing trial exhibits?

Collect and organize all documents, assign exhibit numbers, apply Bates stamps for page-level tracking, place court-specific evidence stickers, redact any privileged or inadmissible content, and generate the exhibit list in the format your jurisdiction requires. This order matters because Bates numbers must be continuous across the set, and the exhibit list references those numbers.

What is the difference between an exhibit number and a Bates number?

An exhibit number identifies the document as a whole (Exhibit 1, Exhibit 2). A Bates number identifies every individual page across the entire case (PLF-000001 through PLF-000847). Both appear on the final exhibit, serving different purposes: exhibit numbers for courtroom reference, Bates numbers for precise page citation in motions, depositions, and cross-examination.

How far in advance should exhibits be prepared before trial?

Most courts require the exhibit list to be filed with the pretrial order, typically 14 to 30 days before trial. Florida circuit courts generally require filing with the joint pretrial stipulation. Federal courts follow the FRCP 26(a)(3) timeline of 30 days before trial. Check your judge's standing order for the exact deadline — some require earlier disclosure.

Do I need evidence stickers if I already have Bates numbers?

Yes, in most jurisdictions they serve different purposes. Bates numbers are for page-level identification and citation. Evidence stickers are the court's official label format, with fields the clerk fills in when the exhibit is formally identified or admitted during testimony. Some courts (like Palm Beach County) require the sticker on the back of the last page.

What happens if my exhibit list doesn't match the actual exhibits?

At best, you get a pointed question from the judge or opposing counsel. At worst, an exhibit is excluded because the list says it's 9 pages but the document is 12, or the description doesn't match what was produced. The safest approach is generating the exhibit list from the same data that produced the stamps, so mismatches are structurally impossible.