How to Add Page Numbers and Bates Numbers to Legal Documents

Use ordinary page numbers for documents you file or read, such as briefs, bundles and contracts, and Bates numbers for documents you produce to the other side, where every page needs a unique reference that runs across the whole set. Both can be added to a finished PDF in one pass, but check your court's rules or the agreed production protocol first, because format and placement are often specified.

Legal work runs on page references. A judge asks counsel to turn to page 47 of the bundle; a deposition cites ABC_00012345. When pages are unnumbered, or numbered inconsistently across exhibits, those references break. This guide explains the difference between the two systems, what courts and protocols actually require, and how to add each with free tools.

Key takeaways

• Page numbers restart in each document and identify a page within it. Bates numbers combine a prefix with a sequence that never repeats across an entire production.
• Courts set pagination rules for filings. The Central District of California requires that "All documents shall be numbered consecutively at the bottom of each page" (C.D. Cal. L.R. 11-3.3).
• Production protocols set Bates formats. One federal order calls for "an alphanumeric prefix followed by an 8 digit number" in the bottom right of each page (D.S.C., CMO 4).
• Siliph's Bates Numbering stamps your prefix plus a six-digit number on each page, and continues the sequence across several files.
• Number last. Finish redactions, page order and conversions before stamping, because numbers are drawn onto the page.

Page numbers or Bates numbers

The name comes from office equipment. The Henry Ford museum holds a Bates numbering machine and explains that "Office workers used it to stamp consecutive numbers or numbers in a repeated pattern onto pages of documents", noting a mechanism patented by Edwin G. Bates in 1891 (The Henry Ford). The digital version does the same job without the ink.

What courts require for page numbers

Rules vary, so read your court's own. Some examples:

• Central District of California: "All documents shall be numbered consecutively at the bottom of each page" (L.R. 11-3.3).
• California state courts: "Each page must be numbered consecutively at the bottom", and numbering "must begin with the first page and use only Arabic numerals" (California Rules of Court, rule 2.109).
• US federal appeals: "Page numbers may be placed in the margins, but no text may appear there" (Fed. R. App. P. 32(a)(4)).
• England and Wales: under Practice Direction 32, the trial bundle "should be paginated (continuously) throughout, and indexed with a description of each document and the page number", and pages of exhibits "should be numbered consecutively at bottom centre" (Practice Direction 32).

Note the detail in the California rule: numbering begins on the first page. If your instinct is to leave the cover unnumbered, check first.

What production protocols require for Bates numbers

In US federal discovery, Rule 34 requires a party to "produce documents as they are kept in the usual course of business or must organize and label them to correspond to the categories in the request" (FRCP 34). It does not prescribe Bates numbers, but case management orders and ESI protocols commonly do. One multidistrict litigation order in the District of South Carolina is typical in its detail (D.S.C., MDL 2873, CMO 4):

• Images "shall be branded in the bottom right with a Bates number", with the order's example sequence starting at ABC_00000001.
• "Bates numbers should contain an alphanumeric prefix followed by an 8 digit number."
• "Each page will also be branded in the bottom left corner with the appropriate confidentiality designation."

Placement rules also protect the content. The Deepwater Horizon litigation order required a Bates number "at a location that does not obliterate, conceal, or interfere with any information from the source document" (E.D. La., Pretrial Order No. 16).

How to add Bates numbers with Siliph

Bates Numbering writes a label on each page made of your prefix and a running number padded to six digits, such as ACME-000001. The label is real PDF text in a monospaced font, so it prints crisply and can be searched. It is free with no account, and each file can be up to 200 MB and 2,000 pages.

1. Open Bates Numbering and add the PDFs in the production. Drag them into order; the numbering carries on from the last page of one file to the first page of the next, and you get one numbered PDF per file.
2. Type a Prefix, such as your party abbreviation or matter code followed by a dash or underscore.
3. Set the Start number: 1 for a new production, or the next free number to continue an earlier one. If the last production ended at ACME-000480, enter 481.
4. Under Position, choose the corner. Bottom right is the default, and it is the placement the South Carolina order uses.
5. Process, download, and record the Bates range of each file in your production log.

Matching an eight-digit format

Siliph pads numbers to six digits. If your protocol asks for an eight-digit number, as in the order above, put two zeros at the end of the prefix: a prefix of "ABC_00" with start number 1 produces ABC_00000001. This works as long as the production stays under one million pages. Check the result against the protocol's example before you serve anything.

What Siliph does not do

The confidentiality legend in the South Carolina order goes in the bottom-left corner. Siliph's Header & Footer always centres its text, so it cannot place a corner legend. If your protocol requires one, use a desktop PDF editor that allows left-aligned stamps, or agree the placement with the other side.

How to add page numbers to a filing

Add Page Numbers stamps a number on every page at one of six positions (top or bottom, left, centre or right), from any start number, with an optional prefix such as "Page ". For "Page 3 of 40" style numbering, Header & Footer accepts {n} for the page number and {total} for the page count, centred at the bottom.

1. Assemble the document first. Join exhibits with Merge PDF and fix the order with Organize, so the numbering runs continuously.
2. Open Add Page Numbers, upload the PDF and pick a position. Bottom centre matches the PD 32 exhibit rule; the California rules quoted above only require the bottom of the page.
3. Set the start number. For a second volume of a bundle that ended at page 400, start at 401.
4. Process and download, then check the first, a middle and the last page.

Every page receives a number. To leave a cover page unnumbered where your court allows it, split the cover off with Split PDF, number the rest starting from 2, and merge the two parts again.

The right order of operations

Numbers are drawn onto the page, so anything you change afterwards can break them. A safe order:

1. Finalise content and page order.
2. Redact privileged or personal information with Redact PDF. Our guide to redacting a PDF properly explains why black boxes are not enough.
3. Convert to the required format, such as PDF/A for e-filing; see PDF/A explained for court and government filing.
4. Add page numbers or Bates numbers.
5. Check the numbered pages, record the ranges, and protect the files with Protect PDF before they leave your office, if your court or protocol permits encryption.

Bates Numbering and Add Page Numbers are hybrid tools. Small files are stamped in your browser. Larger files go over an encrypted connection to Siliph's servers, are processed automatically with no human access, and are deleted within 2 hours.

Frequently asked questions

What is the difference between page numbers and Bates numbers?

Page numbers identify a page within one document and usually restart for each document. Bates numbers combine a prefix with a number that never repeats across a whole production, so every page in thousands of documents has its own reference.

How many digits should a Bates number have?

Whatever your court order or ESI protocol specifies; the South Carolina order quoted above uses eight. Siliph uses six digits, and you can reach eight by adding two zeros to the end of the prefix.

Where should Bates numbers go on the page?

Bottom right is a common placement, and the South Carolina order quoted above specifies it. Wherever it goes, the number must not cover any content on the page, so check pages with text near the margins.

Can I continue Bates numbering from an earlier production?

Yes. Set the start number to one more than the last number used. If the previous set ended at ACME-000480, start at 481 and the new set begins at ACME-000481.

Should the cover page of a court filing be numbered?

It depends on the court. California's rule says numbering begins with the first page, while other courts and document types differ. Check your court's local rules before deciding.