Exhibit numbers vs Bates numbers
Published October 27, 2026
They answer different questions. An exhibit label names one whole document that someone shows the court: at a hearing, at trial, or attached to a motion or declaration. It looks like "Exhibit A" or "Plaintiff's Exhibit 1". A Bates number names one page in a set of documents handed to the other side in discovery, such as SMITH-000047. The same page can carry both. This is general information, not legal advice.
Side by side
| Exhibit label | Bates number | |
|---|---|---|
| What it names | A whole document | A single page |
| Looks like | Exhibit A, Exhibit 1, Plaintiff's Exhibit 3 | SMITH-000047 |
| Used when | Showing a document to the court: a hearing, a trial, an attachment to a filing | Handing documents to the other side in discovery |
| Who assigns it | The party, or in some courtrooms the clerk | The party producing the documents |
| How it counts | One label per document, by side or by filing | One number per page, running across everything that party produces |
| Where it goes | A sticker, stamp or cover sheet on the first page | Every page, usually in a corner |
How exhibits are labeled
Conventions vary by court. California's court self-help site says the plaintiff's exhibits are traditionally numbered and the defendant's are lettered, so Exhibit 1 comes from one side and Exhibit A from the other. It says some courts want you to label your own exhibits as you introduce them, while in others the clerk does it, and it tells readers to check with their court before trial. It also says not to mark exhibits before trial, since you do not yet know which ones the judge will let in.
Federal courts can do it differently. The U.S. District Court for the District of Arizona's standard exhibit instructions give each side a block of numbers (their example is plaintiff 1 to 80 and defendant 100 to 180), use yellow cover sheets for the plaintiff and blue for the defendant, and ask for numbers only, with letters just for sub-parts such as 3a and 3b. The court's local rules, the judge's own procedures or the clerk's office will say which applies in a given case.
When a document carries both
A bank statement produced in discovery as SMITH-000101 to SMITH-000106 can later be attached to a motion as Exhibit C, or shown at a hearing. The Bates numbers stay on the pages. The exhibit label goes on the first page or on a cover sheet in front of it. Citing it as "Exhibit C (SMITH-000101 to SMITH-000106)" tells the other side it is the same document they already have, page for page.
The Arizona instructions make the link plain. They ask for each page of a multiple-page exhibit to be marked, and add: "In bulky documents, BATES stamp numbers may be placed on each page, at the bottom right corner, and can be continuous numbering." In other words, the exhibit number names the document and the Bates numbers name its pages.
The reverse does not work as well. Exhibit letters are not unique across a case: one motion's Exhibit C and another motion's Exhibit C can be different documents. A Bates number stays the same wherever the page turns up.
Which one applies to what you are doing
- The other side sent a request for production. That is discovery, where Bates numbers are used. See responding to a request for production and Bates numbering without a lawyer.
- You are attaching documents to a filing or bringing them to a hearing. That calls for exhibit labels, in your court's style. Filings with a federal court also fall under Rule 5.2's limits on Social Security numbers, account numbers and birth dates; see redacting SSNs and account numbers in court filings.
- Both. Documents already produced keep their Bates numbers when they become exhibits, so the two systems sit side by side.
For what goes into a Bates number itself, see Bates number format, and for the basics, what is Bates numbering.
Tools for each
Exhibit labels can be as simple as a pen, a printed sticker, or a cover sheet from the court. batesstamp.com, free in the browser, adds exhibit stamps such as "EXHIBIT A" as well as Bates numbers. LegalBinder, a Chrome extension, has free exhibit stickers.
BatesNumbering.app adds Bates numbers, and an optional label such as CONFIDENTIAL, to every page, with an index of each file's range. It does not make exhibit stickers or slip sheets, so the exhibit label comes from one of the tools above or the court's own cover sheets.
Common questions
Is an exhibit number the same as a Bates number?
No. An exhibit label such as Exhibit A names a whole document shown to the court; a Bates number such as SMITH-000047 names one page in a set handed over in discovery. One page can carry both.
Are plaintiff's exhibits numbers or letters?
California's court self-help site says the plaintiff's exhibits are traditionally numbered and the defendant's lettered. Other courts differ: the federal District of Arizona's instructions give each side a block of numbers. The court's rules or the clerk will say which applies.
Do exhibits keep their Bates numbers?
Normally, yes: a document produced in discovery keeps its Bates numbers when it later becomes an exhibit, and the exhibit label is added on the first page or a cover sheet. Citing both, such as Exhibit C (SMITH-000101 to SMITH-000106), ties the two together.
Redact and Bates-number a set of PDFs in one pass →Or check a PDF for numbers left in it, free →
More guides: What is Bates numbering · Bates numbering without Acrobat · Bates number format and examples · Bates numbering a discovery response without a lawyer · How to redact a PDF for free · Redacting SSNs and account numbers in court filings · Redacting a bank statement · Why black box redactions fail · Redacting a PDF on iPhone or Mac · A document production index · Rolling productions · Responding to a request for production · Bates and redaction tools compared · batesstamp.com alternatives · RedactifyAI alternatives · Adobe Acrobat alternatives for Bates and redaction