Rolling productions and Bates numbers

Published October 27, 2026

A rolling production hands documents over in batches instead of all at once. Each batch is often called a volume. The Bates numbers carry on from one volume to the next: if volume 1 ended at SMITH-000412, volume 2 starts at SMITH-000413. This page covers how the numbers continue, how volumes are named, supplements, and why a number is never used twice. This is general information, not legal advice.

What the federal rules say about producing in stages

Rule 34(b)(2)(B) of the Federal Rules of Civil Procedure lets a party say it will produce copies instead of allowing inspection, and adds: "The production must then be completed no later than the time for inspection specified in the request or another reasonable time specified in the response." The committee note to the 2015 amendment goes further: "When it is necessary to make the production in stages the response should specify the beginning and end dates of the production."

Supplements are a separate duty. Rule 26(e)(1)(A) says a party who has responded to a request for production must supplement or correct it "in a timely manner if the party learns that in some material respect the disclosure or response is incomplete or incorrect". State rules have their own versions, and a lawyer or your court's self-help center can say which apply to you.

Continuing the numbers

Three things stay the same across volumes: the prefix, the number of digits and the position on the page. Each volume's start number is the last volume's end number, plus one. One running index for the whole case (see production index) makes the next start number easy to find. For prefixes and padding, see Bates number format.

Naming volumes

A volume name says who produced it and which batch it is, such as SMITH-VOL001 or SMITH001. Court orders sometimes set the naming. In the Deepwater Horizon oil spill litigation, the federal court's 2010 order on productions (Pretrial Order No. 16, Eastern District of Louisiana) had each piece of production media identify the producing party and the production "wave". Its example for Transocean's first wave on three hard drives was "TRS001-001", "TRS001-002" and "TRS001-003". The same order asked for the case number, the producing party's name, the production date and the Bates ranges to be on the media, or in a cover letter where that was not practical.

For a self-represented party sending files by email or a download link, the same idea fits in a folder name and a short cover letter: "SMITH-VOL002, produced May 25, 2026, SMITH-000413 to SMITH-000530."

Supplements

A supplement is a later batch that adds documents found after an earlier response, or corrects one. It takes the next unused numbers, never numbers inside an earlier range. A supplemental written response can point to the new range: "Supplemental production for Request No. 3: SMITH-000531 to SMITH-000544." The guide to responding to a request for production covers the written response itself.

Never reuse a number

Once SMITH-000200 has gone out as page 3 of a lease, that number means that page for the rest of the case. If a different page later carried the same number, every letter, deposition and motion that cited it would become ambiguous. Renumbering an earlier volume causes the same problem: the other side's copies, notes and filings already use the old numbers.

Sometimes a page has to go out again, for example with a corrected redaction. How a replacement is numbered is something the parties can agree on between themselves. Whatever is done, the cover letter and the index say which page it replaces, so both sides know which version is current. If a number is skipped, a note in the index says why.

Keeping track

• One running index across all volumes, with the date each went out.
• Each volume kept exactly as sent, with a SHA-256 fingerprint of each file in the index.
• A copy of each cover letter.
• The last number used, written down before the next batch starts.

If you are doing this on your own, Bates numbering without a lawyer walks through a first production step by step.

BatesNumbering.app takes a start number, so a second volume can begin where the first one ended, and writes an index for each run with ranges, page counts and SHA-256 fingerprints. The first 10 pages are free; a set of up to 1,000 pages is $29 once, with 24 hours of re-runs.

Common questions

What is a rolling production?

Producing documents in batches over time instead of all at once. Each batch is often called a volume, and the Bates numbers continue from one volume to the next.

Do Bates numbers restart for each production volume?

Normally no. Each volume starts at the number after the last page of the previous one, with the same prefix and number of digits, so no number is used twice in the case.

How do you name production volumes?

Usually with the producing party and a batch number, such as SMITH-VOL001 and SMITH-VOL002. A court order or an agreement can set the naming; the Deepwater Horizon order used codes such as TRS001-001.

What is a supplemental production?

A later batch that adds or corrects documents after an earlier response. In federal court, Rule 26(e)(1) sets a duty to supplement a response that turns out to be incomplete or incorrect in some material respect; the new pages take the next unused Bates numbers.

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