Paginating Exhibits for Motions

When drafting and filing motions, your argument is only as strong as the record that supports it. Judges and clerks need to quickly locate and review exhibits. One of the most overlooked — but critical — details is how your exhibits are paginated.

The Common Problem: Missing or Confusing Pagination

Too often, exhibits are attached to motions as raw PDFs with no pagination. Or worse, a party submits exhibits that simply reflect the Bates numbers from discovery. Such Bates numbers don’t reset between exhibits nor do they indicate where in your exhibit the page will appear. This creates unnecessary frustration.

For example:

• A 200-page combined exhibit packet may have “page 137” noted in the motion. But unless your exhibits are numbered, chambers will have difficulty finding it.

• Your summary judgment brief cites to Ex. 9, Electronic Schematics, at BATES_009232. Your reader will have to flip through your exhibit to determine where BATES_009232 appears..

Presenting your evidence in the clearest way possible is critical to making your client's side of the story shine through. And a professional preparation of exhibits will impress clients and chambers alike. You and your firm have spent countless hours drafting a summary judgment motion -- your exhibits should reflect the same polish and clairty.

Best Practice: Paginate on a Per-Exhibit Basis

The cleaner approach is to paginate each exhibit individually, starting at page 1 for every new exhibit. This way if chambers reviews your cite to “Ex. B, Sales Logs, at p. 134,” the court can find your citation with ease.

This method:

• Makes citations straightforward (e.g., “See Ex. D at p. 12”).

• Reduces scrolling (or page flipping for readers that print out paper copies) and guesswork in large records.

• Improves professional presentation of your filing.

  
  

Exhibit Flow Can Help

Exhibit Flow's Exhibit Slipsheet Tool not only automatically adds numbered/lettered slipsheets to your exhibits, our app can also automatically add page numbers across all of your exhibits with the click of a button. You can keep it simple ("1") or add the exhibit number/lettering or even file name of each exhibit ("Ex. F, Memorandum of Understanding, P. 1").

Importantly, by adding file names, a reader can now flip through your record and immediately know that Ex. A is the Shareholder Agreement while Ex. Z is the Notice of Breach.

Bottom Line

Clear, consistent pagination isn’t just a formatting choice — it’s part of effective advocacy. By ensuring each exhibit starts at page 1 and is properly labeled, you make it easier for the court to follow your argument, digest the record, minimize the risk of confusion, and present your case in the most professional light.

If your firm is still cobbling together exhibit packets the old fashioned way, it may be time to upgrade. The right software can take this once-painful process and turn it into a streamlined, reliable step in your motion workflow. Exhibit Flow can save you hours of hassle by automating these workflows in seconds.