Pre-Marking Exhibits for Trial and Deposition

Pre-Marking Exhibits Keeps Your Witness Examination Flowing

If you have examined a witness at deposition or trial, you know the ritual. You are building momentum with a witness. You reach for a key exhibit. And then… everything stops.

You have to grab your sheet of exhibit stickers. You peel one off. You stick it on the corner of the first page. You grab a pen. You write "Exhibit 7" on it and hand a copy to the witness, opposing counsel, and the court reporter (or, if at trial, court staff).

By the time the witness is actually looking at the document, the momentum is gone. That is the "Sticker Pause." It is needless, consumes valuable time (particularly key in federal matters where you are limited to a presumptive 7 hours), and breaks the flow of examination.

Pre-marking your exhibits (applying PDF stickers before you ever walk into the room) is the professional standard and automating that process saves you time for the actual practice of law.

The physical act of stickering is distracting too. Whether it is you or your paralegal doing it, it is unnecessary administrative friction.

When you pre-mark your exhibits digitally, you hand the witness a clean, professional document with the exhibit number already printed on the first page. There is no fumbling with adhesive sheets. You simply hand over the document and ask your question.

Never Ask "What Exhibit Are We On?"

Even in the era of remote Zoom depositions, pre-marking exhibits goes a long way. Attorneys who fail to pre-mark their exhibits during depositions or trial constantly lose track of exhibit numbering. This leads to the familiar refrain: "Court reporter, what the last exhibit we introduced?" And then the court reporter has to review her log to get everyone on the same page.

Losing track of exhibit numbers disrupts your rhythm and can make you look unprepared in the eyes of witnesses, opposing counsel, the court, and jurors. If you pre-mark your PDFs with Exhibit Flow, our easy exhibit sticker software, you can pre-mark dozens of exhibits in seconds via an auto-incremented exhibit sticker workflow. You know exactly what number (or letter) corresponds to what file because it is already right there on the page. You never have to ask again: "What exhibit are we on?"

Trial: Pre-Marking is Often Required Anyway

While pre-marking exhibit is a strategic advantage, it is often a procedural requirement for trial. Many pretrial orders and other court rules require parties to prepare pre-marked exhibits ahead of time. Waiting until the eve of trial to manually sticker hundreds of exhibits in Adobe -- or even worse, by hand -- is a recipe for errors and late nights.

How Exhibit Flow Changes the Game

Historically, lawyers and paralegals stuck with physical exhibit stickers because the digital alternative (opening PDFs one by one in Adobe to add exhibit stamps) was too slow.

Exhibit Flow's digital exhibit sticker software tool solves this workflow problem by automating the PDF exhibit sticker process.

🗂️ Batch Process: Select all your files at once.

🎨 Customize: Choose your digital exhibit sticker color, prefix, and starting number.

🔍 Preview & Adjust: Preview and, if needed, move each digital exhibit sticker.

✨ Generate: Apply digital exhibit stickers to all of your PDFs in seconds.

Whether you are handing a paper copy to the judge's clerk or sharing a screen on Zoom, pre-marking exhibits keeps you focused on your examination, not on the paperwork.