Tag Archives: Bates Numbering

Don’t Challenge Under Rule 34 If You Cannot Explain Why.

25 Thursday Feb 2016

Posted by in Discovery, Document Review, Federal Rules of Discovery, Recent Links and Articles

≈ Comments Off on Don’t Challenge Under Rule 34 If You Cannot Explain Why.

Tags

, , , , ,

Attack the Form of Production, by Joshua Gilliland, Esq., Bow Tie Law Blog

https://bowtielaw.wordpress.com/2015/09/22/be-specific-if-you-are-going-to-attack-the-form-of-production/

Oh, Rule 34. You are the code section that keeps giving.

Under Federal Rule of Civil Procedure Rule 34(b)(2)(E)(i), a party ’must 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.’

A Plaintiff brought a motion to compel the opposing party to organize and label their production to correspond to the categories in the Plaintiff’s Requests for Production. Things did not go well for the Plaintiff’s motion. . . .

Continue reading →

Another Way To Number Discovery Documents With Microsoft Word.

21 Saturday Mar 2015

Posted by in Bates Numbering, Discovery, Document Control, Interrogatories, Requests for Admissions, Requests for Production

≈ Comments Off on Another Way To Number Discovery Documents With Microsoft Word.

Tags

, , , , , , , , ,

Making Numbering Interrogatories and Requests for Production/Admission Easy (with Video), by Matt Albrecht, Remedial Action Law Blog (with hat tip to Sam Glover, Lawyerist Blog, and Patricia Lyons)

http://tinyurl.com/pg8aseh

Not surprisingly, Pat Lyons, RP, from Rhode Island, one of the sharpest paralegals I’ve ever met, knows a neat trick. Thanks, Pat! -CCE

Numbering requests for production and requests for admission is something that legal secretaries and attorneys loathe. It’s something that systems administrators loathe to see take so long to do. It’s an error-prone process that occasionally results in mis-numbering and confusion, and when mistakes occur, it just looks bad.

Microsoft Word has auto-numbering features that can make things like this easier. One way that we use auto-numbering is for legal-style numbered paragraphs. Properly applied to Styles in Word, numbered paragraphs are easy, automatic, and they update themselves. We use multilevel lists to accomplish numbered paragraphs, and it works wonderfully. . . .

Continue reading →

“Lock Down” Your Bates Numbers To Prevent Edits By Opposing Counsel.

16 Tuesday Dec 2014

Posted by in Adobe Acrobat, Bates Numbering, Bates Numbers, Discovery, E-Discovery, Legal Technology, Requests for Production

≈ Comments Off on “Lock Down” Your Bates Numbers To Prevent Edits By Opposing Counsel.

Tags

, , , , , , ,

Preventing Edits To Bates Numbers Applied In Acrobat, by Rick Borstein, Acrobat for Legal Professionals Blog

http://tinyurl.com/lvc4j87

If your job is anything like mine, you use Adobe Acrobat to Bates number documents all the time. There are many reasons to use a Bates numbering system. One of the top reasons is that it helps to eliminate confusion and keeps documents organized.

If opposing counsel can change the Bates numbers on your produced documents, it can create havoc. I do not like havoc, especially when I have spent a lot of time and my client’s money to create a neatly Bates-numbered set of documents. Thank you, Mr. Borstein! -CCE

[T]he ability to remove Bates Numbers is valuable in case you make a mistake during the numbering process. However, due to the adversarial nature of the legal business, attorneys may desire to limit what the other side can do with documents.

To whit, this email I received from an attorney last week:

What can I use to flatten Bates numbers so that they cannot be altered or removed using the Acrobat Bates numbering process?

I know I can print to PDF, save as TIFF, print-then-scan, etc., but am looking for a solution that will work in batch mode and not degrade the appearance of the file. Also, I don’t favor using security settings because I don’t want to restrict the user’s ability to access the file.

In this article, I’ll discuss how to ‘lock down’ Bates Numbers so that they cannot be removed by Acrobat’s ‘Remove Bates’ option. . . .

Cool Tip – How To Re-Number Your Exhibits’ Bates Stamps For Trial.

23 Sunday Nov 2014

Posted by in Adobe Acrobat, Bates Numbers, Exhibits, Legal Technology, Trial Notebooks, Trial Tips and Techniques

≈ Comments Off on Cool Tip – How To Re-Number Your Exhibits’ Bates Stamps For Trial.

Tags

, , , , , ,

Trial Tech Tips – TrialDirector Bates Numbering, by Ted Brooks, Court Technology and Trial Presentation Blawg  

http://tinyurl.com/ok53uvl

This tip is one of the best ways to use Adobe Acrobat’s Bates-numbering feature. Not to take away from TrialDirector, but you can do this entirely with Adobe Acrobat. It is fast and easy. If you have not tried it, I strongly encourage it. Mr. Brooks’ post will explain why. -CCE

This article is the first in a series entitled ‘Trial Tech Tips.’ Focused on the crossroads of law and technology, and in no particular order, we will share a collection of proven and tested methods for accomplishing a wide variety of common and/or critical tasks encountered during trial preparation or presentation. We will also try to rank them from one to ten on a ‘geek scale,’ with one being not too technical, and 10 being very technical.

On a geek scale of one to ten, this article would be rated at about an 8.

In litigation, it is generally a good idea to make sure that when a certain document is referred to, it is that exact document, and not another version of the same. In situations where there are more than one, and it can be proven, it can result in an interesting trial.

Bates numbering has been around for some time, and is one good method of making sure that everyone is on the same page – literally. Through the years, inked stamps have been used, printed stickers, and nowadays the method most commonly used adds them via software – generally in the lower right corner of each page. Although the most efficient methods can handle a large volume all in one operation, this can also be done at the individual document level.

There are many reasons for adding a Bates number to your exhibits, and there are many for adding yet another Bates number. For instance, if your exhibits have already been numbered according to document productions, it may be helpful to add another set of numbering tied to trial exhibit numbers. This makes it easier for counsel, judges, witnesses and jurors to quickly get to any given exhibit page. Rather than having some lengthy production-based Bates number (e.g., PLTF000024) that may or may not be followed by its next numerical page (PLTF000025) when used in a trial exhibit, we can simply make reference to the trial exhibit and page number (e.g., 0178-002 would be trial exhibit 178, page 2). . . .[Emphasis added.]

Craig Ball’s Lawyers’ Guide to Forms of Production.

19 Monday May 2014

Posted by in Adobe Acrobat, Authentication, Bates Numbers, Computer Forensics, Databases, Discovery, Document Review, E-Discovery, Emails, Evidence, Federal Judges, Federal Rules of Discovery, Federal Rules of Evidence, Forensic Evidence, Judges, Legal Forms, Legal Technology, Native Format

≈ Comments Off on Craig Ball’s Lawyers’ Guide to Forms of Production.

Tags

, , , , , , , , , , ,

A Guide to Forms of Production, by Craig Ball, Ball In Your Court Blog

http://ballinyourcourt.wordpress.com/2014/05/19/a-guide-to-forms-of-production/

Craig Ball’s Lawyers’ Guide to Forms of Production! Although Mr. Ball says there is much he wants to re-organize and rewrite, I can’t wait to dive in.  You will find the hyperlink to the Guide when you go to the web site. Thank you, Craig Ball! -CCE

Semiannually, I compile a primer on some key aspect of electronic discovery.  In the past, I’ve written on computer forensics, backup systems, metadata and databases. For 2014, I’ve completed the first draft of the Lawyers’ Guide to Forms of Production, intended to serve as a primer on making sensible and cost-effective specifications for production of electronically stored information.  It’s the culmination and re-purposing of much that I’ve written on forms heretofore, along with new material extolling the advantages of native and near-native forms.

Reviewing the latest draft, there is much I want to add and re-organize; accordingly, it will be a work-in-progress for months to come.  Consider it a “public comment” version.  The linked document includes exemplar verbiage for requests and model protocols for your adaption and adoption.  I plan to add more forms and examples. . . .