A page number counts pages within a single document and restarts at 1 for every new file. A Bates number is a unique identifier stamped across an entire production that never repeats and never restarts, which is what allows a citation like SMITH-002419 to point to exactly one page in a case regardless of how many documents were produced. The two coexist because they answer different questions: a page number tells a reader where they are inside one exhibit, while a Bates number tells everyone in the matter which page is being discussed. Deposition transcripts, motions and expert reports cite the Bates identifier precisely because it survives refiling, reordering and reproduction. A third layer, the PDF viewer's own page label, is different again and is not changed by stamping a number onto the page, so a document can legitimately show a page number, a Bates identifier and a viewer label that all differ.
This guide explains legal Bates workflows. BatesFast applies the identifiers; it does not replace review, redaction, or production validation.
What's the Difference Between a Page Number and a Bates Number?
A page number is a property of a single document. Page 1 of a five-page memo is simply the first page of that memo; the same "page 1" also exists inside every other five-page memo in the case, because each document counts its own pages independently.
A Bates number is a property of the production as a whole. It is applied on top of the existing page number, usually after review is complete, and it counts continuously across every document in the set. Two documents can each have a "page 1," but only one page in the entire production can ever be SMITH-000001.
| Characteristic | Page number | Bates number |
|---|---|---|
| Scope | One document | Entire production |
| Restarts? | Yes, at the start of each document | No, continues without gaps |
| Set by | The document's original author | Litigation-support staff or stamping software |
| Typical format | 1, 2, 3… or i, ii, iii… | PREFIX-000001 |
| Used for | Reading order within the document | Locating and citing an exact page in the case |
How Does a Citation Survive Reproduction?
A citation is only useful if it still resolves after the document has been copied, scanned, emailed and refiled. Position-based references fail that test immediately, because reprinting or recombining changes which page sits where.
An identifier burned onto the page travels with the image rather than with the file, so a photocopy of a produced page still carries the reference that locates it. This is the property that makes the practice worth the effort of applying it.
It also survives the document leaving your control. Once a page is produced, opposing counsel, experts and the court each hold their own copies, and a reference that depends on your filing system or your PDF would be meaningless in any of them.
Citation Practice: How to Reference a Bates Number Correctly
Correct citation practice always uses the Bates number, never the document's own page number, because only the Bates number is guaranteed unique across the case. A brief that reads "See SMITH-002419" tells the reader exactly which page to pull, with no need to also identify which document or exhibit it belongs to.
When citing a span of consecutive pages, write the starting and ending numbers, either in full (SMITH-002419 through SMITH-002422) or abbreviated in a form the case has adopted (SMITH-002419-22). Whichever style is used, apply it consistently within a single brief or filing so the citations remain unambiguous to opposing counsel and the court.
It is worth noting that a page's own internal page number should never appear in a formal citation on its own, since "page 4" is meaningless without also naming which document it came from. The Bates number carries that context implicitly, which is precisely why litigation practice standardized on it as the single reference point for pinpoint citations.
What Are Viewer Page Labels, and Why Are They a Third Thing?
A PDF viewer maintains its own page labels, the values shown in the navigation control, and they are metadata rather than content. A document can display roman numerals for front matter and arabic numerals afterwards purely through those labels, with nothing printed on the page at all.
Stamping an identifier onto a page does not change them. The viewer still counts from one, so a page showing a produced identifier in its corner can simultaneously be page four in the navigation control and page seventeen of the original document.
The distinction matters when someone reads a page number over the phone. Agreeing whether the reference is the printed identifier, the number set in the document, or the position the viewer reports avoids a category of confusion that is otherwise very hard to unpick.
How Bates Numbers Relate to Exhibit Numbers
A third identifier often appears alongside a Bates number once litigation reaches a deposition or a hearing: the exhibit number, usually applied as a small colored sticker (Exhibit 14, Plaintiff's Exhibit C) marking a document's role in a specific proceeding. The exhibit number and the Bates number answer different questions and are not interchangeable.
The Bates number identifies the page inside the overall production and stays fixed no matter how many times the document is used afterward. The exhibit number identifies the document's role in one specific deposition or hearing and can change from proceeding to proceeding — the same page might be Exhibit 14 at one deposition and Exhibit C at trial. A well-prepared exhibit log cross-references both, so anyone can move from "Exhibit 14" back to the underlying "SMITH-002419" and confirm it is the same page cited elsewhere in the case.
A Worked Example
Consider a small production of two documents: a three-page email chain and a twelve-page contract, both collected from the same custodian. Before numbering, the email chain's pages are numbered 1 through 3 by whatever program generated it, and the contract's pages are numbered 1 through 12 by its own internal pagination, most likely centered at the bottom of each page.
When the production is stamped, the software or reviewer applies one continuous Bates sequence across both files: the email chain becomes SMITH-000001 through SMITH-000003, and the contract, produced immediately after it, becomes SMITH-000004 through SMITH-000015. Each page still shows its own original page number wherever the author placed it; the new Bates numbers sit in the bottom-right corner, added after the fact. A reader can now cite "SMITH-000009" and know, without asking any further question, that this is page 6 of the twelve-page contract, since that identifier can only ever refer to that one page.
BatesFast applies legal Bates identifiers with the custom prefix, zero padding and continuous numbering that carry across every file in the set.
Common questions
Do Bates numbers replace page numbers?
No, they serve different purposes and commonly appear on the same page together. The original page number stays wherever the author put it; the Bates number is added afterward, typically in the opposite corner, for production tracking.
What if a document already has page numbers printed on it?
That is the normal case and requires no special handling. The Bates stamp is simply placed in a clear area of the page, most often the bottom-right corner, so it does not overlap the document's own pagination or body text.
How do I cite a range of Bates-numbered pages?
A range is typically written with the shared prefix once and the full or abbreviated ending number, for example SMITH-002419 through SMITH-002422, or shortened to SMITH-002419-22 depending on the citation convention the case or court has adopted.
Are Bates numbers case sensitive?
The prefix is typically stamped in a fixed case, usually all uppercase, and should be cited exactly as stamped. Treating the prefix as case sensitive avoids any ambiguity when searching a production database or a review platform for an exact match.
Should I renumber documents received from the other side?
No. Documents produced by another party keep the Bates numbers they arrived with, because those identifiers are how everyone in the matter refers to them. Applying your own numbers on top creates two competing references for the same page and makes citations ambiguous.
Why do some productions use control numbers as well?
Review platforms often assign their own internal control number for tracking, and native files may receive a document-level control number where there is no page-level image to stamp. The Bates number remains the citable identifier; the control number is an internal handle.
Further reading: Bates numbering — Wikipedia.