#8 Pretrial Agreements – Sequential Exhibit Numbering

08 Numbering ExhibitsExhibits Will Be Numbered Sequentially.

It becomes apparent that many litigators are not thinking about trial when they start numbering deposition exhibits.  It is a particularly annoying practice to number exhibits separately for each deposition.  When this is done, the same document can end up being Smith-1, Jones-4, and Johnson-14 once the parties get to trial.  Alternatively, the plaintiffs and defendants can continue the numbering from deposition to deposition but have a separate set of plaintiffs’ exhibits and defendants’ exhibits.  Plaintiffs-14 and defendants-14 then will be different documents.

Exhibits should be numbered at deposition with the ultimate goal in mind – trial.  Each exhibit should have one and only one number, which it will carry through trial.  This practice greatly reduces confusion over exhibit numbering.  It also allows the parties to more easily play at trial the deposition excerpts in which exhibit numbers are referenced.

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