One of the most important ways to organize all medical records, medical billing, lost wage claims, and exhibits in preparation for trial is the use of bates numbering or bates stamping documents. This practice assists law firms and uses identifying numbers and/or date-time marks on documents as they are scanned into the system.
Bates numbering has been a bedrock process for paralegals and law firm for many years. Originally, Bates numbers were affixed to documents using a handheld stamping machine created by the Bates Manufacturing Company. Now, Adobe and other applications can electronically affix the bates stamp and can track numbering for organizational purposes in the firm’s files.
Even for those cases that aren’t considered to be the largest cases in the firm, bates stamping (1) helps organize the case and (2) shows the defense and the court that they will have a prepared Plaintiff.
Use of Initials to Identify the Author or Source
Consider adding initials before the number to identify the witness, party or source of the exhibit. It is an efficient and quick way to remind the firm of the source of each piece of evidence.
Develop Cheat Sheets
Cheat sheets can be invaluable at a trial when handling thousands of documents or other pieces of evidence. List on a separate sheet of paper each of the issues that you will be addressing at the trial, each element needed to prove and each argument that you will make as part of his strategy.
Analyze your master index to determine which piece of evidence will be introduced to support the argument or to prove each element and write the exhibit bates stamp number on the appropriate cheat sheet. These cheat sheets should never replace your master index; however, at trial, you can quickly pull each bates stamp number as you move from point to point.
Produce your bates stamped documents on CD to the defense early and often so that the timely production of records, documents, and exhibits will never be a problem. This shows focus, organization, and preparation on the part of the Plaintiff, and it will help immensely when a trial has arrived, and you want to quickly refer to exhibits in the presence of judge and jury.
For these reasons, it is imperative to hire a veteran trial lawyer to prepare a case and organize the records even before it is filed.