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Exhibit bundling in litigation: order, labelling, portal size

By Clemens Jonathan Schmid and Jonas Maximilian Regul

Contested exhibit packs rarely fail on the law - often on numbering and file technique.

The court cites exhibit K7. Internally three folders exist with slightly different order. That is where the damage starts: not in the legal issue, but in bundle hygiene. Litigation exhibit packs must be citable, complete and technically filable - at the same time.

Partners expect substantive coherence; office and associates often carry the technical load. Without shared rules the same chaos returns before every deadline.

Order and labelling

Fix numbering before the bundle grows - and do not change it silently. A contents list at the front (even a simple list) must match file order. Replaced exhibits get a visible label (K7a / K7 new) instead of silent overwrite. If the other side has already cited, transparency about replacement is owed to your own team - and often to court and opponent.

Page numbers in the bundle (Bates or running) help at the hearing more than elegant filenames alone.

Technique before the portal

Size, orientation, readable scans, no locked passwords, OCR where search and citation matter. Portals often impose hard megabyte limits: compress deliberately after substantive approval, not before in a chaotic intermediate file. Then re-check critical pages (stamps, signatures, colour plans) at zoom.

LexLogik suits technical densification and the quality chain in the browser; exhibit logic and citability stay with the litigation team.

Team rules that survive deadlines

  • One person owns the binding exhibit list; changes run only through them.
  • Keep filing copy and working folder separate.
  • After replacement: update contents and pleading references in one pass.
  • Before upload: open page count, file size, first and last exhibit as a spot check.
  • Record what was filed (filename, size, time, channel).

When the bundle grows late

New exhibits close to a deadline belong at the end with a clear number - not inserted mid-pack if already cited. Tell the team immediately which numbers are new. A second look from someone who did not bundle catches swaps more often than another solo night.

Parallel packs and partial bundles

Sometimes the portal demands separate uploads while the firm keeps one master bundle. Document the mapping: which file equals which exhibit numbers. Without that bridge, two truths appear. The same applies to confidential exhibits for the court only: keep labelling and access separate, but do not “forget” the numbering in the overall schedule.

After filing, the binding send copy belongs unchanged in the matter - not only the working folder. If you amend weeks later, you need the same byte state the portal accepted.

Clean exhibit packs look invisible. Messy ones get cited at the hearing - against you. The last hour before a deadline belongs to the spot check, not to renumbering.

Portal size and split decisions

Decide who chooses a split when the portal reports a size limit: support by checklist, or the matter lead for disputed exhibits. Record split points in the page index so the pleading’s exhibit list stays true.

An exhibit bundle is portal-ready only when order, labelling and size limits align. The page index is support’s working tool - and partners’ insurance when the court asks questions.

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