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How to Automate Exhibit Numbering: A Straightforward Solution and Case Study

Updated: Jun 2, 2021

Any paralegal or junior associate knows the pain of having to number exhibits minutes before a motion is due, or to re-number tens of exhibits after the partner sends last-minute edits. They also know the fear of messing up while rushing to get the motion of file: what if you send the judge to your best evidence on page 5 of Exhibit 3, but the evidence is actually in Exhibit 13? Yikes!

Tedious and error-prone, this whole process was in dire need of automation and a technological glow-up. Native Microsoft Word functionality touted as an exhibit-numbering solution solves only half the problem, as it numbers only the first citation to an exhibit, and can easily lead to broken cross-references and are difficult to update. LitKit's Citations Tool simplifies exhibit and citation formatting in many ways, from automatically updating exhibit numbering to making sure the form of the citation (long, short, or id.) is correct, to simplifying exhibit formatting and consistency.

A full description and demo of the tool can be found on Prelimine's homepage, but today we want to focus on the simplest way of using it--for the technologically averse lawyers or those of us who work for/with them. Recognizing that some attorneys might want the benefit of automatic exhibit numbering while maintaining their usual drafting process, we developed LitKit with a built-in "lite" option that helps track and number factual exhibits only.

One of our users had to draft a 100+ exhibit pleading using LitKit's Citation Tool, but was concerned with the team's adoption of the new technology. So we suggested that she use the "lite" option--that way the user was able to still take advantage of LitKit's automated exhibit numbering and exhibit index functionality while continuing to draft the pleading the usual way.


To set up LitKit's Citations Tool for this process, open the Citations Tool panel, and the Exhibit Formatting view. There, remove all exhibit formatting boxes other than the exhibit number and de-select the "Use id. to represent repeated citations" box, and click "Update Formatting."

Then carry on with drafting your document as you usually would EXCEPT, instead of Ex. X, Ex. _, Ex. **, or whatever placeholder you usually use, add a new exhibit and insert the exhibit number using LitKit. The correct exhibit number will be inserted.

With over 100 exhibits and over 50-pages long, this pleading required additional efficiency. The user therefore also de-selected the "Update content automatically when new citation is added."

This way, inserting a new citation will be quicker as only a placeholder will be inserted instead of running through the document to ensure that the exhibit number is properly updated.


With this set-up, when local counsel sent five additional exhibits, no exhibit re-numbering and reshuffling was necessary. Our user just added the new exhibit citations and they were assigned the proper exhibit number automatically--all the other exhibit numbers were automatically updated upon the insertion of the new exhibit.

Similarly, when the partner decided to move down a paragraph, the exhibit numbers were automatically updated.

Once the motion was finalized, using LitKit, an exhibit index was easily produced, allowing the paralegal on the case to create and add coversheets to the documents and prepare the filing.

Even though the team was not yet on board with new technology and the number of exhibits was excessive, LitKit was able to save our user hours of time that was likely to be dropped from the bill and give her back years that would have been taken off her life from the stress of these last minute changes.

Want to see LitKit in action? Contact us at for a demo or download a free trial here.

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