Guide
Discovery productions with Bates numbering and certification
Updated 2026-09-10 · 3 min read
A defensible production is a batch you can rebuild: the items the defense has not received, contiguous Bates numbers assigned in one transaction, and an attorney certification against a manifest hash. Voided numbers stay burned. The software's job is the ledger and the hash, not the court filing.
Start from the delta
If you rebuild every production from a folder named 'to defense,' you will double-produce and miss revisions. The honest starting point is the set of items that have a disclose decision and no Bates number in a live batch, plus items whose content changed after they were produced. That set should be the same list a gap radar can show. Building from the delta is slower the first time and faster every time after, because the ledger remembers. Prosequi's productions tab is that ledger on the matter, with the same ACL as the rest of the file so a partner cannot see a batch they are not invited to see.
Bates in one transaction
Contiguous numbering fails when two people assign ranges in two tools. The commit should be a single transaction: these items, this range, this batch. If the commit fails, no numbers were spent. If an item is pulled, its number is voided and not reused. That is the only way a later re-verify can mean anything. Do not paste numbers from a spreadsheet into a PDF stamp overnight and call it a system of record. The stamp is an output. The ledger is the record.
Certification is a name on a hash
Certification here means the attorney's name, a timestamp, and a hash of the frozen manifest — not a filing, not a CM/ECF transmission, not a claim that the office has met every constitutional duty. A year later you should be able to re-hash the manifest and get the same value, or know that someone altered the batch. If your vendor cannot re-verify, you do not have a production system. You have a mail merge.
What it never does
It never files. It never decides Brady. It never silently unlimited-stores the vault. Storage is plan-capped with admin alerts. Related reading: disclosure gap tracking (the input), evidence chain of custody (how the file got its hash), and the Trust Center for isolation. Request a synthetic walkthrough from the contact form if you want to certify a batch on training data.
Re-verify later
A year later a defense letter will claim an item was not produced. You should be able to open the batch, see the Bates number, see the hash, and re-compute it. If the hash matches, you have a record. If it does not, you know the batch was altered and the audit chain should say by whom. Spreadsheet stamps cannot do that. Object storage without a manifest cannot do that. The production is not the PDF. The production is the committed row.
Who signs
The attorney whose name is on the certification owns the decision. The paralegal can build the batch. The software should not let a contribute-level partner certify. Court users remain read-only by default. If your ACL model cannot say that in one sentence, it is not ready for discovery. See Bring Your Detective for how partners get onto the matter without becoming certifiers. Keep a written office rule for who may click certify, and enforce it in the product rather than in a hallway. When a batch is voided, the numbers stay burned so a later letter cannot claim those stamps were reused. When storage hits the plan cap, the admin alert is the signal to quote more vault, not to dump files on a share. Productions and the vault are the same matter; splitting them is how items escape the delta.