The State of Exhibit Marking in 2026: Stickers, Stamps, and PDF Exhibits

Walk into almost any deposition in 2026 and you will find two traditions on the same table. One is the paper sticker: yellow or blue, a number written or printed on it, pressed onto the first page. The other is the PDF stamp: the same mark, placed by software on a file that will be shared on screen, emailed, and attached to the transcript. Neither has replaced the other. The more useful question is not which one wins. It is whether the mark, the number, and the exhibit log survive the trip from the room to the record.

This note covers what the rules require, what courts are doing with stickers and files this year, how numbering is being set in large cases, and what to check before a stamped PDF becomes the exhibit.

What the rules require, and what they leave alone

The federal rule is short. Under Federal Rule of Civil Procedure 30(f)(2)(A), documents and tangible things produced for inspection during a deposition “must, on a party’s request, be marked for identification and attached to the deposition.”¹ A person who wants to keep the originals may offer copies to be marked and used as originals, after all parties have a fair chance to compare them.¹ At the end of the deposition, Rule 30(b)(5)(C) has the officer state on the record any stipulations about custody of the transcript, the recording, and the exhibits.¹

Notice what the rule does not say. It does not name a sticker color, a stamp layout, a numbering scheme, or a file format. Those come from local practice, a judge’s procedures, a case order, or the parties’ stipulation.

The rules also keep a distinction the profession guards carefully: being marked is not the same as being received in evidence. Alaska’s court system states it plainly in Administrative Bulletin No. 9, revised effective August 3, 2026. “Marked for identification” means the exhibit “has received an exhibit sticker and exhibit number and has been listed on the exhibit list.” Offering it into evidence is a separate, later step, and admitting it is the court’s decision.² A stamp, paper or digital, records identity. It never decides anything else.

The paper sticker is current practice

Alaska’s bulletin is a useful snapshot because it was revised this year and it is specific. Exhibits must be marked with a court-provided sticker before they are referred to in court. Stickers are color coded: yellow for plaintiffs or petitioners, blue for defendants or respondents, red for grand jury and coroner proceedings, and green for miscellaneous parties. Each sticker carries the full case number and the exhibit number or letter, and it goes in the lower right corner of the first page “in a manner which will not interfere with the viewing of the exhibit.” Plaintiffs number from 1, defendants letter from A, and in cases with many parties and large volumes the court may assign each party a block of one thousand numbers.²

The U.S. District Court for the District of Rhode Island shows the same tradition with a digital option beside it. Its exhibits page requires attorneys to pre-mark all exhibits before trial or an evidentiary hearing, and says stickers “can be obtained from the Clerk’s Office or the electronic versions linked below can be used.”³ The same page lists accepted electronic formats (PDF for documents) and a file naming convention: exhibit number, case number, and description.³

That one page is the state of exhibit marking in 2026. The paper sticker and the electronic sticker are both accepted, and the court cares far more that the number is right and the file is findable than about which one you used.

Numbering is set by order, and orders differ

In a two-party case, numbering is usually a matter of habit and stipulation. In large and multidistrict cases, it is often written into a deposition protocol, and the protocols do not agree.

The Valsartan order goes further than most. It says that once an exhibit has been numbered, “it is intended that it shall retain that number throughout the case.”⁶ Where the same document was numbered differently at different depositions, the court reporter and the parties confer to confirm it. The court reporter for each deposition includes a list of the exhibits referenced in that transcript, and the reporter and the parties keep a joint list showing exhibit number, deponent, and date. The order is careful about who answers for it: the list “may be coordinated with the court reporter service for efficiency, but the parties remain responsible for the accuracy of the list.”⁶

Under orders like these, the reporter’s exhibit log stops being a page at the back of one transcript and becomes a running register for the case. That is real work, and it is exactly the kind of work where a duplicate number or a skipped block causes trouble months later at trial.

AOne block per deposition

BNo overlapping numbers

CKeeps its number later

DJoint list: number, deponent, date

To plan numbers across deponents and days, and print a matching exhibit log, use the free exhibit number planner.

Remote depositions made the PDF the everyday exhibit

Rule 30(b)(4) allows a deposition by remote means on stipulation or court order¹, and in a remote deposition the exhibit reaches the witness as a file. Recent orders describe how that file must behave. The Depo-Provera MDL deposition protocol in the Northern District of Florida, filed March 14, 2025, requires that full copies of exhibits be provided to the witness and counsel, made available through the remote deposition technology, file sharing, or other electronic means, and in hard copy on request. The platform must let the witness privately access any part of an exhibit and move through it, and let counsel display and annotate exhibits, add and remove them, and change their order. The order also says that a witness being given an electronic copy is not, by itself, a basis to object to the exhibit at trial.⁷

The profession worked out much of the practice early. In March 2020, Lynette Mueller, then chair of NCRA’s Technology Committee, wrote in the Journal of Court Reporting that in remote depositions “it is best to have the attorneys (not the court reporter) handle the marking of the exhibits”; described adding a digital exhibit sticker to PDFs in Acrobat; and advised that “there is no need to flatten the document during the deposition.” She also noted that “all exhibits marked during the proceeding are working copies.”⁸ Flattening, in other words, is a finishing step, not a live one.

Vendors have built that practice into their platforms. One agency’s exhibit platform, for example, describes applying “the exhibit sticker with a single click,” moving it or changing its transparency, and sharing the marked exhibit through a secure link.⁹ Before relying on any tool like this, ask the questions in the next section.

Flattened stamp or movable annotation

A PDF can carry a mark in two very different ways. It can be an annotation, which the PDF standard keeps apart from the page’s own content. The standard even names the type: a rubber stamp annotation “displays text or graphics intended to look as if they were stamped on the page with a rubber stamp.”¹⁰ Annotations can be hidden, and the standard offers a Locked flag that, when set, stops a user from deleting an annotation or changing its position and size.¹⁰ Or the mark can be flattened into the page content, where it displays and prints as part of the page.⁸ During preparation, a movable mark is useful. On the exhibit attached to a certified transcript, it is a liability: the next person to open the file can change what the exhibit says about itself.

APaper sticker, lower right

BPDF stamp, still movable

CLog: one number, one file

DFlattened into the page

Court e-filing guidance shows what a court system expects of a PDF it keeps. The District of Oregon’s CM/ECF manual tells filers to “print or flatten the fillable PDF before uploading it to CM/ECF so that the fields are removed,” and states that all PDF documents filed in CM/ECF must be text-searchable under its Local Rule 5-2(b).¹¹ That guidance covers court filings, not deposition exhibits, and requirements vary by court. It is still a fair benchmark for any exhibit that may later be filed or used at trial.

Before a stamped PDF becomes the exhibit, check these:

• The mark is part of the page. Open the final file in a second viewer and try to select or move the stamp. If it moves, it is not finished.
• The text is still searchable. Search for a word on a stamped page to confirm flattening did not turn the page into a picture.
• The mark does not cover content. Alaska’s rule about placement applies to pixels as well as paper. Check pages with content in the corner where the stamp lands.
• The original is kept. Keep the unmarked file the exhibit came from, so a dispute about content can be answered from the source.
• The log matches the files. Every number in the exhibit log has one file, every file has one number, and the description matches the document.
• The numbering follows the order. If a protocol assigns blocks or requires reuse of prior numbers, check the case’s register before you stamp, not after.

What has not changed

The paper sticker survives for good reasons. It is visible across a conference table, and a witness holding the document can see it. The digital stamp brings what paper cannot: identical copies for every participant, numbering that can be checked against a register, and a file that arrives with the transcript instead of in a box.

Underneath both is the same job. Someone marks the exhibit for identification, it is attached to the deposition, its custody is stated on the record, and an index ties each number to one document. Whoever places the mark, the exhibits travel with the transcript the reporter certifies, and the final exhibit index belongs to the reporter, not to the software that helped prepare it.

How DepoStack is approaching this

Exhibits by DepoStack is in Preview for Windows and Mac. It adds exhibit labels to PDFs and keeps numbering and the exhibit log together. You still need to open and check every saved PDF and its index before delivery. The final exhibit index remains the reporter’s responsibility. See the current features, limits, and setup instructions on the Exhibits by DepoStack page.