Exhibit Management: Where Evidence Meets Persuasion (Part 4 of 4)
By Molly Gulbrandson, ParaOne Legal Services
The Final Layer of Motion Prep
In Parts 2 and 3 of this series, we looked at how fact and legal cite checks build credibility and precision into the motion’s foundation.
Now, we move to the final layer: exhibits. Where those verified facts and authorities meet the tangible proof behind them, and the evidence supporting those words is presented clearly.
Exhibits aren’t just attachments. They’re the visual proof of your argument; the part of the motion that turns statements into support and credibility into persuasion.
Building the Foundation
Effective exhibit preparation is built on organization and clarity.
Paralegals are often tasked with pulling the correct documents, creating excerpts if applicable, identifying confidential or underseal exhibits, redacting, and pointing exhibits to a record or to a document, and ensuring that every exhibit:
Corresponds to a specific statement or citation,
Is labeled and described consistently, and
Appears in logical order for the reader’s flow.
A clean, consistent exhibit index may seem like a small detail, but it can guide preparation and is sometimes a required part of a filing, in which case, is the first impression the court has of your filing. Where required, this index will show care, clarity, and professionalism; all qualities that echo throughout the case.
Practical Tips
In Part 2, I shared some of my practical times for fact cite checking. Here’s how that same level of organization carries through to exhibit preparation:
1. Build an exhibit chart.
As I mentioned in Part 2, I build this exhibit chart while fact checking and reviewing exhibits. This is the most efficient way to manage both processes at once.
This chart serves two purposes: it guides exhibit preparation throughout the process, and when required, becomes the foundation for the final index attached to the brief.
I start with a working version that includes two columns:
Column 1: An auto-populated exhibit label (number or letter, depending on preference).
Column 2: A short description of the exhibit.
As I go through the brief, I add each exhibit to the chart in the order identified in the brief.
If a document is referenced multiple times, I include both the long cite and short cite for easy cross-checking (for example, 10/06/2025 Deposition of Jane Doe (“10/06/2025 Doe Depo”)).
For any documents that will be submitted as excerpts rather than full exhibits (such as deposition transcripts), I copy every citation in the brief into my exhibit chart. This makes it much easier to compile those excerpts into a single, complete exhibit later, without having to hunt through the brief page by page. If the brief is revised after I’ve completed the fact check, this step also allows me to quickly confirm that every referenced page is still included and that no new citations have been added.
When the motion is finalized, and if needed, I can convert this working chart into a cleaned-up version formatted as the exhibit index to be filed with the brief, adjusted for any judge-specific preferences.
2. Label exhibits last.
I don’t assign final exhibit letters or numbers until the brief itself is in final form. Because my chart auto-populates, I can quickly reorder exhibits if sections of the motion move around, no manual relabeling required.
In my saved files where I’ve stored the exhibits, I use placeholder names like “Ex. __ – [NAME]” until the final numbering is confirmed. I can then easily add the number or letter for the exhibits.
3. Gather and name exhibits intentionally.
As noted in number 1 above, I handle this step simultaneously with my fact check. If I’m verifying what an exhibit says, I save it right then. No reason to revisit it later.
If the citation points directly to the record, there’s no need to save a separate copy as the record speaks for itself.
Moving through the draft of the brief, I gather every referenced exhibit to ensure nothing is missed. Each file follows the same naming convention: Date – Document Title. If it’s an excerpt, I add [Excerpt] at the end.
I usually wait until the brief is finalized before pulling excerpts. Pages sometimes change as edits evolve, and it’s more efficient to compile excerpts once rather than adjusting them multiple times.
4. Identify confidential exhibits.
I flag any exhibit that has been previously filed under seal or that should be treated as confidential. From there, I identify the local rules governing how confidential materials must be handled in that jurisdiction and share that information with the attorney early on.
Depending on the court’s requirements, this may involve filing a motion to seal, preparing redacted versions, or using separate sealed attachments. Because procedures vary, providing that guidance well in advance of the filing deadline is essential. It avoids last-minute confusion and ensures compliance from the start.
A Note on Flexibility
Occasionally, an attorney is on a tight timeline and asks not to wait until the end to label exhibits, noting that if new ones are added later, they may end up out of order. It goes against every organized bone in my body, but efficiency sometimes wins.
Exhibit prep, like litigation itself, requires being both thorough and adaptable. Perfectly imperfect when the situation calls for it.
And that adaptability brings us to the final step in motion preparation: closing the loop between words and evidence.
Closing the Loop
Motion preparation begins with ideas and ends with evidence.
When exhibits are organized, verified, and presented with intention, they become the final proof that every statement in the motion stands on solid ground.
That’s the difference between a motion that reads well and one that persuades.
Series Wrap-Up
This concludes the 4-part series Motion Preparation from the Paralegal’s Chair.
From organization to cite checking to exhibit management, motion prep is one of the most collaborative and strategic pieces of litigation support.
And in that process, paralegals don’t just assist, they elevate the work itself.